Tell The EPA What You Think!

The EPA has posted some prototype fuel economy labels on their web site, and is asking for the public to comment. You can see them in their full detail here.

There are two proposed

designs. The first shows a large letter grade (also color coded), Green A, Yellow B, Orange C, and Red D. Apparently, everyone passes--F's are not allowed to go on sale?

The second shows some Star Trek style sliding indicators, and leaves out the letter grades, but keeps the color coding.

The EPA is inviting public comment as part of its rulemaking, and you can fill out the form at the bottom of the page and hit "send" to give them a piece of your mind.

I have already voted for Form 2 (the simpler one on the right). I think the letter grade Form 1 is too cluttered, and I don't agree with the way they are assigning letter grades. As much as I hate to sound like a whiny pre-med, the grades need to be on a curve--you can't really compare Silverados with Subarus, can you? The grades should really be assigned among like vehicles.

I also think that the fuel/energy efficiency report should be as simple as possible. Ideally, the form should present one universal metric--MPGe (miles per gallon equivalent), which recalculates all energy consumption into units we are used to, miles per gallon of EPA standard test gasoline. The MPGe also is closely related to CO2 production, so I would leave the CO2 data off of the label completely. MPGe tells you everything most people really care to know.

The fuel const estimate is neat, but how often will they update the number? What if the label is based on $2.70 gasoline and $0.12 electricity, but in fact gas is $3.50 and electricity is now $0.20/kWHr? Will we be constantly reminded now that not only our mileage may vary, but our fuel cost may vary as well?

So that's my advice to the EPA, and my comment as well. Keep it simple, leave the grades off, and be careful about the energy cost assumptions.