|Received:||1/21/2008 2:53:00 PM|
|Commenter:||Henry M Wong|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
Comments:Although I was only made aware of this issuance for feedback recently, I hope these comments are considered. I work with (not for) several organizations on energy efficiency on computer products, such organizations include the Green Grid, US EPA, the California Energy Commission/PIER, LawrenceBerkleyNationalLabs, and US DOE; amongst others. My comments however, should be considered my personal comments and not be considered as representing any of these organizations. My concerns with carbon offsets is the establishment of what amounts to being an energy_currency. Neither the translation of its value or its base value are controlled nor truely verifiable with regards to its impact to environmental concerns. In a simplified example, translation of how a $1MM of offsets would directly fund carbon sequentration projects or lowering barriers to alternative fuels. Not only is there a concern with commercial green-washing, given the hype to join the bandwagon, but, there is also a certain amount of geo-political bravado that needs to be prevented. My recommendation is to establish a comprehensive program modelled after things like those modelled in IEEE's papers on environmental lifecyle impact analysis. Such a program should comprehend the monetary incentives and exchange which value the acceleration of technologies & activities which reduce the environmental impact. Valuing sustained operations and progressive improvements over one time consumption reduction, is an example of the desired exchange. Any economical provisions to incentivize the correct behavoir would be comprehended in the program (whether that is through carbon-offsets or otherwise) I would also recommend the establishment of a task group that combines the ecological, technological, and economic experts that would provide this level of comprehensive approach. Without each, I fear the targets may miss our intended outcome (economic&societal growth and aggressive minimization of ecological impacts).