Director agrees, the Fortnightly doesn't get it.
In your Oct. 1, 1999 editorial regarding green power marketing, you stated that "the FTC would leave consumers in the dark on some environmental claims." (See "We Got Green?" Public Utilities Fortnightly, p. 4.) After reading your observations, we here at the FTC are in the dark as to why you believe that retail power marketers should be required to give consumers information that would shed no light on their purchase decisions.
In our comment to the National Association of Attorneys General (NAAG), we advised that retailers not be required to disclose when a system of tagging (as opposed to contracts) is used to track environmental characteristics of power. In discussing the comment, you seem to understand that tags are equivalent to contracts, and yet you imply that consumers will be harmed if advertisements do not disclose the use of a tagging system.
But, as we went on to say in our comments to NAAG, under both systems the premiums that consumers pay for environmentally preferable power are matched with the producers of that power, even though consumers (under both systems) are all using the same electricity, which is blended on the grid. The only significant difference between the methods is that more trades can be made under tagging because grid constraints need not prevent the purchase of tags (and this could mean that environmental benefits may accrue in areas that are geographically remote to the consumers). And while you allude to the possibility of double-counting green power, such concerns apply equally if a contract system is used.