FE/GHG Label Issues
Overview

y The Alliance supports EPA/NHTSA efforts 

2

FE/GHG Label

y Objective measures of success

{ Clear message to consumers{ F ibl i t ti /ti i Feasible integration/timing{ Technologies not inadvertently “disadvantaged”
Proposed Agenda

1. Label Design

3

1. Preferred Label Format

2. Technical Issues

1. Vehicle Comparison Vehicle Comparison2. Upstream Emissions3. Advance Technology Vehicle Issues

3. I l t ti I Implemen

t

ation Issues

1. Addition of Color2. Lead-Time

4. Single National Label5. Appendix
Label 2 Format

y The Alliance Supports Label 2 Format

4

The Alliance Supports Label 2 Format

{ Consumer focus group data points to supporting Label 2{ Clearer message{ Provides more visible data on fuel economy, a metric that 

are used to.

{ Unlike Label 1, allows for comparisons within each vehicl{ Same feel as traditional label { Could easily fit on current Monroney Label in current FE l

“footprint”

y The Alliance believes Label 2 could be improved if FE/GHG 

range for vehicle class were used (versus range for all light vehicles)
Label 1 Format

y The Alliance does not support Label 1 Format

5

{ Grade rating concerns

Ù Consumer could confuse grade rating with overall v

reliability rating safety rating etc reliability rating, safety rating, etc.

Ù Out of sync with consumers - FE/GHG is one key featu

only feature demanded by consumers (utility, performa

Ù Potential negative impact on promising fuel economy te

Potential negative impact on promising fuel economy te

Ù Periodic adjustments problematic

| Grading “on the curve”

Ù Other energy labels (Energy Star) do not include grade

{ Vertical orientation of label requires Monroney lab

redesign
Label 1 Format ( ) cont.

y The Alliance does not support Label 1 Format

6

{ The most important information to consumers – M

ratings – is less prominent and harder to see

{ Consumer Focus Groups also said MPG was imp

Consumer Focus Groups also said MPG was imp

Ù “City and highway gas mileage estimates were impo

pieces of information ... and was something that neeprominent on the label prominent on the label.”

{ Diesels get downgraded 1⁄2 letter grade { Grading system is overly stringent that only EVs a

PHEVs are able to reach A grade

{ Letter only points to GHG emissions and not to cr

pollutants
Vehicle Comparisons

y The impact of the label is at the dealership

7

{ By the time consumers get to the dealership they’ve alrea

on the class of vehicle they wish to purchase

{ Therefore the com

parison should be within the vehicle cla

y EPA’s own work confirms this:

{ “Buyers begin the vehicle purchasing process with specific vehicles or a 

in mind that fits their needs. They then search for info. relevant to those 

vehicles.”

Ù “70% of consumers surveyed had a specific type of vehicle in mind w

started looking for a new vehicle and the majority of those (81%) said u

p p g yp urchasin

g that vehicle type.”

y Fuel economy ratings should be within vehicle classes (like e

label).
Upstream Emissions 8

y The Alliance agrees with NPRM position – 

label should not include upstream electric emissions. 

y Consumers will benefit most from a robust 

upstream emissions calculator.
Advance Technology Vehicle Is

y Alliance has concerns about....

9

{ Test procedure consistency{ PHEV/EREV vs BEV Metrics{ Testing methodology{ Calculations (as they pertain to SAE methodology 

cycle corrections) cycle corrections)

y We hi

g g hli

ght these issues in the two slides 

appendix but these topics deserve an offlintechnical discussion (when?)
Addition of Color

y Color does not necessaril

y add value for th

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consumer

y Focus group participants: 

{ “black and white format ... ‘clean’ and ‘informativ

did not make it look like someone was trying to something

”

y Many technical challenges: 

{ Printing color in a high Printing color in

a high

-speed industrial environment diffe

speed industrial environment diffe

significantly from today’s black and white process

{ Significant leadtime and cost to implement new color prin

plants/ports

{ “In-Use” concerns with fading and visibility of color labels
Timing

y 2012MY starts January 2nd of 2011CY

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2012MY starts January 2 of 2011CY

y Several Alliance members have anno

launches for Q1 of 2011 launches for Q1 of 2011

y Manufacturers will not have time to 

implement changes for 2012MY vehicimplement changes for 2012MY vehic

{ New data collection{ Redesign Monroney Redesign Monroney{ System integration (hardware/software/etc.)
Black & White Label Lead-Tim

12

System 

+ Integration

Redesign 

Monroney

Sticker

+ Specifications per final rule:

Request for 

Quote to 

supplier / 

Acquisition

+

+ Sticker Acquisition
Single National Label

13

y At least two and sometime three environm

labels are currently required:

{ EPA/NHTSA{ California Environmental Performance Label{ FTC Alt ti F l V hi l L b l FTC Alternative 

Fuel V

ehi

cle 

L

a

b

el

y We would like to work towards a Single Na

Label
Single National Label : Opportunity to Consolida

California Environmental 

Performance Label EPA Fuel Econom

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FTC Range Label for 

Alt ti F l V hi l Alternative 

Fuel Vehi

cles Government 

Ratings L
OUR VISION

...IN CONTINUED SUPPORT OF A NATIONAL 

PROGRAM, WE STRONGLY RECOMMEND THAT 

NHTSA WORK WITH THE U S ENVIRONMENTAL NHTSA WORK WITH THE U.S. ENVIRONMENTAL

PROTECTION AGENCY (EPA), THE FEDERAL TRCOMMISSION (FTC) AND THE CALIFORNIA AIR 

RESOURCES BOARD (CARB) TO COORDINATE TRESOURCES BOARD (CARB) TO COORDINATE T

EFFORTS OF THESE AGENCIES WITH THE ONGEPA NEW FUEL ECONOMY LABEL RULEMAKING

RESULT SHOULD BE A RESULT SHOULD BE A SINGLE NATIONAL FUEL SINGLE NATIONAL FUELECONOMY AND ENVIRONMENTAL PERFORMANMEASURE LABEL ADMINISTERED BY A SINGLE AGENCY AND USED IN ALL STATES AGENCY AND USED IN ALL STATES. 

ALLIANCE LETTER TO NHTSA

JUNE 25, 2010
Appendix

16 
Advance Technology Vehicle Is

17

y Test Procedure Consistency

{ J1711, CARB and EPA Test Procedures 

Ù NPRM departs from proposed and existing SAE, CA

EPA test procedures EPA test procedures

Ù NPRM will cause conflict between referenced docum

{ J2841

Ù Utility Factor (UF) calculations inconsistentÙ Cycle specific UF not considered by J2841 and meth

not defined

{ J1634

Ù Abbreviated procedure that will allow better results w

reduced test burdenreduced test burden
Advance Technology Vehicle Is

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y PHEV/EREV vs BEV Metrics

{ Gas and Electric Operation – the NPRM is unclea{ PHEV and EREV are compromised when compar{ Using MPG-e, GHG, and annual costs is not comp

with range-limited vehicles

y Testing Methodology Testing Methodology

{ Too-stringent requirements for data recording and 

criteria 

{ Undefined Additional Assumptions{ Emissions measurement during EV mode{ No CD criteria emissions equation
Alliance Members

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