                                             SEQ CHAPTER \h \r 1 

DRAFT

SUPPORTING STATEMENT

FOR

INFORMATION COLLECTION REQUEST

Focus Group and Consumer Survey Research for Improving Fuel Economy
Label Design and Content

EPA ICR 2343.01

December, 2009

              

Compliance and Innovative Strategies Division

Office of Transportation and Air Quality

Office of Air and Radiation

U.S. Environmental Protection Agency

Part A

1.  Identification of the Information Collection

 

 	(a) Title of the Information Collection

Focus Group and Consumer Survey Research for Improving Fuel Economy
Label Design and Content

(b) Short Characterization/Abstract

This is a request to conduct focus group and consumer survey research
for the Environmental Protection Agency (EPA).  As required under the
Energy Policy and Conservation Act (EPCA), EPA has promulgated
regulations which specify the design and content of fuel economy labels
that are affixed on the windows of all cars and light trucks sold in the
U.S.  Ref. 49 U.S.C. 32908(b).

EPA is responsible for developing the fuel economy labels that are
posted on window stickers of all new light duty cars and trucks sold in
the U.S. and, beginning with the 2011 model year, on all new medium-duty
passenger vehicles (a category that includes large sport-utility
vehicles and passenger vans).  

In 2006 EPA updated how the window sticker fuel economy values are
calculated to better reflect typical real-world driving patterns and
provide more realistic fuel economy estimates. Since then, increasing
market penetration of advanced technology vehicles, in particular
plug-in hybrid electric vehicles and electric vehicles, will require new
metrics to effectively convey information to consumers.  EPA has
initiated a rulemaking action that will amend the way in which fuel
economy estimates are calculated and/or displayed, particularly for
advanced technology vehicles.  

EPA plans to conduct a limited set of voluntary focus groups and
consumer surveys over the course of the rulemaking to solicit
information from a diverse group of consumers regarding what information
displayed on the fuel economy label will best serve the intended purpose
of providing consumers with useful and meaningful information about the
vehicles they are considering to purchase.  

2.  Need for and Use of the Collection

	(a) Need/Authority for the Collection

The consumer survey and focus group research information is needed by
EPA to assist the Agency in determining the design and content of fuel
economy labels that are understood by and useful to prospective car
buyers. 

.  

	(b) Practical Utility/Users of the Data

The consumer survey and focus group research will be used by EPA to
better understand what information displayed on the fuel economy label
– especially with respect to advanced technology vehicles – will be
most useful and understandable to consumers.   The data gathered will be
used along with comments received during the proposal period of the fuel
economy labeling regulations to assist EPA's final determination of the
label design and content to specify in those regulations.  

3.  Non-duplication, Consultations, and Other Collection Criteria

	(a) Non-duplication

EPA is not requesting information that is anyway duplicative of other
information being collected by any other entity.

	(b) Public Notice Prior to Submission to OMB

EPA is soliciting public comment as required by the Paperwork Reduction
Act via a Federal Register notice published in early December, 2009. 

	

	(c) Consultations

In conducting the focus group research, EPA will contract the services
of a professional market research firm, who will assist in developing
and pre-testing the surveys and in conducting the focus groups.

	(d) Effects of Less Frequent Collection

N/A

	(e) General Guidelines  

The information collected under this action adheres to OMB's general
guidelines for information collections.   

	(f) Confidentiality

Resulting reports from the market research will not be considered
confidential.  The identity of participants will be confidential.

	(g) Sensitive Questions

No sensitive questions will be asked.  The collection complies with the
Privacy Act and OMB Circular A-108.

4.  The Respondents and the Information Requested

	(a) Respondents/NAICS Codes

In general, respondents will consist of randomly selected citizens. 
Some screening may be done to ensure that the respondents may have some
familiarity with fuel economy and fuel economy labels.  For example,
respondents could be randomly selected from records of people who have
recently purchased a vehicle.  The locations of the focus groups have
not been determined, but will most likely be in more than one location
to prevent geographical bias. EPA will rely on the judgment and
expertise of the contractor hired to design and conduct the surveys and
focus groups to determine the geographic locations of the groups, as
well as the appropriate level of screening.   

	(b) Information Requested

		(i) Data items

Survey data will be collected from recent new car buyers.  The surveys
have not yet been developed, but will be developed and appropriately
pre-tested by a contractor under direction from EPA with the goal of
producing statistically robust results.  In general, the surveys will
gather information about the following three issues:

Vehicle buying process and the role of fuel economy information in that
process

Consumer comprehension and reactions regarding different liquid fuel
metrics (i.e., economy vs. consumption)

Preferences regarding label metrics for PHEVs and EVs

Focus groups will explore the same three topics, producing data more
qualitative in nature. Groups will be asked about their car-buying
process and the role of fuel economy, what they know and understand
about the EPA fuel economy label, and the usefulness of the label in its
current form.  They will be asked about how the label could be improved,
and the groups will explore the possibility of displaying more
information on the label, and specifically about a fuel consumption
metric such as gallons per 100 miles.  Groups will also discuss advanced
technology vehicles such as plug-in hybrid electric vehicles and what
the label should display in order to be most helpful to consumers.  

		(ii) Respondent Activities

	

Surveys would be designed to take a respondent no longer than 12
minutes. Focus groups conducted would generally take no longer than 2
hours per group.  EPA is allotting an additional 2.5 hours per
respondent for travel and telephone screening.

5. The Information Collected--Agency Activities, Collection Methodology,
and Information Management

	(a) Agency Activities

In coordination with the contractor, the Agency will review and analyze
the information collected and develop a final report.  Upon completion
of the final report, it will be distributed to interested parties.  EPA
would use the information collected as an aid to determine the final
format of the fuel economy label. 

	(b) Collection Methodology and Management

The survey data will be analyzed using the SPSS statistical package and
summarized in a final report by the contractor. The focus groups will be
recorded audibly and video-taped.  In addition, the contractor
moderating the groups will take notes.  The recorded information will be
used by the contractor to develop a final report.  

	(c) Small Entity Flexibility

Small entity flexibilities are not needed for this information
collection activity.  Participation in focus groups would be strictly on
a voluntary basis.

	(d) Collection Schedule

The surveys and focus groups will be conducted prior to the publication
of the proposed fuel economy labeling regulation.  The actual dates are
to be determined. 

6.	Estimating the Burden and Cost of the Collection

	(a) Estimating Respondent Burden

The burden for respondents participating in the surveys is estimated to
be 12 minutes per respondent.  The burden for respondents participating
in the focus groups is estimated to be 4.5 hours per respondent.  This
includes 2.5 hours for travel and telephone screening and 2 hours for
participation in the focus group.

	(b)	Estimating Respondent Costs

	(i) Labor costs

Labor rates on a per hour basis are estimated as $29.31/hour. This rate
was taken from the Bureau of Labor Statistics Civilian Worker Cost Table
which was most recently updated in June of 2009
(http://stats.bls.gov/news.release/ecec.t02.htm).  This table estimates
the costs per hour worked for employee compensation and costs as a
percent of total compensation for the civilian workforce by occupational
and industry group.  According to this table, the average hourly total
compensation for the civilian worker is $29.31/hour.  The total labor
cost per survey respondent, based on 0.2 burden-hours (12 minutes), is
estimated to be $5.86.  The total labor cost per focus group
participant, based on 4.5 burden hours, is estimated to be $131.90.  

(ii) Estimating Capital and Operations and Maintenance Costs

Respondents will bear no capital and operations and maintenance costs.  

	(c)	Estimating Agency Burden and Cost

EPA's burden and cost includes the cost of overseeing a contractor to
design and administer the surveys and focus groups.  The estimated EPA
personnel effort needed is 0.3 FTE, which amounts to about 624 hours of
effort.  The hourly cost is estimated at $57.22, based on an average of
hourly costs for managerial, technical and secretarial costs.  The total
Agency cost is estimated at $35,705. 

	(d) & (e)	Total Burden Hours and Cost

Table 1

	SURVEYS

NO. OF RESPONDENTS			10,800

		TOTAL BURDEN HOURS 				2160

		TOTAL LABOR COST   			$63,310		

		OPERATING & MAINTENANCE COST	0	

		CAPITALIZED/START-UP COST		0	

	FOCUS GROUPS

NO. OF RESPONDENTS			120

		TOTAL BURDEN HOURS 				540

		TOTAL LABOR COST   			$15,827		

		OPERATING & MAINTENANCE COST	0	

		CAPITALIZED/START-UP COST		0		

	EPA	

		EMPLOYEES		0.3

		HOURS		624

		LABOR COST	$35,705

	(f)	Burden Statement

Section 6(d) & (e) presents the total estimated burden for implementing
the proposed information collection requirements. 

Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal Agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collection, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.  An agency may not
conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB
control number.  The OMB control number for EPA’s regulations are
listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency’s need for this information, the accuracy of
the provided estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No
EPA-HQ-OAR-2009-0865, which is available for public viewing at the Air
and Radiation Docket and Information Center in the EPA Docket Center
(EPA/DC), EPA West, Room B102, 1301 Constitution Avenue, NW, Washington,
D.C.  The Docket Center Public Reading Room is open from 8:30 a.m. to
4:30 p.m., Monday through Friday, excluding legal holidays.  The
telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Air and Radiation Docket and Information Center
is (202) 566-1742.  To submit comments to EPA’s electronic public
docket, go directly to the Federal Docket Management System at
http://www.regulations.gov and follow the online instructions for
submitting comments.  Direct your comments to Docket ID No.
EPA-HQ-OAR-2009-0865.  The system is an “anonymous access” system,
which means we will not know your identity, e-mail address, or other
contact information unless you provide it in the body of your comment.
Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, D.C. 20503, Attention: Desk Office for EPA. Please include
the EPA Docket ID No. EPA-HQ-OAR-2009-0865 in any correspondence. 

Part B of Supporting Statement

1) Introduction to Part B

For reasons explained in Part A, EPA will conduct a series of surveys
and focus groups to assess consumer behavior and attitudes towards fuel
economy and EPA’s fuel economy label.  

                                                       

2) Sections 1 and 2: Survey Objectives, Key Variables, and Survey Design

Survey Objectives:  Surveys and focus groups have three fundamental
objectives:

Inform EPA of the vehicle buying process and the role of fuel economy
information in that process

Evaluate consumer comprehension and reactions regarding different liquid
fuel metrics (i.e., economy vs. consumption)

Evaluate consumer preferences regarding label metrics for advanced
technology vehicles such as electric vehicles and plug-in hybrid
electric vehicles

Key Variables: N/A

Survey Design: Surveys and focus group materials have not yet been
developed, but will be done by a contractor under direction from EPA.  

                                                          

3) Sections 3 - 5: 

Pretests: The contractor performing the surveys will appropriately
pre-test the surveys.

Pilot Tests: N/A

Collection Methods:  Focus Groups, Internet and telephone surveys.

Analyzing Survey Results:  Survey results will be quantitatively
analyzed using appropriate statistical methods and software.  Focus
group results will be qualitatively analyzed. Group reactions will be
noted and compared.  Common comments about specific aspects of the label
content and designs will be noted.  Any common preferences expressed
will be noted.  

	

Attachment I

							

Legal Authority & Regulatory Citations

Clean Air Act:

42 U.S.C. 7525.  Motor Vehicle and Motor Vehicle Engine Compliance
Testing and Certification;   42 U.S.C. 7542.  Records and Reports

Energy Policy and Conservation Act:

49 U.S.C. 32908	Fuel Economy Information	

Regulatory Citations:

40 CFR Part 600 Fuel Economy of Motor Vehicles.

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