Submission Number: 00215
Received: 12/10/2010 12:17:19 PM
Commenter: Kevin DeGroat
Organization: Antares Group, Inc.
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
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The Antares Group is a clean energy company that works with both private sector companies and government institutions to identify, develop and install clean energy technologies including biomass, solar and wind. Antares also works closely with the Federal Energy Management Program (FEMP), which facilitates the Federal Government’s implementation of sound, cost-effective energy management and investment practices to enhance the nation’s energy security and environmental stewardship. This includes facilitating the development of renewable energy by Federal agencies, and working with agencies to explain their accomplishments to the public. Antares strongly supports the majority of the proposed revisions to the Guide concerning renewable energy claims. They clarify important issues concerning renewable energy certificates (RECs) and renewable claims for both the private companies and government agencies we work with. However, Antares disagrees with the FTC’s view on the term “hosted” in reference to the situation in which a renewable energy facility is sited, but the energy it generates is not consumed, on one’s building or land. Antares believes that the term “hosting” would not be deceptive if used in conjunction with a more detailed explanation of the arrangement. Because these kinds of arrangements are very common for renewable energy systems, there is need for some method of describing situations in which an agency or entity has a highly visible renewable energy facility on site but does not use the renewable energy itself.
One area that is a problem for government agencies, and for many private sector firms, is Section 260.14 Renewable Energy Claims, paragraph (d) Example 2 concerning claims that a company “hosts a renewable power facility.” The FTC’s consumer perception survey found consumers did not understand what this meant and misinterpreted it to mean the company is using renewable energy. FEMP believes this consumer misperception is the result of a lack of education and information about this approach to siting renewable energy and the fact that most consumers are unaware of “hosting” and its benefits. “Host” is the most descriptive term for this type of arrangement, but like other environmental claims that consumers tend to misinterpret it requires substantiation. The way this example is presented would discourage companies and agencies from using the term “host.” However, to explain why they have a highly visible renewable energy system on their building or site, agencies and companies will use other ways to describe the arrangement and clear acceptable language in examples would be very helpful. Providing an adequate explanation of the arrangement and its benefits would not be deceptive.
There are two general situations where a company or agency might want to use the term “hosted.” First, when a renewable project is located at their site and the site is using all the electricity, but all of the RECs are sold to a third party. This describes how a 750 kW PVsystem at the National Renewable Energy Laboratory was installed. Second, a renewable energy project may be installed at a site but the site itself doesn’t use any of the electricity or own any of the RECs from the project. This describes how the 37 MW system at Brookhaven National Laboratory will be installed. We have offered some clearer examples and some changes to the proposed example that illustrate how different arrangements can be appropriately explained.