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Last week the Environmental Protection Agency (EPA) published its proposals for new fuel economy labels and the National Automobile Dealers Association (NADA) has responded with a thumbs down. Specifically, NADA is unhappy with the proposed letter grades that would indicate where the labeled vehicle stands relative to its direct competitors. NADA is concerned that the new grades would confuse consumers, especially when comparing different fuel types. This is a dubious argument.

Since the proposed grades would give a rating that is relative to similar vehicles, it shouldn't really matter what the fuel type is. If a compact sedan with a gasoline engine gets a C compared to a similar vehicle with electric drive that gets an A, that seems perfectly reasonable.

NADA does stand on more solid ground when it complains about comparisons between new cars with grades and used cars without them. However, that argument is limited as well, since the 2007 Energy Independence and Security Act that mandated higher CAFE standards also requires new labels to retain MPG ratings. The comparable MPG ratings exist on the new labels but are now de-emphasized. There also doesn't seem to be any mention of the QR codes on the labels that allow consumers to scan the data with a smart-phone and do instant comparisons.

[Source: Detroit News]


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  • 28 Comments
      • 4 Years Ago
      Wouldn't the more obvious (and valid) argument for NADA be that the EV and PHEV fuel economy and emissions values don't take into account upstream electricity production?
      It means the labels aren't really allowing consumers to compare like for like in terms of their environmental impact.
      Exactly how to calculate the impact can be debated, but there should perhaps be a note at the bottom explaining that upstream emissions have been left out.
      I suppose the question is, does it make the letter system misleading?

      www.optimisticengineer.wordpress.com
        • 4 Years Ago
        Nixon - I have read (some of!) the EPA document, and understand their reason for not adding upstream calculations. On closer inspection of the label, I see the "tailpipe only" wording, which is akin to what I said about having a note at the bottom, so you're right that's taken care of.

        However, upstream for gas/diesel vehicles and upstream for electric vehicles are different. If you are starting with renewable energy, then I agree they can be counted as the same starting point in terms of CO2, but if you're burning fossil fuels to produce electricity upstream emissions matter.

        I can't think of an easy way to solve the problem, and I know that even including power plant emissions EVs will come out on top, but I could understand if NADA and others complained about comparing apples with oranges.
        • 4 Years Ago
        Optimistic Eng, oil is not a renewable resource. Please read and comprehend the comments.
        • 4 Years Ago
        @Optimistic Engineer

        Sure. Let us do upstream comparison for gas as well - like all the emission extracting it from Alberta tar sands, for eg.

        How about we also include the death toll in Iraq war or the cost of oil "spill" in the gulf ? Or better still - let us color gasoline RED to denote the blood spilled in "securing" oil ...
        • 4 Years Ago
        The point is that upstream electricity pollution is impossible to rate. In the northwest, they use a lot of hydro electricity production. The pollution rating would be lower than other locations of the country that use coal or gas.

        As time goes on, the amount of pollution created by generating electricity will continue to decrease. As more wind farms, solar farms, and other not-yet-discovered clean technologies continue to be implemented, the generation of electricity will continue to get cleaner and cleaner.

        I don't think the general public (present company excluded -- we're far more informed than the general public) has the ability to calculate pollution factors. This letter grade is just a scarlet letter: If someone is comparing two SUVs for toting their kids around and towing the boat on weekends, they may be "guilted" into choosing an SUV with a "C" grade rather than a "D" grade.

        -Aaron-
        • 4 Years Ago
        DOE has already done the well-to-wheel research. This includes emission from electricity and tail pipe. It even concluded that petroleum displacement being a trade-off with GHG emission. It pretty much said any plugin hybrid with more than 15 EV miles would produce more GHG than a standard HEV (Prius).

        Therefore, assigning a letter grade just from tail pipe measurement is extremely misleading.

        DOE Technical Report: http://www.ipd.anl.gov/anlpubs/2010/06/67242.pdf
        • 4 Years Ago
        Optimistic -

        The EPA labels for gas/diesel vehicles currently do not include upstream costs and emissions. Why do you think it should just be included for EV's?

        And in fact, the proposed rules DO say the CO2 values for all vehicles are limited to just what the vehicle consumes, and not the upstream values:

        "Given space constraints and the difficulty of explaining the potential range of upstream emissions due to different fuel sources, participants tended to agree that this issue could be adequately addressed by a statement on the label indicating that the CO2 values on the label represented vehicle tailpipe emissions only."

        The EPA already covered this issue quite heavily in their full proposed rule doc. Search for "upstream" in this doc, and you will see the EPA discusses this in detail. If you or anyone else would like to propose a better rule for labeling, please do so.

        http://www.epa.gov/fueleconomy/label/nprm-label2010.pdf
        • 4 Years Ago
        Unfortunately you are ALL WRONG.

        First, if you want transparency, you should never combine different and complicated numbers into a single score. They need to stay separate. Also, don't combine efficiency numbers (like MPG) with emission units in x/mile. It doesn't make sense.

        The only informative way of doing the labels is to stick to information we can clearly and completely qualify: MPG for gasoline and kW per mile for electric.
        EVEN THEN, this is only valid for the EPA course (with the EPA driving style) and in the case of range extenders you must publish two separate numbers because things will vary too much depending on driving and charging habits.

        I know that you think you are showing the 'environmental impact' of the car when you post grammes of CO2 per mile, but you are not. You are merely showing exhaust composition and typical discharge rates.
        The link between that and the actual environmental impact is REALLY FAR from being quantified.

        Forget this idiotic idea of giving cars a "single dumbified score" and give us only the information that is clearly understood and in a scientifically transparent and consumable form.

        That is all.
        • 4 Years Ago
        Optimistic Engineer, KISS is probably the best way. If you calculate what is upstream for a EV, the upstream calculation on oil refined into gas, delivered to the gas station should also have Co2 emission numbers added to it and put on the label.
      • 4 Years Ago
      The dealers' know how much more difficult it's going to be to sell moms on a gas guzzling (but PROFITABLE) suv.
        • 4 Years Ago
        ding ding ding, you are the winner.
        • 4 Years Ago
        The new letter grade rating is the best idea to come out of the EPA since 1999, IMO, because of the wealth of info on the sticker and the big, bold letter grade. You can compare vehicles by either the cost to fuel it, grams of CO2 per mile, fuel use per 100 miles as well as the familiar City/Highway mileage figures, and a rating of the "other pollutants" that spew out of the tailpipe (must be NOX/SOX and carbon monoxide, etc). So the sticker will give you the level of info you want without having to do a marathon internet search.

        Here's a PDF I found on the EPA site showing the proposed stickers.
        http://www.epa.gov/fueleconomy/label/label-designs.pdf
      • 4 Years Ago
      Moving from a system that is simply informative (i.e. the current system with a simple MPG) to a system that traditionally represents a pass or fail is something I would have a beef with also. Gas mileage isn't the only measurement of a good vehicle and that's what the lettering "appears" to do. The intention may be to only rate gas mileage, but if that's the case, re-work it again to allow for a numerical MPG.




        • 4 Years Ago
        Jason,

        Actually, the letter grade is done specifically to get away from rating cars only on gas mileage. The letter grade takes other factors into account besides MPG, like GHG emissions. It just happens to be that cars with better MPG also have better GHG numbers.

        Numerical MPG isn't going away. It will still be on the label.
      • 4 Years Ago
      One big problem I have is that they (in their initial release) have already decided the letter grades by car type -- electric, hybrid etc.

      So once a car maker decides to design a certain type of car, this system seems to give them less incentive to make that car more environmentally friendly. They know from the beginning they will be getting a B or a C,etc.
        • 4 Years Ago
        The EPA never said the ratings are broken up by fuel type or technology type. It just happens BEVs and PHEVs are have the highest plug-to-wheel/pump-to-wheel efficiency in the US so far. If there is a diesel that can beat them in efficiency, then it will get the same rating.

        http://www.autoblog.com/photos/epa-fuel-economy-sample-grades/#3320901
        If you look at example ratings, you will see that the Escape, Altima, Camry hybrids falls into the B+ category, which has a lot of other conventional cars. The Escape Hybrid (4WD) and Highlander Hybrid also fall into the B category, which is mostly dominated by gasoline cars. This shows the ratings are NOT broken up by technology type.
        • 4 Years Ago
        The grade isn't based on the type of fuel, its based on the total energy consumption to drive it.

        VW's 1-Liter Diesel concept car (which gets about 238 mpg on regular diesel), would probably get an A+ on this rating.
      • 4 Years Ago
      The whole "saves $####" is crap. Saves $ compared to what?!? The better option would be "est'd annual fuel costs: $####".
      • 4 Years Ago
      same argument Fox News uses. the truth might confuse people so let's not tell them that.
      besides no current US 'car' should register higher than F if the scale was intelligent.
      cars worthy of A doesn't exist. a Leaf might get a C.
      • 4 Years Ago
      I object to allowing pet preferences to be included in a replacement for a straight forward mathematical measure of what a given car will achieve using the same, measuring yardstick.

      Look at how corrupted the "Gold Point " system that the CARB uses is, as an example of extraneous and pet preferences in action. Because the CARBite leadership has a particular pet preference for FCVs, all car makers must accumulate "Gold Points" , earned only by building FCVs. i.e. waste precious resources and develop FCVs even when other alternatives may be cleaner and less polluting! Or the cleaner cars that might result if those wasted funds were spent to further clean and improve the alternative vehicles.

      The EPA is forthright and says it INTENDS to be Biased and award an A to a pet preference for a BEV when an EREV might be just as clean a SULEV II Zero Emission Vehicle, and more practical too. And actually possess a well to wheel lower impact.

      Phooey! if one get 230 mpg and another gets 50, I don't want the 50 mpg to get an A and the other the C because some ham-handed bureaucrat is enamored of its technology. I'll be the judge, not these clods.

      In practice, it is impossible to calculate upstream contribution since they vary so much. The identical car can be judged differently depending on accounting.

      If the EV were driven in California, then California electric generation which has closed down its coal and almost all its nuclear generation is remarkably clean. But not if you know that 30% is imported power, and that 30% is generated by spare, standby, and the absolutely dirtiest plants extant, in neighboring states.

      If I measured the identical car in Arizona, which has lots of hydro and nuclear, would it also be measured by the relatively clean Arizona power generated and consumed there, or docked for the dirty plants only running to ship juice to Californians, too good or too fastidious to dirty their hands, to generate thier own Power, like the Eloi of HG Wells?

        • 4 Years Ago
        Stan said, "if one get 230 mpg and another gets 50, I don't want the 50 mpg to get an A and the other the C because some ham-handed bureaucrat is enamored of its technology."

        That would never happen. There are no fossil burner vehicles that get 230 (or even 70 MPG) for sale in the USA. Similarly, the grade of "C" goes to vehicles that get a whole lot worse than 50 MPG.
        • 4 Years Ago
        One of the issues that comes into play here is that most consumers have the option to choose renewable energy mix for their electricity. So if somehow (which really isn't feasble) EPA were to include CO2 cost of electricity, that could still be invalidated by the consumer's choice of electricity source. I have subscribed my electricity to be 100% renewable, therefore any inclusion of CO2 cost in the sticker would be invalidated. Also as mentioned by others, NOBODY includes the CO2 cost of gasoline. So a well to wheels comparison CAN'T be made.
        So there are no perfect answers. By the EPA proposal, a FCV would rate an A, even though the energy cost is around 4 times that of an EV (and therefore CO2 cost also higher for those who want to point at EVs running from coal).
      • 4 Years Ago
      Do the grade ratings get revised every year or do vehicles only compare against those others that are released that same year? So if my car is an 'A' and the next month another manufacturer ups the ante and now my car is a 'B', does the dealer then need to revise what rating is being shown for my car if it's still being sold?
      • 4 Years Ago
      How is it not confusing when comparing different fuel types? If one vehicle gets a B and the other vehicle gets an A, the average consumer will simply assume that the higher letter grade vehicle is more cost efficient on fuel, which may not be the case at all.
        • 4 Years Ago
        I can assure you that when the average person buys a fuel efficient car, they do so to save money on gas.

        ESPECIALLY in this economy.

        That is why a car that gets 30mpg on diesel is not the same as 30mpg on 93 octane which is not the same as 30mpg on 87 octane.

        It was confusing for my sister for example to calculate fuel prices into fuel efficiency to figure out which was actually the most economical vehicle. It would be even more confusing if the grade is mismatched to that efficiency.
        • 4 Years Ago
        The letter grade represents fuel efficiency so it shouldn't be confusing. If cars using different fueling sources have the same efficiency, then they should have the same grade. Unlike what people assume, the ratings are not made based on type of fueling source, but rather the calculated efficiency.

        Cost efficiency should follow fuel efficiency, unless there is a drastic price change in fuel cost for one of the fuels and not the others.
      • 4 Years Ago
      I liked this label when I saw it. NADA's opposition only confirms my support for it.
      • 4 Years Ago
      From my viewpoint, the success of the electric car is a given. Whether the Leaf succeeds will depend on two things, the quality of the car and the way that Nissan treats its customers. As one of the first buyers of the Prius, I was very impressed by the way that Toyota went out of its way to keep us happy. Unfortunately not all of their dealers treated us as well. Nissan has an advantage here because based on experience with other EV's the electric car needs so little service that buyers will have little interaction with the dealers.

      There is one selling point of the EV that all writers miss. In the early part of the last century when there were more electric cars than ICEs, they were called "ladies cars" because they were so clean. When I first got my Prius and allowed my sister to drive it during an extended visit, the thing that impressed her most was that she had to stop at gas stations much less frequently than with her car. Women will love the ability to charge the car at home and avoid gas stations.

      I think that the sensible way to buy an electric car is with fast charge capability and without the 240 volt home charger. For most days, an ordinary 110 volt home outlet will be adequate. Inevitably fast charge locations will be common taking care of days that are special. I anticipate that they will soon have chargers along interstate highways, possibly at rest stops, so that electric cars can be used on such things as vacation trips.

      The one thing that really bothers me, as I have written before, is the nature of the government incentive. By tying it to how much income tax you pay, it does not help most buyers. With the same $7,500 as a grant to all buyers, the Leaf would be a $26,000 car and competitive with the Prius. As for all the complaints about how electric cars are not competitive with ICEs because they can only be sold with government help which ICEs don't get, there is no item in our entire economy that gets more government assistance than the ICE vehicle. The only reason that we spend billions, perhaps trillions, not counting lives in the Middle East is to provide oil for the ICEs. And how much does the environmental damage of a major oil spill end up costing the general public.

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