Load points of 10, 20, 50, and 100% are among the few technical points the draft establishes. The draft has so far declared a power factor only for the 100% load, at which the power factor will be 0.9. Although the EPA considers this power factor reasonable, the agency is reviewing whether the level will prove more challenging at lower loading points and will determine over the next few months whether the 10, 20, and 50% loads will need separate power-factor requirements.

The EPA is following its standard "tier" stepping process and will first introduce a Tier 1 set of Energy Star power efficiencies for servers and later increase requirements. The agency plans to work with industry groups over the next several months to test server supplies and create a real-world data set to develop consistent test procedures and efficiency levels.