-20-

III. Modified Labeling Program

A. Background

As described in Section II, each value on a fuel economy label
represents the fuel economy estimate of vehicles of the same general
design, called model types. Specifically, the model ‘type includes vehicles
which have the same basic engine and transmission class (defined in Section
“Tr.e), and are in the same car line. ~ ; ~

The current general label often does not reflect design differences
which exist within the classification of model types. Differences in axle
ratios, weight, and engine calibration can have a significant affect on the
fuel efficiency of a particular vehicle. Under the current labeling
program, however, the vehicles with these differences receive the same
label value. If we were to test each subconfiguration to determine the
effect of these differences, over 6,000 additional tests would have to be
performed, an increase of 500 percent over current number of tests. An

imcrease in testing of this magnitude could not be justified in either the

resources required to perform the tests or the associated rise in vehicle cost.

Even though it is not feasible to test each subconfiguration, a
method is available to mathematically adjust test data for several design
differences and produce data applicable to the untested subconfigurations.
EPA has developed? equations to adjust actual test data for differences
in axle ratios, ETW's, and RLHP. Referring back to table I, there were
only three fuel economy values for the example product line Using the
adjusting equations, each vehicle subconfiguration would be represented, by
either test values or adjusted test values. Subsection B of this section

will describe in detail how the calculations are to be made.

9. Murrell, "Technical Support Report for Regulatory Action Light-Duty Vehicle
Fuel Economy Labeling," U.S. Environmental Protection Agency, EPA/AA/CTAB/FE-81-6,
October, 1980


-41-

- The range of highway fuel economy differences for cars
is -6 mpg to +5 mpg.

b. Trucks:

- About 30 percent of all trucks would receive different
estimates of city fuel economy.

- About 25 percent of all trucks would have an estimate
of city fuel economy 1 mpg different from the current
label value.

- Less than 5 percent of all trucks would have an estimate
of city fuel economy 2 mpg or more from the current
label value.

- Less than 5 percent of all trucks would have a label
value recalculated at higher fuel economy values than
present.

- About 40 percent of all trucks would receive different
estimates of highway fuel economy (currently calculated
but not displayed on the vehicle label).

- About 30 percent of all trucks would have an estimate
of highway fuel economy 1 mpg different from the value
currently calculated.

- About 10 percent of all trucks would have an estimate
of highway fuel economy 2 mpg or more from the
currently calculated highway.

- About 10 percent of all trucks would have a recal-
culated highway value higher than the present value.

- The range of city fuel economy differences for trucks
is from -8 mpg to +3 mpg.

- The range of highway fuel economy differences for trucks
is from -10 mpg to +4 mpg.
3. Discussion
In reviewing the data (Appendix A through Appendix E) the effect
the modified label calculation would have on different stratifications of
these data are apparent. Two apparent stratifications are; cars versus

trucks and foreign versus domestic.


Table VII

Fuel Economy Values for Current and Proposed Labels--MPG

1 Present Modified Model Type- Model Type- Model Type-
Model Type Model Type Model Type Axle Axle-ETW Axle-ETW-RLHP
city/highway city/highway city/highway city/highway city/highway

A 16/22 16/20 16/20 16/20 16/20
(actual test (1A81B*) (1A&1B*) (1aA*) (1a*) (1a*)
data in this 17/22 17/22 17/22
model type: (1B*) (1B*) (1B*)
16.0/22.2)

B 16/20 15/18 16/20 16/20 16/20
(no actual test (1C,1D,2A (1¢,1D,2A (1c*) (ic*) (ic
data in this & 2c*) & 2c*) 15/18 15/18 15/18
model type) (1D&2A*) (ip*) (ip*)

14/17 15/18 15/18
(2¢c*) (2a*) (2a*)
14/17 14/17
(2c*) (2c*)

c 14/17 14/17 15/18 15/18 15/18
(actual test (2B&2D*) (2B&2D*) (2B*) (2B*) (2B*)
data in this 14/16 14/16 14/16
model type: (2D*) (2D*) (2D*)
14.7/17.5,
14,0/16.3)

* Index(s) References

1 Refer to Table IL for description of car lines within a model type.

2 Refer to Table VI

Page 37

Model Type-
Subconfiguration

city/highway

16/20
(1a*)
17/22
(1B*)

16/20
(ic)
15/18
(1p*)
15/18
(2a*)
14/17
(2c*)

15/18
(2B*)
14/16
(2D*)


a City Wa)
it
=
i HI
ie) = wan ji LS)
ait 4
‘ =
A= +1 mpg Highway J ~ +7
3 2
a (e} oO
: 2 4
~ 3 a at
tot rc 34
3 S = 3c
28 ig 244
: 184 A = 0 mpg City 1a Pan
=f 2
o oO
OL WI >
maf 7 | on
at ea
& 2
3 my
ut p Bo 3
3 2H
: g 3 i oe
ze cat = eo
72 ot pera
== = a 4 = 0 mpg Highway PSH 2H
one a <a aa
sire 4 Od 2
lee H od
ff “SI L ae
° i L ot
z S: arr
were 4 Number of Labels or
rite 3 =
sen 2) aa8
eae or
went [
zz
err ea
erue
ie io)
Domestic and Foreign Cars’
Level of Labeling Detail
T t < crit ro Oe r
Current Model Proposed Proposed Proposed Proposed Proposed
Type (MT) MT MT + Axle MT + Axle MT + Axle MT + Subcon-
+ ETW + ETW + RLHP figuration
LELP UE
Table No. A-l Relationship of the Number of Labels Required

for Each Level of Label Detail with Sales Percent Within Each
Level of Detail


-14-

overcome vehicle engine friction, driveline friction, and air resistance

in order to keep a vehicle rolling at a constant speed. While EPA has
informally used the term subconfiguration, this term will be formally
defined in a new fuel economy regulation to mean the unique combination of
equivalent test weight and road-load horsepower within a vehicle configura-

tion.

D. Determination of the General Label Value:

The minimum amount of test data required to determine a
general label value is data from at least one vehicle configuration
within each base level. If data from more than one configuration 1s
available within a base level, the base level fuel economy 1s determined by
a sales-weighted average of all the tested configuration fuel economies.
Each model type may contain several different base levels since a model

type can span several different inertia weight classes. That is,

Model Type = basic engine, transmission class, and carline

Base Level = basic engine, transmission class, and inertia weight class

The difference between model type and base level is carline and inertia
weight class. Thus, 1f there 1s more than one inertia weight class within a
carline the model type will have more than one base level. The base level
fuel economy values within each model type are sales weighted and averaged
to obtain the model type fuel economy values. These are the fuel economy

values printed on the vehicle fuel economy labels.

1. Calculation Procedure
a. Vehicle Configuration's Fuel Economy’ If there is

only one set of city and highway fuel economy values (highway values are


Table C-5 Foreign

Fuel Economy Differences Versus Percent Sales; Modified
Model Type Label Minus current Label Value

CARS-CLTY
Percent Differences in
Sales Fuel Economy
3.92 -l xX
93.03 O XXXXXXXXXXXXXXXXXXXXXXXKKXXXXXXXKXKKKKXKXKKKKKK
3.05 +1 XX
100.00
TRUCKS-CITY
2.01 -2) Xx
1.04 -l Xx
96.95 0) XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXKXXXXXXXXXXXXKK

100.00


Table A-11 Domestic and Foreign

Fuel Economy Differences Versus Percent Sales; Modified Model
Type + Axle + ETW + RLHP Label Minus Current Label Value

CARS-CITY

Percent Modified - Current
Sales Label Differences-mpg

0.53 -3) Xx

3.25 “2. XX

18.29 -1  XXXXXXXXX
67.24 ie) XXXXXXXXXXXXXXXXKXXXXXXXKXXXXKXXXXXK

9.14 +1 XXXXX

1.55 +2, =X
100.00

TRUCKS-CITY

0.03 “8 xX

0.01 5 xX

0 OL “4A Xx

0.17 3) Xx

2.15 72 x

26.30 -1 XXXXXXXXXXXXX
66.51 0 XXXXXXXXXXXXXXXXXXXXXXKKXXXXXXXKK

4.78 +l XK

0.03 +20 =X

0.01 +300=«X

100.00


Table A-9 Domestic and Foreign

Fuel Economy Differences Versus Percent Sales; Modified
Model Type + Axle + ETW Label Minus Current Label Value

CARS-CITY
Percent Modified - Current
Sales Label Differences-mpg
0.53 -3) Xx
3.12 -2) XX
17.88 1 XXXXXXKKK
71.96 O XXXXXXXXXXXXXXXXXXXKXXXXXXKXXXXXXXXX
4.98 +1 XX
1.53 +20 =X
100.00
TRUCKS-CITY
0.03 “8 Xx
0.01 “5 xX
0.01 “4 Xk
0.17 -3) Xx
1.96 2 Xx
25.33 ~1  XXXXXKXXXXXXK
68.36 QO = -XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
4.10 +1 XX
0.03 +20=«X
0.00 +3



Appendix B

Domestic Manufacturers

American Motors, Chrysler, Ford, and General Motors
Table Nos. Title

B-1 and B-2 Relationship of the Number of Labels Required for Each
Level of Label Detail with Sales Percent Differences
within Each Level of Labeling; City and Highway Label
Differences. 7

B-3 and B-4 Sales Percentages for Absolute Label Differences versus
Percent Sales; City and Highway Label Differences.

Fuel Economy Differences versus Percent Sales;

B-5 Modified Model Type Label value - Current Label Value;
City

B-6 Modified Model Type Label Value - Current Label Value;
Highway

B-7 Modified Model Type + Subconfiguration Label Values -

Current Label Value, City

B-8 Modified Model Type + Subconfiguration Label Values —
Current Label Value; Highway


Table B-4 Domestic, Trucks

Absolute Label Differences Versus Percent Sales

I. City Il. Highway
Label Ampg % Sales Label Ampg % Sales
A 0 “77 A 0 59
1 22 1 35
2 1 2 4
3 0 >3 2

seeeessesteess:

c 0 65 c 0 52
1 33 1 35
2 2 2 10
3 0 >3 3

D 0 62 D 0 51
1 35 1 34

2 2 2 ll

23 1 23 4

E 0 64 E 0 $1

1 34 1 34

2 2 2 ll

23 0 23 4

A = Modified Model Type Label 0 means fraction < 0.5

B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label

E = Modified Model Type + Subconfiguration Label


Table A-/ Domestic and Foreign

Fuel Economy differences Versus Percent Sales; Modified
Model Type + Axle Label Minus Current Label Value

CARS-CITY
Percent Modified - Current
Sales Label Differences-mpg
2.35 2 =X
18.12 1 XXXXXXKXK
74.82 0 XXXXXXXXXXXXXXXXXKXXXXXXXXXXXXXXXXXXK
4.10 +1 xXx
0.61 +20=«X
100.00
TRUCKS-CITY
0.03 “8 XxX
0.01 5 x
0.01 4 Xx
0.15 -3 x
1.94 2 =X
17.62 1 XXXXXXXXX
78.63 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXK
1.58 +1 x
0.03 +20=«X

100.00


STEP 1:

-24-

Correct for differences
Correct for axle differences
dX = 2.73 ~ 2.43 = 0.30

XK = (2.43 + 2.73)/2 = 2.58

FE, = 16.6 mpg

S = 1.025 - 0.437(AR) = -0.1025

are, =e, { 2(sy(ax) |) = 16,6 2(-0.1025)(0.30) \
Axle T =
1® - (ex) 22.58) ~ (0,1025)(0.30)}
GFE, 19 7 70-1966 mpg

Correct for RLHP differences
aX = 10.4 - 8.9 = 1.5
X= (8.9 + 10.4)/2 = 9.65

FEY = 16.6 mpg

S = -0.247 + 0.756(10 2)RERP = -0.1740

GFE yap 7 FEp{__2(5) (ax) \. 16.6 2(-0.1740)(1.5)
2¢x) = s¢ax) J 2(9.65) - (-0.1740)(1.5)
= -0.4431 mpg

Correct for ETW differences

aX = 3625 - 3375 = 250

X = 3,500

FE, = 16.6 mpg

S$ = -0.657 + 9.542110 >) + 3.512(10 2 °)H? = -0.3187

agg = (EN) = e.g Sh NEE a

= -0.3737 mpg


-42-

The car versus truck stratification is reflected by the number of
labels necessary for each labeling alternative. That 1s, going from the
present labeling program to the model type + axle label alternative would
increase the number of car labels by 94, more than a 15 percent increase
over the current 616. The same alternative would increase the number of
truck labels by 287, more than a 64 percent increase over the current 449.
Going from the present program to the most detailed level of labeling
(1.e., car line + vehicle subconfigurations) would increase the number of
car labels by 1187 (about 3 times the current number of labels) and truck
labels by 2023 (over 5 times the current number of labels). (These data

are applicable for the nine manufacturers evaluated.)

In referring to Appendixes A through C, it is apparent that
the increase in labeling detail will also increase the label fuel economy
values of trucks to a greater extent than those values of cars. This is not
an unexpected trend in that manufacturer make available a larger number of
options for trucks that effect fuel economy than for cases e.g., a wide
range of axle ratios, lower geared transmissions, and severe service (heavy

duty) options, the latter often increase the weight of the vehicle.

Within the stratification of cars and trucks there exists another
level of stratification, domestic and foreign manufactured cars and trucks.
This trend 1s again the result of the number of fuel economy influencing
options offered by the different manufacturers, e.g., the foreign manufac-
turers usuallly offer only a single axle, transmission gearing, or limited
weight adding option for each model type. For example, for the manufacturers

evaluated, the number of labels needed for cars at the model type plus axle


Table C-4

Foreign, Trucks

“absolute Label Differences versus Percent Sales

I. City Il. Highway
Label Ampg % Sales Label Ampg % Sakes
A 0 97 A 0 83
1 1 1 14
2 2 2 1
>3 2

97 B 0
1 1
2 2
0 >3

91 ¢ 0
7 1
2 2
0 23

sesezce:

91 D 0
7 1
2 2
0 >3

E 0 91 E 0 86
1 7 1 ll
2 2 2 1
>3 0 33 2
A = Modified Model Type Label OQ means fraction < 0.5
B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label

D = Modified Model

E = Modified Model

Type

Type

+ Axle + ETW + RLHP Label

+ Subconfiguration Label


A. Test Procedure

A fuel economy test comprises data obtained from two separate

22 4

test procedures; the urban cycle! and the highway cycle? The urban
cycle (or city cycle) is intended to simulate city type driving conditions,
i.e , stop and starts, with intermediate vehicle speeds. The highway cycle
does not include any stop or starts within the cycle, does not have "quick"
changes in speed, but represents higher speeds of in-use operation

characteristic of open country roads, in the range of 40 to 50 mph.

1. Urban Cycle’ A complete urban test cycle consists of a "soak"
period of at least 12 hours prior to the test at a laboratory ambient
temperature between 68 and 86°F. During this soak period the engine is
not started. After the soak, the vehicle is placed on a chassis dynamometer
and the sampling equipment attached, a technician starts and "drives" the
vehicle for a distance of 7.5 miles matching the vehicle speed with
the speed on a pre-printed chart. Upon completion of the simulated 7.5 mile
trip the engine is shut off for a period of ten minutes, as one might after
arriving at the store, office, etc. The engine 1s restarted and the
operator drives the vehicle over the first 3.6 miles of the driving schedule
again. The total distance driven is 11.1 miles During the 11.1 miles, 21
stop and starts are made and a maximum speed of 56 miles per hour (mph) is
reached. The average speed over the complete cycle 1s 21 mph which includes

the idle time during periods when the vehicle is stopped.

1. Kruse and Huls, "Development of the Federal Urban Driving Schedule", U.S.
Environmental Protection Agency, SAE Paper 730553, May 1973.

2. Huls, "Evaluation of Federal Light-Duty Mass Emissions Regulations", U.S.
Environmental Protection Agency, SAE Paper 730554, May 1973

3. Kruse and Paulsell, "Development of a Highway Driving Cycle for Fuel
Economy Measurements", U.S. Environmental Protection Agency, Internal EPA
Report, March, 1974

4. Austin, Hellman, and Paulsell, "Passenger Car Fuel Economy During Non-
Urban Driving", SAE Paper 740542, August 1974


Table C-7 Foreign

Fuel Economy Differences Versus Percent Sales; Modified Model Type +
Subconfiguration Label Minus Current Label Value

CARS-CITY
Percent Differences in
Sales Fuel Economy
0.77 2. Xx
5 83 -l1 = XKX
80.76 OQ = XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXKXXXK
12.53 +1 XXXXXK
Q.11 +2 =X
100.00
TRUCKS-CITY
0.18 8 x
0.06 “5 Xx
2.01 -2 =k
6.89 -l Xxx
90.53 0 XXXXXXXXXXXXXXXXXXXXXXX XXXXXKXXXXXXXXXXXXXXKX
0.33 +1 x

100.00


Table C-6 Foreign

Fuel Economy Differences Versus Percent Sales; Modified
Model Type Label Minus Current Label Value

CARS-HIGHWAY
Percent Differences in
Sales Fuel Economy
£ 0.21 . “30 Xx
0.30 -2 x
14.50 -1 XXXXXKX
67.00 0 XXXXXXXXXXXXXXXXXKXXXXXXXXXXXXXXKK
17.20 +1 XXXXXXXKXK
0.79 +20=-X
100.00
TRUCKS-HIGHWAY
2.01 3) Xx
1.04 2 Xx
14.06 -1 — XXXXXXX
82.89 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXK

100.00


Appendix D

Individual Manufacturers' Fuel Economy Differences
for Each Level of Labeling Detail

Table Nos. Title

D-1 Affect of Modified Label Program on the
American Motors’ Product Line

D-2 Affect of Modified Label Program on the
Chrysler Product Line

D-3 Affect of Modified Label Program on the
Ford Product Line

D-4 Affect of Modified Label Program on the
General Motors Product Line

D-5 Affect of Modified Label Program on the
Fiat Product Line

D-6 Affect of Modified Label Program on the
Nissan Product Line

D-7 Affect of Modified Label Program on the
Toyo Kogyo Product Line

D-8 Affect of Modified Label Program on the
Toyota Product line

D-9 Affect of Modified Label Program on the
Volkswagon Product Line


The model type values for the classification containing the Cardinal car

line would be:

Fuel Economy Label Values
Car line Axle Sales City Highway City Highway Index
Cardinal 2.73 12,000 15.5866 19.5877 16 20 1c
Cardinal 3.08 17,000 15.3076 18.2195 15 18 1D and 2A
Cardinal 3.36 6,000 14.2982 16.7057 14 17 2c

3. Modified Model Type + Axle + ETW- Since the Swift and Blue-
bird carelines contain only one ETW within each combination of model type
and axle ratio, further differentiation by ETW will not change their label
values. The number of labels for the model type classification containing
the Cardinal car line would, however, increase by one when separating on the
basis of axle and ETW. That is, for indexes 1D and 2A both subconfigurations
have the same axle but differenct ETW's. Therefore, instead of combining
these data, as was done at the axle level of detail, each fuel economy value

will now represent a specific fuel economy label.

4. Modified Model Type + Axle + ETW + RLHP: From the example
data in Table VI the number of labels will not increase when adding RLHP
since no combination of modified model type + axle + ETW has more than one

RLHP. This 1s due only to our selection of subconfiguration descriptions.

5. Modified Model type + Subconfiguration. (A unique label for
each subconfiguration within a carline): Our example labels would not

change for the same reasons as cited in 4 above.


-21-

B. Description of Calculation Procedure and Equations

With the calculation procedure described in this report each
vehicle subconfiguration described in a manufacturer's product line will
have fuel economy data; either actual data or data derived by adjusting the
actual data for differences between tested and untested vehicle subconfigura-

‘tions within the same basic engine and transmission class. Although we
were able to derive adjustment equations for axle ratio, RLHP, and ETW; we
were not able to derive equations to adjust for differences between engine
codes nor between transmissions configurations. Therefore, when there
exists an untested engine code and transmission configuration combination
within subconfigurations, the actual test data with the same basic engine
and transmission class combination will be adjusted for any differences in
axle ratio, RLHP, and ETW between the tested and untested subconfiguration.
The results are then harmonically averaged together.” This average value

will then become the adjusted fuel economy value for that untested engine

code and transmission configuration combination.

The simplest case 1s to adjust an untested subconfiguration that
has the same engine code and transmission configuration as does a subconfigu-
ration with actual test data. (See example 1 below.) If there exists two
or more subconfigurations with test data having the same engine code and
transmission configuration as the untested subconfiguration, each of these
tested subconfiguration will be adjusted to the untested subconfiguration
and the resultant adjusted data would be harmonically averaged (see example
2 below). If the untested subconfiguration also has an untested engine
code and transmission configuration combination, each tested subconfigu-
ration having the same basic engine and transmission class will be adjusted,

and the sales weighted harmonic average would then represent the untested

subconfiguration (see example 3 below).


-27-

STEP 2: Combine correction factors

city

FE = FEL, + dFE + dFE + dFE.
1D from 2B 2B axle RLHP ; ETW

14.7 + 0.0 + 0.0470 + 0.5882

15.3352 mpg

STEP 3: Correct for differences between 2D and 1D

Tested Index 2D: Axle = 3.36 RLHP = 10.9 Test Wt. = 4250 FE = 14.0
Untested Index 1D: Axle = 3.08 RLHP = 10.4 Test Wt. = 3500 FE =?

a. Correct for differences in Axle:

aX = -0.28 $ = -0.247 + 0.756(10-2)

_ = -0.3821

E = 3.22

FEop = 14.0

GFE, ye 7 14-0 2(-0.3821) (-0.28) = 0.4731 mpg

2(3.22) - (-0.3821)(-0. 28)

b. Correct for differences in RLHP

dX = -0.5 $ = -0.247 + 0.756(107) X

¥ = 10.65

FE = 14.0

aFEpryp = 14-0 2(-0.1665) (-0.5) = 0.1099 mpg

2010.65) — (-0.1665) (-0.5)


-23-

S = sensitivity factor, where:

For Axle,
City
s
Axle
City
s
Axle
Hwy
s
Axle
Hwy
s

1.025 - 0.437(AR) (without overdrive)

1.028

0.376(AR) (with overdrive)

0.578 - 0.380(AR) (without overdrive)

0.580
Axle. -

0.327(AR) (with overdrive)

For Equivalent Test Weight,

City

S = -0.657 + 9.542(10->)W + 3.512(107)°yH?
ETW

Hwy . -4.— . _
S | = -0.626 + 1.024(10 *)W + 8.174(10 1°)?
ETW

For Road-Load Horsepower,

City -2
s = -0.247 + 0.756(10 “)RLHP
RLHP

Hwy -2.——
s = -0.483 + 1.325(10 “)RLHP
RLHP

C. Actual Calculations
1. In the example data in Table I, engine code 2 with transmission
configuration b has one subconfiguration tested (ref. index 1B) and one

subconfiguration untested (ref. index 1C). To calculate the adjusted city

fuel economy value, the following procedure is used:

Example 1+ Adjust city data from tested subconfiguration 1B to

determine fuel economy of untested subconfiguration IC.

Tested index 1B: Axle = 2.43, RLHP = 8.9, ETW = 3375, FED = 16.6

Untested index 1C- Axle = 2.73, RLHP = 10.4, ETW = 3625, FEady =?


-36-

Table VII page 38 depicts the label values that would be assigned
under each of the alternatives discussed above. The data that make up this
table was derived from the example data of Table VI. The normal complexities
of a product line were not shown in order that the calculation procedure
could be emphasized. We have, however, taken the 1981 product line for
nine manufacturers (American Motors, Chyrsler, Ford, General Motors, Fiat,
Nissan, Toyo Kogyo, Toyota, and Volkswagon) and performed the subject
calculations. An analysis of that data 1s presented in section III of this

report.


-18-

FRI II IIA RIAA AIR II IKKE IIR IKKE IB IIIA AIRRIA KIRK IBRIIAIAAERIK IIIA AER RIA IR,

Table IV ~
*
Base Level Fuel Economy
City Highway
A = 16.6 22.2
B = 14.2184 16.6687

*ref. Table III
Note: Data depicted to one decimal place are from actual tests.

Data depicted to four places represent averaged data.

eo OO OO OO OF
ee ee

IER II KIA IIR IIH IR III IIR KIKI AKIRA IERIE SIRI IERAE SIAL ESI IR EIB IIHE RR

c. Model Type Fuel Economy: When only one base level
exists within a model type, the base level fuel economy, rounded to the
nearest whole mpg, is the model type fuel economy. In the example product
line of Table I, two model types exist with only one base level; model type
A (ref Table Il) with the Swift car line and, model type C with the Blue-
bird car line. Model type B, with the Cardinal car line, contains two base
levels. In order to determine model type B's fuel economy, divide the model
type sales fraction of each base level within the model type by the fuel

economy of the base level. That 1s;

Within Model type B base level I sales = 26,000 and

base level II sales = 9,000. Total model type B sales = 35,000.

26,000 _

35,000 ~ 0.7429

Model B's sales fraction of Base level I =

9,000

35,000 0.2571

Model B's sales fraction, base level II =


Appendix F

Individual Model Types' Fuel Economy Differences
- at Each Level of Labeling Detail
The following pages contain the actual 1981 model types for the manufac-

turers studied in this analysis. Each manufacturer 1s grouped separately.
Within a manufacturer, each basic engine 1s sorted separately, cars first,
followed by trucks. Within each basic engine, the different model types
are shown within their current label values (city/highway). In the row
beside each model type are the five different levels of labeling in increasing
order of detail. The columns contain the city and highway difference
between the current label values and the level of labeling detail of that
column. The difference is equal to the proposal minus the current value.
The percent of sales breakdown for that model type at each level of 1s also
given. The last column also contains a code (*T) to indicate which subcon-
figuration(s) was actually tested to generate the label values for that

vehicle using the current model types calculation method.

***Because this appendix 1s a large volume, 1t may be obtained only
through the Public Docket (No A-80-32) in Washington, DC.


Table C-8 Foreign

Fuel Economy Differences Versus Percent Sales; Modified Model Type +
Subconfiguration Label Minus Current Label Value

CARS-HIGHWAY
Percent Differences in
Sales Fuel Economy
*2°Q,01 © “5 Xx
- 0.01 a ae
1.02 3 =O
2.69 2 Xx
11.90 -1 XXXXXX
60.77 QO  XXXXXXXXXXXXXXXXXXXXXXXKXXXXXKK
18.60 +1 XXXXXXXXK
“4.73 +20 XK
0.27 3 x
100.00
TRUCKS-HIGHWAY
0.18 -10 xX
0.06 -8 x
2.01 -3 x
1.04 x
5.63 -1 XXX
86 18 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXKXXXKXKXK
4.90 +1 xX

100.00


aouaece

Vteoetors

DRABING PAPER WO.

TRACING PAPER

Vraretors

SECTIONS TOKIO TO tmen
lorm Heavy

caoss
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Lime acetto,

Level of Detail

L T
r
4 = + 1 mpg City alba
a ss
ib 41
iT
— fi {
— ij
Sot i
i
=+
A =+ 1 mpg Highway at
mp re
£ J cr
o a
a one a
Lal b o
° 3
“ =
FP)
3 hts A = 0 mpg City t 2
A vt
x H tt
o Ei
© is)
‘2 vi ef
by L
: : EEG HTTH &-
= ra
®
3 i 3
on y a9
> or
ca wy
5 i
i ron
<q 81
3 4 = 0 mpg Highway +7 7 €i
oO ce
2 oh
ue a
° y, 2}
“ Z
2 Number of Labels & oI
g cn
2 CUS a}
i
ta
i I |
y
o
ay 101 *
Domestic Trucks
fo u Leper titi tig
TyTr yyy rt
Level of Labeling Detail
it |
T
4 _t i n t 1
Current Model Proposed Proposed Proposed Proposed Proposed
Type (MT) MT MT + Axle MT + Axle MT + Axle MT + Subcon-
+ ETW + ETW + RLHP figuration
Table No. B-2 Relationship of the Number of Labels Required
for Each Level of Label Detail with Sales Percent Within Each


TABLE I page 10

Example Data

1 Transmission Equivalent ‘ Measured

Basic 2 Inertia Engine Axle Road Load Test ‘ Fuel Economy 4
Car Line Engine Class Config Weight Code Ratio Horsepower Weight Sales City Highway Index
Swift 300-2V M4 M4 a 3500 1 2.73 9.8 3500 12;000 ik eek 1A
Swift 300-2V M4 M4 b 3500 2 2.43 8.9 3375 3;000 16.6 22.2 1B
Cardinal 300-2V M4 M4 b 3500 2 2.73 10.4 3625 12,000 wie wick ic
Cardinal 300-2V M4 M4 c 3500 3 3.08 10.4 3500 14,000 wiek Weick 1D
Cardinal 300-2V M4 M4 a 4000 1 3.08 9.5 3875 3,000 wiek eiek 2A
Bluebird 300-29 MG MG oc 4000 3 3.08 10.6 4000 10,000 14.7 17.5 28
Cardinal 300-2V M4 M4 c 4000 3 3.36 10.4 4000 6,000 Weick tick 2c
Bluebird 300-2V M4 M4 c 4000 3 3.36 109

4250 15 ;,000 14.0 16.3 2D

, **kk Untested

Note: Each term in the heading is defined either in Section II of the text or below.

1 300 - 2V = 300 CID with a 3.a. The base level is made up of the 4 The ‘index references will be
2 venturi carburetor. transmission class not configu- used in the text of this
ration. The vehicle configuration report as a short hand method
and vehicle subconfiguration include of identifying a specific
2 > Manual and Automatic transmission configurations. vehicle description.
Transmissions would
be in different classes. 3.b. Codes a, b, and c represent the
final transmission gear ratio:
a= 1.00
b= 1.05

ce = 1.10


-33-

D. Model Type Label Determinations; Values and Level of Detail
Within Product Line

Now that each subconfiguration is represented by a fuel economy
value, either by actual test data or by adjusted data, label values can be
determined. More data are now available but, the fundamental process
of combining the data remains the same. However, there is no longer a need
to calculate configuration and base level averages. Instead, we will
directly average (according to sales) from the vehicle's subconfiguration
fuel economy. This analysis presents five levels of detail within a
product line by which labels could be determined, all making use of the
same fuel economy values (i.e., test data or adjusted data for all

subconfigurations). They are:

Alternatives Reference Code
1. Modified Model Type Labels A
2. Modified Model Type + Axle B
3. Modified Model Type + Axle + ETW c
4, Modified Model Type + Axle + ETW + RLHP D
5. Modified Model Type + Subconfiguration E

Using the data from Table VI, the procedure to calculate fuel

economy label values directly from subconfiguration is as follows:

1. Modified Model Type Labels: This level of detail 1s the same
as the current labeling program. However, there 1s one significant difference;
each subconfiguration will now be represented by data. Using the model
type classification containing the Swift car line of Table VI, a model type

value would be:


Table Nos.

C-1 and C-2

“C43 and-C-4

C-5

c-8

Appendix C

Foreign Manufacturers

Fiat, Nissan, Toyo Kogyo, Toyota, Volkswagon

Title

Relationship of the Number of Labels Required for Each
Level of Label Detail with Sales Percent Differences
within Each bevel-of-Labeling,--City-and Hrghway Label ~~
Differences.

“Sales Percentages for Absolute Label Differences versus

Percent Sales, City and Highway Label Differences.
Fuel Economy Differences versus Percent Sales;
Modified Model Type Label value - Current Label Value;
City

Modified Model Type Label Value -,Current Label Value;
Highway

Modified Model Type + Subconfiguration Label Values -
Current Label Value, City

Modified Model Type + Subconfiguration Label Values -
Current Label Value; Highway


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{
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oH = 0 ape Caty.2 : i
av 1
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z= i]
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|
T it
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|
|
iG
tf i
Foreign Trucks
Petit pypriy gy |
Coo i
Level of Labeling Detail
| 1
t t 1.
SSE [a ae oo ram CL f
Current Model Proposed Proposed Proposed Proposed Proposed
Type (MT) MT MT + Axle MT + Axle MT + Axle MT + Subc:
+ ETW + ETW + RLHP figuratio
TOTTTTTTTT TT TTT eee EEE EEE PaaS
H
Table No. C-2 Relationship of the Number of Labels Required i

for Each Level of Label Detail with Sales Percent Within Each
Tevel of Detail


Table C-3

Foreign, Cars

Absolute Label Differences Versus Percent Sales

I. City
Label Ampg % Sales
A 0 93
1 7

89
ll

81
18

Il.

Highway
Label Ampg % Sales
rN 0 67
1 32
2 1
>3 0

c 0 64
1 34

2 1

>3 1

0

1

2 7
23

E 0 61
1 31

2 7

>3 1

0 means fraction < 0.5

E 0 81
1 18
2 1
A = Modified Model Type Label
B = Modified Model Type + Axle Label
© = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label


-30-

STEP 4: Harmonic average those adjusted values with the same combination
of engine code and transmission configuration in this example 2B and 2D

with engine code 3 and transmission configuration c.

TE. = 2 = 15.9390 mpg

1 + L
15.9249 15.9531

STEP 5. Calculate the sales weighted harmonic average of the tested
engine codes in the same basic engine, transmission class, as the untested

subconfiguration.

a. Sum the sales for each tested engine code and transmission class
combination.

1. For tested engine code 2 and transmission configuration b
(tested in subconfiguration 1B)

Subconfiguration with engine code 2

and Transmission Configuration b Sales
1B 3,000
1c 12,000
Total, _, 15,000

2. For tested combination of engine code 3 and transmission

configuration c (tested by subconfiguration 2B and 2D).

Subconfiguration Sales
1D 14,000
2B * 10,000
2c 6,000
2D * 15,000
Total, _. 45,000

b. Sum all sales of tested engine codes and transmission cofigurations:

Total. ested = Total, _. + Total,

15,000 + 45,000

60,000

* Tested subconfiguration


Table D-4 General Motors
CARS
Ain mpg +
from original
label A Cc D
City Highway City Highway City Highway ;City Highway City Highway
-l 14.9 19.3 15.1 12.5 17.1 16.3 ‘ATA, 19.5 17.2 19.6
0 76.2 57.3 75.9 58.5 71.5 58.4 66.5 - 57.7- 66.4 57.7
+1 3.0 17.1 3.5 18.7 4.0 15.0 9.1 10.6- 9.1 10.6
‘ y
TRUCKS , >
-1 17.6 21.0 18.0 15.2 29.9 18.6 33.6 21.5' 32.6 21.0
0 81.7 72 3 80.5 67.4 64.9 53.2 58.9 28.0 59.7 48.4
+1 07 13 0.8 5.8 4.7 16 1 6.8 18.8! 6.8 18.8
Note: 0 means fraction <0.01 A = Modified Model Type Label -
-- means no sales in that category B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label;
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label


B. Types of Fuel Economy Labels

The EPA is responsible for specifying, by rule, the form and
content of the fuel economy labels and the manner in which they are affixed.
The Energy Policy and Conservation Act? requires that manufacturers have
fuel economy labels installed on each car and light truck it produces for
sale in the United States. Dealers are required to keep that label on the ©
vehicle until it is delivered to the consumer. Each label must include the
following information: (1) the EPA estimated fuel economy of the automobile,
(2) the estimated annual fuel cost associated with the operation of the
automobile, (3) the range of fuel economy of comparable automobiles and, if
applicable, (4) a Gas Guzzler Tax statement. All of the above information 1s

to be determined according to rules prescribed by the Administrator.

The single fuel economy value that is depicted on the current
label is called the "estimated mpg." The value is determined by combining
numerous city test values as described, in more detail, in section III of
this report. There are currently two types of fuel economy labels that
manufacturers may have approved. These are the general label and the

specific label.

1. General Label/Model Type Label: The general label displays a
fuel economy estimate for a model type. The term model type, covers many unique
vehicles which are similar in body style, engine, and transmission. These vehicles
can be different in other ways that affect fuel economy thus the name "general"

label. For example, differences such as weight, axle ratio, etc., will be found

5. Public Law 94-163, 89 Stat. 871, December 22, 1975


The first part of the driving cycle is commonly referred to
as the "cold start test" as the vehicle has not been operated for a minimum
of 12 hours. The first part of the second cycle is known as the “hot start

test" as the engine has only been shut off for a maximum of 10 minutes.

2. Highway Cycle: The highway cycle consists of one test
cycle of 10.2 miles with no intermediate stop or starts. The maximum speed
during this cycle is 60 mph with an average speed of 49 mph. When possible,
the highway cycle is conducted within three hours of the urban cycle. If it
is not possible to conduct the highway procedure within three hours of the
urban cycle, the vehicle is preconditioned by operating the vehicle over one

cycle (7.5 miles) of the urban test procedure.

3. Data Obtained’ During each driving cycle the level of
exhaust emissions are determined for hydrocarbons (HC), carbon monoxide
(CO), carbon dioxide (co,), and oxides of nitrogen (No). From these
raw data, exhaust emission levels can be expressed in grams of pollutant per
mile and the fuel economy in gallons of fuel per mile. The weight of
pollutants and volume of fuel are determined from the chemical composition
of the exhaust gases using a carbon balance chemical equation. The distance

1s obtained from the driving schedule.

4. Standards: Each fuel economy test comprises of data
from both the urban and highway cycles The urban cycle is the same cycle
used to determine compliance with the exhaust emission standards. In order
for any fuel economy data to be accepted, the emission levels measured on
the urban cycle must not exceed the applicable emission standards. There are

no emission standards for the highway cycle.


-19-

Therefore, model type B's city fuel economy is:

1 = 15,9146 mpg
0.7429 + 0.2571
“16.6 14.2184

(Similarly the highway value = 20.4549 mpg)

HAHA IR IKI IK ITAA RIK IIA IAI IASI IIA ISAIAH AISA IRE SII IBERIA IIA IIA,

*

*

* Table V

*

* . General Label Fuel Economy

*

*

* Model type! Fuel Economy

*

* city? Highway?

*

* A 17 22

*

* B 16 20

*

* Cc 14 17

*

*

* 1. ref. Table IL

*

* 2. The city value is the only one displayed on the vehicle labels
*

* and is called the "estimated mpg."

*

* 3. The highway value is not displayed on the vehicle label, but
*

* since this value is used in other EPA calculations for CAFE
*

* requirements it is available and manufacturers frequently advertise
*

* this value in addition to the city value.

*

tok “ke oe ee

Thus, each Swift would have a fuel economy label depicting

an estimated mpg of 17; each Cardinal = 16, and each Bluebird = 14.

label values are rounded to whole numbers.)

tek ekk

OO OF OO OO OO OO OO OO HOO

*

ek


1. Model Type: EPCA established the term "model type" as
the classification of vehicles for the purpose of averaging for CAFE
values. EPA defined model type on the basis of vehicle characteristics
readily recognized by consumers and important from a fuel economy perspective

(e.g., the general name of the vehicle, engine, and transmission).

Definition: a model type is defined as a unique combination of

car line, basic engine, and transmission class. (See Table 1)

A gar line denotes a group of vehicles within a make or car
division which are similar in construction (such as Chevrolet Camaro). The
level of decor or opulence 1s not considered when establishing a car line.
Features such as roof line, number of doors, seats or windows, generally do
distinguish characteristics of a car line. Station wagons, however,
are considered distinct car lines from sedans. The basic engine classification
includes the number of engine cylinders, engine displacement, and the fuel
system. The transmission class is determined by whether it 1s a manual,

automatic, or semi-automatic, along with the number of forward gears (such

as three speed or four speed).

Table 1 (next page) contains a simplified description of a
ficticious manufacturer's product line which will be used in sample cal-
culation making use of the basic definitions. Each line in the table
represents a vehicle that could be purchased from a dealer. In this
example the basic engine and transmission class are the same for the entire
product line. The model types in this product line are represented in

Table IL.


Table D-6 Nissan
CARS
Ain mpg *
from original : ‘
label A Cc - D
City Highway City Highway City Highway City Highway City Highway
-1 2.7 28.4 2.7 28 4 6.3 30.2 8.2 17.4 4.6 17.4
0 97.3 70.0 96 1 68.8 87.6 67.0 68.0 58.4 70.6 57.4
+1 -- 1.7 12.0 1.7 6.1 1.7 21.5 15.5 22.5 16.5
TRUCKS
-1 — 13.6 -- -- 16.1 16.1 i 16 1" 16.1, 16.1 16.1
0 100.0 86.4 99.3 99.3 82.3 74.0 82.3 74.0 82.3 74.0
+1 - - -- -- 0.9 9.1 0.9 9.1 0.9 9.1
Note: 0 means fraction <0.01 A = Modified Model Type Label '
-- means no sales in that category B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration. Label


Table D-9 Volkswagon
CARS
Ain mpg
from original
label A Cc
City Highway City Highway City Highway City Highway City Highway
-1 -- 8.1 - 8.1 1.5 8.6 1.5 8.6 2.9 5.3
0 87.5 79.2 87.5 79.2 86.1 79.3 86.1 79.3 81.3 74.8
+1 12.5 11.9 12.5 11.9 12.4 11.3 12.4 11.3 15.8 17.7
TRUCKS
-1 -- -- -- - 2.4 0.3 2.4 0.3 2.4 0.3
0 100.0 100.0 100.0 100.0 97.6 87.9 97.9 87.9 97.6 87.9
+1 -- -- -- -- -- 11.8 -- 11.8 -- 11.8
Note 0 means fraction <0.01 A = Modified Model Type Label
~- means no sales in that category B = Modified Model Type + Axle Label
€ = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label


-25-

STEP 2: Combine correction factors

FE

FED + dFE + dFE HP + dFE.

Axle RL EIW
16.6 + ( -0.1966) + (-0.4431) + (-0.3737)

‘Adj

15.5866 mpg

2. In the example data in Table I, engine code 3 has two tested
subconfigurations (ref: index 2B and 2D) and two untested subconfiguration
(ref. index 1D and 2C). To calculate the adjusted city fuel economy

value, the following procedure 1s used’

The first step 1s to adjust the data from the tested
subconfigurations for any differences between them and the untested
subconfigurations in axle ratio, road-load horsepower (RLHP), and equivalent
test weights (ETW). (The actual order is not important.) Since there is
more than one tested subconfiguration with the same engine code, the

adjusted data will be harmonically averaged.

Example 2: Calculate the city fuel economy for subconfiguration 1D*.

Untested vehicle 1D has an engine code of 3 and a transmission

configuration c. Since there are two tested subconfigurations with the

same engine code and transmission configuration, 2B and 2D, each one is to
be adjusted for any differences in axle, ETW, or RLHP that exists between
it and vehicle 1D. (Note that 2B and 2D are not in the same base level as
1D, but can still be used to derive data for 1D since they are in the same
basic engine and transmission class as 1D.) The data will be harmonically
averaged and the results will be used to represent 1D. The calculation

procedures are as follows:

*This identification can be found under the column headed "Index" in Table 1.


EPA~AA-CPSB-81-02

A Comparison of Current and Proposed Vehicle Labeling Programs
by
Clifford D. Tyree

January 1981

Notice

This 1s a Technical support report for regulatory action and it does not
necessarily represent the final EPA decision on regulatory issues. They are
intended to present a technical analysis of issues and recommendations
resulting from the assumptions and constraints of that analysis. Agency
policy constraints or data received subsequent to the date of release of
this report may alter the recommendations reached. Readers are cautioned to
seek the latest analysis from EPA before using the information contained
herein. -

Technical Support Section
Certification Policy and Support Branch
Office of Mobile Source Air Pollution Control
U.S. Environmental Protection Agency


Appendix E

Table Nos. Title

E-1 Number of Labels Required versus Level of Labeling
Detail for Each Manufacturer


Table A-3 Domestic and Foreign, Cars

Absolute Label Differences versus Percent Sales

I. City Tl. Highway
Label Ampg % Sales Label Amne % Sales
A 0 75 A 0 57
1 22 1 34
2 3 2 4

B 0 75 B 0 58
1 22 1 31

2 3 2 6

3 5

c 0 72 ¢ 0 55
1 23 1 34

2 5 2 5

23 0 23 6

D 0 67 D ) 52

1 27 1 34

2 5 2 8

3 1 33 6

E ie) 67 E 0 52
1 27 1 35
2 5 2 8
>3 1 >3 5
A = Modified Model Type Label 0 means fraction < 0.5
B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label

E = Modified Model Type + Subconfiguration Label


-12-

An excerpt of the table depiciting the relationship between

loaded vehicle weight, equivalent test weight and inertia weight is shown

below:

Loaded Vehicle’ Equivalent® Inertia Weight
Weight-Pounds Weight-Pounds Class-pounds

* * *

* * *
3,313 to 3,437 3,375 3,500
3,438 to 3,562 3,500 3,500
3,563 to 3,687 3,625 3,500

* * *

* * *

The complete relationship is found in 40 CFR 86.129-80.

Referring then to the example data in Table I, the product
line is made up of two base level. That is, since each vehicle has the
same basic engine (300-2V) and the same transmission class (M4), the differences
an their inertia weights determine base levels. Since there are only two different
inertia weights listed in this product line there can be only two base

levels.

7. Means the vehicle curb weight plus 300 pounds to simulate a driver and
passenger.

8. Means the weight within an inertia weight class which is used for the
dynamometer testing of a vehicle. (Since dynamometers are not infinitely
variable incremental settings have to be specified.)


-ll-

KIKI AIH IIHR ISA IIR IIHR IK IIR IR IIR RIKER IASI IIR ISI PARA IARI IREIAEER ER

* *
* Table II *
* *
* Model Types for Example Data *
* Index* *
* for Model Types Car Line Basic Engine Transmission Class *
* *
* A Swift 300-2V M4 *
* *
weer B Cardinal 300-2V M-4 *
* *
* c Bluebird 300-2V M-4 *
* *
* ‘ - *
* o* . :

An index will be supplied so that when referencing a specific item *
* in a table in this report the line of information can be identified. *
* *

FRR I KAR IR RISK IIIA IK IKE ERE IAHR RBA ISI EIRP IKI EBB RIK EPRI RR.

The present labeling program would combine the data such that
each vehicle within a model type will have a fuel economy label with
the same fuel economy value even though there are different axle ratios,

engine codes, etc.

2. Base Level: Another major level of description is the
base level. The purpose of the base level is to segment a manufacturer's
product line based on those major design differences affecting fuel economy

in order to specify testing requirements and calculate model type values.

Definition’ a base level 1s a unique combination of basic

engine, inertia weight class and transmission class.

The terms basic engine and transmission class have been
previously defined. An inertia weight class means the class, which is a
group of test weights, into which a vehicle 1s grouped based on its loaded

vehicle weight in accordance with the provisions of 40 CFR Part 86.


43
i it
T
' A = £1 mpg City
Ki Vi
Li
=
=
= r
ae 4 . VA f a o
He A = £1 mpg Highway [Kaif tort
Pe oo E 2
> (Fo cl
» 3 HA a
soe wu bond
7 ° 3
2.38 9 =
< $
, a3 D in | mas Fs
£ t rr g
3 Poy 5
a A = 0 mpg City i °
=
5 7 ia S 2
“ fe
3 om
bat 3)
3 <
c {et £
FT ov
> 2 2
> re)
< 0 tot
= 2 = a
= Lt 7 ls 4
> Eo _ 7 €
2 ‘eT A = 0 mpg Highway e
o- f° ie
eis FEE z
were cr 8 ®
Hi ot 3
sere fF 2 Number of Labels a
eeone T
zac
aon” 11D: 31
cece
fear
eros
7)
{ f Domestic Cars
peppy
Perera yt
Level of Labeling Detail
era
pT yi im
corr
7 “ot a . +
Current Model Proposed Proposed Proposed Proposed Proposed
Type (MT) MT MT + Axle MT + Axle MT + Axle MT + Subcon-
+ ETW + ETW + RLHP figuration
FA
Table No. B-1 Relationship of the Number of Labels Required
for Each Level of Label Detail with Sales Percent Within Each

Level of Detazl


~4h~

Appendixes D depicits the number of vehicles (percent of sales) which would
have their label values change by +l, 0, and -1l mpg for each level of
labeling detail. (The percent of sales does not equal 100 percent as their
are levels which would change by more than 1 mpg.) In reviewing the effect
of increasing the level of labeling detail for all car manufacturers and
then for all truck manufacturers it is apparent that there is an overall
improvement in the labeling accuracy for trucks for each of the first three
alternatives. For cars, the improvement in accuracy is not as significant
as the level of labeling detail is increased. However, in evaluating the
impact of these labeling alternatives for individual manufacturers, it is
apparent that each manufacturer 1s affected differently. One manufacturer
(American Motors) would have the largest percentage of vehicles relabeled
with a higher city value. Ford, Chrysler, Nissan, and Toyota would have a
significant number of vehicles which would have label values decreased by 1
mpg. The foreign trucks would be the least effected by any of these
labeling alternatives with very few changes 1n label fuel economy values or

the number of different labels required.


Table D-7 Toyo Kogyo
CARS
A in mpg
from original
label A Cc
City Highway City Highway City Highway City Highway City Highway
-1 -- 9.9 _ 9.9 1.8 19.6 1.8 15.4 1.8 15.4
0 100.0 90.1 100.0 90.1 98.2 80.4 98.2 84.6 98.2 84.6
+] -- -- -- -— -- -- -- -- -- --
TRUCKS
-1 -- 7.5 -- 7. - 5.0 “_ 5.0, 0.2 2.4
a 100.0 92.5 100.0 92.5 100.0 95.0 100.0 95.0 98.9 97.6
+1 -- -- -- -- -- -- -- -- 0.9 --
Note: 0 means fraction <0.01 A = Modified Model Type Label
-- means no sales in that category B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label


TABLE VI page 32

Example Data

1 Transmission Equivalent Tested and Adjusted
Basic 2 Inertia Engine Axle Road Load Test Fuel Economy 4
Car Line Engine Class Config. Weight Code Ratio Horsepower Weight Sales City Highway Index
Swift 300-2V MG M4 a 3500 1 2.73 9.8 3500 12,000 15.9365 19.8127 1A
Swift 300-2V M4 M4 b 3500 2 2 43 8.9 3375 3,000 16.6 22.2 1B?
Cardinal 300-2V M4 M4 b 3500 2 2.73 10.4 3625 12,000 15.5866 19.5877 IC
Cardinal 300-2V M4 M4 c 3500 3 3.08 10.4 3500 14,000 15.3518 18.1827 ID
Cardinal 300-2V M4 M4 a 4000 1 3.08 9.5 3875 3,000 15.1045 18.3934 2A
Bluebird 300-2V M4 M4 c 4000 3 3.08 10.6 4000 10,000 14.7 17.5 28°
Cardinal 300-2V M4 M4 c 4000 3 3.36 10.4 4000 6,000 14.2982 16.7057 2¢
Bluebird 300-2V M4 M4 c 4000 3 3.36 10.9 4250 15,000 14.0 16.3 20°
Note* Each term in the heading 1s defined either in Section II of the text or below.
1. 300 - 2V = 300 CID with a 3 a. The base level is made up of the 4, The index references will be
2 venturi carburetor. transmission class not configura- used in the text of this
tion. The vehicle configuration report as a short hand méthod
and vehicle subconfiguration include of identifying a specific
2. Transmissions with and transmission configurations. vehicle description.
without overdrive would
be in different classes ' 3.b. Code a, b, and c represent the 5. Tested subconfigurations
as would automatic and final transmission gear ratio:
manual. a= 1.00
b= 1 05

e¢ = 1.10


Table A-4 Domestic and Foreign, Trucks

Absolute Label Differences versus Percent Sales

I. City
Label Ampg % Sales
A 0 80
1 19
2 1
3 0

Siteenameceseeseesessessesssessesss

B 0 79
1 19

2 2

23 0

Seoeeseses=

c 0 68
1 29

2 2

23 1

D 0 67

1 31

2 2

3 0

saeeseescesesseeseces=:

E 0 68
1 30
2 2
>3 0
4 = Modified Model Type Label

B = Modified Model Type + Axle Label

C = Modified Model Type + Axle + ETW Label

II. Highway
Label Ampg % Sales
A 0 62
1 32
2 3
>3 3

Smeeseseesesesese

eaeescesss=s

0 means fraction < 0.5

D = Modified Model Type + Axle + ETW + RLHP Label

E = Modified Model Type + Subconfiguration Label


-31l-

ce. Calculate the sales weighted harmonic average.

FE = 1 = 1

Sales comb) * = 1 Sales). ¥ 1 . Sales,_. 1
Total Sales comb. Total Sale 2-b Total Sales FEs_.

; Loses
sano) C SST )+ (aan) (s5-3350)
= 15.9365 mpg

The resultant city fuel economy value for the untested combination
of engine code 1 and transmission configuration (a) with the subconfiguration

parameters described by index 1A is 15.9365.

D. Completed Calculation of Fuel Economy Values

Using the procedure outlined in the two preceeding examples,
values for the remaining city and all the highway values are calculated and

shown in the following completed table, Table VI.


Table B-8 Domestic

Fuel Economy Differences Versus Percent Sales; Modified Model Type +
Subconfiguration Label Minus Current Label Value

CARS-HIGHWAY

Percent Differences in
Sales Fuel Economy
0.01 -6 x
0.06 5 =X
2.47 4 xX
3.67 3 xX
3.65 “2. XX
22.06 -1 XXXXXXXXXXX
49.58 QO XXXXXXXXXXXXXXXXXXXXXXKXX
13.80 +1 XXXXXXX
3.90 +20 XX
0.80 +30O«X
100.00

TRUCKS-HIGHWAY

0.04 7 Xx

0.03 6 xX

0.58 -5 xk

0.60 “4 XxX

2.41 3) Xx

10.32 -2 > XXXXX
19.33 1 XXXXXXXXXX
51.41 O  XXXXXXXXXXXXXXXXXXXXXKXXXXX
14.75 +1 XXXXXXX

0.52 +20 =X

0.01 23. Xx

100.00 (Max +4)


-8-

within a model type. The model type fuel economy value is calculated

from fuel economy data collected from different vehicle designs and averaged.
This calculation procedure is an average of the vehicle data, taking into
account the anticipated sales of each vehicle used to generate the data.

That 1s, it is a sales-weighted average. (The procedure for sales weighting
is described in more detail in_section III of this report.). The general
label values are determined once for each model year, and are not changed

during that model year.

2. Specific Label: A specific label contains the fuel
economy of a unique vehicle configuration. EPA only allows the use of the
specific labels early in the model year. Usually, manufacturers use
specific labels when they believe data are not available to calculate a
representative general label value. However, once the general label value
is available, it must be used; any specific label within that model type
can no longer be used. One reason for this 1s to keep manufacturers from
affixing specific labels on only the best vehicles while using the more

average general label value on the worst vehicles.

C. Terms Used in Labeling Program

Before beginning the description of the actual process, it is
helpful to understand the basic terminology EPA uses in describing and
grouping the various vehicle models and designs. EPA begins by sorting a
vehicle manufacturer's product line into (a) model types, (b) base levels,
(c) vehicle configurations, and (d) vehicle subconfigurations. Some of the

6 .
definitions used in the calculation procedures are-

6. A complete listing of definitions used in the fuel economy program can
be found 1n 40 CFR 600 002-80.


-22-

The basic adjustment equation is:

FE aaj = FE, + GFE cle + FE Loy + FELD
Where:
FE aaj = adjusted fuel economy

FE, = Tested fuel economy (i.e., actual data)
aFE A le = Change in fuel economy due to differences in axle ratios

= Change in fuel economy due to differences in ETW

~ 8a

FER rHp = Change in fuel economy due to differences in RLHP
The difference in fuel economy (dFE) is found as follows:

qFE = FE -F, = FE, 2(S) (dX)
us T 1
2(X) - s(dx)

Where’
FEL = untested fuel economy
TE, = tested fuel economy
dX = difference between untested and tested parameter, e.g., if
the tested subconfigurations had an axle ratio of 2.76 and the
untested was 2 56; dX = xX x or dX = 2.56 - 2.76 = -0.20
X = average of parameter specifications, 1.e., Axle ratio (AR),
Fquivalent Test Weight (ETW), Road Load Horsepower (RLHP); e.g. for
axle ratios of 2.76 and 2.56, K = (2.76 + 2.56)/2 = 2.66

(Note: Tested 1s always subtracted from untested parameter value.)


Table D-8 Toyota
CARS
A in mpg
from original
label c D
City Highway City Highway City Highway City Highway City Highway
-1 5 6 7.7 6.7 8.8 6.7 8.8 10.3 7.6 8.7 9.3
0 91.0 48.8 90.0 47.7 89.8 47.7 83.4 52.0 83.3 45.7
+) 3.4 40.1 3.4 40.1 3.6 40.1 6.0 23.8 7.6 28.8
TRUCKS
-1 2.2 19.5 2.2 19.5 2.2 19.5 2.2 19.5 2.2 -
0 93.5 74.0 93.5 74.0 93.5 74.0 93.5 74.0 93.5 93.5
+1 -— -- - -—- -- -_ — -- -- --
Note: 0 means fraction <0.01 A = Modified Model Type Label
-~ means no sales in that category B = Modified Model Type + Axle Label
C€ = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label


Table A-14 Domestic and Foreign
Fuel Economy Differences Versus Percent Sales: Modified Model Type +
Subconfiguration Label Minus Current Label Value

CARS-HIGHWAY
Percent Modified - Current
Sales Label Differences-mpg
0.01 “6 xX
0.05 5 Xx
2.04 4 xX
3.21 -3 XX
3.49 2 xx
20.29 -1 XXXXXXXXXX
51.52 QO  XXXXXXXXXXXXXXXXXXXXXXXXXX
14.64 +1 XXXXXXK
4.04 +20 XX
0.57 +30¢=«X
0.13 +4 OX
0.01 OX
100.00
TRUCKS-HIGHWAY
0.03 -10 Xx
0.01 “8 xX
0.04 7 Xx
0.01 “6 xX
0.49 -5 x
0 51 4 Xx
2.35 -3 Xx
8.95 -2  XXXX
17.32 -1 XXXXXXXXX
56.53 0 XXXXXXXXXXXXXXXXXXXXXXXKXKXK
13.30 +1 XXXXXXX
0.45 +2 xX
0.00 >3

100.00 (Max +4)


Table D-5 Frat
CARS -
Ain mpg
from original .
label A Cc D
City Highway City Highway City Highway City Highway City Highway
-1 25.6 — 25.6 ~_ 25.6 -_ 14.9 3.2 14.9 3.2
0 74.4 74.4 Ta & a4 74.4 74.4 81.8 81.8 81.8 81.8
+1 -- 25.6 -- 25 6 - 25.6 3.2 14.9 3.2 14.9
TRUCKS
-1 -- a -- - - -- -- i -- --
0 -- -- -- -- -- -- — -- -- --
+1 -- -- -- -- -- -- -- 0 -- --
Note: 0 means fraction <0.01 A = Modified Model Type Label
-- means no sales in that category B = Modified Model Type + Axle Label
© = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label


Table E-1 Number of Labels Required Versus Level of Labeling Detail for Each Manufacturer
Manufacturer At A B Cc D io E
Total Cars Trucks Total Cars Trucks Total Cars Trucks Total Cars Trucks Total Cars Trucks Total Cars Trucks

American Motors 62h 38 624 38 91-30 61 13543 92 13743 94 142 43 99
Chrysler 21300 «91122 237-9542 309 107-202 519 147-372 1236 310 = 926 1351376975
Ford 235 135 100 235 135 100 328 157 7 569 220 349 B49 325 524 1088 386 702
General Motors 367,225,142 369 227 142 524 271 253 798 362 «436 986 445 = S41 1036 469-567
Fiat Mm 14 0 mw 1b t) 4 14 ty 1616 0 20-20 0 20 20 0
Nissan 59. AT 12 59°47 12 6349 4 73°55 18 139121 18 225° 178 47
Toyo Kogyo 24 20 4 24 20 4 2 20 4 32 24 8 40 32 8 72 56 16
Toyota 5738 19 5738 19 5940 19 6142 19 121 102 19 281-231 50
Volkswagon Mw 22 12 3422 12 3422 12 48 32 1 4832 16, 60h 16
Total Counts 1065* 616 449 1091 622 469 1446 710-736 2251 941 ©1310 3576 1430 2146 4275 1803 2472

* Difference in the number of labels between A’ and A due to finer level of detail describing transmission, e.g., lockup and "creeper"

transmissions are separated out in A.

Ais

4 = Modified
» = Modified
3 = Modified
od * Modified
% = Modified

Model
Model
Model
Model
Model

Type
Type
Type
Type
Type

Current Model Type Label

Label

+ Axle Label

+ Axle + ETW Label

+ Axle + ETW + RLHP Label
+ Subconfiguration Label


Table B-6

Domest ic

Fuel Economy Differences Versus Percent Sales:.Modified

Percent
Sales

0.11

0.52

0.30

Model Type Label Minus Current Label Value

CARS-HIGHWAY

Differences in
Fuel Economy

+1

+2

+3

XXXXXXXXXXK

XXXXXXXXXXXXKKXXXXXXXXXXXXXK

XXXXXXXK

x

x

TRUCKS-HIGHWAY

+1

+2

xX

XXXXXXXXXXKXXXXX

XXXXXXXXXXXXXKXXKXXXXXKXXXXKK

x

x


-39-

As in the example calculations in section III, all subconfigurations
were represented by fuel economy test data or adjusted fuel economy data
prior to calculating the label values. Label values were calculated
for the five different levels of labeling detail described previously. The
manufacturer provided EPA with the total 1981 projected sales for each
subconfiguration at the time their vehicles were labeled. We used these
sales to determine the number of vehicles which would be labeled with a
different fuel economy value if the modified label program were adopted.
Label values, rounded to the whole numbers, were used to determine these

differences.

Three specific comparisons of the current to the modified labeling
system have been made. The comparisons were compiled for all nine manufac-
turers, and also split into the domestic and the foreign manufacturers.

(No attempt was made to separate foreign built vehicles with a domestic
model name or, a foreign manufacturers product line which incorporated

vehicles built in America.) The three specific comparisons made are:
1. Total number of vehicle labels required at each level of
detail.

2. Percent of sales for an absolute fuel economy difference at

various levels of detail.

3. Percent of sales for each 1 mpg fuel economy difference at

various levels of detail.

The tables describing these comparisons are in Appendix A for all

nine manufacturers, Appendix B for the domestic manufacturers, and Appendix C


Table D-1 American Motors Corporation
CARS
Ain mpg
from original
label A c D E
City Highway City Highway City tighway City + Highway City Highway
-1 10.5 0.9 1L 5 0.7 32.0 20.7 32.0 20.7 32.0 20.7
0 87.3 92 5 86.4 92.0 64.9 57.2 64.9 57.2 64.9 57.2
+1 -- 4.3 4.2 0.9 19.2 0.9 19.2 0.9 19.2
TRUCKS .
-1 3.0 32.7 11.8 2.7 11.8 6.4 11.8 . 6.4" 11.8 6.4
0 94.1 57.0 82.8 97.9 81.0 74.4 81.0 76.4 81.0 76.4
+] 22 6.8 3.8 7.2 4.2 6.2 4.2 6.2 4.2 6.2
Note: 0 means fraction <0 01 Modified Model Type Label

-- means no sales in that category

mAoNeD>

oenow ot

Modified Model Type
Modified Model Type
Modified Model Type
Modified Model Type

+ Axle Label

+ Axle + ETW Label

+ Axle +'ETW + RLHP Label
+ Subconfiguration Label


-40-

for the foreign manufacturers. Appendix D contains percent sales for each

of the manufacturers at differences in label fuel economy values and

Appendix E contains the various manufacturer's difference in the total

number of labels at each level of labeling detail.

2. Analysis of data

The

to each level

following general observations are made and are applicable

of labeling detail.

Cars:

About 30 percent of all cars would receive different
estimates of city fuel economy.

About 25 percent of all cars would have an estimate of
city fuel economy 1 mpg different from the current
label value.

About 5 percent of all cars would have an estimate
of city fuel economy 2 mpg or more from the current
label value.

From 5 to 10 percent of all cars would have a label (city)
value recalculated at a higher fuel economy value than
the present.

About 45 percent of all cars would receive different
estimates of highway fuel economy (currently calculated
but not displayed on the label).

About 35 percent of all cars would have an estimate of
highway fuel economy 1 mpg different from the value
presently calculated.

About 10 percent of all cars would have an estimate
of highway fuel economy 2 mpg or more from the
calculated highway value.

From 15 to 20 percent of all cars would have a recal-
culated highway fuel economy value higher than the
present value.

The range of city fuel economy differences for cars
1s -3 mpg to +2 mpg.


Table A-10 Domestic and Foreign

Fuel Economy Differences Versus Percent Sales; Modified
Model Typet+tAxle+ETW Label Minus Current Label Value

CARS-HIGHWAY
Percent Modified - Current
Sales Label Differences—mpg
0.01 “6 XxX
0.03 5 Xx
1.94 4 Xx
3.23 -3) xX
2.71 2X
18.76 -1 XXXXXXXXX
55.23 QO  XXXXXXXXXXXXXXXXXXXXXXXXXXXK
15.09 +1 XXXXXXXK
2.51 +20=«X
0.31 +30 =X
0.18 +h Xk
100.00
TRUCKS-HIGHWAY
0.03 -10 xX
0.01 8 Xx
0.04 -7 x
0.02 -6 x
0.50 -5 x
0 50 4 Xx
2.03 -3) x
7.99 -2 XXXX
20.76 -1  XXXXXXXXXX
55.55 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXX
2.18 +1 XXXXXX
0.38 +2 x
0 Ol >3 x

100.00 (Max +4)


-28-

ce. Correct for differences in ETW

ax = 750 S = -0.657 + 9.542(10>)W + 3.512010) °)H*
X = 3875 = -0.2820

FE = 14.0

GFE ery = 0.7855

Step 4: Combine correction factors
Feo TY = 14.0 + 0.4731 + 0.1099 + 0.7855

1D from 2D
= 15.3684 mpg.

Step 5: Average the adjusted values from 2B + 2D to get the harmonic
estimate of 1D.

City FEIp BNL 2
iL ee eee
FE FEip-28 * FEip-2p
= 2 = 15.3518 mpg
1 + 1
15.3352 15.3684

3. In the example data in Table I, the combination of engine
code 1 and transmission configuration (a) (Ref: indexes 1A and 2A) is not
represented by any data. To calculate the fuel economy for either of these

subconfigurations the following procedure is used’

Adjust each test data in the same basic engine, transmission
class as the untested subconfiguration, for differences in ETW, Axle, and
RLHP between it and the untested subconfiguration. If there 1s more than
one tested vehicle within an engine code, basic engine, and transmission
configuration combination, the adjusted data are harmonically averaged. The
adjusted subconfiguration values and any harmonic average value are then
sales weighted together based on the total projected sales of the basic

engine, engine code, and transmission configuration combinations.


Table A-13 Domestic and Foreign

Fuel Economy Differences Versus Percent Sales; Modified Model Type +
Subconfiguration Label Minus Current Label Value

CARS-CITY
Percent Modified - Current
Sales Label Differences-mpg
0.53 -3) = Xx
3.25 “2 XK
18.38 ~1l  XXXXXKXXX
66.92 O XXXXXXXXXXXXXXXXXXXXXEXXXXXXXXXXX
9.36 +10 XXXXX
1.55 +2. =X
100.00
TRUCKS-CITY
0.03 “8 =x
9.01 “5 OX
0.01 4
0.17 3 Xx
2.22 -2 x
25.03 -1 XXXXXXXXXXXXK
67.76 O XXXXXXXXXXXXXXXXXKXXXXXXXXXXXKXXXK
4.73 +1 OX
0.03 +2,=«X
0.01 43 x


Table B-7

Fuel Economy Differences Versus Perent Sales; Modified Model Type +
Subconfiguration Label Minus Current Label Value

Percent
Sales

0.65"
3.77
21.02

64.01

1.85
100.00

0.01
0.20
2.25
28.17
63.85
5.48
0.03

0.01
100.00

Domestic

CARS-CITY

Differences in

Fuel Economy
3 =X-
20 XX

~l  XXXXXXXXXXK

QO  XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

+1 XXXK

+20 =X
TRUCKS-CITY

4 xX

3) «x

2 =X

-1 XXXXXXXXXXXXXK

QO XXXXXXXXXXXXXXXXXXXXXXXXXKXXXXKK

+1 XXX
+2 x
+3 x


I. Pur. pose

The purpose of this report is to describe (1) the current labeling
program, (2) the proposed labeling program, and (3) to provide an
analysis of the differences between the two programs. The analysis will

address several options available within the proposed labeling program.

Except to briefly describe how the fuel economy data are used in the
corporate average fuel economy (CAFE) calculations and in the determination
of the Gas Guzzler Tax, this document will not address these areas of the

fuel economy program.

II. Current Labeling Program Description

The data from the present EPA fuel economy testing program are
used in three ways: (1) to generate fuel economy label values for use by
consumers, (2) to determine manufacturers’ compliance with CAFE requirements,
and (3) to generate data from which the IRS can establish manufacturers' Gas
Guzzler Tax liability. (EPA and Department Of Energy have a combined
responsibility to make available to the public in the Gas Mileage Guide (the
Guide) the fuel economy values displayed on the labels which are affixed to

each new car.)

The EPA responsibilities for the above functions are to (1)
administer the testing program that generates the fuel economy data, (2)
determine necessary procedures and verify the calculation of fuel economy
values for labels, the Guide, and CAFE and, (3) provide IRS with fuel

economy data in order for them to determine a manufacturers tax liability.


AQuAeTE

teeo-to-s

DRAWING PAPER WO

varr-roes

TRACING PAPER NO}
secTion-toxto

cross
ste

ieen

10
lorm Neavy

usa

wace

acct’ o,

Line

Level of Detail

a
ft :
|
|
A= +1 mpg City |
a : :
a
— :
7 ;
> i
U y U i
C 1
r = et 4
A= +1 mpg Highway 4 i
T
H = 4 2p
HS mI = ac
flo ct im SE
}t a vA
Phew A = 0 mpg City gt
HH ° 7 “
—_ ge
9 .
Hed , go
Ha oh
= uy
rH co
++ g Cor =
Ht ca
b+ ~ —
H & a. - a=
ies aH Se
Hs oe c=
H's oe Ae :
Hs 0 mpg Highway A an + Eoard
b+ cx 7 7 4 —
wa wat
H 3 a
H 3 re eS
a ort
ye ety
oy Z —
He an
H3 2
H 2 Number of Labels {] ait
I it r
+
i
Ps Domestic and Foreign Trucks 5
1
CREEK eet
Level of Labeling Detail q
tit 4 4
Cort
at crit T q
Current Model Proposed Proposed Proposed Proposed Proposed i
Type (MT) MT MT + Axle MT + Axle MT + Axle MT + Subcon-
+ ETW + ETW + RLHP figuration i
Table No. A-2 Relationship of the Number of Labels Required t
for Each Level of Label Detail with Sales Percent Within Each 7



Table Nos.

A-1 and A-2

A-3 and A-4

A-9

A-10

A-ll

A-12

A-13

A-14

Appendix A
Domestic and Foreign Manufacturers
Title

Relationship of the Number of Labels Required for Each
Level of Label Detail with Sales Percent Differences
within Each Level of Labeling; City and Highway Label
Differences.

Sales Percentages for Absolute Label Differences Versus
Percent Sales: City and Highway Label Differences.

Fuel Economy Differences Versus Percent Sales;

Modified Model Type Label Value - Current Label Value;
City

Modified Model Type Label Value - Current Label Value;
Highway

Modified Model Type + Axle Label Value - Current Label
Value; City

Modified Model Type + Axle Label Value - Current Label
Value; Highway

Modified Model Type + Axle + ETW Label Value - Current
Label Value; City

Modified Model Type + Axle + ETW Label Value - Current
Label Value; Highway

Modified Model Type + Axle + ETW + RLHP Label Value -
Current Label Value; City

Modified Model Type + Axle + ETW + RLHP Label Value -
Current Label Value; Highway

Modified Model Type + Subconfiguration Label Value -
Current Label Value; City

Modified Model Type + Subconfiguration Label Value -
Current Label Value; Highway


AQUAREE

Vreortoe

ORAWING PAPER KO]

TRACING PAPER

store

vaay

no

stoxto to twen
aAccT'o, 101M HEAVY

secTiON

cross

"

wave

STH LINE

A=+ 1 mpg City
wa
+ Ao i
T + 7
A= g Highway
11
7
= a s a
=
7
ry
'
A= 0 mpg City
L 7
ol =%
o
a
Q
a
ws
°
-
ov f
3 it y
a
s Vd i
3s q — vA
8 q Sane
a 4
> A= 0 mpg Highway Ane Lt
£
4 7
>
>
o
4
o
a
8
oI t
a
w
°
ov
2
t
cz Number of Labels
AN
re
=
6 Dai" =|
Foreign Cars
Pore tt i
Level of Labeling Detail
pe 1
Cee t
| n a iat 1 4 Li n 4
urrent Model Proposed Proposed Proposed Proposed Proposed
(MT) MT MT + Axle MT + Axle MT + Axle MT + Subc
+ ETW + ETW + RLHP figuratic
PELE LI AAP EP EHP T HEE PPP I TET E TT
Table No. C-1 Relationship of the Number of Labels Required co

for Each Level of Label Detail with Sales Percent Within Each
Tevel of Netes-7


~15-

not included on the label) for a vehicle configuration, then these data
(rounded to the nearest tenth mpg) represent the vehicle configuration's
fuel economy. If there had been more than one vehicle tested within a
configuration, these data would be harmonically averaged and the resultant

value would represent the vehicle configuration's fuel economy.

The term harmonically averaged, in mathematical terms, 1s:

SOS pes rit = nN
N 1
. 1 fF ux
N xX, i=] j
jel J Jj
Where N
x) 1s used to denote the sum of all x,'s from
j=l to j=N

The harmonic average of 2, 4, 8 is:

= 3.43

The harmonic average is used instead of the arithmatic
average because the average of the individual vehicle fuel economy values
does not equal the average fuel economy for the vehicles as a group. For
example

Car A first goes 100 miles and uses 10 gallons of fuel,
thus achieving 10 mpg.

Car A then goes 100 miles and uses 5 gallons of fuel, thus
achieving 20 mpg.

The average fuel economy 1s equal to total miles driven by
the total fuel consumed or:

100 + 100 _ 200 _
Toe 5) 7 15 7 13:33


Table A-12 Domestic and Foreign

Fuel Economy Differences Versus Percent Sales; Modified Model
Type + Axle + ETW + RLHP Label Minus Current Label Value

CARS-HIGHWAY

Percent Modified - Current
Sales Label Differences—mpg
0.01 -6 x
0.03 “5 Xx
2.06 4 =X
3.21 -3 XX
3.46 -2 xX
20.13 -1 XXXXXXKXXX
52.32 QO XXXXXXXXXXXXXXXXXXXXXXKXXX
13.93 +1 XXXKXXX
4.14 +20 XK
0.57 +3 x
0.13 +4 X
_0.01 5 OX
100.00

TRUCKS-HIGHWAY

0.03 “10 =X

0.01 -8 Xx

0.04 -7 Xk

0.02 -6 xX

0.50 “5 Xx

0.50 4 XxX

2.43 -3) Xx

8.76 -2 XXX
18.91 1 XXXXXXXXX
54.96 O  XXXXXXXXXXXXXXXXXXXXXXXXKXX
13.38 +1 XXXXKXX
0.45 +20~=«X

0.01 >3 Xx

100 00 (Max +4)


Table B-3 Domestic, Cars

Absolute Label Differences Versus Percent Sales

I. City
Label Ampg % Sales
A 0 71
1 25
2 4

B Oo. . 71
1 25
2 4

c 0 68
1 25
2 6
3 1

Il. tighway
Label Ampe % Sales
A 0 55
1 34
2 5
>3 6

D 0 64 D 0 50
1 29 1 35
2 6 2 8
3 1 23 7
E 0 50
1 36
2 8
>3 6
A = Modified Model Type Label
B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label

E = Modified Model Type + Subconfiguration Label


-17-

In base level II there are two configurations tested (ref.
Subconfiguration Index 2B and 2D of Table I). Since there is more than one
tested configuration, the base level fuel economy will be determined according

to the general equation:

Base level

fuel econ. = 1
‘raction of ‘raction of
total sales o 1 total sales o 1
configurations}/ Configuration configuration: Configuration | +.
teseted repre-|| No. 1 fuel tested repre- No. 2 fuel
sented by economy sented by economy ~ “
configuration configuration
No 1 sales - No. 2 sales

Within base level 2, index 2B represents vehicles of one
configuration. Indexes 2C and 2D represent vehicles of a second configuration,
but different subconfigurations within that second configuration. Each of
these configurations is represented by test data, so the total sales of

each will be used to determine the base level fuel economy.

Sales of tested configuration No. 1 (2B) = 10,000
Sales of tested configuration No. 2 (2C + 2D) = 21,000
Total Tested Configuration/Base Level Sales = 31,000

No. 1 sales fraction = 10,000 = 0.3226
31,000

No. 2 sales fraction = 21,000 = 0.6774
31,000

Configuration No. 1 fuel economy
Configuration No. 2 fuel economy

14.7 city and 17.5 highway
14.0 city and 16.3 highway

wu

Base Level II's fuel economy 1 = 14,2184 mpg
(0.3226) 1 + (0.6774) 1

14.7 “14.0

(Similarly the highway value = 16.6687 mpg)


4. Modified Model Type Labels + Axle + ETW + RLHP

5. Modified Model Type Labels + Subconfiguration

IV. Effect of Modified Labeling Program on the 1981 General Label Data Base
1. Background
2. Analysis of Data
a. Cars

b. Trucks

Appendices
A. Domestic and Foreign Manufacturers
B. Domestic Manufacturers
C. Foreign Manufacturers

D. Individual Manufacturers’ Fuel Economy Differences for Each Level
of Labeling Detail

E. Number of Labels Required versus Level of Labeling Detail for
Each Manufacturer

F. Individual Model Types' Fuel Economy Differences for Each Level
of Labeling Detail


-38-

Iv. Impact of Modified Labeling Program on the 1981 General Label Data Base.

1. Background
The previous section of this report described the modified labeling

program and how to use the adjustment equations. The section will analyze
the effect of the modified labeling program on the actual product line of
nine manufacturers. The 1981 general label data base is the source of the
data and the 1981 general label value 1s the reference point for all
comparisons. (Note that this comparison does not include the use of an EPA
to in-use correction factor.) It compares only the differences that would
occur due to the modified label calculation method. For example, when the
modified label value 1s calculated it 1s compared to the present label

value as follows:

(Modified label value) - (Current label value) = Difference

The "sign" of the resultant difference indicates the direction
the current label value would be adjusted to arrive at the new adjusted
label value. That is, a -1 mpg difference indicates the modified label

value would be 1 mpg less than the current label value.

The data base was comprised of 1981 product lines for nine manu-
facturers; four domestic manufacturers and five foreign manufacturers They

are

Domestic Foreign
American Motors Fiat
Chrysler Nissan
Ford Toyo Kogyo
General Motors Toyota

Volkswagon


Table D-2 Chrysler
CARS
A in mpg 7 =
from original
label A Cc , D
City Highway City Highway City Highway ‘city - Highway City Highway
-1 36.3 26.4 36.1 25.9 29.1 25.7 27.3 26.2, 28.5 26.4
0 56.4 44.4 55 9 44.4 55.9 44.3 57.8 36.3 56.7 36.0
+1 7.1 6.7 7.4 6.7 7.7 7.1 7.4 12.4. 7.5 12.6
TRUCKS .
-l 26.5 46.5 24.0 30.1 30.5 28.6 29.0 * 20.0. 26.3 19.8
) 70.0 42.4 71.6 45.0 64.4 45.7 64.6 50.9 67.4 51.0
+1 0.1 3.9 1.1 12.9 25.0 12.3 2.6 12.0° 2.4 11.8
Note: 0 means fraction <0.01 A = Modified Model Type Label .
-- means no sales in that category B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label


-26-

Adjust 2B for difference between it and 1D.

Tested Index 2B.

Untested Index 1D: Axle = 3.08 RLPH = 10.4 Test Wt. = 3500 FE =?

STEP 1

Correct for differences between 2B and 1D

Correct for Difference in Axle: No difference, No Correction

Correct for Difference in RLHP

city
RLHP

dX = 10.4 - 10 6 = -0.2 s

K = (10.6 + 10.4)/2 = 10.5 = ~0.1676

_ 2(-0.1676)(-0.2)
OFERrup ~ 14-71 —3CyO75) — (-0.1676)(-0.2) ] = 0.0470 mpg

Correct for difference in ETW
dX = 3,500 - 4,000 = -500
X = (4,000 + 3,500)/2 = 3,750

FED = 14.7

city oso _
s = -0.657 + 9.542(10 yx + 3.512(10 1032 = -0.2942

ETW
2 (-0.2942)(-500) = 0.5882 mpg

oFE rw = 14.7 \2 (3,750) - (-0.2942)(-500)

Axle = 3.08 RLHP = 10.6 Test Wt. = 4000 FE = 14.7 mpg

= 0.247 + 0.756(102) ¥


I. Purpose
Il. Current Labeling Program Description
A. Test Procedures
B. Type of Labels
l. Specific Label
2. General Label
C. Terms Used in Labeling
1. Model Type
2. Base Level
3. Vehicle Configuration
4. Subconfiguration
D. Determination of the General Label Value

1. Calculation Procedure
a Vehicle Configuration's Fuel Economy
b. Base Level Fuel Economy

c. Model Type Fuel Economy

III. Modified Labeling Program

A

B.

Background
Description of Calculation Procedure and Equations
Actual Equations

Completed Calculation of Fuel Economy Values: Model Type Label
Determinations; Values and Level of Detail Within Product Line

1. Modified Model Type Labels
2. Modified Model Type Labels + Axle Labels

3 Modified Model Type Labels + Axle Labels + ETW


Table A-5 Domestic and Foreign

Fuel Economy Differences Versus Percent Sales; Modified Model type
Label Minus current Label Value

CARS-CITY
Percent Modified - Current
Sales Label Differences-mpg
2.49 -2 =X
17.53 1 XXXXXXXXX
75.15 i) XXXXXKXXXXXXXXXXXXXKXXXXXXXXXXXXXXXKXK
4.35 +1 XX
0.48 +2 =X
100.00
TRUCKS-CITY
0.22 -3) Xx
1.08 “2 =X
18.41 1 XXXXXKXXX
79.77 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
0.51 +1 =X
0 01 +2 x

100.00


-34-

Fuel Economy Reference
Car line Sales City Highway Code*
Swift 12,000 15.9365 19.8127 1A
Swift 3,000 16.6 22.2 1A
Total 15,000
Model Type Label Value = 1
(32050) 1 \ + 3,000 1
15,000/\ 15.9365 } 15,000 16.6
= 16.0649 mpg

16 (city) rounded to the nearest whole mpg.

Similarly the model type classification containing the Cardinal
car line is equal to 15.2168 or 15 mpg (city) and the Bluebird car line is

equal to 14.2718 or 14 mpg (city).

Note: Only the model classifications containing the Swift and Bluebird car
lines contain actual test data. All of the data used to represent the model
type classification containing the Cardinal car line are adjusted fuel

economy values.

2. Modified Model Type + Axle Labels: Under this alternative,
within a model type each unique axle ratio will receive a separated label
value. In the above sample calculation there are only two subconfigurations
within the model type classification and, each of these subconfigurations
have a unique axle. Therefore, the model type + axle label value will be

the subconfiguration fuel economy value, rounded to a whole mpg.

Fuel Economy Data Label Values
Car line Axle Sales City Highway City Highway Index
Swift 273 12,000 15.9365 19.8127 16 20 1A
Swift 2.43 3,000 16.6 22.2 17 22 1B

*from Table VI


-43-

level of labeling detail increased by 90 for the four domestic manfacturers
(a 19 percent increase over the present label requirements) while a total
of only 4 additional labels would be needed for the five foreign manufacturers
(a 3 percent increase). Similarly, for truck's the increase was 285 for
the domestic manufacturers (a 71 percent increase) while only 2 additional
labels were needed for the foreign manufacturers (a 4 percent increase).
For the greatest level of detail, an increase of 799 car labels would be
needed for the domestic manufacturers (an increase over the current number
of labels by a factor of 2.8) and 388 labels for the foreign manufacturers
(a factor of 3.75) over the present label requirements. At the same level
of labeling detail for trucks an increase of 194] labels would be required
for the domestic manufacturers (a factor of 5.8) and 82 labels for the

foreign manufacturers (a factor of 2.7).

The increase in the number of labels is primarily due to the
options available from each manufacturer and not a result of technology.
There will be a cost to the manufacturers to generate and apply these new
labels, however, the consumer will benefit. That is, the label value will
be a more vehicle specific value and the accuracy of the label value will
be improved For example, assuming 10 million new car sales a year, about
3 million cars (30 percent) of the present label values would change by
incorporating any one of the labeling alternatives. With about 2 million
of these new cars with revised labels having the fuel economy estimate

revised to a lower value.


Example 3:

~29-

Calculate the city fuel economy value for untested

subconfiguration 1A which has an untested combination of engine code (code

1) and transmission configuration (a).

same basic engine and transmission class are 1B, 2B, and 2D. Adjust each

The tested subconfigurations in the

tested subconfiguration for differences in axle, RLHP, and ETW between the

tested subconfiguration and the untested subconfiguration.

STEP 1:

STEP 2°

STEP 3:

Correct for differences between 1A and 1B

Adjustment of subconfiguration 1B.

FE of 1A from 1B: F FE,, + aFE + dFE

Fia-ip ~ FEip le

Using method of FE described in the previous example:

FE = 16.6 + (-0.1966) + (-0.2794) + (-0.1949)

15.9291 mpg

Correct for differences between 1A and 2B
Adjustment of subconfiguration 2B

FE = 14.7 + 0.4395 + 0.1972 + 0.5882
= 15.9249

Correct for differences between 1A and 2D

Adjustment of subconfiguration 2D

FE = 14.0 + 0.9143 + 0.2534 + 0.7855

15.9531 mpg

nu

RLHP *

dFE

ETW


-13-

FRR IRA IRI I THRE ARR E IARI RII IRIE EKER IIASA IB EVI AIA EIA IHR EER.

* *
* Table III *
* *
* Base Levels in Example Data *
* *
* *
* Index Inertia Index Referred *
* for Base Level Weight from Table I *
* *
* I 3,500 pounds 1A through 1D *
* *
* cu. ID - 4,000" pounds 7 24 through 2D *
* *

PREAH ER ERE RARER EER ERE ERK RERERR EER ERE REE RERER EERE ER EER ERE RERERER

3. Vehicle Configuration: Design differences within base
levels can still have an affect on fuel economy. Therefore, for the
purpose of describing unique test vehicles, base levels are further subdivided

into vehicle configurations.

Definition’ a vehicle configuration is defined as a
unique combination of inertia weight class, basic engine, and transmission
class (all of:which determine a base level) plus engine code, transmission

configuration, and axle ratio.

An engine code goes beyond the definition of basic engine
by isolating different variations of carburetor, distributor, and other key
engine and emission control system component calibrations. Similarly,

transmission configuration considers shift calibrations and other design

factors that determine the performance of the transmission.

4, Subconfiguration: Two more vehicle parameters are used to
describe a vehicle for the purpose of fuel economy testing equivalent test
weight and road-load horsepower. Equivalent test weights are the subdivi-
sions of inertia weight class which most closely approximates the weight of

the actual test vehicle. Road-load horsepower 1s horsepower required to


Table B-5

Domestic

Fuel Economy Differences Versus Percent Sales; Modified
Model Type Label Minus Current Label Value

Percent

Sales

30h
20.39
71.38

4.63

0.59

100.00

0.25
0.92
21.40
76.82
0.60

0.01
100.00

CARS-CITY

Differences in

Fuel Economy

72 xX.
0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXRXXXXXKXK
+1 XX
+2 x
TRUCKS-CITY
-3 x
-2 x ~
-1 XXXXXXXXXXK
0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXKXXXXXK
+1 x
+2 x


Table D-3 Ford
CARS
Ain mpg
from original
label A Cc D
City Highway City Highway City Highway City Highway City Highway
-1 19.2 90 22.6 10.0 19 0 20.4 23.1 24.9 23.8 25.7
0 73.2 60.0 73.7 59.8 75.0 46.5 65.9 33.8, 65.5 37.4
+] 7.6 23.2 2.7 21.5 5.0 24.1 10 0 26.4 9.7 27.6
TRUCKS p
-1 33.4 28.7 24.7 21.6 25.3 20.6 25.2 18.4 25.4 18.4
0 63.6 63.0 60.9 52.0 549 53.3 57.0 49.7 57.0 49.8
+1 0.8 0.3 9.2 8.8 15.1 10.1 13.0 13.0 12.8 12.9
Note: 0 means fraction <0.01 A = Modified Model Type Label
-~ means no sales in that category B = Modified Model Type + Axle Label
© = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label


Table A-6 Domestic and Foreign

Fuel Economy Differences Versus Percentage Sales; Modified
Model Type Label Minus Current Label Value

CARS-HIGHWAY
Percent Modified - Current
Sales Label Differences-mpg
2.10 4 xX
2.39 -3 x
2.67 2 =X
18.23 -1 XXXXXXXXX
57.36 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXKX
15.77 +1 XXXXXXXK
1.22 +2 =X
0.26 +3
100.00
TRUCKS-HIGHWAY
0.10 -6 X
0.44 -5 Xx
0.26 4 Xx
1.60 30 Xx
3.38 -2 xx
29.57 -1 XXXXXXXXXXXXXXK
62.43 QO XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXK
2.17 +1 x
0.05 +2 x

100.00


Table A-8 Domestic and Foreign

Fuel Economy Differences Versus Percent Sales: Modified
Model Type + Axle Label Minus Current Label Value

CARS-HIGHWAY
Percent Modified - Current
Sales Label Differences-mpg
0.01 -6 x
0.03 5 Xx
2.26 “4 OX
2.23 30 Xx
4.69 2 XX
14.96 -1 XXXXXXK
57.82 ) XXXXXXXXXKXXXXXXXXKXXXKXXXXXK
16.31 +1 XXXXXXXEK
1.31 +2 x
0.26 +30=«X
0.12 +4 xX
100.00
TRUCKS-HIGHWAY
0.03 -10 Xx
0.01 -8 x
0.05 -6 x
0.51 “5 Xx
0.49 4 Xx
1.36 -3 x
8.28 -2  XXXX
18.99 -1 XXXXXXXXX
62.59 QO  XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
7.56 +1 XXXK
0.13 +2 =X

100.00


yields:

~-16-

'
The average of the individual vehicle fuel economy values 1s:

10570 =15 mpg (arithmatic average)

The harmonic average of the individual fuel consumptions

T 2 T = 13.3 mpg; the true average fuel economy.
— +

10 20

b. Base Level Fuel Economy: The fuel economy of each

base level is comprised of the average fuel economy of each tested vehicle

configuration within the base level. These data are "weighted" in propor-

tion to the projected sales of the vehicle subconfiguration. That is,

within the same base level, if the fuel economy from one vehicle configura-

tion is very high but with very few sales and the fuel economy from another

vehicle configuration 1s not as high but represents a larger proportion of

sales, the fuel economy from the base level would be "weighted" such that

average fuel economy would be nearer the lower value. For example:

Vehicle configuration A = 30 mpg sales 100

Vehicle configuration B = 22 mpg sales 9,900

Total sales of a base level = 10,000

Base level fuel economy = 1

loo 81, 9,900
10,000 30 10,000 22

= 22.0588 mpg

Sales weighting 1s necessary to ensure the best repre-

sentation of the fuel economy of the vehicles within the base level.

In base level I (ref. Tables I and III), there is only one

tested configuration, therefore, base level I's fuel economy = 16 6 mpg city

and 22.2 mpg highway.