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energy labeling operating cost
In its NPRM, the Commission proposed requiring estimated annual operating cost as the primary energy disclosure on the front package panel and on the rear (or side) panel Lighting Facts label. Specifically, the NPRM required that the front panel display estimated energy cost in an annual dollar figure (e.g., $7.49 per year).
The proposed Lighting Facts label would provide this same cost information, along with the rate and usage assumptions used to calculate the disclosure (i.e., three hours per day and 11.4 cents per kWh), and a notice that Your costs will depend on your rates and use.
The Commission provided three reasons for choosing annual energy cost as the primary energy disclosure.
First, estimated annual energy cost provides a simple way to convey a bulbs energy usage.
Second, in the label study, energy-cost information performed better than a five-star rating system and a lumens per watt disclosure at communicating energy usage. Finally, unlike efficiency ratings (e.g., lumens per watt or a five-star system), an energy-cost disclosure should help consumers avoid buying bulbs that are brighter than necessary, and therefore, save energy.
Comments: Several commenters supported the Commissions proposal to describe energy use via an operatingcost disclosure. For example, CEE stated that its members have extensive experience with communicating energy information and supported the operating-cost disclosure.
The Energy Efficiency Advocates also strongly supported the cost disclosure and concurred with the rate and usage assumptions used to calculate the estimate. GE found the cost disclosure and rate and usage assumptions acceptable, but, along with NEMA, suggested that the FTC shorten the sentence accompanying the disclosure to read Will vary by your rates and use.
NEMA, however, raised concerns about the operating-cost disclosure. It questioned the disclosures usefulness and long-term accuracy because electricity rates and usage vary by region and consumer and change over time.
In NEMAs view, unless shoppers make a conscious effort to review the explanatory rate assumption language appearing on the Lighting Facts label, they will view the disclosed cost as their actual operating cost. In addition, NEMA stated that tracking the cost of power for accuracy and competitive fairness would be costly and laborious, which the Commission understands to mean that manufacturers frequently would have to adjust the rates used for the label. Thus, NEMA argued, the Commission should not require an operating-cost disclosure.
Discussion: The final amendments maintain the operating-cost disclosure.
First, the operating-cost disclosure is an effective comparative tool that will allow consumers to easily compare competing products across bulb types.
Second, similar to the Commissions EnergyGuide label for appliances, the cost is disclosed as an Estimated Energy Cost, clarifying that it is not their actual operating cost. Consumers seeking additional information about the rate assumption used to calculate this estimate can find it on the Lighting Facts label.
Finally, the Commission finds that these benefits outweigh the disadvantages, including the need to adjust the rate assumption periodically over time.
The final amendments include a minor change to the electricity cost rate used for the label. Instead of the proposed 11.4 cents per kWh, the amendments require the use of 11 cents per kWh. This simple, rounded cost figure should be easier for consumers to understand.
Finally, consistent with NEMA and GEs suggestion, the Commission has shortened the explanatory cost information on the label.Instead of Your cost will depend on your rates and use, the final amendments require the language Cost depends on rates and use. This revised language will provide the same message while using less space on the package.
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