|Received:||1/11/2008 5:59:18 PM|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims; Carbon Offsets and Renewable Energy Certificates|
Comments:The claim 'fuel efficient' is being mis-used. Manufacturers have twisted their advertisements to state that any car is fuel efficient at any mile per gallon rating. Many TV commercials have been saying their SUV's get 20 mpg or their cars get 30 mpg and are thus 'fuel efficient'. Consider that Hybrid technology, 40 or 50 mpg around town is what is really fuel efficient. By allowing just any vehicle manufacturer to say any of their cars is fuel efficient is not proper. I propose that only the models with the highest mpg rating(s) can be called 'fuel efficient'. This should be raised over time. The standard Fuel Efficiency Rating (28/24 mpg) will prevent all cars from being called 'fuel efficient', including a Hummer H3, which is better than a H1 or H2, but still only 19 mpg. ----- It could be better to not even allow manufacturers to say any car is "fuel efficient" except at the 85 percentile of the type of car. Then they could claim a (deserved) benefit of highest mileage in their classification. Below this, they must just state the mileage rating. The 28 highway, 22 town miles per gallon style has always been used and people understand this. This in itself is not fuel efficient in a car. Perhaps there is a better way to do this. ANOTHER POSSIBILITY Only use 'fuel efficient' in a car that gets 35 mpg or more on the highway, SUVs that get 30 mpg and trucks that get 25, otherwise give the mpg fuel efficiency highway/town rating only. Use higher numbers if you choose to.