16 CFR Part 259: Guide Concerning Fuel Economy Advertising for New Automobiles; Regulatory Review; Proposed Amendments to Reflect EPA and NHTSA Fuel Economy Labeling Rules and to Consider Prevalent Advertising Claims; FTC File No. R711008 #10

Submission Number:
10
Commenter:
Susan Conti
Organization:
Auto Alliance
State:
District of Columbia
Initiative Name:
16 CFR Part 259: Guide Concerning Fuel Economy Advertising for New Automobiles; Regulatory Review; Proposed Amendments to Reflect EPA and NHTSA Fuel Economy Labeling Rules and to Consider Prevalent Advertising Claims; FTC File No. R711008

The Alliance of Automobile Manufacturers (Alliance) is a trade association of twelve car and light truck manufacturers comprised of BMW Group, FCA US LLC, Ford Motor Company, General Motors Company, Jaguar Land Rover, Mazda, Mercedes-Benz USA, Mitsubishi Motors, Porsche Cars, Toyota Motor, Volkswagen Group and Volvo Cars. Together, Alliance members account for roughly three out of every four new vehicles sold in the U.S. each year. The Alliance appreciates the opportunity to offer comments on the Federal Trade Commission's (FTC's) proposed amendments to its Guide Concerning Fuel Economy Advertising for New Automobiles (Guide). The Alliance supports the Guide's dual goals of ensuring that consumers get accurate fuel economy information to use in comparing vehicles and to allow automobile manufacturers to compete vigorously over fuel economy under a common set of rules. See the attached document for the Alliance's detailed comments and contact information. Thank you.