State of California

AIR RESOURCES BOARD



### STAFF REPORT: INITIAL STATEMENT OF REASONS FOR RUL EMAKING

PROPOSED AMENDMENTS TO

THE SMOG INDEX VEHICLE EMISSIONS LABEL

This report has been reviewed by the staff of the C alifornia Air Resources Board and approved for publication. Approval does not signif y that the contents necessarily reflect the views and policies of the Air Resources Board, nor does mention of trade names or commercial products constitute endorsement or recom mendation for use.



### Date of Release: May 4, 2007

Scheduled for Consideration: June 21, 2007Prepared By:

Zero Emission Vehicle Infrastructure Section

Mobile Source Control Division

Gerhard Achtelik, Manager

Contributing Staff:

Craig Duehring Krista Eley

Acknowledgements:

Staff appreciates the time and assistance provided by the staff of the United States Environmental Protection Agency, automobile manufac tures and environmental groups.

Staff also wishes to acknowledge the support and wo rk from Sarah Carter, Melissa Meuser, Duc Nguyen, and Emily Smith with the Mobile Source Control and Operation Divisi ons.iii TABLE OF CONTENTS

EXECUTIVE SUMMARY ..................................

................................................... ........... 1

I. Introduction and Background........................

................................................... .... 5

II. Need for Regulatory Amendments ..................... .................................................. 6

III. Environmental Justice and Public Outreach .......... ............................................. 7

A. Environmental Justice.............................. ............................................... 7

B. Outreach Efforts ...................................

................................................... 7

IV. Staff Proposal – Smog Score........................

................................................... ..... 9

A. Existing Requirements.............................. .............................................. 9

B. Staff Proposal .....................................

................................................... 10

V. Staff Proposal – Global Warming Score .............. .............................................. 13

A. Existing Consumer Information ...................... ..................................... 13

B. Staff Proposal .....................................

................................................... 13

VI. Proposed Environmental Performance Label Requiremen ts........................... 17

VII. Economic Impacts ...................................

................................................... ......... 21

A. Background.........................................

................................................... 21

B. Estimated Costs.................................... ................................................. 21

C. Total Cost of Implementation ....................... ........................................ 23

VIII. Estimated Environmental Benefits................... .................................................. 2 5

IX. Issues.............................................

................................................... .................... 26

A. Lead Time Requirements ............................. ......................................... 26

B. Label Size .........................................

................................................... ... 27

X. Alternatives .......................................

................................................... ................ 28

A. Alternative 1: Keep Existing Smog Index Label and Add a Global Warming Index ...................................... ................................................. 28

B. Alternative 2: Incorporate SmartWay Certification Mark................... 28

C. Conclusion .........................................

................................................... . 29

XI. References.........................................

................................................... ................ 30

Appendix A – Regulation Language...................

................................................... .. A-1

Appendix B – Example Existing Smog Index Labels .... ......................................... B-1

Appendix C - Technical Analysis....................

................................................... ...... C-1

A. Smog Score......................................... ................................................. C- 1iv

B. Global Warming Score ............................... ......................................... C-7

C. Color Printer Economic Impact ...................... .................................. C-14

Appendix D - Other Vehicle Labels..................

................................................... ..... D-1v LIST OF TABLES

Table III-1: Workshop Dates and Locations ....................... ...................................... 8

Table IV-1: Proposed 2009 Smog Score by Certification .......... ............................ 11

Table V-1: Upstream Adjustment Factors for Alternative Fuels .. ........................ 14

Table V-2: Upstream CO 2Equivalent Values for Hydrogen Internal Combustion

Engine, Hydrogen Fuel Cell Electric, and Battery El ectric Vehicles . 14

Table V-3: Statistical Distribution of California and Federal CO2 Data............... 15

Table V-4: Proposed Global Warming Scores based on CO 2Equivalent Emissions 15

Table C-1: California Light-Duty Vehicle Emissions Standards f or Air

Pollutants .........................................

................................................... . C-1

Table C-2: U.S. EPA Light-Duty Vehicle Emissions Standards for Air

Pollutants .........................................

................................................... . C-2

Table C-3: 2009 Federal and California Combined Certification Levels............ C-3

Table C-4: 2009 Federal and California Combined Certification Levels

with PZEV Category................................. ............................................ C-3

Table C-5: 2009 Smog Score by Certification................... ................................... C-4

Table C-6: Possible 2009 Smog Score by Straight Line Analysis. ..................... C-5

Table C-7: California and Federal CO 2 Combined Data Distribution ................. C-8

Table C-8: California 2007 CO 2 Combined Certification Data....................... ...... C-9

Table C-9: Possible 2009 Global Warming Scores Based on CO 2 Emissions .. C-9

Table C-10: Distribution of California Certifications Based on Vehicle

Classification ..................................... ................................................ C-1 0

Table C-11: Statistical Distribution of California and Federal CO 2 Data............ C-12

Table C-12: Possible 2009 Global Warming Scores Based on CO 2 Emissions C-13vi LIST OF FIGURES

Figure 1: Proposed California Environmental Performance Label ...................... 3

Figure IV-1: Current Smog Index Label ........................... ........................................... 9

Figure IV-2: Distribution of California Certification Levels by Smog Score.......... 11

Figure V-1: Distribution of Global Warming Scores.............. ................................. 16

Figure VI-1: California Environmental Performance Label ......... ............................ 19

Figure VI-2: California Environmental Performance Label with Fle x-Fuel ............ 19

Figure X-1: U.S. EPA SmartWay Certification Mark............... ................................. 28

Figure C-1: Distribution of Smog Scores Based on 2007 Model Yea r

Certifications.....................................

................................................... C-5

Figure C-2: Distribution of Smog Scores Based on 2007 Model Yea r

Certifications.....................................

................................................... C-6

Figure C-3: Distribution of Global Warming Scores Based on 2007 Model Year

Certifications..................................... ................................................. C- 10

Figure C-4: Distribution of Vehicle Classification Based on Cal ifornia EO

Certifications..................................... ................................................. C- 11

Figure C-5: Diagram of a Normal Distribution of Scores ......... .......................... C-13

Figure C-6: Distribution of Global Warming Scores Based on 2007 Model Year

Certifications..................................... ................................................. C- 141



### EXECUTIVE SUMMARY

California citizens purchase approximately 2 millio n 1 new passenger cars, light-duty trucks, and medium duty passenger vehicles each yea r. In addition, the California fleet

of 25 million on-road vehicles travels about 900 mi llion miles each day. This equates to 2,288 tons per day 2 of smog precursor emissions and 0.35 million tons per day 3 of global warming gas emissions. Even with the additi on of cleaner vehicles to California’s vehicle population, both smog forming emissions and global warming emissions from motor vehicles will continue to have a major impact on California’s environment for
years to come.

Over the past several years there have been a numbe r of studies using focus groups and market research to evaluate different types of vehicle labeling and ranking programs. In these studies, respondents preferred some kind of overall environmental score that they could have faith in and would be ap plicable across the country and across all vehicles. Respondents stated that the i nformation needs to be presented in a way that consumers find simple and understandable. Unfortunately, consumers do not have a clear understanding of environmental factors as they relate to car choice and tend to assign responsibility for this issue to gov ernment or industry. However, there appears to be growing public awareness of environme ntal issues. A recent California Field Poll indicates the majority of Californians c onsider global warming a serious problem. 4

Consumer awareness of a vehicle’s environmental foo tprint would help consumers make the cleanest purchasing choice possible when s electing a new vehicle. Ultimately, consumer decisions to buy cleaner cars could result in lower emissions than would be achieved from regulating vehicles alone.

To provide vehicle emissions information to consume rs, the Air Resources Board (ARB) has required a Smog Index Label on new vehicles sin ce the 1998 model year (MY). The Smog Index Label provides consumers with an ind ication of the relative emissions performance of new light-duty vehicles for smog for ming exhaust emissions of non-methane organic gas, oxides of nitrogen, and ev aporative hydrocarbons.

In 2005 Assembly Bill (AB) 1229 was signed into law adding Health & Safety Code § 43200.1 which, among other things, requires ARB t o develop a greenhouse gas index and label, and to review the existing Smog Index La bel. Staff proposes amending the Smog Index Label to add a Greenhouse Gas Index, and add specific requirements to label information and presentation to enhance label appearance and consistency. These labeling requirements are prescriptive by nat ure and will require one label size

1 California Air Resources Board: Certification Data Reported to the California Air R esources Board in

2005

2 California Air Resources Board: 2005 Estimated Annual Average Emissions

3 Inventory of California Greenhouse Gas Emissions an d Sinks: 1990-1999, California Energy Commission Staff Report

4 San Jose Mercury News

, “Survey finds 81% worried about global warming,” Ap ril 12, 2007.2

and design to be used by all affected vehicle manuf acturers. Staff recommends the new label regulations take affect for all passenger cars, light-duty trucks, and medium-duty passenger vehicles manufactured on or a fter October 1, 2008.

Proposed Index Requirements During the review staff found noticeable difference s in the way the current smog index values are presented by different manufacturers, ma king it difficult for consumers to compare smog forming emission values from one vehic le to the next. As a result, staff proposes modifications to the graphics and content of the existing California Smog Index Label and is also proposing a new Global Warm ing Index to be included on the

new label.

The current Smog Index Label uses a relative ratio to compare actual vehicle emissions to an average vehicle. Staff found inconsistencies in existing label size and presentation of content used by manufacturers which creates confusion and misunderstanding by consumers. Prior market resear ch by the United States Environmental Protection Agency (U.S. EPA), based o n consumer focus groups, recommended a simple scale from 1 -10 for both Air Pollution and Greenhouse Gas (GHG) emissions. Staff also performed market resea rch based on consumer focus groups and determined that using a simpler scale fr om 1-10 represents the optimal way to present emissions information.

For the Smog Index, staff recommends using a simple scale from 1-10 where 1 represents the dirtiest vehicle available and 10 th e cleanest based on vehicle emission

certification standards. This scale is consistent with the U.S. EPA scale currently used

on their Green Vehicle Guide website. U.S. EPA fou nd that through focus groups this scale was meaningful for prospective car buyers. W hile U.S. EPA provides these scores on its website, vehicle labeling using these scores is voluntary. Currently none

of the auto manufacturers label their vehicles usin g U.S. EPA’s program, however some manufacturers reference their vehicles’ scores in p roduct literature.

For the global warming index, staff developed a sco ring system also using a simple 1-10 scale. The scoring system incorporates all ve hicle greenhouse gases mandated by the ARB greenhouse gas emission standards, which take effect for 2009 model year. Similar to Smog scores, the U.S. EPA provides green house gas scores on its website but does not require scores be printed on new vehic le labels. U.S. EPA’s greenhouse gas scores are based on different calculation metho ds and at this time are not aligned with staff’s proposed scoring system.

Staff recommends that the scoring system be re-anal yzed when 2012 MY California

certification data becomes available. This new ana lysis is required because annual reductions in global warming emissions, as required by ARB’s greenhouse gas emission standards, may alter the distribution of s cores over time.3

Label In designing the new California Environmental Perfo rmance label, staff turned to market research specialists for help and sought out consum er-based input from focus groups to provide clarity and understanding of a newly design ed label. The purpose of these focus groups was to build upon the work previously done and to obtain up-to-date information from California specific consumers. As a result staff designed a new label

based on this research. The label best understood by respondents is shown in figure 1.

Figure 1: Proposed California Environmental Perform ance Label

Figure 1 shows the Global Warming score on the left and the Smog Score on the right. The black boxes represent the score of the labeled vehicle. A triangle below the scale shows the score of an average vehicle for compariso n purposes. It was clear in the focus groups that with the word “cleanest” under th e 10 and with the statement: “Protect the environment, choose vehicles with the higher sc ores” meant vehicles with more

black boxes were cleaner vehicles. The statement a t the bottom of the label describes the impact of motor vehicles on smog and global war ming. It also points consumers to the ARB’s www.DriveClean.ca.gov website which is a consumer oriented website with information about clean cars, alternative fuel and advanced technology vehicles.

Economic Impacts This regulation proposes modifications to the exist ing Smog Index Label and adds a global warming score to the existing label. Based on the amount of added information required and the addition of the new global warming score, the size of the label must be increased. In addition, Health and Safety Code § 4 3200.1 requires use of a color other than black for some portion of the label.4

The total annual cost to implement this regulation is estimated to be $245,000 for the industry as a whole. The annual cost for a typ ical manufacturer is estimated to be $8,167. This cost estimate will vary slightly b y manufacturer depending on the actual number of assembly plants, ports of entry, p rinters required, and vehicles produced.

Environmental Benefit The purpose of the label is to encourage purchasers to buy new vehicles with the lowest emissions. To the extent that the label accomplish es this, vehicle emissions will decrease. Staff has no basis upon which to quantif y this effect, thus no estimates of

cost effectiveness have been made.

Staff Recommendation Staff recommends the Board approves the new label. The proposed label will provide clarity for consumers and help them make environmen tally beneficial choices.5



### I. Introduction and Background

California citizens purchase approximately 2 millio n 5 new passenger cars, light-duty trucks, and medium duty passenger vehicles each yea r. In addition, the California fleet

of 25 million on-road vehicles travel about 900 mil lion miles each day. This equates to 2,288 tons per day 6 of smog precursor emissions and 0.35 million tons per day 7 of global warming gas emissions. Even with the additi on of cleaner vehicles to California’s vehicle population, both smog forming emissions and global warming emissions from motor vehicles will continue to have a major impact on California’s environment for years to come. Consumer awareness of a vehicle’s e nvironmental footprint would help consumers make the cleanest purchasing choice possi ble when selecting a new vehicle. Ultimately, consumer decisions could resu lt in lower emissions than would result from regulated emission standard requirement s alone.

The average new car purchaser is not aware of the v arious smog forming pollutant emission requirements that apply to new vehicles an d the regulatory terms used to describe emission levels. For example, a Californi a certified vehicle is identified as being a low-emission vehicle (LEV), ultra-low-emiss ion vehicle (ULEV), super-ultra-lowemission vehicle (SULEV), partial zero-emission veh icle (PZEV), or zero-emission vehicle (ZEV). Likewise, in some instances, federa lly certified vehicles using an

emissions “bin” certification level from bin 1 thro ugh bin 9a can also be sold in

California. Both the U.S. EPA’s Green Vehicle Guid e website and the California’s

DriveClean website offer emission classification id entifiers to aid the consumer in selecting clean vehicles. However, these vehicle c lassifications used across multiple information sources can differ and overlap at times , providing additional challenges for the consumer to identify cleaner new vehicles. In addition to smog forming pollutants, cars emit greenhouse gases. Consumers are only jus t beginning to understand the greenhouse gas emissions impacts from cars and have little or no information available about new cars on which to base an informed purchas e decision.

In order to ensure that Californians are effectivel y informed as to the environmental impact of new vehicle purchases, Health & Safety Co de § 43200.1 requires the Air Resources Board (ARB) to revise the existing Smog I ndex Label to include a Global Warming Index.

5 California Air Resources Board: Certification Data Reported to the California Air R esources Board in

2005

6 California Air Resources Board: 2005 Estimated Annual Average Emissions

7 Inventory of California Greenhouse Gas Emissions an d Sinks: 1990-1999, California Energy Commission Staff Report6



### II. Need for Regulatory Amendments

ARB requires that each new passenger car and light- duty truck offered for sale have a window label that includes a rating of its smog-for ming emissions, called the smog index. On October 6, 2005, Assembly Bill 1229 was signed into law (Chapter 575, now Health & Safety Code § 43200.1), which directs the Air Resources Board to review and revise the existing Smog Index Label and to develop a Global Warming Index. A summary of the requirements follows.

• No later than July 1, 2007, revise regulations rel ating to the smog index decal, to rename the existing decal and to provide specified smog forming, and global warming emissions information.

• Label is required to be effective for model year 2 009 and subsequent model year

new motor vehicles.

• Label is required for all passenger cars and light -duty trucks with a gross vehicle weight of 8,500 pounds and medium-duty passenger ve hicles less than 10,000 pounds.

• Global warming index shall include emissions from vehicle operation and upstream emissions.

• Label shall include projected average vehicle emis sions and lowest emission vehicle reference points.

• Label shall use at least one color ink in addition to black.

• Staff shall hold at least one public workshop.

• Staff shall seek input from automotive consumers, graphic design professionals, and other relevant labeling formats.

• This bill permits the ARB to recommend to the Legi slature additional sources of air pollution that emit significant amounts of glob al warming gases for which the disclosure of information regarding those emissions would be an effective means of educating the public about the sources of global warming and its impacts.

Health & Safety Code § 43200 requires the label to be placed on the driver's side window or, if it cannot be so placed, to the windsh ield. This restrictive placement of the label was unintended and could have raised safety c oncerns. Assembly Bill 2557 was signed into law (Chapter 419) on September 22, 2006 , permitting the label to be placed on a side window to the rear of the driver, or if i t cannot be so placed, to the windshield.

A review of the implementation of the existing Smog Index Label shows a lack of consistent label design used by auto manufacturers. Appendix B shows different variations of labels used by the manufacturers. Ba sed on the requirements of Health & Safety Code 43200.1 and staff’s findings regarding the existing Smog Index Label, a proposal for a new Environmental Performance Label has been developed and is presented in this report.7



### III. Environmental Justice and Public Outreach

The ARB is committed to ensuring that all Californi a communities have clean, healthful air by addressing not only the regional smog that h angs over our cities but also the more localized toxic air pollution that is generate d within our communities. The ARB works to ensure that all individuals in California, especially children and the elderly, can live, work and play in a healthful environment that is free from harmful exposure to air pollution.

A. Environmental Justice

On December 13, 2001, the Board approved Environmen tal Justice Policies and Actions, which formally established a framework for incorpor ating environmental justice into the ARB's programs, consistent with the direct ives of State law and policy 8

. “Environmental Justice” is defined as the fair trea tment of people of all races, cultures, and incomes with respect to the development, adopti on, implementation, and enforcement of environmental laws, regulations, and policies. These policies apply to all communities in California but, environmental justic e issues have been raised more in the context of low-income and minority communities because of past land use policies and the accumulative impact of a concentration of e mitting facilities in some neighborhoods.

To achieve this goal, the ARB has established a Com munity Health Program and emphasized community health issues in our existing programs. ARB has published, “The Public Participation Guide to Air Quality Deci sion Making in California” to use as a

basic tool and for information needed to understand and participate in air pollution policy planning, permitting, and regulatory decision makin g processes 9 . The Environmental Justice Policies are intended to promote the fair t reatment of all Californians and cover the full spectrum of ARB activities. Underlying the se Policies is a recognition that we need to engage community members in a meaningful wa y as we carry out our activities. People should have the best possible information ab out the air they breathe and what is being done to reduce unhealthful air pollution in t heir communities. The ARB recognizes its obligation to work closely with all stakeholders; communities, environmental and public health organizations, indu stry, business owners, other agencies, and all other interested parties to succe ssfully implement these policies. Our outreach efforts, described below, facilitate this objective.

B. Outreach Efforts

The ARB strives to involve the widest number of aff ected persons in the development of its regulations. To this end, staff held informal public workshops and meetings prior to publishing the notice and staff report. Information from these workshops can be found

8 Information for these programs can be found at http://www.arb.ca.gov/ch/programs/ej/ejpolicies.pdf

. 9 Information on this program can be found at http://www.arb.ca.gov/ch/public_participation.htm

.8

through the Vehicle Emissions Labeling website 10 . For this rule, staff conducted two public workshops and numerous focused meetings. No tices for the workshops were posted to Vehicle Emissions Labeling web site and e -mailed to subscribers of ARB’s electronic list server. Those workshops held in Sa cramento were webcast for individuals who could not travel to the meeting loc ations. Attendees of the workshops included representatives from auto manufacturers, e nvironmental organizations, and other parties interested in vehicle emissions label ing. To generate additional public participation and to enhance the information flow b etween ARB and interested persons, staff made all documents, including workshop presen tations, available via the Vehicle Emissions Labeling web site.

Table III-1: Workshop Dates and Locations

Date Location
February 15, 2005 Sacramento March 16, 2006 Sacramento

Outreach and public participation are important com ponents of ARB’s regulatory development process. As part of the outreach effor ts, ARB staff made extensive personal contacts with auto manufacturers, environm ental organizations, U.S. EPA, other state air quality agencies and other affected parties through meetings, telephone calls, and electronic list-serves. These activitie s included holding two public workshops, nine focused meetings and conducting more than 50 t elephone conversations. Staff

met with a number of the same stakeholders for focu sed meetings throughout the rulemaking process to receive feedback on staff’s p roposed regulatory amendments. Alternatives were suggested to the proposed regulat ion and explored by staff.

10 More information on Vehicle Emissions Labeling Pro grams can be found at http://www.arb.ca.gov/msprog/labeling/labeling.htm9



### IV. Staff Proposal – Smog Score

A. Existing Requirements

The California Smog Index Label provides consumers with an indication of the relative contribution of new light-duty vehicles to smog for mation based on exhaust nonmethane organic gas (NMOG), oxides of nitrogen (NOx ), and evaporative hydrocarbon (HC) emissions. The current Smog Index Label uses a relative ratio to compare the vehicle being labeled to a base vehicle as determin ed by the ARB. The equation for

this ratio is as follows:

Where NMOG and NOx are tailpipe emissions, HC is ev aporative emissions.

This smog index ratio is then displayed graphically on a label, usually as a number less then 1.0, along with the smog index of an average n ew vehicle for the model year of the vehicle being sold. Figure IV-1 illustrates a typi cal Smog Index Label:

Figure IV-1: Current Smog Index Label

SMOG EMISSIONS INFORMATION

The Smog Index of this vehicle is The Smog Index o f the average new vehicle is

0.34 0.52

▼ ▼

0.0 0.1 0.2 0.3 0.4 0 .5 0.6 0.7 0.8 0.9 1.0......3.0

◄ CLEANER MORE POLLUTING ►

Note: The Smog Index (SI) indicates the relative le vel of smog-forming pollutants emitted by the vehicle. The lower the S I, the lower the vehicle's

emissions.

This label began appearing on new vehicles offered for sale in California in 1998 and is also appearing on vehicles sold in other states tha t have adopted California standards. Some vehicle manufacturers have incorporated the Sm og Index information into the 

### Smog

Index = NMOG+NOx+HC (vehicle being certified)

NMOG+NOx+HC (base vehicle)10

new vehicle’s Monroney label, which provides pricin g information and the vehicle’s U.S. EPA fuel economy ratings.

The existing smog index regulations have allowed th e manufacturers to vary the size and graphical representation of the Smog Index over time. Today, each vehicle manufacturer has its own graphical representation o f the scale, some similar to the one shown above, some showing a scale from 0.0 – 2.0, a nd some showing a scale from 0.0 – 3.0. As the length of the scale increases fr om “0.0 – 1.0” to “0.0 – 2.0” and even “0.0 – 3.0,” the importance of a smog index ratio w hose number is typically less than 1.0 may diminish. Appendix B contains some example pic tures of actual 2007 Smog Index Labels being used by various vehicle manufacturers. For this reason staff proposes prescriptive label requirements.

The U.S. EPA does not require a smog index or score to be included on new cars. On its website, it provides a rating on a scale from 1 -10 (ten being lowest emitting or cleanest), as part of its Green Vehicle Guide 11 . Separate ratings are provided for

vehicles certified to California new vehicle emissi on standards.

B. Staff Proposal

Staff is proposing to modify the graphics and conte nt of the label to increase consumer awareness and understanding of the Smog Index Label . Staff proposes using a simple scale of 1-10 where 1 represents the dirtiest vehic le available and 10 the cleanest. This is the opposite of the current scale, where 0.0 is the cleanest. Staff proposes using this new scale for two reasons. First, consumer focus g roup research indicates more consumers understand 10 is well performing, and 1 i s poor performing. Second, the U.S. EPA has a popular website that uses the 1-10 s cale for both smog and greenhouse gas ratings of new vehicles (Green Vehic le Guide 10 ). The proposed Smog

scores based on the 1-10 scale are shown in Table I II-1. Staff has worked with U.S. EPA and included federal standards (bins) in the ra nking system, and U.S. EPA staff indicates it may change its rating to be consistent with California. A more detailed technical analysis and discussion of the new scores can be found in Appendix C: Technical Analysis.

11 United States Environmental Protection Agency: Green Vehicle Guide, www.epa.gov/greenvehicles11 Table IV-1: Proposed 2009 Smog Score by Certificati on

California Emissions Certification - Federal

Bins NMOG + NOx (g/mile) 2009 Smog

Score Zero Emission Vehicle (ZEV) or Bin 1 0.0 10 Partial Zero Emission Vehicle (PZEV) 0.030 9 Super Ultra Low Emission Vehicle (SULEV) or

Bin 2 0.030 8

Bin 3 0.085 7

Bin 4 0.110 6 Ultra Low Emission Vehicle (ULEV) 0.125 5 Low Emission Vehicle (LEV) or Bin 5 0.160 4 Low Emission Vehicle (LEV) (option 1)* or Bin 6 and SULEV medium duty passenger vehicles 0.190 – 0.200 3

Bin 7 0.240 2

Bin 8a or ULEV (medium duty passenger vehicles) 0.325 1

* LEV (option 1) is an optional certification stand ard for qualifying work vehicles.

Table III-1 lists the certification levels by their California terminology or by U.S. EPA “bins,” the tailpipe emission standard for NMOG and NOx and the proposed Smog

Score. While the PZEV and SULEV – Bin 2 vehicles a re certified to the same exhaust emission standard, PZEV certified vehicles receive a higher score due to their zero evaporative emissions and extended 150,000 mile emi ssion warranty.

Applying this Smog scale to the 2007 MY California certification data yielded the model based distribution of Smog scores shown on Figure I V-2. This distribution is based on 2007 MY California certification data and may look different for the 2009 MY as vehicle manufacturers continue to certify to cleaner standa rds.

Figure IV-2: Distribution of California Certificati on Levels by Smog Score



### 0 20 40 60 80 100 120 140 160 180

1 2 3 4 5 6 7 8 9 10

Smog ScoreNumber of VehicleCertifications12

Based on all 2007 MY vehicles, the average vehicle model score is closest to a 5 on the proposed scale, which correlates to an Ultra Low Em ission Vehicle (ULEV) certification

standard. This is a count of vehicle models howeve r, not a sales weighted fleet average. In 2009, the fleet average emission stand ard would also be closest to the

ULEV certification standard and receive a score of 5. Staff therefore recommends using the ULEV certification as the average and setting t he Smog score of 5 to represent the average vehicle. Vehicles with a score of 1 are ty pically medium-duty passenger vehicles, such as the Ford E-250 Econoline.

For bi-fuel, fuel flexible, and dual-fuel vehicles, vehicles capable of operating on gasoline and an alternate fuel like ethanol propane or natural gas, the scores displayed on the label will be based on only the highest emit ting fuel. The label will direct

consumers to visit ARB’s web site at www.DriveClean .ca.gov to find information on flexible fuel vehicles and the impact of using an a lternative fuel on smog forming pollutant and greenhouse gas emissions.13



### V. Staff Proposal – Global Warming Score

A. Existing Consumer Information

Neither the U.S. EPA nor the ARB currently requires greenhouse gas emissions to be reported on a new vehicle label. U.S. EPA reports a vehicle’s CO2 emissions in its

web-based Green Vehicle Guide. The score is based on the CO2 emissions from the federal test procedure, and the fuel used. Other g reenhouse gases, such as nitrous oxides, are not included in the published score. S eparate ratings for California certified vehicles are provided.

B. Staff Proposal

Staff proposes to use a global warming scoring syst em for labeling that is based on emissions data from ARB’s motor vehicle greenhouse gas emissions regulation. The motor vehicle greenhouse gas regulation bases compl iance on four different sources of pollutants: (1) carbon dioxide (CO 2 ), methane (CH 4 ) and nitrous oxide (N 2 O) emissions resulting directly from operation of the vehicle, ( 2) exhaust CO 2 emissions resulting from operating the air conditioning system (indirect air conditioning (A/C) emissions), (3) refrigerant emissions from the air conditioning sys tem due to either leakage, losses during recharging, sudden releases due to accidents , or release from scrappage of the vehicle at end of life (direct A/C emissions), and (4) upstream emissions associated with the production of the fuel used by the vehicle. Up stream emissions are included so that vehicles using an alternative fuel, a fuel other th an gasoline or diesel, will be given an appropriate score relative to the production and co nsumption of the fuel used.

The greenhouse gas regulation establishes a CO 2 “equivalent” value that includes all the various global warming gases based on their rel ative contribution to global warming.

The CO 2 equivalent value is as follows:

CO 2 Equivalent = CO 2 +296xN 2 O+23xCH 4 –A/C Direct Emissions Allowance–A/C Indirect

Emissions Allowance

Using this equation, and accounting for the upstrea m emissions factor for alternative fuels, ARB accounts for all global warming gasses b eing released into the atmosphere due to the operation of each vehicle.

To maintain simplicity, the greenhouse gas regulati on uses the upstream emissions for

vehicles that use conventional fuels as a “baseline ” against which to compare the relative upstream emissions of alternative fuel veh icles. Therefore, when certifying gasoline or diesel-fuel vehicles, manufacturers wil l report only the “direct” or “on vehicle”

emissions. Table IV-1 lists the CO 2 upstream adjustment factor for alternative fuels used for the greenhouse gas regulation.14

Table V-1: Upstream Adjustment Factors for Alternat ive Fuels

Fuel CO 2Equivalent

Adjustment Factor

Conventional Gasoline (RFG) 1.00

Compressed Natural Gas (CNG) 1.03

Liquid Propane Gas (LPG) 0.89

Ethanol (E85) 0.74

The CO 2Equivalent emissions will be multiplied by the CO 2Equivalent Adjustment Factor for the alternative fuel, as shown in the Table V-1. F or hydrogen internal combustion engine vehicles, hydrogen fuel cell electric and ba ttery electric vehicles, the grams per mile average CO 2Equivalent value is the sum of the upstream emissions and the A/C direct emissions. Therefore these vehicles will be given a constant CO 2Equivalent value listed in

Table V-2.

Table V-2: Upstream CO 2Equivalent Values for Hydrogen Internal Combustion Engine, Hydrogen Fuel Cell Electric, and Battery Electric

Vehicles

Fuel CO 2Equivalent Value (grams/mile) Electricity 130 Hydrogen – Fuel Cell 210 Hydrogen – Internal Combustion Engine (ICE) 290

As required by the greenhouse gas regulation, CO 2Equivalent values are reported for both city and highway testing cycles and than combined t o represent a 55% city and 45% highway driving ratio. This CO 2Equivalent combined value, including likely credits achievable from direct AC emission reductions, is t he value that staff used to develop a global warming scoring and labeling system.

Staff performed a statistical analysis on the CO 2 data available from the model year

2007 California Certifications. Manufacturers are not yet certifying their vehicles to the greenhouse gas regulation standards, and not all ma nufacturers currently provide ARB with this data. Staff requested a complete set of CO 2 data from all manufacturers 12 but

12 Air Resources Board: February 28, 2007 letter to Steven Douglas, Directo r; Alliance of Automobile Manufacturers and February 28, 2007 letter to John Cabaniss, Director; Association of International

Automobile Manufacturers.15

received minimal feedback. Statistically, the avai lable data was sufficient to represent

the new vehicle fleet as a whole. To better illust rate this point, staff compared the California dataset to a more complete dataset from Federal certifications. As seen in Table V-3, the California and Federal average and s tandard deviation values are very close to being equal when not including the MDPV ca tegory. The similarity in values helps demonstrate that the available CO 2 data is adequate to represent the entire fleet.

Table V-3: Statistical Distribution of California a nd Federal CO2 Data

CO 2 combined (g/mile) California
(with MDPV data) California
(without MDPV data) Federal

Minimum 130 130 133

Maximum 874 570 662

Average 358 355 348

Standard Deviation 101 81 76

Staff used the statistical average of 360 grams per mile (g/mile) CO 2 and set that as 5 on the scale. Using a standard deviation of 80 g/m ile, staff developed a scoring system based on two standard deviations from the average t o simulate a normal distribution of

scores. The two extremes blend into the best and w orst scores. Applying this principle to the California dataset staff developed the globa l warming scoring system found in

Table V-4.

Table V-4: Proposed Global Warming Scores based on CO 2Equivalent Emissions

Proposed Global Warming Score CO 2Equivalent

grams per mile

10 Less than 200

9 200-239

8 240-279

7 280-319

6 320-359

5 360-399

4 400-439

3 440-479

2 480-519

1 520 and up

Applying this global warming scoring system to the 2007 MY California certification dataset yields the distribution of scores as shown in Figure-V-1 which closely resembles

a normal distribution.16 Figure V-1: Distribution of Global Warming Scores

The spike at the low end of the scale (score of 1) represents the larger medium-duty passenger vehicles, such as the Ford E-250 Econolin e and Expedition. Vehicles with a score of 10 are typically hybrid passenger cars, su ch as Toyota Prius and Honda Civic Hybrid. Average vehicles obtaining a score of 5 ar e typically large passenger cars and small light-duty trucks, such as the Ford Crown Vic tory, Toyota 4Runner, and Honda Odyssey van.

Staff recommends using this global warming scoring system on the label required by Health & Safety Code 43200.1

The greenhouse gas regulation requires vehicle manu facturers to decrease the fleet average CO 2Equivalent emissions incrementally from 2009 to 2016 at which point the fleet average CO 2Equivalenmt emissions remain constant. Staff looked at these incremental adjustments and determined that by the 2012 MY, on average, vehicles will have

reduced the amount of CO 2Equivalent emissions to the point of skewing the normal distribution of scores to the higher end of the sca le. For example, the incremental change between global warming scores as proposed by this report is 40 (g/mile). Following the reductions required by the greenhouse gas regulation, the fleet average emissions will have been reduced by 84 (g/mile) by 2012. Therefore vehicles on average would be jumping one or more global warming scores to the next cleanest score and skewing the normal distribution of scores . Staff also believes this would be an appropriate time to evaluate the need for modify ing the indices or labeling provision to reflect potentially increasing alternative fuels use in California.

A more technical analysis of the global warming sco ring system can be found in Appendix C: Technical Analysis.



### 0 5 10 15 20 25 30

1 2 3 4 5 6 7 8 9 10

Global Wa rming Score CleanestNumber of VehicleCertifications17



### VI. Proposed Environmental Performance Label Requir ements

A review of the existing Smog Index Label yielded m any inconsistencies from

manufacturer to manufacturer. As mentioned earlier in this report, the many variations

of labels from one manufacturer to the next make it difficult for the consumer to compare vehicles. Appendix B shows a sampling of t he many different variations of labels used by vehicle manufacturers. Based on thi s finding, staff decided to develop a

uniform label that is easier to read and understand . To do this, staff decided to hire market research specialists to help.

In March 2007, ARB staff contracted with two market research firms to conduct two focus groups to evaluate various components of the proposed emissions label. The label designs evaluated were borrowed from the U.S. EPA’s Green Vehicle Guide. The U.S. EPA developed its guide from performing numero us focus group tests over the years, and extensive market research. The purpose of our focus groups was to build upon the work already done by obtaining up to date information and receiving information from California-specific consumers.

Two focus groups were conducted in Los Angeles, Cal ifornia, on March 28, 2007 to obtain reactions to draft labels. One group was co mprised of eight people and one group was comprised of nine people. One criterion for selection was that participants must have purchased a new vehicle within calendar y ears 2006 or 2007. Group number one was comprised of smaller vehicle buyers and group number two was comprised of larger vehicle buyers. The reason beh ind this grouping was that

consumers of similar vehicle sizes would feel more comfortable talking with each other.

The following are some of the key findings of the v ehicle emissions labeling focus

groups 13 :

• Size of label. Consumers preferred the proposed m inimum emissions label size of 4” x 6”. The proposed minimum size was noticeab le, simple and easy to read. The consumers felt the sample emissions label sized 1 1/4” x 4 1⁄4” placed on the Monroney label sized approximately 11” x 17”, was t oo small and that they would not read it. Consumers preferred the emission labe l to be separate and next to Monroney label so that one would not have to walk a round to the other side of

car to read it. Consumers also did not like the sa mple size 2 1⁄2” x 4” of the current smog index. They felt it contained too muc h information on too small of a

label.

• Color of the label border. Consumers liked the gr een border of the proposed emissions label. They felt green represents the en vironment, conservation and that color catches the eye.

13 Vehicle Emissions Labeling Focus Groups Qualitativ e Research, April 6, 2007, prepared for the California Air Resources Board by ConsumerQuest,18

• Global Warming Score title versus Greenhouse Gas S core title. Consumers strongly preferred Global Warming Score. It had mo re meaning and was to the point.

• Cleanest versus Best as an additional indicator at end of scale. Consumers definitely preferred Cleanest. They felt it was mo re descriptive.

• Scale representation. Consumers preferred solid b lack blocks over either a solid black bar or a gradient over the entire scale. The blocks were more definitive and gave another counting mechanism. Colored block s, whether green or blue, were not important. From a distance consumers thin k more blocks would mean worse pollution. However, when consumers look clos er they understand the scale with 10 being the cleanest.

• Identification of agency or group responsible for the label. Consumers preferred California Environmental Protection Agency title wi th line over Air Resources Board versus just Air Resources Board. They felt i t was more official looking and recognizable.

• Consumers desired more information on how the scor es were determined. To

address this concern staff has added an additional statement to the bottom border of the proposed emissions label.

Staff has used the information from these focus gro ups and other stakeholder input to develop the proposed design of the vehicle emission s label. These labeling requirements are prescriptive by nature and will re quire one label size and design to be used by all affected vehicle manufacturers. The de sign of the proposed vehicle emissions label is shown in figure VI-1. Figure VI -2 shows a flexible fuel vehicle with

the “Alternate” fuel statement added.19 Figure VI-1: California Environmental Performance L abel

Figure VI-2: California Environmental Performance L abel with Flex-Fuel

Vehicle Statement

Figure VI-1 shows the Global Warming score on the l eft and the Smog Score on the right. The black boxes represent the score of the labeled vehicle. A triangle below the scale shows the score of an average vehicle for com parison purposes. It was clear in Alternate

fuel

statement20

the focus groups that with the word “cleanest” unde r the 10 and with the statement: “Protect the environment, choose vehicles with the higher scores” vehicles with more

black boxes were cleaner vehicles. The statement a t the bottom of the label describes the impact of motor vehicles on smog and global war ming. It also points consumers to the ARB’s www.DriveClean.ca.gov website which is a consumer oriented website with information about clean cars, alternative fuel and advanced technology vehicles.21



### VII. Economic Impacts

A. Background

Staff is proposing to revise the current smog index and add a global warming index as required by statute. The statute also requires, am ong other things, that the label

contain the use of at least one color of ink other than black (at H&S § 43200.1(b)(2)(D)) and to seek input from consumer focus groups in det ermining the color, which resulted in the selection of the color green.

Changes to the existing label, required by statute to include the additional global warming index information, necessitate an increase in the size of the label. Existing label sizes vary from 11⁄2 x 6 inches to 2 1⁄2 x 4 inches due to the current regulatory requirements for label content. Because of the amount of information already contained on the Smog Index Label and the f act that a new global warming index must be added, the size of the label must be increased to accommodate both indices. The findings of the consumer focus groups indicate that the new label size

should be at least 4 x 6 inches.

Since the statute requires using a color other than black for some portion of the label, the color green was chosen as it represents an environmental color to most

consumers. Most vehicle manufacturers claim to be currently using only black ink printers. Adding a color to the label requires the manufacturers to either obtain preprinted color labels or replace their existing prin ters with color printers. Staff was able to analyze these costs and include them as an economic impact to the industry as a whole.

B. Estimated Costs

1. Label Size

Part of the cost imposed on the manufacturers, base d on these regulations, is

associated with the increase in label size. Since the vehicle manufacturers are already required to print a Smog Index Label, staff reasoned that only minor costs would be incurred for setup, programming, or testin g of the new label.

The increase in label size does not appear to cause much concern for existing assembly line printers as these printers are alread y capable of printing labels up to 6 inches wide and even Monroney labels up to 11 inc hes wide. The Monroney label is a federally mandated sticker affixed to th e side window or windshield of every new passenger car and light-duty truck sold i n the United States. The sticker

includes consumer information such as the manufactu rer's suggested retail price (MSRP), vehicle specifications, standard equipment and warranty details, optional equipment and pricing, and U.S. EPA city and highwa y fuel economy ratings.22

Requiring a label to increase from 2.5 x 4 inches t o 4 x 6 inches will add an estimated 0.8 cents per label based on minimum case package purchasing quantities of label feedstock. This cost will decr ease as order quantities increase. Staff conservatively rounded this cost up to 1 cent per label which equates to 1 cent per vehicle produced.

Based on 2005 California vehicle sales data of appr oximately 2 million passenger cars, light-duty trucks, and medium-duty passenger vehicles, this would impose an industry wide annual operating cost increase of $20 ,000. Thirty vehicle manufacturers are currently certifying their produc ts for sale in California. These manufacturers sell anywhere from 50 to 450,000 vehi cles a year to California citizens. Based on market share, individual manufa cturer costs would vary anywhere from $1 annually to $4,350 annually, but o n average would equate to $667 per manufacturer per year.

2. Label Color

The addition of color also imposes a cost to the ve hicle manufacturer. Regulating a specific color or colors by ARB would require the m anufacturer to bear the cost of ordering pre-printed color labels to use as feedsto ck or bear the cost of replacing their existing black ink printers. Each solution t o providing color labels is acceptable to staff, therefore an analysis of each solution follows. A more detailed and technical analysis can be found in Appendix C.

Replace Existing Label Stock with Pre-Printed Color Label Stock

Pre-printed color labels can be used as feedstock a s long as all the information on the label presented in color is constant for all la bels and the information being printed for each vehicle is in black. The new labe l, as recommended by staff, allows for this possibility. The per-label cost to go from a non-color feedstock label

to color feedstock label is estimated to be about 5 cents per label. This equates to a 5 cents per vehicle cost increase. Based on 2005 California vehicle sales data of approximately 2 million passenger cars, light-duty trucks, and medium-duty passenger vehicles, this would impose a total annua l operating cost increase of $100,000 across all manufacturers. Individual manu facturer costs would vary based on their actual production volume, but on ave rage would equate to $3,333 per manufacturer per year.

Staff believes this option may be used for an exten ded period of time by small volume manufacturers but only for the first year or two by medium to large volume

manufacturers. In discussions with the manufacture rs, staff was given the impression that color labels are something the manu facturers have already been considering. Therefore, staff believes that manufa cturers will upgrade existing black ink printers to color printers.23

Replace Existing Black Ink Printers with Color Prin ters

Staff expects manufacturers will replace existing b lack ink printers with color printers as existing printers wear out. New indust rial laser-jet color printers cost about $6,000 each verses $5,000 for an equivalent b lack ink laser-jet printer. Therefore, staff reasoned that a manufacturer would only incur the incremental cost increase of $1,000 per printer. Staff reasoned tha t existing printers will continue to be used through the end of their useful lifecycle b efore being replaced or will be reutilized elsewhere in the organization. Either w ay, medium and large manufacturers will upgrade to color printers within the first three years of implementation. Staff estimated the range of print ers required to be from as few as 2 to as many as 52 per manufacturer, based on the n umber of assembly facilities and ports used by each manufacturer. The total num ber of printer replacements required for the industry as a whole is estimated t o be 286 which equates to a total statewide incremental cost increase of $286,000 or about $10,000 per average

manufacturer.

This one time capital cost can be annualized over t he 3-5 year life of a printer. Staff used a conservative replacement cycle of thre e years and a 5% real discount rate. Therefore the statewide 3-year annualized ca pital recovery cost will be $105,000 or about $3,500 per manufacturer. There i s also an annual operational cost for switching from black ink cartridges to col or ink cartridges. This annual cost was determined to be $120,000 statewide based on th e estimated number of

vehicles sold in California. This annual cost aver ages out to be $4,000 per manufacturer. Therefore the total annual cost per average manufacturer is the sum of the annualized one time capital cost and the ann ual operational cost which equates to $7,500.

Cost Comparison

The annual cost per average manufacturer ($7,500) f or upgrading to color printers is clearly higher than the annual cost ($3,333) for ordering pre-printed color labels. Manufacturers sell anywhere from 50 to 450,000 vehi cles a year to California citizens. The smaller manufacturers would be requi red to distribute the high capital and operational costs of using color printers over a relatively small number of production vehicles. Staff analyzed this scenario and estimated an annual cost to be as high as $20.00 per vehicle. The larger manuf acturers can distribute these capital and operational costs over a much larger nu mber of production vehicles bringing the annual cost to as little as 2 cents pe r vehicle. This is why staff believes larger vehicle manufacturers will choose t o upgrade to color printers rather than use pre-printed color labels.

C. Total Cost of Implementation

The estimated maximum total annual cost to implemen t this regulation is calculated as the annualized capital cost to upgrade existing printers plus the annual24

operating cost for increasing the label size and us ing color cartridges. For the industry as a whole this equates to $245,000 per ye ar. The initial annualized capital cost for an average manufacturer to impleme nt this regulation is estimated to be $3,500. The annual ongoing cost for increasi ng label size ($667) and using color cartridges ($4,000) for a typical manufacture r is estimated to be $4,667. Therefore the total annual cost, on average, to pri nt the new larger color labels is estimated to be $8,167 ($3,500 + $4,667). This cos t estimate will vary slightly by manufacturer depending on the actual number of asse mbly plants, ports of entry, printers required, and vehicles produced.25



### VIII. Estimated Environmental Benefits

Staff expects that the proposed label will affect t he purchasing choices of some vehicle buyers, however the degree to which this oc curs is not known. If consumers buy vehicles with lower smog indices, smo g emissions will be lower. If they buy vehicles with lower global warming indices , these emissions may also decrease. However, compliance with the current gre enhouse gas emissions standards is based on a fleet average CO 2Equivalent value by each manufacturer. Thus it may be possible that purchase of a cleaner vehicle will allow a manufacturer to produce additional vehicles with hi gher emissions (at presumably a lower cost). This would negate the effect of the l abel resulting in no change in greenhouse gas emissions. Over time however, staff expects that increased awareness of the benefits of purchasing a vehicle w ith low greenhouse gas emissions will result in market pressure to increas e the number of models available with low emissions, with the result being manufactu rer fleet wide emissions will be lower than required by regulation. The increased c onsumer awareness of vehicle greenhouse gas emissions may also encourage purchas ers of other products to buy green.26



### IX. Issues

A. Lead Time Requirements

The vehicle manufacturers have expressed concerns w ith mandating a new label for all

2009 MY vehicles. The first and foremost concern h inges around the fact that all vehicle manufacturers have the ability to introduce 2009 MY vehicles as early as January of 2008. Therefore, there is no way to lab el such early introduction vehicles with a newly regulated label if the regulation itse lf does not become law before these early vehicles are ready for market distribution. The vehicle manufacturers have also stated that a substantial lead time to implement a new label must be considered due to the time required to purchase new label stock or pr inters, restructure existing assembly procedures, and reprogram existing assembly line co mputer language to adapt to the new label format. The following summary illustrate s the main concerns the vehicle manufactures stressed for changing or implementing a new vehicle labeling program.

Staff solicited feedback from the vehicle manufactu rers on actual implementation time once the regulation became law. Staff reviewed thi s feedback and provides the following overview of the implementation process an d estimated processing time:

• Label Database Set-up: Link emission scores with variable label values. (6 months)

• Label Design and Specification: Incorporate new d esign with existing labels and specify ink, durability, paper, etc. (1 month)

• Label/Printer Procurement: Purchase new label fee dstock and if necessary, new printers. (3 months)

• Label Delivery and Implementation: Ship new label feedstock and printers to all assembly plants and ports and integrate new labelin g process into assembly line. (1 month).

Staff notes that the first process, Label Database Set-up, can be accomplished simultaneously with the other processes. However, the last three steps must be accomplished in succession. Therefore, the critica l path for a new label implementation

is estimated to be 6 months. Staff realizes that n ot all vehicle manufacturers operate identically and some variations to this process may occur during implementation, therefore staff recommends adding one additional mo nth to the critical path in order to account for any variations.

Based on this information, staff recommends allowin g at least a 7-month lead time for implementation of the new label requirements once t hey are approved by the Office of

Administrative Law. Staff estimates this will occu r no later than February, 2008. Allowing for a 7-month implementation lead-time, st aff recommends the new label take affect for all vehicles manufactured beginning Octo ber 1, 2008.27

B. Label Size

The vehicle manufacturers have also indicated conce rn about the proposed label size. They’ve stated that increasing the size of the labe l from what they currently produce to the proposed 4 x 6 inches may 1) impact the placeme nt of the label and 2) create visibility problems for consumers wanting to test d rive the vehicle.

Some vehicle manufacturers place the current Smog I ndex Label on the vehicle as a separate label, sized approximately 2.5 x 4 inches, and other vehicle manufacturers place the current Smog Index, sized approximately 1 .25 x 4.25 inches, on the Monroney label. A Monroney label, sized 11 x 17 inches incl udes the vehicle’s options, pricing, fuel economy information and other information. By incorporating the California Smog Index label onto the Monroney label the vehicle man ufacturers have indicated the Smog Index would begin appearing in all 50 states and no t just in California. Unfortunately, the Monroney label already contains a tremendous am ount of consumer information and the available space for a new Environmental Per formance Label is limited. Staff presented a sample of both current industry labels to consumer focus groups held in March 2007, Los Angeles, California. The focus gro ups felt the sample emissions labels were too small and that they would not notic e or read it. Consumers preferred the emission label not be located on the Monroney l abel and preferred the proposed

size of 4 x 6 inches. Staff concluded that maintai ning a minimum label size of 4 x 6 inches is required for consumer awareness and reada bility.

The second issue related to a large label is the po tential obstruction of driver vision for consumers during test drives. The primary concern is for vehicles without rear side windows such as two-seater sports cars and converti bles. Vehicle manufacturers

recommended that a smaller label be authorized for use on such vehicles to limit the already obstructed driver vision from all other fed erally required labels. Staff does not recommend reducing the size of the label in such ca ses because the placement of the

California label is not restricted to side windows only. Like the current Smog Index Label, the proposed 4 x 6 inch label (which is only expanding by an inch or two over the existing label) may also be placed on the windshiel d if there is no space available on the

side windows. There is sufficient windshield area to place the label without interfering

with the driver’s view.28



### X. Alternatives

Thus far no alternative considered by the ARB has b een identified that would be more effective in carrying out the purpose for which the action is proposed or would be as effective and less burdensome to affected private p ersons than the proposed action. The following alternatives were considered in reach ing this conclusion.

A. Alternative 1: Keep Existing Smog Index Label a nd Add a Global Warming Index

One alternative would be to keep the existing Smog Index Label and expand it to add a global warming index. Staff felt this was not the best alternative for two reasons. First, the existing smog index is not well understood by c onsumers and focus group research suggests it needs revision. Second, the label does not have room for adding a new global warming index, and thus a second label for t his index would have to be added. For these reasons a new, larger label is necessary.

Because this alternative requires expanding the exi sting label or adding a new label,

staff assumed there is no cost difference between t his alternative and the one staff is proposing.

B. Alternative 2: Incorporate SmartWay Certificati on Mark

U.S. EPA launched the air pollution and greenhouse gas scores on their Green Vehicle Guide in 2005 to provide consumers with emissions i nformation that allows them to compare the environmental performance of vehicles. In January 2006, the SmartWay

certification mark was added to the Green Vehicle G uide to highlight vehicles that are very good environmental performers relative to othe r vehicles.

The SmartWay certification mark is achieved if a vehicle receives a minimum of a 6 on both the Greenhouse Gas Score and the Air Pollution Score and receives a combined score of 13 or higher. The SmartWay certification mark is shown in Figure X-1.

Figure X-1: U.S. EPA SmartWay Certification Mark

Staff reviewed the SmartWay program and included th e SmartWay certification mark on the new label in focus group discussions. Response to SmartWay was positive and participants liked that the cleanest vehicles were identified using a logo. However ARB and U.S. EPA currently use different methods to det ermine global warming emissions. Staff recommends that the use of the SmartWay certi fication mark on the new label be29

deferred until after the U.S. EPA’s and ARB’s metho ds for scoring global warming gases have been harmonized.

The cost of including the SmartWay certification ma rk is no different than the estimated cost for the proposed label. Staff assumes that mo st manufacturers will upgrade to color printers therefore there would be no addition al cost to print out the color SmartWay logo.

C. Conclusion

Having considered these alternatives, staff conclud es that the proposed regulations are the best alternative because they allow staff to in corporate all previous market research and provide the consumers with a new Environmental Performance Label that will be

noticed.30



### XI. References

California Air Resources Board, Certification Data Reported to the California Air Resources Board, 2005.

California Air Resources Board, Estimated Annual Av erage Emissions, 2005.

California Air Resources Board, Letter to Steve Dou glas, Director, Automobile Manufacturers and letter to John Cabaniss, Director , Association of International Automobile Manufacturers, February 28, 2007.

California Energy Commission Staff Report, “Invento ry of California Greenhouse Gas Emissions and Sinks,” 1990-1999.

San Jose Mercury News, “Survey finds 81% worried ab out global warming,” April 12, 2007.

Schwartz, Cory, “Vehicle Emissions Labeling Focus G roups Qualitative Research, Prepared for the California Air Resources Board, Co nsumer Quest, April 6, 2007.

United States Environmental Protection Agency, www. epa.gov, “Green Vehicle Guide,”

2007.A-1 

### Appendix A – Regulation Language

§ 1965. Emission Control, and Smog Index, and Environmental Performance Labels - 1979 and Subsequent Model-Year Motor Vehicles.

In addition to all other requirements, emission con trol labels are required by the California certification procedures contained in th e “California Motor Vehicle Emission Control and Smog Index Label Specifications for 197 8 through 2003 Model Year Motorcycles, Light-, Medium- And Heavy-Duty Engines And Vehicles,” adopted March 1, 1978, as last amended September 5, 2003, which is i ncorporated herein by reference,

the “California Exhaust Emission Standards and Test Procedures for 2001 and Subsequent Model Passenger Cars, Light-Duty trucks and Medium-Duty Vehicles,” incorporated by reference in §1961(d), the “Califor nia Exhaust Emission Standards and Test Procedures for 2004 and Subsequent Model Heavy -Duty Diesel-Engines and Vehicles,” incorporated by reference in §1956.8(b), the “California Interim Certification Procedures for 2004 and Subsequent Model Hybrid-Ele ctric Vehicle Classes,” incorporated by reference in §1956.8(b) and (d), an d the “California Exhaust Emission Standards and Test Procedures for 2004 and Subseque nt Model Heavy-Duty Otto-Cycle Engines,” incorporated by reference in §1956.8(d). Smog index labels for passenger cars and light-duty trucks shall conform to the “Ca lifornia Smog Index Label Specifications for 2004 Through 2009 Model Year Passenger Cars and Light-Duty Trucks, ” adopted September 5, 2003, as last amended {insert date}

, which is incorporated herein by reference. Environmental Pe rformance labels for passenger cars, light-duty trucks, and medium-duty passenger vehicles shall conform to the “California Environmental Performance Label Specifi cations for 2009 and Subsequent Model Year Passenger Cars, Light-Duty Trucks, and M edium-Duty Passenger Vehicles,” adopted {insert date} , which are incorporated herein by reference. Motorcycles shall meet the requirements of Title 40 Code of Federal R egulations section 86.413-78, as last amended October 28, 1977, which is incorporated her ein by reference.

Note: Authority cited: Sections 39600, 39601, and 43200, and 43200.1, Health and Safety Code. Reference: Sections 39002, 39003, 430 00, 43013, 43018.5 , 43100, 43101, 43102, 43103, 43104, 43107, and 43200, and 43200.1, Health and Safety

Code.

* * * *A-2 State of California

AIR RESOURCES BOARD

CALIFORNIA SMOG INDEX LABEL SPECIFICATIONS

FOR 2004 AND SUBSEQUENT THROUGH 2009 MODEL YEAR

PASSENGER CARS AND LIGHT-DUTY TRUCKS

Adopted: September 5, 2003 Amended: {Insert Date}

Note: This new document is an abbreviated version o f the “California Motor Vehicle Emission Control and Smog Index Label Specification s” (the old Label Specifications document), which has been sunsetted after the 2003 model year. All of the tune-up label requirements in the old Label Specifications document applicable to light-, medium and heavy-duty vehicles and motorcycles are being incorporated into their respective test procedure documents effective with the 2004 model year, making a separate document covering the California tune-up l abel requirements no longer

necessary.

Effective with the 2004 model year, all of the smog index requirements in the old Label Specifications document have been moved to th e new document shown here. Paragraph 1of this new document was previously cont ained in paragraph 11 of the old Label Specifications document; paragraphs 2, 3, and 4 were previously set forth in paragraphs 3.5, 3.5(c), and 3.5(d) respectively of the old Label Specifications document; and Appendix A in this new document is id entical to Appendix A in the old Label Specifications document.A-1 State of California

AIR RESOURCES BOARD

California Smog Index Label Specifications

1. Prohibition . The sale and registration in this state of any c ertified new 2004 and subsequent through 2009 model passenger car or light-duty truck to which a smog index label has not been affixed in accordance with these procedures is prohibited.

2. Requirements . A smog index label made of paper or plastic shal l be securely affixed in a location specified in section 43200 of the Health and Safety Code. The smog index label shall display the smog index for the ve hicle, as specified in section 3 below, and the fleet average smog index, which shall be referr ed to as “The Smog Index of the average new vehicle.” Every model-year, the fleet average smog index shall be updated on the smog index label as specified in section 4 below. The smog index label shall also include information to inform purchasers of the significanc e of the smog index. The smog index label shall take the form set forth in Appendix A o f this document. An alternative label may be used if shown to yield equivalent clarity and if approved in advance by the Executive

Officer.

3. Smog Indices . The following smog indices shall apply to 2004 a nd subsequent through 2009 model-year passenger cars and light-duty trucks 0-8 500 lbs.

GVW:A-2 Enhanced Evap. 2.0g/ diurnal

+ hot soak
test, 0.05 g/mi – running loss
test, at 100,000

miles PCs 0.5 g/

diurnal + hot soak test, 0.05 g/mi – running loss
test, at 150,000

miles LDTs < 6,000

lbs. GVW 0.65 g/ diurnal + hot soak test, 0.05 g/mi – running loss
test, at 150,000

miles LDTs 6,001-

8,500 lbs.

GVW 0.90 g/ diurnal + hot soak test, 0.05 g/mi - running loss
test, at 150,000

miles Evap.

Exempt

LEV I Passenger Cars and Light-Duty Truck 1 (0-3750 lbs. LVW)

LEV 1.00 0.92 0.93 0.94 0.80

ULEV 0.90 0.82 0.83 0.84 0.70

ZEV n/a n/a n/a n/a 0.00

Light-Duty Truck 2 (3751-5750 lbs. LVW)

LEV 1.65 n/a 1.58 1.60 1.45

ULEV 1.51 n/a 1.44 1.45 1.30

Z EV n/a n/a n/a n/a 0.00

LEV II Passenger Cars; Light-Duty Truck 1 (0-3750 lbs. LV W); Light-Duty Truck 2 (3751 lbs. LVW – 8500 lbs. GVWR )

LEV 0.57 0.49 0.50 (0.55) (1) 0.51 (0.57) (1) 0.36

ULEV 0.46 0.39 0.40 0.41 0.26

SULE 0.29 0.21 0.22 0.23 0.09

ZEV n/a n/a n/a n/a 0.00

(1) The smog index in parentheses applies to the option al LEV II LEV standard. Up to 4% of a manufacturer’s light-duty truck 2 fleet with a ma ximum base payload of 2500 lbs. may be certified to a standard of 0.07 g/mi NOx at 50,000 miles.

4. Fleet Average Smog Indices: The following fleet average smog indices shall apply to 2004 and subsequent through 2009 model-year passenger cars and light-duty

trucks 0-8500 lbs. GVW:

2004 2005 2006 2007 2008 2009 2010 and subsequent

1.02 0.80 0.58 0.40 0.38 0.37 0.36

5. Sunset: These specifications will sunset on September 30, 2 008. All passenger cars and light-duty trucks manufactured o n October 1, 2008 and thereafter must comply with the “California Environmental Performan ce Label Specifications” incorporated by reference in Title 13 California Code of Regulat ions § 1965.A-3 APPENDIX A

SMOG EMISSIONS INFORMATION

The Smog Index of this vehicle is The Smog Index o f the average new vehicle is

0.34 0.52

▼ ▼

0.0 0.1 0.2 0.3 0.4 0 .5 0.6 0.7 0.8 0.9 1.0......3.0

◄ CLEANER MORE POLLUTING ►

Note: The Smog Index (SI) indicates the relative le vel of smog-forming pollutants emitted by the vehicle. The lower the SI, the lowe r the vehicle's emissions.A-4

Note for commenters: The entire text of these propo sed specifications is new.

State of California

AIR RESOURCES BOARD

CALIFORNIA ENVIRONMENTALPERFORMANCE LABEL SPECIFIC ATIONS

FOR 2009 AND SUBSEQUENT MODEL YEAR PASSENGER CARS, LIGHT-DUTY TRUCKS, AND MEDIUM-DUTY

PASSENGER VEHICLES

Adopted: {Insert Date}

Note: These specifications shall take effect for al l vehicles manufactured on October 1, 2008 and thereafter. On October 1, 2 008, the Environmental Performance Label will replace the Smog Index Label ; therefore vehicles manufactured on October 1, 2008, and thereafter wil l no longer require a Smog Index Label. Replacing the Smog Index Label with t he new Environmental Performance Label prior to October 1, 2008, is acce ptable.A-5 State of California

AIR RESOURCES BOARD

California Environmental Performance Label Specifi cations

1. Prohibition . The sale and registration in this state of any c ertified new 2009 and subsequent model passenger car, light-duty truck, a nd medium-duty passenger vehicle manufactured on or after October 1, 2008 to which a n Environmental Performance label has not been affixed in accordance with these proce dures is prohibited. Affixing the

Environmental Performance label to a vehicle manufa ctured before October 1, 2008 in lieu of the Smog Index Label is optional, however, each such label optionally affixed and not meeting all specifications herein, is prohibite d.

2. Requirements . An Environmental Performance label made of paper or plastic shall be securely affixed in a location specified in section 43200 of the Health and Safety Code. The Environmental Performance label shall display t he global warming score for the vehicle, as specified in section 3 below. The Envi ronmental Performance label shall display the smog score for the vehicle, as specifie d in section 4 below. The environmental performance label shall take the form set forth in section 7 and

Attachment A of this document.

3. Global Warming Score

(a) The global warming emissions value used to dete rmine a vehicle’s score shall be the CO2Equivalent value as calculated according to Title 13, California Code of Regulations § 1961.1(a)(1)(B) and certified pursuan t thereto.

(b) The average new vehicle CO 2Equivalent combined value is projected to be 360 grams per mile and shall be assigned a score of 5.

(c) The scores in the following table shall apply t o all passenger cars and light-duty trucks 0-8500 pounds GVW and medium-duty passenger vehicles 8,500-10,000

GVW:A-6 Grams per mile

CO 2Equivalent combined Global Warming Score

Less than 200 10

200-239 9

240-279 8

280-319 7

320-359 6

360-399 5

400-439 4

440-479 3

480-519 2

520 and up 1

4. Smog Score

(a) The average new vehicle is assigned an Ultra-Lo w-Emission Vehicle (ULEV) certification and is assigned a score of 5.

(b) The scores in the following table apply to 2009 and subsequent model-year passenger cars and light-duty trucks 0-8500 pounds GVW and medium-duty passenger vehicles 8,500-10,000 GVW:

California Emissions Category - Federal

Bins NMOG + NOx (g/mile) Smog Score

ZEV – Bin 1 0.0 10

PZEV 0.030 9

SULEV – Bin 2 0.030 8

Bin 3 0.085 7

Bin 4 0.110 6

ULEV 0.125 5

LEV – Bin 5 0.160 4 [LEV (option 1) – Bin 6] and [SULEV

(MDPV)] 0.190 – 0.200 3

Bin 7 0.240 2 ULEV (MDPV) – Bin 8a 0.325 1

5. Bi-Fuel, Fuel-Flexible, and Dual-Fuel Vehicles . Notwithstanding Title 13, California Code of Regulations, Section 1961.1(a)(1)(B)(2)(a), the global warming score is based

on exhaust mass emission tests when the vehicle is operating on gasoline.

6. Environmental Performance Label format requireme nts. Detailed printing specifications are given in Attachment A of this pa rt and apply to the provisions in this

section.A-7

(a) Environmental performance labels:

(1) Must be rectangular in shape with a minimum siz e of 6 x 4 inches.

(2) Must be outlined with a 1 point green line and have exactly a 0.5 inch section of green at the top and exactly a 1 inch section of green at the bottom.

(b) Label information. The information on each lab el must meet the following requirements:

(1) The color for the background as specified in At tachment A is PMS 347 C selected from the Pantone Matching System, solid co ated swatch book. When printing in 4 color process the color build fo r the prescribed green is:

Cyan 100 Magenta 0

Yellow 86

Black 3

(2) “Environmental Performance” is the title of the label. This title must be centered in the top section of green. See Attachme nt A for font and color requirements.

(3) The phrase “Protect the environment, choose veh icles with higher scores:” must appear. This phrase must start exactly 2 pica s (0.341 inches) from the left edge of label. See At tachment A for font and color requirements.

(4) “Global Warming Score” is a title that must alw ays appear over its respective scale. This title must start exactly 2 picas (0.341 inches) from the left edge. See Attachment A for font and color requirements.

(5) The number for the Global Warming Score is vari able and must appear over the block it represents on the global warming scale . Scores are determined

in section 3. See Attachment A for font and color requirements.

(6) The number 0 must appear on the left most side of the scale it is under. See Attachment A for font and color requirements.

(7) “Average New Vehicle” must appear under both sc ales at the center point, which is marked by a triangle (item 15 in the style guide). See Attachment A for font and color requirements.

(8) This statement must appear in the lower section of green on every label: “Vehicle emissions are a primary contributor to glo bal warming and smog. Scores are determined by the California Air Resourc es Board based on this

vehicle’s measured emissions. Please visit www.DriveClean.ca.gov for

more information.” This statement must start exact ly 2 picas (0.341 inches) from the left edge. The third row of text will end at the word “visit” and dropA-8 down to a fourth line of text to allow room for ite m 17, the ARB logotype. See Attachment A for font and color requirements.

(9) “higher scores:” must be bolded. See Attachmen t A for font and color requirements.

(10) “Smog Score” must appear over its respective s cale. It shall end exactly 1.5 inches away from the right edge, and shall be flush left with its scale. See Attachment A for font and color requirements.

(11) The number for the Smog Score is variable and must appear over the block it represents on the smog scale. Scores are determ ined in section 4. See Attachment A for font and color requirements.

(12) Squares on the scales. Each square represents a single point on the scale. If a vehicle scores a 5, on a given scale, there wi ll be five squares to represent that score. The first square must be flu sh left with the scale line (Attachment A item 13) and the tenth square must be flush right with item 13, therefore maintaining a distance of exactly 0.042 i nches between squares, even when not all ten squares are present. See Att achment A for size and color requirements.

(13) The scale line must appear on both scales and must be a consistent length. It must always be flush left with its respective ti tle. See Attachment A for font and color requirements.

(14) A number 10 must appear flush right with Attac hment A item 13 of both scales. The number 10 represents the highest score a vehicle can get on

each scale. See Attachment A for font and color re quirements.

(15) A triangle must appear at the center point of both scales representing where the average new vehicle falls on each scale. See A ttachment A for font and color requirements.

(16) The title “Cleanest” must appear flush right a nd underneath the 10 (Attachment A item 14) on both scales. It must alw ays be bold. See Attachment A for font and color requirements.

(17) The California Environmental Protection Agency / Air Resources Board logotype must appear in the lower right hand corner , ending exactly 0.3 inches from the right edge. See Attachment A for f ont and color requirements.

(18) The Drive Clean website ( www.DriveClean.ca.gov ) should always appear in the Myriad Semi-bold within Item 8. See Appendi x A for font and size specifications.A-9 (19) This statement must appear for bi-fueled vehic les: “For bi-fuel vehicles, when using an alternative fuel, scores may improve. See www.DriveClean.ca.gov ”. (20) This statement must appear for fuel-flexible v ehicles: “For flex-fuel vehicles, when using an alternative fuel, scores may improve. See www.DriveClean.ca.gov ”.

(21) This statement must appear for dual-fuel vehic les: “For dual-fuel vehicles, when using an alternative fuel, scores may improve. See www.DriveClean.ca.gov ”.

7. Severability . Each provision of this section is severable, and in the event that any provision of this section is held to be invalid, th e remainder of these specifications

remains in full force and effect.A-10 ATTACHMENT A

ENVIRONMENTAL PERFORMANCE LABEL STYLE REQUIREMENTS

1 Label Background 6 x 4 inches whole; top green: 6 x 0.5 inches; Bottom green: 6 x1 inches; green stroke: 1 point; C olor: PMS 347 C

2 font: Myriad Pro Bold; size: 25 points; color: kn ocked out of green (appears white)

3 font: Myriad Pro Light; size: 15 points; color: B lack

4, 10 font: Myriad Pro Semi-bold; size: 14.4 points ; color: PMS 347 C

5, 11 font: Myriad Pro Semi-bold; size: 19.2 points ; color: Black

6, 14 font: Myriad Pro Light; size: 9.6 points; col or: Black

7 font: Myriad Pro Light; size/leading: 9/10.8 poin ts; color: Black

8 font: Myriad Pro Regular; size/leading: 11.3/13.5 points; color: knocked out of green (appears white)

9 font: Myriad Pro Semi-bold; size: 15 points; colo r: Black

12 size: 0.167 x 0.167 inches; color: Black; distan ce: 0.042 inches apart

13 Scale Line: length: 2.05 inches; stroke: 1 point ; color: Black

15 size: 0.167 x 1.11 inches; color: Black

16 font: Myriad Pro Semi-bold; size: 10.5 points; c olor: Black

17 California Environmental Protection Agency / Air Resources Board logotype: Top Row: font: Myriad Pro Regular; size: 7 points ( Title Case) Bottom Row: font Myriad Pro Regular; size: 12 point s (All Caps) Line weight: 1 point; Color for all: knocked out of green (appears white)

18 www.DriveClean.ca.gov : Font: Myriad Pro Semi-bold Size: 12 points Color: knocked out of green (appears white)

19 Flex-fuel phrase (variable element): font: Myria d Pro Light; size: 9 points;

color: BlackA-11 Environmental Performance LabelA-12 California Environmental Protection Agency

AIR RESOURCES BOARD

CALIFORNIA EXHAUST EMISSION STANDARDS AND TEST PROC EDURES FOR 2001
AND SUBSEQUENT MODEL PASSENGER CARS, LIGHT-DUTY TRUCKS, AND MEDIUM-DUTY VEHICLES

Adopted: August 5, 1999 Amended: December 27, 2000 Amended: July 30, 2002 Amended: September 5, 2003 (corrected February 20, 2004) Amended: May 28, 2004 Amended: August 4, 2005 Amended: June 22, 2006 Amended: [INSERT DATE OF AMENDMENT] Amended: [INSERT DATE OF AMENDMENT]

Note: The proposed amendments to this document are shown in underline to indicate additions and

strikeout to indicate deletions compared to the test procedu res as adopted by the Board on June 22, 2006. Amendments to this document as adop ted on March 22, 2007 as part of the “Rulemaking to Consider Amendments to California’s Emission Warranty Information Reporting and Recall Regulations and Emission Test Procedures,” are indicated by double

underline to indicate additions and double strikeout to indicate deletions compared to the test procedures as amended on June 22, 2006. Existing i ntervening text that is not amended is indicated by “* * * *”. The amendments proposed he re are non-substantive in that they impose no additional or changed requirements beyond those proposed for Section 1965, but are proposed here to maintain consistency.A-13

NOTE: This document is incorporated by reference i n sections 1960.1(k) and 1961(d), title 13, California Code of Regulations (CCR). It conta ins the majority of the requirements necessary for certification of a passenger car, lig ht-duty truck or medium-duty vehicle for sale in California, in addition to containing the e xhaust emission standards and test procedures for these motor vehicles. However, refe rence is made in these test procedures to other ARB documents that contain additional requ irements necessary to complete an application for certification. These other documen ts are designed to be used in conjunction with this document. They include:

1. “California Exhaust Emission Standards and Test Procedures for 2005 and Subsequent Model Zero-Emission Vehicles, and 2001 a nd Subsequent Model Hybrid Electric Vehicles, in the Passenger Car, Light-Duty Truck and Medium-Duty Vehicle Classes” (incorporated by reference in section 1962 , title 13, CCR);

2. “California Evaporative Emission Standards and T est Procedures for 2001 and Subsequent Model Motor Vehicles” (incorporated by r eference in section 1976(c), title 13, CCR);

3. “California Refueling Emission Standards and Tes t Procedures for 2001 and Subsequent Model Motor Vehicles” (incorporated by r eference in section 1978(b), title 13, CCR);

4. OBD II (section 1968, et seq. title 13, CCR, as applicable);

5. “California Smog Index Label Specifications for 2004 through 2009 Model Year Passenger Cars and Light-Duty Trucks ” (incorporated by reference in section 1965, title 13, CCR);

6. “California Environmental Performance Specificat ions for 2009 and Subsequent Model Year Passenger Cars, Light-Duty Tr ucks, and Medium-Duty Passenger Vehicles” (incorporated by reference in 1965, title 13, CCR);

6 7 . Warranty Requirements (sections 2037 and 2038, ti tle 13, CCR);

7 8 . “Specifications for Fill Pipes and Openings of Mo tor Vehicle Fuel Tanks” (incorporated by reference in section 2235, title 1 3, CCR);

8 9 . Guidelines for Certification of Federally Certifi ed Light-Duty Motor Vehicles for Sale in California (incorporated by section 1960.5, title 13, CCR); and

9 10 . “California Non-Methane Organic Gas Test Procedur es,” (incorporated by reference in section 1961(d), title 13, CCR).

The section numbering conventions for this document are set forth in Part I, section A.3 on page A-2.A-14

CALIFORNIA EXHAUST EMISSION STANDARDS AND TEST PROC EDURES
FOR 2001 AND SUBSEQUENT MODEL PASSENGER CARS, LIGHT-DUTY TRUCKS AND MEDIUM-DUTY V EHICLES

The provisions of Subparts B, C, and S, Part 86, T itle 40, Code of Federal Regulations, as adopted or amended on May 4, 1999 o r as last amended on such other

date set forth next to the 40 CFR Part 86 section t itle listed below, and to the extent they pertain to exhaust emission standards and test proc edures, are hereby adopted as the

“California Exhaust Emission Standards and Test Pro cedures for 2001 and Subsequent Model Passenger Cars, Light-Duty Trucks, and Medium -Duty Vehicles,” with the following exceptions and additions.

PART I: GENERAL PROVISIONS FOR CERTIFICATION AND IN -USE

VERIFICATION OF EMISSIONS

* * * *

C. General Requirements for Certification

* * * *

3. §86.1807 Vehicle Labeling

* * * *

3.3 California Labeling Requirements.

3.3.1. In addition to the federal requirements set forth in §86.1807, labeling shall conform with the requirements specified in se ction 1965, title 13, CCR, and the “California Smog Index Label Specifications for 200 4 through 2009 Model Year Passenger Cars and Light-Duty Trucks ” and “California Environmental Performance Specifications for 2009 and Subsequent Model Year P assenger Cars, Light-Duty Trucks, and Medium-Duty Passenger Vehicles” as incorporated by reference in section 1965, title 13, CCR. In cases where there is conflict with the federal label specifications, the California requirements shall a pply.

* * * *A-15 PROPOSED REGULATION ORDER

Set forth below are the proposed amendments to titl e 13 of the California Code of Regulations. Proposed amendments are shown in unde rline to indicate additions and

strikeout to indicate deletions. Amendments to §1961 that were adopted by the Board on March 22, 2007 as part of the “Rulemaking to Consid er Amendments to California’s Emission Warranty Information Reporting and Recall Regulations and Emission Test Procedures,” but which have not yet been approved b y the Office of Administrative Law are

indicated in double underline to indicate additions and double strikeout to indicate deletions. The amendments proposed here are non-substantive in that they impose no additional or changed requirements beyond those proposed for Sect ion 1965, but are proposed here to maintain consistency.

§ 1961. Exhaust Emission Standards and Test Proced ures - 2004 and Subsequent Model Passenger Cars, Light-Duty Trucks, and Medium -Duty Vehicles.

Introduction. [No change.]

Sections (a) through (c). [No change.]

(d) Test Procedures. The certification requirements and test procedur es for determining compliance with the emission standards in this section are set forth in the

“California Exhaust Emission Standards and Test Pro cedures for 2001 and Subsequent Model Passenger Cars, Light-Duty Trucks, and Medium -Duty Vehicles,” as amended June
22, 2006 [i nsert date of amendment for the March 22, 200 7 e mission warranty rulemaking ] [insert date of amendment for this rulemaking] , and the “California Non-Methane Organic Gas Test Procedures,” as amended July 30, 2002, whi ch are incorporated herein by reference. In the case of hybrid electric vehicles and on-board fuel-fired heaters, the certification requirements and test procedures for determining compliance with the

emission standards in this section are set forth in the “California Exhaust Emission Standards and Test Procedures for 2005 and Subseque nt Model Zero-Emission Vehicles, and 2001 and Subsequent Model Hybrid Electric Vehic les, in the Passenger Car, LightDuty Truck and Medium-Duty Vehicle Classes,” incorp orated by reference in section 1962.

Section (e). [No change.]

Note: Authority cited: Sections 39500, 39600, 396 01, 43013, 43018, 43101, 43104 and 43105, Health and Safety Code. Reference: Sections 39002, 39003, 39667, 43000, 43009.5, 43013, 43018, 43100, 43101, 43101.5, 43102, 43104, 43105, 43106, 43204, and 43205, Health and Safety Code.B-1 

### Appendix B – Example Existing Smog Index LabelsB-2C-1 

### Appendix C - Technical Analysis

This Appendix focuses on the technical analysis ARB staff underwent to develop a new Smog and Global Warming scoring system for developi ng a new vehicle emissions label. This Appendix also focuses on the detailed analysis of the economic impact of replacing existing black and white printers with color printe r to print color labels.

A. Smog Score

In developing a new Smog scoring system, staff look ed at California’s LEV II regulations that

will be in affect for all 2009 MY vehicles. Table C-1 represents the California LEV II

emission certification limits for the 2009 MY and t he current air pollution score used by the

U.S. EPA.

Table C-1: California Light-Duty Vehicle Emissions Standards for Air Pollutants

California LEV II Program

Emission Limits at Full Useful

Life
(120,000 miles) Maximum Allowed Grams per

Mile Standard Model

Year Vehicles

NOx NMOG NMOG+NOx Current Air

Pollution

Score

ZEV 2004+ PC, LDT 8500 lbs or less 0.00 0.000 0.000 10

PZEV* 2004+ PC, LDT 8500 lbs or less 0.02 0.010 0.030 9.5

SULEV 2004+ PC, LDT 8500 lbs or less 0.02 0.010 0.0 30 9

ULEV 2004+ PC, LDT 8500 lbs or less 0.07 0.055 0.12 5 7
LEV 2004+ PC, LDT 8500 lbs or less 0.07 0.090 0.160 6
LEV option 1 2004+ PC, LDT 8500 lbs or less 0.10 0. 090 0.190 5

SULEV 2004+ MDV 8501-10,000 lbs 0.10 0.100 0.200 4

ULEV 2004+ MDV 8501-10,000 lbs 0.20 0.143 0.343 3

LEV 2004+ MDV 8501-10,000 lbs 0.20 0.195 0.395 2

SULEV 2004+ MDV 10,001-14,000 lbs 0.20 0.117 0.317 3

ULEV 2004+ MDV 10,001-14,000 lbs 0.40 0.167 0.567 2

LEV 2004+ MDV 10,001-14,000 lbs 0.40 0.230 0.630 1

* Vehicles certified as PZEV have a 150,000 useful life, zero evaporative emissions and a manufacturer 15 years/150,000 miles emissions warra ntee.

Table C-1 includes California certification limits for all vehicles up to 14,000 lbs. GVWR. However, AB 1229 only requires labels to be applied to vehicles up to 10,000 lbs. GVWR.

Therefore the last three shaded rows of this table are not applicable to the labeling requirements.

The applicable NMOG+NOx certification values range from 0.0 (g/mile) being the cleanest to 0.395 (g/mile) being the dirtiest. This 2009 ra nge of certification levels is less than the current range used by the U.S. EPA Green Vehicle Gu ide for scoring air pollution; therefore,C-2

a new scoring system must be developed. In keeping with the philosophy of harmonizing the new California scale with the U.S. EPA scale, s taff took a look at the Federal certification levels for the 2009 model year. Table C-2 illustra tes these values along with the current air pollution scores for each certification level.

Table C-2: U.S. EPA Light-Duty Vehicle Emissions St andards for Air Pollutants

Federal Tier 2 Program

Emission Limits at Full Useful

Life
(100,000-120,000 miles) Maximum Allowed Grams per

Mile Standard Model

Year Vehicles

NOx NMOG NMOG+NOx Current Air

Pollution

Score

Bin 1 2004+ LDV, LLDT, HLDT, MDPV 0.00 0.000 0.000 10

Bin 2 2004+ LDV, LLDT, HLDT, MDPV 0.02 0.010 0.0 30 9

Bin 3 2004+ LDV, LLDT, HLDT, MDPV 0.03 0.055 0.085 8

Bin 4 2004+ LDV, LLDT, HLDT, MDPV 0.04 0.070 0.110 7

Bin 5 2004+ LDV, LLDT, HLDT, MDPV 0.07 0.090 0.160 6

Bin 6 2004+ LDV, LLDT, HLDT, MDPV 0.10 0.090 0.190 5

Bin 7 2004+ LDV, LLDT, HLDT, MDPV 0.15 0.090 0.240 4

Bin 8a 2004+ LDV, LLDT, HLDT, MDPV 0.20 0.125 0.325 3

Bin 8b 2004-2008 HLDT, MDPV 0.20 0.156 0.356 3

Bin 9a 2004-2008 LDV, LLDT 0.30 0.090 0.390 2

Bin 9b 2004-2008 LDT2 0.30 0.130 0.430 2

Bin 9c 2004-2008 HLDT, MDPV 0.30 0.180 0.480 2

Bin 10a 2004-2008 LDV, LLDT 0.60 0.156 0.756 1

Bin 10b 2004-2008 HLDT, MDPV 0.60 0.230 0.830 1

Bin 10c 2004-2008 LDT4, MDPV 0.60 0.280 0.880 1

Bin 11 2004-2008 MDVP 0.90 0.280 1.180 0

Again, the last eight shaded rows (Bin8b-Bin 11) in table C-2 will not apply to 2009 model year vehicles and the range of certification levels will be reduced to those identified in the

non-shaded lines.

Table C-2 represents eight certification levels for all vehicles manufactured up to 10,000 lbs. GVWR. The certification values for NMOG+NOx range from 0.0 (g/mile) being the cleanest to 0.325 (g/mile) being the dirtiest. Like the Cal ifornia table, this 2009 range of certification levels is less then the current range used by the U .S. EPA Green Vehicle Guide to score air pollution; therefore, a new scoring system must be developed. The best way to develop a new scoring system is to merge the California certi fication levels and the Federal certification levels into one table. Table C-3 rep resents these two certification tables merged together.

It should be noted that in 2009, the applicable emi ssion standards for California MDPVs are less stringent than the dirtiest federal Bin 8a sta ndards as shown in table C-3. However, California regulations specify that when this occur s, the “cleaner federal vehicle” must be sold in California. Consequently, no 2009 MY MDPVs are expected to be certified to LEVC-3

(MDPV) or ULEV (MDPV) standards in California. The refore, only the certification levels

identified in the non-shaded rows of Table C-3 woul d be applicable in the 2009 MY:

Table C-3: 2009 Federal and California Combined Cer tification Levels

Emissions Category NMOG + NOx (g/mile)

ZEV – Bin 1 0.000

PZEV – SULEV – Bin 2 0.030

Bin 3 0.085

Bin 4 0.110

ULEV 0.125

LEV – Bin 5 0.160 LEV (option 1) – Bin 6 0.190 SULEV (MDPV) 0.200

Bin 7 0.240

Bin 8a 0.325 ULEV (MDPV) 0.343 LEV (MDPV) 0.395

After removing the bottom two rows, Table C-3 does provide 10 distinct certification levels so applying a scale from 1-10 would be simple. How ever, there are important differences

between the SULEV and PZEV California certification requirements. First, the full-useful life for a SULEV is 120,000 miles versus 150,000 miles f or a PZEV. Second, a PZEV must be certified to “zero” evaporative emissions standards and carry a 15 year/150,000 mile extended emissions warranty, which is not required for the SULEV standard. This is why the PZEV certification level is assigned a score of 9.5 in the current U.S. EPA air pollution scoring system. Staff therefore recommends that th e PZEV certification level be treated as a distinct certification level and be assigned a sc ore better than a vehicle certifying to SULEV standards. By separating the PZEV from the S ULEV certification levels, the

combined California and Federal certification table looks as shown in Table C-4.

Table C-4: 2009 Federal and California Combined Cer tification Levels with PZEV Category

Emissions Category NMOG + NOx (g/mile)

ZEV – Bin 1 0.000

PZEV 0.030

SULEV – Bin 2 0.030

Bin 3 0.085

Bin 4 0.110

ULEV 0.125

LEV – Bin 5 0.160 LEV (option 1) – Bin 6 0.190 SULEV (MDPV) 0.200

Bin 7 0.240 ULEV (MDPV) – Bin 8a 0.325C-4

Based on table C-4, there are 11 total certificatio n levels so applying a simple 1-10 would require combining two levels or eliminating one lev el. One option is to find the two certification levels that are separated by the leas t amount and combine those two levels into one. This option makes sense if the separation is small relative to all other differences between certification levels or at least compared t o the average separation between certification levels. Looking at table C-4, we see that the minimum separation between certification levels takes place between the LEV (o ption 1) – Bin 6 certification level at 0.190 (g/mile) and the SULEV (MDPV) certification level a t 0.200 (g/mile). This small difference of 0.010 (g/mile) is relatively small compared to the average difference of 0.039 (g/mile). Therefore, combining these two certification levels into one would yield a Smog Score

distribution with 10 levels as shown on Table C-5.

Table C-5: 2009 Smog Score by Certification

California Emissions Category –

Federal Bins NMOG + NOx (g/mile) Possible 2009

Smog Score

ZEV – Bin 1 0.0 10

PZEV 0.030 9

SULEV – Bin 2 0.030 8

Bin 3 0.085 7

Bin 4 0.110 6

ULEV 0.125 5

LEV – Bin 5 0.160 4 [LEV (option 1) – Bin 6] and [SULEV (MDPV)] 0.190 – 0.200 3

Bin 7 0.240 2 ULEV (MDPV) – Bin 8a 0.325 1

Applying this proposed Smog scoring system to all 2 007 MY California certification data yielded the distribution of Smog scores as shown on Figure C-1.

The statistical average of smog-forming (NMOG + NOx ) emissions calculated based on the

emission standards to which 2007 MY vehicles certif y is 0.139 (g/mile). This statistical average places the average vehicle available on the market today somewhere between a Smog score of 4 and 5. For the 2009 MY, it is expe cted that a statistically average vehicle

sold in California will be a ULEV certification and will receive a score of 5.

An alternate Smog scoring system can be developed u sing a straight line scale based on the range (dirtiest to cleanest) of emission levels and let the certification levels fall into whatever score they achieve. In this case the rang e is 0.325 – 0.0 (g/mile). Realizing that a Smog score of 10 must be reserved for a true zero e mission vehicle, this leaves nine remaining Smog scores that must be divided up equal ly into an overall range of 0.325 (g/mile). Therefore:

0.325/9 = 0.036 increments/scoreC-5

The straight line scale applied to the 2009 Certifi cation levels and possible Smog Scores is

shown on Table C-6.

Figure C-1: Distribution of Smog Scores Based on 20 07 Model Year Certifications

Table C-6: Possible 2009 Smog Score by Straight Lin e Analysis

California Emissions Category -

Federal Bins NMOG + NOx (g/mile) Straight Line

Scale Possible 2009

Smog Score

ZEV – Bin 1 0.000 0 10

PZEV 0.030 0.001-0.036 9.5*

SULEV – Bin 2 0.030 9

0.037-0.072 8

Bin 3 0.085 0.073-0.108 7

Bin 4 0.110 0.109-0.144 6

ULEV 0.125 6

LEV – Bin 5 0.160 0.145-0.180 5 LEV (option 1) – Bin 6 0.190 0.181-0.216 4 SULEV (MDPV) 0.200 4

Bin 7 0.240 0.217-0.252 3

0.253-0.288 2 ULEV (MDPV) – Bin 8a 0.325 >0.289 1

* A Smog Score of 9.5 was given to vehicles certify ing to the California PZEV standards based on the longer useful life, “zero” evaporative emissions requirements, and extended warranty for these vehicles compared to vehicles ce rtifying to the SULEV standards. 

### 0 20 40 60 80 100 120 140 160 180

1 2 3 4 5 6 7 8 9 10 # Certifications per Score

Smog ScoreC-6

Staff looked at table C-6 and noticed two distinct issues. First, there are two instances where a single Smog score overlaps multiple certifi cation levels. The Smog score of 4 appears twice in the table as does the Smog score o f 6. This overlap is due primarily to the

small incremental difference between a few certific ation levels. For Example, the difference

between the Federal Bin 4 certification level of 0. 110 (g/mile) and the California ULEV certification level of 0.125 (g/mile) is only 0.015 (g/mile) allowing these two certification

levels to achieve the same score of 6. The same ho lds true for the California LEV (option 1) certification level (which is also the Federal Bin 6 certification level) of 0.190 (g/mile) and the California SULEV (MDPV) certification level of 0.20 0 (g/mile). The relative difference between these two certification levels is only 0.01 0 (g/mile) allowing them both to achieve the same Smog score of 4.

The second issue with this Smog score option is tha t some scores are not assigned to a certification level and would not appear on the new label. Looking at table C-6 staff noticed that the Smog scores of 8 and 2 are not assigned to a certification standard. This is due to the fact that there is a relatively large differenc e between certification levels where the Smog score of 8 and 2 do not appear.

Applying this proposed Smog scale to the model year 2007 California certification data yielded the model based distribution of Smog scores as shown in Figure C-2.

Figure C-2: Distribution of Smog Scores Based on 20 07 Model Year Certifications

In this case, the statistical average of 0.139 (g/m ile) receives a score of 6 on the Smog scale. This average score of 6 on a scale from 1-1 0 did not seem appropriate as most consumers associate the number 5 as being the avera ge on a scale from 1-10,

Staff looked at the two distinct distributions of s cores (figures 11.1 and 11.2) and noticed that they appear similar except for the simple chan ge of smog score assignments on the 

### 0 20 40 60 80 100 120 140 160 180

1 3 4 5 6 7 9 9.5 10 # Certifications per Score

Smog ScoreC-7

lower axis. Staff realizes that these distribution s are for 2007 MY California certifications and will probably look a bit different for the 2009 MY California certifications as vehicle manufacturers continue to certify to higher standar ds. Therefore, the simplest and best way to assign smog scores that will allow for the conti nued increase of cleaner vehicles is to select the smog scale that is based on the certific ation analysis rather than the straight-line analysis of certification data. The certification analysis scale as shown on Table C-5 provides a true 1-10 scoring for the entire range o f certification levels and there are no potential for gaps (missing smog score numbers) in the scale.

B. Global Warming Score

In order to develop a scale for global warming emis sions, the expected certification data for global warming emissions from each vehicle model mu st be known. This information is not required for the 2007 model year by ARB and therefo re not all global warming gasses are available for analysis. However, staff was able to access the California certification data base for all 2007 Executive Order (EO) California c ertifications. After filtering out those vehicles that are not required to get an emissions label, the data contained 368 EO certifications. Of those certifications, 137 certi fications voluntarily contained CO 2 data and

there were no certifications that contained CH 4 , N 2 O or A/C refrigerant data. The 137

certifications that contained CO 2 data represent a 37% sample. A 37% sample size is adequate for a statistical analysis of the data as long as the sample size is random. A quick look at the auto manufacturers that provided CO 2 data revealed that the sampling did appear to be random as 16 vehicle manufacturers did provide CO 2 data and 14 vehicle

manufacturers did not.

Since some vehicle manufacturers did not voluntaril y provide CO 2 data, staff formally requested the voluntary submission of all global wa rming emissions – CO 2 , N 2 O, CH 4 , and A/C refrigerants – from the manufacturers in order to develop a more complete dataset. The response ARB received from the vehicle manufacturer s was minimal. Three vehicle manufacturers voluntarily submitted the information as requested, one of which had already voluntary included CO 2 data with the 2007 certification data. However, t hrough this request,

ARB staff was made aware of a Federal certification data spreadsheet available to the general public that contained CO 2 information. This spreadsheet can be found at: www.epa.gov/otaq/cert/mpg/testcars/database/07tstca r.csv

.

Staff reviewed the Federal certification spreadshee t and found certification data for HC, CO,

CO 2 , NOx, PM, as well as mile per gallon fuel economy (MPG). The Federal certification spreadsheet provided certification data for both ci ty and highway testing values of these

emissions. The Federal certification data did not provide certification data for N 2 O, CH 4 or A/C refrigerants. Prior to developing a CO 2Equivalent dataset for either the California or Federal Certification data, staff wanted to look at a direct comparison between the California dataset and the Federal dataset. In doing so, staf f found that the information for similar makes and models of vehicles where very close but n ot identical. Therefore, a CO 2 combined dataset was calculated and analyzed for bo th California and Federal databases using the 55% city and 45% highway driving ratio.

Taking the additional global warming emission infor mation provided by the three manufacturers and updating the California certifica tion dataset; staff was able to increaseC-8

the sample size from 37% to 40%. With 40% of the c ertifications actually reporting CO 2 , staff was able to statistically evaluate the data w ith a 90% level of confidence that the sample size available would adequately represent th e entire population. Table C-7 represents the data distribution for both the Calif ornia and Federal CO 2 combined

certification data.

Table C-7: California and Federal CO 2 Combined Data Distribution

In Table C-7, the first California column represent s CO 2 combined data that was voluntarily provided by the automobile manufacturers and includ es passenger cars, light-duty trucks and medium-duty passenger vehicles. Staff looked a t the certification data available from

the Federal database and noticed that the numbers a re slightly different. This is because

the federal database does not include data on mediu m-duty passenger vehicles (passenger vehicles from 8,500 lbs. to 10,000 lbs. GVWR). The refore, staff developed another

California dataset for CO 2 combined certifications removing the data for all medium-duty passenger vehicles. The second column in Table C-7 above is the result. In comparing the last two columns, staff noticed that the informatio n is extremely similar. The minimum for

both California and Federal is almost identical. T he maximum is somewhat less in California which indicates that California vehicles are typica lly cleaner. And the average for the

Federal and California certification data is extrem ely close as well. Based on this comparison, ARB staff reasoned that although Califo rnia had only 40% of the certification data for all 368 EOs issued, the 40% sample size wa s adequate to represent the entire population of California certified vehicles.

Staff also tried to look at the contributions of N 2 O, CH 4 , and A/C refrigerants based on the limited feedback form the manufacturers to compare the CO 2 combined certification values

to the CO 2Equivalent combined values. Of the three manufacturers that provided addition global warming emissions to ARB, only one manufactu rer provided all four (CO 2 , N 2 O, CH 4 , and A/C refrigerant) emissions certification data a s requested. This manufacturer, however, only has two California certifications on file for 2007. Another manufacturer provided only

CO 2 and CH 4 emissions certification data and this manufacturer has 19 California certifications for 2007. The last manufacturer pro vided only CO 2 data and staff incorporated

this data into the California CO 2 dataset.

Because of the lack of data for N 2 O, CH 4 , and A/C refrigerants, staff decided there was not enough information to factor these emissions into t he development of a global warming scoring system at this time. Therefore, all analys es from this point on are predicated on the CO 2 combined (g/mile) California
(with MDPV data) California
(without MDPV data) Federal

Minimum 130 130 133

Maximum 874 570 662

Range 744 440 529

Average 358 355 348C-9

analysis of 2007 CO 2 data alone. Table C-8 represents only the Califor nia CO 2 combined

dataset and not the CO 2Equivalent combined dataset.

Table C-8: California 2007 CO 2 Combined Certification Data

CO 2 Combined (g/mile)

Minimum 130

Maximum 874 Range 744 Average 358

This distribution represents a range of CO 2 emissions of 744 (g/mile) with a minimum of 130 (g/mile) and a maximum of 874 (g/mile). Similar to the Smog scoring system, staff was able to develop a proposed global warming scoring system using an unbiased, straight line, equitable distribution of scores based on the entir e range of CO 2 emissions. By taking the range of 744 (g/mile) and equally dividing that ran ge into 10 scores, we can determine the

number of increments associated with each score. S ince CO 2 emission are not certified to specified individual levels, as in the case of smog forming emission, the use of a linear scale may be appropriate. This equates to:

744/10 = 74 increments/score

Table C-9 represents a possible global warming scor ing system based on this analysis.

Table C-9: Possible 2009 Global Warming Scores Base d on CO 2 Emissions

Global Warming

Score CO 2 Grams

per mile

10 Less than 205

9 205-279

8 280-354

7 355-429

6 430-504

5 505-579

4 580-654

3 655-729

2 730-804

1 805 and up

Now applying these scores to the 2007 MY California certifications we can see how the certifications are distributed, Figure C-3 graphica lly illustrates this distribution.C-10

In Figure C-3, staff realized that the scores are w eighted more toward the high end of the scale. This means that the majority of the vehicle s will be given scores of 7, 8, and 9. Also, the average global warming emissions of 358 (g/mile ) receives a score of 7, which is not intuitive when looking at a scale from 1-10. Most consumers view the average as being in the middle of the scale or achieving a score of 5 o n a 1-10 scale. Staff took a closer look at this data to see why the distribution was skewed to the high end of the scale. By breaking

down the data set into actual vehicle classificatio ns (i.e., passenger cars, light-duty trucks and medium-duty passenger vehicles), one can see th e actual number of certifications in

each class. Table C-10 illustrates the actual numb er of certifications by vehicle

classification.

Figure C-3: Distribution of Global Warming Scores B ased on 2007 Model Year

Certifications

Table C-10: Distribution of California Certificatio ns Based on Vehicle Classification

Vehicle Certification

Classification Number of Certifications Number of Certifications with Voluntary CO 2 data Passenger Car 226 94 Light-Duty Trucks 136 50 Medium-Duty Passenger

Vehicles 6 3

Totals 368 147

From Table C-10 staff realized that of the total 36 8 Executive Order Certifications on file for the 2007 MY, 61% are passenger cars, 37% are light- duty trucks, and only 2% are mediumduty passenger vehicles, Figure C-4 illustrates thi s distribution. 

### 0 5 10 15 20 25 30 35 40 45 50

1 2 3 4 5 6 7 8 9 10 # Certifications per Score

Global Warming Score

Avg.C-11 PC

LDT

MDPV Figure C-4: Distribution of Vehicle Classification Based on California EO

Certifications.

With 61% of all certifications being passenger cars , which typically produce less global warming emissions than light-duty trucks and medium -duty passenger vehicles, staff expected to see higher global warming scores for pa ssenger vehicles. Therefore, with 61% of the certifications receiving the higher global w arming scores, staff reasoned that the scale would be skewed to the high end. Figure C-3 justif ies this scenario. ARB staff than decided to look at the certification data using a more stat istical analysis to see how the data was distributed around the average of 358 (g/mile). AR B staff also wanted to perform a statistical analysis including standard deviations of the CO 2 data that was available through the Federal certification database and compare thes e results. The federal database

contained over 700 CO 2 values which theoretically should provide a good c omparison for the California certification data. Table C-11 repr esents the two statistical comparisons.

Again, the first California column represents a sta tistical analysis including standard

deviations of all CO 2 data that was voluntarily provided by the automobi le manufacturers and includes passenger cars, light-duty trucks and medium-duty passenger vehicles. In comparing the last two columns, one can see that th e information is extremely similar. The average and the standard deviation for the Federal and California certification data are very close to being equal. The standard deviation only increases significantly when the addition

of the MDPV data is introduced. Based on this find ing, ARB staff decided to develop a global warming scale that represented a normal dist ribution of certifications. Realizing that the MDPV data contribution is only 2% of the entire certification dataset, staff decided to use a standard deviation that more closely represented the majority of certifications rather than the minority. 

## 61% 37%

2%

Passenger
Cars Light-Duty

Trucks

Medium-Duty Passenger

VehiclesC-12

Table C-11: Statistical Distribution of California and Federal CO 2 Data

By using the average of 360 (g/mile) and applying a standard deviation of 80 (g/mile) – the standard deviation we would expect to see given a f ully populated data set, similar to the standard deviation of the Federal fully populated d ata set – a scale can be developed based on two standard deviations of the population that w ill account for 95% of all vehicle certifications. Those falling out side of the two standard deviations would be considered

extreme and would achieve the “best” and the “worst ” score. In the case of a scale from 1-10, the “best” would be scored a 10 and the “wors t” would be scored a 1 and the average would be scored a 5. All other scores would repres ent an equal division of the remaining range of possible CO 2 emissions. This means that the remaining scores ( 2-9) will fall within two standard deviations of the average and should m ake up 95% of all certifications. Applying this principle to the dataset we would exp ect to see a normal distribution. Figure

C-5 shows what a normal distribution would look lik e based on the number of standard distributions away from the average.

Using the average of 360 (g/mile) and going out two standard deviations, 2 x 80 = 160 (g/mile), ARB staff was able to set the extremes at 200 and 520 (g/mile). Therefore, any vehicle certifying to a global warming emissions le vel of 200 (g/mile) CO 2 or less would get a score of 10. Likewise, any vehicle certifying to a global warming emissions level of 520 (g/mile) CO 2 or more would get a score of 1. All other scores would be given to vehicle certifications in the range between 520 and 200 whi ch is 320 (g/mile). By taking the range of 320 (g/mile) and equally dividing that range int o the remaining 8 scores (i.e., scores 2-9),

we can determine the number of increments associate d with each score. This equates to:

320/8 = 40 increments/score

Applying this scale to produce a global warming sco ring system is illustrated in Table C-12.

Applying this global warming score to the 2007 mode l California certification dataset yields the distribution of scores as shown in Figure C-6. Staff recognized that the scores are more normally distributed indicating a more precise dist ribution of global warming scores. The spike at the low end of the scale represents the ad dition of the medium-duty passenger

vehicles to the certification data and should level out over time as those vehicles achieve reduced global warming emissions. CO 2 combined (g/mile) California
(with MDPV) California
(without MDPV) Federal

Minimum 130 130 133

Maximum 874 570 662

Range 744 440 529

Average 358 355 348

Standard Deviation 101 81 76C-13 Figure C-5: Diagram of a Normal Distribution of Sco res

Table C-12: Possible 2009 Global Warming Scores Bas ed on CO 2 Emissions

Global Warming

Score CO 2 Grams

per mile

10 Less than 200

9 200-239

8 240-279

7 280-319

6 320-359

5 360-399

4 400-439

3 440-479

2 480-519

1 520 and up

Staff therefore recommends using a global warming s core based on a statistical analysis of the global warming certification data. In the 200 9 MY, per AB1493 (greenhouse gas regulation), vehicle certifications must include CO 2Equivalent combined data from which a global warming score can be assigned. Staff recomm ends that the values depicted on Table C-12 be adopted for establishing the global w arming scores used on the label. 200 360 520C-14

Figure C-6: Distribution of Global Warming Scores B ased on 2007 Model Year

Certifications

C. Color Printer Economic Impact

This section focuses on the detailed economic impac t imposed on vehicle manufacturers to increase the label size and upgrad e to color printers. Through site visits and conversations with manufacturers, staff was able to identify the types of printers used for labeling purposes. Staff researc hed the replacement cost of new color printers and found that the average cost for an ind ustrial laser jet color printer (e.g. HP 9500) is $6,000. In addition, the cartridge replac ement cost runs about $1,000 for all four cartridges, because most color printers use mu ltiple (3 color and 1 black) cartridges. Each set of cartridges should print ou t 25,000 labels before all four may need replacement. Staff also researched the cost o f an industrial black ink laser jet printer, comparable to the ones used by vehicle man ufacturers today. The average cost of these printers is around $5,000 (e.g. HP 90 00). However, the cost of a replacement black ink cartridge is around $270 per cartridge. Like the color cartridges, the black ink cartridges should print out around 25 ,000 - 30,000 labels before needing replacement.

1. Total Statewide Costs to Comply with Regulation

The estimated incremental cost increase of upgradin g existing black ink label printers to color label printers is estimated to be $1,000 per printer. These label printers are only required at the point of final assembly. Staff est imated the total number of final 

### 0 5 10 15 20 25 30

1 2 3 4 5 6 7 9 10 # Certifications per Score

Global Warming Score

Avg.C-15

assembly plants in North America to be 76. However , vehicles that are imported to the United States may have their labels printed and ins talled at the port.

The State of California has 3 major ports of entry where vehicle manufacturers would most likely chose to import products. These ports are San Diego, Long Beach/Los Angeles, and San Francisco/Oakland. Staff did not account for ports in other states on

the west coast or east coast because staff assumes that vehicles sold in California would most probably enter through one of the three major California ports for

distribution. Discussions with the manufacturers i ndicated that typically, only two of the three major California ports are used to import veh icles into the state. Staff however,

assumed a worst case scenario of each manufacturer using all three major ports in California. Smaller manufacturers building approxi mately 1,000 vehicles per year or less would most likely utilize only one, or at most , two port(s) of entry. Applying this scenario, staff than estimated the total number of facilities that print and apply vehicle

labels to be 149.

Staff also assumed that a manufacturer would have t o purchase two printers for each assembly facility or port to print a label because one printer is typically used as an emergency backup. Likewise, smaller manufacturers building approximately 1,000 vehicles per year or less would most likely utilize only one printer for labeling purposes because the annual production would not justify the need for a backup printer. Therefore, the industry wide total number of printe r replacements is estimated to be 286. At the $1000 incremental cost increase per pr inter, this equates to a total one time capital cost of $286,000 for the industry as a whol e. The incremental cost increase per manufacturer ranged from $1,000 to $52,000 with an average cost of $9,533, or rounded up to $10,000.

This cost represents a one-time capital cost to the manufacturers therefore staff applied a capital recovery factor to annualize these costs. Assuming the useful life of a printer to be 3-5 years, staff used a conservative 3-year r eplacement cycle and a 5% real discount rate to annualize the one-time capital inv estment. This equates to an annualized statewide cost to upgrade printers of $1 05,000 for the industry as a whole. The annualized cost per manufacturer ranged from $3 76 to $19,095 with an average cost of $3,500.

Staff also assumed there is an operational cost dif ference between black ink and color printers. The differential cost between printers i s assumed to be the cost difference between replacement cartridges in going from a blac k ink cartridge to color cartridges. The difference turns out to be approximately $730 a nd only occurs after 25,000 prints or 25,000 vehicles. Staff felt that 25,000 prints from one cartridge might be an optimistic value used by the cartridge manufacturer therefore staff used half this amount, 12,500 prints, as a replacement cycle. App lying this replacement cycle to the increased cost for color cartridges ($730), staff w as able to calculate a per vehicle cost of 6 cents per vehicle. Therefore, multiplying thi s cost by the approximately 2 million annual vehicle sales equates to a $120,000 annual o perating cost for the industry as a whole. The operating cost per manufacturer ranged from $43 to $62,200 annually, depending on production volume, with an average cos t of $4,000.C-16

The total annual cost to implement this regulation is calculated as the annualized capital cost to upgrade existing printers plus the annual operating cost for increasing the label size and using color cartridges. For the industry as a whole this equates to $245,000 per year or $735,000 over a 3-year period. The initial annualized capital cost for a typical manufacturer to implement this regula tion is estimated to be $3,500. The annual ongoing cost for increasing label size and u sing color cartridges for a typical manufacturer is estimated to be $4,667. These cost estimates will vary slightly by manufacturer depending on the actual number of asse mbly plants, ports of entry, printers required, and vehicles produced.D-1 

### Appendix D - Other Vehicle Labels

The United States Environmental Protection Agency ( U.S. EPA) in conjunction with the United States Department of Energy (U.S. DOE) has a comprehensive fuel economy rating and labeling procedure in place. These city and hi ghway fuel economy values (in miles per gallon) have been the primary information source av ailable for consumers to compare the fuel efficiency of vehicles they are interested in purchasing.

Over the past several years there have been attempt s to develop a label for passenger cars and light-duty trucks to encourage consumers to pur chase more environmentally friendly

vehicles. There have also been a number of studies using focus groups and market research to evaluate different types of vehicle lab eling and ranking programs. Below is a description of some of the labels and ranking syste ms that have been developed and evaluated along with results of the market research

.

The U.S. EPA used focus groups to evaluate their Sm artWay certification mark and Green Vehicle Guide rating system 14 . They found that environmental issues other than miles per gallon (MPG) were not key factors in the respondent s’ purchasing decisions. However, participants were more willing to pay attention to emission labeling programs that include an easily understood rating system comparing vehicles. Another comment was that the label should compare similar vehicle classes in order to have credibility.

Another study used focus groups to evaluate several government we b sites that provided

environmental information about vehicles 15 . These included the following web sites:

• DOE and EPA web site www.fueleconomy.gov provides users with information about fuel economy as well as greenhouse gas emissions an d criteria pollutants.

• U.S. EPA web site www.epa.gov/greenvehicles offers similar information with the focus on criteria pollutants rather than fuel economy.

• The American Council for an Energy-Efficient Econom y (ACEEE) web site

www.greencars.com , provides environmental, recycling and energy-cons ervation

information.

• The California Air Resources Board's Cleaner Car Bu yer's Guide www.arb.ca.gov/msprog/ccbg/ccbg.htm lists California vehicles by emissions
category.

From the respondents, it was determined that the mo st useful/meaningful information tended to be in two areas: fuel economy and some ov erall rating of tailpipe emissions. Respondents tended to understand the issues of GHG or global warming more easily when such issues were correlated with familiar concepts such as fuel economy. The distinction between the impacts of different gases appeared to be difficult for people to understand and seemed somewhat unimportant since the respondents v iewed all of the gases as harmful

anyway.

14 SmartWay Vehicle Qualitative Interviews - U.S. EPA by ICF Consulting and APRR August 23

, 2002

15 Providing Consumers with Web-Based Information on t he Environmental Effects of Automobiles. A Qualitative Research Report Based on Focus Groups i n Knoxville, Tennessee and Los Angeles, California - Oak Ridge National Laboratory - June 2003D-2

Most respondents in this study preferred some kind of overall environmental score that (1) they could have faith in, (2) would be applicable a cross the country and across all vehicles, and (3) would be displayed on the new car sticker a nd adopted by magazines such as Consumer Reports . Respondents stated that the information needs to be presented in a way that consumers find simple and understandable. Respondents in all focus groups were

drawn to the U.S. EPA web site's Green Vehicle Rati ng system, citing that designations like "superior" and simple 1-10 scale bar charts were ea sily understood.

Europeans have been studying fuel economy labels fo r passenger cars 16 . A study by the Austrian Energy Agency produced a draft fuel econom y label based on market research. This market research also found that the layout nee ds to be both simple and understandable. The study developed a draft label t hat offers a fuel economy comparison in the form of colored bars making up seven classes, w ell known from European appliance labels. From a wide variety of possible informatio n that could be included on a car label, only information considered critical was included i n the proposed design. With this label, consumers caught the core information (i.e., the fu el consumption of the car considered compared to others) at first glance. The consumer test found that the use of colors is very important for the impact of the label. This label would give vehicles an A – G rating depending on how their emissions compare to other v ehicles. It is unlikely that

manufacturers that receive an “F” on a number of ve hicles would support this approach.

Another study, Final Report on the Green Vehicle Market Alliance P roject , published in March 2004, also evaluates environmental vehicle la beling 17 . In general, the study found that consumers have a good awareness of the existin g fuel economy label and have some understanding of fuel economy insofar as it pertain s to fuel consumption and driving costs, but they poorly link fuel economy to environmental impacts. Moreover, even when consumers consider vehicle environmental impacts, t hey tend to assign responsibility for addressing these issues to the government or automa kers. In short, environmental factors were not clear to the participants and they did not understand that there were significant

environmental differences between new vehicle model s.

16 Choosing cleaner cars: the role of labels and guide s - Department of Transport. Lecture Fuel economy labeling for cars - Presentation Stefphan F ickl - Austrian Energy Agency

17 Final Report on the Green Vehicle Market Alliance P roject , Prepared for Oak Ridge National Laboratory by John M. Decicco, Environmental Defense, March 20 04