These comments are submitted by the following non-profit organizations, which advocate for the interests of low-income energy and utility consumers: The National Consumer Law Center, Public Citizen, the Maryland Energy Advocates Coalition, and the Pennsylvania Utility Law Project.
These comments propose changes in several areas of the Green Guides, 16 C.F.R. part 260, which relate to protections for low-income energy consumers. The above non-profit organizations urge the FTC to adopt changes to the Green Guides that will discourage and reduce the use of deceptive environmental claims for marketing several home energy products to consumers. Deceptive claims associated with energy supply contracts, renewable energy certificates, gas and alternative gas utility services, and other products lead customers to purchase energy products that they do not need or overpay for home energy. Misleading environmental claims can also create suspicion and mistrust when consumers learn of the falsehoods, which undermines support for effective measures to fight climate change.