|Received:||1/23/2008 1:29:57 AM|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims; Carbon Offsets and Renewable Energy Certificates|
Comments:I am a consumer concerned about climate change who recognizes that although I may reduce my energy use, it's nearly impossible, in our fossil fuel-driven economy, to avoid being responsible for some carbon emissions, associated with energy use that I could not eliminate. Thus I was drawn to the opportunity to buy "carbon offsets" when I learned they were available. I have bought offsets from Carbonfund.org and am currently purchasing an offset from NativeEnergy. I believed that by purchasing offsets I could become "carbon neutral"- that is, the emissions that I could not avoid making would be neutralized by an equal reduction in emissions elsewhere, due to projects I was helping to fund. Both CF and NE, on their web pages titled "Why carbon offsets" support that belief, through statements such as "Offsetting your carbon footprint through the purchase of carbon offsets allows you to become part of the solution to climate change by supporting the reduction of carbon dioxide emissions equal to your carbon emissions." (Carbonfund.org) I believed that by purchasing offsets I could make zero net contribution to climate change. I also assumed that any offset I purchased would be "additional"; i.e., my dollars would buy new offsets that wouldn't occur otherwise. But I learned from Carbonfund that they don't guarantee, or necessarily pursue, additionality as a matter of policy - they don't feel it's critical. I moved to NE after reading two reviews of the voluntary offset market - by Clean Air-Cool Planet and by Tufts Climate Initiative - which both rated NativeEnergy highly, as compared to Carbonfund. I could see from NE's website that the wind turbine I was helping to finance was additional. Online "lifestyle" carbon calculators relate to a particular time period, such as a year. The offset I'm buying from NE is for my estimated 2007 emissions. I understood from the project description that the wind turbine was not scheduled to begin operation until the end of 2008, and that then my offset was apportioned over the 25 year life of the machine - but I didn't focus clearly on this "timing" issue until a friend brought it up. I now feel that if consumers are to become carbon neutral, so that they are not contributing to climate change, offsets must be CONCURRENT as well as additional; that is, they should occur at approximately the same time as the emissions being offset. Otherwise, due to the persistence of greenhouse gasses in the atmosphere, the emissions I send up this year will contribute to global warming in advance of the offset I've purchased, which is typically spread out over an extended future period. My offset will take effect too late to be helpful, and I would be wrong to think my impact is reduced to zero. I believe that the products and methods now used in the voluntary market mislead consumers to think they are avoiding personal climate change impacts when they purchase offsets, due to lack of additionality and/or concurrence. I have not seen concurrence discussed in the literature or on any provider's website. Particularly troubling is the possibility that people may feel under less pressure to reduce emissions if they think buying offsets "really works." For example, Terrapass now sells offsets to Enterprise Rent-A-Car customers. Will those customers limit their miles or drive to achieve fuel economy, or will they now feel limits aren't needed because their emissions are being effectively offset? I believe that common standards and verification methods must be adopted, and that offsets must be additional and concurrent, if customers are to understand and receive a product that truly makes them "carbon neutral" as they have been led to expect. Additionally, providers should state clearly that reducing emissions is the first step (and include advice on how to achieve reductions), and purchasing offsets is only the final step.