The proposed rule requests comment on whether the label should include a "merged value" fuel economy and emissions performance of PHEVs, reflecting the combined performance of both operating modes. See 75 Fed. Reg. 58110. The merged value also would represent the fuel economy and emissions performance experienced by the "average driver," based on assumptions about the amount of time the vehicle is operated in each mode (gasoline-powered, battery-powered or combined). While a single number would be easier for consumers to understand, it has the potential to be highly misleading because consumers may vary dramatically in their driving habits. For example, a "merged value" for a PHEV calculated by assuming that the driver is driving in the "electric mode" for 50 percent of the time and "gasoline mode" for the other 50 percent, will be very misleading to consumers that will be driving the "electric mode" for 90+ percent of the time. A better approach is to provide a tool on the website that enables consumers to estimate a merged value based on driver-specific assumptions. [EPA-HQ-OAR-2009-0865-7117.1, p.9]

Honda Motor Company
Two labels for PHEVs: There are several issues we would like to address regarding PHEVs: [EPA-HQ-OAR-2009-0865-6774.1, p.5]
Series and Blended PHEVs: The agencies have proposed different labels for series and blended types. It is Honda's strong belief that such distinctions will become increasingly blurred and unnecessary. There is no SAE definition of an "extended range electric (series) type" vehicle. As we think ahead to the various technologies which may be deployed, the agencies may be creating another distinction ripe for gaming. Some PHEVs may be able to follow UDDS in all-electric mode, but not US06. Others may be able to follow US06 for some short periods but not always in all electric mode. And still other designs may be able to perform US06 in electric mode, however, there may be some driving conditions under which the engine could engage. As we learn more about battery chemistries and durability, the distinctions between series and blended may be more problematic than we realize. [EPA-HQ-OAR-2009-0865-6774.1, p.5]

National Renewable Energy Laboratory (NREL), Center for Transportation Technologies & Systems (CTTS)
Pages 58102-58104 provide introductory information on advanced technology vehicles and request comment on consistent labeling of PHEVs whether or not they qualify as a "dual-fueled" vehicle. I agree with the premise of applying such simplicity and consistency in PHEV labeling, but believe that the proposal injects an unnecessary degree of complexity with the EREV vs. PHEV distinction (in my opinion "EREV" can be considered as a particular PHEV design subcategory and need not be established as a separate vehicle type; such a vehicle can simply be identified as consuming no petroleum fuel during CD operation). As acknowledged in the same section, the line between the two can easily blur. Furthermore, a PHEV that is just tested over the FTP and HFET may have sufficient battery power to complete those cycles all-electrically, but may operate as a blended PHEV in real-world driving that typically requires more power than that demanded by the FTP and HFET. Based on the proposal, there would be a disconnect for consumers of such a vehicle between the label guidance (that the vehicle would operate all-electrically during the CD mode) and their actual experience (that the engine frequently assists during CD mode). See also the below related comments on applying adjustments to PHEV CD consumption and range estimates. [EPA-HQ-OAR-2009-0865-7222, p.3]

Toyota
EPA Statutory Requirements [EPA-HQ-OAR-2009-0865-6901.1, p.8]
PHEVs are considered as dual fueled automobiles under 49 U.S.C. 32901 (a)(9), when exhibiting a minimum driving range of 7.5 miles under the EPA urban test cycle and 10.2 miles when operated on the EPA highway test cycle. The statutory requirement for dual fueled vehicle labels requires that the fuel economy be indicated as the average number of miles traveled by an automobile for each gallon of gasoline (or equivalent amount of other fuel) used. In order to meet this statutory requirement, the electricity used is converted and reported as MPGe. For simplicity and consistency, the agencies plan for all PHEV fuel economy labels to contain information required for dual fueled vehicles under the statute, regardless of dual fuel classification. [EPA-HQ-OAR-2009-0865-6901.1, p.8]
Toyota support only one label format for PHEV, and not two as EPA has proposed. Two different formats, one for extended range PHEV and the other for blended PHEV adds complexity to the labels, can be confusing to those not familiar with the technology, and would be unnecessary because the information can be easily incorporated into one label format for all PHEVs. [EPA-HQ-OAR-2009-0865-6901.1, p.13]
In the proposal, the agencies talked about two "distinct types" of PHEVs:  extended range electric vehicle (EREV) PHEVs, which operate exclusively on the battery as long as the battery is above the minimum charge level, and blended PHEVs, which generally run on a mix of electricity and gasoline while the battery is above the minimum charge.  Sample labels were shown for both, with the same label name of "Dual Fuel Vehicle:  Gasoline-Electricity."  The sample PHEV labels were very similar, except that the EREV PHEV label had an "All Electric" mode of operation while the blended PHEV had an "Electric + Gas" mode of operation.
Several automakers, including Ford, Honda, and Toyota, commented that they believe there should be one PHEV label, not two.  For example, Honda stated that "Some PHEVs may be able to follow UDDS in all-electric mode, but not US06.  Others may be able to follow US06 for some short periods, but not always in all electric mode.  And still other designs may be able to perform US06 in electric mode, however, there may be some driving conditions under which the engine could engage."  Ford recommended "usage of one format, such as 'Electric Assist.'
Also, the California Air Resources Board suggested that the label name for PHEVs should be "Plug-in Hybrid Electric Vehicle."

Response:
The agencies agree that there should be a single label concept for PHEVs.  There is almost an infinite number of possible PHEV designs, and we agree that it does not make sense to try to have discreet labels for each.  On the other hand, we believe it is appropriate to try to provide the information that would be of most direct interest to the consumer.  One piece of information that we believe is useful is whether a vehicle can operate exclusively on electricity or not.  We believe there will be some consumers who will be very interested in displacing gasoline with electricity, and who will want to know whether they can take some trips that will be gasoline-free.  The agencies agree with the commenters that this issue is complicated by the need to use certain test procedures that may not fully reflect the full range of consumer driving behavior and conditions, and that therefore some consumers may not always achieve label results.  The agencies believe that PHEV labels will continue to evolve as more PHEVs designs are commercialized.
In response to the comment from the California Air Resources Board, the agencies have revised the name of the PHEV label to "Plug-In Hybrid Vehicle, Electricity-Gasoline."

4.2.6. "Your actual mileage and costs will vary" Statement
                                                                            224
Organization: Honda Motor Company
Laclede Gas Company
Comment:
Honda Motor Company
Disclaimer: The agencies sought comment on the appropriateness of the current disclaimer "your actual mileage will vary depending on how you drive and maintain your vehicle." Currently some ad hoc disclaimers are required, which were not discussed in the NPRM. Specifically, Honda's Fuel Cell Electric Vehicle, the FCX Clarity, was required to add the following language to the standard disclaimer: "Your actual mileage will vary depending on how you drive and maintain your vehicle, particularly affected by ambient temperature and the use of heating and air conditioning." Honda hopes that if this additional language is applied, it should be applied across the board to all vehicles and vehicle technologies, otherwise, this language should be dropped from Fuel Cell Electric Vehicles. We do not believe that Fuel Cell Electric Vehicles should be singled out for this disclaimer. [EPA-HQ-OAR-2009-0865-6774.1, p.7]

Laclede Gas Company
The statement "Your actual mileage will vary depending on how you drive and maintain your vehicle," should be revised for vehicles that use grid-generated electricity to read: "Your actual mileage and associated electrical power plant emissions will vary depending on how you drive and maintain your vehicle and how electricity is generated in your region. For additional information see (provide EPA website). [EPA-HQ-OAR-2009-0865-7138.1, p.5]
Response:
To simplify label design and implementation, the agencies are finalizing disclaimer text that is uniform across all vehicle technology types.  The finalized language reads "Actual results will vary for many reasons, including driving conditions and how you drive and maintain your vehicle." The agencies do not believe it is necessary to incur the additional complications of having technology-specific disclaimer language.

4.3. Flexible Fuel Vehicles
                                                                            225
Organization: California Air Resources Board (CARB)
Comment:
California Air Resources Board (CARB)
We suggest that for Flex Fuel Vehicles (FFV) you include the values for both gasoline and ethanol similar to what you do for plug-in hybrids. This would allow consumers to easily recognize a vehicle as an FFV and it would provide important information for both fuels. [EPA-HQ-OAR-2009-0865-7527.1, p.5]
Response:
The agencies have finalized labels for FFVs that allow consumers to easily identify the vehicle as an FFV. With respect to including gasoline and ethanol fuel economy values, please see the response in section 4.3.2.
Organization: Raab, Michael
Comment:
Raab, Michael
One other issue the EPA has pointed to is that many flex fuel cars run on gasoline as opposed to E85. Whether they do or do not should not be a consideration for the fuel efficiency labels, which should be based on empirical measurements. A similar argument could be made for electric cars: if people forget to plug them in, or cannot plug them in long enough to charge sufficiently, then they run purely on gasoline. These anecdotal arguments have no place in the evaluation and only the facts should be presented to consumers. [EPA-HQ-OAR-2009-0865-3279, pp.1-2]
Response:
Consistent with the desires of the commenter, the values on the label are based on empirical measurements and do not consider the extent to which the vehicle may (or may not) operate on E85.  We would note, however, that the degree to which E85 is used to fuel FFVs is hardly anecdotal.  It is easy to determine from the amount of E85 that is produced and the number of ethanol-capable vehicles on the road roughly how much these vehicles are using ethanol.
Organization: Renewable Fuels Association
Comment:
Renewable Fuels Association
Labels for Flexible Fuel Vehicles (FFVs) should continue to reflect their fuel economy when operated on gasoline, but should include a statement regarding the benefits of operating the vehicle on E85. [EPA-HQ-OAR-2009-0865-6926.1, p.6]
EPA and NHTSA discuss three options for the labeling of FFVs. We generally support the first option, which is "to make no changes to the current requirements for FFV labels...," meaning FFV labels should continue to reflect their fuel economy when operated on gasoline. However, we also recommend a slight modification to this option that would require that FFV labels display the explanatory statement proposed as part of the second option discussed by EPA and NHTSA. That statement says, "Using E85 uses less oil and typically produces less CO2 emissions than gasoline." 75 Fed. Reg. at 58,111. We believe this is the most suitable option, given that the majority of FFVs continue to be operated predominantly on E10, but also recognizing that consumers may want additional information on the benefits of operating the vehicle on E85. [EPA-HQ-OAR-2009-0865-6926.1, p.6]
Response:
Organization: Smith, Houston
Comment:
Smith, Houston
Further, extended range vehicles like the Volt will require "dual ratings" similar to the current flex fuel label to allow inclusion of the ICE fuel consumption rate in "extended range" mode. This would also require emissions data for this mode as well. [EPA-HQ-OAR-2009-0865-0477, p.3]
Response:
The agencies have finalized labels consistent with these comments. The PHEV labels display efficiency metrics for the operation using only the internal combustion engine, and separately for the operation of the vehicle when it's using a fully charged battery.

4.3.1. Proposal to Base Label Information on Gasoline Operation
                                                                            227
Organization: General Motors (GM)
Alliance of Automobile Manufactures (Alliance)
California Air Resources Board (CARB)
American Council for an Energy-Efficient Economy (ACEEE)
Abengoa Bioenergy
Honda Motor Company
National Petrochemical and Refiners Association (NPRA)
American Petroleum Institute (API)
Comment:
Abengoa Bioenergy
FFV Labels Should Note Benefits of Operating on Ethanol Blends
EPA and NHTSA discuss three options for the labeling of FFVs. We generally support the first option, which is "to make no changes to the current requirements for FFV labels...," meaning FFV labels should continue to reflect their fuel economy when operated on gasoline. However, we recommend that labels for FFVs specifically note that the GHG data provided is based on gasoline as a fuel source, and that the FFV labels be required to add the explanatory statement proposed as part of the second option discussed by EPA and NHTSA that, "Using E85 uses less oil and typically produces less CO2 emissions than gasoline." 75 Fed.Reg. at 58,111. This would give deference to the fact that the majority of FFVs continue to be operated predominantly on E10, but would also recognizing that consumers way want additional information on the benefits of operating the vehicle on E85. [EPA-HQ-OAR-2009-0865-7140.1, p.2]

Alliance of Automobile Manufactures (Alliance)
Flexible Fuel Vehicle (FFV) Reporting Should Be Optional. [EPA-HQ-OAR-2009-0865-6850.2, pp.14]
Currently, manufacturers may voluntarily include the fuel economy estimates (and estimated annual fuel costs) for the alternative fuel on the label, in addition to the gasoline information. The Alliance supports continuing the current requirements for FFV labels and continuing to use the fueleconomy.gov website and the Fuel Economy Guide to provide information on E85. [EPA-HQ-OAR-2009-0865-6850.2, pp.14]

American Council for an Energy-Efficient Economy (ACEEE)
ACEEE supports the suggested approach to merged gasoline and biofuel values for fuel economy and GHG performance, in which the vehicle is assumed to run on 100 percent gasoline, except when the manufacturer can demonstrate that a certain percentage of its vehicles are in fact running on E85. We note that this approach, consistent with that used for light-duty GHG standards for 2016 and after model year vehicles, could be adapted for plug-in vehicles. In that case, manufacturers might be required to use a national average electricity generation mix for the power used to charge their vehicles' batteries unless they were able to demonstrate the use of a lower-emissions generation mix for their vehicles. [EPA-HQ-OAR-2009-0865-7135.1, pp. 7-8]

American Petroleum Institute (API)
 If FFV fuel economy while operating on E85 is added to the FFV labeling requirement, 75 Fed. Reg. 58111 suggests adding text to the label such as, 'While the E85 MPG values are lower than the gasoline MPG values, the use of E85 is typically slightly more energy efficient than the use of gasoline.' Although carefully controlled laboratory studies sometimes show a small impact, it is often within the uncertainty of the measurements as FFVs are not optimized to operate on E85 as a dedicated ethanol vehicle might be. Addition of such a statement to the FFV label would need to include the actual percentage improvement and be supported with appropriate testing and documentation. [EPA-HQ-OAR-2009-0865-7250.1, p.6]

California Air Resources Board (CARB)
We suggest for flex-fuel vehicles that you  include the values for both the gasoline and ethanol,  similar to what you do for plug-in hybrids.  This will  allow consumers to equally recognize that the vehicle  actually is a flex-fuel vehicle and would provide  important information for both fuels.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 133.]

General Motors (GM)
Flex Fuel Vehicles (FFV)
GM supports the agencies' option number one to make no changes to the current optional requirements for FFV labels and continue to use fueleconomy.gov and the Fuel Economy Guide to provide information on E85 use to consumers. Consistent with the current requirements, EPA and NHTSA would finalize regulations that would allow manufacturers to display the E85 fuel economy values on the label on a voluntary basis. [EPA-HQ-OAR-2009-0865-6924.1, p. 5]

Honda Motor Company
In fact, for E85 it would lead to the perverse  result that E85 would have a higher mpg-equivalent than  its actual E85 miles per gallon, and yet customers would  never experience the mpg-e.  We know that consumers do  not like new metrics and may be more comfortable  initially with the mpg-e metric.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 90.]

National Petrochemical and Refiners Association (NPRA)
THE INFORMATION FOR A FFV SHOULD BE BASED ON GASOLINE OPERATION. [EPA-HQ-OAR-2009-0865-6773.1, p.3]
EPA understands that E85 is not widely available. Furthermore, the Agency concluded "that, on average, FFV owners were only tapping into about 0.2% of their vehicle's E85/ethanol usage potential last year" (74 FR 25012). Therefore, FFVs are overwhelmingly refueled with gasoline. The label can include information on E85, but it should also include information on gasoline so as not to mislead consumers. [EPA-HQ-OAR-2009-0865-6773.1, p.3]
Response:
The agencies are requiring a label for ethanol flexible fuel vehicles that is consistent with the principles of the current policy:  all label metrics are based on gasoline operation, a statement is provided so that the consumer knows that the values are based on gasoline operation, and manufacturers may voluntarily include fuel economy estimates on E85 (which would be based on miles per gallon of E85, given that E85 is a liquid fuel).  In addition, manufactures may optionally include the driving range on gasoline and on E85.  As with the required range information on non-petroleum and advanced technology vehicles, the FTC will need to make a formal decision as to whether vehicles with these labels meet the FTC label requirements.  Additional information regarding the performance of the vehicle while operating on E85 will continue to be available via other sources such as the Fuel Economy Guide.
The agencies chose to not include a statement on the label regarding the benefits of using ethanol for a variety of reasons.  The labels already contain a lot of information, and the agencies are concerned about information overload.  More importantly, however, is the fact that every fuel may have a differing set of advantages and disadvantages, and the the agencies ultimately decided that it was not appropriate to highlight the advantages of one alternative fuel and not others.  Agency websites and other resources can be used to determine the potential advantages and disadvantages of alternative fuels relative to the circumstances of any individual consumer.
The agencies are not finalizing the concept of merging gasoline and biofuels performance based on the usage of biofuels.  While this approach may be appropriate for the GHG emission standards program, the agencies concluded it was premature to adopt such a concept in the labeling program.  The labeling program requires comparable, repeatable, and transparent methodologies to the extent possible, and it may not be desirable to have labels that "blend" gasoline and biofuel performance values at differing rates. Doing so would compromise the comparability of the metrics on the label.
EPA is continuing the approach of specifying MPG values, not MPG-equivalent.  As stated in the preamble to the final rule, EPA believes it is important in the case of liquid fuels to use units that relate to how consumers purchase the fuel.  Consumers purchase gallons of gasoline, diesel fuel, and E85, and using MPGe for diesel or for E85 simply takes the metric a step further away from helping the consumer understand the fuel use of the vehicle and the impact on fueling costs.  We believe that changing to MPGe for the fuel economy of diesel or E85 vehicles would be very confusing to consumers, as label MPGe values would then be inconsistent with all consumer calculations of fuel economy (since these fuels are sold in volumetric gallons) as well as fuel economy values shown on vehicle dashboard displays.

4.3.2. E85 Operation
                                                                            231
Organization: Abengoa Bioenergy
Renewable Fuels Association
Comment:
Abengoa Bioenergy
We also urge EPA and NHTSA to give automobile manufacturers the option to voluntarily include information on vehicle labels regarding fuel economy and fuel costs of operating FFVs on E85 rather than on unblended gasoline, provided that this information is based on metrics and values approved by EPA. Manufacturers should be required to use the miles per gallon of gasoline equivalent metric discussed by EPA and NHTSA in the proposal in order to uniformly account for the "slightly higher miles per unit of energy that an FFV achieves on E85 relative to gasoline." 75 Fed.Reg. at 58,112. [EPA-HQ-OAR-2009-0865-7140.1, pp.2-3]

Renewable Fuels Association
Manufacturers should continue to have the option to voluntarily include information reflecting the FFV's performance when operating on E85. However, if manufacturers voluntarily display this information, it must be based on common metrics and values determined by EPA through established vehicle testing protocols. [EPA-HQ-OAR-2009-0865-6926.1, p.6]
We agree that automobile manufacturers should continue to have the option to voluntarily include information reflecting the FFV's fuel economy and estimated fuel costs when operating on E85, and we agree that this voluntary allowance should extend to displaying GHG emissions impacts. However, we believe that if manufacturers choose to display E85 fuel economy information on FFV labels, it must be displayed consistently and must be based on common metrics and values determined by EPA through established testing protocols. That is, individual manufacturers should not be allowed to display their own calculations of fuel economy, fuel cost, and GHG emissions for FFVs operating on E85; rather, this information should be provided by EPA to manufacturers who wish to voluntary display it on the label. [EPA-HQ-OAR-2009-0865-6926.1, pp.6-7]
We also recommend that if manufacturers choose to voluntarily display fuel economy information on FFV labels pertaining to the use of E85, they should be required to use the miles per gallon of gasoline-equivalent metric discussed by EPA and NHTSA in the proposal. As outlined in the proposal, this method would provide a "way to quantitatively account for the slightly higher miles per unit of energy that an FFV achieves on E85 relative to gasoline." 75 Fed. Reg. at 58,112. [EPA-HQ-OAR-2009-0865-6926.1, p.7]

Response:
EPA is continuing the currently allowed option to voluntarily include E85 fuel economy and annual cost values.  As is the case with all fuel economy values, these values are determined using EPA test procedures and calculation methods.  However, EPA is continuing the approach of specifying MPG values, not MPG-equivalent.  As stated in the preamble to the final rule, EPA believes it is important in the case of liquid fuels to use units that relate to how consumers purchase the fuel.  Consumers purchase gallons of gasoline, diesel fuel, and E85, and using MPGe for diesel or for E85 simply takes the metric a step further away from helping the consumer understand the fuel use of the vehicle and the impact on fueling costs.  We believe that changing to MPGe for the fuel economy of diesel or E85 vehicles would be very confusing to consumers, as label MPGe values would then be inconsistent with all consumer calculations of fuel economy (since these fuels are sold in volumetric gallons) as well as fuel economy values shown on vehicle dashboard displays. The agencies proposed a range of options for ethanol flexible fuel vehicles, including maintaining the current policy of requiring only gasoline-based MPG on the label (with optional inclusion of E85-based MPG), requiring the addition of E85-based MPG, and requiring the addition of E85-based MPGe.  Only a few commenters addressed ethanol flexible fuel vehicles, and most who commented on this option supported the current policy.  The agencies are requiring a label for ethanol flexible fuel vehicles that is consistent with the principles of the current policy:  all label metrics are based on gasoline operation, a statement is provided so that the consumer knows that the values are based on gasoline operation, and EPA is finalizing that manufacturers may voluntarily include fuel economy estimates on E85 (which would be based on miles per gallon of E85, given that E85 is a liquid fuel).
Organization: American Council for an Energy-Efficient Economy (ACEEE)
Comment:
American Council for an Energy-Efficient Economy (ACEEE)
For FFVs, ACEEE does not support addition of the statement that "the use of E85 is typically slightly more energy efficient than the use of gasoline" on the label (58111). FFVs are required to operate at least as efficiently on E85 as on gasoline to be considered dual fueled vehicles, so it is possible that manufacturers tune their FFVs to operate slightly less efficiently on gasoline in order to meet this requirement. Optimization of vehicles running on ethanol may indeed lead to superior energy efficiency, but unless there is some real evidence that such efficiency gains have been realized, no claims of this kind are warranted for FFVs. [EPA-HQ-OAR-2009-0865-7135.1, p. 7]
Response:
Organization: Wasserman, Seth
Comment:
Wasserman, Seth
I am concerned about the ratings for flex-fueled vehicles which the new system does not accommodate. The old system would show the range on gasoline, and the range on ethanol, but not the gasoline range when running on ethanol. This is the opposite of what is happening with hybrids and partial electrics. With the hybrid/partial electric the mileage displayed on the window is the gas mileage with the electric assistance. With the ethanol sticker the mileage displayed is the ethanol number, not the gas range with the ethanol assistance. In other words apples to oranges. A hybrid is just a gas car with batteries assisting and an E85 vehicle is another type of hybrid - a gas car that has ethanol assisting. [EPA-HQ-OAR-2009-0865-4564, p. 1]
There needs to be parity. So if there is a MPGe category for electric, there needs to be an MPGe for ethanol. As an example: according to the EPA rating a 2010 Chevy HHR flex-fuel with a 16 gallon tank goes 360 miles or gets 25mpg combined on gas (does not specify E0 or E10) and goes 259 miles or gets 18mpg combined on E85. To someone unfamiliar this looks like a deficiency because the alternate fuel gets a 'worse' number than the fuel we are trying to eliminate/conserve. There needs to be another number shown because when that car went 259 miles on E85, it only used 2.4 gallons of actual gasoline (15% of the 16 gallons of E85) meaning it had a MPGe of 108. [EPA-HQ-OAR-2009-0865-4564, p. 1]
Response:
An E85 vehicle is not a hybrid "gas car that has ethanol assisting."  The commenter appears to misunderstand both the current labeling program (which shows driving range for no vehicle technologies) and the vehicle technologies and as a consequence it is not clear what they would suggest.
The comment regarding using an MPGe value for ethanol is addressed in section 4.3.2.
Organization: Steele, John M.
Comment:
Steele, John M.
I am surprised that there is no rating information for E85 in FFV. Congress has mandated enormous amounts of ethanol, more than can be used in E10, so there must be some plan to push E85. Yet no information on E85 performance is provided to consumers who buy an FFV. Ignoring this looks more wrong in light of the proposals to make sense of alternative fuel ratings for plug-in hybrids. It does not seem right to give consumers information on both fuels in some dual fuel situations and not in others. [EPA-HQ-OAR-2009-0865-3276, p.2]

Response:
It is correct that the current EPA fuel economy label does not provide information regarding ethanol.  However, that information is available in a number of places.  First and foremost, every new FFV today displays a label required by the FTC that shows the vehicle driving range on gasoline and on ethanol, allowing a direct comparison of the performance of the two fuels for a given vehicle.  In addition, ethanol performance information is available at www.fueleconomy.gov and in the annual Fuel Economy Guide published jointly by EPA and DOE. Finally, the new regulations allow manufacturers to optionally include ethanol mpg values and comparative driving range information for both fuels.  The agencies expect to see some adoption of the optional driving range information because it will likely enable manufacturers to avoid also reporting the duplicative FTC label.
Organization: Raab, Michael
Comment:
Raab, Michael
I would like to comment on the proposed fuel economy label for flex fuel cars, as it compares to electric cars and others, which also can use an alternative fuel source. [EPA-HQ-OAR-2009-0865-3279, p.1]
The current proposals for the 'fuel economy' of electric cars are unfair relative to flex fuel cars. Like flex fuel (E85 compatible) cars, electric or hybrid electric cars also use gasoline, but instead of using ethanol to supplement the gasoline, they use electricity, the majority of which comes from coal. From a greenhouse gas perspective, electric cars run primarily on gasoline and coal, as opposed to flex fuel cars, which run primarily on ethanol and gasoline. The problem with the proposed fuel efficiency labels, is that they credit electric and hybrid cars with the energy benefit from electricity (coal), to their gasoline efficiency, but do not do the same for ethanol. [EPA-HQ-OAR-2009-0865-3279, p.1]
For example, while the first 40 miles of driving of the Chevy Volt come from the electrically charged battery, the estimated next 260 miles come from gasoline. To deliver the remaining 260 miles of driving, Edmunds reports that the Volt will use it's 8 gal gas tank, which would equate to ~32.5 mpg for the the majority of the range (best case, even if you attributed the full 40 miles to the gasoline engine), these cars at best should be rated at ~37.5 mpg; certainly not the 230 mpg claimed by Chevrolet. If the same basis for a flex fuel car was used to calculate its mileage as was used to calcualte the ~37.5 mpg for the volt, that is, the flex fuel car was credited for the mileage contributed by ethanol to its range the same way the Volt electricity (coal) was credited to its range, the flex fuel car would have dramatically better fuel efficiency. Consider this example, a flex fuel Ford Escape gets ~23 mpg on E85. However, only 15% of that mileage is attributable to gasoline, thus if the car is credited for the ethanol contribution in the same way that the Volt was credited with the electric contribution, the flex fuel Ford Escape would get ~153 mpg, as compared to the ~37.5 mpg of the Volt. [EPA-HQ-OAR-2009-0865-3279, p.1]
The most fair way to compare these cars is not on a mpg basis, but on an energy/ mile basis, which needs to be measured, not calculated, given the different inefficiencies between batteries and liquid fuels. For example, take a Chevy Volt with a dead battery and empty tank, then measure how much energy is required to charge the battery, how much energy is in the fuel used to fill the tank and run the car until it stops. Do the same thing with the flex fuel car and simply report numbers as energy/ mile (or the inverse, miles/ unit energy). It will take people some time to get used to these, but they will quickly understand that the more miles/ unit energy is what they are interested in (or more likely, the more miles per unit cost). On this basis, the differences between cars will most be determined primarily by their weight, and secondarily by their particular propulsion system, but the numbers will be more comparable across all car for a given class. [EPA-HQ-OAR-2009-0865-3279, p.1]
Response:
The agencies agree with the commenter that it is inappropriate to "credit" EVs and PHEVs with the energy from electricity in a way that misrepresents the vehicle.  The final PHEV labels present fuel efficiency and consumption in an appropriate way by showing the energy use in each mode, without attributing the miles driven using electricity to the gasoline mpg value.  While the labels present a variety of ways to compare vehicles and technologies, there may be other ways that consumers may want to compare vehicles.  To the extent that existing government websites do not facilitate these comparisons, the agencies will strive to offer other comparative metrics (such as energy/mile, which is essentially the MPG-equivalent approach used for some fuels) in the future.

4.4. Compressed Natural Gas Vehicles
                                                                            236
Organization: California Air Resources Board (CARB)
Comment:
California Air Resources Board (CARB)
We recommend that you add the vehicle's range to the compressed natural gas (CNG) label. [EPA-HQ-OAR-2009-0865-7527.1, p.5]
We suggest that you remove the gas pump from the CNG label and only include an icon for CNG. The gas pump may cause consumers to believe the car can run on both gas and CNG. [EPA-HQ-OAR-2009-0865-7527.1, p.5]
Response:
EPA agrees with CARB that the label for CNG vehicles should include the vehicle range, and as such the final regulations require driving range on the label.  The display of driving range will be identical to the range display for other dedicated alternative fuel vehicles, such as EVs and fuel cell vehicles.  While consumers are used to understanding the typical driving range that can be achieved by conventional gasoline and diesel vehicles, EPA believes that it is important that consumers understand the driving range of alternative fuel vehicles, especially in cases where the range is less than the typical gasoline vehicle and where refueling opportunities are more limited.  We also agree with CARB that using a traditional gas pump to represent CNG vehicles may be potentially misleading, and as such we are finalizing labels that use a unique icon to indicate that the vehicle is fueled by CNG.

4.5. Dual Fuel Natural Gas & Gasoline Vehicles
                                                                            237
Organization: Natural Gas Vehicles for America (NGVAmerica)
Comment:
Natural Gas Vehicles for America (NGVAmerica)
Dual-Fueled CNG Vehicles [EPA-HQ-OAR-2009-0865-6921.1, p.8]
The notice indicates that since there is only one OEM NGV currently available and that vehicle is a dedicated vehicle (Honda Civic GX), there are no plans to propose a label for dual-fuel CNG vehicles. However, the notice includes an extensive discussion of requirements and proposed changes to the labels for dual-fuel E85 vehicles. Much of the discussion is relevant to CNG dual-fueled vehicles. The current label for dual-fuel vehicles does not require that manufacturers provide any information on the fuel economy of the vehicle when operating on the alternative fuel. This is because EPCA only requires information on the fuel economy of the dual-fuel vehicle when operating on gasoline. Manufacturers, however, may voluntarily include the alternative fuel's fuel economy on the label. EPCA does require that the Fuel Economy Guide (which is published by DOE) include information about the fuel economy, performance and driving range of the vehicle when operating on the alternative fuel. [EPA-HQ-OAR-2009-0865-6921.1, p.8]
The notice includes two alternative approaches for dual-fuel vehicles: 1) keep the current label format; 2) require inclusion of additional information, including the fuel economy of the vehicle when operating on the alternative fuel. [EPA-HQ-OAR-2009-0865-6921.1, p.8]
In anticipation that additional NGV models, including dual-fuel vehicles, will be made available in the future, we offer the following comments on the dual-fuel labels. We support revising the current labels so that they include fuel economy and emission performance data of the vehicle when operating on the alternative fuel as well as gasoline. The need for such information should be without question. Consumers of such vehicles need to understand how the vehicle will perform on alternative fuel. How else can they make an educated decision regarding the merits of owning and operating such vehicles? The alternative fuel information should be provided in a font size that is at least as large, or perhaps even larger than, the information displayed for gasoline operation. Providing this information should be mandatory not discretionary. As to how the information is depicted and how the ratings are done, we have addressed those issues elsewhere in this document (e.g., show MPGe and show total energy, show tailpipe GHG emissions and upstream emissions or simply show full fuel cycle GHG emissions, rating comparisons should be within class not to average vehicle). [EPA-HQ-OAR-2009-0865-6921.1, p.9]
Response:
The agencies are not finalizing a label for dual-fueled CNG vehicles, consistent with the proposal.  However, should such a vehicle enter the market, the label will likely be modeled upon the dual-fuel gasoline-ethanol label described in this final rule.  The agencies have chosen to finalize labels that do not mandate the display of information relating to the alternative fuel, rather, we have made it optional to display the driving range of both fuels on the label.  Although manufacturers have not typically used the current option to display MPG on both gasoline and ethanol, such comparative information has been available on a label required by the FTC for alternative fuel vehicles.  EPA believes that providing the option to display driving range on both fuels will enable the FTC to reevaluate their requirement and potentially allow manufacturers who choose to put the optional information on their labels to avoid the duplication of the FTC label.  If this becomes the case, then we believe that manufacturers will take advantage of the ability to consolidate information and use the option to include comparative driving range information on dual-fuel vehicle labels.  The agencies found that the available space on the label is simply insufficient to provide all information - from mpg to fuel cost and greenhouse gas emissions and ratings, etc. - for each fuel that the vehicle can operate on.  As the commenter notes, some of this comparative information is available in the Fuel Economy Guide and on www.fueleconomy.gov, and the agencies expect to continue the practice of providing complete information for each fuel for dual-fuel vehicles.  This includes the various new ratings on the new labels.
Finally, the agencies chose not to finalize a label for dual-fuel CNG-gasoline vehicles because there are no such vehicles being certified today.  The agencies would rather address a label for this technology approach in a way that allows some flexibility to address any potential unique characteristics of the technology when it does come to market, rather than locking in a label that might not work for a future and potentially unforseen way of combining CNG and gasoline operation.

4.6. Miscellaneous
                                                                            239
Organization: Argonne National Laboratory
Comment:
Argonne National Laboratory
Label Scope and Objective
A label shall provide the following important information: fuel usage, electricity usage, operational fuel and electricity usage costs, greenhouse gas emissions, criteria pollution (smog-forming pollution).  Of course the above vary according to vehicle mode and usage scenario. [EPA-HQ-OAR-2009-0865-7572.1, p. 2]
How should this information be given? There are two ways to express the above data on a label.  However, a decision is to be made for each parameter how that information is expressed. 1. Data expressed in a way to allow easy relative comparisons to other vehicles. 2. Data expressed that can and will be experienced by the consumer. For a given piece of information (in given usage scenario), it must be decided if the information is used to compare vehicles or to predict the consumer experience. [EPA-HQ-OAR-2009-0865-7572.1, p. 2]
Response:
This comments were made as part of a short Powerpoint presentation that gave specific comment not on the label rulemaking, but on the interim label that appeared on the 2011 Chevrolet Volt.  That label was modeled largely after "Label 2" in the proposed rulemaking.  In general for the Volt and other PHEVs, the commenter will find that the final label does in fact include most of the elements they recommend.  The label includes both a metric that can be used to compare to other vehicles and technologies (MPGe) and a metric that is an estimate of real-world energy consumption in units relevant to how the consumer purchases the fuel (kwhrs per 100 miles for electricity, and gallons per 100 miles for gasoline).

4.6.1. Other Advanced Technology Vehicles
                                                                            240
Organization: Association of International Automobile Manufacturers (AIAM)
Hyundai Motor Company
Toyota
California Air Resources Board (CARB)
California Fuel Cell Partnership
Energy Independence Now (EIN)
Abbat, Pierre
Comment:
Abbat, Pierre
There should also be a sample label for hydrogen cars, for when they become available. Hydrogen will be sold in kilograms. [EPA-HQ-OAR-2009-0865-7588, p.1]

Association of International Automobile Manufacturers (AIAM)
With respect to the advanced technologies covered by the proposal, AIAM believes EPA and NHTSA should include labels for fuel cell electric vehicles along with other advanced technologies covered by the proposal. [EPA-HQ-OAR-2009-0865-7134.1, p.4]

California Air Resources Board (CARB)
We recommend that you develop a label for hydrogen fuel cell vehicles during this rulemaking process. Hydrogen fuel cell vehicles are already certified in California and will be coming in greater numbers by mid-decade. [EPA-HQ-OAR-2009-0865-7527.1, p.2]
We also recommend that you develop a label for  hydrogen fuel cells during this rulemaking.  Hydrogen  fuel cell vehicles are certified in California and will  be coming in greater numbers by mid-decade.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 133.]

California Fuel Cell Partnership
We commend the EPA and NHTSA for the work that went into the proposed changes to the motor vehicle fuel economy label. We did, however, notice the absence of a label for hydrogen fuel cell vehicles. With one fuel cell vehicle certified by the EPA and the anticipation of more as we move towards commercialization it is essential that the consumer be able to compare these vehicles utilizing a similar fuel economy label. [EPA-HQ-OAR-2009-0865-6852.1, p. 1]
We strongly recommend that the EPA and NHTSA develop a fuel economy label for hydrogen fuel cell vehicles, as the electric vehicle label is clearly for plug-in battery electric vehicles and will not fulfill the needs of the upcoming hydrogen fuel cell vehicle fleet. Again, we appreciate the work that has gone into the proposal and the opportunity to comment, and look forward to the proposed label for hydrogen fuel cell vehicles. [EPA-HQ-OAR-2009-0865-6852.1, p. 1]

Energy Independence Now (EIN)
Along those lines, in our review of the  proposed labels, we note one glaring hole; that there is  no label for hydrogen fuel cell vehicles.  While we  believe this was likely an oversight, we want to stress  the importance of preparing for the deployment of fuel  cell electric vehicles into our national fleet.  According to the California Fuel Cell  Partnership's most recent annual survey of its members,  we can expect approximately 450 fuel cell vehicles to be  on the road by ; 4,200 by 2015; and 54,300 by 2018.  And they won't be, obviously, available in every area at  first, but we can expect availability to expand each  year, and so we think it's important to be prepared.  Furthermore, the Honda Clarity fuel cell  vehicle has already been -- had its fuel economy  certified.  And at the recent Chicago public hearing  Hyundai hinted that they intend to deploy commercial  fuel cell vehicles in 2012, which is in the time frame  of this label.  And the majority of other OEMs also  maintain programs aimed at commercial deployment. So that's my first point, that EPA should  develop hydrogen fuel cell labels, in this label  development effort, to facilitate the smooth transition  of this important low-emission technology into the  marketplace.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 120-121.]

Hyundai Motor Company
We recommend that EPA move forward in this rulemaking with a method to assess the fuel efficiency of fuel cell vehicles. This technology has been in development for many years and is well understood at this point so that a methodology can be developed now in anticipation of the introduction of these vehicles. We prefer that the label methodology be available well in advance of when these vehicles are introduced. [EPA-HQ-OAR-2009-0865-7139.1, p.6]
MR. MEDFORD: And then you also said -- I missed the time for the introduction of the fuel cell vehicle that you said there should be a special label provided. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 87]
MS. BAKKER: We intend to use some fuel cell vehicles on a small scale in 2012. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 87]
MR. MEDFORD: As a part of your regular retail sales or demonstration program? [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 87]
MS. BAKKER: Perhaps beyond a demonstration program. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 87]

Toyota
EPA and NHTSA' s NPRM addresses label designs that are more appropriate for advanced technology vehicles that will be commercialized in the next few years -namely EVs and PHEVs. As the agencies are redesigning labels, Toyota would like to see label designs address fuel cell technology vehicles. Even though commercialization may be a little farther off for these vehicles, addressing the requirements of this technology now would be another positive step toward promoting the awareness and introduction of these vehicles. [EPA-HQ-OAR-2009-0865-6901.1, p.8]
Response:
While EPA did not propose explicit labels for hydrogen fuel cell vehicles (FCVs), we are including a label design for FCVs in the final rule. The agencies agree with the commenters. In fact, several fuel cell vehicles have already been certified and labeled by EPA.  Because the label design issues for FCVs are very similar to those for other dedicated, non-petroleum vehicles such as CNG vehicles and EVs, a general label design is readily available to serve as the basis for an FCV label.  Like EVs, the overall efficiency metric will be in MPGe terms, with consumption provided in units of kilograms of hydrogen per 100 miles. Also like EVs and other dedicated alternative fuel vehicles, the label for FCVs will include the driving range of the vehicle.  However, EPA did not propose, and is therefore not finalizing, fuel economy and range test procedures for FCVs. Test procedures will continue to be as specified by EPA under the authority of 40 CFR 600.111-08(f), which allows the Administrator to prescribe "special test procedures" under certain circumstances. However, EPA expects to continue to specify the use of SAE J2572, ("Recommended Practice for Measuring Fuel Consumption and Range of Fuel Cell and Hybrid Fuel Cell Vehicles Fuelled by Compressed Gaseous Hydrogen"). Manufacturers of FCVs should continue to work with EPA to ensure that the procedures are applied according to EPA requirements.
Organization: U.S. Coalition for Advanced Diesel Cars
F., Nick
Comment:
F., Nick
I think you need a separate sticker design for a Prius and for a Chevrolet Volt. The technology is different, and having them both covered by one sticker could lead to confusion for the consumer. For the Prius you need to talk about blended electric and gas driving, but for the Volt you can get away with the simpler idea of an electric mode and a gas mode. [EPA-HQ-OAR-2009-0865-1323, p.1]

Organization: U.S. Coalition for Advanced Diesel Cars
Comment:
U.S. Coalition for Advanced Diesel Cars
Separate Labels for Diesel and Gasoline Vehicles will Provide Consumers with More Accurate Fuel Economy Data. [EPA-HQ-OAR-2009-0865-7130.1, p.7]
Clean diesel vehicles, on average, provide consumers with at least 30% better fuel economy over conventional gasoline vehicles and a 25% reduction in GHG emissions. These numbers are similar to the benefits provided by Flex Fueled Vehicles (FFV). The Agencies have decided to propose different labels for a variety of different technologies including Electric, Plug-in Hybrid Electric, Flex Fuel, and Compressed Natural Gas. Yet, the Agencies have decided to place Diesel-powered vehicles onto the same label with conventional gasoline cars, which leads the consumer to believe there is no difference between the two technologies. [EPA-HQ-OAR-2009-0865-7130.1, p.7]
The Coalition believes that the fuel economy savings and the reduced GHG emissions of diesel powered vehicles warrant a separate label or a label that distinguishes and compares the fuel economy and GHG emissions of diesel vehicles to gasoline models to better inform consumers. Providing a direct comparison will also bring the new labels closer to compliance with the requirements of EISA. [EPA-HQ-OAR-2009-0865-7130.1, pp.7-8]
Response:
Although the agencies are finalizing labels that do in fact make a distinction between diesel and gasoline vehicles, it is unclear how the commenter would have the diesel labels differ from gasoline labels. While the finalized labels prominently identify diesel vehicles, the metrics on the label are fundamentally the same as those for other vehicles using liquid fuels. The agencies believe that the labels accomplish what the commenter is requesting by having the comparisons on the label (MPG, CO2, and smog) be relative to all vehicles, including gasoline and other technologies.
Organization: American Council for an Energy-Efficient Economy (ACEEE)
Comment:
American Council for an Energy-Efficient Economy (ACEEE)
Advanced Technology Vehicle Labels
EPA notes that "the issues associated with and the decisions that we make about labels will go a long way toward preparing us to address labels from other advanced technologies in the future." Knowing how decisions made in one context can carry forward, to bad effect, to entirely different circumstances, we strongly support this observation and urge the agencies to treat advanced technology vehicles in a way that makes sense not only for the vehicles appearing in the market today but also for those yet to arrive. ACEEE supports the principles the agencies set out for advanced technology labels, including objectivity, balance of accuracy and simplicity, equity across technologies, and ability to reduce confusion. We do not believe the agencies proposal is uniformly consistent with these principles, however. [EPA-HQ-OAR-2009-0865-7135.1, p. 4]
Response:
The agencies appreciate ACEEE's support for our general stated principles.  The agencies have responded to ACEEE's specific concerns that the proposal does not meet the stated principles in the appropriate sections of this document.

4.6.2. Technology Neutrality
                                                                            245
Organization: BorgWarner
Comment:
BorgWarner
As a supplier of multiple advanced technologies, BorgWarner supports a technology neutral approach. We believe there is no single `silver bullet' technology or powertrain that will work for all consumers.  It will take a combination of several advanced technologies to meet the varied needs of consumers seeking more fuel efficient and environmentally friendly vehicles. [EPA-HQ-OAR-2009-0865-7531, p.1]
Response:
The agencies acknowledge the comment from BorgWarner.  There are many new and promising technologies coming to the marketplace, and that it will take a combination of these technologies to meet the needs of consumers.  The final label rule and the greenhouse gas rating system were designed to be technology neutral and to apply to a technologically diverse light duty fleet.

5.1. URL on Label 1
                                                                            246
Organization: Association of International Automobile Manufacturers (AIAM)
Environmental Defense Fund (EDF)
Hyundai Motor Company
Massachusetts Institute of Technology
Electric Drive Transportation Association (EDTA)
Tesla Motors
Scarborough, Christina
Comment:
Association of International Automobile Manufacturers (AIAM)
AIAM supports the continuation of the "MPG" metric on the label, since most consumers are familiar with it. However, AIAM also supports the inclusion of a fuel-consumption metric on the label. We agree that this type of metric is new to most consumers. Nevertheless, given the significant new standards for greenhouse gases and fuel economy for the 2012-2016 MY and the need for even more stringent standards in the future, it is more important now than ever before to educate and inform consumers about fuel efficiency. We believe that a tutorial on the relevance and use of this new metric would be a worthwhile addition to the "fuel economy" website. [EPA-HQ-OAR-2009-0865-7134.1, p.4]
AIAM agrees with the agencies' assessment that many consumers use the Internet to gather information to make vehicle purchase decisions, and AIAM supports the inclusion of the fuel economy website address on the new label. It is also important for federal and state agencies to have consistent information on their websites to avoid consumer confusion. [EPA-HQ-OAR-2009-0865-7134.1, p.4]

Electric Drive Transportation Association (EDTA)
Other sources of information  -  especially the internet  -  also play an increasingly important role as a source of information for consumers. The key to a successful redesign of the window label is to re-think the role of the label: it is one tool in the toolkit; it is not the sole, or even primary, means of educating the consumer. The label should be used to highlight key facts, while directing the consumer to other sources with more detailed information, including www.fueleconomy.gov. [EPA-HQ-OAR-2009-0865-7137.1, p.1]

Environmental Defense Fund (EDF)
Innovative Outreach Campaign Important in Light of Changing Purchase Process [EPA-HQ-OAR-2009-0865-6927.1, p.9]
As discussed above, the purchase process for most consumers has changed, beginning earlier and off the lot. Because consumers are arriving at the dealerships already armed with information, it is important that EPA make efforts to provide the fuel economy label and related information to consumers earlier in the purchase process. We support the EPA's proposal to drive consumers to EPA's website. Specifically, we support the expert panel's idea for EPA to develop a "simple" URL- something consumers can easily remember and conveys a message in the URL itself. [EPA-HQ-OAR-2009-0865-6927.1, p.9]

Hyundai Motor Company
Fourth, EPA proposes to prominently add the fuel economy website address on label Option 1 based on the assumption that consumers may use the Internet for gathering information to make their vehicle purchase decisions. Hyundai supports the inclusion of this information but recommends reducing the size of the font and moving the website information to near the bottom of the label (see Figure 3 for a depiction) to provide additional space for other fuel efficiency information. [EPA-HQ-OAR-2009-0865-7139.1, p.4]
Fifth, Hyundai supports the addition of a fuel consumption metric, like gallons per 100 mile, on the label but also believes that the actual mpg data should be emphasized. Fuel consumption is an important tool for informing consumers about a vehicle's fuel usage, though it may not be easily understood in the initial years. MPG, on the other hand, remains the best known metric and should be readily available to the consumer. City and highway data should continue to be the main fuel economy information on the label, because consumers are familiar with these metrics. City and highway data also allows consumers to estimate their fuel economy based on their predominant driving mode, whereas combined MPG is limited to a single value and nondescript driving mode. Combined data should be limited to model-to-model fuel economy comparisons. We are including two suggestions in Figure 3 that emphasize the city and highway MPG data, include the fuel consumption metric, and use the combined MPG value for comparison to other vehicles only. [EPA-HQ-OAR-2009-0865-7139.1, p.4]

Massachusetts Institute of Technology
We also endorse the agencies' proposal to develop more robust web- - -based tools and encourage the agencies to explore additional avenues for disseminating fuel economy and emissions information online. [EPA-HQ-OAR-2009-0865-5849.1, p.1]
As noted above, it is understandable that a single, nationwide label cannot encompass the full range of operational characteristics, electricity prices, and CO2 emissions that a consumer might experience. With this in mind we endorse the agencies' proposal for a web-based tool to assess CO2 emissions and fuel costs based on individual circumstances. This would preserve the simplicity of the label while making more detailed information available to those who want it. We have previously endorsed the idea of revamping the fueleconomy.gov website in our report, An Action Plan for Cars (MIT, 2009). [EPA-HQ-OAR-2009-0865-5849.1, p.3]
Finally, we would like to draw the agencies' attention to another recommendation in our Action Plan for Cars report: the development of an online analogue to the current labeling program. More than half of consumers currently rely on the Internet, and manufacturer websites in particular, for researching vehicle purchases, yet fuel economy values often remain difficult to find on manufacturer websites and are not displayed in a standardized format. We therefore recommend an online labeling scheme that requires city and highway fuel economy estimates to be displayed in a standardized format on manufacturer websites, along with a link to the fueleconomy.gov website. We believe that this would ensure consumers have access to reliable fuel economy and cost information at a sufficiently early stage in their purchasing processes. We encourage the agencies to evaluate their authority to require such a program, or to develop such a program voluntarily with the automotive manufacturers. [EPA-HQ-OAR-2009-0865-5849.1, p.3]

Scarborough, Christina
And I do think -- I love the idea of having a  Web site.  A lot of young people are really interested  in the Web.  I could literally -- I have a smartphone,  so I could be standing in front of that car, I could  'google' the Web site, and I could look up information  about my local area, and that would be it.  I would be  done.  And I would be fully educated through this  process.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 156.]

Tesla Motors
Detailed information, especially information that is highly specific to individual customer use patterns, should not be on the label, but readily accessible in other locations, such as an interactive website or other available portals; therefore, information such as recharge times for electric vehicles and new metrics like kilowatt per hundred miles ("KWh/100 miles") should appear on the website versus the labels. [EPA-HQ-OAR-2009-0865-6933.1, p.2]
To the extent that EPA and NHTSA employ new metrics, Tesla would encourage the Agency to place that new information in appropriate context. For example, EPA and NHTSA have noted the flaws with MPG. The Agencies propose that a gallons/100 mile is a more appropriate metric. Similarly, use of a KWh/100 mile metric for electric vehicles ("EVs") and plug-in hybrid electric vehicles ("PHEVs") may also provide more accurate information to consumers and allow for comparisons of the efficiency of various advanced technology vehicles ("ATVs") so equipped. As a result, Tesla agrees that new and more accurate information can be helpful, but as new information without prior precedent for consumers, the Agencies must be careful to ensure that introduction of the information is accompanied by an education campaign as well so that consumers may fully appreciate the messaging from this information. Such education may be best left off the label, at least initially, and, instead, provided in a location where greater explanation and background can be provided, such as a website. As consumers become more familiar with new metrics, these more accurate values may be shifted over to the label in conjunction with familiar metrics such as MPG and MPGe. [EPA-HQ-OAR-2009-0865-6933.1, p.3]
Moreover, research by consumer groups such as Edmunds and the American Automobile Association demonstrates that the vast majority of consumers conduct much of their research on car purchasing decisions before visiting dealerships and stores. As a result, Tesla believes that the use of external locations, such as websites maintained by the Agencies, provides EPA and NHTSA with the greatest opportunity to present more detailed information about specific vehicle models and technologies, as well as educating consumers on new metrics. [EPA-HQ-OAR-2009-0865-6933.1, p.3]
Use of websites can both enhance information on the labels as well as provide information that is not appropriate for labels. For example, with respect to the former issue, EPA and NHTSA have suggested inclusion of maximum range for EVs on the fuel economy label. Inclusion of range on the label is appropriate if based on driving cycles that best exemplify real world driving. Even then, range may vary greatly from driver to driver depending on use and driver preferences. Accordingly, use of an interactive website where drivers can select a variety of inputs such as distance, location (i.e., city vs. highway), and driver preferences (e.g., faster vs. slower acceleration, heating/air conditioning use, etc.) may assist in educating drivers about ranges that can be expected. Tesla also advocates use of a website to further educate consumers about new metrics. As noted above and as outlined in greater detail in the NPRM, use of the metric gallons/100 miles is more accurate than the traditional MPG. Use of the website to further explain this principle, as well as providing a context in which consumers can convert to this new metric is best accomplished through a website versus labeling. [EPA-HQ-OAR-2009-0865-6933.1, pp.3-4]
Response:
The agencies have decided not to launch a new website in support of the final rule publication and the roll out of the new labels.  The website content on the new label will be highlighted on and integrated within the government's existing comprehensive vehicle web site - fueleocnomy.gov.  The agencies decided that fueleconomy.gov already had brand equity with the general public and has many of the tools consumers need to make informed vehicle purchases. To coincide with the launch of the new label, fueleconomy.gov will include an enhanced emissions calculator that will allow consumers to determine a vehicle's potential upstream greenhouse gas emissions, based on regional electricity emissions rates for electric vehicles, and the electric operation of PHEVs.  This functionality will give consumers more accurate upstream emissions information than is possible on a static, national label. The QR code on the label will allow smartphone users to upload vehicle specific information from the web site on their handheld devices once the label is implemented in MY 2013.
Organization: California Air Resources Board (CARB)
Comment:
California Air Resources Board (CARB)
We do not recommend launching a new web site specifically for this new label. As you state in the NPRM, www.fueleconomy.gov received 30 million hits in 2008. This is a significant number of hits showing that a lot or people use this site for fuel economy related information. In addition, we have found from our own research that people trust a dot gov over a dot com for this type of information. We suggest making fueleconomy.gov the one-stop shop for all label related information as well as providing the tools and resources consumers need to find the cleanest, most efficient car to meet their needs. [EPA-HQ-OAR-2009-0865-7527.1, p.4]
We also don't think you should introduce a new  Web site.  I know that was one of the items.  The  fueleconomy.gov Web site is very well-known to consumers  and is a trusted source of information.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 133.]
Response:
The agencies have decided not to launch a new website in support of the final rule publication and the roll out of the new labels.  The website content on the new label will be highlighted on and integrated within the government's existing comprehensive vehicle web site - fueleocnomy.gov.  The agencies decided that fueleconomy.gov already had brand equity with the general public and has many of the tools consumers need to make informed vehicle purchases. To coincide with the launch of the new label, fueleconomy.gov will include an enhanced emissions calculator that will allow consumers to determine a vehicle's potential upstream greenhouse gas emissions, based on regional electricity emissions rates for electric vehicles, and the electric operation of PHEVs.  This functionality will give consumers more accurate upstream emissions information than is possible on a static, national label. The QR code on the label will allow smartphone users to upload vehicle specific information from the web site on their handheld devices once the label is implemented in MY 2013.
Organization: California New Car Dealers Association
Comment:
California New Car Dealers Association
Our interest, and the importance of our  testimony, stems from the fact that dealership sales  staff is tasked with explaining vehicle-related features  to consumers.  Consumers who read governmental  disclosure on new vehicles rarely call NHTSA or EPA or  CARB with questions, and you can't really expect them to  visit agency Web sites for further information, although they may do so.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 62-63.]
Response:
The website content on the new label will be highlighted on and integrated within the government's existing comprehensive vehicle web site - fueleocnomy.gov.  The agencies decided that fueleconomy.gov already had brand equity with the general public and has many of the tools consumers need to make informed vehicle purchases. The agencies also plan to provide outreach information designed specifically for car dealerships, as we realize the important role that dealers play in educating consumers about the new label.
Organization: Edison Electric Institute (EEI)
Comment:
Edison Electric Institute (EEI)
Metrics that are unfamiliar to consumers and require explanatory information are more appropriately made available on a website, as proposed. See id. at 58084. Similarly, usage and performance estimates that will vary greatly among different types of users, such as driving range and charging/refueling time, should be available in a customizable format on the website to ensure that consumers can access information that is relevant to their anticipated needs and uses, rather than rely on a static average developed for the label. EPA and NHTSA should involve stakeholders in the design of this website and make provisions to ensure that the information it provides to potential customers is regularly updated. [EPA-HQ-OAR-2009-0865-7117.1, p.4]
Labels should include a prominent link to the website. In addition to the data described above, this website should provide an interactive format that allows the consumer to customize projections based on their own likely usage of the vehicle. For example, the website should allow the consumer to enter data about their vehicle usage patterns and receive projections of fuel economy, vehicle range, charging and/or refueling times, and other matters based on those assumptions. Effective use of the website is the key to achieving a simpler label while also giving consumers access to detailed information about their likely personal experience with a vehicle. [EPA-HQ-OAR-2009-0865-7117.1, pp.4-5]
Response:

5.2. Fuel Economy Guide
                                                                            252
Organization: California Air Resources Board (CARB)
Comment:
California Air Resources Board (CARB)
The Fuel Economy Guide is a great resource with a lot of good information, but we agree it may be more useful to also include or have available a checklist that lays out in a simple format what consumers should consider when buying a new car or, as stated in the NPRM, a list of the top ten points on fuel economy or a sort of 'cheat' sheet on the new label with this top ten list. [EPA-HQ-OAR-2009-0865-7527.1, p.4]
With so many people doing research on the internet, a hard copy version of the fuel economy guide seems redundant and a waste of resources. The vehicle information in the guide is much better served as an online tool. We support replacing the guide with something shorter and more interesting that dealers can easily have on site to hand out to consumers as they are looking at cars and asking about the new label. [EPA-HQ-OAR-2009-0865-7527.1, p.4]
Response:
EPA agrees that the Fuel Economy Guide is not being utilized as much by consumers now that they have access to the internet.  As we roll out the new label, and the accompanying comprehensive web site, we plan to provide both dealerships and their customers with outreach materials better suited to today's culture.  We are planning to work with dealership associations and other partner organizations to determine what materials (a checklist?  a pocket guide?  a brochure?) would be most useful for the general public in addition to the Fuel Economy Guide.
Organization: Johnson, Evan W.
Comment:
Johnson, Evan W.
Regardless of What Sticker Format is Chosen, it should Clearly and Conspicuously Disclose if the Manufacturer Recommends or Requires Premium Gasoline for the Vehicle [EPA-HQ-OAR-2009-0865-7252.1, p.2]
The Fuel Economy Guide has for years clearly and conspicuously designated those vehicles for which the manufacturer recommends or requires the use of premium gasoline, as well it should because this is a key piece of information for consumers in assessing the fuel costs of a vehicle they are considering for purchase. The fuel economy labels for these vehicles make no note of the premium gas, however, other than to presumably use a higher gas price in calculating the annual fuel cost. That is a meaningless disclosure. The label need to clearly identify the premium gas usage, as the Guide does, because this is an ongoing cost that consumers will take into account long after they have forgotten the estimated annual fuel cost. This is a glaring omission in the labeling program that needs to be corrected now. [EPA-HQ-OAR-2009-0865-7252.1, p.2]
Response:
Due to all the information require to appear on the new labels, there was not sufficient room to include other options, such as "premium fuel recommended." Though this information will not appear on new label, we agree that this is valuable information for the consumer to have as they are engaged in vehicle research.  This information is currenlty available on the DOE/EPA joint fueleconomy.gov web site, and will be included on the new site, comparecars.gov, in support of the new vehicle labels.
Organization: National Association of Minority Auto Dealers (NAMAD)
Comment:
National Association of Minority Auto Dealers (NAMAD)
In this regard, please note that in addition to the fuel economy labels which have existed in one form or another for some years, franchised dealers also make available to prospective purchasers an annual fuel economy guide issued by the Department of Energy, DOE. In fact, we will start making the model year 2011 version of the guide available this week. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 40-41]
Response:
EPA appreciates the support the dealerships provide in distributing the Fuel Economy Guide.  Now that consumers have access to and do most of the research on the internt, EPA is planning to develop resources that better meet the general public's need for vehicle information.  As we roll out the new label, and an accompanying comprehensive web site (comparecars.gov), we plan to provide dealerships and their customers with outreach materials to educate them on these new tools.
Organization: National Automobile Dealers Association (NADA)
Comment:
National Automobile Dealers Association (NADA)
Distribution of the EPA/DOE Fuel Economy Guide [EPA-HQ-OAR-2009-0865-6940.1, p.9]
In its 2006 Fuel Economy Label Rule, EPA formalized the process used by dealers to provide prospective new vehicle purchasers with copies of the Fuel Economy Guide and with information regarding the www.fueleconomy.gov website. In fact, earlier this month NADA worked with DOE to provide dealerships with specifics on how to obtain and make available to the public electronic or paper copies of the MY 2011 Fuel Economy Guide. Dealerships typically print copies of the Guide upon demand, downloading them as needed. In addition, dealerships have the option of obtaining hard copies of the Guide, should they choose to do. [EPA-HQ-OAR-2009-0865-6940.1, p.9]
Response:
EPA appreciates the support the dealerships provide in distributing the Fuel Economy Guide.  Now that consumers have access to and do most of their research on the internt, EPA is planning to develop resources that better meet the general public's need for vehicle information.  As we roll out the new label, and an accompanying comprehensive web site (comparecars.gov), we plan to provide dealerships and their customers with outreach materials to educate them on these new tools.
Organization: Alliance of Automobile Manufactures (Alliance)
Comment:
Alliance of Automobile Manufactures (Alliance)
The focus on market segments is a well-established concept for vehicle fuel economy. In a recent press release announcing the 2011 Fuel Economy Guide, EPA and the U.S. Department of Energy note, [EPA-HQ-OAR-2009-0865-6850.2, p.9]
Fuel efficient models come in all types, classes, and sizes. The 2011 Fuel Economy Guide can help consumers easily identify the most fuel efficient vehicles that meet their needs. [EPA-HQ-OAR-2009-0865-6850.2, p.9]
The Fuel Economy Guide and the fueleconomy.com website already take a segment-specific approach, which is also consistent with other Federal models for ranking the GHG emissions and energy use of consumer products. For instance, EPA's Energy Guide website compares refrigerators to similar models within a class. [EPA-HQ-OAR-2009-0865-6850.2, p.9]
Response:
The agencies are finalizing a label that includes fuel economy relative to other vehicles in the same class.  All other rating systems on the label will be given relative to all vehicles in the fleet.  Each of the ratings systems on the label will be universal across all new vehicles, rather than broken out by vehicle class.  This approach was based on the text of the Energy Independence and Security Act requiring a rating "that would make it easy for consumers to compare the fuel economy and greenhouse gas and other emissions of automobiles at the point of purchase..."   In addition, many commenters supported the proposed approach of having universal rating systems that apply across all vehicle classes.  These commenters stated that most people shop in more than one class, and, therefore, a rating system that was solely within class was not particularly useful because it would not allow these consumers to compare the vehicles in which they had interest.  Commenters stated that a within-class approach could be misleading by displaying ratings that appear to be comparable but in fact are not, since ratings based on individual classes are not broadly applicable across all vehicles; they are applicable only within the class on which they are based.  As such, a within-class approach could assign a high rating to a vehicle that does relatively well within its class, but which emits at relatively high levels compared to vehicles in other, lower-emitting classes.  For example, a large car that is low-emitting relative to other large cars could score a 7, while a midsize car with average emissions for its class would score a 5, even though the midsize is lower-emitting than the large car.  With a purely within-class approach, the consumer who is considering both of these vehicles would have no way to know that the midsize car is a better environmental choice.

5.3. Smartphone QR Codes
                                                                            256
Organization: Association of International Automobile Manufacturers (AIAM)
Environmental Defense Fund (EDF)
Ford Motor Company (Ford)
Hyundai Motor Company
California Air Resources Board (CARB)
University of Pennsylvania Law School, Environmental Law Project
Bullis, Kevin
SapientNitro
Comment:
Association of International Automobile Manufacturers (AIAM)
AIAM supports the addition of the Smart Phone interactive codes on the label. Millions of Americans have Smart Phones and more and more consumers are using them every day to link to the Internet. [EPA-HQ-OAR-2009-0865-7134.1, p.4]

Bullis, Kevin
Smartphone interactive: Great idea. Maybe auto dealers should be required to provide Internet-connected kiosks for people without smartphones. Also, the website could be a chance to compare EV and hybrid carbon emissions taking into account power plant emissions in different regions. [EPA-HQ-OAR-2009-0865-3415, p.1]

California Air Resources Board (CARB)
We like the smart phone feature that allows consumers to access vehicle information using their smart phones while shopping on dealer's lots. [EPA-HQ-OAR-2009-0865-7527.1, p.2]

Environmental Defense Fund (EDF)
We also support the Agencies' proposal to use QR codes to assist consumers in obtaining more detailed information right from the car lot using their smart phones. [EPA-HQ-OAR-2009-0865-6927.1, p.9]

Ford Motor Company (Ford)
Smartphone QR Codes [EPA-HQ-OAR-2009-0865-7141.1, p.10]
Ford supports the idea of smartphone Quick Response codes as a new feature of the fuel economy label, given certain constraints. This is an innovative new way of transferring information to customers quickly and easily while they are still at the dealership. However, at this point, it is unclear exactly what website or information the code would link to. Ford requests that the linked information be standardized by focusing on the vehicle's particular attributes and not those of others in order to avoid potential competitive issues and unfair advertising. [EPA-HQ-OAR-2009-0865-7141.1, p.10]
In addition to the idea proposed in the NPRM, Ford believes that smartphone QR codes may be useful for conveying additional information to consumers. For example, Ford suggests that a QR code linked to the GREET calculation model could be a potential method of meeting the California environmental performance label requirements to include upstream emissions. [EPA-HQ-OAR-2009-0865-7141.1, p.10]

Hyundai Motor Company
Using Smartphone QR Codes' to link to Fuel Economy Information
Hyundai fully supports addition of a Smartphone Code on the fuel economy label. Smartphone technology is becoming commonplace, and having a quick and easy way for consumers to lookup additional information about a vehicle. In the suggested label changes in Figure 3 [See p.5 of this comment summary for Figure 3 entitled, Suggested Changes to Label Options 1 and 2], we modified the location of the Smartphone QR Code to make room for other information, but the new area allows the size to be slightly increased and should still be easily found by the consumer. [EPA-HQ-OAR-2009-0865-7139.1, p.12]

SapientNitro
As a creative director at an interactive advertising agency, I FIRMLY believe that the QR code (the smartphone barcode) on Label Option 2 is BRILLIANT. I think you need to take that smartphone code and incorporate it into Lable Option 1. Label Option 1 is gorgeous and simple and pedestrian  --  easy to understand. The other is too cumbersome. It would be IDEAL if you produced Label Option 1 and enabled viewers to take that label information with them by snapping a photo of the label with their smartphones that would read the QR code and store the specs in your phone. [EPA-HQ-OAR-2009-0865-1407, p.1]

University of Pennsylvania Law School, Environmental Law Project
Finally, we recommend that the smart phone label be moved to the same section as cost savings. Many consumers are likely to have concerns about the usefulness of the cost savings figure since it is based on averages and therefore is not individualized. By placing the smart phone label next to the savings figure, consumers with a capable mobile device who have these concerns may immediately link to the Fuel Economy website for a more personalized and detailed calculation. This cost-savings calculator would allow them to customize an estimate based on personal driving habits as well as local variations in fuel prices and the availability of alternative fueling stations. Personal driving information may include annual or monthly mileage and proportional travel on highway and local roadways. The zip code algorithm would not only account for the variations in fuel cost, but may also account for variations in weather that may affect fuel efficiency. [EPA-HQ-OAR-2009-0865-7171.1, pp.7-8]
Response:
Thank you for your support of including a smartphone access code on the new label.  In order to address consumers' growing interest in having information accessible via smartphones, EPA is including a QR Code(R) on the new label.  When a smartphone user scans the QR Code(R) on the label, information on that particular vehicle from fueleconomy.gov web site will be displayed on the handheld device. Though several commenters suggested linking to the auto manufacturers' vehicle-specific web sites from the QR Code(R), EPA determined that linking to a government web site was the best way to provide consumers with "just the facts."  The content will be similar to what will be available on the label web page on fueleconomy.gov, but geared to a smartphone platform.  The user can then take advantage of many of the web site's tools and vehicle comparisons from his/her phone while shopping at a dealership.

Organization: JAGTAG, Inc
Comment:
JAGTAG, Inc
Introduction: JAGTAG, Inc. appreciates the opportunity to provide written comments to the "Revisions and Additions to Motor Vehicle Fuel Economy Label." JAGTAG has been involved with 2D barcodes since 2007 and has developed a multimedia messaging platform that uses picture messaging to receive and decode 2D barcodes and send back the proper multimedia or text to mobile phones. Unlike most 2D barcode solutions, JAGTAG delivers multimedia, text and URL (Uniform Resource Locator) to both standard phones and smartphones without installing an application. Our comments will address the proposed "symbol (2D barcode) that can be read by a `Smartphone' for additional consumer information (also known as a QR Code (R))." We are excited by the prospect of utilizing mobile devices to transmit additional information to consumers. We recommend that the Motor Vehicle Fuel Economy Label include a 2D barcode that can be accessed by ALL mobile devices, not just smartphones. [EPA-HQ-OAR-2009-0865-6568.1, p. 1]
Background: The QR Code (R) is a 2D barcode with an embedded URL which, when scanned by the proper application, provides a link to that URL. This category of 2D barcodes requires the device to download the scanning application and access the Internet (URL). Only properly equipped smartphones can scan this type of 2D barcode (QR Code(R)). However, there is a separate category of 2D barcodes that can be accessed by all types of mobile devices including standard phones that do not have mobile Internet plans or scanning applications and smartphones that are Internet enabled. JAGTAG has developed a technology that utilizes a multimedia messaging (MMS) platform to deliver and decode 2D barcodes on standard phones and smartphones that support MMS. In addition, while QR codes (R)can only link to one URL, the JAGTAG MMS platform can deliver a variety of information mediums, including multimedia video, audio and pictures; text; and URL options. [EPA-HQ-OAR-2009-0865-6568.1, p. 1]
Furthermore, the technology developed by JAGTAG has the ability to identify the consumer's device and discern its capabilities. This allows the platform to cater a reply message to the user at the maximium impact for the minimal cost to the user. For example, a standard phone that does not have Internet access can receive text, pictures and/or video, while a smartphone can receive text, pictures, video and a URL. Thus, JAGTAG technology is able to provide a broader range of information (ex: additional consumer information in multiple languages) to a more comprehensive consumer base than the QR Code (R). [EPA-HQ-OAR-2009-0865-6568.1, p. 1]
We recommend that the new Motor Vehicle Fuel Economy Label include a 2D barcode that can be accessed by both smartphones and standard phones through MMS messaging (in place of QR Codes(R))to effectively link more consumers to fuel economy information. [EPA-HQ-OAR-2009-0865-6568.1, p. 1]
Initial Observations: Prior to our more specific recommendations, we have three initial observations which we believe, if addressed, would help make the proposed revisions to the fuel economy label more effective: 1. Include a headline informing consumers what the label's barcode symbol is supposed to do, such as "Scan this code to get comparison fuel information." Many consumers will not know what a 2D barcode is and may ignore it without direction.  2. Provide instructions on how to utilize the label's barcode.  3. These initial instructions will add a perceived value to the label by encouraging consumers to utilize the barcode and access more information. [EPA-HQ-OAR-2009-0865-6568.1, pp. 1-2]
Recommendations:  As referenced in the Proposed Rule (Section I. A. Summary of and Rationale for Proposed Label Changes), all of the label designs co-proposed by EPA and NHTSA include:  A symbol that can be read by a `Smartphone' for additional consumer information (also known as a QR Code(R)).   The intent is "to use the QR Code to directly link the user's Smartphone to vehicle-specific information while providing additional tools for making vehicle comparisons, learning more about the vehicle etc." (Section VI, 4, D, Using Smartphone QR Codes (R) to Link to Fuel Economy Information). [EPA-HQ-OAR-2009-0865-6568.1, p. 2]
The stated intent of the joint proposal is to increase the usefulness of the label in helping consumers choose more efficient and environmentally friendly vehicles/make more informed vehicle purchase decisions. We believe that an important public policy addition to these stated goals is to provide consistent and equitable access to information to all consumers. Including a 2D barcode on the fuel economy label could provide consumers with additional information, but the QR Code as that 2D barcode option DOES NOT effectively provide that information to all consumers, because this information would only be available to at most 20 percent of U.S. mobile phone owners (percentage of U.S. mobile phone owners who own Smartphones). [EPA-HQ-OAR-2009-0865-6568.1, p. 2]
We recommend that the new Motor Vehicle Fuel Economy Label include a 2D barcode that can be accessed by both smartphones and standard phones through MMS messaging (in place of a QR Code (R) specified in Section VI, 4, D-Using Smartphone QR Codes (R) to Link to Fuel Economy Information) to effectively link more consumers to fuel economy information. Specifically, we strongly recommend that the new Motor Vehicle Fuel Economy Label include a JAGTAG 2D barcode. We recommend that this 2D barcode provide links to additional consumer information in multiple languages to allow access to non-English readers.  If EPA/NHTSA does not implement this alternative 2D barcode option, we recommend no barcode over the inclusion of a QR Code. It is not equitable to provide access to additional information only to a small portion of consumers. All consumers deserve access to this information before making a decision about their purchase. The QR code effectively prohibits over 80 percent of mobile phone owners from accessing content. Alternatively, JAGTAG technology can provide access to 90 percent of mobile phone owners. No other 2D barcode delivers to as many people in the United States. [EPA-HQ-OAR-2009-0865-6568.1, p. 2; see pp. 3-10 for additional detailed information on the limitations of QR Codes (R), the advantages of JAGTAG 2D barcode technology, a free dome of JAGTAG technology, and mock ups of the proposed fuel sticker with the JAGTAG barcode.]
Response:
Thank you for providing us information on your multimedia messaging platform.  The majority of comments received on providing smartphone capabilities on the label also supported the inclusion of the QR Code(R).  EPA evaluated other two-dimensional bar codes, including JAGTAG and found that the advantages of the QR Code(R) significantly outweighed the potential advantages of other options.  The QR Code(R) is free to use, in the public domain, does not require entering into a business relationship with private industry, and perhaps most significantly, is described in an ISO standard which is incorporated by reference in the final regulations.  The ISO standard allows the agencies to clearly and completely describe in regulatory language the process for generating a QR Code(R), a necessity of the structure of our program.
Organization: Alliance of Automobile Manufactures (Alliance)
Suzuki Motor Corporation
BMW
Comment:
Alliance of Automobile Manufactures (Alliance)
Use of QR Code For Smartphones
The Alliance supports the QR Code for Smartphones as an optional function on the label. Manufacturers who elect to provide a QR code should provide at least the information on the label plus any additional information they elect to include. [EPA-HQ-OAR-2009-0865-6850.2, p.12]

BMW
The usage of QR code should be optional. If introduced, the OR code should be standardized using the encoded general URL of the EPA/DOE website (http://fueleconomy.gov/m/). The proposed regulation indicated that it is desired to have this QR code be model/vehicle specific with encoding the specific model website for the vehicle. Such an enhancement will require additional lead time because the data needs to be stored (e.g. individual model IDs from the EPA/DOE website), as well as used later on to generate a QR code dynamically. Development of generating QR code during printing of the label will add at least 3-4 months of lead time. [EPA-HQ-OAR-2009-0865-7142.1, p.3]

Suzuki Motor Corporation
4. Make the Smartphone code optional on all the labels. Manufacturers may be able to use their current software and printers to print the new labels if the Smartphone code is not mandatory. [EPA-HQ-OAR-2009-0865-6900.1, p.3]
Response:
Thank you for your comment in support of optionally including a quick response (QR) code on the label.  In order to address consumers' growing interest in having information accessible via smartphones, EPA is including a QR Code(R) on the new label. When a smartphone user scans the QR Code(R) on the label, information on that particular vehicle from the label web page on fueleconomy.gov will be displayed on the handheld device. Though several commenters suggested linking to the auto manufacturers' vehicle-specific web sites from the QR Code(R), EPA determined that linking to a government web site was the best way to provide consumers with "just the facts." The smartphone user can take advantage of many of the web site's tools and vehicle comparisons from his/her phone while shopping at a dealership.  The agencies decided to make this a mandatory component on the label to ensure consistent access to label information from mobile platforms.

Organization: Toyota
Comment:
Toyota
Other Label Text [EPA-HQ-OAR-2009-0865-6901.1, p.8]
EPA requests comments on the usefulness of the Fuel Economy Guide and whether EPA and DOE should develop a different approach in the future - including the idea of transforming the guide into a consumer friendly checklist guide. Toyota believes that the printed version of the fuel economy guide has outlived its purpose. In keeping with the intent of the new label, Toyota would like to see EPA adopt a green approach to the guide and no longer require printed copies which becomes quickly out of date. As one approach, Toyota views EPA's Smartphone proposal as an effective means for providing consumers with more timely and up to date fuel economy guide information. [EPA-HQ-OAR-2009-0865-6901.1, p.8]
Using Smartphone QR Codes to Link to Fuel Economy Information [EPA-HQ-OAR-2009-0865-6901.1, p.15]
For all the label designs being considered, EPA is proposing that manufacturers place a QR Code on the label that will link the web browser of a properly configured smartphone to the mobile version of the EPA/DOE fuel economy information web site. As an additional means to provide readily accessible information to consumers, Toyota does not oppose the concepts outlined in the NPRM. [EPA-HQ-OAR-2009-0865-6901.1, p.15]
Response:
Thank you for your support of including a quick response (QR) code on the new label.  In order to address consumers' growing interest in having information accessible via smartphones, EPA is including a QR Code(R) on the new label  When a smartphone user scans the QR Code(R) on the label, information on that particular vehicle from the label web page on fueleconomy.gov will be displayed on the handheld device. Though several commenters suggested linking to the auto manufacturers' vehicle-specific web sites from the QR Code(R), EPA determined that linking to a government web site was the best way to provide consumers with "just the facts."  The content will be similar to what will be available on the label web pages, but geared to a smartphone platform.  The smartphone user can take advantage of many of the web site's tools and vehicle comparisons from his/her phone while shopping at a dealership.  We agree that as the internet becomes the primary tool to do vehicle research, the Fuel Eocnomy Guide required to be available at all dealerships is being used less and less. As we develop outreach materials around the new label and web site, we are considering doing a streamlined checklist or pocket card that can be distributed at dealerships, and will be more user friendly than the mandated Fuel Economy Guide.

5.4. Other Consumer Education Tools
                                                                            263
Organization: Alliance of Automobile Manufactures (Alliance)
Environmental Defense Fund (EDF)
National Automobile Dealers Association (NADA)
California Air Resources Board (CARB)
American Council for an Energy-Efficient Economy (ACEEE)
Institute for Policy Integrity - New York University School of Law
Catania, Andrew
California New Car Dealers Association
National Association of Minority Auto Dealers (NAMAD)
Comment:
Alliance of Automobile Manufactures (Alliance)
Currently, our members provide detailed and comprehensive vehicle information through a full suite of consumer-oriented materials, including interactive Web sites, innovative new media, and traditional materials. We've learned over time that most consumers do Internet research prior to visiting a dealership.  In fact, 70 percent of the consumers surveyed by EPA had a specific type of vehicle in mind when they started looking for a new vehicle.  And the majority of those, about 81 percent, said they ended up purchasing that type of vehicle.
[These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 14.

American Council for an Energy-Efficient Economy (ACEEE)
Targeting Social Networks
Any marketing and educational effort that is concurrent with the release of the labels should include strategies for targeting entire social networks, especially those of people who may, for the first time, be paying attention to the environmental performance of their vehicles. As the agencies note, because of the marked changes in content and design of new vehicle labels, it is critical to launch a concurrent marketing campaign both online and offline (58138). Research done by ACEEE for the EPA on vehicle labels confirms this. Moreover, it is important to take advantage of the operation of social influence by marketing to entire social networks rather than, or in addition to, individuals. Doing so may address two of the stated goals of the label redesign: understanding how label designs may nudge consumers towards both greater use of the fuel economy labels and towards the purchase of more fuel-efficient vehicles. [EPA-HQ-OAR-2009-0865-7135.1, p. 10]
Recent research suggests that individuals' values related to the environment can develop, and that social networks can influence vehicle purchase decisions amongst those who are 'trying out' environmental values. In the context of the new vehicle label, this influence can take two forms: 1) the diffusion of information about the new label from a trusted source, and 2) a reconsideration of self-identity related to the energy and environmental considerations of vehicles. [EPA-HQ-OAR-2009-0865-7135.1, pp. 10-11]
Therefore, in addition to disseminating relevant technical information about advanced vehicle technologies such as PHEVs, marketing efforts that target holders of these 'transitional' values may result both in greater acceptance of, and in greater uptake of, vehicles with better environmental performance. [EPA-HQ-OAR-2009-0865-7135.1, p. 11]

California Air Resources Board (CARB)
Finally, as you already know, public education will be a key element to rolling out these new labels. There is a lot of great information on these labels, and consumers need to understand how to use this information as they make their purchase decision. YouTube videos, information in dealerships, updating the fueleconomy.gov web site are all ideas that may help educate and inform consumers so that they use this information in their purchasing decision. [EPA-HQ-OAR-2009-0865-7527.1, p.2]

California New Car Dealers Association
When customers have a question about a vehicle  they see at a dealership, they usually ask the  salesperson with whom they are working.  And a  dealership's sales staff therefore becomes the primary  source of information concerning not only the vehicle  itself, but required governmental disclosures posted on  the vehicle.  This is not a duty that our members take  lightly but, in large part, because the satisfied  customer is oftentimes a repeat customer, which we want,  and a knowledgeable salesperson can assist customers in  making the right decisions to meet their own vehicle  personal needs.  On the other hand, if sales personnel can't  thoroughly explain an issue that the customer may have  with the vehicle or a government disclosure, they're  much less likely to make the sale, and even less likely  to have a satisfied customer.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 63.]

Catania, Andrew
Teisl [Mario Teisl, an economics professor at the university of Maine] compared the new car labels' increasing complexity with the same trend that has progressed with nutrition labels. They started simple, "but then over time, as people became more aware of it, more used to using it, then there were calls for adding more data." Teisl's hypothesis suggests that as the impact of automobile purchases become increasingly understood through added detail in the labels, it may spur positive trends in consumers' purchases of more healthy and environmentally responsible vehicles. [EPA-HQ-OAR-2009-0865-7425, p. 1]

Environmental Defense Fund (EDF)
And finally, we recommend the Agencies follow through with the expert panel's recommendation for an innovative outreach campaign that includes crowdsourcing with social media. We believe this type of outreach will help drive consumers to the website, empowering consumers to inform their purchasing decisions with readily available information. [EPA-HQ-OAR-2009-0865-6927.1, p.9]

Institute for Policy Integrity - New York University School of Law
The Agencies Should Mount an Educational and Advertising Campaign [EPA-HQ-OAR-2009-0865-7136.1, p.16]
The agencies voice concerns about consumer confusion throughout the proposed rule. For instance, they are concerned that consumers do not understand kilowatt-hours, and will not know what efficiency measured in kilowatt-hours for electric vehicles will mean to them. Much of this confusion may be alleviated through an effective consumer education program. [EPA-HQ-OAR-2009-0865-7136.1, p.16]
In fact, evidence shows that the revised label's effectiveness may be significantly improved if the agencies make an effort to inform consumers of the revisions and educate them about the changes and what the new information means for them. A number of other countries have begun assessing the efficacy of their own labeling programs, and have come to the conclusion that public education programs are essential to increasing the effectiveness of labels. A report by the Environmental Audit Committee of the U.K. House of Commons is emblematic: [EPA-HQ-OAR-2009-0865-7136.1, p.16]
Labels are more likely to influence a purchasing decision if the customer has prior awareness and understanding of the label. Where the Government supports a labeling scheme as part of its sustainable consumption strategy, it must actively promote and explain the label to consumers, using publicity to raise their awareness and understanding of labels before they make decisions on purchases. [EPA-HQ-OAR-2009-0865-7136.1, p.16]
There is a significant body of research indicating that a label's effectiveness is strongly tied to the degree to which consumers are aware of and understand the label. There is also evidence that too small of a marketing campaign can significantly impair a label's effectiveness. Simply put, consumers must "notice, understand and believe the information presented to them" on the label. Thus, not only the existence of a marketing and educational campaign, but also its quality and pervasiveness may have a dramatic effect on the impact of the proposed revision. [EPA-HQ-OAR-2009-0865-7136.1, pp.16-17]
The agencies have already planted the seeds of this campaign with the fuel economy website. The agencies propose that, whatever information is ultimately placed on the final revised label, the fuel economy website should be featured prominently and more detailed, personalized information should be available to consumers on it. They also propose the addition of a tag that Smartphones can read. [EPA-HQ-OAR-2009-0865-7136.1, p.17]
These efforts should, and easily can, be expanded. For example, if a Smartphone tag is placed on the label, an application should also be developed for popular Smartphone models so that consumers can use the website more easily from their phones. This application could be designed at very little extra cost to the agencies. [EPA-HQ-OAR-2009-0865-7136.1, p.17]
The agencies could also consider the possibility of advertising to promote the website and the Smartphone application, in order to increase the likelihood that consumers will use either or both at the beginning of their searches for new vehicles, before they go to dealerships. If the agencies are reluctant or unable to pay for this advertising directly, they could reach out to manufacturers, environmental groups, and consumer groups who might agree to link back to or advertise the fuel economy website on their own websites Manufacturers might wish to do this because they might benefit as consumers are better able to make informed comparisons between vehicles in the market. Environmental and consumer groups might wish to do this because their missions might include informing consumers as much as possible about the environmental impacts of their vehicles. [EPA-HQ-OAR-2009-0865-7136.1, p.17]
In addition, the inter-agency panel could coordinate on the formulation of an educational campaign for consumers. Given the acknowledged concern throughout the various agencies' rulemakings for the potential for consumer confusion, it may make sense for the agencies to coordinate to improve consumer education about environmental labeling. Potential benefits include saving the cost of mounting multiple campaigns to educate consumers about multiple labeling regimes, as well as preventing the possibility that the agencies could work at cross-purposes in their endeavors to educate the public. [EPA-HQ-OAR-2009-0865-7136.1, p.17]

National Association of Minority Auto Dealers (NAMAD)
Third, of the subset of prospective purchasers who do in fact focus on fuel economy or emissions performance, most tend to look at comparative information before coming to a dealership. With the advent of the Internet, shoppers increasingly cruise comparative information and make preliminary purchase criteria decisions in the comfort of their home or office, arriving at the dealership armed to the hilt with a plethora of knowledge regarding the vehicles to which they've narrowed their search. This trend also will continue going forward. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 42-43]
Lastly, I urge EPA and NHTSA to work with dealers and their associates on educating the public on the new labels once promulgated. When it rolled out its model year 2008 label, EPA worked hard with dealers and others on outreach, an effort that should be similarly engaged in leading up to the model year 2012. As with prior versions of the label, it also will be important to remind the motoring public both that the fuel economy they can expect to achieve will depend on many factors including driving conditions, speed, terrain, and maintenance. And that we should all continue to take the simple, everyday steps that will maximize in-use fuel economy and emissions performance. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 45-46]

National Automobile Dealers Association (NADA)
Lastly, the EPA and NHTSA should work with dealers and their associations to educate the public on the new fuel economy labels, when finalized, consistent with the excellent outreach undertaken when the MY2008 labels were rolled out. It is also important to remind the motoring public that the fuel economy that they can expect to achieve will depend on many factors, including driving conditions, speed, terrain, and maintenance, and there are simple, everyday steps that can be taken to maximum in-use fuel economy and emissions performance.
[These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 40.]
Response:
Thank you for your support of a robust education and outreach campaign surrounding the release of the new labels.  The agencies concur on the need to support the label roll out with a significant outreach campaign and materials.  In addition to enhanced label informaiton that will be added to fueleocnomy.gov, the agencies are also planning to work with many of our partners, including environmental, consumer, and auto interest groups, to educate them so that they can adequately inform consumers on the labels, as they have more direct access to the general public than government agencies.  We also plan to use all social media at our disposal, and will encourage our partners to use their social media tools as well to educate the public.

6. Agency Research on Fuel Economy Labeling
                                                                            268
Organization: Environmental Defense Fund (EDF)
Comment:
Environmental Defense Fund (EDF)
We applaud the Agencies for conducting a comprehensive and innovative consumer based research program to inform the development of the proposed new labels. To help inform the creation of the new label, EPA engaged the help of a marketing firm to design and implement information gathering from the public, including: (1) a literature review;(2) focus groups; (3) an expert panel; and (4) online surveys of new and prospective vehicle buyers. This extensive research initiative was designed to forge a broad and deep understanding of a well-designed consumer-friendly label based on unprecedented outreach to consumers and consumer information experts. [EPA-HQ-OAR-2009-0865-6927.1, p.3]
Response:
We appreciate the support for our research effort.  The final label design is informed by all this research, as well as public comments.

6.2. Focus Groups
                                                                            269
Organization: Alliance of Automobile Manufactures (Alliance)
Comment:
Alliance of Automobile Manufactures (Alliance)
The letter grade option was not presented to any of the focus groups used as the basis of this rulemaking; however, we understand that EPA is conducting a Web-based survey of the proposals, and we assume that that will include the letter grade.
[These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 16; These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 12-13]
Response:
The comment is correct.  The letter-grade label was an outgrowth of the expert panel.  Label option 1 (which features the letter grade) was tested in the web-based survey along with the other two label designs from the proposed rulemaking. As discussed in preamble section I.D, the survey did not uncover any "fatal flaw" with any of the three designs.
All of our market research, as well as public comments, contributed to development of the final label.
Organization: National Automobile Dealers Association (NADA)
Comment:
National Automobile Dealers Association (NADA)
And also for the Alliance, you mentioned that a number of your member companies have done focus groups.  We have not received the data from them.  And  we would very much appreciate any additional data that you have of the American public and provide us information.  We would very much appreciate it.  MR. DOUGLAS:  We'll certainly provide that, and we'll provide detailed and written comments.
[These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 48.]
Response:
Our focus group results, as well as the results of other market research we conducted in support of this rulemaking, are in the rule docket and are posted on EPA's website.

Organization: American Council for an Energy-Efficient Economy (ACEEE)
Comment:
American Council for an Energy-Efficient Economy (ACEEE)
Agency Research on Fuel Economy Labeling
Comprehension of slider bars
The agencies should conduct comprehension testing of the slider bars, especially when used with environmental metrics. While Focus Group III did conduct comprehension testing of the presentation of fuel economy on three proposed labels, no such testing was done on the presentation of environmental metrics. In light of the weight that consumers attach to MPG values after 30 years of seeing them on vehicle labels, and in light of the fact that environmental metrics will feature prominently on vehicle labels for the foreseeable future, it is critical that the presentation be both useful and understandable. [EPA-HQ-OAR-2009-0865-7135.1, pp. 9-10]
As noted above, international research on label design as well as comments from focus group participants suggest that comprehension of continuous scales (such as slider bars) may be low compared to categorical scales (such as stars or leaves).7 Specifically, research on vehicle labels done by ACEEE for EPA found that while consumers perceived the bar-type presentation of environmental metrics as easier to understand than an alternate presentation, this perception was not supported by comprehension tests. [EPA-HQ-OAR-2009-0865-7135.1, p. 10]
Furthermore, participants in Focus Group III expressed both dislike of and confusion about the meaning of environmental metrics presented as slider bars, depending upon the vehicle type. For gasoline and diesel vehicles, focus group participants reported not understanding the slider bar, instead preferring the leaf presentation of Option B (which was found to be most understandable overall). For electric vehicles, the slider bar was either disliked or was reported as providing little information. In contrast, for extended range vehicles, the slider bars used in Option C to express range/charge and vehicle comparison were found to be useful and understandable. [EPA-HQ-OAR-2009-0865-7135.1, p. 10]
These differing responses suggest that: 1) perceived comprehension of slider bars depends on vehicle technology and 2) an alternate representation of environmental metrics may be more comprehensible or more pleasing. [EPA-HQ-OAR-2009-0865-7135.1, p. 10]
Comprehension testing would likely clear up some of these questions, and allow for the design of more effective and comprehensible labels tailored to vehicle type. [EPA-HQ-OAR-2009-0865-7135.1, p. 10]
Response:
We agree with the commenter on the importance of presenting fuel economy and environmental metrics such that they are understandable and useful to consumers; this was one of the key motivating factors in redesigning the label.
To help achieve this goal, the agencies conducted an extensive consumer research campaign that included three phases of focus groups.  Slider bars were among the methods of presentation for greenhouse gases tested in each phase of focus groups. While some focus group participants found star or leaf ratings more understandable, others favored slider bars. In phase 2 -- where participants were asked which presentation method they preferred for individual vehicle types (EVs, PHEVs, etc.) -- no one presentation method was consistently rated the highest across all technologies.  These results helped informed our decision to seek comment on three different rating methods (slider bars, letter grade, and stars) for various metrics in the proposed rulemaking.
We decided upon the final label after considering public comments, the results of our market research (including an internet survey that found no "fatal flaws" with any of the three label designs), and considering and weighing statutory requirements.

6.4. Internet Survey
                                                                            272
Organization: Alliance of Automobile Manufactures (Alliance)
Comment:
Alliance of Automobile Manufactures (Alliance)
We look forward to reviewing the results of the Web-based survey and encourage EPA to make those available well in advance of the end of the comment period.  And we would note that other recent surveys, including those conducted by edmunds.com and Siegel+Gale indicate that a large majority of consumers prefer the more traditional label.
[These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 16.]
Response:
EPA posted the results of the web-based survey in the public docket and on the rule website on November 22-23, 2010 (see http://www.epa.gov/fueleconomy/label/prr-topline-report-11-22-10.pdf and document EPA-HQ-OAR-2009-0865-6913 at regulations.gov).  The docket remained open for 30 days after this date.  No additional comments were received on the report.
The agencies are aware of various surveys, including those by Siegel+Gale, edmunds.com, and other organizations (e.g., fueleconomy.gov, Consumer Reports).  Samples, methods, questions asked, and results varied across the polls; as a result, the agencies considered the breadth of polling results, just as it considered the breadth of comments provided.  The final label design incorporates input from all these sources.

6.5. Additional Research
                                                                            273
Organization: Alliance of Automobile Manufactures (Alliance)
Ford Motor Company (Ford)
Sierra Club
International Council on Clean Transportation (ICCT)
Siegel+Gale
Comment:
Alliance of Automobile Manufactures (Alliance)
Several outside organizations have conducted their own surveys, the results of which point to "Label 2" as the preferred approach. On September 28, 2010, Siegel+Gale reported the results of a survey of 456 Americans as follows: [EPA-HQ-OAR-2009-0965-6850.2, p.3]
Overall, 66 percent rejected the version that emphasized a prominent letter grade (the vertical label) and favored the one that focused on miles per gallon (the horizontal Label). While respondents preferred the horizontal label, 38 percent found some aspect of the horizontal label confusing.5 [EPA-HQ-OAR-2009-0965-6850.2, p.3]
Based on this survey, Siegel+Gale made the following recommendations: [EPA-HQ-OAR-2009-0965-6850.2, p.3]
Moving extraneous data to a website (e.g., gallon gas equivalent per 100 miles, entire range of mpg for all vehicles, greenhouse gases and other air pollutants) [EPA-HQ-OAR-2009-0965-6850.2, p.4]
Removing all non-essential logos and icons to reduce visual clutter [EPA-HQ-OAR-2009-0965-6850.2, p.4]
Using mpg as a primary data point and explain that, for a hybrid electric/gasoline vehicle, the first 50 miles are run by battery [EPA-HQ-OAR-2009-0965-6850.2, p.4]
Emphasizing operating cost rather than savings over time [EPA-HQ-OAR-2009-0965-6850.2, p.4]
Providing a brief explanation of the purpose of the Smartphone bar code. [EPA-HQ-OAR-2009-0965-6850.2, p.4]
Giving more prominence to the benefits (i.e., "ability to calculate estimates personalized for your driving") of visiting the fueleconomy.gov website at the bottom of the label. [EPA-HQ-OAR-2009-0965-6850.2, p.4]
Shortly after the proposed rule was released, Edmunds.com also conducted a preliminary poll that resulted in similar findings. Edmunds.com reported that 82 percent of respondents preferred the more traditional label, with only 18 percent supporting letter grades. Edmunds.com is currently conducting a more in-depth survey. [EPA-HQ-OAR-2009-0965-6850.2, p.4]

5 Siegel+Gale Press Release, "EPA Misses Mark on Fuel Consumption Labels, Sept. 28, 2010, available at: http://www.siegelgale.com/2010/09/28/epa-misses-the-mark-on-fuel-consumption-labels/. The full presentation on this survey is available at http://www.siegelgale.com/pdf/Siegel_Gale_EPA_Labels_Evaluation_FINAL.pdf.

Ford Motor Company (Ford)
Research on Fuel Economy Labeling [EPA-HQ-OAR-2009-0865-7141.1, p.7]
In addition to reviewing the research conducted by EPA and NHTSA, Ford has conducted its own web-based surveys of non-technical Ford employees across the U.S. to gain information about consumer preferences and understanding of various concepts. Ford's surveys gathered general information about driving habits and the importance of fuel economy labeling, but also probed respondents for more specific feedback on PHEV label content. Details of these survey results were previously provided, under Confidential Business Information, to the EPA. In many areas, the Ford surveys found similar results to the agency focus groups. For example, respondents to the Ford survey indicated that MPGe is the preferred way to quantify electrical usage data, while electrical consumption based on kilowatt hours rated poorly. Additionally, the Ford survey found that 96% of respondents rated battery recharge time a 7 or higher (out of 10) in terms of importance. In addition, 74% of respondents rated the charge depleting range in electric mode as a 7 or higher, indicating that these are two key elements they want to see on the label. The survey also found that most consumers thought separate electric-assist and hybrid mode fuel consumption information should be included for PHEVs. [EPA-HQ-OAR-2009-0865-7141.1, p.7]
Similar to agency findings related to an environmental impact rating, Ford survey respondents indicated relatively low consumer interest in this metric. Over a quarter of respondents indicated they would not pay attention to such a rating. Of the options provided, none received more than 31% of the total response. [EPA-HQ-OAR-2009-0865-7141.1, p.7]
For the research quoted within the NPRM, it is important to note that the EPA & NHTSA focus group participants were not directly asked about the letter grade concept, a key element of one of the label proposals. Since the publication of the NPRM, the agencies have implemented an online survey to gather consumer preference feedback on the two primary label options. Ford awaits the final results of this survey and believes they will be a beneficial source of information. Based on several surveys that have been conducted, including Siegel+Gale, Edmunds.com and the EPA/NHTSA survey still in progress, there is still a stronger consumer preference for the features of the traditional label over the letter grade approach. In many cases, the traditional label was favored by more than a 2 to 1 ratio. [EPA-HQ-OAR-2009-0865-7141.1, p.7]

International Council on Clean Transportation (ICCT)
There are two recent studies in Europe on consumer label effectiveness that should be considered by the agencies in development of the final rule. One was a June 2010 study for the Low Carbon Fuel Partnership in the UK, "Low CVP Car Buyer Survey: Improved environmental information for consumers". The second was a 2010 report on behalf of the European Parliament, "Study on consumer information on fuel economy and CO2 emissions of new passenger cars". While ICCT does not endorse the specific findings and the situation in the U.S. may be different than in Europe, the reports contain useful information. [EPA-HQ-OAR-2009-0865-7118.1, pp.2-3]

Siegel+Gale
A survey released today found both of the new automobile fuel economy labels proposed by the U.S. Environmental Protection Agency (EPA) to be confusing. Overall, 66 percent rejected the version that emphasized a prominent letter grade (the vertical label) and favored the one that focused on miles per gallon (the horizontal Label) -- see samples at http://www.siegelgale.com/pdf/Siegel_Gale_Infographics_FINAL.pdf. While respondents preferred the horizontal label, 38 percent found some aspect of the horizontal label confusing. [EPA-HQ-OAR-2009-0865-0824.1, p.1]
The survey -- polling a nationally projectable group of 456 Americans over the age of 18 who are looking to buy a car within the next three years -- was conducted by Siegel+Gale, a global strategic branding firm and pioneer in bringing clarity to business and government communications. The Siegel+Gale SimplicityLab(TM) measured the perception and comprehension of two labels illustrating data about a gas/electric hybrid vehicle -- one of the many alternative fuel vehicles which the EPA hopes car buyers will consider. The survey explored which of the two proposed labels would be most understandable to the average American and which data were of most interest. [EPA-HQ-OAR-2009-0865-0824.1, p.1]
The vertical label went astray in four areas: [EPA-HQ-OAR-2009-0865-0824.1, p.1]
Emphasizing a letter grade [EPA-HQ-OAR-2009-0865-0824.1, p.1]
De-emphasizing miles per gallon (mpg) [EPA-HQ-OAR-2009-0865-0824.1, p.1]
Presenting data without any brief explanation [EPA-HQ-OAR-2009-0865-0824.1, p.1]
Emphasizing savings over time rather than cost of operation [EPA-HQ-OAR-2009-0865-0824.1, p.1]
Review the full survey results at http://www.siegelgale.com/pdf/Siegel_Gale_EPA_Labels_Evaluation_FINAL.pdf. [EPA-HQ-OAR-2009-0865-0824.1, p.2]

Sierra Club
MR. POWELL:  And I did have a second question  for Mr. Magavern.  Just for clarity, I think you had mentioned a  couple of times you had given details regarding a survey  you conducted.  The survey included two versions of the  Label 1, and the third -- was it the other proposal, or  it was the model year '08, what you see on the dealer  lot today?  MR. MAGAVERN:  The latter, what you see today. MR. POWELL:  The latter, okay.  And it was  about 3,200?  MR. MAGAVERN:  3,289 responses.  MR. POWELL:  And that was targeted to?  MR. MAGAVERN:  Our members and supporters.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 105-106.]
Response: