Respond to Draft EPA Stickers for New Plug-In Cars!

By · August 31, 2010

New Proposed EPA Window Sticker Labels

One of many sample labels proposed by EPA and DOT. It's critical to review all the documents so you can provide accurate detailed feedback on the proposals.

In advertisements, fuel economy numbers are the ones that count. In auto showrooms, the window stickers explain these numbers. These stickers are absolutely critical to the prospects for plug-in cars in the marketplace, and have been a long time coming. We've had five years of excitement about the 100+ MPG cars we could someday drive. Now, they're about to arrive!

So the US Environmental Protection Agency and the Department of Transportation want to get this right. To help you, we created this online report, providing links to the proposed stickers and to some of the first media stories, followed by our initial specific technical analysis. We hope those who want to help contribute to the "successful commercialization of plug-in vehicles ASAP" will take Washington up on its invitation to comment in the next 60 days.

The EPA and the DOT's National Highway Traffic Safety Administration have done an outstanding job. We're glad they've found a way to show MPG-equivalents. And they've created some effective graphics and ratings to explain the cost savings and environmental benefits of miles driven in plug-in vehicles. However, they've made it hard for the public to see what's important in the proposals and to contribute their views.

It’s critical that you add your comments to this page. We can make sure that the comments get sent to the EPA. Or you can email your views directly to the EPA about these regulations, which apply to all cars starting with model year 2012.

For those wanting the more detailed full report, please visit the Cal Cars News Archive.

The Basic Documents

Your starting point is the documents about the ruling at Here's where understanding the proposals immediately gets complicated. The site links to two main documents:

  • Seven-page Brochure For the Public
    The brochure includes two label options for the five standard vehicle types: gasoline & diesel (this includes conventional hybrids), electric, plug-in hybrid, flexible-fuel, and compressed natural gas. A small footnote on the cover page saying that the government is "also seeking comment on a third label design" sounds like an afterthought.
  • A Second 19-page Plain Document Only With Images But No Explanations

    This document is entitled, "Proposed Fuel Economy Labels in EPA and DOT Notice of Proposed Rulemaking." Yes, this document includes that third label design, but more importantly, it ALSO includes both "blended" and "extended range electric vehicle" (EREV) variants on the PHEV vehicle type. This second document shows that people who view only the main summary document will have an incomplete picture of what's being proposed, omitting labels for the EREVs/series hybrids that will come to market first: the Chevy Volt, followed soon by the Fisker Karma. And it doesn't effectively present the Toyota Prius Plug-in Hybrid that will follow. Presumably the EPA/DOT were attempting to simplify the issue—but too much was lost.

Deep Dive

The following comments are largely the work of CalCars Technology Lead, Ron Gremban. The points focus on the 19-page document, which you'll need to view as you read these issues.

The EPA and DOT have done an outstanding job. These labels are great, and reflect serious thought and environmental consideration! And including codes scannable by smart phones, they will empower consumers to find out much more.

The top half (down to the section on five-year extra fuel cost or savings compared to an average vehicle) of Label Option 1, for all vehicles, is superb, and provides maximum incentive for buyers to buy green. We hope these ratings and fuel savings are included in the final label design. They produce the ratings that carmakers with many low-ranked vehicles won't want in new car windows in showrooms. Those savings over years—and the demonstrated long-term higher cost of low-ranking vehicles—will provide the best reasons for customers to buy vehicles with high fuel economy and those using clean and cheap electricity.

Cost of Gas. Kilowatt Hour per Gallon.

Although the numbers are placeholders, we suggest a higher price than $2.80 per gallon for gasoline—both U.S. and international oil agencies now expect the price of oil (unlike electricity and natural gas) to increase significantly over the next five years. And we see a strong argument for using a 36.4 kWh per gallon high heat value of gasoline rather than the 33.7 kWh low value. (The extra energy is what's required to vaporize the water vapor in the exhaust, which might conceivably be condensed and recovered in an extra-efficient gasoline vehicle.) But these are minor quibbles with an otherwise outstanding set of labels.

Best Option: Label 1+2.

We see Label Option 2, for all vehicles, as superior to both Label Option 3 and the bottom of Label Option 1 in laying out the details of vehicle performance. We strongly recommend combining the top of Label Option 1 with all of Label Option 2.

Starting with the gas/diesel vehicle (Figure III-9), the gas pump icon, next to the MPG figure and the associated annual fuel cost, all offer obvious visual contrast to the plugs used for EVs and PHEVs. The plots of overall MPG, CO2, and other pollutants on bar graphs read well, too; and are similar to what consumers have seen for years on appliances. Displaying only tailpipe emissions may be the only way to reflect that 'well-to-tank' pollutants vary dramatically between locations and over time, with sources of electricity becoming increasingly clean, while more gasoline is starting to come from such high-CO2 sources as tar sands.

A minor point: throughout, for emissions, we would urge the use grams per kilometer instead of grams per mile. Most consumers will not relate to the absolute number anyway, and what is shown already takes a half step with grams instead of fractional ounces. Why not fully embrace the scientific metric units used by carmakers and governments everywhere else in the world?

Gallons Per 100 Miles

We're delighted to see the gallons per 100 miles figure included. This is a much more important figure than the dumbed-down miles per gallon measure we've grown up with. Seeing it alongside MPG on vehicles will improve consumers' understanding of how fuel economy relates to vehicle size. In fact, taking it one step further, gallons used driving the typical 15,000 miles per year would be even better. Then the huge-seeming 50 MPG difference between 50 and 100 MPG would show up as saving just 150 gallons in a year, while the much smaller-seeming change when a 10MPG vehicle gets 20MG would save 750 gallons—five times as much.

Series Plug-in Hybrid Explanations

The EREV (Figure III-11) label ably explains a complex concept, The line below the two MPG boxes, showing a car driving first "All Electric," then "Extended Range (gas)" is inspired. It clearly shows how the vehicle is powered, with arrows from the electric and extended range miles to the two MPG boxes with electric and gasoline icons, and the 240-Volt charge time shown next to a battery. The "nameplate capacity" of the battery (the basis for federal incentives), is also of value and could be included inside a larger battery icon. Crucially, the boxes show both the "cost per year if always run in All Electric," which an EREV driver rarely exceeding the daily charge range would approach. And it includes the worst-case "cost per year if always run in Gas Only” mode. This latter number would apply only for an unusual driver who decided not to bother spending 15 seconds plugging and unplugging when an outlet was available.

Parallel (Blended) Plug-in Hybrid Graphics

The label for blended-mode PHEVs (Figure III-12) is likewise clear. We would suggest using a color between the electric green and the gasoline yellow to make the blending more obvious compared to the EREV and pure EVs. And perhaps find a way to include kWh per 100 miles along with gallons per 100 miles for the blended mode, so consumers have a way of knowing how much electricity is being used.

This discussion will continue. We hope many interested parties will weigh in publicly and to the federal government. Again, make a study of the documents and post your comments on this page.

For Your Reference

Here are a list of media reports about the proposed labels:


· · 7 years ago

I LOVE seeing the GPC number. We should not have another sticker without it. I'd go further and say that we should lose the MPG figure completely... or hide it really small somewhere for the first couple of years until people figure it out.

My only gripe is that all EVs get an A+. So a Hummer EV that goes half a mile on one kWh or electricity will have the same rating as Leaf that'll go four or five miles on a kWh. But in general, a VERY good change!

· · 7 years ago

I agree with Daryll about all EV's having the same "grade", but it does tell you below the more important things like MPC and KWh per 100 miles so you will know which are more efficient.

They have to cover so many different types of vehicles now and still manage to keep it simple enough that the average person can read it and understand at least most of what it says.

· Tom Schaffter (not verified) · 7 years ago

Volume-Per-Distance Vs. Distance-Per-Volume

Achilles:  You ought to get a plug-in Prius; it'll double you gas mileage, increase it by 50 miles per gallon, from 50 to 100.
Tortoise:  Yes.  Since I drive 20,000 miles a year, that would save me, and the world, 200 gallons every year.
Achilles:  I thought about trading in my F-150 for the hybrid F-150h, but that would only increase my mileage by 3 miles per gallon, from 15 to 18.
Tortoise:  Yes, but you would save more gas than me.
Achilles:  What?
Tortoise:  Since you also drive 20,000 miles per year, your gas consumption would decrease from 1,333 gallons a year to 1,111, saving you 222 gallons.
Achilles:  That's counterintuitive.  I don't get it.
Tortoise:  That's because we're looking at miles-per-gallon, rather than gallons-per-mile, like the Europeans.
Achilles:  The Europeans use gallons-per-mile??
Tortoise: Not exactly; they use liters-per-kilometer, but it's analogous:  volume-per-distance.  Actually they use liters-per-100 kilometers – it gives nicer numbers
Achilles:  O K.
Tortoise:  So let's look at the issue again using gallons-per-100 miles:  My Prius uses 2 gphm, and a plug-in Prius uses 1 gphm; so you save 1 gphm, or 200 gallons in 20,000 miles.  The F-150 uses 6.67 gphm (15 mph), and the F-150h only uses 5.56 gphm (18 mph), saving over 200 gallons, better than the Prius up-grade!
Achilles:  Wow!  Amazing!  And I think I get it.  But there's another issue, O Brilliant One.  What if gas goes up to $5.00 per gallon, which I think is in our near-future?  Then I don't think I'll be able to afford to drive 20,000 a year in my F-150 – that would be, let's see:  6.67 gphm gives $33.33/100 m, or $6670 for 20,000 miles.  Suppose I don't want to increase my gas budget?  This year gas has averaged about $2.75 per gallon; that's $18.34 phm, or $3,670 for my 20,000 miles.  That budget would only allow me 11,000 miles at $5/g.  Now if I get the hybrid truck, with its measly 20% increase in mpg, I  only get a 20% increase in miles for my fixed gas budget, or 13,200 miles.  But if you had a fixed budget, your double-mph-up-grade would allow double milage.
Tortoise: (humbly) I hadn't though of it that way, you clever fellow.  If you'll allow me to summarize:  if one's distance is fixed, then the units, volume per distance (e.g. gphm), will tell one usage; i.e. comparing gphm of two vehicles will easily give usage change.  But if volume is fixed (by budget constraint), then one needs distance-per-mile figures to conveniently compare how far one can drive.
Achilles:  How would I get by without you!

· · 7 years ago

Nice work, Tortoise.... er.. Tony.

I do wish we had a better way of expressing GPC. I'm not sure GPHM is better. Took me a while to figure out what that meant, actually!

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