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Old 06-10-2013, 10:10 AM   #401
Zeeper
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As a complete aside I have filed two separate complaints with state and federal government agencies.

One was a wage dispute filed with the NY state department of labor and the other was a HIPAA complaint filed with the Office of Civil Rights.

Both cases were slam dunks, legally, and I knew that I would prevail so I kept the cases open despite the length of time(multiple years) and many letters and calls it took to get final resolution.

For the wage dispute I submitted copies of my payroll records going back over 7 years (since I was in charge of payroll for my department, it was not hard to obtain the evidence), and for the HIPAA dispute the Office of Civil Rights agreed with me that my case was valid within months of my complaint, and it only took 3 years of follow up to get the resolution in writing.

Your EPA/mpg complaint is far more dubious -- 5 standard deviations and all.

Given even a cursory search reveals some professional drivers got better results than CR, and the EPA mpg tests, even with the CVT that I don't have (you don't either, you don't have the same car that either professional driver tested, so how can you discuss it? LOL), I certainly would not recommend you count on cashing any checks from Subaru.
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Last edited by Zeeper; 06-12-2013 at 01:50 PM. Reason: because I have a stalker who has nothing better to do than track my edits, lol
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Old 06-10-2013, 03:16 PM   #402
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Old 06-10-2013, 05:52 PM   #403
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I have been checking my mail twice a day for nothing!!!
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Old 06-10-2013, 11:22 PM   #404
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Well, I guess I have 4.9 years to wait. That's okay, you will understand that the lack of cogent objections to my posts is encouraging...
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Old 06-10-2013, 11:37 PM   #405
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Quote:
Originally Posted by stevehnm View Post
Well, I guess I have 4.9 years to wait. That's okay, you will understand that the lack of cogent objections to my posts is encouraging...
Man, your something else!! I'm starting to feel better about myself now, that someone of your stature drives a car just like mine. It kind of makes me feel even better about my decision to own a car just like yours!
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Old 06-11-2013, 01:54 AM   #406
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Quote:
Originally Posted by stevehnm View Post
The sticker says "for comparison". The car achieves up to 50 mpg depending on how it is driven. When it is driven the same way as other cars are driven it does not achieve the same mpg as advertised. If you don't get that I'm sorry.



You're confused.



No, you're really confused.



You "build businesses" and agree with the light bulb and ice cream comparisons? There's something ludicrous in that...
Please feel free to set me straight then, because I'm fairly sure that your complaint hinges around the epa estimate and cr's estimate, and the differences therein; as well as so called false advertising on subaru's part, presumably for using the epa estimate in its marketing. Are we both clear on that?

The fact of the matter is that for the great majority of impreza drivers the car not only matches the epa estimate, but surpasses it.

As you have so carefully pointed out the epa estimate is convenient to use for comparison purposes, however those comparisons are only relevant for the epa test. Any other test result, differing from the epa test in methodology - including cr's - cannot reasonably be compared to the epa estimate directly. They can be used in conjunction with the epa test, to help a consumer make a more informed decision. As such, if I read the above posts correctly, the impreza gives close to its epa estimate in cr's test. This cements the impreza, imo, as a great value in its segment.

that's the apples to apples comparison.

apples to oranges is your claim that because SOME other cars, rated lower by epa, were tested as having better mpg by cr, that the impreza should too. And because it does not, you feel that there is a conspiracy by subaru and the epa to "lie" about the impreza's fuel economy.

even if there were evidence for this false advertising and conspiracy - which there is not - the conclusion cannot be drawn from data of DIFFERENT VEHICLES. This is a logical failure. If every vehicle cr tested performed better than the epa rating by a substantial margin there still wouldn't be proof of any false advertising or collusion. We know this because cr achieved nearly the same mpg as the epa estimate, which to my mind validates the epa claimed estimates. Perhaps, steve, you should be asking why the epa estimates other cars so low?
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Old 06-11-2013, 04:07 AM   #407
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That would all be true if all the error, or difference, between the EPA tests and CR's tests were random. However, it's not. There are two and only two types of error. Random error and bias error. To understand the situation one must accept that fact. Once the bias offset is removed from between the EPA and CR tests one can see that they are remarkably equivalent. If you look at the original post in this thread with that in mind you will see what I mean.

I didn't just "pick some cars". I used every car in CR's database that got 35 mpg in their highway test. Every car. Not only is the Impreza an outlier in that situation, but since there is another car tested by the same group it is reasonable to remove that one as well as the validity of Subaru itself is questionable. Once that is done one can see how amazingly identical the results between the two tests are - except for Subaru.

That is all buried in this post later on in the thread:
http://forums.nasioc.com/forums/show...&postcount=198
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Old 06-11-2013, 07:28 AM   #408
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I guess I should also point out that with both complaints I filed, the agencies spent 95% of their time during the first years trying to find a way to close the complaint so they would not have to actually pursue any action. It appears that workers in government agencies, tasked with protecting consumers, prefer to close complaints because you did not submit the correct form for them, or because it is hella easier than investigating it and following up.

So you need to be pretty motivated and persistent (continual phone calls and letters) to keep the complaint open and active, over multiple years. On the plus side, if you are active in responding to their attempts to dismiss your claim, it does not disappear. Once they register your complaint and give it a number you can keep on them to investigate it.

I have no doubt that stevenhmn will keep on them. Of course the fact that tens of thousands of other Impreza drivers do not seem to share his concern (actually there are only a few on the forum, but like the small percent of owners with oil burners, they must be the hidden majority who don't use the internets...) is gonna make it hard to pursue some sort of EPA, class action MPG remedy.

Then there is also the fact that his complaint hinges on the published data from Consumer Reports, who recommend the car for its excellent mileage. Yup, that is a winning hand....

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Old 06-11-2013, 09:27 PM   #409
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Old 06-11-2013, 11:53 PM   #410
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I hope he has very very deep pockets, because its not going to happen. Even if the complaint was accepted etc, it would go to court. It'll take 15-20% ownership to file with the class action with an attny wiling to forgo fees till settlement for anything to go that far. You can calculate your chances of this going anywhere, but I'd bet it'll be in the right side of that little black decimal point. You'll need to tie it in with safety somehow to go anywhere. Just because you think it's false or misleading advertising, that will not get you anywhere. Even if your claim is founded on solid facts they have 15 million dollars worth of disclaimers for advertising et al that makes it impossible to lock in any accountability. Gotta love attnys.
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Old 06-12-2013, 10:18 AM   #411
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I hope he has very very deep pockets, because its not going to happen. Even if the complaint was accepted etc, it would go to court. It'll take 15-20% ownership to file with the class action with an attny wiling to forgo fees till settlement for anything to go that far. You can calculate your chances of this going anywhere, but I'd bet it'll be in the right side of that little black decimal point. You'll need to tie it in with safety somehow to go anywhere. Just because you think it's false or misleading advertising, that will not get you anywhere. Even if your claim is founded on solid facts they have 15 million dollars worth of disclaimers for advertising et al that makes it impossible to lock in any accountability. Gotta love attnys.
Headed for left field with Zeeper eh?
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Old 06-12-2013, 10:23 AM   #412
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Then there is also the fact that his complaint hinges on the published data from Consumer Reports, who recommend the car for its excellent mileage. Yup, that is a winning hand....
Changing the story again? Where does Consumer Reports "recommend the car for its excellent mileage"? They recommend it for its excellent mileage for an AWD vehicle, but that's hardly the same thing. One is a big pond, the other is not.
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Old 06-12-2013, 11:32 AM   #413
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Headed for left field with Zeeper eh?
Actually, you need to re-read my post. You need to remember where I am coming from professionally. If that's left field, you have a long road with many lessons to learn.
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Old 06-12-2013, 12:04 PM   #414
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Changing the story again? Where does Consumer Reports "recommend the car for its excellent mileage"? They recommend it for its excellent mileage for an AWD vehicle, but that's hardly the same thing. One is a big pond, the other is not.
Not only do they recommend the car due to its excellent mileage, they also recommended the redesigned impreza, for a second year in a row, as their top pick for a compact car! They even picked it over the superior mpg champs from kia, Nissan, mazda, ford, Hyundai and Toyota!

Sucks that you have to prevaricate so much, you get all twisted up trying to figure out how to spin the fact that your source of spinnable data recommends the car so highly?

I would think you could be happy your car will keep its resale value, partly due to the CR top pick designation, 'cause you can use that retained value when you trade it for your 'superior' in every way Toyota corolla!

PS Get on CR to upgrade their evaluation of the corolla, that is such a letdown that they recommend the Impreza over your wondercar

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Old 06-12-2013, 01:53 PM   #415
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Actually, you need to re-read my post. You need to remember where I am coming from professionally. If that's left field, you have a long road with many lessons to learn.
Actually, you need to re-read my posts. I never said anything about a "class action suit" or anything like that. So yes, Zeeper coaxed you out into left field.
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Old 06-12-2013, 03:38 PM   #416
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Actually, you need to re-read my posts. I never said anything about a "class action suit" or anything like that. So yes, Zeeper coaxed you out into left field.
Nope, stevhnm is correct.

He is not contacting the EPA to tell them that he thinks Subaru gamed the mpg testing for all of the 2012 and 2013 Impreza's equipped with CVT's, so he is not pretending to represent other impreza drivers, only his car and the other one driven by the professional driver at Consumer Reports.

Stevehnm, be sure to write the EPA back, and tell them that, because that will surely make them want to move your complaint to the top of the pile, so they can act on it post haste!

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Old 06-12-2013, 10:38 PM   #417
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Actually, you need to re-read my posts. I never said anything about a "class action suit" or anything like that. So yes, Zeeper coaxed you out into left field.
Da** you Zeeper- you threw me off 5 or 6 deviations.

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Old 06-13-2013, 01:47 AM   #418
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You mean like above 2000 rpm? My CVT is over 2000 rpm on the flat at the speed limit. Even paddled in 5th gear it won't climb as well as my other identically rated car in high gear.
MPG's really suffer over 3000 RPM. But as you know, you won't get 36 mpg up there or even at 2000 or 2500 rpm, it's only possible below 2000. At 55mph (max posted speed limit on a non-interstate around here), I'm under 2000 rpm, and hence can get the magic 36 (or better). Dunno what the speed limit is on the desert 2 lanes in NM, but one has to look at the test methodology to realize that 65, 70, or 75 is not the speed represented in the test to get that highway number.

Simply put, while the Corolla may have a wider band where the MPG's meet or exceed the sticker (and as a former Corolla owner, I'm familiar with getting better MPG's at 70 than at 55), the Impreza has a much more narrower band. Be it the CVT, the AWD, the flat 4, or a combination of other factors that have yet to be figured out, Subaru built a car that does well under the EPA testing, and perhaps not so well under what some folks (like you) consider average daily highway driving. Call it what you want, say they gamed it, but they built a car that when driven reasonably, performs as advertised. And considering what the previous generation of the Impreza did, mileage wise, it's a heck of an improvement, even moreso when you take the factor of the traditional AWD drain on MPG's that had existed. When you take the entire package of pros and cons of this car (yeah, it's not perfect, but nothing really is perfect), it's not such a bad car. Perhaps for you, the Impreza doesn't do what you want it to do, but most owners I've talked to are pleased with what the car does for them.

I think this is a case where I (and a lot of others here) are going to agree to disagree with you. Preach away, but you're preaching to the choir, it would appear.

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Old 06-13-2013, 02:02 AM   #419
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In this month's Subaru's Drive Magazine, PZEV is explained.
For the explanation, one can infer that PZEV Subaru will do worse in mpg than regular Subaru.
I bet Subaru only test the non-PZEV impreza for EPA.

Check it out for your self:
http://drive.subaru.com/spr13_WhatMakes.aspx

Interesting section:
"The catalytic converter for a PZEV engine has a finer mesh and higher volume of precious metals – platinum, palladium, and rhodium – than the standard converter, as well as twice the effective cleaning surface. This improves the converter’s performance as it reduces gases in the exhaust exiting the tailpipe.
In addition, the revised ECM programming delays ignition timing, which helps the catalytic converter heat up to operating temperatures sooner, thereby reducing cold-start emissions."

The finer mesh in catalytic converter must be more restrictive, and make the engine weaker.

The different ECM programming "retards timing" this definately hurts mpg. Timing needs to be advanced as far as possible to improve mpg. I bet the PZEV is set to have higher catalytic converter target also, to drastically control emission. This prolongs the warm up period compared to other cars.

Aside from the PZEV mpg tax, CVT models has additional deficiency. Subaru put in a weaker CVT and to protect it, the torque converter is not allowed to lock until it fully warms up. This makes the car extremely inefficient before full warm up both from engine and CVT.

I would say the PZEV aspect should be explored if anyone wants to sue Subaru for the lack of mpg.
This is a good post- what's the cost of cleaner emissions? Could be the mpg's we are all looking for, which helps reduce emissions vs less mpg cars with bigger engines hence more emissions. Kinda like a cat chasing its tail.
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Old 06-13-2013, 08:08 AM   #420
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This is a good post- what's the cost of cleaner emissions? Could be the mpg's we are all looking for, which helps reduce emissions vs less mpg cars with bigger engines hence more emissions. Kinda like a cat chasing its tail.
Subaru may be ahead of the curve in only producing PZEV Impreza's, but it is only a matter of time until all manufacturers need to meet the same emissions requirements.

So while it might be possible that eliminating emissions requirements for all vehicles could save gas, it isn't an option.

36mpg highway isn't too shabby for any vehicle, the impreza can meet that with the best emissions equipment installed when driven in the manner in which it was tested.
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Old 06-13-2013, 08:52 AM   #421
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MPG's really suffer over 3000 RPM. But as you know, you won't get 36 mpg up there or even at 2000 or 2500 rpm, it's only possible below 2000. At 55mph (max posted speed limit on a non-interstate around here), I'm under 2000 rpm, and hence can get the magic 36 (or better). Dunno what the speed limit is on the desert 2 lanes in NM, but one has to look at the test methodology to realize that 65, 70, or 75 is not the speed represented in the test to get that highway number.
The EPA numbers aren't taken while really driving. They put together an artificial formulation including fuel usage at power levels and what power levels it takes to drive the car at a variety of speeds including wind resistance, driveline resistance, etc. that they have measured separately and calculate what it will get in the real world. Under those conditions the exact power required is known and the engine can be tuned for efficiency at the most used power levels in the tests.

The big thing is that the window sticker says "for comparison only". What does that mean? It means that under the same conditions different cars with the same rating will get the same mpg.

They do, actually. Mostly. The CR test is a real world test, as is the mpgomatic test. I haven't looked into the mpgomatic tests like the CR tests, mostly because the CR test results are easy to extract so I looked at all of the vehicles CR tested that got the same highway mpg on their test, and discovered that "for comparison purposes" like the sticker said it was true. Except for the Impreza. The Impreza is not consistent in terms of "for comparison purposes". Look at the first post in this thread for details.

A random sampling of mpgomatic vehicles shows pretty much the same thing. You can't just quote them on one vehicle, you have to look at the comparisons. Your mileage may vary but the pros are pretty consistent.

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Old 06-13-2013, 09:15 AM   #422
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sounds like the impreza is an exception to the test. i don't know that that is necessarily subaru's fault. they didn't design the test.
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Old 06-13-2013, 09:48 AM   #423
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The EPA mandated window sticker (2013+) also has this printed on it: "Actual results will vary for many reasons, including driving conditions and how you drive and maintain your vehicle."

The 2012 Window Sticker has slightly different language saying the same thing...

One might conjecture that the CVT/5 Speed owners who are achieving the EPA numbers are driving their car in a way that allows them to obtain the EPA tested numbers, and those who are getting horrible mpg's are driving them in another way, under different conditions, causing their mileage to suffer.

Nah, that wouldn't be a scientific explanation at all, everyone knows that there is no such thing as driver variability!

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Old 06-13-2013, 04:14 PM   #424
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The EPA mandated window sticker (2013+) also has this printed on it: "Actual results will vary for many reasons, including driving conditions and how you drive and maintain your vehicle."

The 2012 Window Sticker has slightly different language saying the same thing...

One might conjecture that the CVT/5 Speed owners who are achieving the EPA numbers are driving their car in a way that allows them to obtain the EPA tested numbers, and those who are getting horrible mpg's are driving them in another way, under different conditions, causing their mileage to suffer.

Nah, that wouldn't be a scientific explanation at all, everyone knows that there is no such thing as driver variability!
I think the major complaint is that other vehicles don't seem to suffer from this driver variable nearly as much. It certainly seems like the case anyway. On my wife's car I can get pretty close to the stated MPGs without having to make an effort. with the impreza I def have to pay more attention to my driving to get close to the estimated numbers. they are def in the realm of possibility but it takes a much more careful driver to get them.
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Old 06-13-2013, 04:36 PM   #425
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Complaining to the EPA that some drivers cannot get the estimated MPG's, while others can, is a lost cause, because those numbers are estimates, not guarantees, and subject to the driver and the type of driving being done.

Many people on the forum are getting the EPA numbers, so the complaint is that some drivers do not? Good luck with that.

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