Submission Number: 00355
Commenter: Michel A. King
Organization: Old Mill Power Company
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
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“It is deceptive to represent, directly or by implication, that electricity is derived from renewable sources when it is not.” National Association of Attorneys General.
It’s clear from the context in which it appears that the original intent of the above quote--which comes from the National Association of Attorneys General’s (NAAG’s) Environmental Marketing Guidelines for Electricity--was to prevent a marketer from falsely claiming that conventional energy is renewable energy. One of the key issues before the Commission as it considers its Proposed, Revised Green Guides is whether the conventional energy component of a product consisting of certificates bundled with such energy has been sufficiently transformed from its conventional origins such that it can be marketed as renewable energy without misleading or materially harming a significant number of stakeholders. As the Problem Description and Analysis in the attached Comments amply demonstrate, the answer is clearly, “No,” primarily because not all of the important benefits of renewable energy convey to a certificate buyer. In the Recommendations section of its Comments, Old Mill Power Company (Old Mill) proposes modifications and additions to the Proposed, Revised Green Guides that address this critical issue while also making the Proposed, Revised Green Guides consistent with all aspects of the NAAG’s Environmental Marketing Guidelines for Electricity, including the quote above.