<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>522852-00544</TD> </TR> <TR> <TD><b>Received Date:</b></TD> <TD>5/2/2006 5:49:51 PM</TD> </TR> <TR> <TD><b>Organization:</b></TD> <TD>Marin Institute</TD> </TR> <TR> <TD><b>Commenter:</b></TD> <TD>Greene, Charles</TD> </TR> <TR> <TD><b>State:</b></TD> <TD>CA</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/> Federal Trade Commission Office of the Secretary Room H-135 (Annex J) 600 Pennsylvania Avenue, N.W. Washington, DC 20580 Filed Electronically to AlcoholReport@ftc.gov <mailto:AlcoholReport@ftc.gov> RE: "Alcohol Reports: Paperwork Comment, FTC File No. P064505 Dear Chairman Majoras: The Marin Institute joined the Center for Science in the Public Interest and several other groups in a joint letter concerning the Federal Trade Commission's (FTC's) request to alcoholic-beverage producers for information pertinent to the preparation of the third report on alcoholic-beverage industry advertising practices. I would like to take this opportunity to add two additional suggestions for data collection. In addition to the detailed list of data elements recommended in the joint letter, the FTC should also collect information on alcoholic-beverage producer's and wholesaler's sponsorship of community events and non-profit organizations. Although often presented as philanthropic activities, sponsorship agreements with alcoholic beverage producers and wholesalers typically include provisions for the prominent display of brand logos on signage, programs, brochures and other materials. To the extent these branded images reach any broad audience, they are promotions for the producers and brands identified and should therefore be considered in any comprehensive review of alcoholic-beverage advertising practices. While not currently measured in any systematic manner, alcoholic beverage makers' investment in this type of promotion appears to be growing relative to more traditional advertising. The FTC should also monitor and measure alcoholic beverage producers' use of emerging electronic media. In addition to the Web and email, alcohol producers have been among the first to exploit new media such as text messaging, mobile TV and pod casting to promote beer, wine and distilled spirits. Alcohol promotions employing cutting edge electronic media are likely to reach a disproportionately young audience because users of such new media are younger than the general population. For the same reason, parents are not exposed to the alcohol ads that their underage children may see or hear on phones, ipods or computer screens because they do not consume the same media as the younger generation. Finally, the FTC should monitor and report on alcoholic-beverage advertising on an annual basis. While the past ad hoc reports have been informative and instructive, regular and systematic data collection and publication of reports would provide more useful information about trends and an opportunity to improve industry practices by increasing accountability. Thank you for your attention to these recommendations. We look forward to a comprehensive report that will provide the basis for good policy and better practice. Sincerely, Charles Greene Executive Director Marin Institute 24 Belvedere Street San Rafael, CA 94901 415-456-5692 http://www.MarinInstitute.org </body> </HTML>