Greenhouse Gas Emission Standards for
Light-Duty Automobiles:
Status of Early Credit Program for
Model Years 2009-2011
&EPA
United States
Environmental Protection
Agency
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Greenhouse Gas Emission Standards for
Light-Duty Automobiles:
Status of Early Credit Program for
Model Years 2009-2011
Compliance Division
Office of Transportation and Air Quality
U.S. Environmental Protection Agency
NOTICE
This technical report does not necessarily represent final EPA decisions or
positions. It is intended to present technical analysis of issues using data
that are currently available. The purpose in the release of such reports is to
facilitate the exchange of technical information and to inform the public of
technical developments.
United States
Environmental Protection
Agency
EPA-420-R-13-005
March 2013
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Executive Summary
On May 7, 2010, the Environmental Protection Agency (EPA) published a final regulation that
laid out the first-ever national greenhouse gas (GHG) emissions standards under the Clean Air
Act.l The standards in this first regulation, which apply to light-duty vehicles, light-duty trucks,
and medium-duty passenger vehicles, cover the 2012 through 2016 model years. Subsequently,
on October 15, 2012, EPA published regulations that will require auto manufacturers to achieve
additional GHG emissions reductions in the 2017 through 2025 model years.2 These rules were
established jointly with the National Highway Traffic Safety Administration (NHTSA), which
established parallel standards for Corporate Average Fuel Economy (CAFE). Collectively the
EPA GHG standards and NHTSA CAFE standards are known as the National Program.
EPA's GHG program, which will now progressively lower the average new vehicle GHG
emissions in each model year from 2012 through 2025, includes a number of flexibilities
designed to provide sufficient lead time for manufacturers to make technological improvements
and to reduce the overall cost of the program, without compromising overall environmental
objectives. One of these flexibilities is an optional program that allows manufacturers with
superior greenhouse gas emission reduction performance to generate early credits in the 2009-
2011 model years. The early credits program provided a valuable incentive for manufacturers
that have implemented GHG-reducing technologies in excess of either the CAFE or California
GHG standards prior to the 2012 model year. These early credits represent surplus reductions
that were not otherwise required by law, and will allow manufacturers to more effectively
transition to the increasingly stringent GHG standards. EPA's early credits program is also an
important example of how the GHG and CAFE programs were aligned to achieve a coordinated
National Program.3
Early credits may be earned through fleet average carbon dioxide (CO2) reductions,
improvements to air conditioning systems that reduce refrigerant leakage or improve system
efficiency, introduction of advanced technology vehicles (i.e., electric, fuel cell, and plug-in
hybrid electric vehicles), and implementation of technologies that reduce CO2 emissions over
driving conditions not captured by the test procedures used for compliance with the CO2
standards (i.e., "off-cycle" reductions).
Manufacturers that chose to participate in the early credits program submitted documentation in
early 2012, as required under the regulations. Seventeen manufacturers chose to participate in
one or more elements of the early credits program, reporting some 209 million metric tons of
CO2 credits over the three model years covered by the program.4 Some companies qualified for
the full range of types of early credits allowed, while others only reported fleet average based
1 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final
Rule, Federal Register 75 (7 May 2010): 25324-25728.
2 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy
Standards, Final Rule, Federal Register 77 (15 October 2012): 62624-63200.
3 Under the CAFE program, manufacturers that have been outperforming the CAFE standards in the same time
period will be approaching the increasingly stringent CAFE standards with credits accumulated in the same model
years as the early GHG credits program.
4 In this report, credits are expressed in the identical units of metric tons or Megagrams (Mg). 1,000,000 grams =
1,000 kilograms = 1 Megagram = 1 metric ton.
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credits or air conditioning credits. As expected, and consistent with the intent of the early credits
program, sixteen manufacturers reported generating credits through fleet average reductions,
which accounts for most of the early credits reported by the industry (180.2 million metric tons).
Ten manufacturers reported credits resulting from improvements to the efficiency of air
conditioning systems (8.1 million metric tons), and nine reported credits for air conditioning
systems with low refrigerant leakage technology (20.8 million metric tons). One manufacturer
provided details describing early off-cycle credits (5,632 metric tons).
This report summarizes and explains the credits reported by each manufacturer in the 2009-2011
model years, as well as explaining the options for earning and using early credits. This report is
also intended to be used as a reference for users of the early credits data, which we are making
available in formats appropriate for importing into spreadsheets or database applications.5 EPA
is neither making any assumptions regarding the potential disposition of these 209 million metric
tons of early GHG credits nor attempting to speculate at this time on how manufacturers will
choose to use these accumulated early credits over the applicable credit lifetimes. However, we
believe that most manufacturers will be taking a long-term view by using their accumulated
credits judiciously to plan a smooth pathway to the increasingly stringent GHG emission
standards in the future. Table 1 shows the total early credits reported by the industry, broken
down by the type of credit.
A comprehensive description of the EPA GHG program is beyond the scope of this document,
thus readers should consult the regulatory announcements and associated technical documents
for a detailed description of the program. See http://www.epa.gov/otaq/climate/regs-light-
duty.htm.
TABLE 1. TOTAL REPORTED EARLY CREDITS, BY
TYPE OF CREDIT
Credit Type
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Total
Credits
(Mg)
180.179.993
20,834,078
8,136,185
5,632
209,155,888
Percent of
Total (%)
86.15
9.96
3.89
0.00
100.00
5 This report and the data upon which it is based can be found and downloaded at http://www.epa.gov/otaq/regs/ld-
hwy/greenhouse/ld-ghg. htm.
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I. Introduction
A. Why are we releasing this information?
EPA is releasing this report as part of our commitment to provide the public with transparent and
timely information about manufacturers' compliance with the GHG program. In the two EPA
regulations that established the greenhouse gas emissions standards for light-duty vehicles, we
committed to making certain information public regarding the compliance of automobile
manufacturers with the program. At the same time, we committed to maintaining our practice of
strongly safeguarding confidential business information, as required by regulation.6
When we issued the proposed rule for the 2012-2016 model year standards, we received
considerable comment about the need for transparency regarding implementation of the program,
and specifically, regarding our compliance determinations.7 Many comments emphasized the
importance of making greenhouse gas compliance information publicly available to ensure such
transparency. In the preamble to the final regulation, we noted that our public release of data
could include ".. .GHG performance and compliance trends information, such as annual status of
credit balances or debits, use of various credit programs, attained fleet average emission levels
compared with standards, and final compliance status for a model year after credit reconciliation
occurs." We further noted that we would ".. .reassess data release needs and opportunities once
the program is underway."8
As was the case with the 2012-2016 model year rule, the proposal for 2017-2025 model year
GHG standards received a number of comments again stressing the need for transparency in the
implementation of the GHG standards.9 Our response in the final rule indicated our continued
commitment to the principle of transparency and to disseminating as much information as we are
reasonably, practically, and legally able to provide.10 We noted that we already release a
considerable amount of information regarding fuel economy, emissions, and vehicle
characteristics for each vehicle model. For example, starting with the 2013 model year, the
downloadable data available at www.fueleconomy.gov includes CC>2 emission values for each
vehicle model. In addition, actual test results are released by EPA at
http://www.epa.gov/otaq/tcldata.htm. We also stated our commitment to further expanding the
information we release regarding GHG program compliance, noting in the preamble to the model
year 2017-2025 final rule that".. .EPA intends to publish the applicable fleet average standards
(for cars and for trucks) and the actual fleet performance for each manufacturer, and the resulting
credits or debits." Further, we stated that we anticipate publishing ".. .the amount of credits
generated by each manufacturer (separately for each of the car and truck fleets) under the
optional credit programs, and the associated volumes of vehicles to which those credits apply."
6 See 40 CFR Part 2, Subpart B, Confidentiality of Business Information.
7 Proposed Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate
Average Fuel Economy Standards, Proposed Rule, Federal Register 74 (28 September 2009): 49454-49789.
8
Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final
Rule, Federal Register 75 (7 May 2010): 25469.
2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy
Standards, Proposed Rule, Federal Register 76 (1 December 201 1): 74854-75420.
9
10
2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel
Economy Standards, Final Rule, Federal Register 77 (15 October 2012): 62889.
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We also suggested that we would likely publish credit transactions, as well as the overall credit
or debit balance for each manufacturer after taking into account the credit and debit carry-
forward provisions and any credit transactions.
Finally, we noted in the model year 2017-2025 final rule preamble that our first public release
would likely be a summary of the 2009-2011 early credits reported by manufacturers.
Subsequent reports will likely be more comprehensive because all manufacturers are required to
submit data and compliance requirements begin to take effect. We expect that our data
publication will evolve over time, as the program progresses and as we gather feedback about
our reporting from stakeholders, and as our data systems and those of manufacturers make
necessary adaptations to the new requirements. Manufacturers must submit final compliance
reports regarding the 2012 model year in March of 2013. Later in 2013, after we complete a
thorough review of the documentation and calculations received from manufacturers, we expect
to publish data for the 2012 model year.
B. What data are we publishing?
The EPA GHG program, which requires compliance with progressively more stringent GHG
standards starting with the 2012 model year and concluding with the 2025 model year, includes
certain flexibilities designed to provide sufficient lead time for manufacturers to make
technological improvements and to reduce the overall cost of the program, without
compromising overall environmental objectives. One of these flexibilities is an optional program
that allowed manufacturers with superior greenhouse gas emission reduction performance to
generate credits in the 2009-2011 model years, prior to the 2012 model year (the "early credits
program"). Because this is an optional program, without any compliance implications in these
early model years, only those manufacturers who achieved emissions performance beyond that
required by existing California or CAFE standards chose to provide data; thus the data does not
include information for all manufacturers. The first opportunity to review data from all
manufacturers will be later in the 2013 calendar year, when we receive compliance reports for
the 2012 model year. While there are factors that could lead to revisions to the early credits data
(e.g., future credit transactions between manufacturers), the data presented in this report is
believed to be stable as of the date of publication. Any changes, should they occur, will be
reflected in updates to the downloadable data and in subsequent EPA reports.
This report will give a broad overview of the optional early credits program to facilitate an
understanding of the early credits data that we are releasing. However, the early credits program
is complex, with many regulatory nuances, and readers are encouraged to consult the regulations
for detailed and specific information.u
Early credits may be earned through fleet average CC>2 reductions, improvements to air
conditioning systems that reduce refrigerant leakage or improve system efficiency, off-cycle
credits for the implementation of technologies that reduce CC>2 emissions over driving conditions
not captured by the test procedures used to show compliance with the CO2 standards, and
introduction of advanced technology vehicles (i.e., electric, fuel cell, and plug-in hybrid electric
11 See 40 CFR 86.1871-12.
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vehicles). The most complex aspect of the optional early credits program is the multiplicity of
"pathways" that a manufacturer may select to earn credits based on their corporate fleet average
tailpipe CO2 emissions performance. The program has four pathways that provide opportunities
for early credit generation through over-compliance with a fleet average CC>2 level specified by
EPA in the regulations. Since EPA's GHG standards do not begin until model year 2012, EPA
established fleet average thresholds below which manufacturers could generate early fleet
average credits. Manufacturers wishing to earn early credits must select one of these four
pathways, and the selected pathway must be followed for the three model years of 2009-2011.
For two of the pathways, the emission levels below which credits are available are equivalent to
the GHG standards established by California prior to the adoption of the EPA GHG program.
Two additional pathways include credits based on over-compliance with CO2 levels equivalent to
the CAFE standards in states that did not adopt the California GHG standards. These four
1 9
pathways are described in more detail in section II.
C. How many early credits were reported?
Table 2 summarizes the credits (or deficits) reported by manufacturers in each of the three model
years for each participating manufacturer. Credits are expressed in units of metric tons, or
Megagrams (Mg). The early credits program requires that participating manufacturers determine
fleet average credits for each of the three model years under their selected pathway, and that they
may carry forward their net credits from the three early years to apply to compliance with EPA's
GHG standards. Thus, even manufacturers with a deficit in one or more of the early model years,
(i.e., their fleet average performance was worse than the applicable emissions threshold under the
selected pathway) could benefit from the early credits program if their net credits over the three
years is a positive value. Manufacturers not listed in Table 1 have thus far elected not to
participate in the early credits program. Due to the ongoing investigation of the emissions and
fuel economy testing methods of Hyundai and Kia, the outcome of which could impact the
credits accrued by these companies, credit values for Hyundai and Kia are not being reported.
They will appear in future reports after the conclusion of the investigation.
12 The California GHG standards and CAFE MPG standards included provisions for model years 2009-2011
allowing credits to be carried forward to later model years. By adopting early credit provisions under the GHG
program, EPA maintained some level of consistency with these pre-existing programs.
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TABLE 2. EARLY GHG CREDITS REPORTED BY MODEL YEAR AND
MANUFACTURER (Me)
Manufacturer
BMW
Chrysler
Daimler
Ford
GM
Honda
Mazda
Mitsubishi
Nissan
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Industry Total
Model Year
2009
409,854
5,583,013
96,467
8,252,113
13,009,374
14,073,890
1,405,721
625,166
10,496,712
1,620,769
448,408
31,325,738
2,243,205
119,583
89,710,013
2010
280,450
4,337,613
124,120
7,093,702
11,073,134
14,070,290
3,201,708
521,776
5,781,739
2,225,296
329,382
35,580
34,457,797
2,811,663
237,398
86,581,648
2011
194,599
(2,129,654)
157,685
(49,379)
493,068
7,370,928
875,213
302,394
1,852,749
1,909,106
98,860
14,192
20,322,300
1,386,537
65,629
32,864,227
Total
884,903
7,790,972
378,272
15,296,436
24,575,576
35,515,108
5,482,642
1,449,336
18,131,200
5,755,171
876,650
49,772
86,105,835
6,441,405
422,610
209,155,888
D. How can these credits be used?
The ability to earn and bank credits, including early credits, is a fundamental aspect of the
program design intended to assist manufacturers in meeting the 2012-2016 model year standards,
as well as to aid in the transition to the progressively more stringent standards in the 2017-2025
model years. In establishing the early credits program, EPA wanted to maintain consistency with
the ability to generate and carry forward credits under both the CAFE standards and the
California standards for the 2009-2011 model years. These credits represent surplus emission
reductions that manufacturers achieved in addition to those required by law under either the
California or CAFE standards. The early credits program gives manufacturers additional
flexibility to transition into the 2012 and later GHG standards with a bank of credits available.
Credit banking, as well as emissions averaging and credit trading (collectively termed
Averaging, Banking, and Trading, or "ABT") have been an important part of many mobile
source programs under the Clean Air Act. These programs help manufacturers in planning and
implementing the orderly phase-in of emissions control technology in their production,
consistent with their typical redesign schedules. These provisions are an integral part of the
standard-setting itself, and not just an add-on to help reduce costs. In many cases, ABT programs
address issues of cost or technical feasibility which might otherwise arise, allowing EPA to set a
standard that is more stringent than could be achieved without the flexibility provided by ABT
programs. We believe that the net effect of the ABT provisions, including the early credits,
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allows additional flexibility, encourages earlier penetration of emission reduction technologies
than might otherwise occur, and does so without reducing the overall effectiveness of the
program.
Credits (or deficits) are calculated separately for cars and trucks. If a manufacturer has a net
deficit in either the car or truck category, existing credits must be applied towards that deficit.
Although a deficit may be carried forward up to three years, under no circumstances is a
manufacturer allowed to carry forward a deficit if they have credits available with which to
offset the deficit. If credits remain after addressing any deficits, those credits may be "banked"
for use in a future year, or sold or otherwise transferred to another manufacturer. Credits earned
in the 2010 through 2016 model years may be carried forward and used through the 2021 model
year. Credits from the 2009 model year and 2017 and later model years may only be carried
forward for five years. Thus, any early credits from the 2009 model year that remain after the
2014 model year will expire. In addition, credits from the 2009 model year may only be used
within a manufacturer's fleet, and may not be traded to another manufacturer. These restrictions
for the 2009 model year were established based on concerns that such credits might provide a
"windfall" since the California light truck standards are less stringent than the comparable CAFE
standards in effect for that model year.
At this point it is difficult to make any assumptions regarding the disposition of these 209 million
tons of reported early GHG credits. One could create any number of hypothetical scenarios that
show these credits being used in a variety of ways (e.g., across the industry, within a single
company, across all model years of the program, within a single model year, within or between
car and truck fleets, etc.). EPA is not attempting to speculate at this time on how manufacturers
will choose to use these reported credits over the applicable credit lifetimes. However, we
continue to believe that most manufacturers will be taking a long-term view of the increasingly
stringent standards in the future and will use their accumulated credits judiciously to plan a
smooth pathway to the low emissions required through the 2025 model year. We do not expect
manufacturers to use these credits injudiciously, e.g., to make short-term adjustments to shift
their fleet to less efficient vehicles or to broadly delay the introduction of technologies, as doing
so could jeopardize long-term compliance and increase the risk effacing future enforcement
actions. We plan to make data on the use of credits, including credit trades among manufacturers,
available in future credit reports.
However, one easy translation to make is to determine what a given exceedance of an emission
standard "costs" in terms of tons of credits. The calculation of fleet average credits (described in
more detail in the next section) is the same for cars and trucks with the exception that the
expected lifetime mileage (vehicle miles traveled, or VMT) differs between cars and trucks.
Because trucks are assumed to have a greater lifetime VMT (225,865 miles) than cars (195,264
miles), a given gram per mile of "non-compliance" in a truck fleet will require more credits (in
tons) to offset. Given these VMT differences, one car that is one gram per mile above the
standard will cost 0.195 metric tons of credits to offset, and similarly, for a single truck that is
one gram non-compliant the cost is 0.226 metric tons. For rough calculations, however, it makes
sense to assume that for cars and trucks, one gram per mile costs about 0.2 metric tons to offset
(or 5 grams per mile non-compliance costs about 1 metric ton). For example, a manufacturer
with a fleet average that is 5 grams/mile above its fleet average standard and that produced 1
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million vehicles in that model year will need about one million metric tons of credit to offset the
deficit created by the noncompliant fleet.
II. Credits Based on Early Fleet Average COz Reductions
Fleet average GHG credits are based on the difference between the applicable emission standard
and the actual fleet performance (in grams per mile), the expected lifetime miles (vehicle miles
traveled, or VMT) of a vehicle, and the total vehicle production volume. The VMT used in this
calculation for passenger cars is 195,264 miles, and for trucks is 225,865 miles. The equation
that generates the metric tons (or Megagrams, Mg) of credits for a given fleet is as follows:
(Standard — Fleet Average) x VMT x Production Volume
Credits (metric tons) =
1,000,000
As described earlier, there are four distinct pathways that manufacturers may select from to earn
early fleet average credits, two of which base credits on the effective California standards, and
the remaining two which include credits based on compliance with the CAFE standards in states
that have not adopted the California standards. Table 3 summarizes the credits reported by
manufacturers under each of the four available pathways. Because these pathways imply slightly
different data and information reporting, we are summarizing the fleet average credits separately
according to the selected pathway. Readers should refer to the Appendix and to the
downloadable data for the complete detailed values underlying the fleet average credits, such as
the applicable emission credit threshold levels and the manufacturer's reported fleet average
performance. Manufacturers reported a total of 180,179,993 metric tons of CC>2, or 86% of all
the early reported credits, based on fleet average CO2 emission reductions (see Table 1). Because
these manufacturers were known to be outperforming either the California or CAFE standards in
the 2009-2011 model years, EPA anticipated that these manufacturers would generate early
credits, and, in some cases, substantial numbers of credits. Although the fleet targets under each
pathway differ slightly, note that they increase in stringency rapidly. See, for example, Table 4,
which shows a reduction in the fleet targets of 56 grams/mile for cars and 49 grams/mile for
trucks from 2009 to 2011. Most manufacturers exhibit a substantial drop in credit accumulation
from 2009 to 2011 (in some cases transit!oning to generating a deficit rather than credits),
indicating that the technological progress of these manufacturers, over these model years, was
being outpaced by the stringency of the emission targets. We expect that this trend will continue
for several model years, and that these companies will use the early credits as they bring new
technologies on line to meet the tight emission standards of future model years. For those
companies with the greatest number of credits, the concerns regarding the potential for
"windfall" credits from the 2009 model year are mitigated by the fact that those credits will
likely expire before those companies can make use of them (and no other company may benefit,
because those credits may not be traded).
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TABLE 3. REPORTED EARLY FLEET AVERAGE CREDITS, BY EARLY
CREDIT PATHWAY
Pathway
1
2
3
4
Total
Credits (Mg)
134,258,207
0
45,547,983
373,803
180,179,993
Percent of Total (%)
74.51
0.00
25.28
0.21
100.00
A. Credits Reported By Manufacturers Using Pathway 1
Pathway 1 requires that credits be measured over the manufacturer's nationwide fleet, with
credits based on fleet performance relative to the California standards in effect at the time. The
California standards effective in the 2009-2011 model years are not based on footprint, but are
"flat" universal standards that all manufacturers were required to meet. Also note that under this
pathway the vehicle categories subject to the thresholds in Table 4 are those defined in the
California regulations. These categories are subtly different from those used in the EPA GHG
program in the 2012 and later model years; readers should refer to the California and EPA GHG
program regulations for the precise definitions.
13
The ten manufacturers selecting Pathway 1 reported generating credits against the California-
equivalent emission standards shown in Table 4.
For EPA definitions, see the Code of Federal Regulations, 40 CFR 86.1803-01. For California definitions, see the
California Code of Regulations, 13 CCR 1900.
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TABLE 4. CALIFORNIA EQUIVALENT EMISSION STANDARDS BY MODEL YEAR AND
VEHICLE CATEGORY (GRAMS/MILE)
Model year
2009
2010
2011
Passenger cars and light trucks
with LVW1 of 0-3,750 Ibs
323
301
267
Light trucks with LVW1
>3,750 Ibs and a GVWR2 up
to 8,500 Ibs, and MDPVs3
439
420
390
LVW is "loaded vehicle weight," defined by regulation as the measured curb weight of the vehicle
plus 300 Ibs.
2
GVWR is "gross vehicle weight rating," which is the maximum load capacity specified by the
manufacturer.
3
MDPV is "medium-duty passenger vehicle," a category that covers passenger vehicles from 8,500-
10,000 Ibs GVWR (i.e., sport utility vehicles and vans).
Table 5 shows the early fleet average credits reported by manufacturers using Pathway 1. As can
be seen, all of these manufacturers reported net credits over the three model years (this is by
definition; if they could not earn net credits under this pathway they would either select a
different pathway or not participate in the early credits program), despite some reporting a deficit
in some model years and vehicle categories. Note that because of concerns expressed by some
stakeholders during the regulatory process that there may be a potential for a large number of
credits under Pathway 1 in the 2009 model year, the regulations included two restrictions. First,
2009 model year credits earned under this pathway may not be sold to another manufacturer, and
second, these credits may be carried forward only five years, to the 2014 model year, after which
they expire. As noted earlier, credits from 2010 and 2011 may be carried forward to the 2021
model year.
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TABLE 5. EARLY FLEET AVERAGE CREDITS REPORTED BY MANUFACTURERS USING PATHWAY 1
Manufacturer
Chrysler
Ford
GM
Nissan
Subaru
Suzuki
Tesla
Toyota
Volvo
Fleet
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Car
Truck
Car
Truck
Total
Model Year
2009
Production
Volume
287,364
528,286
508,727
504,921
1,048,593
844,892
605,439
234,883
156,871
43,945
24,859
10,146
1,273,815
482,202
31,618
11,420
6,597,981
Credits
(MR)
224,447
4,414,889
2,384,066
4,789,847
5,733,069
4,961,620
6,502,124
3,554,474
459,469
1,161,300
232,995
215,413
19,400,957
10,237,780
37,043
82,540
64,392,033
2010
Productio
n Volume
430,110
729,662
856,065
965,968
857,825
932,358
617,548
236,588
183,763
74,489
20,212
8,728
599
1,412,172
793,226
23,529
34,413
8,177,255
Credits
(MR)
(1,259,775)
4,284,933
2,005,904
3,054,497
502,507
8,002,308
4,220,471
1,122,176
71,765
2,153,531
165,760
163,622
35,206
20,129,484
12,003,853
(73,510)
310,908
56,893,640
2011
Productio
n Volume
335,790
739,487
792,654
873,635
1,006,900
1,419,043
666,660
299,074
176,923
129,950
19,390
7,864
269
1,140,255
834,019
24,846
27,761
8,494,520
Credits (Mg)
(2,753,843)
(1,002,145)
(2,476,429)
591,971
(5,701,728)
2,564,097
781,048
540,403
(967,307)
2,876,413
18,931
79,929
14,024
5,343,618
12,997,923
(160,100)
225,729
12,972,534
B. Credits Reported By Manufacturers Using Pathway 2
Pathway 2 is identical to Pathway 1 with the exception that the credits are calculated not for a
nationwide fleet, but for the manufacturer's fleet only in California and the states that have
adopted the California standards under Section 177 of the Clean Air Act (these states are referred
to as the "Section 177 states").14 Pathway 2 was not used by any manufacturer, presumably
because manufacturers that were able to meet the California standards in California and the
Section 177 states found that they could also earn credits in the remainder of the states. In other
words, no manufacturer found an advantage to excluding the states outside California and the
Section 177 states from their credit calculations.
As of the date the regulation was finalized, there were thirteen states that had adopted the California greenhouse
gas emission standards: Arizona, Connecticut, Maine, Maryland, Massachusetts, New Jersey, New Mexico, New
York, Oregon, Pennsylvania, Rhode Island, Vermont, Washington, and Washington, DC.
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C. Credits Reported By Manufacturers Using Pathway 3
Pathway 3 allows manufacturers to earn credits as under Pathway 2 (the California standards
applied to the fleet of vehicles in California and the Section 177 states), plus additional credits
that may be earned in the remaining states against threshold levels that are based on a translation
of the CAFE MPG standards to GHG grams per mile threshold levels. The emission threshold
levels used for generating credits in the states outside California and the Section 177 states under
Pathway 3 are shown in Table 6 below.
TABLE 6. CAFE-EQUIVALENT EMISSION STANDARDS BY MODEL YEAR AND
VEHICLE CATEGORY (GRAMS/MILE)
Model year
2009
2010
2011
Passenger Automobiles
323
323
Footprint-based standard
Light Trucks
381*
376*
Footprint-based standard
* Manufacturers that optionally used a footprint-based standard must use that standard.
These threshold levels are based on the CAFE standards that were in effect in the 2009-2011
model years. In the 2009 and 2010 model years manufacturers could optionally calculate a
manufacturer-specific CAFE standard for their light truck fleet, and starting in the 2011 model
year, footprint-based CAFE standards became mandatory both for cars and trucks. Thus, for the
purposes of generating early light truck credits, manufacturers using the footprint-based option in
the 2009 and 2010 model years must determine a manufacturer-specific, footprint-based CC>2
threshold level to use in lieu of the numerical values shown in the table above. In the 2011
model year the early credits must be generated using a footprint-based CC>2 threshold level. The
specific emission levels actually used and reported by each manufacturer are included in the
detailed table in the Appendix and in the downloadable data. Credits are generated under this
pathway using the car and truck definitions that apply to the CAFE program that are in place for
the model year in which credits are being generated. This adds an additional layer of complexity
for two reasons: (1) these definitions were revised by NHTSA such that they change starting in
the 2011 model year, and (2) medium-duty passenger vehicles (MDPVs) are not part of the
CAFE program until the 2011 model year, and therefore are not part of the early credits
calculations for 2009 and 2010 under Pathway 3.
Table 7 shows the credits reported by the five manufacturers that used Pathway 3. The credits are
shown for each vehicle category within each of the separate regions required under this pathway.
The credits reported in the 2009 model year are subject to the same restrictions as under Pathway
1, i.e., they may not be sold and they have a limited life relative to the 2010 and 2011 credits.
10
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TABLE 7. EARLY FLEET AVERAGE CREDITS REPORTED BY MANUFACTURERS USING PATHWAY 3
Manufacturer
Honda
Mazda
Mitsubishi
Volkswagen
Region
NC
CA/177
NC
CA/177
NC
CA/177
NC
CA/177
Fleet
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Grand Total
Model Year
2009
Production
Volume
433,183
232,149
388,318
89,079
61,283
35,084
40,884
10,612
60,347
8,573
23,293
872
139,498
21,078
118,411
13,295
1,675,959
Credits
(Mg)
5,582,613
2,202,242
4,321,998
1,327,909
514,554
412,061
335,293
143,813
341,724
114,244
150,093
19,105
898,885
85,694
693,642
171,164
17,315,034
2010
Production
Volume
414,562
290,216
429,692
95,106
133,292
64,558
86,948
25,351
30,144
14,832
15,733
2,699
143,295
23,488
134,231
19,350
1,923,497
Credits
(Mg)
5,828,330
3,080,833
3,272,232
1,159,980
1,561,628
685,325
611,201
343,554
270,758
177,552
39,937
33,529
1,371,037
106,102
629,052
257,859
19,428,909
2011
Production
Volume
317,065
280,042
247,437
244,121
112,883
18,435
59,856
25,145
49,447
15,159
25,408
7,712
151,373
35,176
121,114
25,667
1,736,040
Credits
(Mg)
2,290,721
569,265
821,364
3,032,611
506,966
(49,966)
128,565
289,648
212,415
34,239
0
55,740
650,269
79,450
(141,895)
324,648
8,804,040
Notes: CA/177 = The region comprised of California and the Section 177 states. NC = The region comprised of the states
outside California and the Section 177 states.
D. Credits Reported By Manufacturers Using Pathway 4
Pathway 4, which was used by only one manufacturer, is for manufacturers choosing to forego
California-based credits entirely and earn only CAFE-based credits outside California and the
Section 177 states. Credits are earned under this pathway against the thresholds described in
Table 6 and the previous section. Table 8 shows the early credits reported by BMW, the sole
manufacturer that chose to use Pathway 4.
11
-------
TABLE 8. EARLY FLEET AVERAGE CREDITS REPORTED BY MANUFACTURERS USING PATHWAY 4
Manufacturer
BMW
Fleet
Car
Truck
Total
Model Year
2009
Production
Volume
95,270
16,978
112,248
Credits
(MR)
316,248
(49,852)
266,396
2010
Production
Volume
72,225
13,612
85,837
Credits
(MR)
197,441
(24,596)
172,845
2011
Production
Volume
153,966
31,323
185,289
Credits (Mg)
(30,064)
(35,374)
(65,438)
III. Credits Based on Improvements to Air Conditioning Systems
Over 95% of the new cars and light trucks in the United States are equipped with air
conditioning (A/C) systems. There are two mechanisms by which A/C systems contribute to the
emissions of greenhouse gases: through leakage of hydrofluorocarbon refrigerants into the
atmosphere (sometimes called "direct emissions") and through the consumption of fuel to
provide mechanical power to the A/C system (sometimes called "indirect emissions"). The high
global warming potential of the current automotive refrigerant means that leakage of a small
amount of refrigerant will have a far greater global warming impact than emissions of a similar
amount of CC>2. Refrigerant leakage can be reduced significantly by systems that incorporate
leak-tight components, or, ultimately, by using a refrigerant with a lower global warming
potential. The A/C system also contributes to increased tailpipe CO2 emissions through the
additional work required to operate the compressor, fans, and blowers. This additional power
demand is ultimately met by using additional fuel, which is converted into CC>2 by the engine
during combustion and exhausted through the tailpipe. These emissions can be reduced by
increasing the overall efficiency of an A/C system, thus reducing the additional load on the
engine from A/C operation, which in turn means a reduction in fuel consumption and a
commensurate reduction in GHG emissions.
Manufacturers may generate and use credits for improved A/C systems in complying with the
CO2 fleet average standards taking effect in the 2012 model year (or otherwise to be able to bank
or trade the credits). These provisions may be used in the 2009-2011 model years to generate
early credits, prior to the 2012 model year. We expect that most manufacturers will choose to use
the A/C credit provisions as part of their compliance demonstration. Ten manufacturers were
able to claim credits for A/C systems that either reduce refrigerant leakage or reduce GHG
exhaust emissions. Although the quantity of A/C credits is small relative to the fleet average
credits reported by manufacturers, EPA is encouraged by the use of these credit provisions and
takes it as an indication that manufacturers are exploring a full range of options for reducing
GHG emissions. The A/C provisions are structured as credits, unlike the CC>2 standards for
which manufacturers will demonstrate compliance using the EPA test procedures. Those tests do
not measure either A/C refrigerant leakage or the increase in tailpipe CO2 emissions attributable
to the additional engine load of A/C systems. Because it is optional to include A/C-related GHG
emission reductions as an input to a manufacturer's compliance demonstration, the A/C
provisions are viewed as an additional program that credits manufacturers for implementing A/C
12
-------
technologies that result in real-world reductions in GHG emissions. A summary of the air
conditioning credits reported by the industry is shown in Table 9.
TABLE 9. REPORTED EARLY AIR CONDITIONING CREDITS, BY TYPE AND
MODEL YEAR (Me)
Type
A/C Efficiency
A/C Leakage
Total
2009
2,036,470
5,696,751
7,733,221
2010
2,695,786
7,389,503
10,085,289
2011
3,403,929
7,747,824
11,151,753
Grand Total
8,136,185
20,834,078
28,970,263
A. Reported Credits From Reduced A/C Refrigerant Leakage
A manufacturer choosing to generate A/C leakage credits with a specific A/C system is required
to calculate a leakage "score" for the A/C system. This score is based on the number, quality, and
technology of the components, fittings, seals, and hoses of the A/C system. This score, which is
determined in grams per year, is calculated using the procedures specified by the Society of
Automotive Engineers Surface Vehicle Standard J2727. It is subsequently converted to a
grams/mile credit value for consistency with the units of GHG exhaust emissions. The
grams/mile value is used to calculate the total tons of credits attributable to an A/C system by
accounting for the global warming potential (GWP) of the refrigerant, the VMT of the vehicle
class (car or truck), and the production volume of the A/C system. Note that while A/C leakage
credits can also be based on transitioning to systems that use refrigerants with a lower GWP, the
use of the conventional hydrofluorocarbon refrigerant (HFC-R134a) was universal in the model
years covered by these early credits. Thus, these credits are based entirely on improvements to
the physical systems that contain and move the refrigerant through the A/C system.
Nine manufacturers participated in the early A/C credits program based on reducing refrigerant
leakage, as shown in Table 10. These manufacturers reported a total of 20,834,078 metric tons of
CO2 credits over the three model years, or about 10% of the total early credits reported by the
industry (see Tables 1 and 9).
13
-------
TABLE 10. EARLY CREDITS REPORTED EARNED FROM LOW-LEAK AIR CONDITIONING
SYSTEMS
Manufacturer
BMW
Chrysler
Daimler
Ford
GM
Honda
Nissan
Toyota
Volkswagen
Fleet
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Grand Total
Model Year
2009
Production
Volume
95,270
16,978
287,364
528,286
57,812
20,035
421,306
553,174
954,239
729,189
802,442
321,228
143,263
220,896
1,264,617
363,547
266,152
26,130
7,071,928
Credits
(Mg)
47,490
17,334
237,143
551,632
31,408
18,297
247,818
830,382
792,488
1,393,043
246,771
176,484
20,466
100,005
507,913
343,961
110,126
23,990
5,696,751
2010
Production
Volume
72,225
13,612
430,110
729,662
59,736
33,642
713,574
1,085,059
786,528
644,464
836,304
385,322
167,243
214,294
1,402,166
648,233
284,037
36,327
8,542,538
Credits
(Mg)
34,939
13,670
352,786
740,466
30,856
32,334
387,819
1,623,677
716,959
1,487,242
277,048
226,311
16,755
109,905
583,900
598,764
120,055
36,017
7,389,503
2011
Production
Volume
153,966
31,323
335,790
739,487
71,711
33,670
832,559
833,730
658,994
1,089,891
563,002
524,163
248,209
251,623
1,090,293
814,743
268,550
64,780
8,606,484
Credits
(Mg)
80,174
35,952
340,299
843,506
41,110
16,851
476,473
1,279,698
1,340,422
1,648,173
142,831
283,673
44,656
135,259
532,137
343,787
109,887
52,936
7,747,824
B. Reported Credits From Improved A/C System Efficiency
Manufacturers that make improvements in their air conditioning systems to increase efficiency,
and thus reduce CC>2 emissions due to air conditioning system operation, may be eligible for air
conditioning efficiency credits. Most of the additional load on the engine from air conditioning
systems comes from the compressor, which pumps the refrigerant around the system loop. A
significant additional load on the engine may also come from electric or hydraulic fans, which
are used to move air across the condenser, and from the electric blower, which is used to move
air across the evaporator and into the cabin. Manufacturers have several currently-existing
technology options for improving efficiency, including more efficient compressors, fans, and
motors, and system controls that avoid over-chilling the air (and subsequently re-heating it to
provide the desired air temperature with an associated loss of efficiency). For vehicles equipped
with automatic climate-control systems, real-time adjustment of several aspects of the overall
system (such as engaging the full capacity of the cooling system only when it is needed, and
14
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maximizing the use of recirculated air) can result in improved efficiency. The regulations
provide manufacturers with a "menu" of technologies and associated credit values (in grams/mile
of CO2). The total tons of credits are then based on the total volume of vehicles in a model year
using these technologies.
Ten manufacturers used the provisions that allow early credits based on improvements to the
overall efficiency of the A/C system, as shown in Table 11. These manufacturers reported a total
of 8,136,185 metric tons of CC>2 credits over the three model years, or almost 4% of the total
early credits reported by the industry (see Tables 1 and 9).
TABLE 11. EARLY CREDITS REPORTED EARNED BY IMPROVING THE EFFICIENCY OF AIR
CONDITIONING SYSTEMS
Manufacturer
BMW
Chrysler
Daimler
Ford
GM
Honda
Nissan
Tesla
Toyota
Volkswagen
Fleet
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Car
Truck
Car
Truck
Grand Total
Model Year
2009
Production
Volume
95,270
16,978
171,522
435,791
53,062
20,035
0
0
838,289
87,771
466,518
140,335
605,439
234,883
0
1,273,815
482,160
266,152
26,130
5,214,150
Credits
(Mg)
62,528
16,106
68,074
86,828
30,018
16,744
0
0
113,142
12,683
161,988
53,885
225,310
94,333
0
639,927
195,200
231,296
28,408
2,036,470
2010
Production
Volume
72,225
13,612
258,478
579,480
62,638
33,642
34,076
12,516
597,220
620,030
481,676
125,879
617,548
236,588
599
1,412,172
793,187
284,037
36,327
6,271,930
Credits
(Mg)
46,231
12,765
107,553
111,650
35,122
25,808
15,304
6,501
99,629
263,524
177,222
48,334
231,360
81,072
374
768,652
373,144
249,431
42,110
2,695,786
2011
Production
Volume
153,966
31,323
335,790
739,487
69,772
33,670
57,499
464,707
542,683
1,043,792
331,756
342,934
666,660
299,074
269
1,140,255
834,019
268,550
64,780
7,420,986
Credits
(Mg)
113,483
30,428
118,345
324,184
71,586
28,138
14,415
64,493
310,606
330,160
119,152
111,311
248,584
102,799
168
621,412
483,423
239,277
71,965
3,403,929
15
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IV. Credits Based on Off-Cycle Emission Reductions
General Motors requested, and was subsequently granted, off-cycle credits for a technology used
on certain gasoline-electric hybrid vehicles. The off-cycle credits reported by General Motors are
shown in Table 12. The technology is an auxiliary electric pump which keeps engine coolant
circulating in cold weather while the vehicle is stopped and the engine is off. These hybrid
vehicles feature engine stop/start capability for improved fuel economy, and as a result the
engine can frequently be turned off when the vehicle is stopped, such as at a traffic light.
However, during cold weather, a hybrid vehicle without the auxiliary heater pump would need to
keep the engine idling during the stop periods solely to maintain coolant flow to the heater to
maintain a comfortable temperature inside the vehicle. This would reduce the fuel economy
benefits of the stop/start feature during cold weather, which is an "off-cycle" temperature
condition not captured by the greenhouse gas test methods. Note that starting with the 2014
model year, the regulations provide a "menu" of off-cycle technologies and associated credits for
each technology. Manufacturers implementing engine idle stop/start technologies may receive
off-cycle credits for those technologies, and the addition of an auxiliary heat pump (or system
that achieves the same result) to these vehicles will gain additional off-cycle credits.
Manufacturers may also seek additional off-cycle credits for technologies not listed on the menu
based on data and analyses submitted to EPA for approval.
TABLE 12. EARLY CREDITS REPORTED EARNED BY OFF-CYCLE EMISSION REDUCTIONS
Manufacturer
GM
Fleet
Truck
Grand Total
2009
Production
Volume
8,671
8,671
Credits
(Mg)
3,329
3,329
2010
Production
Volume
2,512
2,512
Credits
(Mg)
965
965
2011
Production
Volume
3,484
3,484
Credits
(Mg)
1,338
1,338
V. Early Advanced Technology Vehicle Incentives
The GHG regulations include provisions that provide a temporary regulatory incentive for the
commercialization of certain advanced vehicle power trains — electric vehicles (EVs), plug-in
hybrid electric vehicles (PHEVs), and fuel cell vehicles (FCVs). The purpose of these provisions
is to provide a temporary incentive to promote technologies which have the potential to produce
very large GHG reductions in the future, but which face major challenges, such as vehicle cost,
consumer acceptance, and the development of low-GHG fuel production infrastructure. These
incentives may also be used by manufacturers that introduce these advanced technologies in the
2009-2011 model years.
There are two ways manufacturers can treat advanced technology vehicles that are introduced in
the 2009-2011 model years. First, until specific production volume thresholds are reached, the
GHG emissions of EVs and FCVs will be considered for compliance purposes to be zero, as will
the GHG emissions of PHEVs for the portion of operation that uses electricity from the grid.
After those production thresholds are met, these vehicles will be required to account for their net
16
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"upstream" emissions relative to a conventional gasoline vehicle.15 We acknowledge, based on
current electricity and hydrogen production processes, that EVs, PHEVs, and FCVs yield higher
upstream GHG emissions than comparable gasoline vehicles. But we support temporarily
rewarding advanced emissions control technologies by foregoing modest emissions reductions in
the short term in order to lay the foundation for the potential for much larger emission reductions
in the longer term. EVs, PHEVs, and FCVs are potential GHG "game changers" if major cost
and consumer barriers can be overcome and if there is a nationwide transformation to low- GHG
electricity (or hydrogen, in the case of FCVs). Second, manufacturers have the option of not
including these vehicles in their calculation of fleet average credits in the 2009-2011 model
years, but instead "deferring" the use of these vehicles and their associated compliance values to
the 2012 or later model years. Manufacturers using this option must maintain records of the
volume of these vehicles and their GHG emission levels and ensure that these vehicles are not
included in their fleet average credit calculations using one of the four fleet average credit
pathways.
Two manufacturers chose the "deferral" option, electing to not include some 2011 model year
advanced technology vehicles in their 2009-2011 fleet average credits. Other manufacturers with
advanced technology vehicles chose to include those vehicles in their fleet average credits.
Because there is no emission standard that applies to these vehicles until these manufacturers
elect to "use" these vehicles in compliance calculations for a future model year, there are no
associated tons of credits to report at this time. Thus we are only able to report the volume of
these vehicles and the emission values (as reported to us by these two manufacturers) that
manufacturers have elected to defer to a future model year in the calculation of a future model
year fleet average.
TABLE 13. MODEL YEAR 2011 ADVANCED TECHNOLOGY VEHICLES
REPORTED As DEFERRED TO A FUTURE MODEL YEAR
Production
Manufacturer Fleet Volume GHG (g/mi)
Daimler Car 623 0
GM Car 4,370 54
Grand Total 4,993
VI. Conclusion
EPA's GHG program includes a number of flexibilities designed to provide sufficient lead time
for manufacturers and to reduce the overall cost of the program, without compromising overall
15 In this case, "upstream" refers to the emissions associated with the production and distribution of electricity and
hydrogen.
17
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environmental objectives. One of these flexibilities is an optional program that allows
manufacturers with superior greenhouse gas emission reduction performance to generate early
credits in the 2009-2011 model years. The early credits program provided a valuable incentive
for manufacturers that have implemented GHG reducing technologies in excess of either the
CAFE or California GHG standards prior to MY 2012. These early credits represent surplus
reductions that were not otherwise required by law, and will allow manufacturers to transition to
the increasingly stringent GHG standards. EPA's early credits program is also an important
example of how the GHG and CAFE programs were aligned to achieve a coordinated National
Program.16
EPA is providing this report as part of our commitment to provide the public with timely,
transparent information about the implementation of the light-duty GHG standards program. This
report summarizes the credits reported by each manufacturer in the 2009-2011 model years and
explains the options for earning and using early credits. Manufacturers that chose to participate
in the early credits program submitted documentation in early 2012, as required under the
regulations. Seventeen manufacturers chose to take advantage of one or more elements of the
early credits program, reporting some 209 million metric tons of CC>2 credits over the three
model years covered by the program.
This report is also intended to be used as a reference for users of the early credits data, which we
are making available in formats appropriate for importing into spreadsheets or database
applications. EPA is neither making any assumptions regarding the potential disposition of these
early GHG credits nor attempting to speculate at this time on how manufacturers will choose to
use these accumulated early credits over the applicable credit lifetimes. However, we believe
that most manufacturers will be taking a long-term view by using their accumulated credits
judiciously to plan a smooth pathway to the increasingly stringent GHG emission standards in
the future.
16 Under the CAFE program, manufacturers that have been outperforming the CAFE standards in the same time
period will be approaching the increasingly stringent CAFE standards with a bank of credits accumulated in the
same model years as the early GHG credits program.
18
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APPENDIX I - REPORTED CREDITS BASED ON EARLY FLEET AVERAGE CO2 REDUCTIONS
Manufacturer
BMW
Pathway
4
BMW Total
Chrysler
1
Chrysler Total
Ford
1
Ford Total
GM
1
GM Total
Honda
3
Model
Year
2009
2010
2011
2009
2010
2011
2009
2010
2011
2009
2010
2011
2009
2010
Region
NC
NC
NC
US
us
us
us
us
us
us
us
us
NC
CA
NC
CA
Fleet
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Fleet
Threshold
(g/mi)
323
381
323
376
302
351
323
439
301
420
267
390
323
439
301
420
267
390
323
439
301
420
267
390
323
381
323
439
323
376
301
420
Fleet
Average
(g/mi)
306
394
309
384
303
356
319
402
316
394
309
396
299
397
289
406
283
387
295
413
298
382
296
382
257
339
266
373
251
329
262
366
Vehicle
Production
(# units)
95,270
16,978
72,225
13,612
153,966
31,323
383,374
287,364
528,286
430,110
729,662
335,790
739,487
3,050,699
508,727
504,921
856,065
965,968
792,654
873,635
4,501,970
1,048,593
844,892
857,825
932,358
1,006,900
1,419,043
6,109,611
433,183
232,149
388,318
89,079
414,562
290,216
429,692
95,106
Fleet Average
Credits (Mg)
316,248
(49,852)
197,441
(24,596)
(30,064)
(35,374)
373,803
224,447
4,414,889
(1,259,775)
4,284,933
(2,753,843)
(1,002,145)
3,908,506
2,384,066
4,789,847
2,005,904
3,054,497
(2,476,429)
591,971
10,349,856
5,733,069
4,961,620
502,507
8,002,308
(5,701,728)
2,564,097
16,061,873
5,582,613
2,202,242
4,321,998
1,327,909
5,828,330
3,080,833
3,272,232
1,159,980
-------
Manufacturer
Pathway
Honda Total
Mazda
3
Mazda Total
Mitsubishi
3
Mitsubishi Total
Nissan
1
Model
Year
2011
2009
2010
2011
2009
2010
2011
2009
2010
2011
Region
NC
CA
NC
CA
NC
CA
NC
CA
NC
CA
NC
CA
NC
CA
US
US
US
Fleet
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Fleet
Threshold
(g/mi)
290
347
267
390
323
381
323
439
323
376
301
420
289
347
267
390
323
381
323
439
323
376
301
420
288
335
267
390
323
439
301
420
267
390
Fleet
Average
(g/mi)
253
338
250
335
280
329
281
379
263
329
265
360
266
359
256
339
294
322
290
342
277
323
288
365
266
325
267
358
268
372
266
399
261
382
Vehicle
Production
(# units)
317,065
280,042
247,437
244,121
3,460,970
61,283
35,084
40,884
10,612
133,292
64,558
86,948
25,351
112,883
18,435
59,856
25,145
674,331
60,347
8,573
23,293
872
30,144
14,832
15,733
2,699
49,447
15,159
25,408
7,712
254,219
605,439
234,883
617,548
236,588
666,660
299,074
Fleet Average
Credits (Mg)
2,290,721
569,265
821,364
3,032,611
33,490,098
514,554
412,061
335,293
143,813
1,561,628
685,325
611,201
343,554
506,966
(49,966)
128,565
289,648
5,482,642
341,724
114,244
150,093
19,105
270,758
177,552
39,937
33,529
212,415
34,239
0
55,740
1,449,336
6,502,124
3,554,474
4,220,471
1,122,176
781,048
540,403
-------
Manufacturer
Pathway
Nissan Total
Subaru
1
Subaru Total
Suzuki
1
Suzuki Total
Tesla
1
Tesla Total
Toyota
1
Toyota Total
Volkswagen
3
Model
Year
2009
2010
2011
2009
2010
2011
2010
2011
2009
2010
2011
2009
2010
2011
Region
US
US
US
US
US
US
US
US
US
US
US
NC
CA
NC
CA
NC
CA
Fleet
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Car
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Fleet
Threshold
(g/mi)
323
439
301
420
267
390
323
439
301
420
267
390
301
267
323
439
301
420
267
390
323
381
323
439
323
376
301
420
289
342
267
390
Fleet
Average
(g/mi)
308
322
299
292
295
292
275
345
259
337
262
345
0
0
245
345
228
353
243
321
290
363
293
382
274
356
277
361
267
332
273
334
Vehicle
Production
(# units)
2,660,192
156,871
43,945
183,763
74,489
176,923
129,950
765,941
24,859
10,146
20,212
8,728
19,390
7,864
91,199
599
269
868
1,273,815
482,202
1,412,172
793,226
1,140,255
834,019
5,935,689
139,498
21,078
118,411
13,295
143,295
23,488
134,231
19,350
151,373
35,176
121,114
25,667
Fleet Average
Credits (Mg)
16,720,696
459,469
1,161,300
71,765
2,153,531
(967,307)
2,876,413
5,755,171
232,995
215,413
165,760
163,622
18,931
79,929
876,650
35,206
14,024
49,230
19,400,957
10,237,780
20,129,484
12,003,853
5,343,618
12,997,923
80,113,615
898,885
85,694
693,642
171,164
1,371,037
106,102
629,052
257,859
650,269
79,450
(141,895)
324,648
-------
Manufacturer
Pathway
Volkswagen Total
Volvo
1
Volvo Total
Model
Year
2009
2010
2011
Region
US
US
US
Fleet
Car
Truck
Car
Truck
Car
Truck
Fleet
Threshold
(g/mi)
323
439
301
420
267
390
Fleet
Average
(g/mi)
317
407
317
380
300
354
Vehicle
Production
(# units)
945,976
31,618
11,420
23,529
34,413
24,846
27,761
153,587
Fleet Average
Credits (Mg)
5,125,907
37,043
82,540
(73,510)
310,908
(160,100)
225,729
422,610
IV
-------
APPENDIX II - SUMMARY OF REPORTED CREDITS BY TYPE AND MODEL YEAR, BY
MANUFACTURER
Manufacturer MY Fleet A/C Efficiency A/C Leakage Off-Cycle Fleet Average Grand Total
2009 Car
Truck
2010 Car
BMW Truck
2011 Car
Truck
Total
2009 Car
Truck
2010 Car
Chrysler Truck
2011 Car
Truck
Total
2009 Car
Truck
2010 Car
Daimler Truck
2011 Car
Truck
Total
2009 Car
Truck
2010 Car
Ford Truck
2011 Car
Truck
Total
2009 Car
Truck
2010 Car
GM Truck
2011 Car
Truck
Total
2009 Car
Truck
2010 Car
Honda Truck
2011 Car
Truck
Total
2009 Car
-„ , Truck
JVLazaa
2010 Car
Truck
62,528
16,106
46,231
12,765
113,483
30,428
281,541
68,074
86,828
107,553
111,650
118,345
324,184
816,634
30,018
16,744
35,122
25,808
71,586
28,138
207,416
15,304
6,501
14,415
64,493
100,713
113,142
12,683
99,629
263,524
310,606
330,160
1,129,744
161,988
53,885
177,222
48,334
119,152
111,311
671,892
47,490
17,334
34,939
13,670
80,174
35,952
229,559
237,143
551,632
352,786
740,466
340,299
843,506
3,065,832
31,408
18,297
30,856
32,334
41,110
16,851
170,856
247,818
830,382
387,819
1,623,677
476,473
1,279,698
4,845,867
792,488
1,393,043
716,959
1,487,242
1,340,422
1,648,173
7,378,327
246,771
176,484
277,048
226,311
142,831
283,673
1,353,118
316,248
-49,852
197,441
-24,596
-30,064
-35,374
373,803
224,447
4,414,889
-1,259,775
4,284,933
-2,753,843
-1,002,145
3,908,506
2,384,066
4,789,847
2,005,904
3,054,497
-2,476,429
591,971
10,349,856
5,733,069
3,329 4,961,620
502,507
965 8,002,308
-5,701,728
1,338 2,564,097
5,632 16,061,873
9,904,611
3,530,151
9,100,562
4,240,813
3,112,085
3,601,876
33,490,098
849,847
555,874
2,172,829
1,028,879
426,266
-16,412
278,611
1,839
163,593
31,006
884,903
529,664
5,053,349
-799,436
5,137,049
-2,295,199
165,545
7,790,972
61,426
35,041
65,978
58,142
112,696
44,989
378,272
2,631,884
5,620,229
2,409,027
4,684,675
-1,985,541
1,936,162
15,296,436
6,638,699
6,370,675
1,319,095
9,754,039
-4,050,700
4,543,768
24,575,576
10,313,370
3,760,520
9,554,832
4,515,458
3,374,068
3,996,860
35,515,108
849,847
555,874
2,172,829
1,028,879
-------
Manufacturer
Mitsubishi
Nissan
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
MY Fleet A/C Efficiency A/C Leakage Off-Cycle Fleet Average Grand Total
2011 Car
Truck
Total
2009 Car
Truck
2010 Car
Truck
2011 Car
Truck
Total
2009 Car
Truck
2010 Car
Truck
2011 Car
Truck
Total
2009 Car
Truck
2010 Car
Truck
2011 Car
Truck
Total
2009 Car
Truck
2010 Car
Truck
2011 Car
Truck
Total
2010 Car
2011 Car
Total
2009 Car
Truck
2010 Car
Truck
2011 Car
Truck
Total
2009 Car
Truck
2010 Car
Truck
2011 Car
Truck
Total
2009 Car
Truck
225,310
94,333
231,360
81,072
248,584
102,799
983,458
374
168
542
639,927
195,200
768,652
373,144
621,412
483,423
3,081,758
231,296
28,408
249,431
42,110
239,277
71,965
862,487
20,466
100,005
16,755
109,905
44,656
135,259
427,046
507,913
343,961
583,900
598,764
532,137
343,787
2,910,462
110,126
23,990
120,055
36,017
109,887
52,936
453,011
635,531
239,682
5,482,642
491,817
133,349
310,695
211,081
212,415
89,979
1,449,336
6,502,124
3,554,474
4,220,471
1,122,176
781,048
540,403
16,720,696
459,469
1,161,300
71,765
2,153,531
-967,307
2,876,413
5,755,171
232,995
215,413
165,760
163,622
18,931
79,929
876,650
35,206
14,024
49,230
19,400,957
10,237,780
20,129,484
12,003,853
5,343,618
12,997,923
80,113,615
1,592,527
256,858
2,000,089
363,961
508,374
404,098
5,125,907
37,043
82,540
635,531
239,682
5,482,642
491,817
133,349
310,695
211,081
212,415
89,979
1,449,336
6,747,900
3,748,812
4,468,586
1,313,153
1,074,288
778,461
18,131,200
459,469
1,161,300
71,765
2,153,531
-967,307
2,876,413
5,755,171
232,995
215,413
165,760
163,622
18,931
79,929
876,650
35,580
14,192
49,772
20,548,797
10,776,941
21,482,036
12,975,761
6,497,167
13,825,133
86,105,835
1,933,949
309,256
2,369,575
442,088
857,538
528,999
6,441,405
37,043
82,540
-------
Manufacturer MY Fleet A/C Efficiency A/C Leakage Off-Cycle Fleet Average Grand Total
2010 Car
Truck
2011 Car
Total
-73,510
310,908
-160,100
196,881
-73,510
310,908
-160,100
196,881
------- |