My ranking:

• Label 2 - least bad because it include two pollution numbers. Fails to include 15,000 miles annual mileage.
• Label 3 - next worse, less technical detail but includes 15,000 miles assumption
• Label 1 - nonsense, the "Grade" does not work

I still prefer a chart showing MPG as a function of mph.

Bob Wilson

Need to use the more realistic "distance per fuel" or 100 km per Liter.

It appears that they've come to an agreement with the automakers on how to compare and rate the 'dual fuel' vehicles, i.e. electricity from the grid + pumped fuel.

The metric will be

1. a standard distance of 50 miles of blended driving
2. the current EPA test for vehicles in CS mode or extended range mode ( GM's terminology ).

Each will be shown separately, the 'A' label at the bottom.

As I see it, under label 2, which I like, volt will get an mpge for 40 electric miles, not 50 blended miles. This makes sense in that it tells you the AER and the efficiency during that phase, then the CS mpg. Volt folks should be thrilled with this, except that they think the electricity should be treated as not using any energy and that CS mpg should remain secret due to being irrelevant. But about all they could hope for, really.

PHEV Prius would presumably get a 50 mile blended label 2 variant, but not so fast. What if the car can complete the city and highway tests without the ICE turning on? Then it should get a 14-mile (or whatever) electric only rating, no?

I don't see where they DEFINE who gets a serial hybrid label and who gets the blended 50 mile label. My sense is that manufacturers will want the electric only label for the initial AER to show the higher number for mpge there versus blended. My guess is that since the full hybrid prius phv does use the ICE under certain conditions prior to exhausting AER, it will be stuck with the blended 50-mile number.

They need to at least describe the omission of GHG's and other pollutants at the power plant to avoid greenwashing these ratings. The pollution ratings and the letter grades are really skewed toward EV and big-AER PHVs in this regard, when many get power mainly from coal. I'm very pro-EV, but this just seems like it glosses over the facts about electricity greenness.

I can live without the letter grades. Too many assumptions and omissions.

How the heck would they do that? Each state/region has a different ratio of electric power generation from coal. Would you use the national average or divide the country into regions? What if you had your own solar panels? It is something people need to keep in mind, sometimes it's completely glossed over, sometimes it's the only thing people will talk about when it comes to electric vehicles, but I don't know that there's a good solution on how to describe it.

I'm not suggesting quantifying it, just pointing out that these number assume all renewable electricity. Maybe state on the web site what the green ratings would be with all coal. Then people who really want to know can look up their own renewable/fossil ratio and gain some sense of reality. This matters not only to selection among vehicles, but also on whether to drive needlessly and inefficiently with a BEV versus continuing to conserve resources.

My favorite part:

We welcome your comments on this rule. All comments will become part of the public docket and may be available online at Regulations.gov. Comments will be accepted for 60 days beginning when this proposal is published in the Federal Register. All comments should be identified by Docket ID No. EPA-HQ-OAR-2009-0865 and submitted by one of the following methods:

Too bad that docket number at the regulations.gov website comes back with 4 ID numbers, all of which are past the comment timeframe. I love when government works.

I have a feeling that they are going to do an EPA test on a dyno and assess how much of the 'nominal' gas-free range is actually available in real world driving. AC usage and stop-go driving reduce the gas-free range.


It appears to me that when this actual gas-free range is determined it's then apportioned within the standard 50 mile measurment ( Volt 30 miles / Prius 11 miles ); e.g.

• 60% of that 50 mile trip in a Volt would be using electicity off the grid and 40% would be using pumped fuel. Beyond 50 miles the entire distance would be using pumped fuel.
• 22% of the 50 mile trip in a Prius PHV would be using electricity off the grid and 78% would be using pumped fuel. Again beyond 50 miles the entire distance would be using pumped fuel.

This is how I interpret the info off the labels.

The label indicates they are going to use only 30 miles for the Volt while PHV Prius' MPG is derived from 50 miles.

That's a double standard.

Consider my interpretation from the all labels pdf at pages 12 and 13 IIRC:

Volt, being a serial design (largely EV first, then gas) will get a label with its EV range with mpge from electricity only. Then a gas-only CS mode mpg. If that's 40 miles EV, fine. Another similar car with a 30 mile EV range would also get a 30 mile mpge from electricity only.

Prius PHEV, unless it squeezes under the definition of primarily electric only for x miles, will be deemed a blended PHEV, and get stuck for 50 miles blended, then CS mpg, rather than 14 miles blended but basically EV, then CS mpg. In this way, Prius PHEV is given a less favorable label than the serial hybrids.

Overall, I'm ok with it, but would prefer that blended PHEVs like Prius PHEV be given a blended EV number that correlates with its designed EV range. Only in this way can one readily compare electric and gas efficiency under his own projected driving pattern.

Why ? Do they mention all the extraction , refining emissions for oil ? How about unconventional - since many get oil mainly from tar sands.

Good point, but... It takes fossil fuel to extract both oil and coal. But burning the coal is akin to burning the gasoline. It would be great to back up and include the extraction of both, but let's at least acknowledge that their is ghg, etc. from use of ev's charged from fossils, lest the masses think they can drive needlessly and wastefully just because the pollution is miles away. Conservation still matters.

Burning coal is not the same as gasoline.
1) Oil is a scarce resource. Coal is not. Electric generation can switch to cleaner and/or more plentiful sources. The grid in the U.S. is in the process of doing this. Scarcity along with monopoly control of oil means that price swings and price increases in Gasoline are much more likely.

2) Gasoline causes tail pipe emissions and these are especially in the citiies where they cause health problems. The major polutants from coal NOx and SOx are capped by government regulation. Adding more cars to the grid produces no increase in the dangerous polutants. If there is greenhouse gas legislation CO2 may also be controled and it may be reduced by either more efficient generation or Carbon sequestration.

3) The source of gasoline, is controlled by a small number of countries and companies. Many of these countries have policiies that are counter to the US. A large portion of the trade deficit is caused by importation of oil. So continued high levels of gasoline use translate into a worse economy and the funding of hostile and potentially hostile countries. Oil embargos have already been used twice against the united states and its allies. Oil money has been used to fuel terrorism.

having a CO2 estimate on the label with a guessed at use of electricity would be fine. It shouldn't be included unless other pollutants are included, otherwise we will get to be just like europe and focus solely on the least harmful emissions gas.

Making gasoline also takes a lot of electricity.

I understand your point - but the important thing now is to get people off oil. You don't do that by handicapping the solution ...

How about this instead ? Let us color oil blood red to denote all the lives lost "securing" oil ...

I hope that determination is based on the speed at which you can travel in electric only - rather than serial vs parallel. If in PHEV Prius, you can go at max speed (90mph or whatever) in EV mode only, it should get the same billing as Volt.

I am not a native English speaker, so I don't understand following sentence from page-5 of the PDF.

"The agencies are also proposing to show how far EVs can travel on a full battery charge. For EV CO2 emissions, the agencies propose to show tailpipe-only emissions, which means that EV label CO2 emissions will be zero, given that all of the CO2 emissions associated with EV operation occur at the power plant and other upstream sources."

Does it mean...
A. EV CO2 emissions will be always zero even if it is high Wh/mile number
B. EV CO2 emissions will include CO2 emissions at the power plant and other upstream sources

Which one is correct?

Ken@Japan

HTTP 404 Not Found

Thank you!

So, is it a fair labeling?
I have read that the approx 50% of electricity in the US is from coal fired power plant.
I believe the EV from coal powered electricity emits more CO2 than Prius.

Ken@Japan