Perspectives on EPA / NHTSA 

Revisions to the Fuel Economy Label

Luke Tonachel

Senior Analyst, Transportation Program

Natural Resources Defense Council

EPA MSTRS Meeting, Ann Arbor, October 5, 2010
Slide

NRDC Preferred Approach

• Prominent letter grade system

– Single scale for all cars and trucks

• GHG basis for comparison across 

all technologies

• Clear operational cost impacts

• Include fuel consumption metric

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Slide

Advantages to Preferred 

Approach

• Simplicity

– Letter grade system promoted by expert panel because everyone 

understands it. 

– Provides a full view of choices by putting all vehicles on the same 

rating scale.

– Boils down complex information so it can be factor early in the 

buying process.

– Operational cost: ‘save’ vs. ‘spend’

• Fair assessment

– GHG basis for rating shows environmental impact while also being 

applicable across technology

• Promotes clean technologies

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Slide

Hybrid and Plug-in Models 

Ramping Up

Vehicle Type Already in Market Total by Model Year 2015

Conventional Hybrids 22 52

Plug-in Hybrids 0 18

Battery Electrics 1 32

Fuel Cell Vehicles 0 6

Total 23 108

• Clear need to address advanced technologies

• Differentiation could help sales of new 

technologies

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Number of Electric Vehicle Models Introduced or Expected to be Introduced in 

U.S. Market

Source: Alan Baum & Associates, Sept 2010, http://baum-assoc.com/EVForecast.aspx. 
Slide

Consumers Shop Across 

Vehicle Types

• EPA Pre-Focus Group Survey

– “Most considered more than one vehicle and shopped across 

vehicle types” 

• “More than half (53.6%) compared two to three vehicles 

before making their final decision...”

• “...when it came to the types of vehicles seriously 

considered, more than three-fifths (62.8%) considered more 

than one vehicle type, with a third (32.9%) considering two 

vehicle types and another fifth (19.7%)considering three 

vehicle types.”

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Source: EPA, Fuel Economy Label Pre-Focus Groups Online Survey Report, EPA-420-R-10-907, August 2010 
Slide

Survey: Consumers Focus on 

Size/Capacity and Fuel Economy

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Source: EPA, Fuel Economy 

Label Pre-Focus Groups 

Online Survey Report, EPA420-R-10-907, August 2010 

Top Attributes
Slide

Many Choices of Class and Fuel 

Economy at Single Vehicle Size

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Slide

Potential Vehicle Choices within 

a Footprint

Models

Footprint: ~43.5 ft2

MPG (Adj.

Composite)

Toyota Prius (car) 49.4

Ford Escape Hybrid (truck) 32.0

Mazada3 (car) 24.6 – 28.9

Ford Escape (truck) 25.0 – 20.4

Mitsubishi Eclipse (car) 19.8 – 23.7

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Models

Footprint: ~48.0 ft2

MPG (Adj.

Composite)

Lexus RX 450h (truck) 28.7 – 29.4

Mazada6 (car) 21.0 – 25.4

Volvo XC 60 (car) 18.5 – 21.3

Mitsubishi Endeavor (truck) 17.2 – 18.4
Slide

Summary

• Single scale for all vehicles is crucial

– Enhances usability by demonstrating the spectrum of choices, 

independent of vehicle type

• Letter grade system is key for simplicity

– Easy to understand, the letter grade enables efficiency and pollution 

to be a large factor early in the buying process

• Early shopping process enhanced with operational cost ‘save’ or 

‘spend’

• Together, these attributes serve to promote broader 

commercialization of advanced, clean technologies that are 

increasingly being developed, providing an opportunity to 

leading manufacturers.

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