EPA-AA-CPSB-81-02
A Comparison of Current and Proposed Vehicle Labeling Programs
by
Clifford D. Tyree
January 1981
Notice
This is a Technical support report for regulatory action and it does not
necessarily represent the final EPA decision on regulatory issues. They are
intended to present a technical analysis of issues and recommendations
resulting from the assumptions and constraints of that analysis. Agency
policy constraints or data received subsequent to the date of release of
this report may alter the recommendations reached. Readers are cautioned to
seek the latest analysis from EPA before using the information contained
herein.
Technical Support Section
Certification Policy and Support Branch
Office of Mobile Source Air Pollution Control
U.S. Environmental Protection Agency
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I. Purpose
II. Current Labeling Program Description
A. Test Procedures
B. Type of Labels
1. Specific Label
2. General Label
C. Terms Used in Labeling
1. Model Type
2. Base Level
3. Vehicle Configuration
4. Subconfiguration
D. Determination of the General Label Value
1. Calculation Procedure
a Vehicle Configuration's Fuel Economy
b. Base Level Fuel Economy
c. Model Type Fuel Economy
III. Modified Labeling Program
A Background
B. Description of Calculation Procedure and Equations
C. Actual Equations
D. Completed Calculation of Fuel Economy Values' Model Type Label
Determinations; Values and Level of Detail Within Product Line
1. Modified Model Type Labels
2. Modified Model Type Labels + Axle Labels
3 Modified Model Type Labels + Axle Labels + ETW
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4. Modified Model Type Labels + Axle + ETW + RLHP
5. Modified Model Type Labels + Subconfiguration
IV. Effect of Modified Labeling Program on the 1981 General Label Data Base
1. Background
2. Analysis of Data
a. Cars
b. Trucks
Appendices
A. Domestic and Foreign Manufacturers
B. Domestic Manufacturers
C. Foreign Manufacturers
D. Individual Manufacturers' Fuel Economy Differences for Each Level
of Labeling Detail
E. Number of Labels Required versus Level of Labeling Detail for
Each Manufacturer
F. Individual Model Types' Fuel Economy Differences for Each Level
of Labeling Detail
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I. Purpose
The purpose of this report is to describe (1) the current labeling
program, (2) the proposed labeling program, and (3) to provide an
analysis of the differences between the two programs. The analysis will
address several options available within the proposed labeling program.
Except to briefly describe how the fuel economy data are used in the
corporate average fuel economy (CAFE) calculations and in the determination
of the Gas Guzzler Tax, this document will not address these areas of the
fuel economy program.
II. Current Labeling Program Description
The data from the present EPA fuel economy testing program are
used in three ways: (1) to generate fuel economy label values for -use by
consumers, (2) to determine manufacturers' compliance with CAFE requirements,
and (3) to generate data from which the IRS can establish manufacturers' Gas
Guzzler Tax liability. (EPA and Department Of Energy have a combined
responsibility to make available to the public in the Gas Mileage Guide (the
Guide) the fuel economy values displayed on the labels which are affixed to
each new car.)
The EPA responsibilities for the above functions are to (1)
administer the testing, program that generates the fuel economy data, (2)
determine necessary procedures and verify the calculation of fuel economy
values for labels, the Guide, and CAFE and, (3) provide IRS with fuel
economy data in order for them to determine a manufacturers tax liability.
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A. Test Procedure
A fuel economy test comprises data obtained from two separate
12 34
test procedures; the urban cycle ' and the highway cycle ' . The urban
cycle (or city cycle) is intended to simulate city type driving conditions,
i.e , stop and starts, with intermediate vehicle speeds. The highway cycle
does not include any stop or starts within the cycle, does not have "quick"
changes in speed, but represents higher speeds of in-use operation
characteristic of open country roads, in the range of 40 to 50 mph.
1. Urban Cycle- A complete urban test cycle consists of a "soak"
period of at least 12 hours prior to the test at a laboratory ambient
temperature between 68 and 86 F. During this soak period the engine is
not started. After the soak, the vehicle is placed on a chassis dynamometer
and the sampling equipment attached, a technician starts and "drives" the
vehicle for a distance of 7.5 miles matching the vehicle speed with
the speed on a pre-printed chart. Upon completion of the simulated 7.5 mile
trip the engine is shut off for a period of ten minutes, as one might after
arriving at the store, office, etc. The engine is restarted and the
operator drives the vehicle over the first 3.6 miles of the driving schedule
again. The total distance driven is 11.1 miles During the 11.1 miles, 21
stop and starts are made and a maximum speed of 56 miles per hour (mph) is
reached. The average speed over the complete cycle is 21 mph which includes
the idle time during periods when the vehicle is stopped.
1. Kruse and Huls, "Development of the Federal Urban Driving Schedule", U.S.
Environmental Protection Agency, SAE Paper 730553, May 1973.
2. Huls, "Evaluation of Federal Light-Duty Mass Emissions Regulations", U.S.
Environmental Protection Agency, SAE Paper 730554, May 1973
3. Kruse and Paulsell, "Development of a Highway Driving Cycle for Fuel
Economy Measurements", U.S. Environmental Protection Agency, Internal EPA
Report, March, 1974
4. Austin, Hellman, and Paulsell, "Passenger Car Fuel Economy During Non-
Urban Driving", SAE Paper 740542, August 1974
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The first part of the driving cycle is commonly referred to
as the "cold start test" as the vehicle has not been operated for a minimum
of 12 hours. The first part of the second cycle is known as the "hot start
test" as the engine has only been shut off for a maximum of 10 minutes.
2. Highway Cycle: The highway cycle consists of one test
cycle of 10.2 miles with no intermediate stop or starts. The maximum speed
during this cycle is 60 mph with an average speed of 49 mph. When possible,
the highway cycle is conducted within three hours of the urban cycle. If it
is not possible to conduct the highway procedure within three hours of the
urban cycle, the vehicle is preconditioned by operating the vehicle over one
cycle (7.5 miles) of the urban test procedure.
3. Data Obtained- During each driving cycle the level of
exhaust emissions are determined for hydrocarbons (HG), carbon monoxide
(CO), carbon dioxide (CO ), and oxides of nitrogen (NO ). From these
^ A.
raw data, exhaust emission levels can be expressed in grams of pollutant per
mile and the fuel economy in gallons of fuel per mile. The weight of
pollutants and volume of fuel are determined from the chemical composition
of the exhaust gases using a carbon balance chemical equation. The distance
is obtained from the driving schedule.
4. Standards- Each fuel economy test comprises of data
from both the urban and highway cycles The urban cycle is the same cycle
used to determine compliance with the exhaust emission standards. In order
for any fuel economy data to be accepted, the emission levels measured on
the urban cycle must not exceed the applicable emission standards. There are
no emission standards for the highway cycle.
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B. Types of Fuel Economy Labels
The EPA is responsible for specifying, by rule, the form and
content of the fuel economy labels and the manner in which they are affixed.
The Energy Policy and Conservation Act requires that manufacturers have
fuel economy labels installed on each car and light truck it produces for
sale in the United States. Dealers are required to keep that label on the
vehicle until it is delivered to the consumer. Each label must include the
following information* (1) the EPA estimated fuel economy of the automobile,
(2) the estimated annual fuel cost associated with the operation of the
automobile, (3) the range of fuel economy of comparable automobiles and, if
applicable, (A) a Gas Guzzler Tax statement. All of the above information is
to be determined according to rules prescribed by the Administrator.
The single fuel economy value that is depicted on the current
label is called the "estimated mpg." The value is determined by combining
numerous city test values as described, in more detail, in section III of
this report. There are currently two types of fuel economy labels that
manufacturers may have approved. These are the general label and the
specific label.
1. General Label/Model Type Label' The general label displays a
fuel economy estimate for a model type. The term model type, covers many unique
vehicles which are similar in body style, engine, and transmission. These vehicles
can be different in other ways that affect fuel economy thus the name "general"
label. For example, differences such as weight, axle ratio, etc., will be found
5. Public Law 94-163, 89 Stat. 871, December 22, 1975
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within a model type. The model type fuel economy value is calculated
from fuel economy data collected from different vehicle designs and averaged.
This calculation procedure is an average of the vehicle data, taking into
account the anticipated sales of each vehicle used to generate the data.
That is, it is a sales-weighted average. (The procedure for sales weighting
is ^described in more detail infection III of this report.). The general
label values are determined once for each model year, and are not changed
during that model year.
2. Specific Label- A specific label contains the fuel
economy of a unique vehicle configuration. EPA only allows the use of the
specific labels early in the model year. Usually, manufacturers use
specific labels when they believe data are not available to calculate a
representative general label value. However, once the general label value
is available, it must be used; any specific label within that model type
can no longer be used. One reason for this is to keep manufacturers from
affixing specific labels on only the best vehicles while using the more
average general label value on the worst vehicles.
C. Terms Used in Labeling Program
Before beginning the description of the actual process, it is
helpful to understand the basic terminology EPA uses in describing and
grouping the various vehicle models and designs. EPA begins by sorting a
vehicle manufacturer's product line into (a) model types, (b) base levels,
(c) vehicle configurations, and (d) vehicle subconfigurations. Some of the
definitions used in the calculation procedures are-
6. A complete listing of definitions used in the fuel economy program can
be found in 40 CFR 600 002-80.
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1. Model Type: EPCA established the term "model type" as
the classification of vehicles for the purpose of averaging for CAFE
values. EPA defined model type on the basis of vehicle characteristics
readily recognized by consumers and important from a fuel economy perspective
(e.g., the general name of the vehicle, engine, and transmission).
Definition: a model type is defined as a unique combination of
car line, basic engine, and transmission class. (See Table I)
A car line denotes a group of vehicles within a make or car
division which are similar in construction (such as Chevrolet Camaro). The
level of decor or opulence is not considered when establishing a car line.
Features such as roof line, number of doors, seats or windows, generally do
distinguish characteristics of a car line. Station wagons, however,
are considered distinct car lines from sedans. The basic engine classification
includes the number of engine cylinders, engine displacement, and the fuel
system. The transmission class is determined by whether it is a manual,
automatic, or semi-automatic, along with the number of forward gears (such
as three speed or four speed).
Table 1 (next page) contains a simplified description of a
ficticious manufacturer's product line which will be used in sample cal-
culation making use of the basic definitions. Each line in the table
represents a vehicle that could be purchased from a dealer. In this
example the basic engine and transmission class are the same for the entire
product line. The model types in this product line are represented in
Table II.
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TABLE I
page 10
-Model Type-
Example Data
, Transmission
Car Line
Swift
Swift
Cardinal
Card inal
Cardinal
Bluebird
Card inal
Bluebird
Basic
Engine
300-2V
300-2V
300-2V
300-2V
3 00- 2V
300-2V
300-2V
300-2V
2
Class
M4
M4
M4
M4
M4
M4
M4
M4
3
Conf ig
M4
M4
M4
M4
M4
M4
M4
M4
a
b
b
c
a
c
c
c
Inertia
Weight
3500
3500
3500
3500
4000
4000
4000
4000
Engine
Code
1
2
2
3
1
3
3
3
Axle
Ratio
2.73
2.43
2.73
3.08
3.08
3.08
3.36
3.36
Road Load
Horsepower
9.8
8.9
10.4
10.4
9.5
10.6
10.4
10 9
Equivalent
Test
Weight
3500
3375
3625
3500
3875
4000
4000
4250
Sales
f
12;000
3;<000
12,000
14,000
3,000
10,000
6,000
15, -000
Measured
Fuel
City
***
16.6
***
***
***
14.7
***
14.0
Economy
Highway
***
22.2
***
***
***
17.5
***
16.3
4
Index
1A
IB
1C
ID
2A
2B
2C
2D
-Base Level-
-Vehicle Configuratlon-
-Vehicle Subconfiguratlon-
*** Untested
Note: Each term in the heading is defined either in Section II of the text or below.
300 - 2V = 300 CID with a
2 venturi carburetor.
Manual and Automatic
Transmissions would
be in different classes.
3.a. The base level is made up of the
transmission class not configu-
ration. The vehicle configuration
and vehicle subconfiguration include
transmission configurations.
3.b. Codes a, b, and c represent the
final transmission gear ratio:
a = 1.00
b = 1.05
c = 1.10
The 'index references will be
used in the text of this
i
report as a short hand method
of identifying a specific
vehicle description.
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*^*J
*
*
*
*
*
*
*
*
*
' *'
*
*
*
*
*
Index*
for Model Types
A
B
C
*
Model
Car Line
Swift
Cardinal
Bluebird
Table II
Types for Example Data
Basic Engine Transmission Class
300- 2V M-4
300-2V M-4
300-2V M-4
1
*
*
*
*
*
*
*
*
*
*
*
*
*
*
An index will be supplied so that when referencing a specific item *
* in a table in this report the line of information can be identified. *
* *
"it "ft "ft "frft ^f "fcfc ifc^Ar"Api/rifr"
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An excerpt of the table depiciting the relationship between
loaded vehicle weight, equivalent test weight and inertia weight is shown
below:
7 8
Loaded Vehicle Equivalent Inertia Weight
Weight-Pounds Weight-Pounds Class-pounds
* * *
* * *
3,313 to 3,437 3,375 3,500
3,438 to 3,562 3,500 3,500
3,563 to 3,687 3,625 3,500
* * *
The complete relationship is found in 40 CFR 86.129-80.
Referring then to the example data in Table I, the product
line is made up of two base level. That is, since each vehicle has the
same basic engine (300-2V) and the same transmission class (M4), the differences
in their inertia weights determine base levels. Since there are only two different
inertia weights listed in this product line there can be only two base
levels.
7. Means the vehicle curb weight plus 300 pounds to simulate a driver and
passenger.
8. Means the weight within an inertia weight class which is used for the
dynamometer testing of a vehicle. (Since dynamometers are not infinitely
variable incremental settings have to be specified.)
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******************************************************************^
* *
* Table III *
* *
* Base Levels in Example Data *
* *
* *
* Index Inertia Index Referred *
* for Base Level Weight from Table I *
* *
* I 3,500 pounds 1A through ID *
* *
* -II - 4,000-pounds " " 2A" through 2D *
* *
***************************************************************************
3. Vehicle Configuration: Design differences within base
levels can still have an affect on fuel economy. Therefore, for the
purpose of describing unique test vehicles, base levels are further subdivided
into vehicle configurations.
Definition- a vehicle configuration is defined as a
unique combination of inertia weight class, basic engine, and transmission
class (all of'which determine a base level) plus engine code, transmission
configuration, and axle ratio.
An engine code goes beyond the definition of basic engine
by isolating different variations of carburetor, distributor, and other key
engine and emission control system component calibrations. Similarly,
transmission configuration considers shift calibrations and other design
factors that determine the performance of the transmission.
4. Subconfiguration: Two more vehicle parameters are used to
describe a vehicle for the purpose of fuel economy testing equivalent test
weight and road-load horsepower. Equivalent test weights are the subdivi-
sions of inertia weight class which most closely approximates the weight of
the actual test vehicle. Road-load horsepower is horsepower required to
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overcome vehicle engine friction, dnveline friction, and air resistance
in order to keep a vehicle rolling at a constant speed. While EPA has
informally used the term subconfiguration, this term will be formally
defined in a new fuel economy regulation to mean the unique combination of
equivalent test weight and road-load horsepower within a vehicle configura-
tion.
D. Determination of the General Label Value*
The minimum amount of test data required to determine a
general label value is data from at least one vehicle configuration
within each base level. If data from more than one configuration is
available within a base level, the base level fuel economy is determined by
a sales-weighted average of all the tested configuration fuel economies.
Each model type may contain several different base levels since a model
type can span several different inertia weight classes. That is,
Model Type = basic engine, transmission class, and carline
Base Level = basic engine, transmission class, and inertia weight class
The difference between model type and base level is carline and inertia
weight class. Thus, if there is more than one inertia weight class within a
carline the model type will have more than one base level. The base level
fuel economy values within each model type are sales weighted and averaged
to obtain the model type fuel economy values. These are the fuel economy
values printed on the vehicle fuel economy labels.
1. Calculation Procedure
a. Vehicle Configuration's Fuel Economy If there is
only one set of city and highway fuel economy values (highway values are
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not included on the label) for a vehicle configuration, then these data
(rounded to the nearest tenth mpg) represent the vehicle configuration's
fuel economy. If there had been more than one vehicle tested within a
configuration, these data would be harmonically averaged and the resultant
value would represent the vehicle configuration's fuel economy.
The term harmonically averaged, in mathematical terms, is;
H- 1 " - - N
N N 1
Z 1 -I
J
NX. . .
j-1 J J
N
x is used to denote the sum of all x 's from
J J
j=l to j=N
The harmonic average of 2, 4, 8 is:
H = 3 = 3.43
1 + 1 + 1
248
The harmonic average is used instead of the arithmatic
average because the average of the individual vehicle fuel economy values
does not equal the average fuel economy for the vehicles as a group. For
example
Car A first goes 100 miles and uses 10 gallons of fuel,
thus achieving 10 mpg.
Car A then goes 100 miles and uses 5 gallons of fuel, thus
achieving 20 mpg.
The average fuel economy is equal to total miles driven by
the total fuel consumed or:
100 + 100 = 200 _,.,.,.,
10+5 15
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i
The average of the individual vehicle fuel economy values is
10 + 20 ._ , . , v
r =15 tnpg (.arithmatic average)
The harmonic average of the individual fuel consumptions
yields:
2
: : = 13.3 mpg; the true average fuel economy.
10 20
b. Base Level Fuel Economy: The fuel economy of each
base level is comprised of the average fuel economy of each tested vehicle
configuration within the base level. These data are "weighted" in propor-
tion to the projected sales of the vehicle subconfiguration. That is,
within the same base level, if the fuel economy from one vehicle configura-
tion is very high but with very few sales and the fuel economy from another
vehicle configuration is not as high but represents a larger proportion of
sales, the fuel economy from the base level would be "weighted" such that
average fuel economy would be nearer the lower value. For example:
Vehicle configuration A = 30 mpg sales = 100
Vehicle configuration B = 22 mpg sales = 9,900
Total sales of a base level = 10,000
Base level fuel economy = 1
100 1 9,900 _1
10,000 30 10,000 22
= 22.0588 mpg
Sales weighting is necessary to ensure the best repre-
sentation of the fuel economy of the vehicles within the base level.
In base level I (ref. Tables I and III), there is only one
tested configuration, therefore, base level I's fuel economy = 16 6 mpg city
and 22.2 mpg highway.
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In base level II there are two configurations tested (ref.
Subconfiguration Index 2B and 2D of Table I). Since there is more than one
tested configuration, the base level fuel economy will be determined according
to the general equation:
Base level
fuel econ.
1
"Fraction of
total sales of
configurations
teseted repre-
sented by
configuration
No 1 sales
1
Configuration
No. 1 fuel
economy
Fraction of
total sales of
configurations
tested repre-
sented by
configuration
No. 2 sales
1
Configuration
No. 2 fuel
economy
Within base level 2, index 2B represents vehicles of one
configuration. Indexes 2C and 2D represent vehicles of a second configuration,
but different subconfigurations within that second configuration. Each of
these configurations is represented by test data, so the total sales of
each will be used to determine the base level fuel economy.
Sales of tested configuration No. 1 (2B) = 10,000
Sales of tested configuration No. 2 (2C + 2D) = 21,000
Total Tested Configuration/Base Level Sales = 31,000
No. 1 sales fraction = 10,000 = 0.3226
31,000
No. 2 sales fraction = 21,000
31,000
= 0.6774
Configuration No. 1 fuel economy
Configuration No. 2 fuel economy
Base Level II's fuel economy =
14.7 city and 17.5 highway
14.0 city and 16.3 highway
(0.3226) 1 + (0.6774) 1
14.7
14.0
= 14.2184 mpg
(Similarly the highway value = 16.6687 mpg)
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* *
* Table IV *
* *
*
* Base Level Fuel Economy *
* *
* City Highway *
* *
* A = 16.6 22.2 *
* . *
* B = 14.2184 16.6687 *
* *
* *ref. Table III *
* *
* Note: Data depicted to one decimal place are from actual tests. *
* *
* Data depicted to four places represent averaged data. *
* *
c. Model Type Fuel Economy: When only one base level
exists within a model type, the base level fuel economy, rounded to the
nearest whole mpg, is the model type fuel economy. In the example product
line of Table I, two model types exist with only one base level; model type
A (ref Table II) with the Swift car line and, model type C with the Blue-
bird car line. Model type B, with the Cardinal car line, contains two base
levels. In order to determine model type B's fuel economy, divide the model
type sales fraction of each base level within the model type by the fuel
economy of the base level. That is;
Within Model type B base level I sales = 26,000 and
base level II sales = 9,000. Total model type B sales = 35,000.
Model B's sales fraction of Base level I = 35'000 = 0.7429
Model B's sales fraction, base level II = --'nnn = 0.2571
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Therefore, model type B's city fuel economy is
1 = 15.9146 mpg
0.7429 + 0.2571
16.6 14.2184
(Similarly the highway value = 20.4549 mpg)
fr x^rifr *ff^df "$c ^riftr^f lAriir^riJnfrifcnfrTfe^rVnft'ifr^fTflf«
* *
* *
* Table V *
* *
* General Label Fuel Economy *
* *
*
*
Model type Fuel Economy *
* *
2 3
* City Highway *
* *
* A 17 22 *
* *
* B 16 20 *
* *
* C 14 17 *
* *
* *
* 1. ref. Table II *
* *
* 2. The city value is the only one displayed on the vehicle labels *
* *
* and is called the "estimated mpg." *
* *
* 3. The highway value is not displayed on the vehicle label, but *
* *
* since this value is used in other EPA calculations for CAFE - *
* *
* requirements it is available and manufacturers frequently advertise *
* *
* this value in addition to the city value.
* *
Thus, each Swift would have a fuel economy label depicting
an estimated mpg of 17; each Cardinal = 16, and each Bluebird = 14. (All
label values are rounded to whole numbers.)
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III. Modified Labeling Program
A. Background
As described in Section II, each value on a fuel economy label
represents the fuel economy estimate of vehicles of the same general
design, called model types. Specifically, the model type includes vehicles
which have the same basic engine and transmission class (defined in Section
II.C), and are in the same car line.
The current general label often does not reflect design differences
which exist within the classification of model types. Differences in axle
ratios, weight, and engine calibration can have a significant affect on the
fuel efficiency of a particular vehicle. Under the current labeling
program, however, the vehicles with these differences receive the same
label value. If we were to test each subconfiguration to determine the
effect of these differences, over 6,000 additional tests would have to be
performed, an increase of 500 percent over current number of tests. An
increase in testing of this magnitude could not be justified in either the
resources required to perform the tests or the associated rise in vehicle cost,
Even though it is not feasible to test each subconfiguration, a
method is available to mathematically adjust test data for several design
differences and produce data applicable to the untested subconfigurat ions.
9
EPA has developed equations to adjust actual test data for differences
in axle ratios, ETW's, and RLHP. Referring back to table I, there were
only three fuel economy values for the example product line Using the
adjusting equations, each vehicle subconfiguration would be represented, by
either test values or adjusted test values. Subsection B of this section
will describe in detail how the calculations are to be made.
9. Murrell, "Technical Support Report for Regulatory Action Light-Duty Vehicle
Fuel Economy Labeling," U.S. Environmental Protection Agency, EPA/AA/CTAB/FE-81-6,
October, 1980
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B. Description of Calculation Procedure and Equations
With the calculation procedure described in this report each
vehicle subconfiguration described in a manufacturer's product line will
have fuel economy data; either actual data or data derived by adjusting the
actual data for differences between tested and untested vehicle subconfigura-
tions within the same basic engine and transmission class. Although we
were able to derive adjustment equations for axle ratio, RLHP, and ETW; we
were not able to derive equations to adjust for differences between engine
codes nor between transmissions configurations. Therefore, when there
exists an untested engine code and transmission configuration combination
within subconfigurations, the actual test data with the same basic engine
and transmission class combination will be adjusted for any differences in
axle ratio, RLHP, and ETW between the tested and untested subconfiguration.
The results are then harmonically averaged together.' This average value
will then become the adjusted fuel economy value for that untested engine
code and transmission configuration combination.
The simplest case is to adjust an untested subconfiguration that
has the same engine code and transmission configuration as does a subconfigu-
ration with actual test data. (See example 1 below.) If there exists two
or more subconfigurations with test data having the same engine code and
transmission configuration as the untested subconfiguration, each of these
tested subconfiguration will be adjusted to the untested subconfiguration
and the resultant adjusted data would be harmonically averaged (see example
2 below). If the untested subconfiguration also has an untested engine
code and transmission configuration combination, each tested subconfigu-
ration having the same basic engine and transmission class will be adjusted,
and the sales weighted harmonic average would then represent the untested
subconfiguration (see example 3 below).
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The basic adjustment equation is:
FEAJ. = FE_ + dFEA . + dFE^... + dFE,1T,
Adj T Axle ETW HP
Where :
FE.,. = adjusted fuel economy
Adj
FE = Tested fuel economy (i.e., actual data)
dFE , = Change in fuel economy due to differences in axle ratios
___ dFE = Change in fuel economy due to differences in ETW
Hi X W
dFE = Change in fuel economy due to differences in RLHP
RLHP
The difference in fuel economy (dFE) is found as follows:
dFE = FEu - F = FE / 2(S)(dX)
V2(X) - S(dX)>
Where'
FE = untested fuel economy
u
FE = tested fuel economy
dX = difference between untested and tested parameter, e.g., if
the tested subconfigurations had an axle ratio of 2.76 and the
untested was 2 56; dX = X - XT or dX = 2.56 - 2.76 = -0.20
X = average of parameter specifications, i.e., Axle ratio (AR),
Equivalent Test Weight (ETW), Road Load Horsepower (RLHP); e.g. for
axle ratios of 2.76 and 2.56, x" = (2.76 + 2.56)/2 = 2.66
(Note: Tested is always subtracted from untested parameter value.)
-------
-23-
S = sensitivity factor, where:
For Axle,
City
S = 1.025 - 0.437(AR) (without overdrive)
Axle
City
S = 1.028 - 0.376(AR) (with overdrive)
Axle
Hwy
S = 0.578 - 0.380(AR) (without overdrive)
Axle
Hwy
S = 0.580 - 0.327(AR) (with overdrive)
Axle-
For Equivalent Test Weight,
- - - -
S = -0.657 + 9.542(10 3)W + 3.512(10 IU)W
ETW
Hwy * L in 9
S = -0.626 + 1.024(10 )W + 8.174(10 U)VT
ETW
For Road-Load Horsepower,
City .
S = -0.247 + 0.756(10 )RLHP
RLHP
Hwy
S = -0.483 + 1.325(10 )RLHP
RLHP
C. Actual Calculations
1. In the example data in Table I, engine code 2 with transmission
configuration b has one subconfiguration tested (ref. index IB) and one
subconfiguration untested (ref. index 1C). To calculate the adjusted city
fuel economy value, the following procedure is used:
Example 1' Adjust city data from tested subconfiguration IB to
determine fuel economy of untested subconfiguration 1C.
Tested index IB: Axle = 2.43, RLHP = 8.9, ETW = 3375, FET = 16.6
Untested index 1C- Axle = 2.73, RLHP = 10.4, ETW = 3625, FEAd = ?
-------
-24-
STEP 1: Correct for differences
a. Correct for axle differences
dX = 2.73 - 2.43 = 0.30
X" = (2.43 + 2.73)/2 = 2.58
FET = 16.6 mpg
S = 1.025 - 0.437(AR) = -0.1025
dFE = FE / 2(S)(dX) \ = 16.6 [ 2(-0.1025X0.30)
fUC A. S J.
- S(dX)/ \2(2.58) - (0. 1025)(0.30)j
dFEAxle = ~0-1966
b. Correct for RLHP differences
dX = 10.4 - 8.9 = 1.5
X" = (8.9 + 10.4)/2 = 9.65
FE =16.6 mpg
,-2,
S = -0.247 + 0.756(10 )RLHP = -0.1740
2(S)(dX) \=16.6/ 2(-0.1740)(1.5)
nTUT>
RLnP
2(X) - S(dX)/ V 2(9.65) - (-0.1740X1.5),
= -0.4431 mpg
c. Correct for ETW differences
dX = 3625 - 3375 = 250
X = 3,500
FE = 16.6 mpg
_ c 1 0 2
S = -0.657 + 9.542(10 )W + 3.512(10 )W = -0.3187
,_ _ __ / 2(S)(dX) \ ., , I 2(-0.3187X250)
ETW = T ( 2(X) - S(dX) "
= -0.3737 mpg
-------
-25-
STEP 2: Combine correction factors
= FET + dFEAxle + dFERLHP + dFEETW
= 16.6 + ( -0.1966) + (-0.4431) + (-0.3737)
= 15.5866 mpg
2. In the example data in Table I, engine code 3 has two tested
subconf igurations (ref: index 2B and 2D) and two untested subconf iguration
(ref. index ID and 2C). To calculate the adjusted city fuel economy
value, the following procedure is used
The first step is to adjust the data from the tested
subconf igurations for any differences between them and the untested
subconf igurat ions in axle ratio, road-load horsepower (RLHP), and equivalent
test weights (ETW). (The actual order is not important.) Since there is
more than one tested subconf iguration with the same engine code, the
adjusted data will be harmonically averaged.
Example 2: Calculate the city fuel economy for subconf iguration ID*,
Untested vehicle ID has an engine code of 3 and a transmission
configuration c. Since there are two tested subconf igurations with the
same engine code and transmission configuration, 2B and 2D, each one is to
be adjusted for any differences in axle, ETW, or RLHP that exists between
it and vehicle ID. (Note that 2B and 2D are not in the same base level as
ID, but can still be used to derive data for ID since they are in the same
basic engine and transmission class as ID.) The data will be harmonically
averaged and the results will be used to represent ID. The calculation
procedures are as follows:
*This identification can be found under the column headed "Index" in Table I.
-------
-26-
Adjust 2B for difference between it and ID.
Tested Index 2B. Axle =3.08 RLHP =10.6 Test Wt. = 4000 FE = 14.7 mpg
Untested Index ID: Axle = 3.08 RLPH = 10.4 Test Wt. = 3500 FE = ?
STEP 1 Correct for differences between 2B and ID
a. Correct for Difference in Axle: No difference, No Correction
b. Correct for Difference in RLHP
dX = 10.4 - 10 6 = -0.2 SClty = -0.247 + 0.756(10~2) x"
RLHP
X = (10.6 + 10.4)/2 = 10.5 = -0.1676
HTTF - 14 7 2(-0.1676)(-0.2)
RLHP ~ I 2(10.5) - (-0.1676X-0.2) j = 0.0470 mpg
c. Correct for difference in ETW
dX = 3,500 - 4,000 = -500
X" = (4,000 + 3,500)/2 = 3,750
FE2B = 14.7
city -5 _ -in -2
S = -0.657 + 9.542(10 )X + 3.512(10 )X = -0.2942
ETW /
12 (-0.2942K-500) \ = 0.5882 mpg
dFE , = 14.7 2 (3,750) - (-0.2942) (-500)
ETW \
-------
-27-
STEP 2: Combine correction factors
city
FE = FE._ + dFE . + dFE T UT, + dFE _
1ri c _ 2B axle RLHP ETW
ID from 2B
= 14.7 + 0.0 + 0.0470 + 0.5882
» 15.3352 mpg
STEP 3: Correct for differences between 2D and ID
Tested Index 2D: Axle = 3.36 RLHP = 10.9 Test Wt . = 4250 FE = 14.0
Untested Index ID: Axle =3.08 RLHP = 10.4 Test Wt . = 3500 FE = ?
a. Correct for differences in Axle:
dX = -0.28 S = -0.247 + 0.756(10-2)
_ = -0.3821
X = 3.22
^20 = 14.0
dFE = 14.0 2(-0.3821) (-0.28) _ = 0.4731 mpg
6 2(3.22) - (-0.3821X-0.28)
b. Correct for differences in RLHP
dX = -0.5 S = -0.247 + 0.756(10~2) X~
"X = 10.65
FE = 14.0
dFE = 14.0 2(-0.1665) (-0.5) _ = 0.1099 mpg
2(10.65) - (-0.1665) (-0.5)
-------
-28-
c. Correct for differences in ETW
_ c in 9
dX = 750 S = -0.657 + 9.542(10 3)W + 3.512(10 )W
X" = 3875 = -0.2820
FE = 14.0
dFEETW = 0.7855
Step 4: Combine correction factors
FECLty = 14.0 + 0.4731 + 0.1099 + 0.7855
ID from 2D
= 15.3684 mpg.
Step 5: Average the adjusted values from 2B + 2D to get the harmonic
estimate of ID.
City FE1D = N =
1
FE1D-2D
15.3518 mpg
1
15.3352 15.3684
3. In the example data in Table I, the combination of engine
code 1 and transmission configuration (a) (Ref- indexes 1A and 2A) is not
represented by any data. To calculate the fuel economy for either of these
subconfigurations the following procedure is used
Adjust each test data in the same basic engine, transmission
class as the untested subconfiguration, for differences in ETW, Axle, and
RLHP between it and the untested subconfiguration. If there is more than
one tested vehicle within an engine code, basic engine, and transmission
configuration combination, the adjusted data are harmonically averaged. The
adjusted subconfiguration values and any harmonic average value are then
sales weighted together based on the total projected sales of the basic
engine, engine code, and transmission configuration combinations.
-------
-29-
Example 3: Calculate the city fuel economy value for untested
subconfiguration 1A which has an untested combination of engine code (code
1) and transmission configuration (a). The tested subconfigurations in the
same basic engine and transmission class are IB, 2B, and 2D. Adjust each
tested subconfiguration for differences in axle, RLHP, and ETW between the
tested subconf iguration and the* untested subconf iguration.
STEP 1: Correct for differences between 1A and IB
Adjustment of subconfiguration IB.
FE of 1A from IB: FE 1 = FE +
Using method of FE described in the previous example:
FE = 16.6 + (-0.1966) + (-0.2794) + (-0.1949)
= 15.9291 mpg
STEP 2- Correct for differences between 1A and 2B
Adjustment of subconfiguration 2B
FE = 14.7 + 0.4395 + 0.1972 + 0.5882
= 15.9249
STEP 3: Correct for differences between 1A and 2D
Adjustment of subconfiguration 2D
FE = 14.0 + 0.9143 + 0.2534 + 0.7855
= 15.9531 mpg
-------
-30-
STEP 4: Harmonic average those adjusted values with the same combination
of engine code and transmission configuration in this example 2B and 2D
with engine code 3 and transmission configuration c.
FE = = = 15.9390 mpg
-------
-31-
c. Calculate the sales weighted harmonic average.
FE,
[Total Sales
Sales , \ +
comb.I
1
FE
comb.
Sales
2-b
Total Sale
FE
2-b
Sales
-
Total Sales
«
3-c
/15000\/ 1 \ / 45000\ / 1 \
\6000CXV 15.9291 / UoOOO'' V15.9390/
= 15.9365 mpg
The resultant city fuel economy value for the untested combination
of engine code 1 and transmission configuration (a) with the subconfiguration
parameters described by index 1A is 15.9365.
D. Completed Calculation of Fuel Economy Values
Using the procedure outlined in the two preceeding examples,
values for the remaining city and all the highway values are calculated and
shown in the following completed table, Table VI.
-------
TABLE VI
page 32
Example Data
Car Line
Swift
Swift
Cardinal
Cardinal
Card inal
Bluebird
Cardinal
Bluebird
\Af\A «1
rlOaei
i
Basic
Engine
300-2V
300-2V
300-2V
300-2V
300-2V
300-2V
300- 2V
300-2V
T1 _
lype
Transmission
2
Class
M4
M4
M4
M4
M4
M4
M4
M4
Base Level1
3
Conf ig .
M4 a
M4 b
M4 b
M4 c
M4 a
M4 c
M4 c
M4 c
tr U * 1
venicle
Inertia Engine
Weight
3500
3500
3500
3500
4000
4000
4000
4000
Configuration-
Code
1
2
2
3
1
3
3
3
- Uoh i f 1
Axle
Ratio
2.73
2 43
2.73
3.08
3.08
3.08
3.36
3.36
1 £* Ciir>^»-\f"
Road Load
Horsepower
9.8
8.9
10.4
10.4
9.5
10.6
10.4
10.9
Equivalent
Test
Weight
3500
3375
3625
3500
3875
4000
4000
4250
Tested and Adjusted
Fuel Economy
Sales
12,000
3,000
12,000
14,000
3,000
10,000
6,000
15,000
City
15.9365
16.6
15.5866
15.3518
15.1045
14.7
14.2982
14.0
Highway
19.8127
22.2
19.5877
18.1827
18.3934
17.5
16.7057
16.3
Inde
1A
IB5
1C
ID
2A
2B5
2C
2D5
Note
Each term in the heading is defined either in Section II of the text or below.
300 - 2V = 300 CID with a
2 venturi carburetor.
Transmissions with and
without overdrive would
be in different classes
as would automatic and
manual.
3.b.
The base level is made up of the
transmission class not configura-
tion. The vehicle configuration
and vehicle subconfiguration include
transmission configurations.
Code a, b, and c represent the
final transmission gear ratio:
a = 1.00
b = 1 05
c = 1.10
4. The index references will be
used in the text of this
report as a short hand method
of identifying a specific
vehicle description.
5. Tested subconfigurations
-------
-33-
D. Model Type Label Determinations; Values and Level of Detail
Within Product Line
Now that each subconfiguration is represented by a fuel economy
value, either by actual test data or by adjusted data, label values can be
determined. More data are now available but, the fundamental process
of combining the data remains the same. However, there is no longer a need
to calculate configuration and base level averages. Instead, we will
directly average (according to sales) from the vehicle's subconfiguration
fuel economy. This analysis presents five levels of detail within a
product line by which labels could be determined, all making use of the
same fuel economy values (i.e., test data or adjusted data for all
subconfigurations). They are:
Alternatives Reference Code
1. Modified Model Type Labels A
2. Modified Model Type + Axle B
3. Modified Model Type + Axle + ETW C
A. Modified Model Type + Axle + ETW + RLHP D
5. Modified Model Type + Subconfiguration E
Using the data from Table VI, the procedure to calculate fuel
economy label values directly from subconfiguration is as follows:
1. Modified Model Type Labels: This level of detail is the same
as the current labeling program. However, there is one significant difference;
each subconfiguration will now be represented by data. Using the model
type classification containing the Swift car line of Table VI, a model type
value would be:
-------
-34-
Fuel Economy Reference
Car line Sales City Highway Code*
Swift 12,000 15.9365 19.8127 1A
Swift 3.000 16.6 22.2 1A
Total 15,000
Model Type Label Value = 1
/12,000\/ 1 \ + /3.000 \/ 1 \
\ 15,000/^ 15.9365 ) \ 15,000 J\ 16.6 J
= 16.0649 mpg
= 16 (city) rounded to the nearest whole mpg.
Similarly the model type classification containing the Cardinal
car line is equal to 15.2168 or 15 mpg (city) and the Bluebird car line is
equal to 14.2718 or 14 mpg (city).
Note- Only the model classifications containing the Swift and Bluebird car
lines contain actual test data. All of the data used to represent the model
type classification containing the Cardinal car line are adjusted fuel
economy values.
2. Modified Model Type + Axle Labels: Under this alternative,
within a model type each unique axle ratio will receive a separated label
value. In the above sample calculation there are only two subconfigurations
within the model type classification and, each of these subconfigurations
have a unique axle. Therefore, the model type + axle label value will be
the subconfiguration fuel economy value, rounded to a whole mpg.
Fuel Economy Data Label Values
Car line Axle Sales City Highway City Highway Index
Swift 2 73 12,000 15.9365 19.8127 16 20 1A
Swift 2.43 3,000 16.6 22.2 17 22 IB
*from Table VI
-------
The model type values for the classification containing the Cardinal car
line would be:
Fuel Economy Label Values
Car line Axle Sales City Highway City Highway Index
Cardinal 2.73 12,000 15.5866 19.5877 16 20 1C
Cardinal 3.08 17,000 15.3076 18.2195 15 18 ID and 2A
Cardinal 3.36 6,000 14.2982 16.7057 14 17 2C
3. Modified Model Type + Axle + ETW- Since the Swift and Blue-
bird carelines contain only one ETW within each combination of model type
and axle ratio, further differentiation by ETW will not change their label
values. The number of labels for the model type classification containing
the Cardinal car line would, however, increase by one when separating on the
basis of axle and ETW. That is, for indexes ID and 2A both subconfigurations
have the same axle but differenct ETW's. Therefore, instead of combining
these data, as was done at the axle level of detail, each fuel economy value
will now represent a specific fuel economy label.
4. Modified Model Type + Axle + ETW + RLHP: From the example
data in Table VI the number of labels will not increase when adding RLHP
since no combination of modified model type + axle + ETW has more than one
RLHP. This is due only to our selection of subconfiguration descriptions.
5. Modified Model type + Subconfiguration. (A unique label for
each subconfiguration within a carline): Our example labels would not
change for the same reasons as cited in 4 above.
-------
-36-
Table VII page 38 depicts the label values that would be assigned
under each of the alternatives discussed above. The data that make up this
table was derived from the example data of Table VI. The normal complexities
of a product line were not shown in order that the calculation procedure
could be emphasized. We have, however, taken the 1981 product line for
nine manufacturers (American Motors, Chyrsler, Ford, General Motors, Fiat,
Nissan, Toyo Kogyo, Toyota, and Volkswagen) and performed the subject
calculations. An analysis of that data is presented in section III of this
report.
-------
Page 37
Table VII
Fuel Economy Values for Current and Proposed LabelsMPG
Model Type
1
A
(actual test
data in this
model type:
16.0/22.2)
B
(no actual test
data Ln this
model type)
Present
Model Type"1
city/highway
16/22
(1A&1B*)
C
(actual test
data in this
model type:
14.7/17.5,
14.0/16.3)
Modified
Model Type
c ity/highway
16/20
(1A&1B*)
Model Type-
Axle
city/highway
16/20
(1A*)
17/22
(IB*)
Model Type-
Axle-ETW
city/highway
16/20
(1A*)
17/22
(IB*)
16/20
(1C,1D,2A
& 2C*)
14/17
(2B&2D*)
15/18
(1C,1D,2A
& 2C*)
14/17
(2B&2D*)
16/20
(1C*)
15/18
(1D&2A*)
14/17
(2C*)
15/18
(2B*)
14/16
(2D*)
16/20
(1C*)
15/18
(ID*)
15/18
(2A*)
14/17
(2C*)
15/18
(2B*)
14/16
(2D*)
Model Type-
Axle-ETW-RLHP
c ity/highway
16/20
(1A*)
17/22
(IB*)
16/20
(1C
15/18
(ID*)
15/18
(2 A*)
14/17
(2C*)
15/18
(2B*)
14/16
(2D*)
Model Type-
Subconfigurat ion
city/highway
16/20
(1A*)
17/22
(IB*)
16/20
(1C*)
15/18
(ID*)
15/18
(2 A*)
14/17
(2C*)
15/18
(2B*)
14/16
(2D*)
* Index(s) References
Refer to Table II for description of car lines within a model type.
Refer to Table VI
-------
-38-
IV. Impact of Modified Labeling Program on the 1981 General Label Data Base,
1. Background
The previous section of this report described the modified labeling
program and how to use the adjustment equations. The section will analyze
the effect of the modified labeling program on the actual product line of
nine manufacturers. The 1981 general label data base is the source of the
data and the 1981 general label value is the reference point for all
comparisons. (Note that this comparison does not include the use of an EPA
to in-use correction factor.) It compares only the differences that would
occur due to the modified label calculation method. For example, when the
modified label value is calculated it is compared to the present label
value as follows:
(Modified label value) - (Current label value) = Difference
The "sign" of the resultant difference indicates the direction
the current label value would be adjusted to arrive at the new adjusted
label value. That is, a -1 mpg difference indicates the modified label
value would be 1 mpg less than the current label value.
The data base was comprised of 1981 product lines for nine manu-
facturers; four domestic manufacturers and five foreign manufacturers They
are
Domestic Foreign
American Motors Fiat
Chrysler Nissan
Ford Toyo Kogyo
General Motors Toyota
Volkswagen
-------
-39-
i
As in the example calculations in section III, all subconfigurations
were represented by fuel economy test data or adjusted fuel economy data
prior to calculating the label values. Label values were calculated
for the five different levels of labeling detail described previously. The
manufacturer provided EPA with the total 1981 projected sales for each
subconfiguration at the time their vehicles were labeled. We used these
sales to determine the number of vehicles which would be labeled with a
different fuel economy value if the modified label program were adopted.
Label values, rounded to the whole numbers, were used to determine these
differences.
Three specific comparisons of the current to the modified labeling
system have been made. The comparisons were compiled for all nine manufac-
turers, and also split into the domestic and the foreign manufacturers.
(No attempt was made to separate foreign built vehicles with a domestic
model name or, a foreign manufacturers product line which incorporated
vehicles built in America.) The three specific comparisons made are:
1. Total number of vehicle labels required at each level of
detail.
2. Percent of sales for an absolute fuel economy difference at
various levels of detail.
3. Percent of sales for each 1 mpg fuel economy difference at
various levels of detail.
The tables describing these comparisons are in Appendix A for all
nine manufacturers, Appendix B for the domestic manufacturers, and Appendix C
-------
-40-
for the foreign manufacturers. Appendix D contains percent sales for each
of the manufacturers at differences in label fuel economy values and
Appendix E contains the various manufacturer's difference in the total
number of labels at each level of labeling detail.
2. Analysis of data
The following general observations are made and are applicable
to each level of labeling detail.
a. Cars:
About 30 percent of all cars would receive different
estimates of city fuel economy.
About 25 percent of all cars would have an estimate of
city fuel economy 1 mpg different from the current
label value.
About 5 percent of all cars would have an estimate
of city fuel economy 2 mpg or more from the current
label value.
From 5 to 10 percent of all cars would have a label (city)
value recalculated at a higher fuel economy value than
the present.
About 45 percent of all cars would receive different
estimates of highway fuel economy (currently calculated
but not displayed on the label).
About 35 percent of all cars would have an estimate of
highway fuel economy 1 mpg different from the value
presently calculated.
About 10 percent of all cars would have an estimate
of highway fuel economy 2 mpg or more from the
calculated highway value.
From 15 to 20 percent of all cars would have a recal-
culated highway fuel economy value higher than the
present value.
The range of city fuel economy differences for cars
IB ^ mncr f n +") mno .
-3 mpg to +2 mpg
-------
-41-
- The range of highway fuel economy differences for cars
is -6 mnp to +5 mop.
^-, - - o - . j
is -6 mpg to +5 mpg.
b. Trucks:
- About 30 percent of all trucks would receive different
estimates of city fuel economy.
- About 25 percent of all trucks would have an estimate
of city fuel economy 1 mpg different from the current
label value.
Less than 5 percent of all trucks would have an estimate
of city fuel economy 2 mpg or more from the current
label value.
- Less than 5 percent of all trucks would have a label
value recalculated at higher fuel economy values than
present.
- About 40 percent of all trucks would receive different
estimates of highway fuel economy (currently calculated
but not displayed on the vehicle label).
- About 30 percent of all trucks would have an estimate
of highway fuel economy 1 mpg different from the value
currently calculated.
- About 10 percent of all trucks would have an estimate
of highway fuel economy 2 mpg or more from the
currently calculated highway.
About 10 percent of all trucks would have a recal-
culated highway value higher than the present value.
- The range of city fuel economy differences for trucks
is from -8 mpg to +3 mpg.
- The range of highway fuel economy differences for trucks
is from -10 mpg to +4 mpg.
3. Discussion
In reviewing the data (Appendix A through Appendix E) the effect
the modified label calculation would have on different stratifications of
these data are apparent. Two apparent stratifications are; cars versus
trucks and foreign versus domestic.
-------
-42-
The car versus truck stratification is reflected by the number of
labels necessary for each labeling alternative. That is, going from the
present labeling program to the model type + axle label alternative would
increase the number of car labels by 94, more than a 15 percent increase
over the current 616. The same alternative would increase the number of
truck labels by 287, more than a 64 percent increase over the current 449.
Going from the present program to the most detailed level of labeling
(i.e., car line + vehicle subconfigurations) would increase the number of
car labels by 1187 (about 3 times the current number of labels) and truck
labels by 2023 (over 5 times the current number of labels). (These data
are applicable for the nine manufacturers evaluated.)
In referring to Appendixes A through C, it is apparent that
the increase in labeling detail will also increase the label fuel economy
values of trucks to a greater extent than those values of cars. This is not
an unexpected trend in that manufacturer make available a larger number of
options for trucks that effect fuel economy than for cases e.g., a wide
range of axle ratios, lower geared transmissions, and severe service (heavy
duty) options, the latter often increase the weight of the vehicle.
Within the stratification of cars and trucks there exists another
level of stratification, domestic and foreign manufactured cars and trucks.
This trend is again the result of the number of fuel economy influencing
options offered by the different manufacturers, e.g., the foreign manufac-
turers usuallly offer only a single axle, transmission gearing, or limited
weight adding option for each model type. For example, for the manufacturers
evaluated, the number of labels needed for cars at the model type plus axle
-------
-43-
level of labeling detail increased by 90 for the four domestic manfacturers
(a 19 percent increase over the present label requirements) while a total
of only 4 additional labels would be needed for the five foreign manufacturers
(a 3 percent increase). Similarly, for truck's the increase was 285 for
the domestic manufacturers (a 71 percent increase) while only 2 additional
labels were needed" for the foreign manufacturers (a 4 percent increase).
For the greatest level of detail, an increase of 799 car labels would be
needed for the domestic manufacturers (an increase over the current number
of labels by a factor of 2.8) and 388 labels for the foreign manufacturers
(a factor of 3.75) over the present label requirements. At the same level
of labeling detail for trucks an increase of 1941 labels would be required
for the domestic manufacturers (a factor of 5.8) and 82 labels for the
foreign manufacturers (a factor of 2.7).
The increase in the number of labels is primarily due to the
options available from each manufacturer and not a result of technology.
There will be a cost to the manufacturers to generate and apply these new
labels, however, the consumer will benefit. That is, the label value will
be a more vehicle specific value and the accuracy of the label value will
be improved For example, assuming 10 million new car sales a year, about
3 million cars (30 percent) of the present label values would change by
incorporating any one of the labeling alternatives. With about 2 million
of these new cars with revised labels having the fuel economy estimate
revised to a lower value.
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-44-
Appendixes D depicits the number of vehicles (percent of sales) which would
have their label values change by +1, 0, and -1 mpg for each level of
labeling detail. (The percent of sales does not: equal 100 percent as their
are levels which would change by more than 1 mpg.) In reviewing the effect
of increasing the level of labeling detail for all car manufacturers and
then for all truck manufacturers it is apparent that there is an overall
improvement in the labeling accuracy for trucks for each of the first three
alternatives. For cars, the improvement in accuracy is not as significant
as the level of labeling detail is increased. However, in evaluating the
impact of these labeling alternatives for individual manufacturers, it is
apparent that each manufacturer is affected differently. One manufacturer
(American Motors) would have the largest percentage of vehicles relabeled
with a higher city value. Ford, Chrysler, Nissan, and Toyota would have a
significant number of vehicles which would have label values decreased by 1
mpg. The foreign trucks would be the least effected by any of these
labeling alternatives with very few changes in label fuel economy values or
the number of different labels required.
-------
Appendix A
Domestic and Foreign Manufacturers
Table Nos. Title
A-l and A-2 Relationship of the Number of Labels Required for Each
Level of Label Detail with Sales Percent Differences
within Each Level of Labeling; City and Highway Label
Differences.
A-3 and A-4 Sales Percentages for Absolute Label Differences Versus
Percent Sales: City and Highway Label Differences.
Fuel Economy Differences Versus Percent Sales;
A-5 Modified Model Type Label Value - Current Label Value;
City
A-6 Modified Model Type Label Value - Current Label Value;
Highway
A-7 Modified Model Type + Axle Label Value - Current Label
Value; City
A-8 Modified Model Type + Axle Label Value - Current Label
Value; Highway
A-9 Modified Model Type + Axle + ETW Label Value - Current
Label Value; City
A-10 Modified Model Type + Axle + ETW Label Value - Current
Label Value; Highway
A-ll Modified Model Type + Axle + ETW + RLHP Label Value -
Current Label Value; City
A-12 Modified Model Type + Axle + ETW + RLHP Label Value -
Current Label Value; Highway
A-13 Modified Model Type + Subconfiguration Label Value -
Current Label Value; City
A-14 Modified Model Type + Subconfigurat ion Label Value -
Current Label Value; Highway
-------
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Sales Percent Differences From Current Model Labels
-ent Model Proposed Proposed Proposed Proposed Proposed
; (MT) MT MT + Axle MT + Axle MT + Axle MT + Subcon-
+ ETW + ETW + RLHP figuration
l i i i ii i i i i i i i i i i i i
Table No. A-l Relationship of the Number of Labels Required
--
--
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u-
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Level of Detail
-------
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Table No.
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A-2 Relationship of the Number
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-------
Table A-3
Domestic and Foreign, Cars
Absolute Label Differences versus Percent Sales
I. City
II. Highway
Label
% Sales
Label
ATTIT
% Sales
A
B
C
D
E
A 0
1
2
B 0
1
2
C 0
1
2
I3
D 0
1
2
I3
E 0
1
2
XJ
= Modified
= Modified
= Modified
= Modified
= Modified
75
22
3
75
22
3
72
23
5
0
67
27
5
1
67
27
5
1
Model Type Label
Model Type + Axle Label
Model Type + Axle + ETW Label
Model Type + Axle + ETW + RLHP
Model Type + Subconfiguration
1 iiui-ij
A 0
1
2
X3
B 0
1
2
X3
C 0
1
2
I3
D 0
1
2
I3
E 0
1
2
_>3
0 means fraction
Label
Label
57
34
4
5
58
31
6
5
55
34
5
6
52
34
8
6
52
35
8
5
< 0.5
-------
Table A-4
Domestic and Foreign, Trucks
Absolute Label Differences versus Percent Sales
I. City
Label
Ampg
% Sales
B
0
1
2
3
0
1
2
>3
0
1
2
>3
0
1
2
>3
0
1
2
>3
80
19
1
0
79
19
2
0
68
29
2
1
67
31
2
0
68
30
2
0
II. Highway
Label
Ampg
% Sales
0
1
2
>3
0
1
2
>3
62
32
3
3
63
27
8
2
==========
0
1
2
>3
0
1
2
>3
0
1
2
>3
56
33
8
3
55
32
9
4
57
31
9
3
A = Modified Model Type Label
B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label
0 means fraction < 0.5
-------
Table A-5 Domestic and Foreign
Fuel Economy Differences Versus Percent Sales; Modified Model type
Label Minus current Label Value
CARS-CITY
Percent Modified - Current
Sales Label Differences-mpg
2.49 -2 X
17.53 -1 XXXXXXXXX
75.15 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
4.35 +1 XX
0.48 +2 X
100.00
TRUCKS-CITY
0.22 -3 X
1.08 -2 X
18.41 -1 XXXXXXXXX
79.77 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
0.51 +1 X
0 01 +2 X
100.00
-------
Table A-6 Domestic and Foreign
Fuel Economy Differences Versus Percentage Sales; Modified
Model Type Label Minus Current Label Value
CARS-HIGHWAY
Percent
Sales
2.10
2.39
2.67
18.23
57.36
15.77
1.22
a. 26
Modified - Current
Label Dif ferences-mpg
-4
-3
-2
-1
0
+1
+2
+ 3
X
X
X
XXXXXXXXX
xxxxxxxxxxxxx:
xxxxxxxx
X
X
100.00
TRUCKS-HIGHWAY
0.10 -6 X
0.44 -5 X
0.26 -4 X
1.60 -3 X
3.38 -2 XX
29.57 -1 XXXXXXXXXXXXXXX
62.43 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
2.17 +1 X
0.05 +2 X
100.00
-------
Table A-7 Domestic and Foreign
Fuel Economy differences Versus Percent Sales; Modified
Model Type + Axle Label Minus Current Label Value
CARS-CITY
Percent Modified - Current
Sales Label Differences-mpg
2.35 -2 X
18.12 -1 XXXXXXXXX
74.82 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
4.10 +1 XX
0.61 +2 X
100.00
TRUCKS-CITY
0.03 -8 X
0.01 -5 X
0.01 -4 X
0.15 -3 X
1.94 -2 X
17.62 -1 XXXXXXXXX
78.63 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
1.58 +1 X
0.03 +2 X
100.00
-------
Table A-8 Domestic and Foreign
Fuel Economy Differences Versus Percent Sales: Modified
Model Type + Axle Label Minus Current Label Value
CARS-HIGHWAY
Percent
Sales
0.01
0.03
2.26
2.23
4.69
14.96
57.82
16.31
1.31
0.26
0.12
100.00
Modified - Current
Label Dif ferences-mpg
-6
-5
-4
-3
-2
-1
0
+1
+2
+3
+4
X
X
X
X
XX
xxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxx
X
X
X
TRUCKS-HIGHWAY
0.03
0.01
0.05
0.51
0.49
1.36
8.28
18.99
62.59
7.56
0.13
-10
-8
6
-5
-4
-3
-2
-1
0
+1
+2
X
X
X
X
X
X
xxxx
xxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxx
X
100.00
-------
Table A-9 Domestic and Foreign
Fuel Economy Differences Versus Percent Sales; Modified
Model Type + Axle + ETW Label Minus Current Label Value
CARS-CITY
Percent Modified - Current
Sales Label Differences-mpg
0.53 -3 X
3.12 -2 XX
17.88 -1 XXXXXXXXX
71.96 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
4.98 +1 XX
1.53 +2 X
100.00
TRUCKS-CITY
0.03 -8 X
0.01 -5 X
0.01 -4 X
0.17 -3 X
1.96 -2 X
25.33 -1 XXXXXXXXXXXXX
68.36 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
4.10 +1 XX
0.03 +2 X
0.00 +3
100.00
-------
Table A-10 Domestic and Foreign
Fuel Economy Differences Versus Percent Sales; Modified
Model Type+Axle+ETW Label Minus Current Label Value
CARS-HIGHWAY
Percent
Sales
0.01
0.03
1.94
3.23
2.71
18.76
55.23
15.09
2.51
0.31
0.18
100.00
Modified - Current
Label Dif ferences-mpg
-6
-5
-4
-3
9
-i
0
+1
+2
+3
+4
X
X
X
XX
X
xxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxx
X
X
X
TRUCKS-HIGHWAY
0.03
0.01
0.04
0.02
0.50
0 50
2.03
7.99
20.76
55.55
2.18
0.38
0 01
100.00
-10
-8
-7
-6
-5
-4
-3
-2
-1
0
+ 1
+2
>3
(Max +4)
X
X
X
X
X
X
X
xxxx
xxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxx
X
X
-------
Table A-;ll Domestic and Foreign
Fuel Economy Differences Versus Percent Sales; Modified Model
Type + Axle + ETW + RLHP Label Minus Current Label Value
CARS-CITY
Percent Modified - Current
Sales Label Differences-mpg
0.53 -3 X
3.25 -2 XX
18.29 -1 XXXXXXXXX
67.24 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
9.14 +1 XXXXX
1.55 +2 X
100.00
TRUCKS-CITY
0.03 -8 X
0.01 -5 X
0 01 -4 X
0.17 -3 X
2.15 -2 X
26.30 -1 XXXXXXXXXXXXX
66.51 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
4.78 +1 XX
0.03 +2 X
0.01 +3 X
100.00
-------
Table A-12 Domestic and Foreign
Fuel Economy Differences Versus Percent Sales; Modified Model
Type + Axle + ETW + RLHP Label Minus Current Label Value
CARS-HIGHWAY
Percent
Sales
0.01
0.03
2.06
3.21
3.46
20.13
52.32
13.93
4.14
0.57
0.13
0.01
100.00
Modified - Current
Label Dif ferences-mpg
-6
-5
-4
-3
-2
-1
0
+ 1
+2
+3
+4
+5
X
X
X
XX
XX
XXXXXXXXXX
xxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxx
XX
X
X
X
TRUCKS-HIGHWAY
0.03
0.01
0.04
0.02
0.50
0.50
2.43
8.76
18.91
54.96
13.38
0.45
0.01
100 00
-10
-8
-7
-6
-5
-4
-3
-2
-1
0
+1
+2
>3
(Max +4)
X
X
X
X
X
X
X
xxxx
xxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxx
X
X
-------
Table A-13 Domestic and Foreign
Fuel Economy Differences Versus Percent Sales; Modified Model Type +
Subconfiguration Label Minus Current Label Value
CARS-CITY
Percent Modified - Current
Sales Label Differences-mpg
0.53 -3 X
3.25 -2 XX
18.38 -1 XXXXXXXXX
66.92 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
9.36 +1 XXXXX
1.55 +2 X
100.00
TRUCKS-CITY
0.03 -8 X
0.01 -5 X
0.01 -4 X
0.17 -3 X
2.22 -2 X
25.03 -1 XXXXXXXXXXXXX
67.76 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
4.73 +1 XX
0.03 +2 X
0.01 +3 X
100.00
-------
Table A-14 Domestic and Foreign
Fuel Economy Differences Versus Percent Sales; Modified Model Type +
Subconfiguration Label Minus Current Label Value
CARS-HIGHWAY
Percent
Sales
0.01
0.05
2.04
3.21
3.49
20.29
51.52
14.64
4.04
0.57
0.13
0.01
100.00
Modified - Current
Label Dif ferences-mpg
-6
-5
-4
-3
-2
-1
0
+ 1
+2
+3
+4
+5
X
X
X
XX
XX
XXXXXXXXXX
xxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxx
XX
X
X
X
TRUCKS- HIGHWAY
0.03
0.01
0.04
0.01
0.49
0 51
2.35
8.95
17.32
56.53
13.30
0.45
0.00
100.00
-10
-8
-7
6
-5
-4
-3
-2
-1
0
+1
+2
>3
(Max +4)
X
X
X
X
X
X
X
xxxx
xxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxx
X
-------
Appendix B
Domestic Manufacturers
American Motors, Chrysler, Ford, and General Motors
Table Nos. Title
B-l and B-2 Relationship of the Number of Labels Required for Each
Level of Label Detail with Sales Percent Differences
within Each Level of Labeling; City and Highway Label
- - Differences. " ___
B-3 and B-4 Sales Percentages for Absolute Label Differences versus
Percent Sales; City and Highway Label Differences.
Fuel Economy Differences versus Percent Sales;
B-5 Modified Model Type Label value - Current Label Value;
City
B-6 Modified Model Type Label Value - Current Label Value;
Highway
B-7 Modified Model Type + Subconfiguration Label Values -
Current Label Value, City
B-8 Modified Model Type + Subconfiguration Label Values -
Current Label Value; Highway
-------
--
--
--
--
--
Number of Labels Required for Each Level of Detail.
1
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Table No. B-l Relationship of the Number of Labels Required
for Each Level of Label Detail with Sales Percent Within Each
Level of Detail
-------
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Sales Percent Differences From Current
Current Model Proposed Proposed Proposed Proposed Proposed
Type
(
MT) MT MT + Axle MT + Axle MT + Axle MT +
+ ETW + ETW + RLHP figu
Table No. B-2 Relationship of the Number of Labels Requir
for Each Level of Label Detail with Sales Percent Within E
Level of Detail
Subcon-
ration
ed -H4+
ach TNT
-------
Table B-3
Domestic, Cars
Absolute Label Differences Versus Percent Sales
I. City
II. Highway
Label
% Sales
Label
Amr
Sales
A
B.
C
D
E
A =
B =
C =
D =
E =
0
1
2
0
1
2
0
1
2
3
0
1
2
3
0
1
2
I3
Modified Model
Modified Model
Modified Model
Modified Model
Modified Model
71
25
4
71
25
4
68
25
6
1
64
29
6
1
64
29
6
1
Type Label
Type + Axle Label
Type + Axle + ETW Label
Type + Axle + ETW + RLHP
Type + Subconfiguration
I LJ
A 0
1
2
I3
B 0
1
2
>_3
C 0
1
2
I3
D 0
1
2
>_3
E 0
1
2
A3
Label
Label
55
34
5
6
56
31
7
6
53
34
6
7
50
35
8
7
50
36
8
6
-------
Table B-4
Domestic, Trucks
Absolute Label Differences Versus Percent Sales
I. City
Lab-el
Ampg
% Sales
0
1
2
3
0
1
2
>3
0
1
2
>3
77
22
1
0
0
1
2
>3
0
1
2
>3
76
22
2
0
65
33
2
0
62
35
2
1
64
34
2
0
II. Highway
Label
Ampg
% Sales
B
0
1
2
>3
0
1
2
>3
0
1
2
>3
0
1
2
>3
59
35
4
2
58
30
10
2
52
35
10
3
0
1
2
>3
51
34
11
4
'51
34
11
4
A = Modified Model Type Label
B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label
0 means fraction < 0.5
-------
Table B-5 Domestic
Fuel Economy Differences Versus Percent Sales; Modified
Model Type Label Minus Current Label Value
CARS-CITY
Percent Differences in
Sales Fuel Economy
3.01 -2 X2L
20.39 - -1 XXXXXXXXXX
71.38 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
4.63 +1 XX
0.59 +2 X
100.00
TRUCKS-CITY
0.25 -3 X
0.92 -2 X
21.40 -1 XXXXXXXXXXX
76.82 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
0.60 +1 X
0.01 +2 X
100.00
-------
Table B-6 Domestic
Fuel Economy Differences Versus Percent Sales;~Modified
Model Type Label Minus Current Label Value
CARS-HIGHWAY
Percent
Sales
2.54
2.85
3.17
19.01
55.34
15.46
1.31
0.32
Differences r
Fuel Economy
-4 X
-3 X -
-2 XX
-1 XXXXXX
0 XXXXXX
+1 xxxxxx:
+2 X
+3 X
100.00
TRUCKS-HIGHWAY
0.11 -6 X
0.52 -5 X
0.30 -4 X
1.53 -3 X
3.79 -2 XX
32.24 -1 XXXXXXXXXXXXXXXX
58.90 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXX
2.55 +1 X
0.06 +2 X
100.00
-------
Table B-7 Domestic
Fuel Economy Differences Versus Perent Sales; Modified Model Type +
Subconfiguration Label Minus Current Label Value
CARS-CITY
Percent Differences in
Sales Fuel Economy
0.65" - -3 X-
3.77 -2 XX
21.02 -1 XXXXXXXXXXX
64.01 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
8.70 +1 XXXX
1.85 +2 X
100.00
TRUCKS-CITY
0.01 -4 X
0.20 -3 X
2.25 -2 X
28.17 -1 XXXXXXXXXXXXXX
63.85 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
5.48 +1 XXX
0.03 +2 X
0.01 +3 X
100.00
-------
Table B-8 Domestic
Fuel Economy Differences Versus Percent Sales; Modified Model Type +
Subconfiguration Label Minus Current Label Value
CARS-HIGHWAY
Percent
Sales
0.01
0.06
2.47
3.67
3.65
22.06
49.58
13.80
3.90
0.80
100.00
Differences ii
Fuel Economy
-6
-5
-4
-3
-2
-1
0
+1
+2
+3
X
X
X
XX
XX
XXXXXX
xxxxxx
XXXXXX
XX
X
TRUCKS- HIGHWAY
0.04
0.03
0.58
0.60
2.41
10.32
19.33
51.41
14.75
0.52
0.01
100.00
-7
-6
-5
-4
-3
-2
-1
0
+ 1
+2
>3
(Max +4)
X
X
X
X
X
xxxxx
xxxxxx
xxxxxx
xxxxxx
X
X
-------
Appendix C
Foreign Manufacturers
Fiat, Nissan, Toyo Kogyo, "Toyota, Volkswagen
Table Nos. Title
C-l and C-2 Relationship of the Number of Labels Required for Each
Level of Label Detail with Sales Percent Differences
withan Each tevet~of"irabe-ling,"Ci±y~and Highway Label
Differences.
-C-3 and^C-4 Sale's" Percentages for Absolute Label Differences versus
Percent Sales, City and Highway Label Differences.
Fuel Economy Differences versus Percent Sales;
C-5 Modified Model Type Label value - Current Label Value;
City
C-6 Modified Model Type Label Value -.Current Label Value;
Highway
C-7 Modified Model Type + Subconfiguration Label Values -
Current Label Value, City
C-8 Modified Model Type + Subconfiguration Label Values -
Current Label Value; Highway
-------
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Current Model Proposed Proposed Proposed Proposed Proposed
Type (MT) MT MT + Axle MT + Axle MT + Axle MT + Subc
+ ETW + ETW + RLHP figuratic
i III Mill
Table No. C-l Relationship of the Number of Labels Required lH
for Each Level of Label Detail with Sales Percent Within Each
T evel Q* HP* =' 1
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MT + Axle MT + Axle MT + Axle MT + Subc-
+ ETW + ETW + RLHP figuratio
ill i ii i i I il
Table No. C-2 Relationshio of the Number of Labels Required JJj
for Each Level of Label Detail with Sales Percent Within Each
T evel of Detail
-------
Table C-3
Foreign, Cars
Absolute Label Differences Versus Percent Sales
I. City
II. Highway
Label
Ampg
Sales
Label
Ampg
% Sales
A
B
C
D
E
A 0
1
\ V
B 0
1
C 0
1
D 0
1
2
E 0
1
2
= Modified Model Type
= Modified Model Type
= Modified Model Type
= Modified Model Type
= Modified Model Type
93
7
92
8
89
11
81
18
1
81
18
1
Label
+ Axle Label
+ Axle + ETW Label
+ Axle + ETW + RLHP
+ Subconf iguration
A 0
1
2
>3
B 0
1
2
I3
C 0
1
2
I3
D 0
1
2
2.3
E 0
1
2
I3
0 means fraction <
Label
Label
%7
32
1
0
67
32
1
0
64
34
1
1
64
28
7
1
61
31
7
1
0.5
-------
Table C-4
Foreign, Trucks
Absolute Label Differences versus Percent Sales
I. City
II. Highway
Label
Ampg
% Sales
Label
% -
A
B
C
D
E
A =
B =
C =
D =
E =
0
1
2
0
1
2
X3
0
1
2
XJ
0
1
2
X3
0
1
2
_>3
Modified Model Type
Modified Model Type
Modified Model Type
Modified Model Type
Modified Model Type
97
1
2
97
1
2
0
91
7
2
0
91
7
2
0
91
7
2
0
Label
+ Axle Label
+ Axle + ETW Label
+ Axle + ETW + RLHP
+ Subconf iguration
I'O
A 0
1
2
_>3
B 0
1
2
X3
C 0
1
2
I3
D 0
1
2
X3
E 0
1
2
I3
0 means fraction <
Label
Label
83
14
1
2
87
9
1
3
77
20
1
2
77
20
1
2
86
11
1
2
0.5
-------
Table C-5 Foreign
Fuel Economy Differences Versus Percent Sales; Modified
Model Type Label Minus current Label Value
CARS-CITY
Percent Differences in
Sales Fuel Economy
3.92 -1 XX
93.03 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
3.05 +1 XX
100.00
TRUCKS-CITY
2.01 -2 X
1.04 -1 X
96.95 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
100.00
-------
Table C-6 Foreign
Fuel Economy Differences Versus Percent Sales; Modified
Model Type Label Minus Current Label Value
CARS-HIGHWAY
Percent
Sales
0.21
0.30
14.50
67.00
17.20
0.79
Differences i:
Fuel Economy
-3 X
-2 X
-1 XXXXXX
0 XXXXXX
+1 XXXXXX
+2 X
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
100.00
TRUCKS-HIGHWAY
2.01 -3 X
1.04 -2 X
14.06 -1 XXXXXXX
82.89 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
100.00
-------
Table C-7 Foreign
Fuel Economy Differences Versus Percent Sales; Modified Model Type +
Subconfiguration Label Minus Current Label Value
CARS-CITY
Percent Differences in
Sales Fuel Economy
1 0.77 -2 X
5 83 -1 XXX
80.76 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
12.53 +1 XXXXXX
0.11 +2 X
100.00
TRUCKS-CITY
0.18 -8 X
0.06 -5 X
2.01 -2 X
6.89 -1 XXX
90.53 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
0.33 +1 X
100.00
-------
Table C-8 Foreign
Fuel Economy Differences Versus Percent Sales; Modified Model Type +
Subconfiguration" Label Minus Current Label Value
CARS-HIGHWAY
Percent Differences in
Sales Fuel Economy
"^o.or c -5 x
- 0.01 . - -4 X
1.02 -3 X
2.69 -2 X
11.90 -1 XXXXXX
60.77 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
18.60 +1 XXXXXXXXX
'4.73 +2 XX
0.27 +3 X
100.00
TRUCKS-HIGHWAY
0.18 -10 X
0.06 -8 X
2.01 -3 X
1.04 X
5.63 -1 XXX
86 18 0 XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
4.90 +1 XX
100.00
-------
Appendix D
Individual Manufacturers' Fuel Economy Differences
for Each Level of Labeling Detail
Table Nos. Title
D-l Affect of Modified Label Program on the
American Motors' Product Line
D-2 Affect of Modified Label Program on the
Chrysler Product Line
D-3 Affect of Modified Label Program on the
Ford Product Line
D-4 Affect of Modified Label Program on the
General Motors Product Line
D-5 Affect of Modified Label Program on the
Fiat Product Line
D-6 Affect of Modified Label Program on the
Nissan Product Line
D-7 Affect of Modified Label Program on the
Toyo Kogyo Product Line
D-8 Affect of Modified Label Program on the
Toyota Product line
D-9 Affect of Modified Label Program on the
Volkswagen Product Line
-------
Table D-l
American Motors Corporation
CARS
Am mpg
from original
label A B
City Highway City Highway City
-1 10.5 0.9 11 5 0.7 32.0
0 87.3 92 5 86.4 92.0 64.9
+ 1 4.3 4.2 0.9
C D
t
Highway City ' Highway City
20.7 32.0 20.7 32.0
57.2 64.9 57.2 64.9
19.2 0.9 19.2 0.9
E
Highway
20.7
57.2
19.2
TRUCKS
t
-1 3.0 32.7 11.8 2.7 11.8
0 94.1 57.0 82.8 97.9 81.0
+1 22 6.8 3.8 7.2 4.2
Note: 0 means fraction <0 01 A = Modified
means no sales in that category B = Modified
C = Modified
D = Modified
E = Modified
6.4 11.8 ' 6.4S 11.8
! i (
74.4 81.0 76.4 81.0
6.2 4.2 6.2 4.2
Model Type Label
Model Type + Axle Label
Model Type + Axle + ETW Label
Model Type + Axle +'ETW + RLHP Label
Model Type + Subconf iguration Label
6.4
76.4
6.2
-------
Table D-2
Chrysler
CARS
A in mpg
from original
label
D
City Highway City Highway City Highway City- Highway City Highway
-1
36.3 26.4
36.1 25.9
29.1 25.7
27.3 26.2
28.5 26.4
56.4 44.4
55 9 44.4
55.9 44.3
57.8 36.3
56.7 36.0
7.1
6.7
7.4
6.7
7.7
7.1
7.4 12.4.
7.5 12.6
TRUCKS
-1
26.5 46.5
24.0 30.1
30.5 28.6
29.0 p 20.0
26.3 19.8
70.0 42.4
71.6 45.0
64.4 45.7
64.6 50.9
67.4 51.0
0.1
3.9
1.1 12.9
25.0 12.3
2.6 12.0-
2.4 11.8
Note: 0 means fraction <0.01
means no sales in that category
A = Modified Model Type Label
B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label
-------
Table T)-3
Ford
CARS
A in mpg
from original
label A B
City Highway City Highway City
-1 19.2 9 0 22.6 10.0 19 0
0 73.2 60.0 73.7 59.8 75.0
+1 7.6 23.2 2.7 21.5 5.0
C D
Highway City Highway City
20.4 23.1 24.9 23.8
46.5 65.9 33.8, 65.5
24.1 10 0 26.4 9.7
E
Highway
25.7
37.4
27.6
TRUCKS ,,
-1 33.4 28.7 24.7 21.6 25.3
0 63.6 63.0 60.9 52.0 54 9
+1 0.8 0.3 9.2 8.8 15.1
Note: 0 means fraction <0.01 A = Modified
means no sales in that category B = Modified
C = Modified
D = Modified
E = Modified
20.6 25.2 18.4 25.4
53.3 57.0 49.7 57.0
10.1 ,13.0 13.0 12.8
Model Type Label
Model Type + Axle Label
Model Type + Axle + ETW Label
Model Type + Axle + ETW + RLHP Label
Model Type + Subconf iguration Label
18.4
49.8
12.9
-------
Table D-4
General Motors
CARS
Am mpg
from original
label
D
City Highway City Highway City Highway -City. Highway City Highway
-1
14.9 19.3
15.1 12.5
17.1 16.3
17.1 , 19.5
17.2 19.6
76.2 57.3
75.9 58.5
71.5 58.4
66.5 57.7-
TRUCKS
66.4 57.7
+1
3.
0
17
.1
3.5
18
.7
4
.0
15
.0
9.
1
10
.6-
9
.1
10.6
-1
17.6 21.0
18.0 15.2
29.9 18.6
33.6 21.5'
32.6 21.0
81.7 72 3
80.5 67.4
64.9 53.2
58.9 28.0
59.7 48.4
0 7
1 3
0.8
5.8
4.7 16 1
6.8 18.8'
6.8 18.8
Note- 0 means fraction <0.01
means no sales in that category
A = Modified Model Type Label
B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label)
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label
-------
Table D-5
Fiat
CARS
Am mpg
from original
label
D
City Highway City Highway City Highway City Highway City Highway
-1
25.6
25.6
25.6
14.9
3.2
14.9
3.2
74.4 74.4
74 4 74 4
74.4
74.4
81.8 81.8
81.8 81.8
+ 1
25.6
25 6
25.6
3.2 14.9
3.2 14.9
TRUCKS
-1
0
Note- 0 means fraction <0.01
means no sales in that category
A = Modified Model Type Label
B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration Label
-------
Table D-6
Nissan
CARS
Am mpg
from original
label A B
City Highway City Highway City
-1 2.7 28.4 2.7 28 4 6.3
0 97.3 70.0 96 1 68.8 87.6
+1 1.7 12.0 1.7 6.1
C
Highway
30.2
67.0
1.7
TRUCKS
-1 13.6 16.1
0 100.0 86.4 99.3 99.3 82.3
+1 0.9
Note: 0 means fraction <0.01 A = Modified
means no sales in that category B = Modified
C = Modified
D = Modified
E = Modified
16.1
74.0
9.1
l
- D
City Highway City
8.2 17.4 4.6
68.0 58.4 70.6
21.5 15.5 22.5
\
' 16. 1 ;' 16.1 16.1
82.3 74.0 82.3
0.9 9.1 0.9
E
Highway
17.4
57.4
16.5
16.1
74.0
9.1
Model Type Label '
Model Type + Axle Label
Model Type + Axle + ,ETW Label
Model Type + Axle + ETW + RLHP Label
Model Type + Subconf iguration- Label
-------
Table D-7 Toyo Kogyo
CARS
A m mpg
from original
label ABC
City Highway City Highway City Highway
-1 9.9 9.9 1.8 19.6
0 100.0 90.1 100.0 90.1 98.2 80.4
D E
City Highway City Highway
1.8 15.4 1.8 15.4
98.2 84.6 98.2 84.6
+ 1
TRUCKS
-1
7.5
7.5
5.0
5.0
0.2
2.4
100.0 92.5
100.0
92.5
100.0 95.0
100.0 95.0
98.9
97.6
+ 1
0.9
Note: 0 means fraction <0.01
means no sales in that category
A = Modified Model Type Label
B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconfiguration"Label
-------
Table D-8 Toyota
CARS
A in tnpg
from original
label A B C D
City Highway City Highway City Highway City Highway City
-1 56 7.7 6.7 8.8 6.7 8.8 10.3 7.6 8.7
0 91.0 48.8 90.0 47.7 89.8 47.7 83.4 52.0 83.3
+1 3.4 40.1 3.4 40.1 3.6 40.1 6.0 23.8 7.6
E
Highway
9.3
45.7
28.8
TRUCKS
-1 2.2 19.5 2.2 19.5 2.2 19.5 2.2 19.5 2.2
0 93.5 74.0 93.5 74.0 93.5 74.0 93.5 74.0 93.5
93.5
+1
Note: 0 means fraction <0.01 A = Modified Model Type Label
means no sales in that category B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconf iguration Label
-------
Table D-9 Volkswagen
CARS
Aln mPg
from original
label A B C D
City Highway City Highway City Highway City Highway City
-1 8.1 8.1 1.5 8.6 1.5 8.6 2.9
0 87.5 79.2 87.5 79.2 86.1 79.3 86.1 79.3 81.3
-H 12.5 11.9 12.5 11.9 12.4 11.3 12.4 11.3 15.8
E
Highway
5.3
74.8
17.7
TRUCKS
-1 -- 2.4 0.3 2.4 0.3 2.4
0 100.0 100.0 100.0 100.0 97.6 87.9 97.9 87.9 97.6
-i-l -- -- 11.8 -- 11.8
0.3
87.9
11.8
Note 0 means fraction <0.01 A = Modified Model Type Label
means no sales in that category B = Modified Model Type + Axle Label
C = Modified Model Type + Axle + ETW Label
D = Modified Model Type + Axle + ETW + RLHP Label
E = Modified Model Type + Subconf iguration Label
-------
Appendix E
Table Nos. Title
E-l Number of Labels Required versus Level of Labeling
Detail for Each Manufacturer
-------
Table E-l
Number of Labels Required Versus Level of Labeling Detail for Each Manufacturer
Manufacturer
A1
American Motors
Chrysler
Ford
General Motors
Fiat
Nissan
Toyo Kogyo
Toyota
Volkswagen
Total Counts
Total
62
213
235
367
14
59
24
57
34
1065*
Cars
24
91
135
225
14
47
20
38
22
616
Trucks
38
122
100
142
0
12
4
19
12
449
Total
62
237
235
369
14
59
24
57
34
1091
Cars
24
95
135
227
14
47
20
38
22
622
Trucks
38
142
100
142
0
12
4
19
12
469
Total
91
309
328
524
14
63
24
59
34
1446
Cars
30
107
157
271
14
49
20
40
22
710
Trucks
61
202
171
253
0
14
4
19
12
736
Total
135
519
569
798
16
73
32
61
48
2251
Cars
43
147
220
362
16
55
24
42
32
941
Trucks
92
372
349
436
0
18
8
19
16
1310
Total
137
1236
849
986
20
139
40
121
48
1
3576
Cars
43
310
325
445
20
121
32
102
32
1430
Trucks
94
926
524
541
0
18
8
19
16
2146
Total
1'42
1351
1088
1036
20
225
72
281
, 60
4275
Cars
43
376
386
469
20
178
56
231
44
1803
Truck
99
975
702
567
0
47
16
50
16
2472
* Difference in the number of labels between A1 and A due to finer level of detail describing transmission, e.g., lockup and "creeper"
transmissions are separated out in A.
Current Model Type Label
Modified Model Type Label
Modified Model Type + Axle Label
Modified Model Type + Axle + ETW Label
Modified Model Type + Axle + ETW + RLHP Label
Modified Model Type + Subconfiguration Label
-------
Appendix F
Individual Model Types' Fuel Economy Differences
at Each Level of Labeling Detail
The following pages contain the actual 1981 model types for the manufac-
turers studied in this analysis. Each manufacturer is grouped separately.
Within a manufacturer, each basic engine is sorted separately, cars first,
followed by trucks. Within each basic engine, the different model types
are shown within their current label values (city/highway). In the row
beside each model type are the five different levels of labeling in increasing
order of detail. The columns contain the city and highway difference
between the current label values and the level of labeling detail of that
column. The difference is equal to the proposal minus the current value.
The percent of sales breakdown for that model type at each level of is also
given. The last column also contains a code (*T) to indicate which subcon-
figuration(s) was actually tested to generate the label values for that
vehicle using the current model types calculation method.
***Because this appendix is a large volume, it may be obtained only
through the Public Docket (No A-80-32) in Washington, D C.
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