Comments:Comment on Question 3: What benefits has the Guide provided to purchasers of new automobiles? §259.2(a)(1)(ii) states: “A representation regarding only city or only highway fuel economy, only the corresponding EPA estimate must be disclosed.” The Guide mandates that when an auto manufacturer or dealer provides a reference to city or highway fuel economy that the EPA’s estimate must be used. This provides a benefit to the consumer in that he knows whether he sees an ad for Smith Nissan or Jones Nissan that each dealer will provide the same estimates. Neither dealer is at an advantage in this situation. They must each advertise the same estimate and are on the same footing with this consumer at least in this particular detail. The Guide does allow for an auto dealer or manufacturer to provide a non-EPA test in §259.2(c) (2, 3 & 4). (2) “The source of the non-EPA test is clearly and conspicuously identified: (3) The driving conditions and variables simulated by the test which differ from those used to measure the “estimated city mpg” and/or the “estimated highway mpg” and which result in a change in fuel economy, are clearly and conspicuously disclosed. 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; and (4) The advertisement clearly and conspicuously discloses any distinctions in “vehicle configuration” and other equipment affecting mileage performance between the automobiles tested in the non-EPA test and the EPA tests.” This office believes that requiring auto dealers and manufacturers to use one uniform estimate provides stability and equality for the consumer when purchasing a new car. However, if the auto dealer or manufacturer does not use the EPA estimates, then they have to clearly and conspicuously provide how they arrived at their estimates. The auto dealer or manufacturer would have to abide by the Guide when deviating from the EPA estimates and provide the consumer with the same information and perform the same tests as the EPA does. This office believes that by requiring the use of the EPA estimates that this dissuades auto dealers and manufactures from creating their own estimates. We believe auto dealers and manufacturers find it easier, more cost effective and less labor intensive to use the pre-determined EPA estimates. In conclusion, this office believes that through the use of the EPA Guide the consumer is provided with one uniform set of numbers instead of a vast amount of information as to how the auto dealer or manufacturer arrived at its own estimate. Comment on Question 3: Has the Guide imposed costs on the purchasers? This office does not have comment on this question