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Not all the SSDs in that comparison were done with the same setup. Also, idle is all that really matters.
http://www.hardware.fr/articles/860-24/consommation-efficacite-energetique.html
Why would idle be the only one that matters? Aren't the active figures important for laptop users?
If you have a fast drive, it will obviously complete I/O tasks quicker (some might be familiar with the term "race to idle") and hence spend less time writing/reading and more time idling. In terms of laptop battery life, idle power consumption is the most important aspect, although it does depend on one's workload