For the modeled Rayleigh-fading setup, active RIS has higher energy efficiency than passive RIS only when the number of reflecting elements is below about 2^10; above that, passive RIS wins.
Asymptotic performance analysis of large-scale active IRS-aided wireless network,
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Energy Efficiency Analysis of Active RIS-enhanced Wireless Network under Power-Sum Constraint
For the modeled Rayleigh-fading setup, active RIS has higher energy efficiency than passive RIS only when the number of reflecting elements is below about 2^10; above that, passive RIS wins.