| Comment Number: | 529732-00001 |
| Received: | 7/19/2007 5:12:58 PM |
| Organization: | Broward County Consumer Affairs |
| Commenter: | Jennifer Di Bono |
| State: | FL |
| Agency: | Federal Trade Commission |
| Rule: | Guides Concerning Fuel Economy Advertising for New Automobiles |
| Attachments: | 529732-00001.pdf Download Adobe Reader |
Comments:
Comments on Question 2: What changes, if any, should be made to the Guide to reflect recent amendments to EPA’s fuel economy testing and labeling requirements? 1. The pertinent parts of §259.1 Definitions, reads: 259.1 New Automobile: Any passenger automobile or light truck for which a fuel economy label is required ….. Beginning 2011, the EPA will be requiring fuel economy labels for vehicles up to 10,000 pounds versus the current 8,500 pound requirement. It is this office’s suggestion to expand the vehicles covered in this rule to include the new class of automobiles or “Medium Duty Passenger Vehicles” that will be required to post a fuel economy label. 2. The pertinent parts of §259.1(e & f) reads: (e) Estimated in- use fuel economy range. The estimated range of city and highway fuel economy of the particular new automobile on which the label is affixed. (f) Range of estimated fuel economy values for the class of new automobiles. The estimated city and highway fuel economy values of the class of automobiles ….. The EPA’s new fuel economy guidelines will require specific wording for describing the estimated city and highway range. This office suggests including this wording in section 259.1(e): “Expected range for most drivers _ _ to _ _ MPG”. In addition, the new fuel economy guidelines will reflect a Combined Fuel Economy estimate. This office suggests amending section 259.1(e&f) to reflect the estimated range for city, highway, and combined fuel economy estimate. 3. §259.2 (a)(1) (i, and ii) Advertising Disclosures, reads: (1) If the advertisement makes: (i) Both a city and highway fuel economy representation, both the “estimated city mpg” and the “estimated highway mpg” of such new automobile, must be disclosed; (ii) A representation regarding only city or only highway fuel economy, only the corresponding EPA estimate must be disclosed; 4. The pertinent parts of §259.2 (2) & (b)(1 & 2) & (c)(1) read: (2) That the US EPA is the source of the “estimated city mpg” and “estimated highway mpg” and that the numbers are estimates. (b)(1& 2)…… (i.e. city mpg range or highway mpg range or both)….. (c)(1) The advertisement also discloses the “estimated city mpg” and/or the “estimated highway mpg,” as required by 259.2(a), and the disclosure required by 259.2(a), and gives the “estimated city mpg” and/or the “estimated highway mpg” figures(s) substantially more than any other estimate.; provided, however, for radio and television advertisements in which any other estimate is used only in the audio, equal prominence must be given the “estimated city mpg” and/or the “estimated highway mpg” figure(s); The EPA’s new fuel economy label will not only reflect city and highway estimates, but a combined estimate as well. Therefore it is this office’s suggestion that the words “estimated combined fuel economy” be added after each reference to “estimated city mpg” and “estimated highway mpg” in § 259.2 (a)(1) (i, and ii) and §259.2 (2) & (b)(1 & 2) & (c)(1). 5. Lastly, the pertinent parts of §259.2(c)(3) reads: …..Such conditions and variables may include, but are not limited to, road or dynamometer test, average speed, range of speed, hot or cold start, and temperature; Beginning with the 2008 automobiles, the EPA has instituted new testing conditions to determine fuel economy. These “real world conditions” include: high speed/rapid acceleration driving, use of air conditioning, and cold temperature operation. Additional considerations will be: like road grade, wind, tire pressure, load and the effects of different fuel properties. It is this office’s recommendation that these real world conditions be added to §259.2(c)(3).