Submission Number: 00053
Received: 11/17/2010 9:13:18 AM
Commenter: William Seeger
Organization: Ecohabitat, LLC
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
The FTC's review and establishment of "green" definitions is welcome and long overdue.
It is recommended that the guidelines focus on quantitative improvements of materials and processes that prioritize energy and water efficiency. Please keep in mind that Webster's Dictionary defines "sustainability" as an adjective not a noun and, therefore, any statements to that fact are completely descriptive. Standards of completed, third-party verified and tax supported construction should be at least 50% more efficient. "Green" single family homes and products should avoid carbon footprint calculations since they are based on assumptions and do not include a performance test upon installation.