Summary of Interagency Working Comments Received on Draft Rule under EO 12866 Review. 

Subject to Further Policy Review 

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Below is a summary of interagency comments received 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 enthusiastically appreciate and support 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 electric vehicles (EVs), where the source of 

electricity is critical to determining the magnitude of the emissions attributable to them 

(see graphic below). EISA does not require that 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 alternative representations of emissions (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 agencies 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 developing 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, regardless of source? Did the agencies conduct 

an analysis to see if this was possible? 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 source? This is somewhat different from an 

“upstream” definition, which can include emissions from the production and 

processing of a fuel. Commenters suggest the agencies evaluate label options for 

“emissions from the combustion of fuel (source of energy) used to directly power 

the vehicle” that includes electricity. For example, Executive Order 13514 

requires Federal Agencies to account for and report GHG emissions resulting 

from vehicle operation. This includes emissions from the combustion of any nonrenewable fuel or energy source used to directly power the vehicle, including 

electricity used by EVs. National or regional factors can be used to calculate 

GHG emissions resulting from vehicle operation. 
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c. Some interagency commenters suggested that applying a rating of 0 grams/mile to 

EVs may lead to attacks that the Administration is purposely 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 “tailpipe 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 'when driving' was contradictory to the 

overall zero emission claim, and the impression that the car's use would not result 

in the production of emissions.”

d. It is important to be consistent and not 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 and carbon neutrality is ongoing. The 

Administration has documents out for public comment where 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, national cost estimates are used for Energy 

Guide labels even though the cost of electricity 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 depending on the mix of electricity generation 

where they are used--that Energy Guide labels be updated to include lifecycle 

GHG emissions. Specifically, they recommended “adding to the Energy Guide 

label an indicator of how an appliance’s total energy consumption might affect 

levels of greenhouse gas emissions” (emphasis added). NAS also recommended 

“moving over time to use of the full-fuel-cycle measure of energy consumption 

for assessment of national and environmental impacts, especially levels of 

greenhouse gas emissions.” 

f. Not all EVs are created equal – some will require much more energy per mile 

traveled than others, and using a single value of zero grams of CO2per 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, according to several estimates, the lifecycle 

emissions of EVs that are supplied with electricity generated by coal-fired power 

plants exceed the lifecycle emissions of gasoline-powered HEVs. 
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h. Technical comment: The proposed rating system may make it hard to achieve the 

rule’s stated purpose of allowing consumers to compare fuel economy because 

EPA’s proposal to rely upon CO2 emissions for assigning letter grades, rather than 

fuel economy or some combination of the 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 CO2 emissions (0 grams/mile, with an 

A+ threshold of 76 grams/mile). However, 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). Similar problems could arise with regards to 

carbon-intensive but energy-dense diesel. EPA states: “Because vehicles that are 

low in CO2 emissions have inherently good fuel economy (and vice versa), and 

because CO2 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 nonzero 

fuel economy/consumption values (in terms of kW-hrs/100 miles or mpgequivalent), but do not include corresponding CO2 emissions – even though 

electricity sources providing the fuel for EVs currently produce CO2 emissions. 

One option may be a nationwide average emissions 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-grid factors used to convert fuel use to 

GHG emissions . Thus, the rulemaking process is a valuable opportunity to 

propose both alternatives and gather feedback about the best possible display of 

emission data for EVs and other technologies. The agencies should therefore 

accept comments about solutions to concerns about how to calculate imputed 

emissions for EVs, overcome challenges about regional or temporal variations in 

CO2 emissions from electricity generation, 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 Working Comments Received on Draft Rule under EO 12866 Review. 

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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 socially 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 more easily assess the true costs and emissions 

of different vehicles and make fully-informed decisions. The agencies should not imply 

that consumers who do not buy more fuel efficient 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 agencies consider in deciding how to 

help consumers compare vehicles? The current 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 year model year even if it is more efficient 

because of the shifting median vehicle. Do the 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 highlight the model year more prominently on 

the label. Also, the agencies should consider – in greater detail – that consumers may 

want to compare essentially identical vehicles, but for different model years. As 

described above, under the updated grading scheme, 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 preference for energy efficient and environmentally friendly 

vehicles” (page 14). 
Summary of Interagency Working Comments Received on Draft Rule under EO 12866 Review. 

Subject to Further Policy Review 

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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 presentation 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 excluded 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 upgrade might not level the playing field. 

Have the agencies considered implications from 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 upstream emissions refers to on page 29. 

8. Commenters recommended that the agencies use “GHG Performance” instead of 

“Environment” on the label itself because 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 included 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 cars or light trucks) and customize them for 

(re)sale. Would these firms be required to provide a label when they resold the vehicle? 

(Commenter asked this because these “aftermarket” firms are likely to be small 

businesses, and if they are covered by the rule need to be included 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 should also include “auto dealers,” 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 regulated entities). 
Summary of Interagency Working Comments Received on Draft Rule under EO 12866 Review. 

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12. The NPRM does a great job outlining 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 than GMP. Commenter 

understands that people now are 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 relative font sizes or placements changing 

over a decade. 

13. On page 30 of the preamble there is a discussion 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 last paragraph, the word “actually” should be 

replaced with “typically” as shown below. This change would make the sentence 

consistent with the discussion preceding this sentence and corresponds to DOE’s findings 

in testing E85-FFVs energy efficiency and fuel economy. 

“While the E85 mpg values are lower than the gasoline mpg values, the use of 

E85 is actually typically slightly more energy efficient 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 basis since these fuels are 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 equivalent basis. 

17. Label 1 “Saves/Spend” Disclosures: For vehicles with below-average economy, proposed 

Label 1 would disclose the additional cost of fuel 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 average vehicle.” Similarly, for above average 

vehicles, Label 1 contains a savings claim (e.g., “Over five years, this vehicle saves 
Summary of Interagency Working Comments Received on Draft Rule under EO 12866 Review. 

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$5,700 in fuel costs compared to the average vehicle”). 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 without realizing that 

figure is only a portion of that total. In addition, 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 potential 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 configuration). Commenter recommends that EPA and 

DOT consider displaying the annual operating cost figure prominently in lieu of the 

problematic saves/spend disclosure. Such a change is likely to make the label clearer, 

simpler to read and less cluttered. 

18. Environmental and Combined MPG Scales: The 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 information. 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 environmental impacts are collinear with fuel 

economy, commenter suggests that EPA and DOT consider consolidating information (or 

significantly reducing the prominence of environmental disclosures) wherever possible to 

reduce clutter. For example, the greenhouse gas 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 “hang 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 consumers 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 question of whether any car ought to receive a 

grade of A+. There may be undue psychological effects on consumers’ environmental 

choices. Consumers might get the impression that their environmental obligations are 

fulfilled after getting an A+ car. In addition, people tend to drive 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, there 
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are many cleaner ways to get around than an electric vehicle – even if it is powered by 

wind energy – such as bicycling, metro, walking, etc. 

22. The labels could be a major source of unbiased information on vehicle environmental 

performance and fuel efficiency. The guidance to the Administrator in the Statute is 

clear. The labels should provide consumers with information compare the fuel economy 

and greenhouse gas and other emissions of automobiles at the point of purchase with an 

emphasis on vehicles that provide the lowest greenhouse gas emissions over the useful 

life of the vehicles. The decision contained in the proposed rule to base greenhouse gas 

performance on tailpipe emissions is highly misleading. This approach overestimates the 

benefits of electric vehicles and underestimates 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 interagency commenter recommended 

that the labels be redesigned to include information on the greenhouse gas performance 

of E10 and E85 and other flexible fuel vehicles consistent with EPA estimates of the 

benefits of these fuels from the RFS. Commenter recommends that the GHG values for 

plug-in electric vehicles include the emissions associated with 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 and EVs on gasoline savings will provide 

consumers with information regarding the 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 contained in this section correctly report 

greenhouse gas emissions from plug-in electric vehicles and flexible fuel vehicles. The 

basis for the values and ratings should include upstream emissions and carbon 

sequestration. Some commenters suggested that the current approach is misleading and 

will misinform the public on the environmental performance of the vehicles. 

25. Within Section II.3. Add the following 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 cellulosic biofuel, biomass-based diesel, advanced 

biofuel, and total renewable fuel that must be used in transportation 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 Working Comments Received on Draft Rule under EO 12866 Review. 

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 Ethanol produced from corn starch at a new (or expanded capacity from an existing) 

natural gas-fired facility using advanced efficient technologies 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 consistent with the vehicle GHG emissions 

compliance levels recently adopted by EPA, which treat GHG emissions for electric 

operation 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 issue of upstream emissions either way. A few raised it when they 

noted that an electric 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 determined that it would be challenging for the 

label to meaningfully represent the range of emissions from power plants operated on 

different fuels, and suggested that this information was obtainable from other sources. 

Given space constraints and the difficulty of explaining the potential range of upstream 

emissions due to different fuel sources, participants 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 Emissions” and include a note explaining that 

the value includes direct emissions as well as upstream emissions and reductions from 

alternative fuels.” That value will be calculated 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 readily 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. 
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Page 57: “The agencies believe that these 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 consumers may be interested in more detailed 

estimates of the upstream GHG and energy impacts associated with vehicles 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 operation, 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 the addition of E85 fuel economy values to 

FFV labels using the units of miles per gallon of gasoline. Since E85 has a lower energy 

density (i.e., about 25% less energy per gallon) than gasoline, 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 mean that ethanol is a “less efficient” fuel 

than gasoline; in fact, FFVs are typically slightly more efficient on E85 than on gasoline 

in terms of miles per unit of energy. Accordingly, one approach under this option would 

be to add text such as the following wording 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 efficient than the use of gasoline.” Under this option, it 

would also be possible to add E85 values for CO2 emissions (an FFV typically emits 

slightly less CO2 per mile on E85 than on gasoline) and 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 combusting E85 fuel will be shown alongside the 

tailpipe CO2 emissions assuming conventional fuel. If CO2 values are not shown, it 

would also be possible to include a statement such as “Using E85 uses less oil and 

typically produces less CO2 emissions than gasoline.” 

Page 71: “... A. Proposed Label Designs 

The agencies are proposing two label designs, presenting both designs 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 essentially present exactly the same basic information. 

For conventional vehicles, for example, each design displays the following: 

 City MPG 

 Highway MPG 

 Combined gallons/100 miles 

 CO2 grams per mile (combined city/highway) 

 CO2 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 uses 
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 Three “slider bars” showing the performance of the labeled vehicle relative to other 

vehicles for mpg, CO2, 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 logos 
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Page 73: On all labels add another bullet regarding average reduction 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” 
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subject to further policy review. 

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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” 
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subject to further policy review. 

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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. 
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Page 88: Create a similar label for FFV --- (see suggested prototype on next page) 

Delete “tailpipe only” 

 CO2 avoided using E10 

 CO2 avoided using E85 
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Suggested prototype for FFV Label 

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

ethanol and 50% advanced biofuel (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 calculation: Not done for this exercise 

347 229 

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