<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>522852-00967</TD> </TR> <TR> <TD><b>Received Date:</b></TD> <TD>5/3/2006 6:32:11 PM</TD> </TR> <TR> <TD><b>Organization:</b></TD> <TD></TD> </TR> <TR> <TD><b>Commenter:</b></TD> <TD>Didier, Larry</TD> </TR> <TR> <TD><b>State:</b></TD> <TD>IL</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, I am pleased to hear that the FTC is taking a long, hard look at the advertising and marketing practicies of the alcohol industry. Evidence is clear that the industry has targeted underage minors in many of their advertising campaigns and marketing efforts over the years. The industry's recent "minimal" support of efforts to dissuade youth from drinking their products are really a case of "FAR too little, and way TOO late." At the same time they spend billions encouraging people to use and even abuse their products, they spend a few million saying that they don't really want young adults' business. Most of their efforts is directed at parents, putting the responsibility on them to counter the industry's huge marketing efforts. Therefore, I want to urge the FTC to issue a report on this issue that is stronger and more detailed than the ones released in 1999 and 2003. The federal government does not do nearly enough to monitor alcohol industry marketing. This industry seems more interested in their "bottom-line" than in protecting young people. Their efforts at self-regulation have clearly been insufficient, especially given the well-documented and repeated failures of alcohol manufacturers to adhere to their own voluntary guidelines. Tens of thousands of young people are assaulted, injured and even killed each year as a result of their own alcohol abuse and that of those around them. In flagrant violation of its own standards, the alcohol industry continues to conduct slick marketing campaigns, designed to appeal to youth, 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 watn to suggest that the FTC staff carefully examine the recommendations of the National Academy of Sciences (NAS) report on underage drinking. Additionally, they should strengthen their own reporting process in the following ways: 1. Conduct and issue annual reports 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 industry-sponsored "responsibility" and "prevention" advertising, as well as advertising touting the charitable activities of alcoholic-beverage producers or promoting the "health benefits" of alcoholic beverages. 4. Make measured comparisons on the voluntary advertising compliance among various segments of the alcoholic-beverage industry, and recommend strategies for both strengthening and enforcing advertising standards. 5. Have FTC staff members carefully assess the recommendations of some of our best public health and governmental agencies, and incorporate those recommendations whenever feasible (like "most" of the time.) Groups such as the Center for Science in the Public Interest (CSPI), the Center on Alcohol Marketing to Youth (CAMY), the National Institute on Alcoholism and Alcohol Abuse of NIH (NIAAA), and the aforementioned NAS report, Reducing Underage Drinking: A Collective Responsibility, issued in 2004 - all of them have done extensive study of this issue, free from political pressure to "couch" their findings, and could provide great assitance to the FTC in its efforts. Thank you for listening to and considering my views on this all important issue. I am hopeful that the FTC will play a continued and increasingly active role in protecting our youth from irresponsible and dangerous alcohol marketing. </body> </HTML>