Monroney Label Consumer Focus Groups
Supporting Statement
A12. Provide estimates of the hour burden of the collection of information. 10
A14. Provide estimates of annualized costs to the Federal government. 12
Under its 5-Star Safety Rating Program, the National Highway Traffic Safety Administration (NHTSA) subjects vehicles to frontal crash, side crash, and rollover resistance tests and, based on the results, assigns safety ratings to the tested vehicles. The ratings are expressed in terms of a 5-star rating system, with 5 stars being the highest rating and 1 star, the lowest. The ratings enable consumers to consider and assess the relative safety of vehicles before deciding which new vehicle they want to purchase.
The Automobile Information Disclosure Act (15 U.S.C. 1231-1233), or the “Monroney Act,” was enacted into law in 1958 and requires all new light vehicles to have a window sticker affixed that shows:
Vehicle model;
Vehicle identification number;
The final assembly point;
The name and location of the dealer to whom the vehicle is to be delivered;
The manufacturer’s suggested retail price (MSRP) of the base vehicle;
The transportation charges for delivery of the vehicle from the manufacturer to the dealer; and
The total MSRP of all of the above.
The Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU), P.L. 109-59 (August 10, 2005; 119 Stat. 1144) requires new passenger vehicles to also include safety rating information published by NHTSA under its 5-Star Safety Rating Program as part of the Monroney label. Pursuant to the SAFETEA-LU, NHTSA published a final rule (71 FR 53572) on September 12, 2006 requiring manufacturers to include safety rating information by September 1, 2007.
On July 11, 2008, NHTSA published a final decision notice announcing enhancements to the NCAP programs. These enhancements include:
For the frontal crash program – modifying the frontal NCAP rating system to reflect updated test dummies, expanded injury criteria, and the inclusion of all body regions that are covered by Federal Motor Vehicle Safety Standard (FMVSS) No. 208;
For the side crash program – modifying the side NCAP rating system to reflect new side impact test dummies, new injury criteria, the inclusion of nearly all of the body regions that are covered by FMVSS No. 214, as well as a new pole test using a small female crash test dummy;
A new overall vehicle score that will be based on frontal crash, side crash, and rollover resistance test results; and
A new program that will recommend to consumers advanced crash avoidance technologies that have been shown to reduce crashes and that meet NHTSA’s performance criteria.
The enhancements to NCAP took effect in the 2011 model year.
On July 29, 2011, NHTSA published in the Federal Register (76 FR 45453) (Docket No. NHTSA–2010–0025) a final rule to revise the agency’s regulation on vehicle labeling of safety rating information to reflect the enhancements to the NCAP program, particularly the addition of the overall vehicle score. The final rule is included in this package as Appendix A.
The final rule included:
Beginning with model year 2012, safety rating labels on new passenger vehicles that are manufactured on or after January 31, 2012 would be required to include, as the first item of safety information in the safety rating label, an overall vehicle score based on a vehicle's frontal crash, side crash, and rollover resistance ratings. The agency will allow early compliance for model year 2012 vehicles that are manufactured before January 31, 2012 provided that the ratings placed on the safety ratings label are derived from vehicle testing conducted by NHTSA under the enhanced NCAP testing and rating program.
Language describing the nature and meaning of the NCAP test data used to generate vehicle safety ratings and a referral to http://www.safercar.gov for additional vehicle safety information in the safety rating label would be revised slightly and, in some cases, relocated in the safety rating label.
The following text, “Safety concern: Visit www.safercar.gov or call 1-888-327-4236 for more details.” is only required in the overall vehicle score area of the label. This mitigates space concerns in cases where a vehicle receives a safety concern in more than one crash test area.
The adopted language states that frontal crash ratings and the overall vehicle score should only be compared to other vehicles of “similar size and weight,” rather than of “similar weight class.”
The agency has slightly modified explanatory language that will be required in the side crash area of the safety rating label to make clear that the ratings reflect risks involved in a real-world side impact crash, rather than risks associated with the two crash tests that are used to determine the side crash ratings.
The final rule also discussed NHTSA’s plans to conduct comprehensive consumer research on the entire Monroney label to better understand possible tradeoffs consumers make during their purchase decisions and whether the content, amount of space, font sizes, color and/or other variables have an impact on consumer attention and comprehension.
As a first step in this consumer research, NHTSA is requesting approval to conduct qualitative research with consumers and new vehicle dealers to achieve the aforementioned objectives.
Through this research, NHTSA must explore how safety information impacts vehicle purchase decisions, where consumers look for safety information and how consumers and dealers use safety and other information located on the Monroney label to aid purchase decisions, in order to help guide changes to the Monroney label. Additionally, NHTSA will use this research to discuss potential communication channels in order to guide the development of a consumer education program.
Specifically, the objectives of this research are as follows:
Understand vehicle purchase decision-making criteria;
Identify and evaluate sources of vehicle safety information to help inform the development of a consumer education program;
Evaluate Monroney label content comprehension and potential tradeoffs; and
Evaluate recent changes to the safety rating section of the Monroney label to help inform future revisions.
As NCAP is responsible for providing consumers with important safety information that will assist them in their vehicle purchase decisions, this research will be used to gather data to substantiate the effectiveness of revised Monroney label design changes and communications approaches. The data collected will also be used to assist NHTSA to better communicate vehicle safety information to consumers. This qualitative research will also provide meaningful insights into the consumers’ vehicle purchase process and help to inform future quantitative studies and/or additional research as needed.
NHTSA will also use this research to begin to explore the usefulness of adding the advanced crash avoidance safety information to the safety rating label; however, a more in-depth examination of public interest will be best executed as a separate collection in the future.
NHTSA is proposing to conduct two (2) focus groups each in five (5) cities - Boston, Massachusetts; Los Angeles, California; Tampa, Florida; Seattle, Washington; and Kansas City, Missouri. We recommend splitting the focus groups by gender, with one female group and one male group per city and will include a mix of ethnic and racial backgrounds, so that we receive feedback from all primary vehicle decision makers. Based on our experience, in mixed-gender groups that discuss vehicles and the vehicle purchase process, women generally defer to male opinions rather than providing their own well-thought out opinions. Conducting groups that are homogenous by gender will alleviate this problem, and provide guidance on what was/is important in the purchase process, as well as how useful and understandable consumers find the safety rating information and the rest of the information on the Monroney label.
Through the focus group screening process, we will identify participants who are recent purchasers and those who are intended purchasers (i.e., plan to purchase in the next 12 months). Among those planning to purchase, we will evaluate sources of information currently used by consumers, and the emphasis they place on the safety rating section of the Monroney label for point-of-sale safety information. Among those who have recently purchased, we will be able to explore what was most important, and where they turned for necessary vehicle information. The screener for these focus groups is included in this ICR package as Appendix B.
For the dealer interviews, we will conduct 30-minute onsite interviews with a salesperson responsible for assisting customers with new vehicle purchases. Potential respondents will be identified through a telephone recruit. No preference will be given to a particular vehicle manufacturer or dealership.
The discussion guide for these focus groups and interviews is included in Appendix C. The same discussion guide will be used for the focus groups and interviews and specifies which questions are applicable for both uses.
The following sections describe the justification for this proposed consumer research plan in detail.
The National Traffic and Motor Vehicle Safety Act of 1966, Title 15 United States Code 1395, Section 106 (b), gives the Secretary authorization to conduct research, testing, development, and training as authorized to be carried out by subsections for this title. The Vehicle Safety Act was subsequently re-codified under Title 49 of the U.S. Code in Chapter 301, Motor Vehicle Safety. Section 30168 of Title 49, Chapter 301, gives the Secretary authorization to conduct research, testing, development, and training to carry out this chapter. The full text is included in this package as Appendix D.
The purpose of this research is to obtain critical information that will allow NHTSA and NCAP to fulfill a congressional mandate to improve highway traffic safety. Specifically, the data from this collection will be used to enhance consumer comprehension of safety rating information and guide the development of a consumer education program related to vehicle safety.
The findings from this proposed research will assist NHTSA in ensuring that the information developed by NCAP as part of the Monroney label is easily comprehended by consumers. NHTSA will use the findings to develop relevant and effective consumer education initiatives to increase awareness and comprehension of vehicle safety concerns.
This qualitative data collection will be completed face-to-face, in a group or one-on-one discussion setting. A face-to-face setting is the best approach for this exploratory phase of research as it will facilitate a deep conversation about each of the research objectives. The discussion will be helpful in gaining an understanding of consumer comprehension of ratings and their perceptions, opinions, and beliefs regarding relevant issues. Video and audio recordings of these discussions will be available to assist in transcription and report writing, but no other automated technologies will be used in this phase. Group participants will be informed of all technologies in use prior to the discussion.
NHTSA researchers have reviewed all recent studies pertaining to the Monroney label. Previous studies have either been limited in scope, or have incurred some form of response bias. For example, a 2008 mall-intercept project was conducted only in the Washington, D.C. metro area, and therefore the results cannot be considered indicative of the U.S. vehicle-buying population. A 2009 online survey was conducted with general consumers; however, the only way to access this survey was by visiting Kelley Blue Book’s website (http://www.kbb.com). With this singular point of entry, respondents to this study are inherently more likely to research vehicles online and are more likely to name KBB.com as a source of vehicle information. Reports from these research studies, as well as a 2010 memo detailing the findings from this research review and the research gaps identified are included in attachments to this submission package.
This item does not apply to the consumer focus group plan. For the dealer research, interviews will be scheduled at a mutually agreeable time so as to reduce burden and not interrupt business.
As an agency responsible for updating the standards upon which vehicle safety is communicated, NHTSA is relying on consumer data to develop standards and educational and informative messages that are comprehended by consumers, useful to their purchase decisions, and help make the highways safer by encouraging consumers to purchase safer vehicles. Without timely, accurate information on consumer perceptions of vehicle safety, trusted sources of information, and consumer comprehension and use of safety information and the Monroney label content, it will be impossible to identify the most effective methods for communicating safety information to vehicle-buying consumers. NHTSA will be ill-equipped to recommend changes to the safety rating section of the Monroney label without understanding if consumers comprehend the information enough to benefit from its availability.
No special circumstances require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.6.
The notice requesting public comment on the proposed collection of information was published to the Federal Register on Thursday, September 8, 2011 [Federal Register Volume 76, Number 174; pages 55735-55736]. NHTSA received two comments in support of this information collection request – one each from Motor & Equipment Manufacturers Association (MEMA) and Robert Bosch, LLC (Bosch).
MEMA’s comment included a number of suggestions that are already present in the current ICR package. This includes testing the size and location of the safety ratings portion of the Monroney label, exploring whether or not the current safety section is understandable and assessing the usefulness and likelihood to use various sources of information, including SaferCar.gov and third-party vehicle information resources. MEMA also requested that NHTSA explore whether or not the safety ratings portion of the Monroney label is legible and prominent. To ensure these topics are covered, questions have been added to Section 3 of the discussion guide.
In addition to these comments, MEMA is particularly interested in additional research surrounding crash avoidance technologies. While we will begin to explore the inclusion of crash avoidance technologies on the safety ratings portion of the Monroney label, NHTSA is planning to conduct follow up research on this specific topic, at which point the topics that MEMA would like us to address will be explored.
Like MEMA, Bosch has also suggested NHTSA explore the size and location of the safety ratings portion of the Monroney label, which NHTSA already intends to do through this collection. Bosch also included a number of suggestions for the focus groups, including the following:
Conduct groups in six cities instead of five to provide more geographic coverage.
NHTSA believes that the five cities planned for this study provides enough coverage to gather the qualitative data necessary to provide guidance and inform follow up quantitative research for this initiative.
Separate focus groups by men and women.
NHTSA plans to conduct groups that are homogenous by gender.
Focus on new car buyers that are selected by the stage of the shopping process.
NHTSA has added a question to the screener that explores what stage of the shopping process potential participants are in. We will aim to get a mix of respondents within our groups so that various stages of the process are represented.
Consider recruiting a few minority-only groups for the study.
Instead of recruiting minority-only groups, NHTSA plans recruit a mix of ethnicities and racial backgrounds within each of the 10 focus groups.
Include an exercise in which focus group participants inspect a vehicle with a Monroney label attached in order to observe and record their reactions.
NHTSA will be providing respondents with examples of current Monroney labels so that they can assess the legibility of the safety ratings portion of the Monroney label without relying on memory. We do not believe the benefits provided by creating a mock dealership environment are significant enough to rationalize the costs and resources required to execute this activity.
Include an exercise in which respondents evaluate the importance of vehicle purchase decision making criteria by asking them to allocate fictional money to the criteria they believe to be important.
NHTSA plans to discuss the importance of purchase decision criteria with participants by having the moderator write out the top-of-mind important criteria on a flip chart. Using that list, the moderator will be able to probe how respondents rank each item.
Research participants are provided a cash honorarium as compensation for their time. This honorarium is provided as an incentive for participants to take the time to travel to the focus group facility and participate in the discussion (therefore minimizing participant out-of-pocket expenses), as well as a sign of appreciation for their thoughts and opinions. The amount necessary for the honorarium varies by market, level of screening criteria and difficulty of obtaining participation from certain target participants. Given the general consumer nature of these groups and required participants, we expect the honorarium to be $75 for their time. Within each market, compensation will be equal for all participants; however, compensation will vary by market.
Focus groups generally include 90 minutes of discussion; however, due to the nature of this research we will be conducting 2-hour focus groups. This will provide the time necessary to cover all points of discussion, as well as detailed group evaluation of various options of the safety rating section and the Monroney label. As a result of this additional time and the necessary screening criteria, higher cost markets such as Boston and Los Angeles usually require a higher incentive to ensure a group of at least eight (8) participants participate; however, NHTSA will work with local facilities to comply to with the $75 incentive level.
Interviews will dealers are regarded as “expert” interviews, rather than general consumers. In order to properly compensate these respondents for their time, and encourage participation during the workday, we recommend using the same level of incentive ($75) as the consumer research.
For the qualitative research, any personal information, such as name and telephone number will strictly be used for the purposes of recruitment or conducting interviews. Participants will be face-to-face with the moderator, and NHTSA team members will observe the focus groups, but privacy will be protected to the extent of the law. Dealer interviews will not be available for onsite observation due to space limitations.
Prior to the start of the discussion, the moderator will assure participants that their responses are kept private to the fullest extent of the law and that they will not be personally identified in the report or documentation resulting from the research. Throughout the discussion, participants will only be identified by first name and any video or audio recordings of the focus groups or interviews will be in the sole possession of NHTSA.
This research will not include any questions of a sensitive or private nature.
For the focus group phase of this collection, NHTSA plans to conduct a total of 10 focus groups, each lasting approximately two hours. In each group, 8 participants will be seated. Therefore, a total of 80 people will participate in the group sessions. For recruiting of these participants, however, a total of 120 potential participants (12 per group) will be recruited via telephone screening calls, which are estimated to take 10 minutes per call. Based on experience, it is prudent to recruit up to 12 people per group in order to ensure at least 8 will actually appear at the focus group facility at the appointed time. In the same sense, it is likely that 15 dealers will be recruited for the research in order to confirm 10 interviews.
Thus, the total burden per person actually participating in this research is estimated to be 130 minutes for consumers (10 minutes for the screening/recruiting telephone call plus 120 minutes in the focus group discussion session) and 40 minutes for dealers (10 minutes for the screening/recruiting telephone call, plus 30 minutes in the interview). Additionally, the total burden per person recruited (but not participating in the discussions) is 10 minutes.
Therefore, the total annual estimated burden imposed by this collection of information is approximately 187.5 hours.
Qualitative Phase |
No. of Participants |
Hours per Person |
Total Participant Hours |
Focus Group & Dealer Interview Recruiting |
135 |
1/6 Hour (10 minutes) |
22.5 |
Focus Groups in 5 Cities |
80 |
2 |
160 |
Dealer Interviews in 5 Cities |
10 |
½ Hour (30 minutes) |
5 |
The maximum total input cost, if all respondents were interviewed on the job, is estimated as follows:
$16.27 per hour1 |
x 187.5 |
$3,050.63
|
The only cost burden any respondents will experience are the costs related to travel to and from focus group facilities. These costs are minimal and will ultimately be offset as focus group participants will be provided a cash honorarium (detailed in item A14).
Assuming respondents travel a maximum of 60 miles round-trip to and from the facility, the total maximum travel costs would be:
City |
Maximum Participants Per Group |
Maximum Total Participants |
Maximum Miles Traveled |
IRS Standard Mileage Rate2 |
Total Mileage Costs |
Focus Groups in 5 Cities |
12 |
120 |
60 |
$0.51/mile |
$3,672.00 |
Focus group participants generally travel far less than 30 miles one-way to participate and ultimately travel costs vary per person. This serves as an estimate of the maximum costs that respondents could be expected to incur. Note that travel costs do not apply to dealer interviews as these will be conducted onsite.
There will be no record keeping or reporting costs to respondents.
The costs associated with the qualitative phase of this research include direct costs such as facility rental, technology use (i.e., audio and video recordings), participant incentives, and staff travel.
Focus Group Facility Rental & Technology
Expense |
Unit Cost |
Total Units |
Total Cost |
Facility Rental |
$500 (per group) |
10 |
$5,000 |
Video & Audio Recordings |
$100 (per group) |
10 |
$1,000 |
Transcription |
$300 (per group) |
10 |
$3,000 |
Additional Facility
Expenses |
$400 (per group) |
10 |
$4,000 |
Total Facility Costs |
|
|
$13,000 |
Research Incentives & Recruitment Costs
City |
Estimated Unit Cost |
Participants Per Group |
Total Groups |
Total Participants |
Total Costs |
Recruitment Costs |
$110 |
12 |
10 |
120 |
$13,200 |
Respondent Incentives (Consumer Research) |
$75 |
8 |
10 |
80 |
$6,000 |
Respondent Incentives (Dealer Research) |
$75 |
- |
- |
10 |
$750 |
Total Recruitment and Incentive Costs |
|
|
|
|
$19,950 |
Staff Travel
For a 5-city focus group plan, we estimate the costs of staff travel to be approximately $5,000 per person. This figure includes airfare, hotel room, ground transportation, and other incidental expenses.
All staff travel will be billed to this project at cost and utilize government travel guidelines. Actual costs may vary and are dependent on dates of travel and research schedule.
Partner
Hours
Staff time for our research partners is calculated
using per hour billing rates. The hours estimated here are based on
hours needed for past qualitative projects of a similar scope. These
hours include time needed for screener and discussion guide
finalization, group moderating, data analysis and reporting, as well
as meetings and conference calls with the NHTSA team.
Level |
Labor Hour Rate |
Estimated Hours |
Total Costs |
Vice President |
210 |
105 |
$22,050 |
Senior Project Manager (Account Supervisor) |
155 |
170 |
$26,350 |
Research Assistant (Assistant Account Executive) |
100 |
170 |
$17,000 |
Total Partner Staff Time |
|
|
$65,400 |
NHTSA estimates the total cost of this focus group research to be $98,350, which does not include NHTSA staff travel cost. The final cost will be dependent on the number of NHTSA and partner staff that will be required to travel to each focus group location, and actual staff hours required.
This item is not applicable. This is a new research project.
The schedule for this consumer research has been planned as follows:
ACTION/MILESTONE |
TARGET COMPLETION DATE |
Qualitative Research ICR Process |
|
Post 60-Day Notice on Federal Register |
September 8, 2011 |
60-Day Comment Period |
September 8 – November 7, 2011 |
Informal Review of Package by OMB |
(During 60-Day Comment Period) |
Revise ICR package based on comments received |
November 14, 2011 |
NHTSA review revised documents |
November 15 – 18, 2011 |
Post 30-Day Notice to Federal Register |
November 21, 2011 |
OST Review and formal submission to OMB |
November 21 – December 5, 2011 |
30-Day notice closes |
December 21, 2011 |
OMB Completes Review of ICR documents |
February 20, 2012 |
OMB Approves Qualitative package |
March 1, 2012 |
Qualitative Research Execution |
|
Set-up Focus Groups (finalize locations, dates, recruit) |
March 1 – March 16, 2012 |
Conduct research |
March 21, April 10, 2012 |
Top-Line Interim Reports |
A city-specific summary of findings is sent within one day of the focus groups being conducted in that city. |
Final Reports for Qualitative Research Due |
April 24, 2012 |
Final dates of deliverables will ultimately be dependent on the date of OMB approval.
We do not seek approval to not display the expiration date for OMB approval for this research plan.
No
exceptions to the certification are required for this research plan.
Focus Group Recruitment
Focus groups for the NCAP Monroney label research program will be held utilizing the Fieldwork Network of focus group facilities. This company has 25 years of experience in qualitative research and currently runs 17 focus group facilities in various cities. Fieldwork also has partners in other locations around the country that can be utilized depending on the location of these focus groups.
For focus group research, recruitment can be executed using one or a mix of the following methods:
A list of potential respondents is provided to the focus group facility. This method is generally used when participants must meet specific and unique criteria or when the group is to be made up of a specific population for which a list of members exists.
A database of potential local respondents is compiled by facilities over time. These are people who have agreed in advance to participate in focus groups, if they qualify. The focus group facility maintains this database and adheres to the Marketing Research Association’s code of ethics on data collection in keeping personal information private.
An advertisement looking for participants can be included in the local newspaper, on a local website, or through some other channel to attract potential participants.
Since the first methodology does not apply to this program, focus group respondents for this research will be recruited using the latter methods.
Potential participants will be screened for various criteria and the sample for these discussion groups will be built in the following way:
First, participants must qualify as an adult over the age of 18.
Next, participants will be identified for inclusion in either the male or female focus group.
Next, participants will be asked if they or any of their family members work or have worked for an automobile manufacturer. Those answering ‘yes’ will not qualify for the groups.
Next, participants must qualify as having purchased a passenger vehicle in the last 6 months or as planning to purchase a passenger vehicle in the next 12 months.
Finally, participants must qualify as the primary or shared decision maker for vehicle purchases.
The screening criteria used for the focus groups are included as Appendix B of this package.
Focus groups will be homogenous by gender as past experience has demonstrated that in mixed groups that discuss vehicle-related purchases, women generally defer to male opinions rather than providing their own, well-thought-out perspectives. Therefore, we will seek out an even number of males and females in each city in order to hold one female group and one male group.
Dealer Interview Recruitment
In order to identify potential dealers to include in these interviews, NHTSA will use a third-party recruiter to identify salespeople (i.e., those people who help customers to purchase new vehicles) at dealers in each of our 5 research cities and make random calls to schedule interviews.
Dealers will be screened to ensure:
Interviewee is a salesperson of a new vehicle dealership.
Interviewee has regular contact with customers and provides information throughout their purchase decision.
Interviewee has appropriate permission to participate in research.
A mix of representatives from manufacturers. (Note: No hard quotas will be set for this criterion as this is qualitative research and will be exploratory in nature, not representative.)
1 From Bureau of Labor and Statistics’ median hourly wage (all occupations) in the May 2010 National Occupational Employment and Wage Estimates, Last Modified April 2011.
2 From Internal Revenue Services’ 2011 Standard Mileage Rate for business miles driven.
NHTSA:
Monroney Label Consumer Research ICR
Focus Group Supporting
Statement
| File Type | application/msword |
| File Title | raft Deliberative Documen |
| Author | Edelman |
| Last Modified By | test |
| File Modified | 2012-07-13 |
| File Created | 2012-07-13 |