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 incorporating A/C leakage improvements”. 

2a) Table VII.A. 1-1 

“Why are vehicle numbers different depending on the cost?” 

Response: These are minimum and maximum values. 

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

The purpose of this row is to provide minimum 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-vehicle 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 numbers and low label costs, because those fall between the values 

reported here, and the table would 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 information at the beginning of this section as the 

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

This value, as with all the costs in this section, is discussed in the Draft Supporting Statement for 

Information Collection Request, Fuel Economy Labeling of Motor Vehicles (Proposed Rule), 

EPA ICR 2392.01, cited at the introduction 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 docket.” 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 Requirements Request that a phrase be added: “. . . and 

any displacement of currently provided information that consumers find 

useful in informing their 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 duplicated #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 instead 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 technology 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 fuel 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 includes emissions from fuel production 

(http://www.driveclean.ca.gov/images/ep_label_large.jpg)” 

Response: Defer until we receive new language for upstream section back from OMB.