I applaud the Commission's efforts to provide more information to consumers about the light bulbs we purchase. I have two comments: First, I do feel that lumens per watt should be a required value for the proposed label. Once efforts to educate the public regarding the meaning and use of lumens are successful, this value will become much more useful, as it is the truest measure of efficiency. I understand the concern that it may lead some to select a brighter bulb than necessary, but it will also lead an educated consumer to make the wisest and most efficient choice. While the energy cost value is useful for comparison purposes, it doesn't tell the whole story. Secondly, I think the idea of creating a "watt-equivalence scale" is a wonderful idea. I would like to suggest that it be used as a point-of-sale reference item, similar to the laminated reference charts that are on display in stores. Thank you.
16 CFR Part 305: Proposed Amendments to the Appliance Labeling Rule That Would Change the Existing Labeling Requirements for Lamp Products (Light Bulbs) #545052-00007
16 CFR Part 305: Proposed Amendments to the Appliance Labeling Rule That Would Change the Existing Labeling Requirements for Lamp Products (Light Bulbs)