|Received:||7/20/2007 11:47:52 AM|
|Organization:||Broward County Consumer Affairs Division|
|Commenter:||Jennifer Di Bono|
|Agency:||Federal Trade Commission|
|Rule:||Guides Concerning Fuel Economy Advertising for New Automobiles|
Comments:Comment on Question 10: Are there any unfair and deceptive practices occurring in the promotion or advertising of fuel economy that are not covered by the Guide? If so, what mechanisms should be explored to address such practices? (e.g., consumer education, industry self-regulation, or revisions to the Guide?) Currently, there are no areas relating to the advertising of fuel economy that are not covered by the Guide. This office believes the Guide is a sufficient document for the prevention of unfair and deceptive trade practices. We believe that without the Guide the incidence of unfair and deceptive trade practices would be an everyday occurrence. As a consumer protection agency, this office relies heavily on the Guide as a legal document and enforcement tool. Without the Guide, this agency, as well as every other consumer protection agency, would not be an effective tool to ensure that advertisements were truthful and accurate. This office reviews auto advertisements for deceptive and unfair advertisements in an effort to be proactive in protecting consumers from deceptive advertising. Reviewing auto advertisements is one way in which we attempt to meet this objective. It is through the use of the Guide that this office is able to accomplish its objective. This office believes that consumer education in the area of fuel economy should continue to be explored. Miles per gallon (MPG) is a phrase embedded in almost everyone’s vocabulary. It allows consumers to compare vehicles and make informed decisions. Dealers know how important it is to promote the mpg of a vehicle since you can hardly read an auto advertisement that does not represent each vehicle’s mpg. When shopping for a vehicle consumers will generally look at warranties, performance, style and fuel efficiency. With the current gasoline situation, there is a renewed interest in how many miles per gallon a vehicle gets. This office believes because of climbing gasoline prices it is more important than ever that consumers be educated with regard to the new EPA rules on fuel economy. The EPA estimates fuel economy will drop 12-30% for city estimates and 8-25% for highway estimates under its new rules. It has to be expected that this will cause concern among consumers. Therefore, continued consumer education is imperative as these new fuel economy labels begin to appear on new 2008 vehicles. Consumers need to understand that auto manufacturers have not redesigned the vehicles to be less fuel efficient, but rather the EPA has instituted additional tests that reflect a more “real world” estimate. It will be important in the upcoming months to explain to consumers that they are actually being provided a more accurate mpg estimate.