With regard to the comment about placing annual fuel costs on a slider scale, the agencies did explore this option in our market research.  However, due to the fact that the relative fuel costs are represented effectively in other formats, the agencies are not finalizing an additional slider bar for cost.
The agencies also explored describing all consumption metrics, such as CO2, cost and gallons consumed, on an annual basis.  For consistency with other regulatory programs, such as the National Program for light-duty greenhouse gases (75 FR 25324), a grams per mile unit was retained for CO2.  The agencies are finalizing gallons per 100 miles to introduce consumers to a linear fuel consumption metric, since we believe consumers will learn to understand how much fuel is used over a tangible, 100 mile, increment.  For PHEVs the final label displays consumption metrics for both charge depleting and charge sustaining modes of operation.  The agencies appreciate the concern that the slider bar value is a utilitized value and is therefore not necessarily achieved by the driver at discrete intervals.  The final label includes a fuel economy rating that is based on a utilitized value because we believe that a utilitized value is a fair method for comparisons. We understand that there may be higher consumption metric variability among individual driving patterns for PHEV owners, but we believed it was important to provide a consistent comparison metric across all vehicles. The final label displays this value as 1 to 10 rating rather than as an MPGe value which should address the commenter's concern about implying fuel consumption precision. The agencies note that the annual fuel cost is calculated as the commenter suggests, as a utilitzied annual cost.
Organization: Siegel+Gale
Comment:
Siegel+Gale
Siegel+Gale suggests the EPA can improve the consumer-preferred horizontal design by: [EPA-HQ-OAR-2009-0865-0824.1, p.2]
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-2009-0865-0824.1, p.2]
Removing all non-essential logos and icons to reduce visual clutter [EPA-HQ-OAR-2009-0865-0824.1, p.2]
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-2009-0865-0824.1, p.2]
Emphasizing operating cost rather than savings over time ? Providing a brief explanation of the purpose of the Smartphone bar code. [EPA-HQ-OAR-2009-0865-0824.1, p.2]
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-2009-0865-0824.1, p.2]
Response:
EPA appreciates the specific suggestions provided by the commenter.  EPA agrees that directing consumers to website is an appropriate way to make more information available than can easily fit on the label.  However, many of the items identified by the commenter are in fact required by statute to appear on the label, such as a rating system that would make it easy for consumers to compare the fuel economy and greenhouse gas and other emissions of automobiles.  Focus group results indicated that consumers trust a government source for fuel economy information; therefore the agencies believe it is important to retain government agency identification on the label to maintain the credibility of the label information.  Many commenters and focus group participants responded positively to the icons, such as the gas pump and electric plug.
On the final label, the agencies have additionally incorporated the term "QR Code" near the smartphone interactive.  Space limitation on the label prevented a more expansive explanation.  However, QR Codes are becoming more familiar to consumers, and a quick Internet search immediately reveals the utility of a smartphone QR code; therefore the agencies believe that the terms "Smarthphone" and "QR Code" are sufficient for consumers with smartphones to quickly figure out how to download a QR code reader, scan the code, and reach the website.
Organization: California Air Resources Board (CARB)
Comment:
California Air Resources Board (CARB)
ARB also suggests including a statement that identifies motor vehicle usage as a primary cause of global warming and how emissions of those gases from motor vehicles may be reduced. On the Environmental Performance Label, ARB states that 'Vehicle emissions are a primary contributor to global warming and smog.' If the national label includes a space for upstream emissions, ARB may be able to include this statement there, or you could add this to the text at the bottom of the label. [EPA-HQ-OAR-2009-0865-7527.1, p.1]
Although we support using the gasoline template for conventional hybrids, we recommend that you identify the vehicle as a hybrid on the label. This will help consumers distinguish these vehicles from other conventional gas cars. [EPA-HQ-OAR-2009-0865-7527.1, p.2]
As consumers begin seeing new technologies hit the dealer lots, we believe it would be helpful if the technology type were more prominently represented on the label. [EPA-HQ-OAR-2009-0865-7527.1, p.4]
We suggest that the label for all PHEVs have a space for all electric range whether it is zero or 50. This is a piece of information we believe consumers will be looking for when considering a PHEV. [EPA-HQ-OAR-2009-0865-7527.1, p.5]
Please consider developing an icon for FFVs with a smaller gasoline tank and an icon for ethanol. This may help consumers recognize that the car they are buying can run on both gas and ethanol. [EPA-HQ-OAR-2009-0865-7527.1, p.5]
Response:
In order to facilitate label harmonization, we have been working with the California Air Resources Board to develop a label that will meet California's requirements (see Section 10.2 of this document.) Therefore, the final label will require the statement, "Vehicle emissions are a significant cause of global warming and smog."
We agree that range is an important piece of information for potential purchasers of advanced technology vehicles since these vehicles typically cannot travel as far on a refueling as can a conventional gasoline vehicle, and the refueling infrastructure for non-liquid fuels is currently limited. Therefore, we are requiring the inclusion of range on all EV, PHEV, CNG, and hydrogen FCV labels. Additionally we are requiring an option for vehicle manufacturers to voluntarily include E85 range information on the labels for ethanol flexible fuel vehicles.
We also agree that the technology type is important information for consumers, and are requiring that it be prominently displayed in the upper right hand corner. However, the size of this header is limited by the overall size of the label, other important label content, and the desire to avoid making the label appear "too busy" by removing too much blank space. We have added "E85" above the gasoline icon to the header of FFV labels to help consumers recognize that these vehicles can run on both fuels.
We require that a conventional hybrid (operated on gasoline) be labeled as a "Gasoline Vehicle" since this is the fuel consumers will purchase to operate the vehicle. Any fuel economy and environmental benefits that result from the hybrid technology will be reflected on the label in the MPG estimate and various slider bars.
Organization: Securing America's Future Energy (SAFE)
Comment:
Securing America's Future Energy (SAFE)
Rather than simply identifying problems with the labels, SAFE went a step further and developed solutions. SAFE worked closely with MSDS, a full-service branding and design firm, to enhance the design and structure to create informative, consumer-friendly labels. Together, we developed a modular label that conveys critical information on fuel consumption and cost across all vehicle types, while allowing for a more meaningful comparison of the selected vehicle, other vehicles in its class, and all vehicles on the basis of fuel costs and emissions. [EPA-HQ-OAR-2009-0865-7522.1, p.2]
In our comments, SAFE identifies those elements that we believe should be part of a fuel economy and emissions label, offers critiques of some of the elements that are part of the labels presented in the proposed rule, and offers its own label design, based on Label 2 in the NPRM. Two versions of the label, one intended for gasoline vehicles and one intended for electric vehicles, are depicted in Figures 1 and 2 below [See p.3 of this comment summary for Figures 1 and 2]. The entire set of labels is included in the body of these comments. High resolution copies of the labels are attached to the end of the PDF file that contains these comments. [EPA-HQ-OAR-2009-0865-7522.1, p.2; see p.24 of this comment summary for High Resolution copies of the labels]
If, as we hope, the agencies find that the labels we have designed offer improvements to the labels in the NPRM, SAFE and MSDS welcome the opportunity to continue assisting the agencies as they work with the design. [EPA-HQ-OAR-2009-0865-7522.1, p.4]
Label Design and Layout [EPA-HQ-OAR-2009-0865-7522.1, p.11]
SAFE has worked with MSDS to design a fuel economy and emissions label that incorporates the required elements and is based on Label 2 in the proposed rule, but which we believe improves on its design. SAFE and MSDS hope that the agencies find the design compelling. We are available to adjust the design and share other ideas with the agencies if such assistance would be helpful. [EPA-HQ-OAR-2009-0865-7522.1, p.11]
SAFE and MSDS also recognize that there are different ways that some elements could be reported. For instance, in the quadrant of the label dedicated to fuel costs, one could report fuel cost per mile or fuel cost per 100 miles. Similarly, one could report GHG emissions in grams per mile, which may be more information than is needed for most consumers, or on a simple 1 to 10 scale. Obviously, if the agencies like the general template, individual elements in the design can be adjusted as appropriate. [EPA-HQ-OAR-2009-0865-7522.1, p.11]
SAFE and MSDS Label Design [EPA-HQ-OAR-2009-0865-7522.1, p.11]
The label that MSDS designed is based on the layout on Label 2 in the NPRM and is depicted in Figure 3 below [See p.13 of this comment summary for Figure 3 entitled, SAFE/MSDS Label for Gasoline Vehicles]. The basic template is one that should work for every type of vehicle. Equally important, although SAFE strongly supports the design as depicted in these comments, and believes that each element of the sample labels should be included on the final label, even if the agencies decide to include some different elements on the label, SAFE and MSDS strongly believe that our template clearly and concisely conveys a wealth of information to consumers. [EPA-HQ-OAR-2009-0865-7522.1, p.11]
The label includes larger, easier to identify icons to indicate the type of fuel consumed by the vehicle. The gas pump is universally recognized symbol which was revised to be more compatible with the typography on the label. For vehicles that draw electricity from the grid, we selected an electric bolt as it is a more widely used and recognized symbol than a plug, and more legible in this application. For compressed natural gas vehicles, we used a flame, which is also widely recognized. [EPA-HQ-OAR-2009-0865-7522.1, p.11]
The new design uses Helvetica Condensed as its font. In addition to being popular and readily available, it is a member of the Helvetica font family, which is commonly used in documents and maps issued by a number of authorities, including the DOT and EPA. Most importantly, when constrained to a small space, it offers greater legibility per square inch than the font used in the proposed Label 2. [EPA-HQ-OAR-2009-0865-7522.1, p.11]
The top half of each label contains two parts. The top left reports fuel economy and fuel consumption and the top right reports fuel costs. [EPA-HQ-OAR-2009-0865-7522.1, p.12]
The lower part of each label is the space in which key attributes of vehicles are compared to each other. We feel that stretching the comparison bars across the entire width of the label is an improvement over the proposed label. Because the comparison bar has a wider range, it exposes nuanced differences between vehicles more clearly than the short spectrums on the previous design. By placing each of the bars on top of each other instead of next to each other, there is a consistent worst/best scale that a consumer can use to compare vehicles to each other. [EPA-HQ-OAR-2009-0865-7522.1, p.12]
For each of the four data points depicted on the bars, the value for the vehicle is indicated by the black box. For elements that are reported as ranges, such as cost of operating a PHEV, the black box is widened to indicate that the actual value could be anywhere in the range depending on how the vehicle is operated. Thus, once one is familiar with the layout, even from a distance one can get a sense of how the vehicle rates simply by seeing if the boxes are to the right or left of the space. The boxes are easily visible from over 15 feet, which means that a consumer walking though a car lot can quickly glance at the label and get a sense of how the vehicle will perform. The design of the bars allows a consumer to see how the vehicle performs, how other vehicles in its class perform, and how all other vehicles perform, with respect to each reported element. [EPA-HQ-OAR-2009-0865-7522.1, p.12]
Finally, the SAFE/MSDS label is in black and white. SAFE was admittedly intrigued by the use of color in the labels that the agencies proposed, and appreciate that color can convey messages without taking up additional space. Upon further reflection, however, we realized most of the color used in proposed Labels 1 and 2 added little if any value to the labels. [EPA-HQ-OAR-2009-0865-7522.1, p.12]
[See EPA-HQ-OAR-2009-0865-7522.1, p.13-18 for comments pertaining to SAFE/MSDS' proposed labels for Gasoline Vehicles, Natural Gas Vehicles, Electric Vehicles, PHEV Extended Range Electric (Series) Vehicles, and PHEV (Predominantly Blended) Vehicles]
Response:
The agencies appreciate the specific comments and example labels provdied.  Much of the information on the top half of the labels submitted with this comment is similar to information on the final label.  (Please see Section 3.6.1 and 3.6.2 for comments and responses on various cost values).  The bottom portion of the commenter's label contains ideas that have merit; However, the multiple scales and the differentiating line elements are difficult to read when placed in a 4.5 x 7 inch label.  The agencies agree that directional consistency among the rating scales is important and is finalizing all rating scales with a consistent 1 (worst) to 10 (best) scale.  Although stacked rating scales may provide one method for quickly evaluating a vehicle, the agencies believe that the final layout of the rating scales is sufficiently clear to consumers and has the additional benefit of partitioning the infomation, such that it is easily findable by topic of interest.  The agencies considered numerous fonts and design styles for the final label. The fonts that are being finalized are easily readable and a are consistent with the overall label design.
Organization: Foster, Marcus
Comment:
Foster, Marcus
The abbreviations and symbols for units on your labels are a mess. For a start, the SI symbol for kilowatt-hour is `kW-h', not `kW-hrs'. For `gallon' you have `G' (in `MPG') and `gallons'; for mile, you use `M' (in `MPG') and `mile'. At least you use the correct SI symbol `g' for 'gram'. [EPA-HQ-OAR-2009-0865-4833, p. 2]
Why do you mix customary units (mile, gallon) and SI units (gram)? This is a recipe for confusion  -  remember the Mars Climate Orbiter? Either use all customary units, with emissions in oz/mile, or have the ***** to switch to SI units completely. [EPA-HQ-OAR-2009-0865-4833, p. 2]
The average person struggles to understand and convert the reciprocal quantities `fuel economy' and `fuel consumption'. You should wean Americans off the economy measure, because it is difficult to make comparisons about annual fuel usage. I suggest you take the plunge and adopt fuel consumption in L/100 km, like the rest of the world. [EPA-HQ-OAR-2009-0865-4833, p. 2]
Response:
The commenter is correct that the agencies are not using a single symbol or unit convention, such as the International System of Units (SI),for the fuel economy label.  The reason is that the agencies endeavored to select the most common and familiar units, to avoid creating any unnecessary confusion for consumers.  For instance, "MPG" is a shorthand term that most people recognize immediately as meaning "miles per gallon", but "G" in isolation would not necessarily read "gallons" to most people; therefore the agencies chose to use the term "gallons" when describing gallons per 100 miles, since this is a new and unfamiliar metric. Similarly, the agencies recognize that kW-h is the correct SI unit for kilowatt-hour; however, it is a commons convention to abbreviate "hour" as "hrs" and it is also common to use kW-hrs when referring to the energy unit kilowatt-hours. The agencies considered "kW-hrs" to be the most consumer-friendly abbreviation for kilowatt-hours.
The final label does include a consumption metric on the label because EPA agrees that a fuel consumption metric is a better tool for making economically sound decisions and recognize that it will not become widely utilized if it is not first introduced on the label.
Organization: Tesla Motors
Comment:
Tesla Motors
Tesla also believes that additional comparative information should also be provided on the new label in a manner meaningful to consumers. For example, option 2 provides sliding scales for fuel economy compared to other vehicles generally and vehicles in a similar class. Other sliding scales include greenhouse gas measures and traditional pollutant measures. Such information can provide consumers with a "shortcut" analyses on fuel economy labels by providing an easy to understand comparison they would otherwise have to do by reviewing numerous labels with a single metric. While new to motor vehicles, such comparative scales have been used in the past and are familiar to consumers  -  specifically, EnergyGuide labels on home appliances provide information on a sliding scale demonstrating which appliances are more energy efficient versus other similar types of appliances. Just as the EnergyGuide labels provide useful comparative information, similar scales can be applied to motor vehicles as well. [EPA-HQ-OAR-2009-0865-6933.1, pp.2-3]
Response:
We agree that it is important to provide easy ways for consumers to compare fuel economy and environmental information across all vehicle technologies. The final label requires a slider bar, with a one-to-ten scale,  to show how the vehicle's fuel economy and greenhouse gas emissions compare among all other vehicles. Information on the best and worst fuel economy for other vehicles in the same class (e.g., small SUVs) will also be provided on the label.  Finally, the label will include a one-to-ten slider bar that shows how the vehicle's smog emissions compare among all vehicles.
Organization: F., Nick
Mauldin, Ronald
Comment:
F., Nick
I have made some amendments to your design. The image can be found here: http://www.flickr.com/photos/31385480@N05/4944096848/ [EPA-HQ-OAR-2009-0865-1323, p.1]

Mauldin, Ronald
Rather than trying to describe my recommended changes, I have completed an alternative design and have attached that design to this email. I believe you will find my combination label design to better meet the objectives of the label. If you are interested, I am available for consultation on a re-design of the label. [EPA-HQ-OAR-2009-0865-5795, p. 1, see p. 2 for suggested alternate label design.]
Response:
Thank you for the thoughtful design suggestions.  EPA took all comments into consideration when setting forth the final label design.
Organization: University of Pennsylvania Law School, Environmental Law Project
Comment:
University of Pennsylvania Law School, Environmental Law Project
In this comment, we evaluate the relative strengths and weaknesses of these labels and propose an amalgam of Labels 1 and 2 as the ideal choice in light of the following considerations: aesthetics and ease of consumer use, as well as clarity of presentation of environmental impacts and benefits, fuel economy, fuel costs and savings, and likelihood of withstanding judicial review. [EPA-HQ-OAR-2009-0865-7171.1, p.2]
Our amended label design highlights the environmental impact of each vehicle by clearly listing relevant information under the term "Environment," and by increasing the size of the GHG and Other Air Pollutants slider bars to make them much easier to read. [EPA-HQ-OAR-2009-0865-7171.1, p.5]
Our amended label design also eliminates the horizontal section of small, cramped boxes in which fuel economy is displayed in Label 1. These are confusing, difficult to read, and hinder vehicle comparisons by providing many pieces of information with no apparent visual hierarchy. Instead, we have highlighted gal/100mi., vehicle range for electric vehicles, and the slider bar that illustrates fuel economy in MPG/MPGe within vehicle class. Given the short time consumers spend viewing the label, our amended label allows them to find all relevant information more quickly, facilitated by better visual displays of fuel economy. At the same time, it allows a consumer inspecting a vehicle from a short distance to quickly locate the vehicle's miles per gallon information, and, once they do, simultaneously presents them with the more useful gallons consumed per hundred miles metric. [EPA-HQ-OAR-2009-0865-7171.1, p.6]
EPA and NHTSA have provided a range of proposed automobile labels that would fulfill their statutory mandate. While each of these labels has strengths, we believe that a modification of Label 1 would most effectively convey information that would allow consumers to compare vehicles and understand their associated fuel costs and environmental impacts. Our proposed label, which is attached to this comment as Appendix A, utilizes some elements of Label 2, while maintaining the vertical layout, letter grade and prominently displayed 5-year fuel cost savings from Label 1. Our proposed label also includes important information such as gallons/100 mi., the annual fuel cost, and the MPG as situated within the range of all vehicles and the range for the particular class. We include a separate section labeled "Environment," as appears in Label 2, for those consumers who wish to separately compare that information. While much of the same information appears on our label and the proposed Label 1, we believe that our proposal more clearly provides the consumer with a hierarchy of information in various categories by utilizing size and distinct topical sections. We believe that, with these modifications, the new fuel economy label will effectively convey useful information to future auto-buyers and encourage the purchase of more environmentally friendly vehicles. [EPA-HQ-OAR-2009-0865-7171.1, p.11]
[Appendix A can be found in Docket number EPA-HQ-OAR-2009-0865-7171.2.]
Response:
EPA appreciates the thoughtful comments and design suggestions.  EPA agrees that the slider bars on Label 1 are likely to be more effective when the size is increased; therefore the final label includes slider bars that are larger in size than on proposed Label 1. EPA believes that the MPG and gallons per 100 mile values are easy to find on the final label.  In addition, the final label contains information in a format that allows consumers to quickly find the category of information in which they are most interested.

3. Label Content (Metrics and Ratings Systems)
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Organization: Edison Electric Institute (EEI)
Comment:
Edison Electric Institute (EEI)
EEI recognizes that there is a legislative mandate for the label to include a rating system 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 ...." EISA, 49 U.S.C. 32908(g)(1)(a)(ii). EEI does not endorse or oppose a specific vehicle rating system. However, EEI encourages EPA and NHTSA to adopt a rating system that (a) is based on specific quantitative data, and (b) does not use symbols or terms that could skew consumers' perceptions. For example, consistent with the familiar FTC Energy Guide yellow appliance efficiency labels, rating scales should be included, but not qualitative assessments like "best" and "worst." [EPA-HQ-OAR-2009-0865-7117.1, p.5]
Response:
The ratings on the label will be based on quantifiable data as requested by the commenter.  The greenhouse gas score, for example, is based on tailpipe CO2 emissions and the methodology for assigning a score can be found in the preamble.  While the labels do include the term "best," we chose not include the term "worst."
Organization: National Automobile Dealers Association (NADA)
National Association of Minority Auto Dealers (NAMAD)
Comment:
National Association of Minority Auto Dealers (NAMAD)
First, as the proposal correctly notes, the overwhelming majority of prospective light-duty purchasers focus on fuel economy only when fuel prices are relatively high and only as a relatively minor criteria when compared to other vehicle attributes. I believe that this reality will continue to be the case for model year 2012 and on into the future. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 41-42]

National Automobile Dealers Association (NADA)
First, as the joint proposal correctly states, most prospective light-duty vehicle purchasers only focus on fuel economy when fuel prices are relatively high, and only as a relatively minor criterion when compared to other vehicle attributes. I will tell you from being a Honda dealer we are definitely focused and driven on fuel economy; however, it is a function of price.  That is what  interests consumers.  Right now, they're not that interested.  Two years ago, top of the mind. So like anything in life, we tend to remember what's happening right now, and then when it goes away, it's not the top news story, so to speak.  Then we go away.  The fuel economy information labels, we really need to leverage this reality and not fight it.  It is the way it is. Second, even fewer prospective purchasers consider greenhouse gas and other emissions when shopping for new cars.  That doesn't mean that they don't want cleaner and greener cars; it's just, basically, they recognize that new vehicles are cleaner and greener. Anything they trade in, the new car is going to be better.  And again, NHTSA and EPA should strive to leverage that and not fight this.  I believe in life you have to deal with things how they are and not sometimes how you hope they are. Third, prospective purchasers who focus on fuel economy or emissions performance tend to evaluate comparative information before coming into a dealership. 90 percent of all consumers -- and I think that's a low number -- look on the Web site, narrow their choices down. Everything you buy you look on the Web site before.  If you want a camera, you look on the Web site. They are doing their homework before they go in, and they narrow it down to some choices.  This simply reflects how new vehicle shopping is done these days. Customers use the Internet to look at comparative information and make preliminary purchase decisions in the comfort of their home or office -- I'm sure they're not doing it on work time -- before they arrive at the dealership to test-drive vehicles. Now, that doesn't mean the labels lack value or that dealers shouldn't print out the Department of Energy's Economy Guide for Purchasers who ask for one. It's just one more truth EPA and NHTSA must account for and accommodate. [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 33-34.]
Response:
The agencies understand that consumer interest in fuel economy is directly correlated to the price of gasoline.  Gasoline prices have fluctuated significantly over the last several years and currently stand at over $4 a gallon for much of the United States, likely leading to a renewed consumer focus on fuel economy.  Regardless of gasoline prices, the label is designed to efficiently convey fuel economy and environment information to consumers.  As NADA commented, we do expect many consumers to do vehicle comparisons on the web, which is exactly why we are developing more detailed web comparison tools including an emission calculator and information on emissions that will be created by electricity generation.
Organization: Securing America's Future Energy (SAFE)
Comment:
Securing America's Future Energy (SAFE)
Information That Belongs on the Label [EPA-HQ-OAR-2009-0865-7522.1, p.4]
As a general matter, the most critical information on the label includes the following vehicle characteristics: 1) operating cost; 2) emissions profile; and 3) oil consumption. [EPA-HQ-OAR-2009-0865-7522.1, p.4]
Response:
The label will include information on fuel costs, but not maintenance costs.  Maintenance costs are beyond the scope of this label.  The label will also include information about greenhouse gases and combined smog emissions, and additional emissions information will be available on the website. Both fuel economy and fuel consumption numbers will be shown on the label.

3.1. Fuel Economy Performance & Consumption
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Organization: Alliance of Automobile Manufactures (Alliance)
Association of International Automobile Manufacturers (AIAM)
Environmental Defense Fund (EDF)
Natural Resources Defense Council (NRDC)
Diesel Technology Forum
Toyota
Electric Drive Transportation Association (EDTA)
Edison Electric Institute (EEI)
National Automobile Dealers Association (NADA)
California Air Resources Board (CARB)
Tesla Motors
Securing America's Future Energy (SAFE)
Institute for Policy Integrity - New York University School of Law
Nissan
National Renewable Energy Laboratory (NREL), Center for Transportation Technologies & Systems (CTTS)
BorgWarner
Argonne National Laboratory
Center for Biological Diversity (Center)
International Council on Clean Transportation (ICCT)
Honda Motor Company
National Petrochemical and Refiners Association (NPRA)
U.S. Coalition for Advanced Diesel Cars
Consumers Union
National Wildlife Federation (NWF)
University of Pennsylvania Law School, Environmental Law Project
Natural Gas Vehicles for America (NGVAmerica)
Smith, Houston
Steele, John M.
Priddy, RL
California Cars Initiative
Catania, Andrew
Honeywell
Foster, Marcus
Johnson, Evan W.
Siegel+Gale
National Association of Minority Auto Dealers (NAMAD)
Duoba, Mike
United Transportation Advisors
Community Environmental Council
Abbat, Pierre
Comment:
Fuel Economy Metric
The agencies proposed to retain the current practice of placing MPG on the label for vehicles that use liquid fuels such as gasoline and diesel.  There are two main reasons for this.  First, representing the vehicle's fuel economy performance on the label with an estimate of miles per gallon is a core element of the fuel economy information requirements of EPCA, which specifically states that the label must display "the fuel economy of the automobile" [1] and defines "fuel economy" as "the average number of miles travelled by an automobile for each gallon of gasoline (or equivalent amount of other fuel) used, as determined by the Administrator." [2]   Historically, the label has presented this information in terms of gallons of purchased fuel, since this is the most meaningful for the consumer.  Thus, gasoline vehicle labels have historically displayed miles per gallon of gasoline, while diesel vehicle labels have displayed miles per gallon of diesel. [3]  Second, consumers are very familiar with the MPG metric, as it has been the ubiquitous fuel economy metric for liquid fuels on vehicle labels since 1977.
Comments overwhelmingly supported the use of MPG for gasoline and diesel vehicles. The one major exception was the American Council for an Energy Efficient Economy, which advocated that diesel vehicle fuel economy values be calculated on an MPGe basis to reflect the higher energy content of diesel fuel.
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.
Fuel Consumption Metric
In the past few years, many stakeholders and academics have suggested that a fuel consumption metric--such as gallons per 100 miles -- could be beneficial on the fuel economy label as either a replacement for, or a complement to, MPG.  This could serve to address the fact that, with fuel economy, there is a non-linear relationship between gallons (or gasoline-equivalent gallons) used over a given distance and MPG (or MPGe).  Accordingly, a certain MPG improvement at a lower MPG level saves much more fuel (and thus money) than the same MPG improvement at a higher MPG level; this is known as the "MPG illusion."[4]  These stakeholders suggest that the public would be better equipped to make economically sound purchasing decisions with a metric that directly reflects fuel consumption and, correspondingly, fuel costs.   In response to these suggestions and concerns over the MPG illusion, the proposal introduced fuel consumption on the label, in the form of gallons per 100 miles for combined city/highway operation, as a complement to the MPG metric for liquid fuels.
Many comments were received on the general question of whether a fuel consumption metric should be added to gasoline vehicle labels and there was broad support for doing so, including, among others, the Argonne National Laboratory, Association of International Automobile Manufacturers, Honda, Hyundai, Toyota, Center for Biologial Diversity, International Council on Clean Transportation, Environmental Defense Fund, Natural Resources Defense Council, Consumers Union, American Automobile Association, Borg Warner, California Cars Initiative, Community Environmental Council, National Renewable Energy Laboratory, Securing America's Future Energy, University of Pennsylvania Law School, and the MIT Research Group.  Most supporters cited the non-linearity associated with the MPG illusion, and suggested that it was important to begin the process of educating consumers about fuel consumption, while also keeping fuel economy metrics.  There were a few opponents of including fuel consumption metrics, such as the California Air Resources Board, the Alliance of Automobile Manufacturers, Ford, and the National Automobile Dealers Association, who generally argued that fuel consumption was not important enough to warrant adding yet more numbers to the label.

[1] 49 U.S.C. 32908(b)(1)(A).  EISA also requires fuel economy information.  See 32908(g)(1)(A).
[2] 49 U.S.C. 32901(a)(11).
[3] Similarly, for those manufacturers who elect to put E85 information on the label for a flexible-fueled vehicle, it would be displayed as miles per gallon of E85.
[4] An example of this "MPG illusion" is that a 20 MPG vehicle uses 25% less fuel than a 15 MPG vehicle, while a 40 MPG vehicles uses only 12.5% less fuel than a 35 MPG vehicle; that is, the same 5 MPG improvement will have different effects on fuel consumption (and fuel costs) depending on the starting point for the improvement.  An extreme example is that, at a fuel economy of 1000 MPG, the fuel consumption is so minute (0.001 gallons per mile) that it no longer matters whether the fuel economy is increased to 1010 MPG, 2000 MPG, or even 1,000,000 MPG; the only fuel that can be further saved is some fraction of that 0.001 gallons per mile.
Response:
Fuel Economy Metric
The agencies are requiring the use of MPG for liquid fuels for the same reasons articulated in the proposal:  historical implementation of the EPCA requirements, consumer familiarity, and the fact that these fuels are purchased by the gallon.  We believe that changing to MPGe for the fuel economy of diesel vehicles would be very confusing to consumers, as label MPGe values would then be inconsistent with all consumer calculations of fuel economy (since diesel is sold in volumetric gallons) as well as fuel economy values shown on vehicle dashboard displays. 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,[1] 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). [2]
Fuel Consumption Metric
The widespread commenter support for including fuel consumption metrics echoed EPA's concerns about the MPG illusion.  EPA agrees that a fuel consumption metric is a better tool for making economically sound decisions and recognizes that it will not become widely utilized if it is not first introduced on the label. Therefore, EPA is requiring the use of fuel consumption on the label--in the form of gallons per 100 miles for combined city/highway operation for liquid fuels--though in reduced prominence relative to the traditional MPG metric.

[1] "Values are based on gasoline and do not reflect performance and ratings on E85."
[2]In addition, as required under EPA's authority in EPCA, the Fuel Economy Guide and web site will continue to provide the fuel economy estimates on E85, the driving range on E85, and information about how the performance might change when operating on mixtures of E85 and gasoline.

3.2. Greenhouse Gas Performance
                                                                             72
Organization: California Air Resources Board (CARB)
Naghdi, Kamran Michael
California New Car Dealers Association
Energy Independence Now (EIN)
National Association of Minority Auto Dealers (NAMAD)
Comment:
California Air Resources Board (CARB)
We recommend using a different scale for  rating a car's greenhouse gas emissions.  We believe it  may be confusing for consumers to see two different  scales on the label; one that uses a score for other  pollutants, and one that uses an absolute value for  greenhouse gas emissions.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 131.]

California New Car Dealers Association
I guess two suggestions that we would have  would be to include more contextual information.  On  Label 2 you have the environment section which has  greenhouse gas emissions on the zero to 850 scale and the other pollutants from 1 to 10.  We would like to  have a bracket showing how those scores compared to  other vehicles in the same class.  We think that would  be helpful for consumers and helpful in informing our  consumers how the vehicle compares.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 70-71.]

Energy Independence Now (EIN)
While fuel efficiency is a critical metric the  consumer already uses to compare vehicles to one  another, the introduction of a metric that accounts for  all greenhouse gas emissions is equally important.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 122.]

Naghdi, Kamran Michael
I commed your idea for labelling the vehicles CO2 foot print. any such measures will create consumer and OEM awareness. [EPA-HQ-OAR-2009-0865-3497, p.1]
In my opinion, one needs to adopt a long term and whollistic policy. And that is what EcoCa has done.  [EPA-HQ-OAR-2009-0865-3497, p.1]
In the USA, 1.5M workers drive to work, the production lines and paint shops are highly polluting when some of the OEMs claim to be producing zero emissions vehicles.  [EPA-HQ-OAR-2009-0865-3497, p.1]
EcoCa, Greener All the Way, starts by providing pre-engineered, modular, free worker housing made next to the plant using Renewable Energy in order to reduce commuting. The factory can be powered 100% by renewable energy. Our three quadri-cycle, light weight, low cost vehicles (EcoCa Electric, EcoCA hybrid petrol/CNG and 340cc (US made engine) have the lowest petrol consumption for long distance driving) have true zero emissions all the way.  [EPA-HQ-OAR-2009-0865-3497, p.1]

National Association of Minority Auto Dealers (NAMAD)
Second, despite the new mandate set out in section 105 of EISA, even fewer prospective new vehicle purchasers consider a vehicle's greenhouse gas or other emissions when shopping. As with fuel economy, I do not expect emissions performance to play a significant role in most new vehicle purchase decisions in moving forward as the overwhelming majority of customers at least implicitly recognize that vehicles are highly regulated to meet strict fuel economy and emissions performance standards. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 42]
Response:
The agencies are finalizing a label with a greenhouse gas rating on a 1-10 scale, consistent with the format of the smog rating.  We feel that including this information is the best way to meet our statutory requirements in EISA and provide meaningful information to consumers.
The agencies decided to include information for within class comparisions in a text statement next to the combined Fuel Economy and Greenhouse Gas slider bar.  The agencies considered label designs using a bracket to identify within class comparisions (as suggested by the California New Car Dealers Association) for the Fuel Economy slider bar, however for the final design the Fuel Economy and GHG ratings were merged on to one slider bar and the seperate bracket for within class comparisions was not compatible.
The agencies agreed that GHG metric will be based on tailpipe CO2, emissions.  The large majority of GHG emissions from the tailpipe of a vehicle are CO2 and adding small amounts of other GHGs would not ultimately provide consumers with more information to compare vehicles.

3.2.1. Methodology
                                                                             74
Organization: Toyota
California Air Resources Board (CARB)
Securing America's Future Energy (SAFE)
National Wildlife Federation (NWF)
University of Pennsylvania Law School, Environmental Law Project
Comment:
California Air Resources Board (CARB)
We recommend that you include all greenhouse gas pollutants in a vehicle's total greenhouse gas emissions. [EPA-HQ-OAR-2009-0865-7527.1, p.3]
National Wildlife Federation (NWF)
Greenhouse gas emissions are a critical environmental performance measure, and one that will become increasingly central over the lifetime of the vehicles receiving these new labels. It also provides an important crosscutting metric that consumers can use to assess environmental performance across diverse technologies. Greenhouse gas emissions should be amongst the criteria most prominently displayed on the label. [EPA-HQ-OAR-2009-0865-7528.1, p.3]
Securing America's Future Energy (SAFE)
Emissions profile: Concerns about the environmental sustainability of fossil fuels have grown in prominence in recent decades. The Department of Energy reports that from an end-use perspective, the transportation sector is the single largest source of U.S. CO2 emissions, having surpassed industrial emissions in 1999. In 2009, total domestic emissions from petroleum -- 70 percent of which is used in transport -- were 2,306 million metric tons (40 percent of total emissions). At current levels, U.S. oil consumption in the transportation sector is simply inconsistent with even moderate goals for reducing economy-wide emissions of greenhouse gases. These concerns were central in EPA's decision to begin regulating greenhouse gas emissions from the light-duty fleet beginning in 2012, and the medium- and heavy-duty fleet beginning in 2014. [EPA-HQ-OAR-2009-0865-7522.1, p.5]
Light-duty vehicle emissions not only represent a substantial portion of the nation's carbon emissions, they also represent a substantial externality of operating a vehicle that many consumers may not take into account, or even be fully aware of. To help consumers understand the true environmental consequences of their choice in vehicle, and to assist consumers who want to drive cars with lower emission profiles, vehicles' emissions, of both carbon and criteria pollutants, should be included on the label. [EPA-HQ-OAR-2009-0865-7522.1, p.5]

Toyota
Toyota agrees with the agencies proposal that the greenhouse gas information be based on CO2 emissions for the vehicle model type, rather than the carbon-related exhaust emissions (CREE) methodology. The use of CREE would only add a level of complexity that would not be conducive to public understanding of GHG emissions between vehicles. [EPA-HQ-OAR-2009-0865-6901.1, p.5]
University of Pennsylvania Law School, Environmental Law Project
We concur with EPA and NHTSA that only CO2 emissions ought to be included in the greenhouse gas (GHG) performance values, due to the fact that (1) CO2 comprises approximately 95% of tailpipe GHG emissions, and (2) the inclusion of CH4 and N2O emissions, which are currently set at the same level for all vehicles rather than calculated according to individual vehicle's emissions, would add no meaningful information to the GHG performance values. [EPA-HQ-OAR-2009-0865-7171.1, p.4]
Response:
The agencies agree with commenters that it is important to include greenhouse gas (GHG) information on the label, and in fact are required to include this information under the Energy Independece Security Act of 2007.  The agencies agreed that the label will be based on tailpipe CO2 emissions.  As the commenter from the University of Pennsylvania noted, CO2 makes up 95% or more of tailpipe GHG emissions, therefore adding other GHG emissions would complecate the label without providing the consumer with any significant additional information.  The agencies agreed with Toyota that we do not want to introduce the complexity of carbon-related exhaust emissions (CREE) calculations into the labeling process.

3.2.2. A/C Credits
                                                                             76
Organization: Toyota
California Air Resources Board (CARB)
Institute for Policy Integrity - New York University School of Law
International Council on Clean Transportation (ICCT)
University of Pennsylvania Law School, Environmental Law Project
Comment:
California Air Resources Board (CARB)
We recommend including air conditioning (A/C) credits as part of a vehicle's greenhouse gas emissions. This may give manufacturers more incentive to use advanced A/C systems on their vehicles. [EPA-HQ-OAR-2009-0865-7527.1, p.3]

Institute for Policy Integrity - New York University School of Law
The Agencies Should Take into Account Air-Conditioning Credits Earned by Manufacturers [EPA-HQ-OAR-2009-0865-7136.1, p.15]
Onboard air-conditioning systems contribute to greenhouse gas emissions through leakage of hydro fluorocarbon ("HFC"), and through the additional load running the air-conditioning places on the vehicle's engine, reducing fuel efficiency, and proportionally increasing emissions. Currently, manufacturers can generate credits towards their greenhouse gas compliance obligations by reducing leakage of HFCs from the air-conditioning. [EPA-HQ-OAR-2009-0865-7136.1, p.15]
The agencies should factor these credits into the greenhouse gas emissions values that appear on the fuel economy label. HFCs are a significant greenhouse gas, and manufacturers should be rewarded for reducing HFC leakage by having the credits they earned factored into the information customers see on the fuel economy label. Further, consumers should be informed, as much as possible, as to actual the environmental impact of the vehicles they drive. [EPA-HQ-OAR-2009-0865-7136.1, p.15]
In the unlikely event that the agencies find that that including air-conditioning credits in greenhouse gas calculations would significantly delay the rule, they should consider including this analysis in their post-promulgation research agenda. [EPA-HQ-OAR-2009-0865-7136.1, p.15]

International Council on Clean Transportation (ICCT)
Air Conditioning Credits for Greenhouse Gas Emissions [EPA-HQ-OAR-2009-0865-7118.1, p.6]
Greenhouse gas credits should not be include on the label for air conditioning. Air conditioning systems will move to systems with virtually no greenhouse gas emissions in the next 3 to 7 years, so the credits will become meaningless in a short period of time. Further, the contribution of air conditioning to overall greenhouse gas emissions is much smaller than the greenhouse gas emissions from production and disposal of the vehicle, which are also not included. [EPA-HQ-OAR-2009-0865-7118.1, p.6]

Toyota
Toyota does not agree with the inclusion of an air conditioning (A/C) factor in the GHG performance used for labeling, originating from the AIC credits generated under the light duty vehicle GHG requirements. Including AIC related credits for reporting CO2 reductions would not reflect technical accuracy because these reductions are not measured tailpipe reductions. [EPA-HQ-OAR-2009-0865-6901.1, p.5]

University of Pennsylvania Law School, Environmental Law Project
We do not believe that the letter grade should include any information about the A/C leakage of the car. A/C leakage is already figured into overall GHG emissions using the standard 5-part test. Therefore, allowing manufacturers to boost their letter grade by decreasing A/C leakage would essentially be "double dipping" and could convey false information to consumers. A more appropriate place to display information about A/C credits is on the website. [EPA-HQ-OAR-2009-0865-7171.1, p.4]
Response:
The agencies decided that the label will reflect tailpipe emissions, and accordingly A/C credits will not be incorporated into the GHG emission numbers or GHG rating.  There are two components of an air conditioning system that impact the GHG emissions of a vehicle, air conditioner efficiency and refrigerant leakage.  Air conditioner efficiency , or how much energy the vehicle engine must provide to run the air conditioning system, does affect tailpipe GHG emissions and manufacturers choosing a more efficient air conditioner may see a reduction in the GHG label numbers.  Air conditioner leakage credits will not be included in the label calculations, since the agencies decided the label should reflect tailpipe emissions.  Reducing the amount of leakage and using refrigerants with less global warming potential are both targeted under the light duty GHG rules and other EPA air conditioning programs.

3.2.3. Units
                                                                             78
Organization: Alliance of Automobile Manufactures (Alliance)
American Council for an Energy-Efficient Economy (ACEEE)
Comment:
Alliance of Automobile Manufactures (Alliance)
Measurement for GHG Performance [EPA-HQ-OAR-2009-0865-6850.2, p.12]
The Alliance agrees that GHG performance would be most transparent to the consumer if expressed in grams per mile. [EPA-HQ-OAR-2009-0865-6850.2, p.12]

American Council for an Energy-Efficient Economy (ACEEE)
Units for Representing Greenhouse Gas Emissions
Greenhouse gas emissions should be represented as annualized tons of CO2 equivalent rather than grams per mile. The most compelling reason for expressing emissions in annual tons rather than grams per mile is that consumers are likely more familiar with the former presentation than the latter. This is borne out in comments noted in the Federal Register (58135): participants reported understanding the environmental information in general, but did not understand the meaning of 'grams of CO2'. [EPA-HQ-OAR-2009-0865-7135.1, p. 9]
Providing emissions in annual tons may be familiar to consumers from other contexts, whereas a grams per mile (CO2 g/mile) representation requires the consumer to perform more calculations to yield a familiar metric. Given the limited viewing time of vehicle labels, it is unlikely that the proposed grams per mile presentation will yield useful information for the consumer. Furthermore, expressing the environmental rating in units of grams of carbon dioxide per mile does not allow for easy comparison with carbon emissions reported in other contexts, and therefore does not allow consumers a quick, easy means of understanding the magnitude of their vehicles' carbon emissions. [EPA-HQ-OAR-2009-0865-7135.1, p. 9]
While grams per mile might appear to have special relevance given that this is the unit in which GHG emissions from vehicles are now regulated, the gap ("shortfall") between grams per mile for purposes of compliance and real-world grams per mile would become a perennial source of confusion, as it has for fuel economy, if this is the unit used on the label. [EPA-HQ-OAR-2009-0865-7135.1, p. 9]
The second reason for expressing emissions in annual tons is an issue of framing. Expressing emissions in 'tons per year' has more impact than 'grams per mile' because a ton sounds like so much more than a gram. This difference may influence consumers' perceptions of the importance of including the new environmental metrics in their purchase decisions: if grams are perceived as insignificant, then the entire metric may be ignored. [EPA-HQ-OAR-2009-0865-7135.1, p. 9]
Lastly, just as expressing fuel savings over five years conveys a better sense of the value of this benefit than, say, cents saved per mile, expressing emissions as annual tons is a more meaningful framing of environmental impact. [EPA-HQ-OAR-2009-0865-7135.1, p. 9]
Response:
Organization: Association of International Automobile Manufacturers (AIAM)
Ford Motor Company (Ford)
Toyota
Institute for Policy Integrity - New York University School of Law
Center for Biological Diversity (Center)
Honda Motor Company
University of Pennsylvania Law School, Environmental Law Project
Comment:
Association of International Automobile Manufacturers (AIAM)
Regarding the request for comments on use of "grams per mile" or some other metric for GHG, AIAM supports the use of grams per mile as the GHG performance metric. [EPA-HQ-OAR-2009-0865-7134, p.4]

Center for Biological Diversity (Center)
Grams of CO2 Per Mile is an Appropriate Metric for Tailpipe GHG Emissions. [EPA-HQ-OAR-2009-0865-7122.1, p.3]
New vehicle labels must contain GHG performance information. The Agencies propose to use grams per mile of CO2 as the sole basis for GHG emissions performance in the Proposed Revisions. We agree that this choice can serve as a reasonable proxy, considering that CO2 constitutes 95% of tailpipe GHG emissions and is applicable to all vehicles: the grams per mile metric pertains to electric vehicles, dual fuel vehicles, gasoline vehicles, and flex fuel vehicles alike. Because of its universal application, this metric allows consumers to evaluate the tailpipe emissions of each vehicle regardless of class designations. [EPA-HQ-OAR-2009-0865-7122.1, p.3]
Fourth, the grams of CO2 per mile metric should be included in a larger font to highlight the metric's environmental importance and the direct correlation between fuel consumption and CO2 emissions. [EPA-HQ-OAR-2009-0865-7122.1, p.9]

Ford Motor Company (Ford)
We support the CO2 information being presented on the label in absolute form (grams/mile) to help with transparency to the consumer. CO2 values, in units of grams/mile, will directly relate to the performance of a vehicle and help with consumer introduction and acceptance of this new greenhouse gas performance metric. [EPA-HQ-OAR-2009-0865-7141.1, p.3]

Honda Motor Company
In the case of CO2, we believe that the grams/mile data itself will become a key indicator for consumers. Combining or evaluating this data with other data is unnecessary and adds clutter to a label chock full of information. [EPA-HQ-OAR-2009-0865-6774.1, p.2]
CO2 Metric: The agencies seek comment on the type of metric for CO2, whether this should be in grams/mile, tons/year, or displayed on another scale entirely, such as a one through ten scale. Honda supports the use of a grams/mile metric. The grams/distance metric is gaining currency globally, and increasing consumer awareness of this value will be an important accomplishment of this label. The grams/mile metric will bring the consumer in-line with the policy discussion affecting their future vehicle choices. Furthermore, one through ten scales tends to be relative and not absolute values and change over time. If "ten" is the best on the scale, a score of six one year might be a score of five the next. Changing relative scales tend to decrease consumers' confidence in the value of the information. Please see our prior discussion on upstream emissions. [EPA-HQ-OAR-2009-0865-6774.1, p.4]

Institute for Policy Integrity - New York University School of Law
Carbon Dioxide Information Should be Presented in Tons Per Year [EPA-HQ-OAR-2009-0865-7136.1, p.16]
The fuel economy label should provide consumers with information about the vehicles they drive in a way that is salient and not confusing; this means that information should be presented as it is most commonly understood. With respect to carbon dioxide emissions, the information should be presented in tons per year rather than grams per mile. Grams per mile may lack salience. The ton is the most common metric for carbon emissions in the public discourse, and the principal sponsor of the program's reauthorizing legislation mentioned emissions per year rather than per mile. Additionally, tons per year is the metric EPA already uses in its recommendations for how to calculate green house gas emissions for passenger vehicles. Given that consumers are already familiar with measuring greenhouse gases in tons, they will most readily understand the new vehicle labels if the agencies continue this practice. [EPA-HQ-OAR-2009-0865-7136.1, p.16]

Toyota
Toyota supports EPA's proposal to use grams per mile as the metric to display greenhouse gas performance information on the label because it is consistent with the metric already under consideration for GHG emission standards and compliance for light duty vehicles. [EPA-HQ-OAR-2009-0865-6901.1, p.6]

University of Pennsylvania Law School, Environmental Law Project
Carbon output measurements should continue to be depicted in grams per mile, rather than tons per year. Not only are consumers accustomed to thinking of vehicle fuel consumption and emissions in terms of "per mile," this measurement is also very definite and allows the consumer to determine how much GHG a given car will release every year by simply multiplying this number by the number of miles they estimate they will drive that year. [EPA-HQ-OAR-2009-0865-7171.1, p.5]
Response:
The agencies agree with the majority of commentors that grams per mile is the appropriate metric for displaying greenhouse gas (GHG) emissions on the fuel economy label.  We agree that grams per mile is analogous to the miles per gallon fuel economy number that has traditionally been, and remains, the focus of the fuel economy label.  The final label design shows GHG emissions in grams per mile, in addition to the 1-10 rating scale.  Additional metrics, such as tons per year, may be added to the website at a later time.

3.3. Fuel Economy and GHG Rating Systems
                                                                             82
Organization: Alliance of Automobile Manufactures (Alliance)
Comment:
Alliance of Automobile Manufactures (Alliance)
Comparison of Median Values [EPA-HQ-OAR-2009-0865-6850.2, p.11]
The comparison to median values for each model year would lead to consumer (and manufacturer) confusion, especially if this would result in mid-year rating adjustments as new models are introduced or in a lower rating for the same vehicle in a later model year. [EPA-HQ-OAR-2009-0865-6850.2, p.11]
Response:
We agree that mid-year rating adjustements could lead to situations where vehicles sitting next to each other on the lot would have values that are not directly comparable, and that this would be undesirable.   Therefore, we do not intend to adjust rating systems or median vehicle values mid-model year.  We plan to provide guidance prior to each model years that will be used on for all vehicles of that model year.  It is true that vehicles of different model years would then have ratings that are not directly comparable; however, we believe that it is more important that the rating systems and the median vehicle reflect the new vehicle fleet as it evolves than that vehicles of different model years have comparable ratings.  For those who wish to compare vehicles across model years, the label and website provide MPG and g/mi values that can be directly compared.
Organization: International Council on Clean Transportation (ICCT)
Comment:
International Council on Clean Transportation (ICCT)
The studies also found that it is important to limit the number of grades and regularly adjust the requirements for each grade. [EPA-HQ-OAR-2009-0865-7118.1, p.3]
Response:
The final label design will have a 1-10 greenhouse gas rating instead of a letter grade.  The scale will be evaluated annually, and adjusted if necessary.
Organization: Natural Resources Defense Council (NRDC)
Toyota
Securing America's Future Energy (SAFE)
AAA
EcoMotors International, Inc.
California New Car Dealers Association
Comment:
AAA
Label 2 offers easy-to-read, sliding scales that provide consumers with a comprehensive overview of the environmental performance, and energy cost savings of the particular vehicle under consideration. These scales also are very similar to labels first affixed to cars being sold in California in 2009 as a result of a state law mandating both a Smog Score and Global Warming score. These labels have been widely accepted and adopted by thirteen other states across the country. As many consumers are already familiar with this configuration AAA supports its further utilization. [EPA-HQ-OAR-2009-0865-6914.1, pp.1-2]

California New Car Dealers Association
MR. MEDFORD:  And finally, the last question I  have is:  The Congress requires us to have this rating  scale for rating vehicles and we've done that, and the  slider bar both for greenhouse gases and fuel economy,  and we have this category of vehicles that the EPA uses  to designate.  Are you okay with that approach?  MR. MORRISON:  Yes.  Our members have said  that having the category -- we do like having the  bracket within the slider bar.  MR. MEDFORD:  And you had mentioned for the  greenhouse gases you don't like the words 'best' and  'worst,' and that's true for the fuel economy too?  MR. MORRISON:  Absolutely.  If you look in our  prepared testimony, we do include all of the labels, and  on the last page we actually have the CARB label down  there.  And as you can see, there's the number down at  the bottom.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 78.]

EcoMotors International, Inc.
The agencies seek comment on whether separate ratings should be provided for other emissions or whether a single combined rating for fuel economy, GHG and other emissions should be provided. [EPA-HQ-OAR-2009-0865-6851.1, p.6]
The Energy Independence and Security Act of 2007 (EISA) requires that each new vehicle be labeled with a rating system that includes 'a designation of automobiles with the lowest greenhouse gas emissions over the useful life of the vehicles; and the highest fuel economy.' EcoMotors favors transparency in vehicle labeling and believes that fuel economy, GHG emissions, and other emissions (if the agencies choose to include information on other pollutants) should be separately identified on vehicle labels. GHGs and other emissions should reflect upstream emissions from fuel production and distribution in order to achieve equity across different vehicle technologies. Consumers should be given the opportunity to weigh the relative importance of these metrics for themselves. [EPA-HQ-OAR-2009-0865-6851.1, p.6]

Natural Resources Defense Council (NRDC)
MR. MEDFORD: This could be for any of you, but the law requires us to provide, you know, the scales that we have for both fuel economy and for criteria pollutants or smog emission pollutants, a rating for the entire fleet. And so we sort of have to do that and provide that. We also have considered at one point within that scale doing it by the category of vehicle you're buying, but it really does add sort of a level of complexity, and we decided not to do that in this proposal. Do you have a view about that? [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 35-36; This question posed by EPA was also answered by Ron Minsk, pp.33-37]
MR. TONACHEL: I think it's also a matter of emphasis, I think as I was pointing out, the letter grade is helpful because it can be used very quickly early in the buying process. But that doesn't take away the need to provide more detail in the label as well. I think you can cross a number of things that you provide in a label, which may not be the first thing that you look at, but that doesn't mean you shouldn't have them on there. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 37]

Securing America's Future Energy (SAFE)
MR. MEDFORD: This could be for any of you, but the law requires us to provide, you know, the scales that we have for both fuel economy and for criteria pollutants or smog emission pollutants, a rating for the entire fleet. And so we sort of have to do that and provide that. We also have considered at one point within that scale doing it by the category of vehicle you're buying, but it really does add sort of a level of complexity, and we decided not to do that in this proposal. Do you have a view about that? [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 35-36; This question posed by EPA was also answered by Luke Tonachel of Natural Resources Defense Council, pp.37]
MR. MINSK: I thought that on one of them you actually -- you did.
MR. MEDFORD: Is that 3MM.
MR. MINSK: I thought it was on two you did. You had a bar, and then it had -- I thought that that was Label 2, and I think that makes a lot of sense.
MR. MEDFORD: Hang on a second. It shows a range, but it doesn't break it down by vehicle type.
MR. MINSK: On one of them. On Label 2 it does.
MR. MEDFORD: You think that's not too confusing or do you have a view about it? You like that?
MR. MINSK: I like that. I think we have to give people a lot more credit than we are. I mean, people aren't -- people are capable of understanding more than the letter A and B and C, and they're capable of understanding, you know, all vehicles have a subset of vehicles. If we talk down to people, they'll act like we expect them to. If we talk up to them, they'll rise to the occasion.
[These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 35-37]

Toyota
Separate absolute ratings for F/E, GHG, & other emissions - as is being proposed on EPA's Label Option 1 and Label Option 2, and uses the same information but is distinguished via a different format: Toyota agrees that representing the ratings separately for F/E, GHG, and other emissions could provide the consumer with a useful comparison of each category among vehicles. [EPA-HQ-OAR-2009-0865-6901.1, p.6]
All the remaining information displayed in the bottom portion of the label would be available to consumers who want to know the more detailed information. Toyota does not agree with EPA's view that that this approach is easily understood by consumers and simplifies the process of evaluating the overall energy efficiency and environmental impacts of the vehicles consumers are considering. Toyota sees that co-displaying the grade rating with corresponding scale bars will diminish the significance of any grading system because consumers would be unclear as to what the grading scale truly represents. [EPA-HQ-OAR-2009-0865-6901.1, p.12]
Response:
The final label design maintains separate metrics for fuel economy, greenhouse gasses, and emissions that are precursors for smog.  The agencies agreed that separate metrics are useful to consumers, and that including the separate information will help consumers make an informed vehicle decision.  The slider bars that are used to show the relative rating of vehicles no longer show that a low rating is the "worst," though the high score does retain the "best" designation.
Two of the commenters approved of the metrics on the California vehicle label.  The final label design was in fact developed to include metrics that meet the California labeling requirements, including a 1-10 greenhouse gas rating scale.  California needs to determine whether this meets their labeling requirements.  California needs to determine whther this meets thei labeling requirements.  If so, this will allow for a harmonization of labels, which was a strong request from automakers.
Emissions due to electricity or other upstream activities will not be included on the label, but will be addressed on a website that will be launched with the new labels.

3.3.1. Fuel Economy Rating Slider Bar
                                                                             87
Organization: Toyota
Argonne National Laboratory
Comment:
Argonne National Laboratory
Exponential Data on Linear Scale
The slider bar is the one place where consumption must be provided. The sliding scale is designed to illustrate the differences among vehicles. Huge fuel savings will be hidden by small changes for low mileage vehicles and conversely, people will see exaggerated differences between high-mileage vehicles which actually represent very small amounts of fuel. [EPA-HQ-OAR-2009-0865-7572.1, p. 3; see commenter's Chevy Volt label at page 3]

Toyota
Label 2 displays the range of fuel economy of the applicable vehicle class, by means of a bracket on the slider bars, where as, Label 1 provides this information in text form. Toyota thinks that consumers will benefit most from understanding the fuel economy of the applicable vehicle class and EPA's graphical interpretation can be helpful in doing so. [EPA-HQ-OAR-2009-0865-6901.1, p.13]
Response:

<IP_ADDRESS>. Range of Fuel Economy for Comparable Vehicles
                                                                             88
Organization: National Renewable Energy Laboratory (NREL), Center for Transportation Technologies & Systems (CTTS)
Center for Biological Diversity (Center)
Gates, Matthew
Comment:
Center for Biological Diversity (Center)
The "How This Vehicle Compares" sliding scale common to Proposed Labels II and III is misleading because it downplays the overall environmental impacts of the vehicle by placing the vehicle, graphically, within a class-derivative emissions bracket. We acknowledge that the Agencies are statutorily required to include a statement that conveys the fuel economy range for comparable vehicles, but this information need not be conveyed graphically. Rather, it should appear in text form and in a small font size. Proposed Label I displays this preferred format, and is the option we encourage the Agencies to adopt. [EPA-HQ-OAR-2009-0865-7122.1, p.4]
Third, as described above, the "How This Vehicle Compares" sliding scale used in Proposed Labels II and III is misleading. Although the scale includes all CO2 emissions, it downplays the overall environmental impacts of the vehicle by placing it, graphically, within a class-derivative emissions bracket. We acknowledge that the Agencies are statutorily-required to include a statement that provides the fuel economy range for comparable vehicles, but this statement should be made in text-form, and in a smaller font. Proposed Label I displays such a format, and is the choice we encourage the Agencies to adopt. [EPA-HQ-OAR-2009-0865-7122.1, p.9]

Gates, Matthew
I am pleased to see the proposed fuel economy labels, which are a step in the right direction. I particularly like the 'How this vehicle compares' and 'other air pollutants' bars, which remind me of similar bars on appliance stickers. [EPA-HQ-OAR-2009-0865-1179, p.1]

National Renewable Energy Laboratory (NREL), Center for Transportation Technologies & Systems (CTTS)
I similarly recommend against using MPG or MPGe for the comparison slider bars on the label since MPG does not provide a linear comparison. If multiple sliders are presented on the label I believe it would be less confusing and would aid in the information campaign if they all reflected consumption and emphasized the lower number was better (less cost, less fuel required, less emissions, etc). I do think that the relative comparability across all vehicle classes is a good idea, with a sub-bracket indicating the range of vehicles in the same class. [EPA-HQ-OAR-2009-0865-7222, p.3]
Response:
The agencies do not agree with the Center for Biological Diversity (CBD) that the graphical approach to presenting MPG is misleading, and because the graphic shows both the within class comparison as well as the comparison to all vehicles the Agencies don't understand how the approach can possibly be misleading.  The CBD is correct that EPA is statutorily required to show the range of fuel economy of comparable vehicles, and presenting this in a graphical sliding scale has been done on the EPA fuel economy label since the 2008 model year.  When this format was established EPA found that a common response was similar that of Mr. Gates, in that the graphic was easily recognized and interpreted because it was familiar due to the use of a similar approach to showing the energy use of appliances.  The sliding scale for MPG that the agencies are adopting in the final rule - like those in the proposal - show both how the vehicle compares to all other vehicles and to how the vehicle compares to others in its class.  Thus the graphic meets the desires of the CBD to show the comparison to all vehicles as well as meeting the statutory requirement to show the range of fuel economy of comparable vehicles.  The agencies believe that this approach is the best possible way to present the information, allowing viewers to easily and quickly see in a familiar graphical format how a given vehicle compares to others in its class and to the broad set of all vehicles.  Relegating the within class comparison to fine print, as the CBD suggests, would at best be putting useful information where consumers are unlikely to see it, and at worst could be misleading or interpreted as an attempt to hide information.
The agencies understand NREL's comment that MPG does not facilitate a linear comparison.  However, the MPG slider bar is used to meet multiple statutory requirements, each of which requires a comparison using MPG.  The agencies believe that the presentation of a fuel consumption rate on the revised label is a reasonable start to getting consumers to understand that consumption is a metric that is directly tied to the impact on a consumer's fuel expenses.
Organization: Toyota
Comment:
Toyota
Range of FIE of Comparable Vehicles [EPA-HA-OAR-2009-0865-6901.1, p.7]
EPCA requires that the label contain the range of FIE of comparable cars from all manufacturers. EPA's 2006 labeling rule provided a graphical element in an attempt to meet this requirement. However, EPA's 2010 focus groups reported that this information continues to be under-utilize by consumers in making vehicle purchase decisions. Based on the results reported by EPA, Toyota would support EPA's proposal to simply provide a text statement that would read 'Combined fuel economy for {insert vehicle class} ranges from XX to XX,' in order to meet the statutory obligations and keep the label simple and useful. [EPA-HA-OAR-2009-0865-6901.1, pp.7-8]
Response:
The agencies believe that either approach noted by Toyota can be understood by consumers, and the approach ultimately selected represents an attempt to strike the right balance between use of graphical elements versus use of text.  The agencies agree that either approach will satisfy the statutory mandate.

3.3.2. GHG Rating Slider Bar
                                                                             91
Organization: California Air Resources Board (CARB)
Suzuki Motor Corporation
Comment:
California Air Resources Board (CARB)
We recommend using a different scale for rating a car's greenhouse gas emissions. We believe it may be confusing for consumers to see two different scales on the label - one that uses a 'score' for 'other pollutants' and one that uses an absolute value for greenhouse gas emissions. We found from our focus group research that consistent scales with the same rating system and value for best and worst are easier for consumers to understand. Therefore we recommend moving away from the absolute number on the greenhouse gas scale and moving toward a 1-10 rating similar to the scale used for 'other pollutants.' This would also avoid having to put 0 grams per mile of greenhouse gases for plug-in electric and fuel cell vehicles. [EPA-HQ-OAR-2009-0865-7527.1, p.3]

Suzuki Motor Corporation
Change the Greenhouse Gas bar to be similar like the California Environmental Performance Label (CEPL) Global Warming scale which uses a score from 1 thru 10 and does not have any colors except black text. Delete the text "Worst" and change from "Best" to "Cleanest" on the bar which can be pre-printed on the label. Change the rating number to be a simple printed number that is not enclosed within a pointer as proposed. See the sample Global Warming Score scale below. These changes will allow most manufacturers to use their current software and printers to print the new emission labels. [EPA-HQ-OAR-2009-0865-6900.1, p.3]
Response:
The agencies are requiring a relative greenhouse gas rating on a one to ten scale and an absolute greenhouse gas rating in text near the slider bar, both of which would be based on combined 5-cycle tailpipe CO2 emission rates, as measured by EPA.  The relative rating is intended to address the large number of comments received in support of a relative rating that allows a quick and easy assessment of a vehicle's relative environmental impact.  While a letter grade rating can be  readily understood, the agencies agree with some commenters' concerns that it may imply more meaning about overall vehicle attributes -- an assessment of overall quality on a number of factors--than was intended.  We recognize that the letter grade is a fairly significant departure from the current fuel economy label, which provides absolute numerical values and no relative ratings.  The agencies believe that the one to ten rating fills a middle ground between the absolute numerical values of the current label and a letter grade rating, providing a similar ease of use without conveying any perceived value judgment that may be associated with a letter grade.  Additionally, we agree that having consistent systems for the two environmental ratings on the label may help to minimize confusion and increase comprehension.  A one to ten scale was one of the options proposed for the greenhouse gas rating and is being finalized on the label for the smog rating; its use here would thus provde consistency between the environmental ratings on the label.  Finally,  the use here of a one to ten system is a logical extension of its use on the EPA Green Vehicle Guide web site and the California Environmental Performance Label, where it serves a similar purpose.
One challenge with a one to ten scale is that its directionality is not clear--that is, it is not immediately obvious if one or ten is the "best." It therefore lacks the clarity of a letter grade.  For this reason, we are including the word "best" at the "10" end of the scale.  We have not elected to use the word "cleanest" because doing so would not allow us to label all the slider bars in a consistent fashion; the more general term "best" is applicable acros fuel economy as well as emissions, and we have thus retained it here. We have eliminated the word "worst" from the "1" end of the scale as unnecessary.
We have also adopted changes to the design of the slider bar that will allow printing with black ink on card stock pre-printed with the blue elements.
Organization: Merritt, Kevin
Comment:
Merritt, Kevin
The current sliding scales have an opaque numbers in them. Those numbers overlap color on the scale If the sliders were moved up, then the color on these labels could be pre-printed. The current design would require just in time (color laser printers) to replace current mono printers. This could have significant costs implications for hardware and programming.[EPA-HQ-OAR-2009-0865-4723, p.1; this comment can also be found at section 3.3.1, 3.4.2 & 9.1 of this comment summary]
The sliding scale used has white letters. Becuase it overlaps the colored 'slider bar', this would require that the label be printed using a color printer. Preprinted color media would otherwise show through the the lower half of text of the arrow slider. If the arrows were simply placed above the slider, then pre-printed stock could be used. Also is there a specicification for the color used? (There are many shaded of yellow... or could other colors be used... or could grey be used, allowing existing pritnes to be used?) [EPA-HQ-OAR-2009-0865-3705, p.1; this comment can also be found at section 3.3.1, 3.4.2 & 9.1 of this comment summary]
Response:
Organization: Argonne National Laboratory
Comment:
Argonne National Laboratory
One Slider, Two Pieces of Information
The debate between presenting greenhouse gas and tailpipe-only or total-cycle emission need not be in conflict on the label.  Both pieces of information can be shown on the same slider. Once again fine print must be present to make sure that local emissions can be checked for a more accurate answer to consumer. But is must be noted that label information is used as a figure of merit summary and national averages WILL be important parameters for analysts (professional or lay) to compare a new technology vehicle's impact on society. [EPA-HQ-OAR-2009-0865-7572.1, p. 4; see commenter's new Volt label ANL suggestions at page 5.]
Response:
We have decided that the label is not the appropriate place to provide upstream emissions information.  Please see section 4.1 for a thorough discussion.
Organization: California Cars Initiative
Comment:
California Cars Initiative
The plots of overall MPG, CO2, and other pollutants on bar graphs read very well, too; and customers can relate to these graphs as similar to what they have been seeing for years on appliances. A minor point: why not rate CO2 in g/km instead of g/mile, as customers are unlikely to relate to the absolute number anyway, and g/km is what is used throughout the rest of the world? [EPA-HQ-OAR-2009-0865-4695, p. 1]
Response:
We considered a wide array of metrics for use on the label.  Although g/km has the advantage the commenter states, we decided not to adopt this approach because of its lack of consistency with the other values on the label, which are on the basis of miles.

3.3.3. Combined Fuel Economy & GHG Slider Bar on Label 3
                                                                             94
Organization: Alliance of Automobile Manufactures (Alliance)
Comment:
Alliance of Automobile Manufactures (Alliance)
Proposal for Single GHG/Criteria Emissions Rating [EPA-HQ-OAR-2009-0865-6850.2, p.11]
The Alliance does not support capturing GHG and criteria pollutant emissions in a single rating. Doing so would only confuse two very different categories of pollutants: one is local, one is global; one is controlled though tailpipe emissions and improvements in fuel quality, while the other is a function of miles driven and grams per mile, and cannot be controlled at the tailpipe. The "Label 2" approach is best with its separate yet equally prominent scales for fuel economy, greenhouse gas emissions and other emissions. [EPA-HQ-OAR-2009-0865-6850.2, pp.11-12]
Response:
We agree that it is challenging to combine GHGs and other emissions into a meaningful scale.  The rule finalizes separate ratings for each.
Organization: Renewable Fuels Association
Comment:
Renewable Fuels Association
While "Label 3" appears to offer the most information, it also appears the most cluttered and disorganized. Moreover, the proposed "Label 3" provides a combined metric for fuel economy and GHG performance. Combining these two metrics makes it difficult for consumers who may value GHG performance more than fuel economy (or vice versa) to make informed decisions and fair comparisons of the vehicle's individual attributes. [EPA-HQ-OAR-2009-0865-6926.1, p.6]
Response:
We agree that it is more helpful to portray fuel economy separately from greenhouse gases, since their relationship varies from one fuel to another and some people may value one attribute more than another.  This rule finalizes fuel economy values separate from the greenhouse gas ratings.
Organization: Hyundai Motor Company
Comment:
Hyundai Motor Company
Additionally, Label 3 lacks a comparative depiction of the vehicle's CO, rating compared to other models; we prefer Labels 1 and 2, which both include the comparison of CO, performance. [EPA-HQ-OAR-2009-0865-7139.1, p.6]
Response:
We have adopted greenhouse gas ratings that provde a comparative depiction of the vehicle's rating relative to all other new vehicles.
Organization: Toyota
Comment:
Toyota
Alternative Label Design (Label 3) [EPA-HQ-OAR-2009-0865-6901.1, p.13]
EPA also seeks comment on a third label design that includes the same information as the other labels, but displays alternative ways of communicating the information. [EPA-HQ-OAR-2009-0865-6901.1, p.13]
Toyota views the display of information on this proposal to be a distraction for consumers. In particular, the use of a combined greenhouse gas and fuel economy rating represented by one slider bar using a 1-10 rating scale further obscures the vehicle F/E and GHG performance, and the use of a star rating system might suggest a correlation with NHTSA' s rating system. [EPA-HQ-OAR-2009-0865-6901.1, p.13]
Response:
Although greenhouse gases and fuel eocnomy are related, this relationship varies from fuel to fuel; we have determined that it is difficult to have a rating that is meaningful across all fuels for both greenhouse gases and fuel economy.   Therefore, the label is being finalized with ratings for fuel economy and for greenhouse gases, with one slider bar for both ratings.  The ratings are defined such that gasoline vehicles will recieve the same rating for both fuel economy and GHG, and may combine the ratings to show only one combined indicator on the slider bar.  For other fuels, when the fuel economy and GHG rating are not the same, the agencies will require two indicators, one for fuel economy and one for GHG, on one slider bar.
We also agree that a star system could be confused with NHTSA's vehicle safety rating system, and have therefore chosen to not adopt this approach.

<IP_ADDRESS>. Range (D to A+)
                                                                             96
Organization: Natural Resources Defense Council (NRDC)
Comment:
National Resources Defense Council (NRDC)
The NRDC-proposed scheme could also better align the EPA/DOT rating scale with that of California. The NRDC scheme eliminates the A+ designation and reduces the letter grade scale from eleven levels (D to A+) to ten (D to A), which is same number used in the California Environmental Performance label. [EPA-HQ-OAR-2009-0865-6925.1, p.7]
Response:
The automotive manufacturers were very supportive of trying to harmonize the final label design with California's label requirements so that vehicles sold in California would not require an additional, unique label.  The final label utilizes a 1-10 GHG rating scale instead of the proposed letter grades that meets the requests of the automakers and NRDC.  California will need to determine whether our label meets their requirements.
Organization: Honeywell
Comment:
Honeywell
However, should the EPA/NHTSA move forward on 'Label Option 1', Honeywell would revise a letter system away from the 'A+ through D' proposal to a more objective approach such as 'A-J' or numerical system such as '1-10'. [EPA-HQ-OAR-2009-0865-7095.1, p.2]
In the Alternative, If  EPA/NHTSA Adopts a Letter Grading System, Honeywell Recommends that Proposed Label Option 1 Incorporates the Following Suggested Improvements:
If EPA/NHTSA maintain the letter grade approach under the Final Rule, we recommend that they revise the rating system away from the A+ through D school-like approach, which comes with significant preconceived connotations in the United States. The vehicle label must be balanced graphically to provide consumers with a fair representation of the entire and distinct environmental information required by EISA. The Final Rule must not overemphasize a single indicator; particularly one that consumers do not easily understand and is based on factors likely unknown to most. While we applaud the agencies' attempt to simplify the information on the label through the utilization of a grading system, we are concerned that proposed Label Option 1 and its prominent display of the grade will overshadow the valuable information with which consumers are most comfortable. [EPA-HQ-OAR-2009-0865-7095.1, p.4]
:: While Honeywell agrees that a letter grade approach may provide a 'format the consumers will recognize,' American consumers have preconceived notions about letter grades, particularly when limited to a school-like range of A+ through D as proposed by  EPA/NHTSA. In many communities, a grade of below an 'A' is often perceived as substandard and not satisfactory. A more neutral approach that expands or revises the letter ratings, such as A - J or 1 - 10 is preferable. [EPA-HQ-OAR-2009-0865-7095.1, p.4]
Response:
The final label includes a 1-10 GHG rating system, not the proposed letter grades, in response to this and other comments.
Organization: Center for Neighborhood Technology
Duoba, Mike
Comment:
Center for Neighborhood Technology
CNT recognizes the serious amount of thought and work that has gone into the creation of the draft labels and applauds the people at EPA and NHTSA who formulated those ideas and did that work. The results are impressive and CNT celebrates them. But meaningful labels also have meaningful cutoff points that properly identify the most and least fuel-efficient vehicles. Rating distribution should not be too heavily weighted to the center. There should be thicker tails on the ratings distribution, more A's and D's, if not F's, and fewer B's and B-. Reworking the distribution scale would come closer to the truth that not all vehicles are above average. That, for the environment and for everyday affordability, some vehicles are indeed failing. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 84]

Duoba, Mike
I think we understood the need -- or I understood the need that we would need a better resolution to score these vehicles as a letter grade, that the issue we're having between putting this type of vehicle in a specific class and all of the vehicles together. We need more resolution, so I would support the proposal that Hyundai mentioned earlier where you have this zero to 100 scale. It looks like a grade that you would have on a test, just like a letter grade, and you're within a specific class of vehicles and you can still decide which one is better than the other. There will be no incentive for a better, higher performing SUV if they all get a score of or D- or D+ or whatever. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 104-105]
MR. MEDFORD: Okay. And you also suggested that we go to a zero-to-100 scale, not the letter grade because -- [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 115]
MR. DUOBA: I agree that more resolution is better. I noticed that everybody's got a different opinion within a class or not within a class. Well, in the information that's provided, we can do both, and that's what you need. And I think the slider bar with that whole section of SUVs or whatever is a good idea. Again, it's consumption-based and not miles-per-gallon-based. It will help out. If you have a higher resolution, that would be fine. I don't know whether or not a letter grade is going to hit home with more consumers than a number that's like at 95 verses an 85 or something like that. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 115-116]
Response:
The proposed rating methodology resulted in a distribution of vehicle sores that was concentrated near the center of the scale.  Several commenters noticed this and asked the agencies to consider methods to "flatten" the distribution of vehicles in order to create more differentiation between the vehicles that make up the majority of the fleet.  The agencies agreed with this request.  The full methodology for determining the Fuel Economy and the GHG ratings is defined and discussed in detail in the preamble.
Essentially, the average vehicle is based on the expected CAFE fleet average for each year from 2012-2016, then the thresholds for the highest and lowest ratings are set by subtracting or adding two standard deviations (in terms of vehicle fuel consumption) from the mean, with the ratings in between defined by creating even sized "bins."  This approach does flatten out the distribution of vehicles as suggested by several commenters.
Organization: Tesla Motors
Comment:
Tesla Motors
For example, the Agencies have proposed the use of a letter grade to rank vehicles (i.e., option 1). Tesla believes that this type of approach is commendable in that it provides the type of general comparative information useful to consumers, allowing them to make choices based on relatively simple, straightforward metrics. Combining the metrics familiar to consumers, along with new information, can greatly enhance consumer knowledge and allow them to make more informed choices. [EPA-HQ-OAR-2009-0865-6933.1, p.2]
Response:
The final label design will include a 1-10 GHG rating instead of the proposed letter grades, however we belive that this maintains the "simple, straightforward" metrics that Tesla prefers.
Organization: Alliance of Automobile Manufactures (Alliance)
Auerbach, Jan (Lane)
Bullis, Kevin
Comment:
Alliance of Automobile Manufactures (Alliance)
Moreover, in the case of an A+ vehicle, there would be absolutely no reason to reduce emissions below 76 grams per mile, the level for an A+.
Finally, we believe the A, B, C, D ranking is arbitrary and unnecessary.  Consumers are more than capable of using the fuel economy CO2 and fuel consumed per hundred gallons to inform their decision.
[These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 16.]

Auerbach, Jan (Lane)
Given this history, I believe the fuel economy label should display most prominently the fuel economy for the particular label and not try to encourage customers to look at other vehicles that might have a higher letter grade. It is most likely that all the vehicles that a customer is interested in looking at would be in the same general class of vehicles, so that all the vehicles they cared about would have a B or a C, making the comparison meaningless. If someone is out to buy an SUV, they are not going to start looking at a hybrid simply because the government decided that the one rates an A and the other a D. The government should be in the business of providing facts and not directing customers to particular vehicles. While the concept is well intentioned, I believe the result of the letter grade label will be that the label is ignored since the information on it that really is important is in too small type for people to find and focus on. I urge you to retain the prominence of the city and highway number and don't adopt the letter grade label concept. [EPA-HQ-OAR-2009-0865-4916, p. 1]

Bullis, Kevin
In the 'graded' option, the grades aren't precise enough to make comparisons between vehicles and can be misleading since actual emissions can vary substantially for PHEVs depending on how they're driven. Would a EV get an A and a PHEV a B, even though they would have identical emissions if a person drove only short distances in all-electric mode? If they got identical grades, on the other hand, this would hide the fact that the PHEV would use gasoline if it weren't recharged often. [EPA-HQ-OAR-2009-0865-3415, p.1]
Response:
The final label will have a 1-10 GHG rating instead of the proposed letter grade, in response to these and other comments.  As described in the preamble, the methodology for defining the rating system has also changed in order to "flatten" out the distribution of ratings, resulting in more vehicles that score high (and low) ratings, and less vehicles clustered near the average ratings.  The agencies believe that this will help to provide more resolution between the ratings while maintaining the simplicity of a 1-10 rating system.
The finalized label does provide information on within class fuel economy comparisions, as required by EPCA.  The agencies decided not to make the GHG rating unique to each vehicle class because most consumers do shop across multiple vehicle classes, and the distinction between classes has become increasingly blurred with the proliferation of crossover type vehicles.
PHEVs present a unique challenge due to their unique and complex technology.  PHEVs are capable of operating on electricity, gasoline, or a mixture of both fuels.  How much of each fuel is consumed is highly dependant on many factors, including charging frequency, vehicle control strategies, trip lengths, etc.  The final labels provide enough information that consumers can make decisions based on their own driving and charging habits, however the overall GHG rating will be based on standard test cycles, which is the appropriate means for comparing the vehicle with other vehicles.  See the Preamble sections III.M and III.N for a detailed explanation of EV and PHEV test procedures.  As more PHEVs come to market, the agencies will continue to evaluate PHEV technology.
Organization: Hill, Joel
Comment:
Response:
Organization: Honda Motor Company
Comment:
Honda Motor Company
Other Emissions Performance Rating Systems: The agencies inquire as to the appropriateness of rating Other Emissions on a ten point scale (a scale similar to one shown in Table II.A.5-2). There is no clear way to show absolute numbers for these pollutants, since they are an amalgamation of many different pollutants. The ten point scale will vary as we move from Tier II to Tier III and from LEV II to LEV III. We prefer as absolute a scale as possible, especially one which shows the same scale for both cars and trucks. Currently there are different standards for cars and trucks and just as we recommend an absolute number for CO2, we recommend a scale as unchanging and consistent over time as possible. [EPA-HQ-OAR-2009-0865-6774.1, pp.4-5]
Response:
The agencies do not believe that it is scientifically sound to combine the emissions of very different air pollutants into a single absolute scale.  We also received no comments in support of presenting these pollutants on individual scales on the label.  Of the approaches considered, the ten point scale based on the set of emissions standards to which the vehicle is certified seemed to be the most readily understandable and to reasonably convey the relative emissions levels among new vehicles.

<IP_ADDRESS>. Methodology
                                                                            102
Organization: Lorenzo, Jose
Comment:
Association of International Automobile Manufacturers (AIAM)
AIAM is also concerned that the proposed  vehicle rating system in Label  does not allow  consumers to distinguish differences among vehicles  since over  80 percent of the vehicle models are closely  grouped together in the middle of the proposed grading  scale.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 55.]

Consumers Union
Recommendations
Our primary recommendation is to flatten the curve used for the letter grades to provide meaningful distinctions to consumers for cars in the middle of the curve and avoid overpacking the middle grades. Consumers buying vehicles on the extreme ends of fuel economy (such as plug-in electric vehicles or heavy SUVs) are probably aware they are on the extreme end of the fuel economy range. Making greater distinctions in the mid-range of the scale is likely to be more informative for most buyers than an overemphasis on the outliers. [EPA-HQ-OAR-2009-0865-7251.1, p.4]

Lorenzo, Jose
However, I prefer label 2 if the following explanation of the grade is accurate: 'Under the new system, electric vehicles would receive the highest grade (A+), plug-in electric hybrids would receive an A, and traditional hybrids an A-.'[EPA-HQ-OAR-2009-0865-7600, p.1]
Response:
The proposed rating methodology resulted in a distribution of vehicle sores that was concentrated near the center of the scale.  Several commenters noticed this and asked the agencies to consider methods to "flatten" the distribution of vehicles in order to create more differentiation between the vehicles that make up the majority of the fleet.  The agencies agreed with this request.
In brief, the average vehicle is based on the expected CAFE fleet average for each year from 2012-2016, then the thresholds for the highest and lowest ratings are set by subtracting or adding two standard deviations (in terms of vehicle fuel consumption) from the mean, with the ratings in between defined by creating even sized "bins."  This approach does flatten out the distribution of vehicles as suggested by several commenters.  The full methodology for determining the Fuel Economy and the GHG ratings is defined and discussed in detail in the preamble.
Organization: Renewable Fuels Association
Honeywell
Congress of the United States, U.S. House of Representatives
Comment:
Alliance of Automobile Manufactures (Alliance)
Moreover, the A, B, C system is skewed toward electric vehicles while penalizing worthy advanced technology vehicles in other categories. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 12]

Congress of the United States, U.S. House of Representatives
Additionally, unlike the mpg metric, the proposed grading system is biased in favor of certain types of vehicles. The 'A' and 'A+' categories are reserved for a very narrow range of vehicles, i.e., battery electric vehicles and plug-in hybrids. However, a fuel efficient, clean diesel vehicle would be penalized a low or mediocre grade. Similarly, most fuel efficient SUVs and pickup trucks would rate no higher than a 'C+' [EPA-HQ-OAR-2009-0865-7541.1, p.1]

Honeywell
Honeywell is concerned that  EPA/NHTSA's proposed letter grade approach [Label Option 1] may prejudice or confuse consumer-purchasing decisions and may tend to favor particular technologies (e.g., electric), prejudicing advanced technologies such as turbo downsizing. [EPA-HQ-OAR-2009-0865-7095.1, p.3]

Renewable Fuels Association
Moreover, we do not believe any vehicle option is deserving of the grade "A+," which is reserved for EVs in the proposed rule. A grade of "A+" implies that the vehicle has no climate impacts and is perfectly energy efficient. Obviously, no such vehicle exists. Further, we note that the grades of "A" and "A+" tentatively afforded to PHEVs and EVs are based, in part, on tailpipe emissions only and that upstream emissions are ignored in determining the grades. [EPA-HQ-OAR-2009-0865-6926.1, p.6]
Response:
The agencies are finalizing a 1-10 GHG rating system instead of the proposed letter grades.  In addition, the agencies significantly changed the methodology used to define the rating system in order to "flatten" the distribution of vehicles, resulting in more vehicles getting higher (and lower) ratings, and less vehicles getting average ratings.  The rating scale will be determined as explained inthe preamble:
"The agencies are finalizing a numeric rating system for the relative GHG scale where each vehicle will be assigned a GHG rating from one to ten based on each vehicle's combined 5-cycle CO2 tailpipe emission rate, as shown in Table D.1.    The midpoint of the rating system, which defines the break between a rating of a five and a six, is defined as the average, or mean, emission rate of the fleet, based on all vehicle model types across the fleet.  The highest rating (10) is defined by subtracting two standard deviations from the mean, such that any vehicle that achieves an emission rate less than two standard deviations below the mean will receive a rating of ten.  Conversely, any vehicle that is more than two standard deviations above the mean will receive the lowest rating, which is a one.  The ratings of two through nine are defined based on even increments of combined 5-cycle CO2 tailpipe emission rates between the highest and lowest ratings.   This approach is based on a simple statistical approach that should be applicable to a changing fleet of vehicles over time.  The agencies believe that this is a straightforward and robust methodology for rating vehicle GHG emissions that results in a flatter distribution of vehicle ratings across the entire fleet."
Using this methodology, several vehicles achieve a 10 rating, including an EV, a PHEV, a CNG vehicle, a fuel cell vehicle, and more than one hybrid, so clearly the top rating is not reserved for EVs only.  The Escape Hybrid scores a 9/10, so it is possible for SUVs to recieve a high rating.
Organization: General Motors (GM)
Alliance of Automobile Manufactures (Alliance)
Association of International Automobile Manufacturers (AIAM)
Environmental Defense Fund (EDF)
Ford Motor Company (Ford)
Natural Resources Defense Council (NRDC)
Hyundai Motor Company
Diesel Technology Forum
Toyota
Union of Concerned Scientists
Consumer Federation of America (CFA)
National Automobile Dealers Association (NADA)
California Air Resources Board (CARB)
Sierra Club
Securing America's Future Energy (SAFE)
American Council for an Energy-Efficient Economy (ACEEE)
Institute for Policy Integrity - New York University School of Law
Nissan
Center for Biological Diversity (Center)
National Petrochemical and Refiners Association (NPRA)
Consumers Union
Metropolitan Washington Air Quality Committee (MWAQC)
National Wildlife Federation (NWF)
Natural Gas Vehicles for America (NGVAmerica)
American Petroleum Institute (API)
Smith, Houston
Pershey, Nick
Encana Natural Gas Inc.
Ree, Andree
Catania, Andrew
EcoMotors International, Inc.
California New Car Dealers Association
Occidental College
Energy Independence Now (EIN)
IMPCO Technologies
Kustin, Camille
National Association of Minority Auto Dealers (NAMAD)
Operation Free
Center for Neighborhood Technology
United Transportation Advisors
Comment:
Many comments were received on methodology of the various proposals for greenhouse gas rating systems on the label, covering a variety of topics.  Most of these comments focused on the letter grade -- or, more generally, any rating systems on the label -- with a primary focus on the issue of ratings being within class or spanning all vehicle types.
Commenters in favor of ratings that span all vehicle types typically noted that the majority of consumers shop across more than one vehicle class, and that therefore the only way to provide comparable ratings is for the rating system to span all classes.   Some commenters noted that people have individual ways to define vehicle class and that there is no single system that would address this various approaches.  Commenters in support of ratings across all vehicles typically noted that providing ratings only within class would be confusing, and provided examples in which a higher-emitting vehicle received a better rating than a lower-emitting vehicle in a different class, commenting that a label displaying only within-class information would therefore be misleading.  These commenters tended to note that the environment does not discriminate by vehicle class and that vehicle class has no bearing on the environmental impact of the emissions.  Some commenters indicated that within class ratings would hamper the effectiveness of the new label and the likelihood that it would lead to better decision-making.  They also commented that rating across all vehicle will still allow comparisons within class, or , more broadly, across all the vehicles in which the consumer is interested -- such an approach meets the needs of consumers shopping within class as well as those shopping across classes.   Some also noted that those who are interested in more differentiation than that provided by the ratings can use the actual MPG values or fuel costs to compare vehicles.  Commenters in favor of ratings spanning all vehicles include ACEEE, CARB, CBD, CNT, CFA, CU, EIN, EDF, EcoMotors, Hyundai, MWAQC, NWF, NRDA, Occidental College, Sierra Club, and UCS, as well as many private citizens.

Commenters opposed to ratings that span all vehicles indicated that the goal of the label--to provide useful information for consumers--is best met through comparisons to similar vehicles.   These commenters indicated that people buy vehicles that meet their needs and that therefore ratings within class are the most relevant and easy to use, and will enable consumers to identify the vehicles that rate better within their class.  Some of these commenters felt that ratings across all vehicles would disparage those consumers who need a larger or more powerful vehicle, and that rating vehicles without holding attributes such as capacity or towing capability constant is not meaningful.  Others stated that a scale across all vehicles would not provide adequate differentiation within a class, on the assumption that vehicles within a class tend to cluster in terms of energy use and environmental performance.   Some of these commenters noted that auto manufacturers take pride in offering vehicles that are leaders within their class, and that this incentive would be minimized if ratings are not class-specific.  In addition, several commenters suggested that ratings across all vehicles would be inconsistent with the agencies' recent approach to fuel economy and GHG emission standards, which take vehicle footprint into consideration.  The Alliance of Automobile Manufacturers made a case that EISA requires easy comparisons, that within-class comparison are the easiest and most useful, and that "EISA should not be interpreted as requiring a rating that does not recognize the variety of vehicles."  Commenters in favor of class-specific ratings include AAM, CNCDA, DTF, Ford, GM, IMPCO, NAMAD, NADA, NGVAmerica, Nissan, SAFE, and UTA.
An additional comment that was raised, particularly with regard to the letter grade, is that it may imply, incorrectly, that it addresses a broad array of vehicle attributes, such as safety, quality, and performance.  Many of these commenters went on to state that the letter grade focuses on a single attribute -- GHGs--that people do not value, and that it is confusing by combining elements that consumers value differently and that don't track each other, such as GHGs and other emissions.  These commenters include AAM, AIAM, API, EcoMotors, Ford, NAMAD,NADA, SAFE, and Toyota, as well as a number of private citizens.
Several commenters, including AAM, Diesel Technology Forum,  EcoMotors, Ford, SAFE, and Toyota, suggested that the government should not make judgments about which factors should be the most important to the consumer, and instead should supply objective information on separate scales that the consumers can weigh for themselves.
On the other hand, some commenters, including ACEEE,CFA, EDF, NRDC, and Occidental College, stated that the letter grade provided a clear focus and was helpful by distilling complex information into a simple and concise rating.  These commenters stated that such a rating empowers consumers to take environmental and energy impacts into account and to communicate those choices to manufacturers.  Further, it allows manufacturers to readily market their vehicles with the best energy and environmental performance.
ACEEE supported the letter grade as clear and useful, but commented that it should not combine elements -- rather, the label should clearly indicate that fuel economy performance and GHG performance may diverge.   They stated that, while it was worthwhile to dispel the MPG illusion, that this could best be accomplished through annual fuel cost rather than the letter grade.
The method for rating diesel vehicles was raised by ACEEE and the Diesel Technology forum.  ACEEE stated that it was appropriate for the ratings to reflect the higher carbon content of diesel fuel, and went on to suggest that diesel MPG should be based on energy content rather than volume -- that is, that diesel fuel economy should reflect MPGe rather than MPG.  Conversely, the Diesel Technology Forum stated that it would be unfair if the GHG rating for diesel vehicles were to reflect the higher carbon content of diesel fuel, since that rating would not reflect the higher mileage of diesels due to their greater energy content, and that doing so would reflect an anti-diesel bias on the part of the agencies.
Several commenters addressed the type of rating itself.  ACEEE stated that categorical ratings -- that is, discrete rather than continuous -- have been found in the past to be the most effective at communicating basic information.  CARB  noted that consistent scales with the same rating system are the easiest to understand, and suggested using 1-10 scales for all ratings.  They also noted a preference for discrete rather than continuous or absolute ratings.
As discussed elsewhere in this document, several commenters supported flattening the curve used for the letter grade rating -- that is, that it would be helpful for consumers to have meaningful differentiation among vehicles if the ratings were spread out, with a greater proportion receiving the highest and lowest ratings than as proposed for the letter grade.  In addition to those discussed elsewhere, these commenters also included AIAM, Consumers Union, and Hyundai.  On the other hand, some, including ACEEE and Occidental College, commented that the curve is fine as proposed, or that it was too generous.
There were several comments on the treatment of advanced technology vehicles on the label.    The Alliance stated that the letter grade rating system was skewed toward electric vehicles, while the Diesel Technology forum and many private citizens commented that the best letter grades are reserved for EVs and PHEVs.  Toyota commented, accurately, that the ratings are not technology-specific; however, they went on to comment  that the methodology used results in the better grades being applied only to advanced technology vehicles, and that this was inappropriate.  ACEEE commented that the relative efficiencies of electric vehicles are important and that a rating based on tailpipe GHGs does not capture this.  Nissan suggested that city fuel economy should be emphasized for EVs, since they will be primarily driven in the city.  Several citizens suggested that rating systems be based on technology -- that is, hybrids in one category, EVs, in another, and so on.
Consumers Union suggested that, while they supported comparing across all vehicles, it would be helpful for the MPG within class to be indicated on the label with the actual values rather than an unlabeled bracket on a slider bar.
NADA commented that the label 1 rating system does not allow comparisons of new vehicles to used vehicles, and that a rating system comparing all vehicles against each other would discourage the purchase of new vehicles if they do not appear to have an improved fuel economy performance.  Conversely, CFA and EDF commented that ratings that change over time encourage manufacturers to continuously improve and reflect the changing fleet over time.
 Finally, several citizens suggested specific rating systems, providing MPG ranges for each letter grade or rating.
Response:
We are requiring, as proposed, ratings that span all vehicle classes for which labels are required.  Although the agencies' consumer research indicates that many consumers narrow their vehicle choices early in the buying decision, our research also indicates that most do not focus narrowly on a single class.  Focus group participants indicated that they shopped, on average, across two to three vehicle classes.[1]  For these consumers to be able to compare vehicles in different classes, the information must necessarily span those classes, or it will be of little use or, worse, misleading: a vehicle that is "best" in one class, in terms of the metrics presented on the label, may be less so when compared to other classes.  For those consumers shopping across classes who wish to know the relative performance of those choices, a single all-vehicles rating system will enable them to make accurate comparisons across whichever vehicles they choose to shop.  Such an approach would still be useful within a class, since each metric will differentiate vehicles regardless of their class.
Although the agencies agree that most consumers do narrow their vehicle their choices by vehicle type early in the buying decision, they do not focus narrowly on a single class, at least as defined by the EPA.  Focus group participants indicated that they shopped, on average, across two to three vehicle classes.[1]  For these consumers, a single rating system will enable them to make accurate comparison across whichever vehicles they choose to shop.  Although the agencies agree with commenters that, for the most part, consumers do not shop across segments that are dramatically different from each other, our research finds people are often choosing between segments that are somewhat similar, such as a compact and a midsize, or an SUV and a cross-over.    In order to compare vehicles in different segments, the information must necessarily span those segments or it will be of little use, or worse, misleading: a vehicle that is best in one class may be less so when compared to other classes.  For those consumers shopping across classes who wish to know the relative performance of those choices, ratings must cross those classes.

Additionally, it is clear that segments are not easily definable across the population, as evidenced by the variety of ways on which vehicles are categorized today by consumer websites and magazines, manufactures, and government agencies.   Many consumers are shopping for attributes beyond those described by vehicle segment or body class, and it does not appear to be possible to define that subset of characteristics universally.

[1]Environmental Protection Agency Fuel Economy Label: Pre-Focus Groups Online Survey Report, EPA420-R-10-907, August 2010, p. 18.

Additionally, as discussed in the NPRM, NHTSA believes that the clearest interpretation of EISA is that fuel economy, GHG, and other emissions rating systems should apply to all automobiles rather than to specific classes.  49 U.S.C. 32908(g)(1)(A)(ii) states that the agency must develop label rating systems "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 clear contrast to EPCA's requirement, codified at 49 U.S.C. 32908(b)(1)(C) that fuel economy range information be presented for "comparable automobiles."  32908(g)(1)(A)(ii) also requires that rating systems include designations of the automobiles with the "lowest greenhouse gas emissions" and "highest fuel economy," which NHTSA believes is most meaningfully fulfilled by designating the automobiles with the best GHG and fuel economy ratings in the entire fleet.  Given this statutory language, NHTSA believes that it is reasonable and appropriate to conclude that if Congress had intended the 32908(g) rating systems to apply only within class, it would have used language more like 32908(b)(1)(C), and that therefore rating systems for fuel economy, GHGs, and other emissions as described in 32908(g) should most reasonably apply to the entire fleet.

            In order to satisfy EPCA requirements,[2]the label additionally indicates the range of fuel economy values for the relevant vehicle class.  This approach allows those consumers who shop within one class to see the fuel economy of the vehicle under consideration relative to other vehicles within its class.  The agencies also believe it addresses the concern of the commenters who argued that within-class comparisons might be more useful to certain consumers  -  in essence, the EISA and EPCA requirements, when combined, are able to provide consumers with both in-class and fleet-wide information on the metric that many have identified as most important to them.
We are requiring separate information for fuel economy, greenhouse gases, and other emissions.  The agencies believe that this approach is clearly consistent with the language in EISA, is allowed under the EPCA provisions, and will best allow consumers to compare each of these elements.  We are also requiring one to ten ratings to address the large number of comments received in support of a relative rating that allows a quick and easy assessment of a vehicle's relative environmental impact.  While a letter grade rating can be  readily understood, the agencies agree with some commenters' concerns that it may imply more meaning about overall vehicle attributes -- an assessment of overall quality on a number of factors--than was intended.  We recognize that the letter grade is a fairly significant departure from the current fuel economy label, which provides absolute numerical values and no relative ratings.  The agencies believe that the one to ten rating fills a middle ground between the absolute numerical values of the current label and a letter grade rating, providing a similar ease of use without conveying any perceived value judgment that may be associated with a letter grade.  Additionally, we agree that having consistent systems for the two environmental ratings on the label may help to minimize confusion and increase comprehension.  Finally, the use here of a one to ten system is a logical extension of its use on the EPA Green Vehicle Guide web site and the California Environmental Performance Label, where it serves a similar purpose.

As far as diesels are concerned, we did not propose changes to the current practice of providing MPG in terms of volumtric fuel rather than energy content--that is, to change from MPG to MPGe, and thus we cannot make such a change in the final rule.   Comments overwhelmingly supported the use of MPG for liquid fuels, and the agencies are requiring the use of MPG for liquid fuels for the same reasons articulated in the proposal:  historical implementation of the EPCA requirements, consumer familiarity, and the fact that these fuels are purchased by the gallon.  We believe that changing to MPGe for the fuel economy of diesel vehicles would be very confusing to consumers, as label MPGe values would then be inconsistent with all consumer calculations of fuel economy (since diesel is sold in volumetric gallons) as well as fuel economy values shown on vehicle dashboard displays.   On the other hand, we continue to believe that it is appropriate for the GHG rating to reflect the carbon content of the fuel being combusted and, thus, its CO2 emissions.  We disagree that this accurate accounting of CO2 emssions reflects an anti-diesel bias, particularly in light of the decision to show MPG rather than MPGe for diesels.

Regarding the form of the rating itself, the agencies agree that consistent systems are more understandable and useful, and that discrete, categorical ratings are effective for many consumers.  Thus, we are finalizing the use of one to ten ratings on the label.  While a letter grade rating can be  readily understood, the agencies agree with some commenters' concerns that it may imply more meaning about overall vehicle attributes -- an assessment of overall quality on a number of factors--than was intended.  We recognize that the letter grade is a fairly significant departure from the current fuel economy label, which provides absolute numerical values and no relative ratings.  The agencies believe that the one to ten rating fills a middle ground between the absolute numerical values of the current label and a letter grade rating, providing a similar ease of use without conveying any perceived value judgment that may be associated with a letter grade.

We also agree with the majority of commenters on this topic that the ratings should be technology-neutral.

We agree that presenting the range of fuel economy within a class is more useful when numerical values are provided, ad the final label takes this approach.
We also agree with commenters that revising the rating systems over time to reflect the evolving fleet is the more appropriate approach.  Otherwise, as the new vehicle fleet improves its fuel economy and emissions performance over time, "grade inflation" will make static ratings less and less meaningful.  Although we acknowledge that this approach of revising rating systems to track the fleet makes them not comparable from one model year to the next, we note that the primary purpose of the label is to compare new vehicles against each other.  For those consumers who wish to consider used vehicles, the absolute fuel economy and GHG emissions values can be used.