Submission Number: 00010
Received: 7/25/2011 4:53:36 PM
Commenter: Todd Campbell
Organization: Clean Energy Fuels
Agency: Federal Trade Commission
Initiative: 16 CFR Part 309: Advance Notice of Proposed Rulemaking Concerning the Labeling Requirements for Alternative Fuels and Alternative Fueled Vehicles, FTC File No. R311002
Attachments: No Attachments
1. Any label used to describe the benefits of using an alternative fuel should demonstrate "fuel displacement" of foreign oil over fuel economy. In this way, alternative fuels and higher efficiency vehicles would receive equal credit and be valued appropriately by a consumer.
2. The GHG performance reflected on the label for any vehicle present a full life cycle assessment of such emissions and that both fossil-based and biological-based natural gas values should be shown for natural gas vehicles to demonstrate the full range of GHG reduction benefits.