FE/GHG Label Issues10/7/2010OverviewyThe Alliance supports EPA/NHTSA efforts to revise2FE/GHG LabelyObjective measures of success{Clear message to consumersF ibl i t ti /ti i{Feasibleintegration/timing{Technologies not inadvertently “disadvantaged”10/7/2010Proposed Agenda1.Label Design31.Preferred Label Format2.Technical Issues1Vehicle Comparison.VehicleComparison2.Upstream Emissions3.Advance Technology Vehicle IssuesI l t ti I3.ImplementationIssues1.Addition of Color2.Lead-Time4.Single National Label5.Appendix10/7/2010Label 2 FormatyThe Alliance Supports Label 2 Format4TheAllianceSupportsLabel2Format{Consumer focus group data points to supporting Label 2{Clearer message{Provides more visible data on fueleconomy, a metric that consumersare used to.{Unlike Label 1, allows for comparisons within each vehicle class.{Same feel as traditional label{Could easily fit on current Monroney Label in current FE label“footprint”yThe Alliance believes Label 2 could be improved if FE/GHG emissionsrange for vehicle class were used (versus range for all light dutyvehicles)10/7/2010Label 1 FormatyThe Alliance does not support Label 1 Format5{Grade rating concernsÙConsumer could confuse grade rating with overall vehiclereliability rating safety rating etcreliabilityrating,safetyrating,etc.ÙOut of sync with consumers - FE/GHG is one key feature but notonly feature demanded by consumers (utility, performance, etc).Potential negative impact on promising fuel economy technologiesÙPotentialnegativeimpactonpromisingfueleconomytechnologiesÙPeriodic adjustments problematic|Grading “on the curve”ÙOther energy labels (Energy Star) do not include grades{Vertical orientation of label requires Monroney labelredesign10/7/2010Label 1 Format(cont.)yThe Alliance does not support Label 1 Format6{The most important information to consumers – MPGratings – is less prominent and harder to see{Consumer Focus Groups also said MPG was important:ConsumerFocusGroupsalsosaidMPGwasimportant:Ù“City and highway gas mileage estimates were importantpieces of information ... and was something that needed to beprominent on the label”prominentonthelabel.{Diesels get downgraded 1⁄2 letter grade{Grading system is overly stringent that only EVs andPHEVs are able to reach A grade{Letter only points to GHG emissions and not to criteriapollutants10/7/2010Vehicle ComparisonsyThe impact of the label is at the dealership7{By the time consumers get to the dealership they’ve already decidedon the class of vehicle they wish to purchase{Therefore the comparison should be within the vehicle classyEPA’s own work confirms this:{“Buyers begin the vehicle purchasing process with specific vehiclesor a vehicle typein mind that fits their needs. They then search for info. relevant to those particularvehicles.”Ù“70% of consumers surveyed had a specific type of vehicle in mind when theystarted looking for a new vehicle and themajority of those (81%) said they endedupurchasingthat vehicle type.”p g ypyFuel economy ratings should be within vehicle classes (like existinglabel).10/7/2010Upstream Emissions8yThe Alliance agrees with NPRM position – thelabel should not include upstream electric utilityemissions.yConsumers will benefit most from a robust on-lineupstream emissions calculator.10/7/2010Advance TechnologyVehicle IssuesyAlliance has concerns about....9{Test procedure consistency{PHEV/EREV vs BEV Metrics{Testing methodology{Calculations (as they pertain to SAE methodology and 5cycle corrections)cyclecorrections)yWe highlight these issues in the two slides in thegappendix but these topics deserve an offlinetechnical discussion (when?)10/7/2010Addition of ColoryColor does not necessarilyadd value for the10consumeryFocus group participants:{“black and white format ... ‘clean’ and ‘informative,’ anddid not make it look like someone was trying to ‘sell’ themsomething”yMany technical challenges:{Printing color in a high-speed industrial environment differsPrintingcolorinahighspeedindustrialenvironmentdifferssignificantly from today’s black and white process{Significant leadtime and cost to implement new color printers at allplants/ports{“In-Use” concerns with fading and visibility of color labels10/7/2010Timingy2012MY starts January 2ndof 2011CY112012MYstartsJanuary2of2011CYySeveral Alliance members have announcedlaunches for Q1 of 2011launchesforQ1of2011yManufacturers will not have time toimplement changes for 2012MY vehiclesimplementchangesfor2012MYvehicles{New data collection{Redesign MonroneyRedesignMonroney{System integration (hardware/software/etc.)10/7/2010Black & White Label Lead-Time12SystemIntegration+RedesignMonroneySticker+Specificationsper final rule:Request forQuote tosupplier /Acquisition+FinalImplementationat plants/ports+StickerAcquisition10/7/2010Single National Label13yAt least two and sometime three environmentallabels are currently required:{EPA/NHTSA{California Environmental Performance LabelFTC Alt ti F l V hi l L b l{FTCAlternativeFuelVehicleLabelyWe would like to work towards a Single NationalLabel10/7/2010Single National Label : Opportunity to Consolidate LabelsCalifornia EnvironmentalPerformance LabelEPA Fuel Economy Label14FTC Range Label forAlt ti F l V hi lAlternativeFuelVehiclesGovernment SafetyRatings LabelOUR VISION...IN CONTINUED SUPPORT OF A NATIONALPROGRAM, WE STRONGLY RECOMMEND THATNHTSA WORK WITH THE U S ENVIRONMENTALNHTSAWORKWITHTHEU.S.ENVIRONMENTALPROTECTION AGENCY (EPA), THE FEDERAL TRADECOMMISSION (FTC) AND THE CALIFORNIA AIRRESOURCES BOARD (CARB) TO COORDINATE THERESOURCESBOARD(CARB)TOCOORDINATETHEEFFORTS OF THESE AGENCIES WITH THE ONGOINGEPA NEW FUEL ECONOMY LABEL RULEMAKING. THERESULT SHOULD BE ASINGLE NATIONAL FUELRESULTSHOULDBEASINGLENATIONALFUELECONOMY AND ENVIRONMENTAL PERFORMANCEMEASURE LABELADMINISTERED BY A SINGLEAGENCY AND USED IN ALL STATESAGENCYANDUSEDINALLSTATES.ALLIANCE LETTER TO NHTSA10/7/2010JUNE 25, 2010Appendix10/7/201016Advance TechnologyVehicle Issues17yTest Procedure Consistency{J1711, CARB and EPA Test ProceduresÙNPRM departs from proposed and existing SAE, CARB, andEPA test proceduresEPAtestproceduresÙNPRM will cause conflict between referenced documents{J2841ÙUtility Factor (UF) calculations inconsistentÙCycle specific UF not considered by J2841 and methodologynot defined{J1634ÙAbbreviated procedure that will allow better results withreduced test burden10/7/2010reducedtestburdenAdvance TechnologyVehicle Issues18yPHEV/EREV vs BEV Metrics{Gas and Electric Operation – the NPRM is unclear{PHEV and EREV are compromised when compared to BEV{Using MPG-e, GHG, and annual costs is not compatiblewith range-limited vehiclesyTesting MethodologyTestingMethodology{Too-stringent requirements for data recording and validationcriteria{Undefined Additional Assumptions{Emissions measurement during EV mode10/7/2010{No CD criteria emissions equationAlliance Members1910/7/2010