EPA Seeks Public Comment on Proposed new Fuel Economy Labels for Autos

You may recall an ad campaign on the internet that used the number 230mpg in several creative executions a couple of summers ago.  That campaign sparked much criticism and debate.  A common theme of those conversations was the need to adapt the way vehicle efficiency is communicated to the public as a wave of alternative propulsion systems hit the market.  How should the EPA display efficiency of Electric Vehicles?  Is it fair that a Gasoline/Electric Hybrid be classified the same as a Gasoline Only or an Electric Only Vehicle?  On an Electric Vehicle, does total range matter to a consumer and should it be displayed on a label?  Also on Electric Vehicles, does the time it takes to recharge the batteries matter to consumers and should it be displayed on a label?  Do consumers really understand 'Greenhouse Gas' emissions, what they do, and how they are measured?   Ultimately, what are the most important facts that are relevant to the average consumer in helping to make a purchase or lease decision?

We already have a wide range of traditional Internal Combustion Engine (ICE for short) vehicles along with many Hybrid variations, Diesel Engines, E85 Flex Fuel Engines, Natural Gas and even Hydrogen.  In the next few months, we will see the all-electric Nissan LEAF come to market along with the Extended Range Electric Chevy VOLT.  With all of these powertrain variations, how will consumers make educated decisions as to which vehicle offers them the best combination of utility, style, safety and economy?
That's where today's announcement by the EPA and DOT comes in.  The government is proposing the first major changes in over 30 years to the fuel economy labels affixed to the windows of all new vehicles.  You can read the official press release below, or watch the following video for an explanation.

Do you have an opinion?  If so, please take the time to express it - all viewpoints are welcome and necessary.  How will these new labels affect consumers in the Metro New York market?  The real question is how does individual usage affect real-world economy?  Take one example of a Chevy VOLT:
With a 40 mile all-electric range, a VOLT driver who commutes from Westport to Greenwich CT each day may travel about 38 miles a day.  That consumer would use ZERO gallons of gasoline to make that daily commute.  But another driver, making the same commute, driving a vehicle that gets 35 to 40 mpg, would use one gallon of gas per day.  That's a significant difference over time.  How should the EPA display this to a consumer?

Take another driver who lives in Danbury and commutes to Stamford each day.  Their job also takes them on the road during the day and their typical daily mileage is about 100 miles.  If they drove a conventional ICE car, its easy to figure out 20mpg equals about 5 gallons of gas per day.  If they drove a Chevy VOLT, the first 40 would be all electric, and then the last 60 would be driven using electricity produced by the on-board generator.  With an estimated 40mpg equivalent, the VOLT would us about 1.5 gallons per day.  And if this same consumer drove a Nissan LEAF, with its 100 mile all-electric range, they would use ZERO gasoline in a typical day.  The only major concern for the LEAF driver is total range, because if some days their errands take them further than 100 miles, they will not make it back home and could become stranded until they could recharge the LEAF's battery (Nissan estimates recharging will take over 20 hours using a conventional 100V outlet - or the LEAF can recharge in about 10 hours using a fast, dedicated 240V charger).

As you can see, an individuals typical driving habits can greatly effect which type of vehicle would make the best choice.  Also, when it comes to using something like the proposed letter grade below, how to you fairly rate one vehicle vs. another when there are so many varied uses?  The EPA can take three vehicles, a 2-seat sports car, a 4-passenger compact car, and an 8-passenger cross-over SUV and rank them in terms of efficency, giving each a letter grade.  But as a consumer, if you need to transport 6 people, how does this grading system help you?  IMHO, the letter grading system seems to complicate an already complicated issue.... so the question remains:  What do you think of the EPA's suggested new disclosure stickers?  If you are curious of what others think, you can find a wide range of comments on some other sites as well.... here are some links:

GM-VOLT has a nice thread of comments on the subject...

Tonic takes a quick public poll of their own.

The New York Times has posted an aricle and public comments...

EPA PRESS RELEASE:  August 30, 2010 - As a new generation of cars and light trucks start appearing on the market, the U.S. Department of Transportation (DOT) and the U.S. Environmental Protection Agency (EPA) are jointly proposing changes to the fuel economy labels consumers see on the window of every new vehicle in dealer showrooms. The proposed rule seeks public comment on label design options and related issues. The public can view the proposed rule and labels at: http://www.epa.gov/fueleconomy/ and submit comments as part of the rulemaking process via email to: newlabels@epa.gov. They can also review the proposed rule at http://www.nhtsa.gov/fuel-economy.

“We are asking the American people to tell us what they need to make the best economic and environmental decisions when buying a new car,” said EPA Administrator Lisa P. Jackson. “New fuel economy labels will keep pace with the new generation of fuel efficient cars and trucks rolling off the line, and provide simple, straightforward updates to inform consumers about their choices in a rapidly changing market. We want to help buyers find vehicles that meet their needs, keep the air clean and save them money at the pump.”

“New technologies such as battery electric vehicles and plug-in hybrids are entering the American market in greater numbers,” said U.S. Transportation Secretary Ray LaHood. “We need to provide consumers with labels that include fuel economy and environmental information so that buyers can make better informed decisions when purchasing new vehicles.”

The goal of the new fuel economy labels is to provide consumers with simple, straightforward energy and environmental comparisons across all types of vehicles, including electric vehicles (EV), plug-in hybrid electric vehicles (PHEV), and conventional gasoline-powered vehicles.

DOT and EPA are looking to provide enhanced information on efficiency and environmental performance – including information about air pollutants, such as smog, that impact public health – to consumers. The Energy Independence and Security Act of 2007 specifically calls on EPA and DOT to rate available vehicles according to fuel economy, greenhouse gas emissions and smog forming pollutants.

EPA and DOT are proposing two new label designs for comment. One label design prominently features a letter grade to communicate the vehicle’s overall fuel economy and greenhouse gas emissions performance. The new design will also provide consumers with an estimate of the expected fuel cost savings over five years compared to an average gasoline-powered vehicle of the same model year.

The second proposed label retains the current label’s focus on miles per gallon (MPG) and annual fuel costs, while updating the overall design and adding the required new comparison information on fuel economy and emissions.

Both proposed label designs expand on the content of the current label by including new information on fuel consumption, tailpipe carbon dioxide (CO2) emissions and smog-related emissions. The new labels would provide information on a new web-based interactive tool that can also be accessed by smart phone. This tool would allow consumers to personalize the information about a vehicle’s performance.

For EVs and PHEVs, the agencies are proposing to show energy use by translating electricity consumption into miles per gallon equivalent. The proposed label designs for EVs also include energy use expressed in terms of kilowatt-hours per 100 miles.

DOT and EPA encourage public feedback on all aspects of the proposal, including which designs or design features would best help consumers compare fuel economy, fuel costs, and environmental impacts of different vehicles and across different vehicle technologies.

The agencies are proposing that the label only present information on vehicle tailpipe emissions. Upstream emissions, which are associated with electricity generation or refining fuel, would not be displayed on the label. EPA and DOT propose to develop a website to provide consumers additional information on non-tailpipe emissions, while taking comment on other approaches to provide consumer information about lifecycle emissions across various vehicle fuels and technologies. The agencies are aiming to complete the rule in time to allow the new label to appear on the windows of as many 2012 model year vehicles as possible.

DOT and EPA are providing a 60-day public comment period that begins with the proposal’s publication in the Federal Register.

More information on the proposed labels and submitting comments: http://www.epa.gov/fueleconomy/ and http://www.nhtsa.gov/fuel-economy