The undersigned consumer, energy efficiency, science and environmental organizations submit the following in response to the Federal Trade Commission’s request for comments on the Guide Concerning Fuel Economy Advertising for New Automobiles. We understand that the Federal Trade Commission is seeking comments on the use of fuel economy ratings in advertising that relate to deceptive or unfair claims under the FTC Act, rather than specific comments as to the benefits of mileage ratings in advertisements. The FTC’s concern that mpg advertising disclosure not be deceptive is well founded.