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pdfSupporting Statement for a Paperwork Reduction Act
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Federal Trade Commission Study on Labeling for Lamp (Light Bulb) Products
(OMB Control No. 3084-NEW)
Section 324 of the Energy Policy and Conservation Act of 1975 (“EPCA”), 42 U.S.C.
§§ 6291- 6309, requires the Federal Trade Commission (“FTC” or “Commission”) to prescribe
labeling rules for the disclosure of estimated annual energy cost or alternative energy
consumption information for a variety of products covered by the statute, including home
appliances (e.g., refrigerators, dishwashers, air conditioners, and furnaces), lighting, and
plumbing products. The Commission’s Appliance Labeling Rule (“Rule”), 16 CFR 305,
implements these requirements by directing manufacturers to disclose energy information about
major household appliances, lighting, and plumbing products. This information enables
consumers to compare the energy use or efficiency and operating costs of competing models.
A.
JUSTIFICATION
1. & 2. Necessity for Information Collection and How the Data Will Be Used
For most consumer lamp (light bulb) products, the FTC’s current rules require disclosure
of energy use (in watts), light output (in lumens), and life (in hours) on packaging.1 In the
Energy Independence and Security Act of 2007 (“EISA”), Congress directed the FTC to consider
the effectiveness of these lamp labeling requirements2 and alternative labeling disclosures. In
particular, the Act calls on the Commission to consider whether alternative labeling approaches
will help consumers better understand new high-efficiency lamp products and help them choose
lamps that meet their needs. The FTC must complete the rulemaking by June 2010.
As a first step toward fulfilling this mandate, the Commission published an Advance
Notice of Proposed Rulemaking on July 18, 2008 (73 FR 40988) that provided background about
current FTC labeling rules for light bulbs, the recent Congressional mandate, the purpose of the
FTC labeling requirements, and various labeling considerations. In the Notice and at a public
roundtable held on September 15, 2008, the Commission sought comment concerning the
effectiveness of current labeling requirements, as well as whether labeling alternatives would
help consumers in their purchasing decisions. Specifically, the Commission asked for comment
on whether lamp packages should disclose characteristics such as lamp brightness, energy use,
1
2
See 16 CFR Part 305.
Pub. L. 110-140, 121 Stat. 1492. See Section 321(b) of the EISA, amending § 324(a) of
the EPCA. The current requirements do not impose a uniform disclosure format. Instead, the
labeling requirements provide manufacturers flexibility regarding the size, font, and style in which
the information is presented. See 16 CFR Part 305.
energy cost, color temperature, and lamp life. FTC staff, through its contractor, also asked a
consumer focus group about various attributes of light bulb labels.3
The Commission also requested that commenters provide consumer research data related
to lighting disclosures. No commenters, however, submitted or identified any recent,
comprehensive consumer research. The Commission, therefore, is planning to conduct a
consumer research study to aid in determining what revisions, if any, it should make to existing
labeling requirements. The Commission announced this consumer research effort in a December
1, 2008 notice (73 FR 72800). The Commission received no comments in response to that
notice. The Commission will use the consumer research results, along with other information
gathered through the roundtable and written comments, to develop proposed changes to current
lamp labeling requirements. This Notice provides additional details about the proposed research,
an estimate of the burden hours associated with the collection of information for that activity,
and an invitation for comment on these issues.
The FTC proposes to collect information from consumers to gather data on the
effectiveness of current lamp labels and alternative label designs. The proposed study will
involve a sample of approximately 5,600 respondents who are at least 18 years old and recent or
likely future light bulb purchasers.4 The FTC and its contractor will administer questions to the
respondents online over the Internet.5 The study will employ standard consumer survey
methodologies, including copy testing and choice experiments, to explore how different label
designs impact consumer decision-making regarding the purchase of light bulb products. The
study will allow the FTC to explore the performance of various label formats, the labeling
preferences of the respondents, and their understanding of relevant lighting concepts.
The study will use a basic label design that includes certain information disclosures on
the front of the package, as well as more comprehensive label disclosures on the rear or side
panel (see sample labels at the end of this Notice). The test labels on the front of the package
3
A report on the seven-person focus group, prepared by FTC’s contractor, Synovate, Inc.,
is available at http://www.ftc.gov/os/comments/lightbulbs/index.shtm.
4
The FTC expects to study a stratified sample of the adult United States population that is
broadly representative of consumer group attributes (e.g., geographic location, housing
characteristics, gender, age, education, and race/ethnicity) based on the most recent Census
Bureau’s Current Population Survey and the Department of Energy’s Residential Energy
Consumption Survey. The contractor will identify respondents using any relevant, preexisting data
in its Internet panel database and any necessary additional screener questions. The screener
questions will help to ensure that the demographic composition of the sample reasonably matches
that of the target population. Allowing for non-responses, up to approximately 15,000 respondents
will answer screener questions. This number of respondents should enable the FTC to obtain its
target sample size of 5,600 individuals.
5
The FTC also will pretest the study on approximately 25 individuals to ensure that all
questions are understood. The pretest participants will be drawn from the target population.
2
will include four (or fewer) disclosures: light output (or “brightness”), energy (e.g., efficiency,
cost), life, and color temperature. The study will explore different approaches for making these
disclosures. For instance, we will test respondents’ perception of energy use disclosures
displayed in the form of annual energy (operating) cost, luminous efficacy (lumens/watt), and a
five-star rating system. Table 1 below contains the list of variations to be tested. Given the
small size of light bulb packaging and the associated space constraints, the information that can
be included on the front of the package is limited. Therefore, we are not testing complex scales
or similar graphical formats that would not fit easily on the front display panel.
The test label design will also include a “Lighting Facts” label on the rear or side panel.
This label is similar in appearance to the “Nutrition Facts” label required by the Food and Drug
Administration. The label drafted for this study includes a variety of information disclosures
such as brightness, life, energy use in watts, voltage, luminous efficacy, and energy cost.6
The study results will allow the FTC to compare the effectiveness of various label
approaches. In analyzing the results, the FTC will conduct a statistical comparison of
respondent answers across different test label components. If there are differences in accuracy
rates for particular label approaches, the direction and statistical significance of these differences
will aid the FTC in assessing whether one type of label design is more comprehensible than
alternative designs. The FTC will use the study results in conjunction with other information
generated during this rulemaking proceeding to develop and propose changes to existing labeling
requirements, if such changes are warranted.
3.
Information Technology
Consistent with the aims of the Government Paperwork Elimination Act, 44 U.S.C.
§ 3504 note, the proposed study will use the Internet for data collection. The Internet was selected
as the means to collect data, in part, to minimize burden on respondents and to collect data in a
cost-efficient manner. For example, people who choose to participate in the study will be able to
view the product labels and questionnaire, as well as submit their responses via computer at a time
and location of their choosing.
4.
Efforts to Identify Duplication/Availability of Similar Information
FTC staff’s efforts to identify duplicate sources of information included a review of studies,
data, news articles, and information found through contacts with industry trade associations,
consumer groups, governmental agencies, and academic researchers. We have not identified any
duplicate studies. We have reviewed a study related to color temperature conducted by the
6
A “Lighting Facts” label also could contain additional information such as voluntary
disclosures provided by the manufacturer (e.g., minimum starting temperature), and other
information mandated by state or federal requirements (e.g., hazardous content disclosures or
information required by the Federal Communications Commission). However, because such
voluntary disclosures and state or federally mandated disclosures will vary by manufacturer and
lamp technology, we are not including any such disclosures on the test labels.
3
Lighting Research Center, Rensselaer Polytechnic Institute (Leslie, R., and Rea, M., “A System for
Communicating Color: What Do Consumers Think”).7 That study was limited in its focus.
5.
Efforts to Minimize Small Organization Burden
Not applicable. The questions are being asked only of individual consumers.
6.
Consequences to Federal Program and Policy Activities/Obstacles to Reducing
Burden
If this information is not collected, the FTC will lack the benefit of recent and
comprehensive consumer research to further address important issues related to the development of
energy labels for consumer products. This information is important for completing the
congressionally mandated rulemaking.
The study has been designed to minimize burden on respondents, using cost-effective
techniques, without sacrificing the statistical value of the information to be collected. For example,
as discussed in Section A.3 of this document, respondents will be permitted to complete the
questionnaire at a time most convenient to them.
7.
Circumstances Requiring Collection Inconsistent with Guidelines
The collection of information in the proposed study is consistent with all applicable
guidelines contained in 5 C.F.R. § 1320.5(d)(2).
8.
Public Comments/Consultation Outside the Agency
In developing the proposed study, FTC staff sought informal input from staff at the Food
and Drug Administration (which has conducted similar studies in the past), the Department of
Energy, and the National Institute of Standards and Technology. Moreover, as required by 5 CFR
1320.8(d), the FTC published a Notice seeking public comment on the proposed collection of
information. See 73 FR 72800 (December 1, 2008). No comments were received in response to
that Notice. Pursuant to the OMB regulations (5 CFR 1320) that implement the PRA, the FTC is
providing a second opportunity for public comment while seeking OMB approval for the proposed
consumer research.
Additionally, the FTC held a public roundtable on September 15, 2008, to discuss multiple
issues regarding the rulemaking proceeding for the Rule. See 73 FR 40988 (July 18, 2008). As
part of that workshop, the FTC invited and received written comments that provided suggestions
7
See
http://www.lrc.rpi.edu/programs/lightingTransformation/colorCommunication/pdf/whatDoCons
umersThink.pdf. The study was conducted with funding from the Department of Energy and
Environmental Protection Agency.
4
for various changes to existing disclosures.8
9.
Payments or Gifts to Respondents
FTC staff expects that the contractor will provide participants a customary and usual
incentive for their participation in the experiment. More specifically, the contractor will give
qualified respondents (i.e., those who complete the questionnaire) payments or gifts valuing
approximately one dollar and the contractor will give other respondents (i.e., those who participate
in the study, but do not complete the questionnaire) payments or gifts valuing less.
10. & 11.
Assurances of Confidentiality/Matters of a Sensitive Nature
Responses to the study questionnaire provided to the FTC will not include any information
about the identity of individual respondents. In addition, the contractor will be required to have
sufficient procedures in place to prevent unauthorized access to respondent information, such as
storing personally identifying information on separate servers from questionnaire response data;
using firewalls to secure its servers; and maintaining audit records of log-ins, file accesses and
other security incidents. Finally, this data collection would not include sensitive questions. A draft
of the questionnaire accompanies this submission.
12.
Estimated Annual Hours Burden
The Commission estimates that the cumulative total burden hours for the study will be
approximately 2,971 hours. This total estimate is derived as follows. First, the FTC plans to
conduct a pretest of approximately 25 persons that will take approximately 30 minutes on average
per person, resulting in a total of approximately 13 burden hours (25 respondents x 30 minutes).
Second, once the pretest is complete, the FTC and its contractor will ask screener questions of
approximately 15,000 respondents in order to obtain the FTC’s target sample size of 5,600
individuals. The FTC estimates that it will take respondents one minute to respond to the screener
questions. Thus, the total burden related to the screener questions will be approximately 250 hours
(15,000 respondents x 1 minute). Finally, those respondents that pass the screener questions will
answer the entire questionnaire. Using a conservative estimate of 6,500 individuals,9 the FTC
further estimates that participating in the study will require an additional 2,708 hours as a whole
(6,500 respondents x 25 minutes). Finally, the cost per respondent should be negligible.
Participation is voluntary and will not require start-up, capital, or labor expenditures by
respondents.
8
See http://www.ftc.gov/os/comments/lightbulbs/index.shtm.
9
Although the target sample is 5,600 individuals, the procedures used by the contractor
may result in collection of information from a slightly higher number of individuals.
5
13.
Estimated Annual Cost Burden
The cost per respondent should be negligible. Participation is voluntary, and will not
require any labor expenditures by respondents. There are no capital, start-up, operation,
maintenance, or other similar costs to the respondents.
14.
Estimate of Cost to Federal Government
The total cost to the Federal Government for the information collection will be
approximately $150,000. This estimate includes the costs paid to the contractor to develop an
online data collection procedure, draw the sample, collect the data, create a database of the results,
perform simple data analyses, and prepare a methodological report. This cost also includes FTC
staff time to design the study, manage the study, analyze the data, and draft a report. The cost of
FTC staff time is necessarily an estimate because several factors in this calculation may vary,
including the number of staff involved and the actual amount of time required. Clerical and other
support services and costs of conducting the study are included in this estimate.
15.
Program Changes or Adjustments
This is a new data collection. Thus, FTC staff requests a program change increase of 2,971
hours.
16.
Plans for Tabulation and Publication
FTC staff intends to use the results of the study to help assess whether current FTC labeling
requirements should be changed and, if they should, to guide recommendations for such changes.
The collection of the information would begin after the completion of the OMB review process.
The projected duration of the information collection is approximately eight weeks. The estimated
date for the completion of the report is Spring of 2009. The underlying rulemaking must be
completed by June 2010.
17.
Display of Expiration Date for OMB Approval
Not applicable.
18.
Exceptions to Certification
Not applicable.
B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
1.
Description of Sampling Methodology
The study will help FTC staff understand how recent and likely future light bulb purchasers
comprehend information on existing and alternative labels and the likely usefulness of that
information in making purchase decisions. The study will use a nationwide Internet panel to obtain
6
a sample of recent and likely future light bulb purchasers who broadly reflect the diversity of the
American population of such purchasers. The FTC will work with its contractor, Synovate, Inc.,
which has substantial experience assessing consumer communications using Internet protocols and
alternative protocols. This expertise should be helpful in designing the research, administering the
study, and drawing appropriate conclusions based on the results. By using random assignment
across treatments, FTC staff believes the research will provide useful information on the effects of
alternative label designs in a cost-effective manner and help guide the FTC in its efforts to examine
the effectiveness of its energy labeling regulations.
After considering the costs and benefits of various data collection methods, FTC staff
determined that an Internet panel with nationwide coverage is the most efficient way to collect data
to meet the research objectives within a feasible budget. The study will use procedures recognized
in the marketing research industry as appropriate for consumer research via the Internet. For
example, in order to ensure that the respondents broadly reflect the diversity of the American
population of recent or likely future light bulb purchasers, the FTC will consult with its contractor
regarding methods developed to minimize potential differences between an Internet panel study
and a study based on a probability sample, and with the advice of the contractor develop quotas or
employ other appropriate techniques. Moreover, the results of the research will be appropriately
qualified.
The sample for the study will be drawn from Synovate’s Internet panel, which has more
than 1 million members throughout the nation derived through a variety of methods. Panel
members typically receive about one invitation per month to participate in research projects. As
discussed above, in consultation with its contractor, FTC staff has determined that a screening
sample of up to 15,000 respondents will be needed to ensure 5,600 completed responses. The
sampling procedure will utilize the contractor’s Internet panel as efficiently as possible. FTC staff
will work with the contractor to identify demographic characteristics of light bulb purchasers. If
the contractor has prior data on screening criteria, such as age, gender, education, race/ethnicity,
homeowner status or purchase behavior, then potential respondents will be screened initially based
on this prior information. If such data are not available, staff will develop a screener, in
consultation with the contractor, to collect needed screening data.
Synovate has used a variety of techniques, including demographic weighting, propensity
scoring, and quota sampling to obtain accurate projections of national sentiment based on samples
drawn from its Internet panel. Accordingly, FTC staff will work with Synovate to ensure that the
sample is as representative of the nation as possible. Additionally, quotas may be developed, in
consultation with the contractor, to ensure as much as possible that the sample reflects the target
population. Although quota sampling will ensure that the respondents share characteristics similar
to the target population, and although the panel will include nationwide coverage, FTC staff does
not expect this Internet sampling procedure to yield a national probability sample. As such, FTC
staff does not intend to generate nationally representative results or precise estimates of population
parameters from this study. However, an attempt will be made to match the study’s sample to
known demographic characteristics of the target population of recent or likely light bulb
purchasers. The matching will be used to produce samples with a reasonable degree of diversity
and realism for key demographic characteristics.
7
The study will rely primarily on a between-subjects experimental design. Different
subjects will review different label treatments, including a control (current label) design. The
design will promote internal validity through random assignment to treatment conditions (label
designs). Random assignment should ensure similar populations across treatments, and that
differences in outcome measures between the groups reflect differences in label executions.
Respondents will answer objective questions about how well they understand information on
energy labels. Differences in consumer comprehension, measured by the accuracy of answers to
these objective questions, will be used to distinguish between label executions.
Standard statistical techniques, such as t-tests and chi-square tests, will be used to assess
potential differences in label executions. Although respondents will view one type of label for the
comparative comprehension tests, they will view labels for several products. The order of the
exposure to the labels for these two products will be rotated to counterbalance any possible order
effects. Although the primary analysis is based on a between-subjects design, respondents will
also be asked questions to determine which types of label information are most useful to them.
These data will be used to gauge which labels respondents find most useful. In addition, the design
may include a few follow-up questions at the end of the study based on exposure to other label
executions.
The sample size will consist of 5,600 consumers. This sample size was determined based
on a number of considerations, including the funds available for the study and the cost of different
sample size configurations, the number of label designs to be tested, and a power analysis. We
plan to have a sample size of 5,600 and will use 15 to 20 label execution for a total of
approximately 280-373 respondents per cell. A table summarizing the power analysis appears
below. In this table, p1 is the true proportion in population 1 (treatment group 1), p2 is the true
proportion in population 2 (treatment group 2), and alpha equals .05.
Table 3
Power Analysis for n1=n2=300, alpha=.05
p1
2.
p2
Power for
two-sided test
Power for
one-sided test
.65
.75
.73
.83
.70
.80
.78
.86
.75
.85
.84
.91
.80
.90
.91
.95
Description of the Information Collection Procedures
As discussed in section A above, the FTC has selected Synovate, Inc. a consumer research
firm, to recruit 5,600 individuals 18 years of age or older for the study. The FTC’s questionnaire
will include questions to understand the importance of the light bulb disclosures in consumer
8
purchase decisions and to determine if alternative label formats are more effective than the current
label. The questionnaires will consist primarily of closed-ended questions and include no more
than four open-ended questions.
The procedure for administering the questionnaire will be determined in consultation with
the contractor. It is expected that the contractor will develop an online program that will allow
respondents to view appropriate questions and materials based on their answers to prior questions.
In this way, an Internet methodology can be an improvement over mail questionnaires, where
respondents can preview questions and materials that are best asked in a controlled sequence.
The contractor will provide the FTC with raw data, as well as tabulated data, simple
graphical representations of the data, and simple significance test results. For example, it is
expected that the contractor will provide a graphical depiction of the percentage of respondents
who answer individual questions correctly under each labeling scenario and present results of
appropriate tests to determine if the differences are statistically significant.
As discussed in more detail below, the study will assign respondents into groups (i.e.,
cells), each of which will be assigned a different label design (i.e., treatment). The study will use
approximately six to twelve hypothetical test light bulbs, each with different performance
characteristics such as brightness, energy use, life, and color temperature. While each cell will
answer the questionnaire while reviewing disclosures for all hypothetical bulbs, the label treatment
will vary. The underlying questions for every respondent, however, will remain the same
regardless of which label treatment they view.
a.
Label Variables and Respondent Cells
The study will arrange respondents into 15 to 20 cells of approximately 300 respondents
each. Respondents in each cell will view one of 15 to 20 randomly-assigned treatments. For
example, one group will answer the questionnaire while viewing labels displaying the current
disclosure format, while another group will view labels with an alternative format.
Examples of the variables we will use to create the treatments appear in Table 1 below.
The planned treatments appear in Table 2. The variables include:
Color Temperature: The study will explore three principal ways of communicating color
temperature on the front package panel. One approach involves the use of standard terms to
describe color temperature such as “soft white” and “daylight.” The terms used in the study are
consistent with those in existing industry consensus standards and also previous ENERGY STAR
efforts.10 The second approach will include a label that provides information on color temperature
10
The color temperature descriptors used in the study are based on ANSI C78.376-2001
and draft ENERGY STAR Program Requirements for CFLs (Fourth Draft, Feb. 27, 2007)
(http://www.energystar.gov/ia/partners/prod_development/revisions/downloads/cfls/Criteria_CFLs
_Version4.0_draft4.pdf). The Consortium for Energy Efficiency also suggested such a system in
their comments. See http://www.ftc.gov/os/comments/lightbulbs/536795-00011.pdf. The
9
through six color-coded boxes, similar to a system considered in previous consumer research.11
The third approach will include a basic “Cool-Warm” scale as illustrated in Example Label C at the
end of this Notice. In addition to these three approaches on the front package panel, the “Lighting
Facts” label, on the back panel will include information about color temperature (e.g., 2700 K).
Sample labels appear as a supplementary document attachment to this instant submission.
Five-Star Efficiency Rating: The study will include some label designs that display a fivestar rating system for energy efficiency.12 In assigning ratings to the test models, the study uses the
rating system proposed by the Natural Resources Defense Council (NRDC).13
Yearly Energy Cost Information: The front package panel for some treatments will include
a yearly energy cost estimate based on a 2008 national average residential electricity cost of 10.8
cents/kWh and a usage rate of 3 hours per day.14
Watt-Equivalent Information: Several treatments will include information on the rear-panel
“Lighting Facts” label that provides the brightness (in lumens) of typical incandescent bulbs at
various wattages. This wattage-equivalent numbers are consistent with information provided by
the ENERGY STAR program.15
descriptors are as follows: 2700K (“Soft White”), 3000K (“Warm White”), 3500K (“White”),
4100K (“Cool White”), 5000K (“Natural”) and 6500K (“Daylight”).
11
See supra note 7.
12
In response to the 2008 ANPR, several commenters urged the FTC to consider a 5-star
rating system. See Natural Resources Defense Council comments
(http://www.ftc.gov/os/comments/lightbulbs/536795-00003.pdf ); American Council for an
Energy-Efficient Economy comments
(http://www.ftc.gov/os/comments/lightbulbs/536795-00012.pdf); and Joint Comments from Pacific
Gas and Electric Company, Southern California Edison, Sempra Energy Utilities, and Ecos
Consulting comments (http://www.ftc.gov/os/comments/lightbulbs/536795-00010.pdf).
13
See NRDC comments (http://www.ftc.gov/os/comments/lightbulbs/536795-00003.pdf).
In particular, we have consulted NRDC’s proposed “Curved Efficacy Boundaries” system as
illustrated in Appendix 1 of its comments. This rating system relies on luminous efficacy
(lumens/watt) weighted by lumens to create five efficiency categories for lamps. For example,
under this system, a typical incandescent (60-watts, 800 lumens) receives 1 star; a typical compact
fluorescent (CFL) bulb (13 watts, 800 lumens) receives 4 stars; and a typical LED (light-emitting
diode) bulb (7 watts, 800 lumens) receives 5 stars.
14
See 73 FR 11406 (March 3, 2008) (DOE national average energy cost figures for 2008).
Similarly, yearly bulb life information in the study will be based on a usage rate of 3 hours per day.
15
See ENERGY STAR information at http://www.energystar.gov/index.cfm?c=cfls.pr_cfl
(e.g., 800 lumens=60-watt incadenscent; 1110 lumens=75-watt incandescent). The disclosures of
such “watt-equivalence” (i.e., the light output expressed by reference to the energy use of standard
10
TABLE 1 - Examples of Label Variables
Location/
Descriptor
Variable
Variable
Variable
Variable
Front PanelLight Output
Light Output in
lumens
Brightness in
lumens
Front Panel Energy
Annual energy
costs
Energy efficiency in
lumens/watt
Energy efficiency
based on 5-star
rating
Energy in watts
Front PanelLife
Life in years
Life in hours
Front PanelColor Temperature
Word descriptor
(e.g., “soft
white”“daylight”)
Six colored-coded
boxes
Cool-Warm Scale
Rear Panel
“Lighting Facts”
label with watt
equivalent
information
“Lighting Facts”
label without watt
equivalent
information
No information on
rear panel
TABLE 2 - Draft Treatments
Label
Treatment
Front Light
Output
Front Energy
Front Life
Front Color
Temperat
ure
Back Lighting Facts
Other
1 (current)
Light Output
- Lumens
Watts
Hours
—
no lighting
facts
front explanatory
statement req by
current rule
2 (current)
Light Ouput Lumens
Watts
Hours
—
lighting facts
w/o watt equiv.
chart, with
color word
descriptor
front explanatory
statement req by
current rule
incandescent bulbs). is currently standard practice on CFL packages as manufacturers seek to help
consumers understand the light output of CFLs in the context of an incandescent bulb’s energy use.
Due to space constraints, the study will not test such information on the front panel. We anticipate,
however, that, regardless of any final FTC labeling requirements, manufacturers of CFL’s will
continue to provide information about watt-equivalence on their packaging as long as such
information is useful to consumers.
11
3 (current)
Light Ouput Lumens
Watts
Hours
—
lighting facts
with watt
equiv. chart,
with color scale
4
BrightnessLumens
Energy Cost
Years
Word
Descriptor
lighting facts
w/o watt equiv.
chart
5
Light Output
- Lumens
Energy Cost
Years
Color
Boxes
lighting facts
w/o watt equiv.
chart
6
BrightnessLumens
Energy Cost
Years
Color
Scale
lighting facts
w/o watt equiv.
chart
7
BrightnessLumens
5 Star Rating
Years
Word
Descriptor
lighting facts
w/o watt equiv.
chart, with stars
8
BrightnessLumens
5 Star Rating
Years
Color
Scale
lighting facts
w/o watt equiv.
chart, with stars
9
BrightnessLumens
Lumens/watt
Years
Word
Descriptor
lighting facts
w/o watt equiv.
chart
10
BrightnessLumens
Lumens/watt
Years
Color
Scale
lighting facts
w/o watt equiv.
chart
11
BrightnessLumens
Lumens/watt
Years
Color
Boxes
lighting facts
w/o watt equiv.
chart
12
BrightnessLumens
Energy Cost
Years
Color
Scale
“temperature” not
“appearrance”
lighting facts
w/o watt equiv.
chart
13
BrightnessLumens
5-Star Rating
Years
Color
Scale
lighting facts
with watt
equiv. chart,
with stars
14
BrightnessLumens
5-Star Rating
+
Energy Cost
Years
Color
Scale
lighting facts
w/o watt equiv.
chart, with stars
12
front explanatory
statement req by
current rule
lighting facts
w/o watt
equiv. chart,
with color
scale, with both
appearance and
temperature
descriptors
15
16
BrightnessLumens
c.
Energy Cost
Years
Color
Scale
*Note that
“lighting facts”
will appear as the
“front” in this
treatment. The
rear label will not
have any bulb
attributes.
no lighting
facts
Test Lamp Models
The study will employ six to twelve different hypothetical lamp models, each with
different brightness, energy use, life, and color temperature characteristics. Several of these
hypothetical models will be marked as ENERGY STAR products where the hypothetical criteria
meet the ENERGY STAR criteria.16 The various characteristics of several hypothetical models
appear in Table 3. Because we are considering a labeling approach that will convey uniform
information to consumers regardless of the bulb type, the hypothetical labels will not identify the
technology of the enclosed lamp (e.g., incandescent, compact fluorescent, or solid-state).
However, the hypothetical characteristics (e.g., lumens, energy use, and life) of the test models
will be consistent with the characteristics of available bulb technologies.
TABLE 3 - Examples of Test Models
Model
Lumens
Watts
Life in
hours
Life in
years
Yearly
Energy
Cost
5 Star
Energy
Rating
ENERGY
STAR
Lumens/
Watt
Color
Temp
(in K)
Color
Temp
(name)
A
820
60
1500
1.4
$7.10
1
No
14
2700
Soft
White
B
1690
100
750
0.7
$11.83
2
No
17
2700
Soft
White
C
825
13
6000
5.5
$1.54
4
Yes
63
6500
Daylight
D
870
13
6000
5.5
$1.54
4
Yes
67
2700
Soft
White
E
870
13
6000
5.5
$1.54
4
Yes
67
4100
Cool
White
F
1199
20
10000
9.1
$2.37
4
No
60
6500
Daylight
16
For the purposes of the study, it will be assumed that high efficiency bulbs consistent
with LED performance qualify for ENERGY STAR even though the ENERGY STAR program has
not finalized criteria for LED bulbs at this time.
13
G
1500
23
10000
9.1
$2.72
4
Yes
65
3500
White
H
1750
26
6000
5.5
$3.07
4
Yes
67
2700
Soft
White
I
870
7
25000
22.8
$0.83
5
Yes
124
2700
Soft
White
J
870
14
25000
22.8
$1.66
4
Yes
62
2700
Soft
White
K
800
40
3000
2.7
$4.73
3
No
20
3000
Warm
White
All respondents will answer a series of questions about the characteristics of the products
described in the labels and their preferences pertaining to those products. The questionnaire also
will seek information about respondents’ understanding of different lighting concepts such as
lumens (i.e., light output) and color temperature (i.e., the color characteristics of a light source).
Finally, the study will seek to gauge whether respondents have preferences regarding how certain
types of information are communicated.17
3.
Methods to Maximize Response Rates/Reliability of Sample Data
This study would use an existing Internet panel to draw a sample. The panel includes
people who have expressed interest in sharing their opinions via the Internet and do so regularly.
Seventy-five percent of those who receive the questionnaire are expected to qualify for the study
and twenty-five percent of those who receive an invitation to participate are expected to agree to
complete the questionnaire. To help ensure that the participation rate is as high as possible, FTC
staff and/or the FTC’s contractor will:
•
Design an experimental protocol, in consultation with the contractor, that minimizes burden
(short in length, clearly written, and with appealing graphics);
•
Test the draft protocol with a pretest to ensure that the protocol does minimize burden and
refine the protocol as appropriate;
•
Administer the experiment to individuals who have expressed interest in participating in
Internet studies; email reminders to respondents who do not complete the protocol soon
after the original invitation to participate is sent; and
•
Provide contact information on where to get help for respondents who may have questions
as they complete the study.
4.
Testing of Procedures or Methods Undertaken
Staff will pretest the questionnaire in the online format by sampling approximately 25
17
The study also will contain questions related to respondents’ experiences with current
light bulb labels.
14
respondents to ensure that all questions are easily understood and that the online procedure is
sufficient to generate reliable data. This pretest is part of the collection of information for which
staff seeks OMB approval.
5.
Individuals Consulted on Statistical Aspect of the Study
The study design has been reviewed internally by Manoj Hastak, a faculty member in the
Business School at American University. Dr. Hastak has served as a consultant on experimental
and survey studies for the FTC on numerous occasions. The contractor, Synovate, Inc, is
experienced in conducting statistically rigorous internet-based studies.
15
| File Type | application/pdf |
| File Title | H:\Paperwork Reduction Act Clearances\Lamp Study Supptg Stmt 4-27-09_mtd.wpd |
| Author | rgold |
| File Modified | 2009-04-27 |
| File Created | 2009-04-27 |