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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                                    -2-
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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                                    -3-
          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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                                    -4-
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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                                 -5-
    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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                                    -6-
             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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                                   -7-
         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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                                   -8-


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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                                  -9-
             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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                                     -11-
                           *^*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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                                     -12-
                 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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                                 -13-

******************************************************************^
*                                                                         *
*                              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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                                    -14-
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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                                  -15-
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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                                    -16-



                                                                            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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                                    -17-
                 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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                                    -18-
*                                                                          *
*                              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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                                    -19-
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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                                   -20-


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

-------
                                   -21-
      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).

-------
                                -22-
 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 Level—1


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  Labels—MPG
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.

-------
                                    -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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-------
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
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1
2

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1
2
I3
D 0
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Model Type + Axle + ETW Label
Model Type + Axle + ETW + RLHP
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2
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2
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D 0
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E 0
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2
_>3
0 means fraction


Label
Label
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34
4
5
58
31
6
5
55
34
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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

-------



















































--



--




--

--

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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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-------
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
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1


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8


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11


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>3

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34
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28
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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



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Modified Model Type
Modified Model Type
Modified Model Type
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1
2

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1
2
0
91
7
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0
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7
2
0
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7
2
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+ Axle + ETW Label
+ Axle + ETW + RLHP
+ Subconf iguration
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2
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1
2
X3
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1
2
I3
D 0
1
2
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E 0
1
2
I3
0 means fraction <


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Label
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14
1
2
87
9
1
3
77
20
1
2
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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

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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

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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

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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

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                                Appendix E
Table Nos.                                Title
E-l                Number of Labels Required versus Level of Labeling
                            Detail for Each Manufacturer

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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

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                                 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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