ACEEE Comments on Revisions and Additions to Motor Vehicle Fuel Economy Label Proposal

EPA and NHTSA have two aims in redesigning the fuel economy label: i) to help consumers choose more efficient and environmentally friendly vehicles, and ii) to help consumers understand the performance of advanced technology vehicles. The agencies have made several useful proposals that can promote the first of these aims, including highlighting vehicles’ fuel consumption, as well as fuel economy, and adding information on GHG and criteria pollutant emissions to the label. ACEEE does not always agree with the agencies on the proposed implementation of these features on the labels, and in particular we believe that fuel efficiency and environmental performance should be treated as distinct attributes. We strongly support the agencies’ proposal to rate all vehicles on a single scale, rather than provide within-class ratings only. We also support a categorical environmental rating as a central component of the vehicle label if the rating properly captures the GHG emissions of the vehicle, including full fuel-cycle emissions, and is oriented toward comprehensive environmental performance. None of the proposed labels meets this criterion, however.

With regard to the second aim, ACEEE does not find the agencies’ proposal to be successful, largely as a consequence of its consideration of tailpipe GHG emissions only. Unfortunately, this element has the potential to do damage that goes beyond confusion of consumers, to undermining both the credibility of EPA and public support for advanced technology vehicles.