EPA-AA-CPSB-82-04
Estimate of Changes to Fuel Economy Label Values Resulting
from the Proposed Mid-Year Label Updating
November 1982
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 Sources
U.S. Environmental Protection Agency
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Estimate of Changes to Fuel Economy Label Values Resulting
from the Proposed Mid-Year Label Updating
I. Purpose
Characterize the number, magnitude, and direction of the
changes in fuel economy label values that could result if mid-
year label updating were adopted.
II. Background
EPA is proposing several changes to the current fuel
economy program which will increase the usefulness and repre-
sentativeness of the fuel economy values to consumers. One of
these proposals is to have the label values updated at least
once per model year, at about mid-year. The label updating
would involve recalculating the label values using revised
sales projections and including test data obtained since- the
initial label calculation.
This report estimates the maximum number of label values
that would likely change by mid-year and magnitude these
changes.
III. Methodology
There are currently no mid-year sales projections or
applicable test data lists. We can, however, estimate the
maximum probable change in label values at mid-year by exam-
ining the overall changes during the entire model year. This
is done by using the label values, produced early in the model
year, and the Final Corporate Average Fuel Economy (FCAFE)
report model type values. The FCAFE uses actual production
figures (not sales projections) and the entire years test
results to calculate model type fuel economy values. By sub-
tracting the label value from the FCAFE value, we can determine
the change in label value for a given model type over the
entire model year. We used this change as a worst-case approx-
imation of the changes we expect in a mid-year labeling
program. Since most running changes are implemented during the
first half of the model year, using end-of-year data is not a
bad approximation, but it is a worst case.
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The latest model year with completed FCAFE calculation
(as of the time of this report) is 1980. In order to limit the
scale of this study but maintain representativeness, this study
represents only the ten top selling manufacturers, who's total
sales represent over 90 percent of all U.S. sales. These
companies are AMCi Chrysler, Ford, General Motors, Honda,
Nissan (Datsun), Toyo Kogyo (Mazda), Toyota, Volkswagen, and
Fuji Heavy Industries (Subaru). Only the 49-state vehicles
were included in the study to further decrease its complexity
(California sales are less than 10 percent of all U.S.. sales).
•
Even with these limiting factors, this analysis still
involved over 700 model types, representing about 10 million
vehicle sales. This was comprised of over 425 passenger
vehicle model types (representing production of about 8 million
vehicles) and over 250 light truck model types, both two-wheel
drive (2WD) and four-wheel drive (4WD) (representing production
of about 2 million vehicles).
The data processing consisted of subtracting the model
type city and highway values calculated at labeling time
(rounded to 0.1 miles per gallon) from the FCAFE model type
values (also rounded to 0.1 miles per gallon). The difference .
between the CAFE and label value had to be at.least 1.0 mpg in
order for the actual label value to be changed. These model
type differences that met this 1.0 mpg requirement were then
grouped by vehicle type (passenger, truck, 2WD, 4WD) and by
domestic verses foreign vehicles.
IV. Results
The results of the label changes for the 1980 model year
are summarized on the attached tables. Table I summarizes
passenger automobiles, Table II summarizes light-duty trucks,
and Table III is an overall summary. Overall, 4 percent of the
model types decreased in label value for the city estimate, and
15 percent decreased for the highway estimate. If we assume a
worst case of all of these changes in vehicle fuel economies
and sales portions to occur by mid-year, this would represent
the maximum likely number of label changes required by the
proposed mid-year update. The changing of a label value due to
an increase in value would be optional under the proposal.
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Table I
Model Type Value Changes
Passenger Automobiles 1980 Model Year
FCAFE - Label In MPG
(Based on a minimum change of 1.0 mpg)
-3 -2 -1 0 12
Domestics (Total No. of Labels:
City
Highway
Foreign (Total No. of
City
Highway
Total Vehicles (Total
City
Highway
3%
Labels:
—
308)
0%
5%
130)
2%
No. of Labels:
0%
2% 4%
7%
13%
5%
8%
438)
7%
12%
92%
77%
95%
85%
93%
80%
0% —
2% —
1%
2% 2%
0% 0%
2% 1%
0%
—
0%
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Table II
Model Type Value Changes
Light-Duty Trucks 1980 Model Year
PCAPE - Label In MPG
(Based on a minimum change of 1.0 mpg)
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Domestics 2WD (Total No. of Labels: 161)
City
Highway ~ ~ 10%
Domestic 4WD (Total No. of Labels: 82)
City — 2% 1%
Highway — — 13%
Domestic Total (Total No. of Labels: 243)
City — 1% 0%
Highway — ~ 11%
Import 2WD (Total No. of Labels: 21)
City ~ —
Highway
Import 4WD (Total No. of Labels: 6)
City —
Highway
Import Total (Total No. of Labels: 27)
City — —
Highway
Truck Totals (Total No. of Labels: 270)
City — 1% 0%
Highway — — 10%
96% 4%
81% 5% 4%
95% 1% —
85% 1% — —
96% 3%
83% 4% 2% — .
100% — --
100% — — —
100% —
100% — —
100% — — —
100% — — —
96% 3%
84% 3% 2%
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Tabel III
Model Type Value Changes
Total 1980 Model Year
FCAFE - Label MPG
(Based on a minimum change of 1.0 mpg)
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Trucks 2WD (Total No. of Labels: 182)
City — — ~ 97% 3% —
Highway — — 9% 84% 4% 3%
Trucks 4WD (Total No. of Labels: 88)
City — 2% 1% 95% 1%
Highway — — 13% 86% 1%
All Trucks (Total No. of Labels: 270)
City — 1% 0% 96% 3%
Highway — — 10% 84% 3% 2%
Passenger Automobiles (Total No. of Labels: 438)
City — 0% 7% 93% 0% 0%
Highway 2% 4% 12% 80% 2% 1% 0%
Grand Total (Total No. of Labels: 708)
City — 0% 4% 94% 1% 0%
Highway 1% 3% 11% 81% 2% 1% 0%
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