Summary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

1 Below is a summary of interagency comments r eceived during EO 12866 review of the draft rule “Revisions to Motor Vehicle Fuel Economy Label. ” They are for your consideration and subject to further policy review.

In general, interagency reviewers enthusiastic ally appreciate and s upport EPA and DOT efforts to provide accurate information to consumers to enable them to make fully-informed vehicle purchasing decisions.

1. Emissions for Electric Vehicles: Interagency reviewers recommend that the agencies accept comments on a more complete range of issues regarding what emissions
information to include on the label, how to calculate emissions data, and how to present it. This is particularly important for el ectric vehicles (EVs), where the source of electricity is critical to determining the magn itude of the emissions attributable to them (see graphic below). EISA does not require th at emissions be limited to the tailpipe, and guides EPA to broadly consider emissions over the useful life of the vehicle.

Thus, it might be useful to include alternativ e representations of em issions (instead of including just tailpipe emissions) in the NPRM before it is published for comments. For example, the agencies could include full life cycle emissions on the label, or emissions from just the combustion of the fuel used to power vehicles and seek comment on these alternative representations. This way, the agen cies will have an opportunity to outline all of the issues in the NPRM and fully engage the public and stakeholders in order to address any issues regarding emissions data or regarding devel oping a methodology that comes as close as possible to providing consumers with accurate information about the emissions from their vehicle purchases.

The following points highlight important questions about the proposed emission methodology for EVs:

a. Is there a way to consider and represent the emissions from the full life cycle of the fuel used to power a vehicle, rega rdless of source? Did the agencies conduct an analysis to see if this was po ssible? Please share this analysis.

b. Is there a way to consider and represent the emissions from combustion of the fuel used to power a vehicle, regardless of sour ce? This is somewhat different from an “upstream” definition, which can incl ude emissions from the production and processing of a fuel. Commenters suggest the agencies evaluate label options for “emissions from the combustion of fuel (sou rce of energy) used to directly power
the vehicle” that includes electricit y. For example, Executive Order 13514 requires Federal Agencies to account for and report GHG emissions resulting from vehicle operation. This includes em issions from the combustion of any nonrenewable fuel or energy source used to directly power the vehicle, including electricity used by EVs. National or re gional factors can be used to calculate GHG emissions resulting from vehicle operation.Summary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

2 c. Some interagency commenters suggested th at applying a rating of 0 grams/mile to EVs may lead to attacks that the Admi nistration is purposel y providing consumers with misleading information in order to advance deployment of more EVs, particularly around the time the Leaf and Volt come out in the fall. Notwithstanding the parenthetical “tailpip e emissions”, the label may be viewed as a claim by the Administration that EVs cause no GHGs to be emitted. The Advertising Standards Authority of the UK, for example, recently banned BMW's
use of the claim of "zero CO2 when driving" for an EV, stating: “We considered that [BMW's] inclusion of the phrase 'w hen driving' was contradictory to the overall zero emission claim, and the impre ssion that the car's use would not result in the production of emissions.”

d. It is important to be consistent and no t set precedents that will be problematic down the road. In the biofuels context, EPA has declared in the RFS2 that
biofuels emissions should be measured on a lifecycle basis. For example, the discussion on biogenic emissions a nd carbon neutrality is ongoing. The
Administration has documents out for public comment wh ere this topic is being
addressed .

e. While a national average is problematic because of the variance in emissions profiles of different forms of electricity generation, national averages are used for other energy labels. For example, nati onal cost estimates are used for Energy Guide labels even though the cost of elec tricity varies widely . Moreover, EPA’s proposal for how to treat GHG emissions from EVs should consider the 2009 recommendations from a National Academies panel on building and appliance efficiency. In that report, the NAS recommended--notwithstanding that the GHG footprint of appliances differs depend ing on the mix of electricity generation where they are used--that Energy Guide labels be updated to include lifecycle GHG emissions. Specifically, they reco mmended “adding to the Energy Guide label an indicator of how an appliance’s total energy consumption might affect levels of greenhouse gas emissions” (em phasis added). NAS also recommended “moving over time to use of the full-fu el-cycle measure of energy consumption
for assessment of national and environmen tal impacts, especially levels of greenhouse gas emissions.”

f. Not all EVs are created equal – some w ill require much more energy per mile traveled than others, and using a single value of zero grams of CO 2 per mile may not sufficiently inform consumers about the divergent emissions impacts of
different EVs.

g. The grading approach could be misleading if EPA fails to consider all relevant emissions, particularly with regard to the relative grades for EVs (A+), PHEVs (A), and HEVs (A-). For example, accord ing to several estima tes, the lifecycle emissions of EVs that are supplied with electricity generated by coal-fired power plants exceed the lifecycle emissi ons of gasoline-powered HEVs.Summary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

3 h. Technical comment: The proposed rating system may make it hard to achieve the rule’s stated purpose of allowing cons umers to compare fuel economy because EPA’s proposal to rely upon CO 2 emissions for assigning letter grades, rather than fuel economy or some combination of th e two, is problematic if EVs are not assigned emission values. 1 For example, the EV represented in Figure III-2 is assigned an A+ letter grade based upon its CO 2 emissions (0 grams/mile, with an A+ threshold of 76 grams/mile). Howeve r, according to Table II.A.4-1, the same EV would be assigned an A grade based upon its fuel economy (102 mpgequivalent city and 94 mpg-equivalent highway, though the A+ fuel economy threshold is 117 mpg-equivalent). Simila r problems could arise with regards to carbon-intensive but energy-dense diesel. EP A states: “Because vehicles that are
low in CO 2 emissions have inherently good fuel economy (and vice versa), and
because CO 2 emissions are the primary determinant of fuel economy using EPA test procedures, vehicles would generally tend to have the same “score” for fuel economy as for GHG emissions” (pg. 32). Yet the labels for EVs include nonzerofuel economy/consumption values (in terms of kW-hrs/100 miles or mpgequivalent), but do not include corresponding CO 2 emissions – even though electricity sources providing the fuel for EVs currently produce CO 2 emissions. One option may be a nationwide average em issions factor that could easily be applied for calculating emissions from EVs.

i. To be sure, using a nationwide average is problematic as well, given the variance
in carbon emissions from different forms of electricity. There can be a significant difference between national and regional e-gr id factors used to convert fuel use to GHG emissions . Thus, the rulemaking pr ocess is a valuable opportunity to propose both alternatives and gather feedb ack about the best possible display of
emission data for EVs and other technol ogies. The agencies should therefore accept comments about solutions to con cerns about how to calculate imputed emissions for EVs, overcome challenges a bout regional or temporal variations in
CO 2 emissions from electricity generati on, and present average or locationspecific emissions for EVs.

1 The following comparison assumes that the values presented in the rule’s labels have a basis in reality.Summary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

4 2. Objective Language : Commenters recommend that the agencies modify language that may be perceived as trying to manipulate consumers into making certain consumption
decisions that the Administration views as so cially desirable from a policy perspective. 2
Instead, the rule should be described as an objective attempt to provide more and better information to consumers so that they can mo re easily assess the true costs and emissions
of different vehicles and ma ke fully-informed decisions. The agencies should not imply that consumers who do not buy more fuel effi cient vehicles are making poorer decisions, when it may be their preference to do so even with more information. Please make these revisions throughout the entire document.

3. Median Baseline Vehicle : What alternatives did the agenci es consider in deciding how to help consumers compare vehicles? The curren t proposal to shift each year’s median vehicle might make it very difficult or even misleading when consumers are comparing identical vehicles but different model years. A new model year vehicle might have lower ratings and cost savings than the previous y ear model year even if it is more efficient because of the shifting median vehicle. Do th e agencies think this could be problematic?

4. Display of Model Year: Under the grading scale, the model year of a vehicle is extremely important because the relative metrics are updated every year. The agencies should therefore solicit comments on whether to high light the model year more prominently on the label. Also, the agencies should consid er – in greater detail – that consumers may want to compare essentially identical vehi cles, but for different model years. As described above, under the updated grading sc heme, the newer vehicle could have a

2 Such terminology is used in various sections of the document. One example: “...to also assist us in identifying opportunities and strategies to increase consumer prefer ence for energy efficient and environmentally friendly vehicles” (page 14).Summary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

5 lower grade even if it is more efficient than an older model, due to a different baseline for the grading scale. A similar condition could exist for the presentati on of “fuel savings”
information.

5. Half letter upgrade for PHEVs: Currently, the rule allows all vehicles to receive a half a letter grade upgrade if they perform well on “other GHG emissions” except for PHEVs. The agencies state that PHEVs are exclude d from receiving an upgrade if they are eligible to receive it because they want only EVs to get the A+ rating. PHEVs get an A for just the CO2 emissions and if they perform well on other GHG emissions, could get an A+. Excluding PHEVs from getting this u pgrade might not level the playing field. Have the agencies considered implications fr om not allowing for a leveled playing field? Commenters recommended that the agencies not exclude PHEVs from getting this half letter upgrade if they are eligible to receive it.

6. Overall Monroney Label Impacts: How would changes from this NPRM impact other components of the Monroney label? What is the relative size of the fuel economy component compared to the safety ratings component? How might the difference in size of the various components influence consumer perception about other vehicle attributes -- such as safety?

7. Please explain what the cumulative cap on ups tream emissions refers to on page 29.

8. Commenters recommended that the agen cies use “GHG Performance” instead of
“Environment” on the label itself becaus e the agencies are only considering GHG impacts. It is more accurate to refer to it as GHG reductions instead of “Environment.” Please make this change in the NPRM as well.

9. It would be helpful if the proposed rule in cluded a list of acronyms at the beginning of
the document.

10. Could the agencies please clarify whether the proposed rule would affect “aftermarket” manufacturers (firms that purchase passenger car s or light trucks) and customize them for (re)sale. Would these firms be required to prov ide a label when they resold the vehicle? (Commenter asked this because these “afte rmarket” firms are likely to be small businesses, and if they are covered by the rule need to be incl uded in the Regulatory Flexibility Act (RFA) analysis.) (Commenter notes that Sec. 600-316-08 says that the “final stage” manufacturer is treated as the manufacturer for purposes of compliance with the rule.)

11. The RFA analysis/certification s hould also include “auto dealer s,” as the rule (Subpart E, Sec. 600-405) requires them to ensure that labels are in place and to obtain, display, and
make available to consumers the Fuel Economy Guide (comparison booklet). Commenter assumes these costs are de minimus, so including them in the RFA analysis could be done in a brief sentence or two (but they should be included in the analysis and table of regulate d entities).Summary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

6 12. The NPRM does a great job outlini ng the benefits of gallons per mile instead of miles per gallon. But then label 2 has MPG in huge font (the biggest on the label) and GPM in tiny

font. And all the labels have the slider bar as MPG rather th an GMP. Commenter understands that people now ar e used to the concept of MPG, but did the agencies consider gradually transitioning the label from emphasizing MPG to emphasizing GPM? Commenters could imagine, for example, the re lative font sizes or placements changing

over a decade.

13. On page 30 of the preamble there is a discus sion on using A/C leakage adjustments in the

determination of GHG emissions. If this option were adopted would it be inconsistent with labeling the emission as “tailpipe emissions”? Wouldn’t including A/C leakage adjustments also lead to widening the gap between what is on the label and what consumers get in the “real world”?

14. On page 66 in the forth sentence of the la st paragraph, the word “actually” should be replaced with “typically” as shown below. This change would make the sentence

consistent with the discussi on preceding this sentence and corresponds to DOE’s findings in testing E85-FFVs energy e fficiency and fuel economy.

“While the E85 mpg values are lower th an the gasoline mpg values, the use of
E85 is actually typically slightly more energy efficien t than the use of gasoline.”

15. On page 67, the proposed methodology for assigning an overall combined value for greenhouse gas emissions or fuel economy for FFVs based on the fraction of alternative fuel currently in use seems uninformative for consumers. Especially with FFVs, it is unlikely that any individual consumer uses the national average fraction of alternative fuel. Possibly deriving a merged value for a clearly stated percentage of the alternative fuel (say 10% or 25% E85 usage for an FFV) would be of more value to the consumer.

16. Combined fuel economy labeling options for E85-FFV and diesel vehicles: It is not clear from the discussion if the combined FE ratings for diesel and E85-FFV vehicles would be on a gasoline equivalent basis or a per gallon basis of diesel or E85. DOE’s believes it

would be more useful to consumers if the combined FE ratings for diesel and E85-FFV

vehicles were on a diesel or E85 volumetric ba sis since these fuels ar e also sold on a per gallon basis. However, it is appropriate for the combined FE ratings for non liquid fuels such as CNG and electricity to be on a gasoline e quivalent basis.

17. Label 1 “Saves/Spend” Disclosures: For vehi cles with below-average economy, proposed
Label 1 would disclose the additional cost of fu el as compared to the average vehicle. For example, the disclosure on Figure III-5 states “Over five years, you will spend $3,600 more in fuel costs compared to the aver age vehicle.” Similarly, for above average vehicles, Label 1 contains a savings clai m (e.g., “Over five years, this vehicle savesSummary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

7 $5,700 in fuel costs compared to the average ve hicle”). These disclosures present several potential problems. First, commenter expects that many consumers will interpret the “spend” disclosure to be a representation of total operating cost w ithout realizing that figure is only a portion of that total. In addi tion, the basis for the saves/spend disclosure is five years of operation while, elsewhere on the label, the basis for the total operating cost disclosure is one year of operation. This may cause confusion. In addition, we expect the five year assumption will be lost on many consumers. Finally, because the saves/spend figures compare to an “average vehicle” that may not be in a consumer’s decision set, these figures may not be particularly useful to many consumers. Given these concerns, the “saves/spend” disclosure should be tested for these po tential problems. Commenter notes that FTC has found through consumer research that the annual operating cost provides a useful, straightforward disclosure that allows for easy comparisons among all products (regardless of size and configura tion). Commenter recommends that EPA and DOT consider displaying the annual operati ng cost figure prominently in lieu of the problematic saves/spend disclosure. Such a ch ange is likely to make the label clearer, simpler to read and less cluttered.

18. Environmental and Combined MPG Scales: Th e three small scales on Label 1 (combined MPG, CO2, and Air Pollutants) are difficult to read and clutter the label. Accordingly, commenter suspects that consumers will have difficulty understanding these scales and their presence may detract from other label in formation. To the extent that such rating scales are required under the statute, commenter suggests that EPA and DOT consider whether the simple letter rating on Label 1 meets such requirements. If they do,
commenter recommends that these small scales be removed from the label. This would increase label space and allow the size of the disclosures above the ranges to be increased. Similarly, to the extent that e nvironmental impacts are collinear with fuel economy, commenter suggests that EPA and DOT consider consolidating information (or significantly reducing the promin ence of environmental disclosures) wherever possible to reduce clutter. For example, the greenhouse ga s and air pollutant scales in Label 2 could be eliminated or made less prominent to simplify the label and make it easier for

consumers to use.

19. FTC Label Reference: On page 61, the term “ha ng tag” should be replaced with the term
“label.”

20. Some commenters questioned the utility of the overall summary rating because it does not by itself provide useful information to consumers. Have the agencies considered increasing the font of information that cons umers might find more useful and decreasing the font of the overall summary rating that might not provide any useful information?

21. Some consideration should be given to the que stion of whether any car ought to receive a grade of A+. There may be undue psychologi cal effects on consumers’ environmental choices. Consumers might get the impression th at their environmental obligations are fulfilled after getting an A+ car . In addition, people tend to dr ive more miles if they think
their car is more fuel efficient, and so if someone is led to believe their car has NO environmental impact, then who knows how they ’ll change their behavior. In fact, thereSummary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

8 are many cleaner ways to get around than an el ectric vehicle – even if it is powered by wind energy – such as bicy cling, metro, walking, etc.

22. The labels could be a major source of unbi ased information on vehicle environmental performance and fuel efficiency. The guidance to the Administrator in the Statute is clear. The labels should provide consumer s with information compare the fuel economy and greenhouse gas and other emissions of auto mobiles at the point of purchase with an emphasis on vehicles that provide the lowe st greenhouse gas emissions over the useful
life of the vehicles. The decision contained in the proposed rule to base greenhouse gas performance on tailpipe emissi ons is highly misleading. This approach overestimates the
benefits of electric vehicles and underestimat es the performance of vehicles operating on ethanol or biodiesel. Tailpipe emissions do not reflect the greenhouse gas emissions
associated with the useful life of a vehicle. One inte ragency commenter recommended that the labels be redesigned to includ e information on the greenhouse gas performance
of E10 and E85 and other flexible fuel vehi cles consistent with EPA estimates of the
benefits of these fuels from the RFS. Comm enter recommends that the GHG values for plug-in electric vehicles incl ude the emissions associated w ith electricity production.

23. A stated goal of the fuel economy standards is to provide information to consumers to allow them to identify those vehicles that use less oil and have a lesser environmental impact. Including information for E85 a nd EVs on gasoline savings will provide consumers with information regarding th e benefits of ethanol in reducing oil consumption. One commenter recommended that the labels for alternative fuel vehicles include information specifically on gasoline savings in addition to fuel savings.

24. Page 28, Section II.3. Neither approach c ontained in this sec tion correctly report greenhouse gas emissions from plug-in electric ve hicles and flexible fuel vehicles. The basis for the values and ratings should include upstream emissions and carbon sequestration. Some commenter s suggested that the current approach is misleading and will misinform the public on the environmen tal performance of the vehicles.

25. Within Section II.3. Add the followi ng from the EPA RFS fact sheet:

The U.S. Environmental Protection Agency recently finalized the National Renewable Fuel Standard program (commonly known as the RFS program) which establishes new specific annual volume standards for cellulosi c biofuel, biomass-based diesel, advanced biofuel, and total renewable fu el that must be used in tr ansportation fuel. The expanded use of renewable fuels is expected to reduce greenhouse gas emissions by 138 million metric tons when the program is fully implemented in 2022. The reductions will be equivalent to taking about 27 million vehicles off the road.

EPA has determined that:Summary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

9  Ethanol produced from corn starch at a new (or expanded capacity from an existing) natural gas-fired facility usi ng advanced efficient technologie s that we expect will be most typical of new production facilities will reduce GHG emissions by at least 20%;

 Biobutanol from corn starch will reduce GHG emissions by at least 20%:

 Ethanol produced from sugarcane will reduce GHG emissions by at least 50%:

 Biodiesel from soy oil and renewable diesel from waste oils, fats, algal oils, and greases will reduce GHG emissions by at least 50%

 Cellulosic ethanol and cellulosic diesel (based on currently modeled pathways) will reduce GHG emissions by at least 60%;

The agencies propose to base the greenhouse gas performance values flexible fueled vehicles incorporating the average greenhouse gas benefits from ethanol and biodiesel expected for that year. The agencies also propose to include the following statement on conventional fuel vehicle labels: Using fuels blended with ethanol/biodiesel will reduce oil consumption and greenhouse gas emissions. The agencies seek comment on how to best provide the public information on CO2 emissions from combusting fossil fuels and reductions in CO2 emissions from combusting biofuels

.

Page 29: “...As far as emission sources to include, NHTSA and EPA propose that the greenhouse gas emissions represented on the label include only vehicle tailpipe emissions
and do not account for as well as any GHG emissions and reductions generated upstream
of the vehicle. NHTSA and EPA request comments on how best to provide that information. This approach is also co nsistent with the vehicle GHG emissions compliance levels recently adopted by EPA, which treat GHG emissions for electric operati on as zero up to a cumulative production cap per manufacturer. When exploring this issue with focus groups, the agencies found that most participants
did not consider the is sue of upstream emissions either way. A few raised it when they
noted that an el ectric vehicle indicated zero emissions , and suggested that these vehicles did cause some emissions at the power plant, which should be represented on the label. On further discussion, they generally determ ined that it would be challenging for the
label t o meaningfully represent the range of emissions from power plants operated on different fuels, and suggested that this information was obtai nable from other sources. Given space constraints and the difficulty of explaining the potent ial range of upstream emissions due to different fuel sources, partic ipants tended to agree that this issue could be adequately addressed by a statement on the label indicating that the CO2 values on the label represented vehicle tailpipe emissions only . The label designs presented in this NPRM include the words “Average CO2 Emi ssions” and include a note explaining that
the value includes direct emissions as well as u pstream emissions and reductions from
alternative fuels.” That value will be calcu lated using the mandated blend percentage of renewable biofuels for that year specified under the RFS . The agencies seek comment on whether this wording will be re adily and uniformly understood to mean show that upstream GHG emissions are not being reflected on the label, or whether other, more direct wording might be clearer and more helpful to consumers.Summary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

10 Page 57: “The agencies believe that th ese various requirements are met by providing information on the performance of the vehicle itself on the label and not as well as by including upstream emissions reductions in emissions .”

Page 58: “..However, EPA notes that some c onsumers may be interested in more detailed estimates of the upstream GHG and energy impact s associated with vehi cles that they are considering purchasing beyond what is provided on the label . We plan to provide
additional information on websites that will inform consumers of the projected upstream GHG and energy impacts of vehicle operati on, based on both national average values and, where appropriate because of regional variability, regional values as well...”

Page 66: “...A second option is to require th e addition of E85 fuel economy values to FFV labels using the units of miles per gall on of gasoline. Since E85 has a lower energy density (i.e., about 25% less energy per gallon) than gasoli ne, this means that, other things being equal, an FFV will have a lower fuel economy on E85 than it will on gasoline. EPA recognizes that this does not m ean that ethanol is a “less efficient” fuel than gasoline; in fact, FFVs are typically s lightly more efficient on E85 than on gasoline in terms of miles per unit of energy. Accordingly, one appr oach under this option would be to add text such as the following wordi ng on the label that conveys this message: “While the E85 mpg values are lower than the gasoline mpg values, the use of E85 is actually slightly more energy e fficient than the use of gaso line.” Under this option, it would also be possible to add E85 values for CO 2 emissions (an FFV typically emits slightly less CO 2 per mile on E85 than on gasoline) a nd fuel costs (an FFV typically costs somewhat more to operate on E85 than gasoline, though this can vary by region). In addition, the CO2 reductions from combusti ng E85 fuel will be shown alongside the tailpipe CO2 emissions assuming conventional fuel. If CO 2 values are not shown, it would also be possible to include a statem ent such as “Using E85 uses less oil and typically produces less CO 2 emissions than gasoline. ”

Page 71: “... A. Proposed Label Designs The agencies are proposing two label designs , presenting both de signs as equal “coproposals” but expecting to finalize only one design based on public comments and other information gathered after the proposal. Although the two designs shown below have fundamentally different visual appearances and will no doubt elicit very different reactions from some viewers, they essentiall y present exactly the same basic information. For conventional vehicles, for example, each design displays the following:

 City MPG

 Highway MPG

 Combined gallons/100 miles

 CO 2 grams per mile (combined city/highway)

 CO 2 benefits of the use of renewable fuels

 Gasoline or diesel fuel savings from using alternative fuels

 Estimated annual fuel cost

 Range of fuel economy within the class

 The fuel the vehicle usesSummary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

11  Three “slider bars” showing th e performance of the labeled vehicle relative to other vehicles for mpg, CO 2 , and other air pollutants

 Annual fuel cost assumptions

 A symbol that can be read by a “‘Smartphone ”’ for additional consumer interactions (i.e., a “QR” Code)

 A Fuel Economy Guide statement

 EPA, DOE, and DOT logosSummary of Interagency Worki ng Comments Received on Draft Rule under EO 12866 Review. Subject to Further Policy Review

12 Page 73: On all labels add another bullet regarding average reduc tion in CO2 due to
renewable fuels

Figure III-1. Label 1 for conventional (gas) vehicle, B grade.

 Using fuels blended with
ethanol will reduce greenhouse gas emissions. Delete “tailpipe only” replace with “conventional gasoline”Summary of Interagency Work ing Comments on Draft Rule under EO 12866 review. These are subject to further policy review.

13 Page 80: For FFV--- (similar comments on other label designs)

Include Separate row with values based on conventional gasoline and E85. Do not base GHG benefits on tailpipe emissions – rather use values consistent with those developed by EPA
under the RFS. Delete “tailpipe only” replace with “conventional gasoline”Summary of Interagency Work ing Comments on Draft Rule under EO 12866 review. These are subject to further policy review.

14 Page 82: --- (similar comments on other label designs)

Delete tailpipe only Replace with “conventional gasoline”

Add: Using fuels blended with ethanol will reduce greenhouse gas emissions.Summary of Interagency Work ing Comments on Draft Rule under EO 12866 review. These are subject to further policy review.

15 Page 88: Create a similar la bel for FFV --- (see suggested prototype on next page)

Delete “tailpipe only”

 CO2 avoided using E10

 CO2 avoided using E85Summary of Interagency Work ing Comments on Draft Rule under EO 12866 review. These are subject to further policy review.

16 Suggested prototype for FFV Label

Note E85 CO2 calculation: Assume that the nati onal average RFS for a given year is 50% corn

ethanol and 50% advanced biof uel (hypothetical) = 0.15 x (gas emissions) + (0.85 x 0.5)(0.8 x gas emissions) + (0.5 x 0.85)(0.4 x gas emissions) = 229 vs 347

Note E85 only Fuel Economy calculati on: Not done for this exercise 229 347 

### E85 Conventional Gasoline 

### Flex Fuel Vehicle

Conventional gasoline consumption per year 

# 38

1,114 Cost per year if
run in E85 mode

E85 Gas only Gallons fuel per
100 miles