Question #/ TOPIC Responsible 

Agency 

OMB Comment Proposed Response 

1.Emissions for Electric Vehicles 

EPA Interagency reviewers recommend that the agencies 

accept comments on a more complete range of issues regarding what emissions information to include on the label, how to calculate emissions data, and how to present it. 

• Forthcoming 

2.Objective Language EPA Commenters recommend that the agencies modify 

language that may be perceived as trying to manipulate consumers into making certain consumption decisions that the Administration views as socially desirable from a policy perspective.2 Instead, the rule should be 

described as an objective attempt to provide more and better information to consumers so that they can more easily assess the true costs and emissions of different vehicles and make fully-informed decisions. The agencies should not imply that consumers who do not buy more fuel efficient vehicles are making poorer decisions, when it may be their preference to do so even with more information. Please make these revisions throughout the entire document. 

• The agencies willu

preamble in approobjectivity. 

3. Median Baseline Vehicle 

EPA What alternatives did the agencies consider in deciding 

how to help consumers compare vehicles? The current proposal to shift each year’s median vehicle might make it very difficult or even misleading when consumers are comparing identical vehicles but different model years. A new model year vehicle might have lower ratings and cost savings than the previous year model year even if it is more efficient because of the shifting median vehicle. Do the agencies think this could be problematic? 

• The agencies unde

expressed in this cthere is no perfect think using each ycomparison is the underlying assumpdate to be most usWhen the Agencietesting post-propoprobe on this and assumptions issue
• We will invite com

raised by the commwill review this seA.10.of the preamif we need to more discussion. 

4. Display of Model Year 

EPA Under the grading scale, the model year of a vehicle is 

extremely important because the relative metrics are updated every year. The agencies should therefore solicit comments on whether to highlight the model year more prominently on the label. Also, the agencies should consider – in greater detail – that consumers may want to compare essentially identical vehicles, but for different model years. As described above, under the updated grading scheme, the newer vehicle could have a lower grade even if it is more efficient than an older model, due to a different baseline for the grading scale. A similar condition could exist for the presentation of “fuel savings” information. 

• Model year is clea

all Monroney labeand the NHTSA sincorporated into tlabel, it would be model year on the well. Many consuMonroney label, sinformation on the to compare a new vehicle is with ww

5. Half letter upgrade for PHEVS 

EPA Currently, the rule allows all vehicles to receive a half a 

letter grade upgrade if they perform well on “other HG emissions” except for PHEVs. The agencies state that PHEVs are excluded from receiving an upgrade if they are eligible to receive it because they want only EVs to get the A+ rating. PHEVs get an A for just the CO2 emissions and if they perform well on other GHG emissions, could get an A+. Excluding PHEVs from getting this upgrade might not level the playing field. Have the agencies considered implications from not allowing for a leveled playing field? Commenters recommended that the agencies not exclude PHEVs 

• The agencies are n

letter upgrade/dowpollutants, simply comment on the oseveral other optiogrades 

• We propose addin

the relevant draft p44 (Section II. A.7that only those vehfuel economy and emissions receive 
from getting this half letter upgrade if they are eligible to receive it. 

system would be afrom the next groupromoted to the hitheir air pollutant under the letter grwould not be able A+ grade if they w3. Therefore, only eligible for the higeconomy and CO2 possible rating, whthe purpose of deseconomy/lowest Gpractical effect of only electric-poweeligible for an A+ seek comment on should be providewhether a single crating for fuel ecoemissions should b

6. Overall Monroney Label Impacts 

EPA How would changes from this NPRM impact other 

components of the Monroney label? What is the relative size of the fuel economy component compared to the safety ratings component? How might the difference in size of the various components influence consumer perception about other vehicle attributes -- such as safety? 

• The proposal does 

effects that the proon other Monroneas the safety ratingproposal in Sectioagencies also seek the potential for thto create confusion information found in particular, the s
Specifically, the aon whether consumlarge letter grade oother aspects of th(such as safety) beenvironmental impconcern, the agencprominent black bthe purpose of the Nevertheless the aon whether additiorequired under 329this potential conf

• The agencies also 

whether the co-proparticular Label 1 large font for the omight inadvertentlfrom the black-andratings. As one wpotential issue, NHrequire under 49 Csafety ratings be lophysically possibleconomy and enviensure that the staget “lost” on the MSimilarly, the agenwhether their regueconomy and envirequire that it be lo
physically possiblratings." 

7. Explain text on p. 29- cumulative cap on upstream emissions 

EPA • The phrase referen

comments is not obelieve it is anywh

• The phrase on pag

production cap perefers to the provi2016 light-duty veestablishes a thresproduction (or salemanufacturer duritimeframe, below zero gram per milEVs, and the electand above which tcompliance value upstream GHG emthreshold is 200,0manufacturers whEVs/PHEVs/FCV300,000 vehicles f

8. Label Title EPA Commenters recommended that the agencies use “GHG 

Performance” instead of “Environment” on the label itself because the agencies are only considering GHG impacts. It is more accurate to refer to it as GHG reductions instead of “Environment.” Please make this change in the NPRM as well. 

• The title on both c

Economy and EnvComparisons” refeinformation on eacperformance metriinformation, and dgreenhouse gases emissions as well. 
the title is approprconsumers to all thinformation availa

9. List of acronyms needed 

EPA It would be helpful if the proposed rule included a list 

of acronyms at the beginning of the document. 

• The agencies have 

acronyms for inclu

10. Effect on aftermarket 

EPA Could the agencies please clarify whether the proposed 

rule would affect “aftermarket” manufacturers (firms that purchase passenger cars or light trucks) and customize them for (re)sale. Would these firms be required to provide a label when they resold the vehicle? (Commenter asked this because these aftermarket” firms are likely to be small businesses, and if they are covered by the rule need to be included in the Regulatory Flexibility Act (RFA) analysis.) (Commenter notes that Sec. 600-316-08 says that the “final stage” manufacturer is treated as the manufacturer for purposes of compliance with the rule.) 

• Because the “after

several different tythe response to whrequirement appliesituation. The diffsituations are as fo

1) Independent CommICIs are companies thoverseas either becausto the U.S., or because otherwise available in performance sports capostal vehicles). Undregulations, such imporequired to be emissioFE label. Small businour Regulatory Flexib2) Alternative-fuel cocurrent regulations, alare not subject to the Frequirements. We are changes for alternativFE label proposal. Thalternative-fuel conveour RFA analysis. 
3) Manufacturer-appr(e.g., limousines); Socertify vehicles that alcompanies to modify certain weight limit anemissions certificate. also provide fuel econaftermarket companieestimates for the modithe weight of the modEPA’s current regulatcompany does not neeemissions as long as tweight limit specified but they do need to pulabel on the modified manufacturer providefrom the non-modified We are not proposing provisions with the FE Therefore, small businconverters covered unapproved modificationmanufacturers are regbe included in our RFadjust the text in the Rthis. 4) Other types of modEPA Advisory CirculMarch 1977) that clar
tampering, aftermarkea vehicle from it certiflong as they do not adof accessories to the vthey do not modify themission control systesuch cases the aftermarequired to obtain a secertification or put thevehicle. Therefore, smcompanies engaged in modifications are not analysis. 

• We do not believe 

changes to the pro“aftermarket” issualready included t“aftermarket” situlabel is required (ianalysis/discussio

11. RFA and autodealers 

EPA The RFA analysis/certification should also include 

“auto dealers,” as the rule (Subpart E, Sec. 600-405) requires them to ensure that labels are in place and to obtain, display, and make available to consumers the Fuel Economy Guide (comparison booklet). Commenter assumes these costs are de minimus, so including them in the RFA analysis could be done in a brief sentence or two (but they should be included in the analysis and table of regulated entities). 

• We agree that “au

responsibilities unlabeling regulationproposal does not requirements to ththere is no incremdealers” due to the 

• We will revise our 

(in both the introdpreamble, see “SUINFORMATION: 
Apply to Me?” ansection VIII.B.3, Tin “auto dealers”. 

• We will also add d

section of the preano incremental imdue to the propose

12. Font size of MPG vs. GMP Label 2 

EPA The NPRM does a great job outlining the benefits of 

gallons per mile instead of miles per gallon. But then label 2 has MPG in huge font (the biggest on the label) and GPM in tiny font. And all the labels have the slider bar as MPG rather than GMP. Commenter understands that people now are used to the concept of MPG, but did the agencies consider gradually transitioning the label from emphasizing MPG to emphasizing GPM? Commenters could imagine, for example, the relative font sizes or placements changing over a decade. 

• The agencies did c

prominence of GPagencies agree to issue in section IIIfollowing languag

“The agencies are seewhether to gradually iof gallons per hundred consumer familiarity aconsumption metric.” 

13. p. 30 AC Leakage EPA On page 30 of the preamble there is a discussion on 

using A/C leakage adjustments in the determination of GHG emissions. If this option were adopted would it be inconsistent with labeling the emission as “tailpipe emissions”? Wouldn’t including A/C leakage adjustments also lead to widening the gap between what is on the label and what consumers get in the “real world”? 

• The agencies are n

A/C leakage adjuscomments 

• We agree to seek c

on the issue raised comment: “Wouladjustments lead tbetween what is oconsumers get in t

14. p. 66 EPA On page 66 in the forth sentence of the last paragraph, 

the word “actually” should be replaced with “typically” as shown below. This change would make the sentence consistent with the discussion preceding this sentence 

We will make this proin the preamble: “Whare lower than the gasuse of E85 is actually 
and corresponds to DOE’s findings in testing E85-FFVs 

energy efficiency and fuel economy. “While the E85 mpg values are lower than the gasoline mpg values, the 

use of E85 is actually typically slightly more energy efficient than the use of gasoline.” 

energy efficient than t

15. p. 67 methodology for assigning ghg value for FFVs 

EPA On page 67, the proposed methodology for assigning an 

overall combined value for greenhouse gas emissions or fuel economy for FFVs based on the fraction of alternative fuel currently in use seems uninformative for consumers. Especially with FFVs, it is unlikely that any individual consumer uses the national average fraction of alternative fuel. Possibly deriving a merged value for a clearly stated percentage of the alternative fuel (say 10% or 25% E85 usage for an FFV) would be of more value to the consumer. 

• The agencies are s

comment on this ipage 68, is not to ufraction of E85 usgasoline/1% E85)gasoline use as the most flexible fuel gasoline all the timproposal does alloa different gasolinprovide data to shvehicles are in facmix, on average, iapproach is consisflexible fuel vehiccompliance under for 2016 and later 

16. labeling option for E85-FFV 

EPA Combined fuel economy labeling options for E85-FFV 

and diesel vehicles: It is not clear from the discussion if the combined FE ratings for diesel and E85-FFV vehicles would be on a gasoline equivalent basis or a per gallon basis of diesel or E85. DOE’s believes it would be more useful to consumers if the combined FE ratings for diesel and E85-FFV vehicles were on a diesel or E85 volumetric basis since these fuels are also sold on a per gallon basis. However, it is appropriate for 

• With respect to E8

on page 67 the prompg (volumetric) equivalent) metriccomment on whetboth. With respecis silent on this issto continue to repovolumetric basis a
the combined FE ratings for non liquid fuels such as CNG and electricity to be on a gasoline equivalent basis. 

the past. We will aII.C.4 to address t"EPA proposes to fuel economy of dtraveled on a gallofuel has a long hisvolumetric basis, adifferences betweeand a gallon of diesmall." 

17, Saves/Spend Disclosure Issues 

EPA Label 1 “Saves/Spend” Disclosures: For vehicles with 

below-average economy, proposed Label 1 would disclose the additional cost of fuel as compared to the average vehicle. For example, the disclosure on Figure III-5 states “Over five years, you will spend $3,600 more in fuel costs compared to the average vehicle.” Similarly, for above average vehicles, Label 1 contains a savings claim (e.g., “Over five years, this vehicle saves $5,700 in fuel costs compared to the average vehicle”). These disclosures present several potential problems. First, commenter expects that many consumers will interpret the “spend” disclosure to be a representation of total operating cost without realizing that figure is only a portion of that total. In addition, the basis for the saves/spend disclosure is five years of operation while, elsewhere on the label, the basis for the total operating cost disclosure is one year of operation. This may cause 

• The Expert Panel 

is a much more pocost. The Agencieopportunities for cpertinent informatof “spend” and the represents a five ythe Agencies also OMB June 18, 20calls for simple su

• The commenter st

figures compare to that may not be in set, these figures museful to many conthe median vehicleit to be a reference Unfortunately, it ivalue on the label specific vehicles t
confusion. In addition, we expect the five year assumption will be lost on many consumers. Finally, because the saves/spend figures compare to an “average vehicle” that may not be in a consumer’s decision set, these figures may not be particularly useful to many consumers. Given these concerns, the “saves/spend” 

disclosure should be tested for these potential problems. 

Commenter notes that FTC has found through onsumer research that the annual operating cost provides a useful, straightforward disclosure that allows for easy 

comparisons among all products (regardless of size and configuration). Commenter recommends that EPA and DOT consider displaying the annual operating cost figure prominently in lieu of the problematic saves/spend disclosure. Such a change is likely to make the label clearer, simpler to read and less cluttered. 

considering. Howto have specific cosuch as this on a wconsumers to pershabits and vehicle agencies are takinways to demonstracomparisons (see II.A.10) 

• The agencies are c

proposal engaging the additional rescomment. In addibelieve both Interconducted as well groups which are proposal will provdata on this issue. 

• We will seek com

by FTC and inclulanguage as in Secbeginning after, “Tcomment on this aapproaches, as oppapproach of displacost savings relatiin the fleet.” “ Thseeking comment potential of consuthe two different c
Label 1 with regarannual fuel cost of and the 5 year fuecompared to the ainterested in receivthese values may iand we intend to eprior to finalizing exploring research branch agencies.” 

18. Environmental & Combined MPG Scales 

NHTSA Environmental and Combined MPG Scales: The three 

small scales on Label 1 (combined MPG, CO2, and Air Pollutants) are difficult to read and clutter the label. Accordingly, commenter suspects that consumers will have difficulty understanding these scales and their presence may detract from other label information. To the extent that such rating scales are required under the statute, commenter suggests that EPA and DOT consider whether the simple letter rating on Label 1 meets such requirements. If they do, commenter recommends that these small scales be removed from the label. This would increase label space and allow the size of the disclosures above the ranges to beincreased. Similarly, to the extent that environmental impacts are collinear with fuel economy, commenter suggests that EPA and DOT consider consolidating information (or significantly reducing the prominence of environmental disclosures) wherever possible to reduce clutter. For example, the greenhouse gas and air pollutant scales in Label 2 could be eliminated or made less prominent to simplify the label and make it easier for consumers to use. 

• The agencies b

addressed this attached documlanguage from 
19. p. 61-FTC Label Reference 

EPA FTC Label Reference: On page 61, the term “hang tag” 

should be replaced with the term “label.” 

• The agencies wil

preamble langua

20. Overall Rating utility 

NHTSA Some commenters questioned the utility of the overall 

summary rating because it does not by itself provide useful information to consumers. Have the agencies considered increasing the font of information that consumers might find more useful and decreasing the font of the overall summary rating that might not provide any useful information? 

• Please Pages 24 

regarding this dis

21. Should any car receive an A+ 

EPA Some consideration should be given to the question of 

whether any car ought to receive a grade of A+. There may be undue psychological effects on consumers’ environmental choices. Consumers might get the impression that their environmental obligations are fulfilled after getting an A+ car. In addition, people tend 

to drive more miles if they think their car is more fuel efficient, and so if someone is led to believe their car has NOenvironmental impact, then who knows how they’ll change their behavior. In fact, there 

• The agencies bel

grading scale is inecessary differeuseful to both comanufacturers. Tadd language to tinviting commen

22. GHG performance based on tailpipe misleading bias against ethanol or biodiesel 

EPA Biofuel issues 

• These commen

interrelated 

• One primary th

that we should GHG issues--isuggested chanpart of our respEV emissions 

• A second thru

we should shoenvironmental 

23.Alt Fuel Labels should include info on gasoline savings in addition to fuel savings 24. p.28, SecII.3- upstream emissions issue 25. SectionII.3 proposed language 
addition from RFS fact sheet 

fuel--is already Preamble as on third and fourtagencies discuproviding E85and we ask for of the E85 flex

• EPA is oppose

proposed labelpreclude changproposal and a 

p. 29 suggested lang change to include RFS language p. 57-adding upstream emissions language p. 58 – upstream lang p. 66 – suggest adding co2 reduction from combusting E85 fuels alongside tailpipe CO2 p.71 – Renewable fuels lbenefits- add info to label Pages 12-16 (alternative labels) 
Internal EPA and NHSTA—Under Review ... Do Not Distribute...8/11/2010 

Rank Order of Ten Lowest-GHG Vehicles Unchanged 

Under Both Tailpipe-Only and Tailpipe Plus Upstream Approaches 

Proposal--Tailpipe-Only Tailpipe + Upstream 

Vehicle CO2/mile Grade CO2/mile Grade 

Nissan Leaf EV 0 A+ 197 AChevrolet Volt PHEV 89 A 210 AToyota Prius PHEV 133 A 217 AToyota Prius HEV 178 A- 224 AHonda Civic HEV 212 A- 266 AHonda Insight HEV 217 A- 273 AFord Fusion HEV 228 A- 287 ASmart 247 B+ 311 B+ 

Lexus 250h HEV 254 B+ 320 B+ 

Nissan Altima HEV 261 B+ 329 B+ 

Key Assumptions 

• Leaf EV, Volt PHEV, and Prius PHEV all assumed to use 200 Watt-hours per 

mile when operating on electricity over the EPA test and assuming a 30% range 

(43% electricity consumption) shortfall from test to road; EPA has not certified 

any of these vehicles and therefore does not have formal test data on these 

vehicles. This is the best information available. 

• Volt PHEV assumed to operate on electricity 50% of the time. 

• Prius PHEV assumed to operate on electricity 25% of the time. 

• Uses 2005 nationwide average value of 0.642 grams of upstream GHG per Watthour at powerplant (adjusted to include GHG emissions from feedstock 

extraction, transportation, and processing as well) from MY2012-2016 light-duty 

vehicle GHG final rule (75 Federal Register 25437). See separate docketed 

memo to docket and spreadsheet which provides emissions factor for this 

analysis. 

• Assumes typical 7% electricity grid transmission losses. 

• Uses 2250 grams upstream GHG per gallon of gasoline – consistent with value 

used in the light duty 2012-2016 GHG final rule. 

• Our proposal does not include a rating scale for tailpipe + upstream GHG 

emissions. The grades we have assigned in the above table for “tailpipe + 

upstream emissions” assumes an "equal increments of CO2" scale identical in 

approach to that used in the proposal’s tailpipe-only scale.