| Comment Number: | 519870-00019 |
| Received: | 01/13/2006 06:06:46 PM |
| Organization: | Collaborative Labeling and Appliance Standards Program |
| Commenter: | Stephen Wiel |
| State: | DC |
| Agency: | Federal Trade Commission |
| Rule: | Energy Policy and Conservation Act - Appliance Labeling Rule |
| Docket ID: | To Be Added |
| Attachment: | 519870-00019.pdf Download Adobe Reader |
Comments:
Dear Mr. Newsome: CLASP has fully reviewed the comments submitted by the American Council for an Energy-Efficient Economy in response to this ANOPR. We strongly support all of ACEEE's recommendations regarding improvements to the EnergyGuide labeling program, particularly adoption of a categorical style label. CLASP's work in Argentina, Bahrain, Brazil, Colombia, China, the Dominican Republic, Ecuador, Egypt, Ghana, India, Mexico, Nepal, Poland, South Africa, Sri Lanka, Thailand, Tunisia, and Uruguay has led us to conclude that categorical labels are the most understandable and therefore the most effective. We believe this to be true when comparison labels (such as EnergyGuide) are applied alone or in conjunction with endorsement labels (such as Energy Star) as is the case in the U.S. Support for this conclusion may be found in the CLASP standards and labeling guidebook, which is already in the record as footnote 12 in the Federal Register notice inviting these comments (Wiel, Stephen, and McMahon, James E., ‘‘Energy-Efficiency Labels and Standards: A Guidebook for Appliances, Equipment, and Lighting, 2nd Edition,’’ Collaborative Labeling and Appliance Standards Program [CLASP], 2005) and in the attached paper presented by our Executive Director, Christine Egan, at the 2005 European Council for an Energy Efficient Economy (ECEEE) Summer Study. CLASP's mission and organizational structure allows it to provide these comments with no other agenda than maximizing the social benefit of the EnergyGuide label to all stakeholders. CLASP is an outgrowth of an initiative begun in 1996 at Lawrence Berkeley National Laboratory to help developing countries pursue energy-efficient standards and labeling policies. Shortly afterward, the US Agency for International Development embraced the effort and funded Lawrence Berkeley National Laboratory, the Alliance to Save Energy, and the International Institute for Energy Conservation to pursue this initiative. For the five years 2000 through 2004, CLASP, operating as a partnership of its three founders with increasing collaboration with additional partners and with $9.4 million from 12 different donors, provided assistance for the development and implementation of 21 new minimum energy performance standards, energy efficiency endorsement labels, and energy information labels. In 2005, CLASP completed its originally intended transformation into an independent non-profit corporation open to all willing and able participants. It now operates as a global organization, governed by eleven directors from eight countries in four continents, and is the only organization in the world devoted solely to addressing energy efficiency standards and labels. We are pleased to be able to provide these comments, stand ready to answer any further questions that you have, and would be happy to help in any other way that you would like. With warm regards, Stephen Wiel, President of the Board, Collaborative Labeling and Appliance Standards Program (CLASP), 13 January 2006