16 CFR Part 305: Proposed Amendments to the Appliance Labeling Rule That Would Change the Existing Labeling Requirements for Lamp Products (Light Bulbs) #545052-00016

Submission Number:
545052-00016
Commenter:
Bill Shepherd
Organization:
Gainesville Regional Utilities
State:
FL
Initiative Name:
16 CFR Part 305: Proposed Amendments to the Appliance Labeling Rule That Would Change the Existing Labeling Requirements for Lamp Products (Light Bulbs)

Gainesville Regional Utilities and the City of Gainesville, Florida support the proposed changes to the New Output-Based Labels for Light Bulbs. The only comment we would like to make has to do with the Lumen reporting. It is our opinion that the common consumer would not be able to relate with what is a bright vs. dim lumen level without having a scale similar to the one proposed for "Color Appearance" in Prototype Label 6. We suggest presenting the Lumen output in a similar scale so the consumer will see a relative brightness of the lamp they are looking to purchase. Using a simplified version of the Brightness scale in Figure 5 would probably meet this need. Answers to the additional questions, 1. What costs or burdens, and any other impacts, would the proposed requirements impose, and on whom? None 2. What regulatory alternative to the proposed requirements are available that would reduce the burdens and/or increase the benefits of the proposed requirements? None Thank you for the opportunity to comment. Sincerely, Bill Shepherd Energy & Business Services Manager Gainesville Regional Utilities