Submission Number: 00265
Received: 12/10/2010 3:43:55 PM
Commenter: David Zimmerman
Organization: Tennessee Valley Authority
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
• A document is needed to provide clear guidance for the owners of renewable energy sites and the owners of the associated renewable energy.
• The term “hosting” should be allowed as long as sufficient information is supplied stating the percentage used by the hosting facility and the recipient of the remaining renewable energy.
• An organization should not be able to make the statement “made with renewable energy” unless 100% of their energy is renewable. However, it is acceptable to use to make a statement that “we purchase 15% of our electrical demand with renewable energy”
• As long as sufficient RECs are retired for a renewables claim, it is not necessary for a disclosure stating the source of the RECs. However, there should be sufficient documentation maintained to validate any claims.
• If local benefits are claimed by the renewable energy user, then the energy must be generated within the designated local area.