<HTML> <HEAD> <title>WebForm1</title> <meta name="GENERATOR" content="Microsoft Visual Studio .NET 7.1"> <meta name="CODE_LANGUAGE" content="Visual Basic .NET 7.1"> <meta name="vs_defaultClientScript" content="JavaScript"> <meta name="vs_targetSchema" content="http://schemas.microsoft.com/intellisense/ie5"> <META http-equiv=Content-Type content='text/html; charset=UTF-8'> </HEAD> <body > <TABLE id="Table1" cellSpacing="1" cellPadding="1" width="100%" border="0"> <TR> <TD><b>Comment Number:</b></TD> <TD>522852-00112</TD> </TR> <TR> <TD><b>Received Date:</b></TD> <TD>5/2/2006 12:38:18 PM</TD> </TR> <TR> <TD><b>Organization:</b></TD> <TD></TD> </TR> <TR> <TD><b>Commenter:</b></TD> <TD>Harper, Nancy</TD> </TR> <TR> <TD><b>State:</b></TD> <TD>MI</TD> </TR> <TR> <TD><b>Agency:</b></TD> <TD>Federal Trade Commission</TD> </TR> <TR> <TD><b>Rule:</b></TD> <TD>Proposed Information Requests to Manufacturers of Alcoholic Beverages</TD> </TR> <TR> <TD><b>Docket ID:</b></TD> <TD>PO64505</TD> </TR> <TR> <td colspan='2'>No Attachments</td> </TR> </TABLE> <hr/> <b>Comments:</b><br/><br/> Chairman Deborah Platt Majoras Federal Trade Commission - Office of the Secretary Room H-135 (Annex J), 600 Pennsylvania Avenue, N.W. Washington, DC 20580 Dear Chairman Majoras, Exposure to alcohol advertising is an important factor in alcohol consumption among young people, according to a study funded by the National Institute of Alcohol Abuse and Alcoholism. "Market advertising expenditures per capita were related to drinking levels and to growth in drinking over time," Snyder's group reports in the Archives of Pediatrics and Adolescent Medicine for January. For each additional dollar per capita spent on advertising, individuals consumed 3 percent more alcoholic beverages per month. Young people were more likely to drink more over time in areas with more alcohol advertising. "All these findings point to alcohol advertising as an important arena for interventions seeking to reduce underage drinking and its tragic consequences," Dr. David H. Jernigan, from Georgetown University in Washington DC, comments in a related editorial. SOURCE: Archives of Pediatrics and Adolescent Medicine January 2006. ...for underage drinkers, exposure to one more ad than the average for youth was correlated with a 1 percent increase in drinking, and that an additional dollar spent per capita on alcohol advertising in a local market was correlated with a 3 percent increase in underage alcohol consumption as well. Approximately 20 percent of all alcoholic drinks are consumed by individuals below age 21, Dr. Leslie B. Snyder, from the University of Connecticut in Storrs, and colleagues note in their report. When they do drink alcohol, underage drinkers tend to imbibe more heavily than adults and are involved in twice as many fatal car crashes while driving. As a citizen and taxpayer, I support the FTC's intention to undertake a new report reviewing alcohol industry advertising practices and compliance with voluntary advertising codes. I urge the FTC to issue a stronger and more detailed report than those released in 1999 and 2003. The federal government does not do nearly enough to monitor alcohol industry marketing. Self-regulation by the industry is clearly insufficient, given the well-documented, repeated failures of alcohol manufacturers to adhere to voluntary guidelines. Underage drinking results in death and serious injury to thousands of young people every year. In flagrant violation of its own standards, the alcohol industry routinely conducts slick marketing campaigns, designed for obvious youth appeal, in media outlets and sports venues with a large underage audience. Because of the massive public health consequences of underage drinking and the alcohol industry's utter failure to police itself, I urge the FTC to strengthen its reporting process in the following ways: 1. Report on alcohol industry advertising practices once a year, as the FTC now does with tobacco advertising. Although the previous ad hoc reports have been useful, an annual report on alcohol advertising compliance would greatly increase accountability of alcohol marketers. 2. Collect much more detailed data, including product brands popular with youth, target-audience ethnicity, sports-related marketing, and magazine and television advertising where youth audience rates exceed 15 percent. 3. Collect information on "responsibility" and "prevention" advertising by alcoholic-beverage companies, as well as advertising touting charitable activities of alcoholic-beverage producers or promoting the "health benefits" of alcoholic beverages. 4. Compare voluntary advertising compliance among various segments of the alcoholic-beverage industry, and make recommendations for both strengthening and enforcing advertising standards. Thank you for considering my views. I hope to see the FTC play a continued and increasingly active role in protecting our youth from irresponsible and dangerous alcohol marketing. </body> </HTML>