Re: Fuel Economy Label Rule Fuel Economy Label Rule Fuel Economy Label Rule ; follow up issues follow up issues

Roberts French Roberts French t

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: Julia Rege 06/29/2011 02:40 PM

Cc: Alan Stout, John Cabaniss, Lisa Snapp

Julia,

I can respond to #1 and #2 as follows:

#1: As you know, EPA requested comment on a new option for meeting LD CH4 and N2O standards in the HD GHG proposal, and manufacturers are aware that EPA is likely to include regulatory language for such a new option in the final rule. Paragraph (f)(3) is in fact in the final rule and relates to this option , but did not need to be included in Alan's document. That document was intended to give manufacturers some notice of amendments that they'd not yet been exposed to, and the new LD CH4/N2O option does not fall into that category.

#2: This is something we pledged to fix I think as far back as our GHG implementation meeting that occurred in last year. I intended that this be in the label rule, but missed the boat, and the HD GHG team graciously allowed me to get this fixed in their rule . We realized a while ago that requiring both FTP and HFET DFs would add unnecessary burden.

As far as #3 goes, this is a question for Linc, myself, and others implementing the label rule to discuss. However, I do not believe that there is any flexibility in the regulations to allow what you suggest (if you find something, let me know). As you note, the values will change annually (maybe more frequently but only rarely would we expect this to occur). This doesn't mean the fine print can't be pre-printed; it just means that label print runs shouldn't exceed the quantity needed for a given model year. So a little moderation in print quantity and careful planning should allow pre -printing of the fine print with minimal waste, thus removing the paper shift concern (paper shift of a quarter of an inch is a number I have not heard before, and seems both large and inconsistent even with my pre-2008 Toyota label, not to mention my el-cheapo ink jet at home). I'll get back with you if the rest of the team thinks I'm off base, but I don't think that's likely.

Best,

Rob

------------------------------------------------------------------------------------------------------------- Roberts W. French, Jr. U.S. EPA Office of Transportation and Air Quality Compliance and Innovative Strategies Division 2000 Traverwood Drive Ann Arbor, MI 48105 Phone: 734.214.4380 Fax: 734.214.4869 Email: french.roberts@epa.gov

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Julia Rege 06/29/2011 09:39:25 AM Alan, First, in case you haven't heard, I've move...

From: Julia Rege <JRege@globalautomakers.org> To: Alan Stout/AA/USEPA/US@EPA, Lisa Snapp/AA/USEPA/US@EPA, Roberts

French/AA/USEPA/US@EPA Cc: John Cabaniss < jcabaniss @globalautomakers.org> Date: 06/29/2011 09:39 AM Subject: Fuel Economy Label Rule; follow up issuesAlan,

First, in case you haven’t heard, I’ve moved from Hyundai to Global Automakers. My new contact information is located at the bottom of this email.

Second, a couple of Global Automakers’ members have identified a couple of questions/concerns with the new label, which are detailed below. John or I would be happy to discuss any of these with you further if necessary. We would appreciate a quick response on the first two items if possible, but understand that the third item might be a bit more involved and take more consideration.

Best, Julia

1. § 86.1823-08 (m) (2) (i) reads,”..........or determined under §86.1818-12 (f) (3), FTP-based deterioration factors....”

 Is §86.1818-12 (f) (3) a correct citation as it does not seem to exist?

2. § 86.1823-08 (m) (2) (ii) reads, “ For manufacturers complying with the fleet averaging option for N2O and CH4 as allowed under §86.1818–12(f)(2), deterioration factors based on FTP testing shall be determined and may be used to determine full useful life emissions for the FTP and HFET

tests . The manufacturer may optionally determine separate deterioration factors shall be determined for the FTP and HFET test cycles, in which case. Therefore each FTP test performed on the durability data vehicle selected under §86.1822–01 of this part must also be accompanied by an
HFET test.

 The understanding up to this point was that manufacturers would have to obtain separate FTP DF and Hwy DF. The new provision adds flexibility and reduces testing resource/burden by allowing the FTP DF as well as the Hwy DF, so this change is welcomed. However, we wanted to make sure we are understanding this correctly (since this sort of appears out of nowhere in this label final rule).

3. The label requires white “fine print” at the bottom of the label and contains numbers that will change at least annually, possibly more often. This prevents manufacturers from pre-printing this section on the label as they currently do for any other white print that is part of the “grid” . Additionally, the white “fine print” is extremely close to the edge of the black section so alignment of this section with the rest of the pre-printed “grid” is probably going to be an issue. The paper in the printers can and often do shift by up to a quarter of an inch from one page to the next. The clearances in the new Label are nowhere near that distance. So, this reversed variable text will be very difficult to output with proper alignment.

• An easy remedy would be to change the bottom label section to a white background . The consumer would gain legibility since small, white reversed text is difficult to read, and the manufacturer can apply this black variable text when imprinting at the ports and other locations. Here is a rough example of a white box and black variable text in the lower third of the label:Julia Rege

Senior Manager, Environment & Energy Association of Global Automakers, Inc. (Global Automakers) 1050 K Street, NW, Suite 650 Washington, DC 20001 202.650.5559 (direct) 202.650.5555 (main) jrege @globalautomakers.org

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