8/23/2010 EPA/NHTSA Response to OMB comments received 8_23_7am:

1) Adding sentence to AC leakage discussion. Response: We will add the proposed sentence:

“Because A/C related reductions are not “tail

‐ pipe”, including leakage improvements in the tailpipe emissions could be misleading and inaccurate. If the final label includes other non

‐ tailpipe emissions, the agencies may consider incorporatin g A/C leakage improvements”.

2a) Table VII.A. 1-1 “Why are vehicle numbers differe nt depending on the cost?” Response: These are minimum and maximum values.

The sources of both the vehicle sales a nd label cost numbers are in the text.

The purpose of this row is to provide minimu m and maximum printing cost changes. The

minimum cost is based on a combination of low-vehicle numbers and low label cost; the maximum cost is the combination of high-vehi cle numbers and high label cost. No useful information is gained by providing the additional combinations of low-vehicle numbers and high label costs, or high-vehicle numbe rs and low label costs, because those fall between the values reported here, and the table woul d become needlessly cluttered.

2b) Facility Costs - Provide citation for this information, “we use the approximation of unitizing increased test costs by assuming that a facility capable of performing 750 FTP/HFET pairs would cost $4 million.”

Response: We have cited the source of this inform ation at the beginning of this section as the

ICR. We can add a footnote here al though we do not believe it is necessary.

This value, as with all the cost s in this section, is discussed in the Draft Supporting Statement for Information Collection Request, Fuel Economy La beling of Motor Vehicles (Proposed Rule), EPA ICR 2392.01, cited at the introduc tion to this section. [“For details of this analysis, see the “Draft Supporting Statement for Information Collection Request, Fuel Economy Labeling of Motor Vehicles (Proposed Rule)”, in the doc ket.” p. 139.] The value in the Supporting Statement is derived from ICR Supporting Statement 0783.54 and has been used in various rulemakings in recent years.

3) . Projected Impact of the Proposed Requi rements Request that a phrase be added: “. . . and any displacement of currently provid ed information that consumers find useful in informing th eir purchase decisions.”

Response: We accept this change, with the substitution of the word “revisions” for “displacement.” “Displacement” implies that information was removed; “revision” is a more general statement of changes.4) The O & M costs and labor hours- this dupl icated #2 above. Same response as above.

5a). C. Benefits of Label Changes. Request addition of sentence, “We caution that insights into comprehensibility and usefulness may be limited in predicting changes in consumer behavior due to the proposed label change.” Response: We accept this sentence.

5b) Request addition of sentence, “Some evidence suggests that consumers may focus on the up-front costs of fuel-saving technology when buying vehicles inst ead of giving equal weights to the upfront cost as well as the future fuel savings.” Response: We prefer the original sentence , “Some evidence suggests that consumers may not accurately compare future fuel savings with the up-front costs of fuel-saving t echnology when buying

vehicles.” The substitute sentence is not an accurate summary of Turrentine and Kurani. That

article focuses on consumers’ not calculating fuel savings at all, or not calculating them correctly, not on whether they put disproportionate weight on up-front costs. The primary focus of this paragraph is not on the role of fu el economy in consumer purchase decisions, but on consumer misunderstanding of fuel savings from increasing fuel economy, as discussed in

Turrentine & Kurani.

6) 5. California Environmental Performance Label . Request addition of sentence , “The Global Warming index on California’s label incl udes emissions from fuel production (http://www.driveclean.ca.gov/im ages/ep_label_large.jpg)” Response : Defer until we receive new language fo r upstream section back from OMB.