| Comment Number: | 519870-00015 |
| Received: | 01/13/2006 02:12:07 PM |
| Organization: | California Urban Water Conservation Council |
| Commenter: | John Koeller |
| State: | CA |
| Agency: | Federal Trade Commission |
| Rule: | Energy Policy and Conservation Act - Appliance Labeling Rule |
| Docket ID: | To Be Added |
| Attachment: | 519870-00015.pdf Download Adobe Reader |
Comments:
Under Item IV.F of the Notice in the Federal Register, Vol. 70, No. 211, page 66311, suggestions are sought for changes in labeling requirements for PLUMBING PRODUCTS. This comment addresses same........... CHANGE SOUGHT: Add an "HET" designation as either a permanent or removable label on all toilet fixtures offered for sale in the marketplace and that meet the HET qualifications............... BACKGROUND: A new product in the U.S. marketplace is the HIGH EFFICIENCY TOILET (HET). As noted in the attached document, the HET functions at a maximum flush volume of 20 percent less than the current national standard of 1.6 gallons per flush (equal to a maximum of 1.28 gallons per flush). HETs were developed to help address the critical need for advancing energy and water efficiency in the U.S. Since 1998, 77 different HET models have been introduced into the marketplace by 16 different manufacturers. By January 2006, 15 different HET financial incentive programs have been introduced by water utilities in California directed at consumers and specifiers, encouraging those parties to purchase HETs rather than conventional 1.6 gallon fixtures. Similar programs are being developed in other parts of the U.S. It is critical that consumers be informed as to which fixtures are the most efficient. This information should be provided by a product label.