16 CFR Part 305; Energy Labeling Rule; Project No. R611004 #00011

Submission Number:
Mark Krebs
Initiative Name:
16 CFR Part 305; Energy Labeling Rule; Project No. R611004
Supplementary Notice of Proposed Rulemaking on Energy Labeling Rule Regulatory Review 16CFR Part 305 Project No. R611004 Submitted electronically via https://ftcpublic.commentworks.com/ftc/energyguidereview/ Reference: https://ftcpublic.commentworks.com/FTC/InitiativeDocFiles/591/FTC_FRDOC_... Comments of Laclede Gas: Page 8362 of the February 6, 2013 Federal Register provides a nebulous rationale for the purpose of the FTC's "yellow sticker" program as shown by the following excerpt: The Commission's Energy Labeling Rule (''Rule'') (16 CFR Part 305), issued pursuant to the Energy Policy and Conservation Act (EPCA),1 requires energy labeling for major household appliances and other consumer products to help consumers compare competing models.2 Laclede considers the above definition to be deficient as a means of providing appropriate consumer education for compare competing models. To begin, "yellow stickers" have moved away from showing average utility costs as a method of comparative information. Furthermore, the "yellow sticker" program has never been useful for comparing gas to electric operating costs. As proposed on page 34653 of the June 18, 2014 Federal Register, the future "yellow sticker" only shows misleading site-based efficiency within the same fuel sources (e.g. gas AFUE). Meaningful operating cost comparisons between gas appliances and electric appliance should be also be provided to consumers. Consumer education could also be improved by providing environmental impact information (e.g., "carbon footprints"). Consumer information could be further improved by including full fuel-cycle efficiency data. Another questionable enhancement is the reference to productinfo.energy.gov/. This database is also segregated and misleading in in that it only allows for comparisons between the same fuel sources using site-based performance indicators. And now, the FTC is promoting ENERGY STAR information that indicates there is a non-existent regional component that consumers should somehow evaluate. This ENERGY STAR inclusion is especially egregious as it is tantamount to a denial of the American Public Gas Association (APGA) settlement which led to the withdrawal of the Department of Energy's 2011 Direct Final Rule for regional furnace efficiencies. In short, the FTC appears to be retreating from better educating consumers.