5/24/2011 6:08:11 PM

          Revisions and Additions to Motor Vehicle Fuel Economy Label
            Docket ID No. EPA-HQ-OAR-2009-0865 and NHTSA-2010-0087

                          DRAFT Response to Comments

                                 May 24, 2011
                                 Introduction

 The Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) are issuing a joint final rule establishing new requirements for the fuel economy and environment label that will be required to be posted on the window sticker of all new automobiles sold in the U.S. beginning with model year 2013.  This rulemaking is in response to (1) provisions in the Energy Independence and Security Act of 2007 that imposed several new labeling requirements and (2) new advanced-technology vehicles entering the market.

 The label provides clearer and expanded information to American consumers about projected fuel costs and savings, new vehicle fuel economy and fuel consumption, and greenhouse gas and smog-forming emissions.  NHTSA and EPA believe that these changes will help consumers to make more informed vehicle purchase decisions particularly as the future automotive marketplace provides more diverse vehicle technologies from which consumers may choose.

The proposed rule was published on September 23, 2010 (see 75 FR 58078).  More than 50 organizations, including auto manufacturers and dealers, state and local governments, environmental groups, consumer organizations, other non-governmental organizations, provided detailed comments. Over 6,000 private citizens also submitted comments.

Most of the 6,000+ comments received from citizens fell into several categories that we were able to quickly analyze and consider; for example, a preference for Label 1 or Label 2.  The citizen comments included in Index of Proposal Commenters that follows are those that are more detailed.  These citizen comments are similar in complexity to comments from other entities, which are also included in the Index.
                         Index of Proposal Commenters
Organization
Abbreviation
Comment Document ID Number
American Automobile Association
AAA
EPA-HQ-OAR-2009-0865-6914.1.pdf
EPA-HQ-OAR-2009-0865-6914.html
Abbat, Pierre

EPA-HQ-OAR-2009-0865-7588.pdf
Abengoa Bioenergy

EPA-HQ-OAR-2009-0865-7140.1.pdf
EPA-HQ-OAR-2009-0865-7140.html
Alliance of Automobile Manufactures
Alliance
EPA-HQ-OAR-2009-0865-6850.1.pdf
EPA-HQ-OAR-2009-0865-6850.2.pdf
EPA-HQ-OAR-2009-0865-6850.html
American Council for an Energy-Efficient Economy
ACEEE
EPA-HQ-OAR-2009-0865-7135.1.pdf
EPA-HQ-OAR-2009-0865-7135.html
American Petroleum Institute
API
EPA-HQ-OAR-2009-0865-7250.1.pdf
EPA-HQ-OAR-2009-0865-7250.pdf
American Public Gas Association
APGA
EPA-HQ-OAR-2009-0865-6794.1.pdf
EPA-HQ-OAR-2009-0865-6794.pdf
Argonne National Laboratory

EPA-HQ-OAR-2009-0865-7172.1.pdf
EPA-HQ-OAR-2009-0865-7172.pdf
EPA-HQ-OAR-2009-0865-7572.1.pdf
EPA-HQ-OAR-2009-0865-7572.html
Association of International Automobile Manufacturers
AIAM
EPA-HQ-OAR-2009-0865-7134.1.pdf
EPA-HQ-OAR-2009-0865-7134.html
Auerbach, Jan (Lane)

EPA-HQ-OAR-2009-0865-4916.pdf
Automotive Global Accounts

EPA-HQ-OAR-2009-0865-6285.pdf
BMW
BMW Group
EPA-HQ-OAR-2009-0865-7142.1.pdf
EPA-HQ-OAR-2009-0865-7142.html
BorgWarner

EPA-HQ-OAR-2009-0865-7531.pdf
Bullis, Kevin

EPA-HQ-OAR-2009-0865-3415.pdf
California Air Resources Board
CARB
EPA-HQ-OAR-2009-0865-7527.1.pdf
EPA-HQ-OAR-2009-0865-7527.pdf
California Cars Initiative

EPA-HQ-OAR-2009-0865-4695.pdf
California Fuel Cell Partnership

EPA-HQ-OAR-2009-0865-6852.1.pdf
EPA-HQ-OAR-2009-0865-6852.pdf
California New Car Dealers Association

no files for docket
Catania, Andrew

EPA-HQ-OAR-2009-0865-7425.pdf
Center for Biological Diversity
Center
EPA-HQ-OAR-2009-0865-7122.1.pdf
EPA-HQ-OAR-2009-0865-7122.2.pdf
EPA-HQ-OAR-2009-0865-7122.html
Center for Neighborhood Technology

no files for docket
Cleeves, Monty

EPA-HQ-OAR-2009-0865-1387.pdf
Community Environmental Council

EPA-HQ-OAR-2009-0865-4668.pdf
Congress of the United States, U.S. House of Representatives

EPA-HQ-OAR-2009-0865-7581.1.pdf
EPA-HQ-OAR-2009-0865-7581.html
Consumer Federation of America
CFA
EPA-HQ-OAR-2009-0865-7173.1.pdf
EPA-HQ-OAR-2009-0865-7173.pdf
Consumers Union

EPA-HQ-OAR-2009-0865-7251.1.pdf
EPA-HQ-OAR-2009-0865-7251.pdf
Diesel Technology Forum

EPA-HQ-OAR-2009-0865-6247.1.pdf
EPA-HQ-OAR-2009-0865-6247.pdf
EPA-HQ-OAR-2009-0865-6365.1.pdf
EPA-HQ-OAR-2009-0865-6365.html
DieselGreen Fuels

EPA-HQ-OAR-2009-0865-1376.pdf
Duoba, Mike

no files for docket
Ecolane Transport Consultancy and WhatGreenCar.com

EPA-HQ-OAR-2009-0865-0094.1.pdf
EPA-HQ-OAR-2009-0865-0094.pdf
EcoMotors International, Inc.

EPA-HQ-OAR-2009-0865-6851.1.pdf
EPA-HQ-OAR-2009-0865-6851.pdf
Edison Electric Institute
EEI
EPA-HQ-OAR-2009-0865-7117.1.pdf
EPA-HQ-OAR-2009-0865-7117.pdf
Electric Drive Transportation Association
EDTA
EPA-HQ-OAR-2009-0865-7137.1.pdf
EPA-HQ-OAR-2009-0865-7137.pdf
Encana Natural Gas Inc.

EPA-HQ-OAR-2009-0865-7170.1.pdf
EPA-HQ-OAR-2009-0865-7170.pdf
Energy Independence Now
EIN
no files for docket
Environmental Defense Fund
EDF
EPA-HQ-OAR-2009-0865-6927.1.pdf
EPA-HQ-OAR-2009-0865-6927.html
F., Nick

EPA-HQ-OAR-2009-0865-1323.pdf
Ford Motor Company
Ford
EPA-HQ-OAR-2009-0865-7141.1.pdf
EPA-HQ-OAR-2009-0865-7141.html
Foster, Marcus

EPA-HQ-OAR-2009-0865-4833.pdf
Gas Technology Institute
GTI
EPA-HQ-OAR-2009-0865-6858.1.pdf
EPA-HQ-OAR-2009-0865-6858.pdf
Gates, Matthew

EPA-HQ-OAR-2009-0865-1179.pdf
General Motors
GM
EPA-HQ-OAR-2009-0865-6924.1.docx
EPA-HQ-OAR-2009-0865-6924.html
EPA-HQ-OAR-2009-0865-7549.1.pdf
EPA-HQ-OAR-2009-0865-7549.pdf
Haller, Bill

no files for docket
Heinzmann, John David

EPA-HQ-OAR-2009-0865-4706.pdf
Highland Laboratories, Inc

EPA-HQ-OAR-2009-0865-4983.pdf
Hill, Joel

EPA-HQ-OAR-2009-0865-4862.pdf
Honda Motor Company

EPA-HQ-OAR-2009-0865-6774.1.pdf
EPA-HQ-OAR-2009-0865-6774.html
Honeywell

EPA-HQ-OAR-2009-0865-7095.1.pdf
EPA-HQ-OAR-2009-0865-7095.pdf
Hunter, Robert S.

EPA-HQ-OAR-2009-0865-4232.pdf
Hyundai Motor Company

EPA-HQ-OAR-2009-0865-7139.1.pdf
EPA-HQ-OAR-2009-0865-7139.html
Illinois Student Environmental Coalition

no files for docket
IMPCO Technologies

no files for docket
Institute for Policy Integrity - New York University School of Law

EPA-HQ-OAR-2009-0865-7136.1.pdf
EPA-HQ-OAR-2009-0865-7136.html
International Council on Clean Transportation
ICCT
EPA-HQ-OAR-2009-0865-7118.1.pdf
EPA-HQ-OAR-2009-0865-7118.html
JAGTAG, Inc

EPA-HQ-OAR-2009-0865-6568.1.pdf
EPA-HQ-OAR-2009-0865-6568.html
Jobe, Jonathan

EPA-HQ-OAR-2009-0865-4633.pdf
Johnson, Evan W.

EPA-HQ-OAR-2009-0865-7252.1.pdf
EPA-HQ-OAR-2009-0865-7252.pdf
Johnson, Ken

EPA-HQ-OAR-2009-0865-3507.pdf
Kelly, David

EPA-HQ-OAR-2009-0865-3351.pdf
Kustin, Camille

no files for docket
Laclede Gas Company

EPA-HQ-OAR-2009-0865-7138.1.pdf
EPA-HQ-OAR-2009-0865-7138.pdf
Linsky, Robert

EPA-HQ-OAR-2009-0865-3382.pdf
Liscia, Laurent

EPA-HQ-OAR-2009-0865-4225.pdf
Lorenzo, Jose

EPA-HQ-OAR-2009-0865-7600.pdf
EPA-HQ-OAR-2009-0865-7604.pdf
Massachusetts Institute of Technology

EPA-HQ-OAR-2009-0865-5849.1.pdf
EPA-HQ-OAR-2009-0865-5849.html
Mauldin, Ronald

EPA-HQ-OAR-2009-0865-5795.pdf
Merritt, Kevin

EPA-HQ-OAR-2009-0865-3705.pdf
EPA-HQ-OAR-2009-0865-4723.pdf
EPA-HQ-OAR-2009-0865-3549.pdf
Metropolitan Washington Air Quality Committee
MWAQC
EPA-HQ-OAR-2009-0865-5848.1.pdf
EPA-HQ-OAR-2009-0865-5848.html
Mitsubishi

EPA-HQ-OAR-2009-0865-6934.1.pdf
EPA-HQ-OAR-2009-0865-6934.html
Mopsik, Frederick I.

EPA-HQ-OAR-2009-0865-3349.pdf
Naghdi, Kamran Michael

EPA-HQ-OAR-2009-0865-3497.pdf
National Association of Minority Auto Dealers
NAMAD
no files for docket
National Automobile Dealers Association
NADA
EPA-HQ-OAR-2009-0865-6940.1.pdf
EPA-HQ-OAR-2009-0865-6940.html
National Petrochemical and Refiners Association
NPRA
EPA-HQ-OAR-2009-0865-6773.1.pdf
EPA-HQ-OAR-2009-0865-6773.html
National Propane Gas Association
NPGA
EPA-HQ-OAR-2009-0865-7096.1.pdf
EPA-HQ-OAR-2009-0865-7096.pdf
National Renewable Energy Laboratory (NREL), Center for Transportation Technologies & Systems
CTTS
EPA-HQ-OAR-2009-0865-7222.1.pdf
EPA-HQ-OAR-2009-0865-7222.pdf
National Wildlife Federation
NWF
EPA-HQ-OAR-2009-0865-7528.1.pdf
EPA-HQ-OAR-2009-0865-7528.pdf
Natural Gas Vehicles for America
NGVAmerica
EPA-HQ-OAR-2009-0865-6921.1.pdf
EPA-HQ-OAR-2009-0865-6921.pdf
Natural Resources Defense Council
NRDC
EPA-HQ-OAR-2009-0865-6925.1.pdf
EPA-HQ-OAR-2009-0865-6925.html
Neighbour, Rob

EPA-HQ-OAR-2009-0865-0807.pdf
Nelson, Dennis R.

no files for docket
Nelson, Steve

EPA-HQ-OAR-2009-0865-4069.pdf
Nissan

EPA-HQ-OAR-2009-0865-6922.1.pdf
EPA-HQ-OAR-2009-0865-6922.html
Occidental College

no files for docket
Operation Free

no files for docket
Pershey, Nick

EPA-HQ-OAR-2009-0865-3412.pdf
Priddy, RL

EPA-HQ-OAR-2009-0865-3278.pdf
Public Hearing Transcript, Chicago

EPA-HQ-OAR-2009-0865-7548.pdf
Public Hearing Transcript, Los Angeles

EPA-HQ-OAR-2009-0865-7551.pdf
Raab, Michael

EPA-HQ-OAR-2009-0865-3279.pdf
Ree, Andree

EPA-HQ-OAR-2009-0865-3469.pdf
Reger-Nash, Bill

EPA-HQ-OAR-2009-0865-7036.pdf
Renewable Fuels Association

EPA-HQ-OAR-2009-0865-6926.1.pdf
EPA-HQ-OAR-2009-0865-6926.html
Richter Creative

EPA-HQ-OAR-2009-0865-1364.pdf
EPA-HQ-OAR-2009-0865-2847.pdf
Santos, Alejandra

no files for docket
SapientNitro

EPA-HQ-OAR-2009-0865-1407.pdf
EPA-HQ-OAR-2009-0865-2846.pdf
Scarborough, Christina

no files for docket
Scheve, Elliot

EPA-HQ-OAR-2009-0865-2580.pdf
Schrader, Andy

no files for docket
Securing America's Future Energy
SAFE
EPA-HQ-OAR-2009-0865-7522.1.pdf
EPA-HQ-OAR-2009-0865-7522.pdf
Siegel+Gale

EPA-HQ-OAR-2009-0865-0824.1.pdf
EPA-HQ-OAR-2009-0865-0824.html
Sierra Club

EPA-HQ-OAR-2009-0865-7221.1.pdf
EPA-HQ-OAR-2009-0865-7221.2.pdf
EPA-HQ-OAR-2009-0865-7221.pdf
EPA-HQ-OAR-2009-0865-7223.1.pdf
EPA-HQ-OAR-2009-0865-7223.pdf
Simon, Chris

EPA-HQ-OAR-2009-0865-3359.pdf
Smith, Houston

EPA-HQ-OAR-2009-0865-0477.pdf
Steele, John M.

EPA-HQ-OAR-2009-0865-3276.pdf
Suzuki Motor Corporation

EPA-HQ-OAR-2009-0865-6900.1.pdf
EPA-HQ-OAR-2009-0865-6900.html
Tesla Motors

EPA-HQ-OAR-2009-0865-6933.1.pdf
EPA-HQ-OAR-2009-0865-6933.html
Thain, Bruce

EPA-HQ-OAR-2009-0865-3296.pdf
Thomas, Sandy

EPA-HQ-OAR-2009-0865-0093.1.pdf
EPA-HQ-OAR-2009-0865-0093.pdf
Toyota

EPA-HQ-OAR-2009-0865-6901.1.pdf
EPA-HQ-OAR-2009-0865-6901.html
U.S. Coalition for Advanced Diesel Cars

EPA-HQ-OAR-2009-0865-7130.1.pdf
EPA-HQ-OAR-2009-0865-7130.html
Union of Concerned Scientists

EPA-HQ-OAR-2009-0865-7132.1.pdf
EPA-HQ-OAR-2009-0865-7132.html
United Transportation Advisors

EPA-HQ-OAR-2009-0865-0183.html
EPA-HQ-OAR-2009-0865-4722.pdf
University of Pennsylvania Law School, Environmental Law Project

EPA-HQ-OAR-2009-0865-7171.1.pdf
EPA-HQ-OAR-2009-0865-7171.2.pdf
EPA-HQ-OAR-2009-0865-7171.pdf
Volvo

EPA-HQ-OAR-2009-0865-7123.1.pdf
EPA-HQ-OAR-2009-0865-7123.2.pdf
EPA-HQ-OAR-2009-0865-7123.html
Wasserman, Seth

EPA-HQ-OAR-2009-0865-4564.pdf
Wong, Jeffrey

EPA-HQ-OAR-2009-0865-4847.pdf
Woon, Michael

EPA-HQ-OAR-2009-0865-3163.pdf
Yarrow, Jon

EPA-HQ-OAR-2009-0865-4246.pdf

1.1. Support
                                                                              8
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
Massachusetts Institute of Technology
Toyota
Union of Concerned Scientists
Electric Drive Transportation Association (EDTA)
Consumer Federation of America (CFA)
Edison Electric Institute (EEI)
National Automobile Dealers Association (NADA)
California Air Resources Board (CARB)
Sierra Club
Tesla Motors
Securing America's Future Energy (SAFE)
American Council for an Energy-Efficient Economy (ACEEE)
Institute for Policy Integrity - New York University School of Law
Volvo
Suzuki Motor Corporation
Nissan
BorgWarner
Abengoa Bioenergy
Argonne National Laboratory
Center for Biological Diversity (Center)
U.S. Coalition for Advanced Diesel Cars
Metropolitan Washington Air Quality Committee (MWAQC)
National Wildlife Federation (NWF)
AAA
Renewable Fuels Association
National Propane Gas Association (NPGA)
BMW
Thomas, Sandy
American Petroleum Institute (API)
Priddy, RL
Encana Natural Gas Inc.
California Cars Initiative
Mauldin, Ronald
Catania, Andrew
Honeywell
Laclede Gas Company
IMPCO Technologies
Haller, Bill
Operation Free
Center for Neighborhood Technology
Illinois Student Environmental Coalition
DieselGreen Fuels
Community Environmental Council
Comment:
The agencies received overwhleming support for revising the labels to respond to stautory requirements, to provide a broader array of information about the energy, cost,  and environmental aspects of vehicle choices, and to accomodate advanced technology vehicles as they enter the marketplace.  Of the over 6000 comments received from private citizens, over 80% were supportive of revising the label in general.   Thsoe oppposed tended to refer to the usefulness of the current label, and did not address the new statutory requirements nor the emergence of new technologies.  Of all the comments submitted on behalf of corporations and organizations--including auto manufacturers and dealers, fuel suppliers, environmental and consumer organizations, and academics--none were opposed to revisions, and nearly all explicitly expressed support for updating the label.
Response:
The agencies agree that label revisions are needed to accomodate statutory requirements, to provide additional information for the consumer to take into consideration, and to accommodate advanced technology vehicles.

2.1. Proposed Label Designs
                                                                             10
Organization: General Motors (GM)
Alliance of Automobile Manufactures (Alliance)
Diesel Technology Forum
Toyota
Securing America's Future Energy (SAFE)
Volvo
Suzuki Motor Corporation
Nissan
Abengoa Bioenergy
Argonne National Laboratory
Honda Motor Company
Renewable Fuels Association
American Petroleum Institute (API)
Mitsubishi
Liscia, Laurent
Honeywell
Foster, Marcus
Siegel+Gale
California New Car Dealers Association
Scarborough, Christina
Congress of the United States, U.S. House of Representatives
Abbat, Pierre
Lorenzo, Jose
Comment:
Abbat, Pierre
I prefer design 2 because the information in largest type is a number, and because it shows how much the fuel costs, rather than how much it saves, which is muddled thinking. [EPA-HQ-OAR-2009-0865-7588, p.1]

Abengoa Bioenergy
"Label 2" Option Should be Selected
In general, Abengoa Bioenergy supports the adoption of the "Label 2" option proposed by EPA and NHTSA, provided that the label is modified to reflect full "well-to-wheels" lifecycle emissions rather than tailpipe-only emissions. The letter grades proposed by "Label 1" are overly subjective, overly simplified, and may weigh either fuel economy, GHG emissions, or other factors differently than certain consumers. Similarly "Label 3" combines the two metrics and would make it difficult for consumers who value either fuel economy or GHG performance more highly to make an informed choice. We believe that "Label 2" best achieves the goals of full disclosure of objective data in a format that allows consumers to make up their own mind about the factors that are most important to them in buying a new vehicle. [EPA-HQ-OAR-2009-0865-7140.1, p.3]

Alliance of Automobile Manufactures (Alliance)
A More Traditional Label Such As "Label 2" Will Be More Useful to Consumers. The Alliance supports a more traditional label such as the proposed "Label 2." 49 U.S.C. Section 32908(b)(1)(A) requires that each label indicate the fuel economy of the automobile; fuel economy is the essential or "core information" that must be communicated. The additional information required by Section 32908(g) must accompany and not overwhelm the fuel economy information. "Label 2" continues the proper emphasis on fuel economy  -  while enabling consumers to become more familiar with the new greenhouse gas metrics. The responses from the focus groups point toward this as an evolution of the current label design. This would provide the same basic information as "Label 1," but would use a format consumers are already familiar and comfortable with. It would also provide more visible data on fuel economy, the metric that consumers expect and rely upon, and allow for comparisons within each vehicle class. Some of the major manufacturers have also conducted their own focus groups - the results of which have been shared with EPA  -  which support the more traditional label. [EPA-HQ-OAR-2009-0965-6850.2, p.1]
A More Traditional Label Such As "Label 2" Will Be More Useful to Consumers. [EPA-HQ-OAR-2009-0965-6850.2, p.3]
The Alliance supports a more traditional label such as the proposed "Label 2." The responses from the focus groups point toward this evolution of the current label design. This would provide the same basic information as "Label 1," but use a format consumers are already familiar with and understand. It also provides more visible data on fuel economy, a metric that consumers are used to and rely upon, and allows for comparisons within each vehicle class. Some of the major manufacturers have also conducted their own focus groups - the results of which have been shared with EPA  -  which support the more traditional label. [EPA-HQ-OAR-2009-0965-6850.2, p.3]
Prominence of MPG Values [EPA-HQ-OAR-2009-0865-6850.2, p.11]
As the Agencies note in their first focus group report, the one thing that participants across all groups said that they wanted to see on a full label was the fuel consumption information expressed in terms of MPG. They explained that they were used to the MPG system and that it would take time for them to adopt other metrics, including `gallons per 100 miles.' Further, they added that the city and highway gas mileage estimates were important pieces of information that helped them to compare vehicles based on their driving styles, and was something that needed to be prominent on the label. [EPA-HQ-OAR-2009-0865-6850.2, p.11]
Because MPG values are numbers that customers understand and will continue to look for, they should continue to be prominent on the fuel economy label. [EPA-HQ-OAR-2009-0865-6850.2, p.11]

American Petroleum Institute (API)
Based on the considerations above, 'Label Option 2' stickers, without the letter grades, are strongly recommended. [EPA-HQ-OAR-2009-0865-7250.1, p.6]
Overall, new vehicle labels should present a few simple, accurate and easy to read facts in a way that promotes a practical comparison between the vehicles that a given consumer is considering when shopping for a new vehicle. [EPA-HQ-OAR-2009-0865-7250.1, p.7]

Argonne National Laboratory
The label should present the relevant and independent vehicle performance metrics separately. Slider bars or providing context to other vehicles is a valid approach to helping the consumer understand the values. For all vehicles, the relevant metrics worth highlighting on a label are:
   * Petroleum-based fuel consumption per distance
   * Greenhouse gas emissions per distance
   * Energy cost per distance, or estimated per year etc.
   * Criteria emissions rating [EPA-HQ-OAR-2009-0865-7172.1, p.3]

California New Car Dealers Association
Based on our members' feedback concerning  their experiences with the Air Resources Board's  Environmental Performance labels, we've learned that our  members actually generally like having easily understood  information concerning a vehicle's environmental  performance posted on the vehicle. [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 63.]
Label 2, on the other hand, as with a lot of  the representatives, and as has been seen with the  survey information from Edmunds and others, we believe  that to be comprehensive.  It contains the information  that our members tell us that customers are looking for.  We think it's easy to understand. [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 70.]

Congress of the United States, U.S. House of Representatives
The Proposed rule presents two primary label options. Label 1 minimizes miles per gallon (mpg), an objective measure of the fuel economy performance of a vehicle, in favor of a prominently displayed subjective 'letter grade'. In contrast, Label 2 focuses on the mpg metric and implements the other information Congress required under EISA. Consumers are very familiar with the mpg metric and rely on it when purchasing a new motor vehicle. [EPA-HQ-OAR-2009-0865-7541.1, p.1]
We hope you will agree that it is essential for consumers to have clear and concise information about the fuel economy performance of their vehicle. However, Label 1 marginalizes the most important piece of information on the fuel economy sticker, namely fuel economy of the vehicle. Moreover, Label 1 unfairly promotes certain vehicles over others. [EPA-HQ-OAR-2009-0865-7541.1, p.1]
We believe that Label 2 better serves the needs of the consumer by continuing to prominently display the mpg of the vehicle, and is consistent with the statutory intent of EISA. [EPA-HQ-OAR-2009-0865-7541.1, p.1]

Diesel Technology Forum
The announced purpose of this proposal is to ..." increase [the label's] usefulness to consumers in picking efficient and environmentally friendly vehicles." Judged by that rationale, we strongly recommend a more traditional label design similar to label #2 which retains the focus on fuel economy values and resembles the existing label. [EPA-HQ-OAR-2009-0865-6247.1, p.2]

Foster, Marcus
Lastly, the choice of Label 1 (with a school-grade and five-year saving based on comparison to an unidentified `average' vehicle) and label 2 (more factual, less comparison). I favour the relative simplicity of Label 2, but taking into account the comments above, it should show: Fuel consumption only in L/100 km, not fuel economy; No `MPGe' for EV's, just a cost/mile comparison; Use full-fuel-cycle (not tailpipe) emissions. [EPA-HQ-OAR-2009-0865-4833, p. 2]

General Motors (GM)
GM opposes the letter grade and believes Label #2 is more appropriate to communicate and compare the fuel efficiency of vehicles.  Label #2 is a more traditional label and will be the most accepted and least disruptive way to communicate fuel economy since it is an evolution of today's label. [EPA-HQ-OAR-2009-0865-6924.1, p. 2]

Honda Motor Company
Overall Label Designs: The agencies requested comment about the two designs in the NPRM. Honda strongly prefers the existing size and landscape layout for the revised fuel economy label (Figure III-9. Label 2). The vertical design (Figure III-1. Label 1) has several key problems, discussed below. [EPA-HQ-OAR-2009-0865-6774.1, p.1]
As an initial observation, the motor vehicle fuel economy label is an important consumer education tool. To maximize its efficacy, it should be modified as infrequently as possible so that consumers become used to the information and format offered and it should offer meaningful information in the simplest manner possible. Our comments are calculated to meet these objectives. Over the next decade, consumers will encounter new powertrain technologies whose performance is measured in different metrics and using terms and concepts that will be new to many. We urge the agency not to overwhelm consumers and to offer information that is accurate, intuitive and will have meaning when comparing vehicles. [EPA-HQ-OAR-2009-0865-6774.1, p.1]

Honeywell
Honeywell strongly urges a more traditional label. 'Label Option 2' would provide consumers more reliable and accurate vehicle information, while 'Label Option 1' would favor a particular technology and could reduce consumer interest in other fuel-saving technologies such as turbo downsizing. [EPA-HQ-OAR-2009-0865-7095.1, p.2]
EPA/NHTSA's Proposed Label Option 2 is Favorable, as the Letter Grading System Option Creates Bias Against Certain Advanced Vehicle Technologies, Such as Turbo Downsizing.
Honeywell believes that EPA/NHTSA's proposed label that does not include a letter grade (Label Option 2) is favorable. It satisfies the labeling requirements of the Energy Independence and Security Act by enabling consumers to consider all necessary data to 'compare the fuel economy and greenhouse gas and other emissions of automobiles at the point of purchase' without adding confusion and creating bias toward certain vehicle classes or forcing certain technologies. [EPA-HQ-OAR-2009-0865-7095.1, p.2]
Label Option 2 provides the consumer with a familiar format/layout that presents improved, easy to understand, comprehensive information on the fuel economy, operating cost in terms of fuel consumption, and other environmental impacts of each covered vehicle. Label Option 2 is objective and enables consumers to better compare vehicles within and across class categories on 'greenhouse gases, and other emissions' without creating biases. [EPA-HQ-OAR-2009-0865-7095.1, p.3]
Label Option 2 presents in a balanced way all the distinct environmental data that EISA requires  EPA/NHTSA to include on the vehicle label so the consumer can make 'more informed decisions on how a vehicle they buy may impact the environment.' Unlike the letter grade approach, Label Option 2 does not overemphasize a single indicator (i.e., a letter grade), one that may not be easily understood and be based on factors unknown to most consumers. As the agencies recognize, 'consumers do not act on details.' [EPA-HQ-OAR-2009-0865-7095.1, p.3]
Label Option 2 better enables consumers to 'select more energy efficient and environmentally friendly vehicles that meet their needs,' such as those utilizing turbo downsizing technologies, and does not force certain technologies. Label Option 1 places currently available advanced technologies, including turbo downsizing, at a disadvantage. [EPA-HQ-OAR-2009-0865-7095.1, p.3]
Label Option 2 better 'allow[s] for comparison across technologies' and 'make[s] it easy to identify the most fuel efficient vehicles.' Unlike the letter grade approach, Option 2 provides objective data in a familiar format that will enable consumers to get a clear understanding of the fuel economy and environmental performance of a specific vehicle in a class of vehicles that meets their needs. Label Option 1 grades vehicles without regard for class category, making it difficult for consumers to get a clear understanding of the fuel economy and environmental performance of the class of vehicle that meets their needs. Under the proposed system, larger vehicles, such as SUVs and minivans, potentially are penalized when being compared under the same rating system as small passenger cars. [EPA-HQ-OAR-2009-0865-7095.1, p.3]
As proposed, the large size (over half the label) and prominent position of the letter grade overshadows the utility of all the other valuable information that the agencies include on the label, as required in EISA. These include the more common and widely recognized metrics of city/highway MPG and estimated annual fuel cost. [EPA-HQ-OAR-2009-0865-7095.1, p.4]

Liscia, Laurent
As the Executive Director of a standards organization, I'm sensitive to issues of consumer label standardization: the information should be immediately understandable and easily placed in context. Both proposals are quite attractive. Good job! Proposal 1 focuses on 'the grade' but feels less informative than proposal 2, which could be augmented by a grade if necessary (in the top right corner or possibly in relation with the How this Vehicle Compares diagram). The grade itself is a bit obscure when presented without context. [EPA-HQ-OAR-2009-0865-4225, p. 1]

Lorenzo, Jose
Generally I have a small preference towards label 2 if we ignore the large letter grade section of label 1. [EPA-HQ-OAR-2009-0865-7600, p.1]

Mitsubishi
Maintain the landscape orientation, like Label 2, for new labels and maintain existing fuel economy label size, (AIAM, Alliance) [EPA-HQ-OAR-2009-0865-6934.1, p.1]

Nissan
Nissan supports the use of the Option 2 label design, as opposed to the letter grade design in Option 1, as well as the development of labels specific to vehicle types. [EPA-HQ-OAR-2009-0865-6922.1, p.1]
Nissan endorses Option 2 presented in the proposal. The Option 2 design more clearly presents the information consumers find the most useful  -  MPG and MPGe  -  and sets forth the remaining information in an easy to read fashion. [EPA-HQ-OAR-2009-0865-6922.1, p.2]
Nissan's market research also confirms a consumer preference for Option 2, even amongst those consumers most aware of environmental considerations. Nissan conducted an online survey of potential LEAF customers who had expressed interest in receiving information and potentially purchasing a zero emission, full electric vehicle. In total, 1,573 people took the survey. [EPA-HQ-OAR-2009-0865-6922.1, p.2]
The respondents were shown electric vehicle labels based on both options contained in the NPRM. A significant majority  -  72% (1129 of this group) preferred the Label Option 2 over Label Option 1. A solid 60% of the respondents expressed a liking for the MPG based label in Option 2 and a similar percentage expressed support for the charge and range, comparison, environmental impact and annual electric cost information on Option 2. A lesser percentage (between 50-55%) reported liking the letter grade and about 90% expressed neutrality about the top label when shown Option 1. (See Attachment A). The Nissan survey suggests that, when faced with a label that does not provide meaningful comparative information, consumers may simply be neutral towards the data presented and not utilize the information in their purchasing decisions. [EPA-HQ-OAR-2009-0865-6922.1, p.3]

Renewable Fuels Association
EPA and NHTSA should adopt the proposed "Label 2" ("traditional" format), as it best serves the needs of consumers. "Label 2" is more objective and familiar than "Label 1" ("letter grade" format) and less cluttered than "Label 3" ("alternative design" format). [EPA-HQ-OAR-2009-0865-6926.1, p.5]
EPA and NHTSA seek comment on three proposed options for revising the appearance of the fuel economy labels. We believe EPA and NHTSA should adopt "Label 2," provided that the greenhouse gas "slider bar" is modified to reflect full fuel lifecycle direct GHG emissions, rather than simply tailpipe-only GHG emissions. "Label 2" largely preserves the familiar vehicle fuel economy label format currently in use, prominently features objective data, allows for balanced comparisons across vehicle options, and uses well-understood metrics. [EPA-HQ-OAR-2009-0865-6926.1, p.5]

Scarborough, Christina
In terms of the other one, I really find it a little confusing.  There's like a bunch of different boxes and they range, and I just feel like this one is  really straightforward. [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 155.]

Securing America's Future Energy (SAFE)
Adopting a label based on Label 1 in the NPRM would be a mistake. The approach reflected in that label oversimplifies important information, is inconsistent with recent fuel economy and GHG emissions regulations for light-duty vehicles, and does not present critical information in an easy-to-use format. In sharp contrast to Label 1, Label 2 represents a sound starting point for a label that conveys the critical information that consumers need to know and that policymakers should want consumers to consider when purchasing a new vehicle. [EPA-HQ-OAR-2009-0865-7522.1, p.2]

Siegel+Gale
The EPA redesigned the labels to inform consumers about operating cost and environmental impact and to reflect the increasing availability of alternative fuel vehicles. Siegel+Gale's survey concluded that the horizontal label was viewed as more understandable than the vertical one. In fact, over half (59 percent) of those surveyed said they would not want to purchase a vehicle without it -- an indication of support for the horizontal approach over the vertical approach.[EPA-HQ-OAR-2009-0865-0824.1, p.1]
"By giving so much space on the label to the letter grade, other data were presented with little or no context and crammed into the lower third of the label, causing confusion," says Alan Siegel, founder and chairman of Siegel+Gale and a pioneer in promoting simplicity in communications. "Our survey demonstrates that Americans want clarity and usefulness in communications from government agencies. The redesign of the fuel economy label is a major initiative that will touch countless Americans. Now is the time for the federal government to show its commitment to making clear communications a national priority." [EPA-HQ-OAR-2009-0865-0824.1, p.1]
"The recommendations are simple: scrap the vertical label, lose the letter grade and emphasize the mpg and cost of owning the vehicle," adds Siegel. "If the EPA takes these steps, it may be successful in increasing the number of fuel-efficient vehicles on the road and communicating clearly with consumers."[EPA-HQ-OAR-2009-0865-0824.1, p.2]

Suzuki Motor Corporation
Suzuki also supports the more traditional fuel economy label design (label 2) with some minor changes that would provide simple and easy to understand information for consumers without imposing a significant cost burden on auto manufacturers. [EPA-HQ-OAR-2009-0865-6900.1, p.2]
Change the font size of the combined fuel economy (FE) value to be the same font size as the proposed city and highway FE value.
Change the font size of the city FE value to be the same size as the proposed combined FE value.
Change the font size of the highway FE value to be the same size as the proposed combined FE value. [EPA-HQ-OAR-2009-0865-6900.1, p.4]

Toyota
The orientation is a portrait orientation, rather than the landscape style of the current label. Departing from the traditional landscape view and using a portrait orientation will require a significant redesign of the existing window Mononey label. The merits of making this change to the label appear dubious and can lead to consumer confusion due to the changed window sticker. [EPA-HQ-OAR-2009-0865-6901.1, p.11]
EPA proposes Label 2, as a more traditional approach, similar to the current fuel economy label and highlights the key metrics of MPG and annual fuel cost. Toyota favors this label design. [EPA-HQ-OAR-2009-0865-6901.1, p.12]

Volvo
Volvo recommends that automakers continue to be granted discretion in orienting and positioning the fuel economy label block. [EPA-HQ-OAR-2009-0865-7123.1, p.2]
In that regard, Volvo does not support a fuel economy/environmental performance label that magnifies a single attribute of a vehicle so that it is out of proportion to other attributes that clinics and surveys tell us are at least as important to them. [EPA-HQ-OAR-2009-0865-7123.1, p.3]
Response:
The agencies heard a wide range of viewpoints and considered a wealth of input from market research, an expert panel, hearings, and public comments in deciding on the final label design and content.  The agencies have chosen to require a label that combines the cost-saving element of Label 1 and the GHG rating of Label 3 with key elements of the co-proposed Label 2, using a single additional color besides black and white. Each of these elements including a discussion of comparisons within class and across all vehicles is discussed in greater detail in other sections of this Response to Comments document.
An internet survey was administered at the time of the release of the proposed rule in September, 2010, to determine whether any of the label designs had flaws that could undermine their ability to convey the desired information to the U.S. new car buying population. EPA and NHTSA did not uncover any fatal flaws with either of the co-proposed labels. For the co-proposed labels and the alternative label, we designed the survey to test the understandability of the labels as well as whether the label designs affected consumers' abilities to select efficient and environmentally-friendly vehicles, given their typical travel pattern.  The survey had nearly 3200 respondents of self-identified U.S. new vehicle purchasers, each of whom saw only one of the three label designs.  Respondents were asked questions that sought to reveal understanding of the information on the label, as well as questions that sought to reveal variations in vehicle selection based on label design.
Overall, the results showed that the differences between the three label designs with respect to understandability were small in magnitude, with label 2 appearing to be a little more understandable than label 1.[1]  Likewise, the variations with regard to vehicle selection were relatively small.  Although in all cases the majority of people selected the vehicle with lower projected fuel costs and higher savings, label 1 somewhat enhanced this effect over label 2.[2]  Because the survey did not uncover any "fatal flaw" with any of the three labels that would exclude it or any of its key elements from serious consideration in the final rule, the agencies continued to consider all elements of the three labels in developing the final rule.  A report on that survey and its results is available in the public docket and on the web site for this rule.[3]
The final fuel economy and environment labels retain many of the attributes of the existing fuel economy label.  The agencies agree that a more traditional label format, such as the one being finalized, provides consumers a familiar means for information regarding the fuel economy of vehicles. Retaining the prominence of the fuel economy values and the size and shape of the label is a natural evolution of the current label.  EPA also agrees that this moderate evolution, introducing the new metrics without diminishing the prominence of the MPG value, will allow consumers to become more familiar with the new fuel consumption and environmental metrics while retaining easy access to the familiar MPG metric.

[1] PRR, "Internet Survey Results on the Effects of Fuel Economy Labels on Understanding and Selection" November 2010, p. 1-8.
[2] Ibid, p. 9-12.
[3]PRR, "Internet Survey Results on the Effects of Fuel Economy Labels on Understanding and Selection" November 2010.

Organization: National Automobile Dealers Association (NADA)
Comment:
National Automobile Dealers Association (NADA)
At issue is how best to fulfill this statutory mandate. EPA and NHTSA should start by recognizing that the fuel economy labels rolled out for MY 2008 work well and, as such, should serve as the basic framework for fuel economy/emissions labels moving forward. Dealerships know this because prospective purchasers raise relatively few questions about existing labels and, when those questions arise, they are relatively easy to answer, either directly or by reference to www.fueleconomy.gov. There is no need to "fix what isn't broke." [EPA-HQ-OAR-2009-0865-6940.1, p.3]
Both the existing fuel economy label and the www.fueleconomy.gov web site were put to an unprecedented test in the latter half of 2009 with the implementation of the Consumer Assistance to Recycle and Save Act of 2009 (CARS or "Cash-for-Clunkers"). The CARS program allowed owners of vehicles meeting statutorily specified criteria to receive a $3,500 or $4,500 credit for trading in their vehicles and purchasing or leasing new, more fuel efficient vehicles. To be eligible for either the $3,500 or $4,500 credit, the CARS program required purchasers to show that the new vehicles they were buying had significantly higher fuel economy ratings than their trade-ins. Consequently, prospective purchasers and dealers consulted new vehicle fuel economy labels and www.fueleconomv.gov thousands of times each day on the path to consummating some 680,000 eligible new vehicle sales with an average fuel economy improvement of 60%! Never before had the fuel economy label played such a pivotal role in assisting consumers with making fuel economy related purchase decisions.3 [EPA-HQ-OAR-2009-0865-6940.1, p.3]
Given that existing labels work well and that fuel economy label information must be factual and neutral, NADA generally supports proposed "Label 2, "since it retains the current label's focus on miles per gallon (mpg) and annual fuel costs, while updating its overall design, and incorporating the new information required by EISA. Of the three principal options set out in the proposal, Label 2 poses the least risk of confusing the buying public, of making new vehicle purchasing decisions more difficult, or of treating automakers or fuel types unfairly. Label 2 attempts  --  clearly and simply  --  to present vehicle-specific metrics such as combined mpg, city mpg, highway mpg, and annual fuel cost, and does so based on reasonable and easy-to-understand assumptions. Critically, these metrics can be used by prospective new vehicle purchasers to make comparisons as they see fit. [EPA-HQ-OAR-2009-0865-6940.1, p.4]
City and Highway Fuel Economy Metrics: Retain the existing label's type font for the city and highway fuel economy estimate metrics. NADA supports deleting the existing label's "expected range" language for the city and highway numbers. [EPA-HQ-OAR-2009-0865-6940.1, p.6]
Combined Fuel Economy Metric: As on the existing label, this number only should be used for in-category comparisons. The combined fuel economy comparison box should be titled "How This Vehicle's Combined Fuel Economy Estimate Compares to Similar Vehicles," and the subtitle should be deleted. The range bar only should show numbers for same category vehicles, should be labeled as such, and should use the terms "highest" and "lowest," not "best" and "worst." For vehicles with the "highest" combined fuel economy for their category, consideration should be given to a notation to that effect, or to including the Smart Way logo awarded to the best in-category combined fuel economy and emissions performers. Consideration also should be given to the inclusion of a simple footnote describing what "combined fuel economy" means. [EPA-HQ-OAR-2009-0865-6940.1, p.6]
Annual Fuel Cost Metric: The label should show an estimated annual fuel cost metric along with the assumptions upon which it is based located adjacent to it (as in the existing label), not in the bottom margin. No other fuel cost metric is necessary or appropriate. [EPA-HQ-OAR-2009-0865-6940.1, p.6]
"Environment" Metrics: The title of this box should be changed from "Environment" to "How This Vehicle's Emissions Performance Compares to Similar Vehicles." "Emissions," not "Environment" is the language used in EISA and is what should be used on the label. Like with the combined fuel economy metric, only a comparison to vehicles in the same category should be presented, for GHGs and emissions. NADA supports a tailpipe only, grams per mile metric for GHGs. The second comparison bar should read "Other Air Emissions" not "Other Air Pollutants," and both bars should use the terms "highest" and "lowest," not "best" and "worst." For vehicles with the "lowest" GHG and other air emissions in their category, consideration should be given to a notation to that effect, or to including the Smart Way logo awarded to the best in-category combined fuel economy/emissions performers. EISA doesn't require and NADA doesn't support the disclosure of upstream emissions data on these labels. [EPA-HQ-OAR-2009-0865-6940.1, pp.6-7]
Language in the Bottom Margin: As noted above, assumptions used to calculate the annual fuel cost metric should be moved up to and just below the annual fuel cost estimate figure. The "disclaimer" should be rewritten to read "Actual mileage and emissions will vary for many reasons including driving conditions and how a vehicle is driven and maintained." The next sentence should be rewritten to read "Visit www.fueleconomy.gov for more information, to calculate personalized estimates, or to download the Fuel Economy Guide." Also, in order to harmonize with and incorporate the FTC's alternative fueled vehicle information label, NADA recognizes that NHTSA/EPA labels for alternative fueled vehicles may need to incorporate some of the "vehicle selection" and "additional information" language currently found on the FTC label. [EPA-HQ-OAR-2009-0865-6940.1, p.7]
Label 2 offers the public the advantage of a familiar landscape format consistent with what has been used since fuel economy labeling began over 35 years ago. It generally highlights the key data elements prospective purchasers long have come to expect from fuel economy labels, while incorporating the new information required by EISA in a manner that is much cleaner, simpler, and more straight-forward than the Label 1 or Label 3 alternatives. [EPA-HQ-OAR-2009-0865-6940.1, p.8]
Arguably, the information set out on those labels, you know, they do drive the crash worthiness design.  In contrast, fuel economy labels simply should provide useful facts in an easy-to-understand manner.  I'm not saying that NADA does not support fuel economy improvements because we do and we always have.
[These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 30.]
In April 2010, Secretary of Transportation LaHood noted that the CARS program was "wildly successful" both for its dramatic impact on the economy and on fleet turnover and fleet fuel economy. http://www.nhtsa.gov/PR/DOT-85-10. Interestingly, EPA's recently published annual report on fuel economy trends fails to credit the CARS program for its impact on OEM production fuel economy, despite touting MY2009/ 10 fuel economy to be at its most favorable level since the database began in 1975. http://www.epa.gov/otaq/fetrends.htm.
Response:
While the agencies agree that the fuel economy label of 2008 provided useful consumer information, and have therefore retained many of the features of the previous label, this rulemaking responds to provisions in the Energy Independence and Security Act of 2007 that imposed several new labeling requirements and new advanced-technology vehicles entering the market.  NHTSA and EPA believe that a single, coordinated fuel economy and environment label is the most appropriate way to meet the statutory requirement, and are therefore finalizing a redesigned label.  This final rule expands the current fuel economy label to a more comprehensive fuel economy and environment label that includes additional information related to vehicle fuel consumption, greenhouse gas (GHG) and smog-forming emissions, and fuel costs or savings over a 5-year period relative to the average vehicle, as well as a smartphone interactive code that links to a web site for more detailed information and options for direct vehicle comparisons. NHTSA and EPA believe that these changes will help consumers to make more informed vehicle purchase decisions, particularly as the future automotive marketplace provides more diverse vehicle technologies from which consumers must choose. Please see other sections in this document for a more comprehensive explanation of topics such as ratings within class and across all vehicles, harmonization with other agencies, and upstream emissions
The agencies do no agree that the FTC abbreviation should be added to the top margin of the label. This rule is a joint rulemaking for EPA and DOT, but the FTC will ultimately need to make a formal decision as to whether vehicles with these labels meet the FTC label requirements.
The Agency does not believe that the new label must replicate every aspect of the FTC alternative fuel vehicle label in order for the new EPA label to satisfy the the requirements of the FTC's statute and thus be considered to have met the requirements of the FTC's label.
The agencies appreciate the specific language suggestions, such as "highest" and "lowest" rather than "best" and "worst"; "How This Vehicle's Emissions Performance Compares to Similar Vehicles"  rather than "Environment"; "Emissions," not "Environment"; the rewording suggestion for the statement explaining that actual results will vary for many reasons; and other re-wording suggestions.  The agencies believed it was important to select language that is concise - to reduce clutter- and clear to consumers. Thus the final language is generally the shortest and most direct language of the numerous options available.
According to the FTC, the Energy Policy Act of 1992 "directs the Commission to issue a rule establishing uniform labeling requirements, to the greatest extent practicable, for alternative fuels and alternative fueled vehicles. The Act does not specify what information should be displayed on the labels. Instead, it provides generally that the rule must require disclosure of 'appropriate,' 'useful,' and 'timely' cost and benefit information on 'simple' labels." (60 FR 26926, May 19, 1995). The FTC chose to highlight the driving range of a vehicle using alternative fuel, and the new labels allow driving information to be incorporated on FFV labels (required on electric vehicles, plug-in hybrid vehicles, CNG vehicles, and fuel cell vehicles). The Agency believes that driving range information can, with the additional information available on the labels of alternative fuel vehicles, be considered as meeting the intent of the 1992 Energy Policy Act. However, it is not within EPA's discretion to make such a conclusion. Following the conclusion of this rulemaking action we expect the FTC to evaluate the new labels and make a formal determination as to whether use of the EPA label can allow a manufacturer to be waived from putting an FTC label on their vehicles.
EPA appreciates the comment that fuel economy label played a pivotal role in assisting consumers with making fuel economy related purchase decisions during the CARS program.  EPA and NHTSA believe that the new label provides additional metrics, not previously readily available, for consumers to consider.  Consumers will find both familiar and new metrics on the redesigned label. We expect that the broader set of metrics on the new label will allow consumers to make even more informed vehicle purchase decisions.
The comment about the fuel economy trends report is beyond the scope of this rulemaking, however, EPA appreciates the feedback on the Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975 Through 2010 (PDF). We note that the CARS program is in fact mentioned in this report, on Executive Summary page i, which says, "The Car Allowance Rebate System likely impacted consumer demand."
Organization: Consumers Union
Priddy, RL
California Cars Initiative
Highland Laboratories, Inc
Comment:
California Cars Initiative
I believe that Label Option 2, for all vehicles, is superior to both Label Option 3 and the bottom of Label Option 1 for laying out the details of vehicle performance. I strongly recommend using Label Option 1 after modifying it by replacing its bottom, details section with the whole of Label Option 2. The following points are about the exceptional features, as well as a few recommendations for minor improvements, specifically of Label Option 2. [EPA-HQ-OAR-2009-0865-4695, p. 1]
The top half (through 5-year extra fuel cost or savings) of Label Option 1, for all vehicles, is superb, and provides maximum incentive for buyers to buy green. I sincerely hope this part, especially the 5-year extra fuel cost or savings, is included in the final label design. The huge grade, along with the color coding, makes the most basic comparison obvious. The indication of 5-year fuel cost or savings in comparison to the average will provide the best yet major and obvious incentive for customers to buy into top fuel economy and/or alternate fuels (especially electricity, which is both clean and really cheap). [EPA-HQ-OAR-2009-0865-4695, p. 1]

Consumers Union
Class comparison bar
The class comparison bar on Label I will be very useful to the many consumers considering vehicles across classes. CU would recommend that the class comparison bar be made larger on the label so consumers can more easily recognize this important information. [EPA-HQ-OAR-2009-0865-7251.1, p.2]
Comments regarding Label Type II
The Type II label displays important information very clearly. CU believes that using Type II as a starting point and adding the letter grade from Type I would provide a clearer, more straightforward label with a good emphasis on fuel economy than does Label I. The range and charge time are very useful for the electric vehicle label, but the charge time should specify what type of charger is used for the calculation. It would be helpful to enlarge the assumptions of average cost/kWh and cost/gallon so consumers can compare it to their own locale and sense of where prices are likely to go in the near future. [EPA-HQ-OAR-2009-0865-7251.1, pp.3-4]

Highland Laboratories, Inc
I prefer the first label with the large 'B' on it. [EPA-HQ-OAR-2009-0865-4983, p.1]
However, the mpg in town and highway should be larger (similar to the # 2 label). Both labels are excellent. [EPA-HQ-OAR-2009-0865-4983, p.1]
I do hope that the EPA will do serious evaluation of each vehicle that display's these signs and there are no exceptions. In the past Hummer's did not display the current EPA ratings. Tons of CO2 should be in bold lettering and evaluated accurately. [EPA-HQ-OAR-2009-0865-4983, p.1]

Priddy, RL
Label Option 2, for all vehicles, is superior to both Label Option 3 and the bottom of Label Option 1 in laying out the details of vehicle performance. I would strongly recommend combining the top of Label Option 1 with all of Label Option 2. [EPA-HQ-OAR-2009-0865-3278, p.1]
About Label 2 's exceptional features with a few recommendations: [EPA-HQ-OAR-2009-0865-3278, p.1]
Starting with the gas/diesel vehicle (Figure III-9), the gas pump icon, next to the MPG figure and the associated annual fuel cost, all offer obvious visual contrast to the plugs used for EVs and PHEVs. The plots of overall MPG, CO2, and other pollutants on bar graphs read well, too, and are similar to what consumers have seen for years on appliances. Displaying only tailpipe emissions may be the only way to reflect that `well-to-tank' pollutants vary dramatically between locations and over time, with sources of electricity becoming increasingly clean, while more gasoline is starting to come from such high-CO2 sources as tar sands. [EPA-HQ-OAR-2009-0865-3278, p.1]
The top half (down to the 5-year extra fuel cost or savings compared to an average vehicle) of Label Option 1, for all vehicles, is superb. These ratings and fuel savings should be in the final label design. Those savings over years will provide the best reasons for customers to buy vehicles with high fuel economy and those using clean and cheap electricity. [EPA-HQ-OAR-2009-0865-3278, p.1]
Response:
The agencies agreed with commenters suggesting we explore labels that combined the letter grade and the five year relative savings value from label 1 with label 2; however, space constraints proved to be too challenging.  The simplicity of the letter grade is diminished when other items are increased in prominence. In addition, 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. Therefore, the agencies are not finalizing a label with a letter grade, but are finalizing instead a relative greenhouse gas rating 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. In addition, the agencies are finalizing the five year relative savings value from label 1 on a landscape layout that is similar to the current fuel economy label and proposed label 2.
Organization: AAA
Comment:
AAA
When comparing the two label options included in the proposal, we believe that Label 2 is the better consumer tool, and most thoroughly achieves the agencies' goal of helping consumers "make fully-informed decisions when purchasing a new vehicle." [EPA-HQ-OAR-2009-0865-6914.1, p.1]
Response:
The agencies considered all stakeholder input before finalizing a label that combines the cost-saving element of Label 1 and the GHG rating of Label 3 with key elements of the co-proposed Label 2, using a single additional color besides black and white.
Organization: Association of International Automobile Manufacturers (AIAM)
Hyundai Motor Company
Electric Drive Transportation Association (EDTA)
Edison Electric Institute (EEI)
California Air Resources Board (CARB)
Institute for Policy Integrity - New York University School of Law
International Council on Clean Transportation (ICCT)
Linsky, Robert
Laclede Gas Company
IMPCO Technologies
Comment:
Association of International Automobile Manufacturers (AIAM)
MS. OGE:   Also, you stated that as an Association you don't have a position between the two labels. [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 73.]
MR. CABANISS:  That's correct. [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 73.]
MS. OGE:  Do you expect to get a consensus or we're going to hear from the different member companies  on that issue? [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 73.]
MR. CABANISS:  Well, we have another month or  so to go with the written comments.  So in that time,  obviously, we'll be working closely with all our members  to fine-tune all of our comments.  And if we're able to reach a consensus on a particular label -- or, you know,  with respect to your question today about how to better  differentiate between models and a grading system, we'll  certainly consider some points that I've heard today  along the lines of, you know, within class versus across  the whole range of models.  We'll consider those things  and try to give you more information in our written  comments. [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 73-74.]

California Air Resources Board (CARB)
Regarding the overall design of any label you develop, as you found in your focus group research, keep it simple. Right now there is a lot of information on all of the different label designs. It may be worth reexamining what really needs to be there and what consumers really care about. [EPA-HQ-OAR-2009-0865-7527.1, p.2]
We suggest that the information you provide on the label be consistently laid out so that the same information can be found in the same location on the label no matter what type of vehicle you are looking at. [EPA-HQ-OAR-2009-0865-7527.1, p.2]
In order to de-clutter the label, we suggest you consider removing duplicate information. For instance, on Label 1, CO2 grams per mile (g/mile) are provided both in the table of information and as part of the greenhouse gas rating scale. It may be worth removing it from the table since the information is also on the rating scale below. [EPA-HQ-OAR-2009-0865-7527.1, p.2]
Although we think that the letter grade proposed in Label 1 is very innovative and eye catching, the bottom part of this the label is cluttered. As mentioned above, any duplicate numbers should be removed and only presented once. Also, as mentioned above, the information should be consistently placed on the label. If not for all technologies then at least within similar technologies. This is most important with plug-in hybrids. No matter what type of plug-in vehicle it is, the information on the labels should be consistently placed. [EPA-HQ-OAR-2009-0865-7527.1, p.3]
We prefer the graphical representation of the range of fuel economy of comparable vehicles as shown in Label 2 over having this information in the text. We believe the information is useful and helps consumers see where the car they are considering compares to similar vehicles. [EPA-HQ-OAR-2009-0865-7527.1, p.4]

Edison Electric Institute (EEI)
In general, greater simplicity will help ensure that the numerous data points included on the label are clear and understandable. Greatest prominence should be given to metrics that are familiar to the consumer  -  especially fuel economy and average annual fuel costs. In addition, any rating system adopted should avoid symbols or terms that could skew consumers' perceptions. Metrics that are unfamiliar and require explanatory information are more appropriately made available on a website, the link to which should be prominently displayed on the label. Stakeholders should be afforded the opportunity to participate in the development of this website. [EPA-HQ-OAR-2009-0865-7117.1, p.2]
Consistent with the requirements of Energy Policy and Conservation Act of 1975 and the Energy Independence and Security Act (EISA) of 2007, EPA and NHTSA should adopt a revised vehicle label that presents clear, understandable, unbiased fuel economy and related information in a way that will aid consumers in assessing their vehicle options. The goal of the proposed revisions is to "increase the usefulness of the label in helping consumers choose more efficient and environmentally friendly vehicles." 75 Fed. Reg. 58082. [EPA-HQ-OAR-2009-0865-7117.1, p.3]
In general, greater simplicity in the vehicle label will help to ensure that the necessary information is clear to the consumer. The proposed labels include numerous data points. While each piece of information is understandable on its own, the combined result is a complex label that may be confusing to consumers. Regardless of which proposed label ultimately is selected, EPA and NHTSA should consider ways to simplify the label so that consumers can more quickly and easily understand the key fuel economy facts about vehicles. [EPA-HQ-OAR-2009-0865-7117.1, pp.3-4]

Electric Drive Transportation Association (EDTA)
Emphasize Simplicity [EPA-HQ-OAR-2009-0865-7137.1, p.2]
The members of EDTA favor greater simplicity in the vehicle label to ensure that the necessary information is clear to the consumer. The proposed labels include numerous data points. While each piece of information is understandable on its own, the result is a complex label that may be confusing to consumers. Regardless of the label family selected, EPA and NHTSA should consider ways to simplify the label so that consumers can more quickly and easily understand the key fuel economy facts about the vehicles. [EPA-HQ-OAR-2009-0865-7137.1, p.2]

Hyundai Motor Company
Labels 1 and 2 [EPA-HQ-OAR-2009-0865-7139.1, p.1]
Hyundai could support either proposed Labels 1 or 2 as a layout but is supplying several comments related to content and to a certain extent design considerations for whichever layout is finalized. [EPA-HQ-OAR-2009-0865-7139.1, p.1]

IMPCO Technologies
And, Ms. Hay, thank you for your testimony.  I  don't believe I heard in your testimony that your  organization has any preference between the two labels.  MS. HAY:  No, we don't have a preference.  MS. OGE:  Okay.  Thank you. [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 149.]

Institute for Policy Integrity - New York University School of Law
Regardless of either how the cost-benefit analysis is ultimately conducted or which label design the agencies ultimately settle on, the agencies should make some important substantive changes to the label, in order to ensure that consumers are both well informed as to the actual impact of their vehicles, and not unduly confused by the manner in which information is presented. These changes include using well-to-wheel analysis to calculate emissions for all vehicles, adding information on all greenhouse gases rather than only carbon-related emissions, taking into account air conditioning credits in the emissions information, displaying emissions information in tons per year rather than grams per mile, and mounting an advertising and educational campaign in order to minimize consumer confusion in the face of new technologies. [EPA-HQ-OAR-2009-0865-7136.1, p.13]
In addition to these substantive changes, EPA and NHTSA should, with the help of OIRA, coordinate with other federal agencies that are involved in environmental labeling programs in order to formulate best practices in this area. [EPA-HQ-OAR-2009-0865-7136.1, p.13]

International Council on Clean Transportation (ICCT)
The proposed rulemaking proposes to add additional information to the label, as well as ratings to help the reader interpret the information. The additional information is potentially useful, but will it just serve to confuse most customers? Past efforts by the agencies have focused on trying to simplify the label information, so that customers can more easily understand the label values and what they mean. Overall, ICCT does not believe we have the expertise to know whether customers will find the additional information useful or confusing. In general, our sense is to try to keep the label as simple and easy to understand as possible, but additional information may be useful. Our primary recommendation is that the agencies should invest in studies of consumer response to different information and label formats, using expert contractors. [EPA-HQ-OAR-2009-0865-7118.1, p.2]

Laclede Gas Company
However, the bulleted list of objectives shown below is out-of-synch with the two shown above by emphasizing visual design elements over that of identifying most fuel efficient and environmentally friendly vehicles. The list should be numbered and the last one listed (Make it easy to identify the most fuel efficient and environmentally friendly vehicles) should be reordered as number one. [EPA-HQ-OAR-2009-0865-7138.1, p.4]
The labels should:
:: Create an immediate first impression for consumers [EPA-HQ-OAR-2009-0865-7138.1, p.4]
:: Be easy to read and understand quickly [EPA-HQ-OAR-2009-0865-7138.1, p.4]
:: Clearly identify vehicle technology (conventional, EV, EREV, PHEV) [EPA-HQ-OAR-2009-0865-7138.1, p.4]
:: Utilize color [EPA-HQ-OAR-2009-0865-7138.1, p.4]
:: Chunk information to allow people to deal with "more information" [EPA-HQ-OAR-2009-0865-7138.1, p.4]
:: Be consistent in content and design across technologies [EPA-HQ-OAR-2009-0865-7138.1, p.4]
:: Allow for comparison across technologies [EPA-HQ-OAR-2009-0865-7138.1, p.4]
:: Make it easy to identify the most fuel efficient and environmentally friendly vehicles [EPA-HQ-OAR-2009-0865-7138.1, p.4]
This reordering would better indicate that the EPA and NHTSA recognize their responsibilities to serve the American public with objective information with which to make better informed purchase decisions as well as harmonize this list with the other two objectives. [EPA-HQ-OAR-2009-0865-7138.1, p.4]

Linsky, Robert
as an informaiton designer, I believe that all documents need to be written and designed to present informaiton clearly and easily for all users. I have been praciting information design for over 20 years and i would like to offer my expertise pro bono to make these labels more user friendly. my blog on informaiton design is: http://informationdesigndoc.blogspot.com [EPA-HQ-OAR-2009-0865-3382, p.1]
Response:
The agencies agree with the comments stating that simplicity and clarity are important and appreciate the comments that acknowledge that it is important to conduct consumer market research to healp analyze effective means for conveying information clearly to consumers.  Therefore, the agencies heard a wide range of viewpoints and considered a wealth of input from market research, an expert panel, hearings, and public comments in deciding on the final label design and content.
The agencies also agree with the comments suggesting that consistency across vehicle technologies is important, where possible.  Although there are different elements and units that are required for specific vehicle technologies, the agencies endeavored to maintain as much consistency as possible across the labels.
While duplicate or similar information can add to the clutter of the label, the agencies believed that it was necessary to show some information in several forms to enhance clarity, for ease of use, and for consistency across vehicle technologies.  For instance, the fuel economy and the CO2emission rates, are displayed as values in units of MPG and grams per mile, respectively.  Fuel Economy and greenhouse gas emissions are also displayed as a 1-10 rating to allow a quick and easy assessment of a vehicle's relative fuel economy and environmental impact.  Consistent with EISA, the fuel economy and greenhouse gas 1-10 rating(s) helps consumers easily compare the fuel economy and greenhouse gas and other emissions of automobiles at the point of purchase.
The agencies wish to clairfy that the NPRM and final rule preambles' bulleted lists, described by the commenter, are not intended to be read as a list describing the agencies' opinion about the order of importance of the bulleted items.  This lists described the result of focus group leanings and are not listed in a specific order.
The agencies explored a wide range of units for each metric before finalizing the units displayed on the final label.  Displaying greenhouse gas information in tons per year was considered, however, 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.
Please see other sections in this document for a more comprehensive explanation of topics such as upstream emissions and air conditioning credits.

Organization: Natural Gas Vehicles for America (NGVAmerica)
Comment:
Natural Gas Vehicles for America (NGVAmerica)
CNG Labels [EPA-HQ-OAR-2009-0865-6921.1, p.9]
Proposed Label 2 includes a picture of a pump in the upper right corner and the words "Compressed Natural Gas" along with a diamond with the letters "CNG" inside the diamond. There also is a larger pump symbol located next to the fuel economy rating for the vehicle. We recommend including the letters CNG inside the pump that appears next to the fuel economy rating as currently called for in the Manual on Uniform Traffic Control Devices (2009), which sets out requirements for highway signs. The current signage for CNG fueling stations shows the pump with CNG spelled out vertically inside the pump. Other alternative fuels are similarly noted with appropriate lettering inside the pump (e.g., EV, E85). [EPA-HQ-OAR-2009-0865-6921.1, p.9]
Response:
Space limitations on the label preclude an easily-readable vertical "CNG" inside the gas pump. In addition the FHWA road signs are meant to convey the existence of a fueling station. However the fuel economy and environment label is conveying among other things, which fuel the vehicle uses, and the agencies are concerned about potentially implying that a liquid fuel gas pump would be used to fuel CNG vehicles. Therefore the agencies are finalizing the diamond symbol with horizontal "CNG" text.
Organization: Environmental Defense Fund (EDF)
Union of Concerned Scientists
Consumer Federation of America (CFA)
Sierra Club
Tesla Motors
National Wildlife Federation (NWF)
Ree, Andree
Catania, Andrew
Comment:
Catania, Andrew
Of the two labels I am in favor of the one that displays a letter grade for the given vehicle's fuel economy and greenhouse gas emissions (this is the version of the new label the comment addresses). The grade presents a measurement of a vehicle's environmental impact based on mile per gallon and emission data of one vehicle as it compares to all others on the market. Therefore, I feel that the grade allows a consumer to make a more informed purchase decision that takes the externalities of owning a vehicle into consideration. [EPA-HQ-OAR-2009-0865-7425, p. 1]
Consumer Federation of America (CFA)
The Consumer Federation of America (CFA) is pleased to submit these comments on the proposed rules regarding the revision of the motor vehicle fuel economy labeling program. Of the two different label designs the agencies are proposing, the CFA supports Label 1. This design prominently features a letter grade (A+ to D) to communicate the overall fuel economy and greenhouse gas emissions, and the 5 year-fuel-cost savings compared to an average vehicle. We believe that the Label 1 grading system will have a profoundly positive effect on improving vehicle fuel efficiency. [EPA-HQ-OAR-2009-0865-7173.1, p.1]
Environmental Defense Fund (EDF)
The Agencies are proposing two new labels that are different in how they present and emphasize information. Both labels, Label 1 and Label 2, present data on greenhouse gas emissions, criteria pollutant emissions, and fuel economy. However, Label 1 also includes a prominent letter grade that reflects combined performance on greenhouse gas emissions and fuel economy. We strongly recommend adoption of Label 1 for the clarity and rigor of information it provides for consumers. Congress revised the label requirements in the Energy Independence and Security Act to strengthen consumers' right to know by providing consumers with expansive information about vehicle fuel economy and air pollution discharges. EDF recommends final adoption of Label 1 including the letter grade to provide the clear, rigorous consumer-friendly information that Congress intended. [EPA-HQ-OAR-2009-0865-6927.1, p.2]
National Wildlife Federation (NWF)
Whether done in a stacked scale format or in another manner, the label should clearly communicate key efficiency, environmental, and cost data consistently and both in absolute and relative terms.
It is probably useful not only to stack the scales so that all the "worst" ends are on one side and the "best" ends are on the other, but to visually separate the efficiency, environmental and cost measures, and to do this consistently, and with the same units, regardless of the vehicle fuel or fuel mix. In each of these categories there are measures of both primary and secondary importance, but we would summarize our comments above by highlighting the central importance of MPG/MPGe, CO2e emissions per mile, other pollutant emissions, and relative cost. [EPA-HQ-OAR-2009-0865-7528.1, p.4]
Large, readable sliding scales provide an extremely valuable means to show key values in context both of the full fleet and within a size class.
In all the labels presented in Figure III of the "Revisions and Additions to Motor Vehicle Fuel Economy Label" Notice of Proposed Rulemaking, there are scales to show "worst" to "best" in a number of criterion including fuel economy, emissions, and other air pollutants. In order for a consumer to best understand with a quick glance, it is our impression that these scales are much clearer when stacked vertically, than when smaller and spread horizontally across a page. If vertically stacked, visually consistent, and labeled in plain language, they also provide a means to cut through the confusion of very different absolute scales. [EPA-HQ-OAR-2009-0865-7528.1, p.4]
Ree, Andree
So if you make it simple by providing a basic grade and lots of other information on the vehicle's sticker. Being sure to point out that it's based on 15,000 miles a year under average conditions. With a suggestion to visit the fuel economy site, to see how to improve the grade of their vehicle. Improve the mpg. And driving less instantly cuts pollution, of any vehicle. [EPA-HQ-OAR-2009-0865-3469, p.2]
Sierra Club
To be most effective, window labels should convey a range of helpful information in a simple format that is easily digestible by consumers. Key considerations include which metrics to display and the layout of the label. We support a simple label that effectively conveys emissions, both greenhouse gas emissions and traditional criteria emissions, and that allows consumers to easily compare vehicles and provides information regarding the economic costs of operating the vehicle and the savings associated with efficiency. [These comments were submitted by Jack Darin as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 71]
A sample of some of the specific comments that  we got.  One person said:  'I love the label with the  vertical design and the information it contains.  The horizontal label is just a facelift of the information  that is already posted on vehicles.  The vertical label  is progress toward raising greater environmental  awareness.  I've read that the horizontal label is  currently preferred by the public.  I believe this is  only because this is what they are used to.  The  vertical label still provides the mpg and operation  costs, so the consumer isn't missing any data.  People  will soon get used to the new design and will come to  appreciate the additional information and evaluation.'  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 98-99.]
And a third person said:  'Labels 1 and 2 are  both good.  I'm against Label 3, as it doesn't tell me  quickly what I want to know about fuel economy and  emissions.'  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 99.]
Tesla Motors
The labels should be straightforward and contain information that is both relevant and easy to understand; therefore, Tesla supports the use of letter grades as presented as "Label 1" in the NPRM. [EPA-HQ-OAR-2009-0865-6933.1, p.1]
While Tesla supports the inclusion of new additional information on fuel economy labels, the Company also cautions that not all information can appear on the label. First, the amount of space on the labels is limited. As a result, labels must be clear, concise and highlight key metrics and information. [EPA-HQ-OAR-2009-0865-6933.1, p.3]
Union of Concerned Scientists
SIMPLE, EYE-CATCHING DESIGN: Third, UCS recommends that the final label design be relatively simple, easy on the eye and, to the extent practical, uncluttered. The purpose of the label is to convey accurate information to prospective vehicle purchasers to help them make informed decisions. Too much information may discourage consumers from reading or digesting the key comparison data on the label. [EPA-HQ-OAR-2009-0865-7132.1, pp.2-3]
MR. MEDFORD: And you said that the final label should be easy on the eye. Do you think any of these two that we co-proposed are easy on the eye?
MS. HOHMANN: I do. Especially the first one. I think, again, the letter grade is real important. I think it's very clear and understandable to consumers, and I think the layout is very clear.
Response:
Thank you for all the positive support for Label 1.  These comments were consistent with insights and guidance the agencies received from the Expert Panel:
   * Keep it simple
   * Consumers are likely to view the labels for a very short time -- roll ratings and metrics up into a single score
   * Use cost savings information -- a very strong consumer motivator
   * Develop a web site that would be launched in conjunction with the new label. This consumer-focused web site could provide more detailed information, along with access to tools, applications, and social media.[1]
The agencies strove to maintain a simple layout, while ensuring that all required and desired elements were included.
Many comments supporting Label 1 were particularly supportive of the letter grade. While the agencies agree that a letter grade rating can be  readily understood, the agencies also agree with some commenters' concerns that a letter grade may imply more meaning about overall vehicle attributes -- an assessment of overall quality on a number of factors--than was intended.  Additionally, 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 believe that the 1 to 10 rating will provide simple and clear information about a vehicle's environmental impact. 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.
The agencies appreciate the specific comments submitted suggesting a stacked layout for all scales to improve readability at a quick glance.  Although stacked scales may provide value when the slider bars are small and numerous, the agencies believe that the final layout 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 agreed with comments suggesting that dividing the label information into "chunks"  on the label would enable consumers to readily find metrics on the label.

[1] Environmental Protection Agency Fuel Economy Label: Expert Panel Report, EPA420-R-10-908, August 2010.
The agencies have chosen to require a label that combines the cost-saving element of Label 1 and the GHG rating of Label 3 with key elements of the co-proposed Label 2, using a single additional color besides black and white.
Organization: Center for Biological Diversity (Center)
Comment:
Center for Biological Diversity (Center)
Changes to Proposed Label III. [EPA-HQ-OAR-2009-0865-7122.1, p.10]
Proposed Label III contains many of the same flaws found in Proposed Label II. It uses the same misleading sliding scale for CO2 emissions (because of the class rating bracket), and similarly highlights MPG values rather than environmental ratings. If Proposed Label III is adopted, we encourage the Agencies to make the above-mentioned changes as well as the following additional alterations. The "five star" rating system for other air pollutants should be based on a scale of more than a "0 to 5" range, such as the "1 to 10" scale on Proposed Labels I and II to more accurately convey such important information. The "Environment Rating" title is also misleading and provides poor fuel consumption data to consumers because it lacks a scale or benchmark. The word "rating" itself implies that a scale exists, yet none can be found on the label. Fuel consumption information should be presented in a sliding scale similar to that found in Proposed Label I. [EPA-HQ-OAR-2009-0865-7122.1, p.10]
Response:
The agencies appreciate the specific comments on Label 3.  We are not finalizing a star rating nor a one to five rating system for any of the scales, but are instead finlaizing one to ten scales, consistent with the commenter's suggestion. To provide context for the rating systems for fuel economy and greenhouse gases, the final label includes values that describe the best fuel economy and greenhouse gas values.
Organization: Yarrow, Jon
Comment:
Yarrow, Jon
Label 1 is not clear enough and almost hides the familiar mpg values. [EPA-HQ-OAR-2009-0865-4246, p. 1]
Label 2 does not clearly distinguish between gasoline, electric etc and in dual fuel style is too busy with information. Environment ratings need to be clearly defined, ratings on a 1 -10 scale having a definition described elsewhere are arbitrary. [EPA-HQ-OAR-2009-0865-4246, p. 1]
Label 3 is favored as it instantly indicates which type of propulsion method the vehicle uses, the environment rating is clear and the star rating is easily compared, althougb somewhat arbitrary. My only real concern is that the fuel economy and greenhouse gas rating bar chart will conflict with the CARB EP label that also appears on our Monroney, much better to follow the 'How this vehicle compares' chart from label 2. [EPA-HQ-OAR-2009-0865-4246, p. 1]
Response:
To develop the final label, we considered input from public comments, the results of our market research, statutory requirements and other factors. The result is a label that we believe combines the best elements of the three designs we requested comment on in the proposed rulemaking. For example, we have chosen to require a label that combines the cost-savings element of Label 1 and the GHG rating of Label 3 with key design elements of Label 2. We agree with this commenter that the mpg metric is familiar to consumers, and have chosen to prominently feature it in the final label design.
We also agree that it is undesirable to have conflicting environmental ratings on our label and California's Environmental Performance (EP) Label. We have worked closely with California's Air Resources Board (ARB) to develop a label that we believe meets their statutory requirements and would allow ARB to adopt the national label in place of its EP Label. For example, our final label includes both "smog" and greenhouse gas ratings relative to all new vehicles, using a one-to-ten format that is consistent with ARB's historical approach.
Organization: Steele, John M.
Comment:
Steele, John M.
Of the two labels, I strongly prefer option 2 for clarity and ease of finding the information I need to make a decision. [EPA-HQ-OAR-2009-0865-3276, p.1]
The technology or fuel type is better positioned in label 2 than label 1.The upper right corner is far more prominent. [EPA-HQ-OAR-2009-0865-3276, p.1]
The placement and size of CO2 labeling seems to far outweigh the 'other pollutants.' There is certainly both concern about global warming and uncertainty over its magnitude, and CO2's contribution. However, there is no doubt that present and likely levels of CO2 offer no direct threat as a suffocant or poison to human health, and are a vital gas to plants. The Criteria Pollutants regukated under the National Ambient Air Quality Standards are a direct threat to hguman, animal, and plant health in excess of their allowed concentrations and exceed those allowances in some of cities. The label should NOT portray CO2 as 'more important' than criteria pollutants by area, position or font size in the label, and a better phrase than 'other pollutants' is needed. They sound quite important. [EPA-HQ-OAR-2009-0865-3276, p.1]
Response:
The agencies agree that the placement of the technology or fuel type is well-positioned in Label 2; hence, the final label retains this feature of the proposed Label 2. The agencies agree that "Other Air Pollutants" may not convey the serious health and environmental impacts that criteria pollutants impose; therefore the final label, uses the term "Smog Rating".  The greenhouse gas ratings are specifically required by EISA, and the statute calls for the label to include a designation of automobiles with the lowest greenhouse gas emissions. EISA requires that the agencies create a label with 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, including a designation of automobiles with the lowest greenhouse gas emissions over the useful life of the vehicles and the highest fuel economy;."[[1]]

[[1]]  49 U.S.C. 32908(g)(1)(a)(ii).

Organization: Ford Motor Company (Ford)
Comment:
Ford Motor Company (Ford)
Label Format: EPA and NHTSA should implement the 'Label 2' format with some modifications. Ford strongly believes the Label 2, or 'traditional' format, provides more benefit to the consumer in terms of transparency of fuel economy information, can accommodate change more readily, and is more robust from a national perspective. We are not in support of the Label 1 format which includes a letter grade system and vertical footprint. [EPA-HQ-OAR-2009-0865-7141.1, p.1]
The Label 1 option proposed by the agencies represents a significant departure from today's current label design. We do not believe the approach represented by Label 1 is in the best interest of consumers, dealers or manufacturers. [EPA-HQ-OAR-2009-0865-7141.1, p.2]
In general, Ford supports the Label 2 option, with several suggestions for improvement that are outlined in the 'Proposed Revisions to Fuel Economy Label Appearance' section of these comments. The measured fuel economy data are given more prominence on this label which provides the transparency consumers have requested and are comfortable with. Ford supports continued use of MPG results since they are a well understood metric that provides consumers with a more balanced comparison for vehicles within the same class. Continuing to feature the MPG results prominently will allow consumers to make informed decisions about the fuel economy leaders within a segment and help them purchase a vehicle that best fits their needs. Ford also believes it is very important that the fuel economy comparison, using a sliding bar indicator, continue to show vehicle segmentation by class. [EPA-HQ-OAR-2009-0865-7141.1, p.3]
Ford supports the increased prominence of the combined city/highway fuel economy result on label 2, and we strongly support the continued inclusion of separate city and highway fuel economy values. Our market research continues to indicate consumers understand and like city, highway and combined values for comparison purposes; these values align with their individual driving habits. [EPA-HQ-OAR-2009-0865-7141.1, p.3]
Proposed Appearance Modifications [EPA-HQ-OAR-2009-0865-7141.1, p.5]
Ford recommends that the agencies adopt a label format that includes many of the features of Label 2, but with improvements to emphasize information that is of primary importance to the consumer for decision-making and comparison purposes. [EPA-HQ-OAR-2009-0865-7141.1, p.5]
For reference, please see the figures below to compare the PHEV label proposed in the NPRM with an example illustrating Ford's recommendations: [EPA-HQ-OAR-2009-0865-7141.1, p.5; See pp.5-6 of this comment summary for figures displaying the proposed NPRM PHEV Label 2 Option and the Ford Recommendations for PHEV Label]
Proposed PHEV modifications from the Label 2 format include the following: [EPA-HQ-OAR-2009-0865-7141.1, p.6]
1. Increase the relative size of charge range bar and reduce other slider bars. This will help consumers understand the bi-modal fuel efficiency nature of these types of vehicles. [EPA-HQ-OAR-2009-0865-7141.1, p.6]
2. Remove the consumption metric, gallons per 100 miles. [EPA-HQ-OAR-2009-0865-7141.1, p.6]
3. We advocate not differentiating between the PHEV architecture and recommend that the headings for this section be updated simply to 'Electric Assist' [EPA-HQ-OAR-2009-0865-7141.1, p.6]
4. We recommend a change to the annual cost calculations for PHEVs to provide information that is more representative of actual customers who will generally operate in both electric and gasoline modes, depending on driving conditions. Please see the 'Alternative PHEV Annual Cost Elements' section of these comments for more detail on these suggested calculation changes. [EPA-HQ-OAR-2009-0865-7141.1, p.6]
Response:
The final label contains features of proposed Label 2. These features include prominently displaying the vehicle's combined MPG or MPGe (as well as city/highway MPG(e) on labels for most vehicle technologies), a horiztonal landscape, and other design components.
For PHEV labels, we agree with the commenter that the charge & range bar is useful to consumers and have included it on the final label design. However, the size of the bar was limited by the overall dimensions of the label, other important information displayed on the PHEV label, and the desire not to make the final design too "busy" by eliminating too much blank space.
While we recognize the tradeoffs associated with adding fuel consumption to an already busy PHEV label, we believe that this is useful information for consumers. For the final PHEV labels, we are requiring fuel consumption separately for both gasoline (in gallons per 100 miles) and electricity (in kilowatt-hours per 100 miles). We believe that the combination of the MPGe metric (for those who want a simple comparative metric) and the separate fuel consumption metrics (for those who want to compare relative gasoline and electricity use) will help to satisfy different consumer needs.
For PHEVs, each mode contains the combined city/highway MPG or MPGe value, the fuel consumption value(s), and a title describing the fuel type (e.g., "Electricity," "Electricity + Gasoline," "Gasoline Only") and the appropriate fuel type icons.  We believe that this combination of information conveys in the most succinct and accurate way both the energy use that the consumer can expect, the fuels needed to achieve those values, and comparative MPG and MPGe metrics. Please also see our response in Section <IP_ADDRESS> of this document.For information on the annual fuel cost calculations for PHEV labels, please see our response in Section 4.2 of this document.

2.3.2. Label Footprint
                                                                             42
Organization: Alliance of Automobile Manufactures (Alliance)
Association of International Automobile Manufacturers (AIAM)
Ford Motor Company (Ford)
Union of Concerned Scientists
Volvo
Honda Motor Company
BMW
Honeywell
Comment:
Alliance of Automobile Manufactures (Alliance)
"Actual Size" of Proposed Labels Is Inconsistent With Draft Regulatory Language [EPA-HQ-OAR-2009-0865-6850.2, pp.13]
Under Section 600.302-112(a) of the proposed rule, fuel economy labels would be required to be "rectangular in shape with a minimum height of 178 mm and a minimum width of 114mm." The foregoing dimensions correspond to the footprint of the current fuel economy label. However, none of the "actual size" labels appearing in the proposed rule match this footprint. "Label 1," in particular, would require a 30 percent increase in the overall label height in order to accommodate new information, thereby crowding out other elements of the Monroney label. To avoid requiring yet another separate vehicle label, it is critical that the final rule allow a label size and shape that does not conflict with the inclusion of safety and vehicle pricing information that is otherwise required on the Monroney label. [EPA-HQ-OAR-2009-0865-6850.2, pp.13-14]
Association of International Automobile Manufacturers (AIAM)
AIAM members support maintaining the landscape orientation for new labels and maintaining the same sized labels as currently required. Maintaining these elements will ease implementation and reduce costs of the new label requirements. [EPA-HQ-OAR-2009-0865-7134.1, p.4]
BMW
Concerns Regarding 'Label 1'
'Label 1' is not practical for the BMW Group from a real estate and design perspective. The BMW Group has tried to harmonize the appearance and creation of the labels with all regulatory requirements considered while providing a common appearance for the customer. This follows the principle of having the same information visible on the same place on the label regardless of model year. In addition, the BMW Group will always provide the required 'Monroney' information on one label. A change to the EPA section to a different size other than the 4.5 x 7 inches will cause us not only to completely redesign the label, but also abandon the 'common appearance' concept. [EPA-HQ-OAR-2009-0865-7142.1, p.1]
Ford Motor Company (Ford)
Proposed Revisions to Fuel Economy Label Appearance [EPA-HQ-OAR-2009-0865-7141.1, p.4]
Label Footprint [EPA-HQ-OAR-2009-0865-7141.1, p.4]
Ford recommends the use of the landscape footprint found in the Label 2 proposal; we have significant concerns with implementing the vertical format associated with the Label 1 proposal. Ford, like many manufacturers, incorporates the fuel economy label information into the larger Monroney window label. Along with the fuel economy information, the Monroney label also includes the government 5-star safety ratings, vehicle identification information and the applicable standard and optional equipment for each vehicle. We have found that Label 1 would require significant modifications to our current Monroney label design, would not benefit the consumer, but would increase the overall cost needed for implementation of the new fuel economy information. [EPA-HQ-OAR-2009-0865-7141.1, p.4]
In the example below [See pp.4-6 for two examples displaying the Foot Print Issue with vertical label], we highlight how the vertical format conflicts with our ability to display the full array of required information. Today's landscape footprint provides the flexibility to work with NHTSA 5-star rating footprint and the area required to display vehicle specific information required on the Monroney Label. [EPA-HQ-OAR-2009-0865-7141.1, p.4]
Ford therefore supports an option that will preserve the footprint of the current fuel economy label. Label 2 achieves this continuity in format and is preferred from that perspective. [EPA-HQ-OAR-2009-0865-7141.1, p.4]
Honda Motor Company
Armed with information, consumers may make  good judgments based on their own needs.  We believe  that the traditional landscape label with relevant  information is what is most expected and needed by  consumers.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 90.]
Honeywell
The proposed portrait layout (as opposed to the more familiar and traditional landscape layout) further biases the consumer to rely upon the single letter grade metric. This will undermine the utility of all the other valuable information on the label. As currently designed, this other information appears to become the ''fine print' that many consumers likely will overlook. [EPA-HQ-OAR-2009-0865-7095.1, p.4]
Union of Concerned Scientists
We don't have a preference regarding a vertical or  horizontal design.  And I'm not referring to the  specific labels you have in your rule, just the general  idea of something horizontal or vertically laid out, we  don't have a preference, but we do think that it should  include a letter grade scale.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 84.]
Volvo
Label Size Disparities in the Regulation
The label dimension requirements, in text and the graphic examples disagree significantly with each other in both size and proportion. Plainly, the new information and layout according to Option 1 cannot be accommodated within the existing label footprint. [EPA-HQ-OAR-2009-0865-7123.1, p.2]
Volvo recommends that the footprint of the current fuel economy label be preserved, not expanded. [EPA-HQ-OAR-2009-0865-7123.1, p.2]
Response:
The agencies heard comments from the automakers that the vertical label orientation, as proposed on Label 1 in the preamble, would be very difficult to incorporate into the existing Maroney label.  The existing label is in a landscape format and changing to a vertical layout would, at a minimum, require manufacturers to redesign their entire Maroney label.  Some manufacturers thought that the vertical label would be impossible to integrate into the Maroney label and might require a separate label.  All of the manufacturers were for integration of labels, not new labels.
While we did receive plenty of comments supporting the design of proposed Label 1 in general, we did not receive any strong arguments for a vertical layout over the horizontal layout.  Considering that the vertical layout would result in a cost to the manufacturers, a significant change in Monroney label design, and that there was no strong support for a vertical label, the agencies decided to stay with the more familiar horizontal layout.  In addition, the agencies decided to keep the overall dimensions of the label the same as the previous generation of labels so that manufacturers can use the same space on their Maroney labels.

2.3.3. Color
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Organization: Volvo
Comment:
Volvo
Within the existing fuel economy landscape footprint, on all labels, a common, multicolor background design can be imprinted and then delineated, according to vehicle emission performance, with printed black lines, text, and shapes. [EPA-HQ-OAR-2009-0865-7123.1, p.3]
Response:
The agencies heard this comment from several manufacturers who were concerned with the costs and logistical challenges of printing with multiple colors.  The easiest way to use color on the label is to print color on a pre-printed background that is consistent for all labels, then use black ink to print on top of the pre-printed background.  The label design that we are finalizing does include color, but that color is limited to the slider bars and the border, and both the color and placement of color is consistent on all labels, regardless of vehicle technology.  This will enable those manufacturers that wish to take advantage of pre-printed background colors to do so.
Organization: Priddy, RL
Comment:
Priddy, RL
The label for blended-mode PHEVs (Figure III-12) is likewise clear. My suggestion is to use a color between the electric green and the gasoline yellow to make the blending more obvious compared to the EREV and EVs. [EPA-HQ-OAR-2009-0865-3278, p.2]
Response:
The agencies discussed many options for blended PHEV labels due to their complexity of operation.  In the end, the agencies decided to use a similar approach for blended PHEVs and EREVs on the label for simplicity, and because there are currently no blended PHEVs on the market to evaluate.  In addition, the agencies decided to use only one color on the label.
Organization: Union of Concerned Scientists
Center for Biological Diversity (Center)
University of Pennsylvania Law School, Environmental Law Project
Comment:
Center for Biological Diversity (Center)
Lastly, while Proposed Label II contains some color, its use is much less prominent than in Proposed Label II than in Proposed Label I which is color-coded according to the CO2 emissions of the vehicle. The Agencies should take advantage of the relatively nominal costs of color by revamping the label's appearance, using colors to meaningfully and quickly convey environmental information to consumers. [EPA-HQ-OAR-2009-0865-7122.1, p.10]
Union of Concerned Scientists
Additionally, we strongly support the decision to use color as part of the design -- as a purely black-and-white label is much less likely to be eye-catching. [EPA-HQ-OAR-2009-0865-7132.1, p.3]
Additionally, we strongly support -- I'm  saying 'strongly' because it's shocking that this has  come up so many times already today.  We strongly  support the decision to use color as part of the design,  as a purely black-and-white label would be less  eye-catching.  Frankly, we think it's a little bit silly for  the OEM's to complain so much about having to use color  because we think it's important -- and this is what they  say -- they want people to see these labels as well.  Well, if you really want a consumer to notice the label,  you have to put some color into it.  And as it has already been noted, the Environmental Performance label here in California does  require at least one color, and they seem to be able to  comply with that.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 86-87.]
University of Pennsylvania Law School, Environmental Law Project
Use of Color in the Label
Consumers have been shown to respond well to different colors and simpler designs. In our label design, we adopt Label 1's use of color as a designation of vehicle rating, rather than Label 2's use of color to denote vehicle types. If the label will incorporate color at all, it is more meaningful to use it as a comparison tool than as a pure identifier. Real consumers will walk into showrooms and car lots looking for a clear and immediate way to differentiate between many vehicles, and a rating system that uses color is an effective way to achieve this. EPA and NHTSA have stated that the label's purpose is to provide "information that will be most useful for consumers in making informed decisions regarding the energy efficiency and emissions impacts of the vehicles they purchase." Using color to indicate a vehicle's relative strength in these specific categories therefore better reaches the agencies' purpose than a use of color that only identifies the fuel type use by a vehicle. [EPA-HQ-OAR-2009-0865-7171.1, p.3]
If public comment reveals that generating colored labels is too costly or burdensome on manufacturers, we strongly suggest that the agencies insist on retaining color in at least one part of the label: the five-year fuel costs. On an otherwise colorless label, or even on a label that uses color alongside the letter grading system, a line of heavy red ink that reads "this vehicle costs" significantly more to fuel over five years than the average vehicle is likely to be a highly effective tool for directing consumer behavior. Consumers are likely to recognize that a line of red ink denotes a cost or loss to them relative to other vehicles they might purchase, and this single piece of information could become the most effective tool for guiding consumers away from the most environmentally unfriendly vehicles on the market. [EPA-HQ-OAR-2009-0865-7171.1, p.4]
Moreover, emphasizing vehicles that have higher costs than the average vehicle using red ink and the term "spends" or "costs" instead of "saves" tells consumers that they might be experiencing a loss relative to consumers who buy more fuel-efficient cars. One effect of the red ink would be to have consumers perceive savings they pass up as a loss since the possibility of loss can be an even stronger motivator than gain. This would probably be the most effective use of color on the entire label, and might in fact operate as the strongest motivator for consumers to choose more fuel-efficient vehicles. [EPA-HQ-OAR-2009-0865-7171.1, p.7]
Response:
The agencies felt that adding color to the labels was imperative in drawing attention to the label and in communicating the information contained within the label.  However, we also acknowledge that using multiple colors would require significant changes to the way vehicle labels are currently produced.  Vehicle manufacturers were very concerned with printing with color inks on each label, which is what the initial designs likely would have required.  Instead, the manufactures preferred using color on a standardized, pre-printable background that could then be printed with black ink for each individual vehicle.  The final label design reflects this approach.
The California label is also designed in such a way that the color on that label is pre-printed on a standard background, and is not currently printed using color inks for each vehicle.  Vehicle manufacturers strongly advocated for a label design that would also meet California requirements, so that the separate California label could be eliminated.  The California label is required to contain color, therefore the EPA label must contain at least one color to meet this requests from the vehicle manufacturers.
Proposed Label I and Proposed Label II did use colors in different ways, as pointed out be several commenters.  Proposed Label I used color to differentiate between vehicle ratings, while Proposed Label II used color to differentiate between technologies.  In addition to printing costs, the agencies were also concerned that using color to differentiate vehicles could be problematic if colors began to fade.  Red colors fade to orange, and green colors fade to yellow, which could cause confusion for consumers considering that orange and yellow labels were also proposed.
Because the agencies are only using one color on all labels, color on the label is now being used to highlight important information instead of differentiating between vehicles or technology.  The design of the label leaves the application of color the same for all labels so that color can be pre-printed as a standard background for all labels and does not require color ink printing for each vehicle.  This did not leave the option of using colors for differentiation of specific data, such as the 5 year cost numbers.
Organization: General Motors (GM)
Alliance of Automobile Manufactures (Alliance)
Association of International Automobile Manufacturers (AIAM)
Hyundai Motor Company
Securing America's Future Energy (SAFE)
Occidental College
Richter Creative
Comment:
Alliance of Automobile Manufactures (Alliance)
The Agencies Should Not Require Color Labels.
The data presented in the NPRM does not show a clear consumer benefit from the addition of color. The proposed color spectrum lacks any universally recognized meaning, and the proposed labels are already too cluttered to add a narrative explanation of the color scheme. The popularity of tinted windows and propensity of color to fade in sunlight means that the colors will appear grey or faded on vehicles in dealer lots. And with nearly three million Americans suffering color blindness, the proposed addition of color may actually lead to confusion and misinterpretation. To the extent that the Agencies are seeking to "chunk" various categories of information, this could be achieved by boxing, rather than the addition of color. [EPA-HQ-OAR-2009-0865-6850.2, p.7]

Association of International Automobile Manufacturers (AIAM)
The use of orange or yellow colors could be easily misinterpreted by consumers as warnings. Therefore, these colors should be avoided. [EPA-HQ-OAR-2009-0865-7134.1, p.4]
Fourth, the use of orange or yellow colors  tend to easily be misinterpreted by consumers as  warnings.  And fifth, color labels are difficult to see  and read with tinted windows.  [These comments were submitted as testimony at the Los Angeles hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7551 PP 56.]

General Motors (GM)
Color can be discriminatory to a large part of the vehicle buying public.  One in 76 people are color blind.  Of those, over 90 percent cannot see red or green. [EPA-HQ-OAR-2009-0865-6924.1, p. 4]
Many new vehicles are produced with tinted windows.  Many colors cannot be viewed accurately through tinted glass. [EPA-HQ-OAR-2009-0865-6924.1, p. 4]
The addition of color will require testing to determine the effects of how a variety of colors many change under solar loading.  This new testing requirement would extend our necessary lead time.  The 12-15 month timeframe assumes no problems with the performance of the color under these extreme conditions. [EPA-HQ-OAR-2009-0865-6924.1, p. 4]
Accurate lead time for color is nearly impossible to predict since the NPRM did not go into detail on specifications for color.  The necessary specifications would include items such as Pantone identifier and requirements for exposure durability to sunlight. [EPA-HQ-OAR-2009-0865-6924.1, p. 4]

Hyundai Motor Company
Another concern is the proposed use of orange or yellow and/or orange colors for the 'B' through 'D' grades could be misinterpreted by consumers as warnings, and the majority of vehicles would be labeled in these colors under the proposed distribution of grades. [EPA-HQ-OAR-2009-0865-7139.1, p.9]
Finally, color labels are difficult to see and read if tinted windows are supplied. [EPA-HQ-OAR-2009-0865-7139.1, p.9]
For these reasons, Hyundai believes color labels are challenging to implement. Our preference is to maintain a black and white label, and examples of Label Options 1 and 2 in black and white can be found in Figure 3. [EPA-HQ-OAR-2009-0865-7139.1, p.9; see p.5 of this comment summary for Figure 3 entitled, Suggested Changes to Label Options 1 and 2]
Richter Creative
I've been a professional graphic designer for 25 years and I believe that the use of colors is novel but extremely prejudicial. From across the showroom a buyer will be able to see the large green, yellow, or red circle and, when given the option will, subconsciously if not outright consciously, tend to lean more toward the green circled car for a host of embedded sociological reasons. Green is go, enviro-friendly, people friendly, socially acceptable... red is stop, danger, angry, hot, and many other 'negatives'. By adding color to the design you add emotion. Take away the color and all that is left is factual information which is the point. Right? Let the car have the emotional pull on buyers. [EPA-HQ-OAR-2009-0865-1364, p.1]
Securing America's Future Energy (SAFE)
On Label 2, color is used solely to convey the type of fuel used by the vehicle. That information, however, is duplicative of the information conveyed both in writing and by the icon on the top of the label. Once again, we do not believe that color is used to convey enough additional information to justify the complexity and cost of adding it to the label. SAFE also notes that many of the vehicles on which the labels will be placed are tinted, reducing the ability to distinguish between color and therefore its value. [EPA-HQ-OAR-2009-0865-7522.1, p.12]
We don't want this label to suffer the same fate of the color-coded threat level system used by the Department of Homeland Security, which is universally regarded as irrelevant. [These comments were submitted as testimony at the Chicago hearing.  See Docket Number EPA-HQ-OAR-2009-0865-7548 PP 26]
Response:
The agencies felt that adding color to the labels was imperative in drawing attention to the label and in communicating the information contained within the label.  However, we also acknowledge that using multiple colors would require significant changes to the way vehicle labels are currently produced.  Vehicle manufacturers were very concerned with printing with color inks on each label, which is what the initial designs likely would have required.  Instead, the manufactures preferred using color on a standardized, pre-printable background that could then be printed with black ink for each individual vehicle.  The only color that will be required is blue, which the agencies felt was a "neautral" color that did not have the positive/negative connotations that many commenters raised.  The final label design reflects this approach and the agencies believe that this will not adversely affect the lead time required by manufacturers to implement the new label.
The California label is also designed in such a way that the color on that label is pre-printed on a standard background, and is not currently printed using color inks for each vehicle.  Vehicle manufacturers strongly advocated for a label design that would also meet California requirements, so that the separate California label could be eliminated.  The California label is required to contain color, therefore the EPA label must contain at least one color to meet this requests from the vehicle manufacturers.
Proposed Label I and Proposed Label II did use colors in different ways, as pointed out be several commenters.  Proposed Label I used color to differentiate between vehicle ratings, while Proposed Label II used color to differentiate between technologies.  In addition to printing costs, the agencies were also concerned that using color to differentiate vehicles could be problematic if colors began to fade.  Red colors fade to orange, and green colors fade to yellow, which could cause confusion for consumers considering that orange and yellow labels were also proposed.
Because the agencies are only using one color on all labels, color on the label is now being used to highlight important information instead of differentiating between vehicles or technology.  This also eliminates the concern about differentiating colors behind tinted glass or by those who are color blind.  The design of the label leaves the application of color the same for all labels so that color can be pre-printed as a standard background for all labels and does not require color ink printing for each vehicle.  This did not leave the option of using colors for differentiation of specific data, such as the 5 year cost numbers.
Organization: International Council on Clean Transportation (ICCT)
Comment:
International Council on Clean Transportation (ICCT)
For example, the studies show that a color-coded label more easily draws attention of customers and tends to have more of an impact on purchase decisions than a black and white label. [EPA-HQ-OAR-2009-0865-7118.1, p.3]
Response:
The agencies agreed that a colored label would more readily draw the attention of consumers, as opposed to a black and white label.  The agencies proposed two different color schemes, with Proposed Label I utilizing color to differentiate vehicles by GHG rating, and with Proposed Label II using color to differentiate vehicle technologies.  The agencies received many comments about the application of color, and ultimately decided that requiring color labels as proposed would impose a significant cost on vehicle manufacturers.  Thus, the final label retains one color, blue, which the agencies felt was  a"neutral" color that is effective to highlight desired parts of the label without strong positive/negative connotations.  The labels are designed such that the color portions are in the same place for all labels, regardless of technology, so that any manufacturers that would like to take advantage of pre-printing color on the labels can do so (this was a common request from manufacturers).
As finalized, the fuel economy, environment, and GHG slider bars are all highlighted with color to grab the attention of consumers.  The vehicle technology is also highlighted in color to alert consumers to the type of vehicle they are considering.  The agencies felt that these were important parts of the label to highlight, and that doing so will help to communicate information more efficiently to consumers.
Organization: BMW
Comment:
BMW
The BMW Group prefers not to have a 2-color gradient fill, either with uni-color or color comparison bars. [EPA-HQ-OAR-2009-0865-7142.1, p.2]
'Label 2' uses a gradient 2-color fill for the vehicle comparison as well as environmental comparison scales. From our perspective, we see this gradient fill as potentially misleading since there is no connection between the color and the position of the score indicator for the actual vehicle. The BMW Group's current design tool does not support a gradient 2-color fill. Should this feature be required, a lengthy upgrade process would have to be initiated with the vendor. Funding and enough time for implementation will be needed. [EPA-HQ-OAR-2009-0865-7142.1, p.2]
Response:
The agencies are finalizing a design that incorporates color such that all color parts of the label can be pre-printed on a standard background label and color printing by the manufacturer is not required.  We believe this should alleviate the concern raised by BMW.  In addition, no other manufacturer was concerned with printing gradients, and the final rule allows for more lead time than initially proposed.
Organization: Suzuki Motor Corporation
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 3.3.2, 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 3.3.2, 3.4.2 & 9.1 of this comment summary]

Suzuki Motor Corporation
Suzuki recommends changing the combined fuel economy bar so it does not contain variable colors and is much simpler to print similar to the current combined scale. Use of standard text, a bar line and a pointer as shown below can be easily incorporated. [EPA-HQ-OAR-2009-0865-6900.1, p.3]
Response:
The agencies designed the final label with the intent that any color could be pre-printed using a standard background.  The use of color on the label is limited to the slider bar backgrounds and the vehicle type identifier in the upper right corner.  All labels will use the same shade of blue.  All other vehicle specific information that is likely to be printed just in time at the manufacturing plant or port of import can be printed in black and white on the preprinted color background.  The agencies eliminated using white numbers and other label features that would require color printing.  In addition, the agencies plan to provide an electronic template that will proved the specific shade of blue to use on the label.

2.4. Additional Design Ideas
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Organization: Argonne National Laboratory
Comment:
Argonne National Laboratory
Conventional Vehicle Label
Argonne offers two suggestions on the Conventional Vehicle Label design, which are shown below, for reference. The preferred approach is to modify Label 2 to highlight fuel consumption in the upper left quadrant suggesting the font size of the messages be reversed whereby, fuel consumption in gallons used every 100 miles be the predominant message and the mpg rating be downsized in font, in comparison. We urge that this be the beginning of the transition to fuel consumption replacing fuel economy. Similarly, the lower left slider scale should depict fuel consumption for the displayed value range. Depicting the exponential metric MPG in a linear scale slider bar provides more reinforcement of the "MPG Illusion." A perhaps stylistic suggestion is to make all the slider bars consistent to make them all reflect a proportional "negative impact" thus making higher scores worse. Fuel costs, fuel consumption, greenhouse gas emissions, and criteria pollution are all "more is worse" indexes. Locating the zero point to the right for greenhouse gasses is fundamentally awkward. If this is the first time we are using slider bars for label information, the "more is worse" slider could be introduced and the public understand it is proportional to vehicle impacts, or "footprint." [EPA-HQ-OAR-2009-0865-7172.1, p.5]
[See page 5 of this comment for two suggestions on the Conventional Vehicle Label design.]
The adoption of slider scales is a very useful means to display relevant information. Annual costs could also be shown on a slider bar scale. The depiction of the entire new vehicle fleet for the parameter of interest, with a highlight section for a specific category of vehicle is an admirable approach. This could be adopted for all the proposed slider bars, i.e., fuel consumption, greenhouse gases, other air pollutants and cost. [EPA-HQ-OAR-2009-0865-7172.1, pp.5-6]
What type of information belongs in the slider bars area?  How should it look?
Best on Right: Agree that the best layout displays best results all the way to right. However vehicle impact is best conveyed through 'More is Worse' message (consumption, cost, emissions). Current opinion is that it is OK to put Zero on right as best case, as long as all bars are consistent. One problem: current smog emissions is 'Higher is Better,' this is remedied by removing this from slider bar area. [EPA-HQ-OAR-2009-0865-7572.1, p. 4; see commenter's example Slider Bar at page 4.]
Assorted Unit Basis: CO2(g/mi), fuel (Gallons per 100 miles), Costs (per year)....?  Suggest introducing all the metrics important to assessing a vehicle's impact (on environment and wallet) on a yearly basis. Slider bar results are calculated using a Utility Factor for aggregate results Much easier to understand if they are given as an annualized 'average.' For example fuel consumption per 100 miles will NOT be experienced by the consumer if they drive 100 miles in the vehicle. [EPA-HQ-OAR-2009-0865-7572.1, p. 4; see commenter's example Slider Bar at page 4.]
Response:
The agencies appreciate the comments about reversing the prominence of the fuel consumption value and decreasing the prominence of the MPG value;  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 to allow consumers to become gradually familiar with the fuel consumption metric.
The agencies agree that depicting an MPG scale in a linear format may reinforce the "MPG Illusion"; therefore the agencies are finalizing a rating for fuel economy and greenhouse gases that depicts the fuel economy rating as a numeric one to ten rating based on each vehicle's 5-cycle combined fuel consumption.  See the preamble, section III.D. for more details about the fuel economy and greenhouse gas rating methodology.
The agencies considered how to address that fact that different performance value metrics may have scales with different directions. The agencies decided to eliminate the potential for confusion by using only 1 to 10 rating scales on the label where a higher score (10) is defined as the preferable "Best" value.