Much like everything else which has any large entity involvement, it seems the Energy Star is run by a bunch of clueless fools instead of people who don't have their heads up their own buttocks.
Every TV should be broken into a size class and within that size class a specific goal for Energy Star rating should be set with a progressively more difficult level for that rating. We've seen plasmas thinned up over the years, and I would imagine less power going to them with more efficient design.
The problem is that they are also making cruddier and cruddier product now. Instead of product you buy which draws more power, but lasts 20+ years, you buy something which has minimal quality and undersized power supplies which fails within just a few years, and this movement is being continued with exactly this type of foolish initiatives.
If they were smart, the focus wouldn't be on Energy Star, but on quality of merchandise above all else. Something which could last for decades and trumps that which needs constant repair or replacement.
Really though, even a elementary school kid would understand that you don't put out the same expectations across the board. You don't give a calculus test to the second graders, you give them second grade level tests, and you continue that on up through all the grades. Yet, they put down a power requirement for all displays like they are all the same.
So, when I buy that 19" TV which sucks over 100 watts they will be so happy that I have an Energy Star sticker on it, but the 60"+ display which draws 112 watts will be frowned upon.
Stupid is a stupid does I suppose.
I do fully expect California to give this policy a great big hug of stupid.