Bad mileage - a talk with the EPA
11-27-2003, 08:05 AM
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Bad mileage - a talk with the EPA
I contacted the EPA about what recourse we have if we're getting 30% less mileage than the window sticker minimum. I was contacted by an EPA representative. No great news, but some very interesting information!
Here's my notes:
The EPA representative I spoke with confirmed that the RX-8 was tested in Ann Arbor, Michigan. The cars tested were pre-production, had over 4000 miles on them and had a production body. Sometimes the cars they get are “mules”, they don’t have the body of a production car but the engine, transmission, drivetrain, tires and PCM (computer) must be representative of production.
Both City and Highway tests were run on a dyno with a 48” diameter roll loading the driving wheels.
The City test is 7.5 miles, stop-and-go, starting with a “cold start”. The average speed is 20 mph, with 18 stops, a hot start in the middle of the test and 18% idle time, to simulate stopping at traffic lights. The test dates back to the 1970’s! The EPA rep admitted that this test may need an update, but said that those in a position to change it were reluctant because of its 30 year history and the ability to do a relative comparison between vehicles has been successful.
The Highway test is 10 miles with a 48 mph average speed and begins with a hot start. There are no stops and little idling time. The max speed is 60 mph.
The numbers posted on the window sticker are derived from the emissions testing described, above. A sample bag of exhaust gas is collected and the gas mileage is determined, based on the amount of unburned hydrocarbons in the sample. City mileage is de-rated 10% from the test result, to reflect “real world” conditions. The highway mileage is de-rated by 22%
The consumer has no recourse, based on EPA mileage estimates. The recommended course of action by the EPA representative I spoke with was to first contact your dealer. Second, if you don’t get things resolved, contact Mazda North America. He actually referenced page 9-2 in the owners manual! For our Northern friends, the Canadian ‘Customer Assistance’ page is 9-3. Note that Canada seems to have a more thorough arbitration process! Long-story-short is that if you thought that the posted mileage numbers gave any guarantee, forget it! He agreed that the 30% lower mileage seen by some owners was significant, but suggested going ‘by the book’ to get it resolved.
Q: Can you suggest what an owner needs to document to legitimize claims of low mileage? Driving profile is very important. Someone that buys an RX-8 is not likely to follow the profile used in the EPA tests, above. It would be helpful to also note whether you top off the tank, how you calculate mileage. It is also good to do a continuous monitoring of mileage, that is, consecutive tanks. I write down the trip odometer and main odometer readings on gas receipts.
Q: Is there any mechanism to prevent an OEM from providing “special” test cars that are NOT representative of production? He did not think Mazda built special cars for the test. The manufacturer must provide 3-4 test cars, to start, more if they don’t pass the test. There are follow-up tests at 50,000 miles (partial life) and 100,000 miles. They have a “deterioration factor” that is applied to the original test results. If the later tests fail, the OEM has to do a recall. The cars tested in the follow-up tests are purchased by Mazda and submitted to the EPA. If production parameters change, during production, that would affect test results (shift points, calibration, etc), they have to submit them for re-testing.
Q: Are the test cars have VIN numbers. The OEM cannot produce or sell cars until they get certification. The cars submitted are definitely pre-production.
Q: Are the state emissions tests accurate? He did not think state testing would compare, or be as complete as the procedures and equipment used at EPA. The EPA test facility is in Ann Arbor, Michigan (about two hours from me!). There are also independent labs, one owned by Mercedes but used by many other manufacturers and one in California.
Other interesting tidbit…. GM had equipment to build rotary engines, back in the 70’s. They dropped the program based on problems with seal durability, oil burning and emissions problems. It is rumored that all the equipment was sold off.. by the pound!
Here's my notes:
The EPA representative I spoke with confirmed that the RX-8 was tested in Ann Arbor, Michigan. The cars tested were pre-production, had over 4000 miles on them and had a production body. Sometimes the cars they get are “mules”, they don’t have the body of a production car but the engine, transmission, drivetrain, tires and PCM (computer) must be representative of production.
Both City and Highway tests were run on a dyno with a 48” diameter roll loading the driving wheels.
The City test is 7.5 miles, stop-and-go, starting with a “cold start”. The average speed is 20 mph, with 18 stops, a hot start in the middle of the test and 18% idle time, to simulate stopping at traffic lights. The test dates back to the 1970’s! The EPA rep admitted that this test may need an update, but said that those in a position to change it were reluctant because of its 30 year history and the ability to do a relative comparison between vehicles has been successful.
The Highway test is 10 miles with a 48 mph average speed and begins with a hot start. There are no stops and little idling time. The max speed is 60 mph.
The numbers posted on the window sticker are derived from the emissions testing described, above. A sample bag of exhaust gas is collected and the gas mileage is determined, based on the amount of unburned hydrocarbons in the sample. City mileage is de-rated 10% from the test result, to reflect “real world” conditions. The highway mileage is de-rated by 22%
The consumer has no recourse, based on EPA mileage estimates. The recommended course of action by the EPA representative I spoke with was to first contact your dealer. Second, if you don’t get things resolved, contact Mazda North America. He actually referenced page 9-2 in the owners manual! For our Northern friends, the Canadian ‘Customer Assistance’ page is 9-3. Note that Canada seems to have a more thorough arbitration process! Long-story-short is that if you thought that the posted mileage numbers gave any guarantee, forget it! He agreed that the 30% lower mileage seen by some owners was significant, but suggested going ‘by the book’ to get it resolved.
Q: Can you suggest what an owner needs to document to legitimize claims of low mileage? Driving profile is very important. Someone that buys an RX-8 is not likely to follow the profile used in the EPA tests, above. It would be helpful to also note whether you top off the tank, how you calculate mileage. It is also good to do a continuous monitoring of mileage, that is, consecutive tanks. I write down the trip odometer and main odometer readings on gas receipts.
Q: Is there any mechanism to prevent an OEM from providing “special” test cars that are NOT representative of production? He did not think Mazda built special cars for the test. The manufacturer must provide 3-4 test cars, to start, more if they don’t pass the test. There are follow-up tests at 50,000 miles (partial life) and 100,000 miles. They have a “deterioration factor” that is applied to the original test results. If the later tests fail, the OEM has to do a recall. The cars tested in the follow-up tests are purchased by Mazda and submitted to the EPA. If production parameters change, during production, that would affect test results (shift points, calibration, etc), they have to submit them for re-testing.
Q: Are the test cars have VIN numbers. The OEM cannot produce or sell cars until they get certification. The cars submitted are definitely pre-production.
Q: Are the state emissions tests accurate? He did not think state testing would compare, or be as complete as the procedures and equipment used at EPA. The EPA test facility is in Ann Arbor, Michigan (about two hours from me!). There are also independent labs, one owned by Mercedes but used by many other manufacturers and one in California.
Other interesting tidbit…. GM had equipment to build rotary engines, back in the 70’s. They dropped the program based on problems with seal durability, oil burning and emissions problems. It is rumored that all the equipment was sold off.. by the pound!
11-27-2003, 08:14 AM
#2
Re: Bad mileage - a talk with the EPA
Originally posted by Charles Cope
Other interesting tidbit?. GM had equipment to build rotary engines, back in the 70?s. They dropped the program based on problems with seal durability, oil burning and emissions problems. It is rumored that all the equipment was sold off.. by the pound!
Other interesting tidbit?. GM had equipment to build rotary engines, back in the 70?s. They dropped the program based on problems with seal durability, oil burning and emissions problems. It is rumored that all the equipment was sold off.. by the pound!
11-27-2003, 10:16 AM
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Re: Bad mileage - a talk with the EPA
A sample bag of exhaust gas is collected and the gas mileage is determined, based on the amount of unburned hydrocarbons in the sample
Originally posted by Charles Cope
Other interesting tidbit…. GM had equipment to build rotary engines, back in the 70’s. They dropped the program based on problems with seal durability, oil burning and emissions problems. It is rumored that all the equipment was sold off.. by the pound!
Other interesting tidbit…. GM had equipment to build rotary engines, back in the 70’s. They dropped the program based on problems with seal durability, oil burning and emissions problems. It is rumored that all the equipment was sold off.. by the pound!
Regards,
Gordon
11-28-2003, 11:01 AM
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Re: Bad mileage - a talk with the EPA
Originally posted by Charles Cope
The numbers posted on the window sticker are derived from the emissions testing described, above. A sample bag of exhaust gas is collected and the gas mileage is determined, based on the amount of unburned hydrocarbons in the sample. City mileage is de-rated 10% from the test result, to reflect “real world” conditions. The highway mileage is de-rated by 22%
The numbers posted on the window sticker are derived from the emissions testing described, above. A sample bag of exhaust gas is collected and the gas mileage is determined, based on the amount of unburned hydrocarbons in the sample. City mileage is de-rated 10% from the test result, to reflect “real world” conditions. The highway mileage is de-rated by 22%
The EPA's numbers were actually 20.402 mpg city / 30.2244 mpg highway (23.8967 mpg combined). These EPA unadjusted figures are determined by running 2 driving schedules on dynos. To test city/urban economy, the EPA measured fuel usage on their LA-4 driving schedule (aka FTP-72, UDDS, etc). To test highway fuel economy, the EPA measured fuel usage on their Highway Fuel Ecomony Test (HWFET) driving schedule."
So how did the numbers change from 20.4/30.2 to 18/24? Sorry to proponents of conspiracy theories but www.fueleconomy.gov has the answer:
"To make the numbers in the Fuel Economy Guide more useful for consumers, EPA adjusts these laboratory test results to account for the difference between controlled laboratory conditions and actual driving on the road. The laboratory fuel economy results are adjusted downward to arrive at the estimates in the Fuel Economy Guide and on the labels seen on new cars, light trucks, and vans. The city estimate is lowered by 10% and the highway estimate by 22% from the laboratory test results. Experience has proven that these adjustments make the mileage estimates in the Fuel Economy Guide correspond more closely to the actual fuel economy realized by the average driver."
20.402 * .9 = 18.4 city mpg
30.2244 * .78 = 23.6 highway mpg
Originally posted by Charles Cope
The consumer has no recourse, based on EPA mileage estimates. The recommended course of action by the EPA representative I spoke with was to first contact your dealer. Second, if you don’t get things resolved, contact Mazda North America. He actually referenced page 9-2 in the owners manual! For our Northern friends, the Canadian ‘Customer Assistance’ page is 9-3. Note that Canada seems to have a more thorough arbitration process! Long-story-short is that if you thought that the posted mileage numbers gave any guarantee, forget it! He agreed that the 30% lower mileage seen by some owners was significant, but suggested going ‘by the book’ to get it resolved.
The consumer has no recourse, based on EPA mileage estimates. The recommended course of action by the EPA representative I spoke with was to first contact your dealer. Second, if you don’t get things resolved, contact Mazda North America. He actually referenced page 9-2 in the owners manual! For our Northern friends, the Canadian ‘Customer Assistance’ page is 9-3. Note that Canada seems to have a more thorough arbitration process! Long-story-short is that if you thought that the posted mileage numbers gave any guarantee, forget it! He agreed that the 30% lower mileage seen by some owners was significant, but suggested going ‘by the book’ to get it resolved.
There are many factors which can affect individual fuel economy but if anyone here doubts the EPA results, they should be able to find a certified testing center that can simulate the FTP-72 and HWFET dyno tests under federal testing conditions. I would think that any halfway serious lawsuit would need to have some halfway relevent evidence of testing results (under epa test procedures) for their car in addition to just mileage estimates where many other factors are involved.
Originally posted by Charles Cope
Q: Is there any mechanism to prevent an OEM from providing “special” test cars that are NOT representative of production? He did not think Mazda built special cars for the test. The manufacturer must provide 3-4 test cars, to start, more if they don’t pass the test. There are follow-up tests at 50,000 miles (partial life) and 100,000 miles. They have a “deterioration factor” that is applied to the original test results. If the later tests fail, the OEM has to do a recall. The cars tested in the follow-up tests are purchased by Mazda and submitted to the EPA. If production parameters change, during production, that would affect test results (shift points, calibration, etc), they have to submit them for re-testing.
Q: Is there any mechanism to prevent an OEM from providing “special” test cars that are NOT representative of production? He did not think Mazda built special cars for the test. The manufacturer must provide 3-4 test cars, to start, more if they don’t pass the test. There are follow-up tests at 50,000 miles (partial life) and 100,000 miles. They have a “deterioration factor” that is applied to the original test results. If the later tests fail, the OEM has to do a recall. The cars tested in the follow-up tests are purchased by Mazda and submitted to the EPA. If production parameters change, during production, that would affect test results (shift points, calibration, etc), they have to submit them for re-testing.
https://www.rx8club.com/showthread.p...245#post156245
Originally posted by Charles Cope
Q: Are the state emissions tests accurate? He did not think state testing would compare, or be as complete as the procedures and equipment used at EPA. The EPA test facility is in Ann Arbor, Michigan (about two hours from me!). There are also independent labs, one owned by Mercedes but used by many other manufacturers and one in California.
Q: Are the state emissions tests accurate? He did not think state testing would compare, or be as complete as the procedures and equipment used at EPA. The EPA test facility is in Ann Arbor, Michigan (about two hours from me!). There are also independent labs, one owned by Mercedes but used by many other manufacturers and one in California.
Originally posted by Charles Cope
Other interesting tidbit…. GM had equipment to build rotary engines, back in the 70’s. They dropped the program based on problems with seal durability, oil burning and emissions problems. It is rumored that all the equipment was sold off.. by the pound!
Other interesting tidbit…. GM had equipment to build rotary engines, back in the 70’s. They dropped the program based on problems with seal durability, oil burning and emissions problems. It is rumored that all the equipment was sold off.. by the pound!
Brian
Last edited by Buger; 11-28-2003 at 11:09 AM.
11-28-2003, 01:30 PM
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Actually, there's more to GM dropping the rotary than simply the fuel crisis. Instead of paying for the full copyright, that would have given them access to all the research on the rotary done up to that time, they only got the benefits of the early work. When they started work on the rotary, they basically had to duplicate all the previous work done by Mazda (probably in a less efficient manner).
By the time the fuel crisis came around, GM hadn't overcome most of the design difficulties, so they scrapped it. If they had bought the full copyrights, they would had working models much sooner, and they would have been more likely to stick with it. BTW, a lot of other companies were basically waiting to see if GM was going to have a production rotary. If GM made a rotary-powered car, a lot of the other US companies would have followed.
Imagine if the rotary engine had been researched as much as the piston engines.... Maybe a lot of the issues that Mazda is still dealing with would be resolved by now.
By the time the fuel crisis came around, GM hadn't overcome most of the design difficulties, so they scrapped it. If they had bought the full copyrights, they would had working models much sooner, and they would have been more likely to stick with it. BTW, a lot of other companies were basically waiting to see if GM was going to have a production rotary. If GM made a rotary-powered car, a lot of the other US companies would have followed.
Imagine if the rotary engine had been researched as much as the piston engines.... Maybe a lot of the issues that Mazda is still dealing with would be resolved by now.
11-28-2003, 02:13 PM
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So does this meanthat if you want to get the 18mpg posted on the sticker for city mpgthat you have to stay around 20 - 25 mph all the time while you drive? Thats bullshit
11-28-2003, 04:15 PM
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Hahaha and drive an average speed pf 48 mph on the highway with no stops and never exceding 60... I think the EPA needs to step out of the dark ages. Interesting info charles.
11-28-2003, 05:14 PM
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Did you not read the whole post? If you drive the way the EPA does in the test, you'll probably get the 20.4 city /30.2 hwy that they got in the test. The 18/36 numbers are adjusted in an attempt to account for normal driving.
11-28-2003, 05:17 PM
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Originally posted by rabinabo
Did you not read the whole post? If you drive the way the EPA does in the test, you'll probably get the 20.4 city /30.2 hwy that they got in the test. The 18/36 numbers are adjusted in an attempt to account for normal driving.
Did you not read the whole post? If you drive the way the EPA does in the test, you'll probably get the 20.4 city /30.2 hwy that they got in the test. The 18/36 numbers are adjusted in an attempt to account for normal driving.
11-28-2003, 05:24 PM
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To be precise, here's the relevent bit:
"To make the numbers in the Fuel Economy Guide more useful for consumers, EPA adjusts these laboratory test results to account for the difference between controlled laboratory conditions and actual driving on the road. The laboratory fuel economy results are adjusted downward to arrive at the estimates in the Fuel Economy Guide and on the labels seen on new cars, light trucks, and vans. The city estimate is lowered by 10% and the highway estimate by 22% from the laboratory test results. Experience has proven that these adjustments make the mileage estimates in the Fuel Economy Guide correspond more closely to the actual fuel economy realized by the average driver."
"To make the numbers in the Fuel Economy Guide more useful for consumers, EPA adjusts these laboratory test results to account for the difference between controlled laboratory conditions and actual driving on the road. The laboratory fuel economy results are adjusted downward to arrive at the estimates in the Fuel Economy Guide and on the labels seen on new cars, light trucks, and vans. The city estimate is lowered by 10% and the highway estimate by 22% from the laboratory test results. Experience has proven that these adjustments make the mileage estimates in the Fuel Economy Guide correspond more closely to the actual fuel economy realized by the average driver."
11-28-2003, 05:26 PM
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As I recall, EPA numbers were meant to be used by consumers merely to compare cars, not as an estimate of actual consumer fuel economy. That doesn't mean that there isn't a problem with the RX-8, but any ideas about basing a lawsuit on EPA numbers as "representations" by Mazda is a non-starter.
I'm averaging 18.6 mpg on my AT, but I am sure that I've been driving more conservatively than the typical poster on this board. I've just begun to play with the paddle shifters and I am betting that it's going to hurt my mileage. Fun = Poor Mileage. There are two things that surprise me in all this: (1) I would think a low-friction engine would be more fuel efficient by design, but that doesn't seem to be the case; (2) no one seems to have any strong theories as to why this car is disappointing some buyers in the fuel economy area. There are lots of ideas about HP and everything else, but no one has been able to explain the difference we're having between drivers.
BTW, don't make the dumb mistake I initially made of including the tank the dealer included with the sale of the car in calculating gross average mileage. Your average mileage is the total odo miles/total gallons you put in the car at the time of your last fill-up. Of course, your average for the last tank is measured at fill-up and is the miles driven since the last fill up/gallons used in most recent fill-up.
I'm averaging 18.6 mpg on my AT, but I am sure that I've been driving more conservatively than the typical poster on this board. I've just begun to play with the paddle shifters and I am betting that it's going to hurt my mileage. Fun = Poor Mileage. There are two things that surprise me in all this: (1) I would think a low-friction engine would be more fuel efficient by design, but that doesn't seem to be the case; (2) no one seems to have any strong theories as to why this car is disappointing some buyers in the fuel economy area. There are lots of ideas about HP and everything else, but no one has been able to explain the difference we're having between drivers.
BTW, don't make the dumb mistake I initially made of including the tank the dealer included with the sale of the car in calculating gross average mileage. Your average mileage is the total odo miles/total gallons you put in the car at the time of your last fill-up. Of course, your average for the last tank is measured at fill-up and is the miles driven since the last fill up/gallons used in most recent fill-up.
11-29-2003, 07:10 AM
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Thanks to all who have added and enhanced the info I got from EPA, especially Brian/Buger - great research/knowledge. My original intent was to see if the gov would give those getting 12-13mpg while they drive an RX like an econo box, some additional leverage to get their cars fixed. I believe that the production methods, tolerances, etc. on the Renesis engine are probably in need of refinement and that's why there is such a wide variation in performance & efficiency seen by our "community". SO: Should those unlucky enough to get an engine on the "wrong end of the curve" have no recourse to get a new engine, Flash image or car?
Contact your dealer, contact Madza North America, read your state's lemon law, that's what we got, right now. I thought of sending the mileage statistics compiled by Norton in his thread: “Statistical Analysis Approach to Understanding MPG Issue” https://www.rx8club.com/showthread.p...threadid=13280 to the EPA or Mazda or ??
Any other ideas?
Contact your dealer, contact Madza North America, read your state's lemon law, that's what we got, right now. I thought of sending the mileage statistics compiled by Norton in his thread: “Statistical Analysis Approach to Understanding MPG Issue” https://www.rx8club.com/showthread.p...threadid=13280 to the EPA or Mazda or ??
Any other ideas?
11-29-2003, 04:45 PM
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It would be great to find a lab that can replicate the test conditions of the official EPA test and run some of our cars through it. anyone have any hot leads on this?
11-30-2003, 01:25 AM
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Originally posted by 8_wannabe
It would be great to find a lab that can replicate the test conditions of the official EPA test and run some of our cars through it. anyone have any hot leads on this?
It would be great to find a lab that can replicate the test conditions of the official EPA test and run some of our cars through it. anyone have any hot leads on this?
http://www.etclab.com/ did the FTP-75, HWFET, US-06 and SC-03 tests on a Toyota Prius and Honda Insight for the NREL (National Renewable Energy Lab).
You can read a little bit about it at the below links:
http://www.ctts.nrel.gov/analysis/hev_test/data.shtml
http://www.ctts.nrel.gov/analysis/he...ocedures.shtml
I assume that there should be labs in other cities that could do the same testing. Not sure exactly how altitude affects the test results as I believe the EPA testing is done at 2 different sites in Michigan.
Brian
11-30-2003, 05:10 AM
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The main EPA test facility is.. http://www.epa.gov/nvfel/
I sent a note asking if they test "consumer" vehicles and for info on other labs that might.
I sent a note asking if they test "consumer" vehicles and for info on other labs that might.
12-03-2003, 04:45 AM
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Originally posted by Charles Cope
I sent a note asking if they test "consumer" vehicles and for info on other labs that might.
I sent a note asking if they test "consumer" vehicles and for info on other labs that might.
I regret to inform you that the National Vehicle and Fuel Emissions
Laboratory here in Ann Arbor is not able to provide testing services for
consumers, or for other private entities (that is, we also do not tender
contracts for use of our facilities for private vehicle testing).
There are a number of independent test laboratories around the US that
are capable of performing emission and fuel economy testing of cars and
light-duty trucks in accordance with all applicable regulations (test
procedures, test equipment specifications, and so forth). I have
attached a listing of those independent test labs that EPA is aware of,
that have such capabilities. We do not claim that this list is
exhaustive, as we have no means of determining what labs have this
capability unless they notify us.
The list is attached twice, as an Adobe Acrobat portable document
(LabList-May2002.pdf) and as a Microsoft Excel spreadsheet document
(LabList-May2002.xls).
(See attached file: LabList-May2002.pdf)(See attached file:
LabList-May2002.xls)
Just to give you some notion of the overall complexity of this testing:
Here at EPA, for internal budget and planning purposes, we estimate a
cost in laboratory time and equipment (not including personnel costs) of
about $1500 per FTP (Federal Test Procedure) per vehicle. One of the
labs listed in the attached documents, Mercedes-Benz Service Corp. here
in Ann Arbor, charges approximately $2500 to conduct one complete series
of tests (FTP and Highway Fuel Economy Test) on one vehicle. I would
expect that other labs' charges would be in the same general range.
I hope that you find this information responsive to your needs. Thank
you for contacting EPA's Office of Transportation and Air Quality.
12-03-2003, 05:58 AM
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Great work, Charles. My suggestion: We ought to pick one or two cars that are getting around 15 mpg or below, and all chip in for the test. Maybe we can contribute as we did for the server upgrade. Then we will have real-world cars tested with actual EPA conditions to take our battle forward that a problem here needs to be addressed. Or, we find the cars get the results Mazda said all along, and our low mileage is due to driving habits and we can all shut up. Either way, we have a path to resolve the issue.
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