2012-07-10 Response to published NOPR.

Comments on External Power Supply standards: 1. Plantronics currently makes a range of products that incorporate external power supplies. Most of these comply with the Energy Star and California Energy Commission rating of Class V. Given the proposed energy efficiency requirements for the DOE, only one of our current models would meet the new proposed energy efficiency level. This is particularly true of the 0.1W standby level. To source, release, and incorporate new power supplies that meet this efficiency standard requires a long lead time. Some of the tasks that are necessary: a. Source new power supply designs from our EPS suppliers b. Qualify these designs, not just to the DOE requirements, but for all international markets. This requires submittal to dozens of countries that regulate EPS locally. c. The EPS would also need to be re-qualified at the finished product level, since all of these EPS must be paired with our products and evaluated for safety, EMC, and local regulations internationally. All prior product level reports would need to be updated to include the new EPS. d. The old power supply inventory would need to be depleted and the new model cut in. 2. The actions above normally would require a minimum of 18 to 24 months in order to avoid scrapping old EPS, and to allow adequate time for compliance approvals work to be done and local certifications to be in place. 3. Plantronics therefore requests that the new DOE energy efficiency requirements have a minimum of 18 months from passage to effectivity in order to avoid excess burden to manufacturers and suppliers. 24 months would be preferred. Comments on Battery Charger standards: 1. Plantronics is already well positioned to meet the California Energy Commission battery charger energy efficiency standards. Our reading of the DOE standards so far shows that these parallel the CEC rules very closely, which we consider a very good sign. However, one major item requires some discussion and clar