Guides for the Use of Environmental Marketing Claims #536013-00009

Submission Number:
Scott Nathanson
Union of Concerned Scientists
Initiative Name:
Guides for the Use of Environmental Marketing Claims
Please find attached an RTF document with over 16,000 individual citizen letters from around the country in regard to the FTC's revision of its Green Guides on environmental advertising. I have corresponded with Marcy Baskin in your agency, who told me that this was the most appropriate format to ensure these public comments were reviewed and considered. All of these letters are pertaining to a growing new segment of environmental advertising hitherto not broached by the FTC--green promotion of fuels--most notably today's corn ethanol. High gas prices and increased concerns about global warming pollution have led to burgeoning interest in alternative fuels. It has also created a ripe market that ethanol producers and automakers producing so-called "flex fuel vehicles" to market their products as green. Some of the promotional material coming from the industry is clearly misleading. For example, VeraSun claims in their promotional material that "Unlike fossil fuels, E85 actually reduces greenhouse gas (GHG) emissions." This is a misrepresentation of the scientific consensus that corn ethanol has greenhouse gas emissions 80% as high as gasoline, and suggests that using this fuel reduced emissions, when it just increases emissions slightly less than gasoline. Indeed, current corn ethanol may indeed have a higher lifecycle carbon footprint over gasoline, and has a host of other resource use issues that make a green label far from accurate. Yet there are no rules, standards, or even government cautions, on this subject. The public's ability to make accurate purchasing choices on this extremely popular, yet oft misunderstood issue, is therefore greatly affected. We hope you will consider these letters as grounds enough to hold your next public meeting on the Green Guides to cover the subject of the environmental advertising of ethanol and other alternative fuels. You will be doing the public a great service by tackling this issue at such a crucial time. In order to make these letters as easy to process as possible, we have created an .RTF document where all 1,311 letters that in some way have been personalized by the author are at the beginning. The final edited letter belongs to Patti Wright. Following Ms. Wright, the remaining 14,691 letters were sent based entirely on our suggested sample letter. While they are the same in content, the fact that an additional 14,691 took the time to engage you on this issue should be proof enough that this warrants a public meeting. Thank you for your time and consideration, Scott Nathanson National Field Organizer, Clean Vehicles Program Union of Concerned Scientists