|Received:||1/25/2008 2:38:03 PM|
|Organization:||The Clean Air Conservancy|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims; Carbon Offsets and Renewable Energy Certificates|
Comments:The Clean Air Conservancy (CAC) appreciates this opportunity to provide comments as part of the FTC’s regulatory review of the Guides for the Use of Environmental Marketing Claims. The CAC is this country’s first non-profit environmental organization formed to acquire and retire emission credits and pollution allowances for the public good. We were founded in1992 as the EPA’s Acid Rain Program established a Cap-and-Trade scheme to regulate SO2 emissions. We participated in the first public auction of SO2 allowances, established a network of schools to buy and retire allowances, and were named one of the 10 best small environmental non-profits by Outside Magazine. We pioneered event greening and with the US Olympic Organizing Committee made the Salt Lake City Winter Olympics Net Zero in air pollution emissions by quantifying and retiring SO2, NOx, and CO2 reductions to fully offset the event. Most of the contentious issues discussed at the FTC workshop will be resolved through pending legislation, including standards of additionality. The lack of a national US program of GHG emission reductions has led to a fragmented voluntary market with competing standards. However, the rapid rise of very large mandatory carbon markets, including new multi-state schemes in the US, the CDM and JI programs, and the EU emissions trading scheme (EU ETS) will drive voluntary and mandatory markets towards a global market with a single international standard. Therefore, the resolution of such issues is beyond the scope of the regulatory review needed from FTC. The greater and more pressing need is to establish complete standards for claims of Carbon Neutrality for products, events and other advertised “footprints”. Shifting consumer preferences for greener products means the demand for Carbon Neutral products will continue to grow, but under current practices, there is significant danger of green washing. The greatest need for consumers is clear, transparent and understandable standards for products and services that are labeled as being Carbon Neutral. Companies making such claims must be required to provide objective verification for their claims. The CAC has demonstrated that claims of Carbon Neutrality can be objectively verified using available business-friendly methodologies under its innovative NetZero™ certification standard. This standard requires that companies or event organizers seeking certification develop objective emissions estimates, and track actual emissions. At the project end, we review records and collected data to verify the actual emissions and require the purchase of the verified tonnage plus 10% from a commoditized market such as the EU ETS or the CCX. The purchased emission reductions are permanently retired via transfer into the CAC Trust, insuring that they cannot be resold or used as compliance instruments. Transparency is provided through an online registry of all retired assets in the trust. Objective verification should be required for all Carbon Neutral claims and the supporting data should be available to consumers. For full transparency, the information should include at a minimum the data used, the calculation methods applied, any third-party verifications and a precise description of what aspect of a product makes it Carbon Neutral. We would be pleased to discuss our views and perspectives on these issues with the FTC staff at any time and encourage the rapid development of the standards in these comments.