|Received:||4/16/2007 6:01:46 PM|
|Organization:||Rheem Manufacturing Company|
|Agency:||Federal Trade Commission|
|Rule:||Appliance Labeling Rule|
Comments:The Rheem Manufacturing Company, is a privately held company that manufactures a full line of residential and light commercial heating and cooling products, and residential and commercial water heaters that are marketed throughout North America. Rheem Manufacturing operates six manufacturing facilities, three of which are ISO: 9000 certified manufacturing facilities and located in the U.S. (Fort Smith, AR, Milledgeville, GA, and Montgomery, AL). We believe we have the broadest and most complete line of HVAC and water heating products in the industry. We are pleased to provide the following comments on the Federal Trade Commissions Appliance Labeling Rule. Rheem supports the Federal Trade Commission (Commission) proposed rule to eliminate EnergyGuide labeling requirements for heating and cooling equipment and, instead, reference the ARI and/or GAMA directories for performance information. As noted in the NOPR, heating and cooling products are generally not bought through comparison shopping and, therefore, EnergyGuide information will not affect consumers purchasing decisions. The ARI/GAMA electronic directories, however, are constantly updated with new information on energy performance and should be the source for ensuring that distributors, dealers, consumers and the general public have the most up-to-date information. Furthermore, we support the FTC’s intent to continue labeling water heaters along with separate criteria for the tank and tankless water heaters. Rheem opposes the proposed rule to replace the EnergyGuide label on air conditioners and furnaces with a permanent label that includes the model number and energy efficiency rating on the outside surface of the product. The proposal will not help consumers in their purchasing decisions and therefore is not an improvement over the current EnergyGuide label. Instead, Rheem proposes that the FTC label be eliminated on air conditioning and heating equipment and that only the fact sheet requirements as proposed be required. Rheem is in agreement with the FTC in maintaining the labeling of water heaters and to keep separate the EnergyGuide criteria for tank and tankless water heaters. We also support the proposed change in label scheme to a cost range instead of energy range using a (1) one year or alternate label with cost per (5) years. The FTC seeks comment on several issues: Whether there should be a mandatory disclosure indicating that conditions restricting airflow will immediately and perhaps significantly reduce energy efficiency below the levels stated on the label. Rheem does not oppose a mandatory disclosure. Restricted airflow affects SEER and HSPF, but does not affect AFUE. The fact sheet-related information provided would be a simplified version of that currently required by the Rule. Rheem supports a simplified version of the fact sheet. The Commission is not proposing to require information about operating costs or range information for these products. Rheem agrees with the Commission that determination of operating costs is complicated by regional climate and energy costs. The availability of industry directories provides the most accurate and up-to-date source of comparative model data for consumers. As an alternative to the proposed elimination of cost information for these products, the Rule could require manufacturers to provide a single estimated operating cost for their models based on national average figures for energy costs (e.g. heating/cooling loads based on Region IV as delineated in 10 CFR Part 430, Subpt. B, Appendix M). Rheem opposes the proposed requirement that manufacturer’s provide a single estimated operating cost. It is likely that this information would be used to calculate an inaccurate payback as consumers weigh the advantages of higher efficient equipment. Energy costs have fluctuated widely in the recent past. The GAMA and ARI industry directories provide a means for HVAC professionals and homeowners to compute realistic and up-to-date operating cost estimates.