|Received:||7/24/2006 8:07:22 PM|
|Agency:||Federal Trade Commission|
|Rule:||Appliance Labeling Research|
Comments:I commend the FTC for its general research design to develop better understanding of consumer comprehension of the Energy Guide label and alternate label designs, as outlined in the June 23, 2006 Federal Register notice. It is difficult to offer specific comments on the adequacy of the research design without the actual survey instrument intended for use. As a result, I offer only the following general comments: 1) FTC proposes including "a refrigerator condition that combines all full-size refrigerators into one category (i.e., eliminates separate ranges of comparability for configurations such as side-by-side doors and bottom-mounted freezers." This quotation is confusing. Does FTC plan to eliminate all size distinctions among refrigerators, or all configuration distinctions within a given size, or both? The two are neither mutually exclusive nor integrated. In comments I provided at the May 3 public workshop, I suggested that eliminating configuration distinctions within a particular size range might be necessary to reduce consumer confusion when comparing across configuration categories. For example, a bottom-mount refrigerator of a given size class may rank poorly in energy consumption relative to other bottom-mount models, yet still be less consumptive than a side-by-side model of the same size class that ranks very well relative to other side-by-side models. This leads to consumer confusion about the meaning of the comparative scale in relation to absolute energy consumption. This confusion is reduced if all refrigerators of a particular size category are compared on the same comparison scale. However, putting all refrigerators, no matter size or configuration, into the same comparison is likely to also cause confusion. In this case, the consumer is likely to perceive an "apples to oranges" comparison between small and large capacity models. Ultimately, my understanding of the literature to date on consumer comprehension of relative comparisons across all size/type categories suggests that FTC would have difficulty interpreting the results of a survey that attempted to quantify comprehension of the Energy Guide label in a "one category for all full-size refrigerators" condition. What would it mean if consumer comprehension went down? It might mean that consumers have a hard time gleaning information about consumption across such a wide range of refrigerator configuration options. It might also mean that consumers find such a comparison invalid and implicitly reject it in their calculations. Absent good qualitative data about consumer beliefs and values with regard to such comparison, FTC would be unable to give meaning to the quantitative results. There is qualitative data that suggests that consumers make comparisons among different refrigerator configurations in a similar size range and that they are confused by the current lack of label information across these configurations. FTC could use that data to interpret survey respondent results to a label that provided comparison data within a specific size range. Going beyond that comparison to include all configurations AND all sizes would be bad research design. 2) I believe the interpretation FTC provided of CEE's comment with regard to "lifecycle costs" is in error. FTC could consider providing information about the total energy cost of a labeled product over its anticipated product life instead of or in addition to its annual operating cost. This would simply be annual operating cost times anticipated product life in years. DOE standards procedures include information about anticipated product life, so FTC could provide this information in compliance with 42 USC 6294. However, I believe prior research (specifically ACEEE's focus group research) has indicated that consumers react negatively to information about total operating cost. For that reason, I believe FTC should not pursue that option further. Thank you for the opportunity to comment.