|Received:||7/24/2006 4:11:26 PM|
|Organization:||Seattle Public Utilities|
|Agency:||Federal Trade Commission|
|Rule:||Appliance Labeling Research|
Comments:Now that the US EPA Administrator has formally launched the WaterSense Program (federal water efficiency product label similar to Energy Star), the FTC should examine whether to include FTC labels on other water using products, particularly appliance products that use large amounts of both water and energy. In many areas of the Country, the cost of water and sewer is significant relative to the cost of energy, and thus the consumer should be provided with all utility information in order to make an informed decision based on operating costs. Looking at labels that include Energy Star but not WaterSense departs from the intent of the 2005 Federal Energy Policy Act, since that Act specifically includes plumbing products. Water use information should be considered as part of the label study. In addition, the water label should factor in the embedded energy in pumping and treating water (it has been estimated that water and sewer treatment, heating, and pumping uses 10% of all US Energy).