Greenhouse Gas
Emission Standards for
Light-Duty Vehicles
Manufacturer Performance Report
for the
Model Year
Fisker
Porsche
Toyota
Mazda
Ford
Subaru
General Motors
Mitsubishi
Nissan
Volkswagen
BMW
Chrysler
Volvo
Mercedes-Benz
Suzuki
Jaguar
Land Rover
Ferrari
Coda
Tesla
Fisker
Porsche
Toyota
Mazda
Ford
Subaru
General Motors
Mitsubishi
&EPA
EPA-420-R-14-011 April 2014
United States
Environmental Protection
Agency
Nissan
Volkswagen
BMW
Chrysler
Volvo
Mercedes-Benz
Suzuki
Jaguar
Land Rover
Ferrari
Coda
Tesla
Fisker
Porsche
Toyota
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Greenhouse Gas
Emission Standards for
Light-Duty Vehicles
Manufacturer Performance Report
for the
Model Year
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.
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Table of Contents
EXECUTIVE SUMMARY i
1 INTRODUCTION 1
1.1 WHY ARE WE RELEASING THIS INFORMATION? 1
1.2 WHAT NEW DATA ARE WE PUBLISHING? 2
1.3 HOW CAN C02 EMISSIONS CREDITS BE USED? 4
1.4 WHICH MANUFACTURERS AND VEHICLES ARE INCLUDED IN THIS REPORT? 5
1.4.1 Small Businesses 5
1.4.2 Smo// Volume Manufacturers 5
1.4.3 Operationally Independent Manufacturers 6
1.4.4 Hyundai and Kia 6
1.4.5 Aggregation of Manufacturers 6
2 OPTIONAL EARLY GHG CREDITS FROM 2009-2011 MODEL YEARS 8
3 CREDITS REPORTED FROM THE 2012 MODEL YEAR 11
3.1 CREDITS BASED ON FLEET AVERAGE TAILPIPE GHG EMISSIONS 13
3.1.1 Manufacturers in the Primary Standards Program 17
3.1.2 Manufacturers in the TLAAS Program 20
3.1.3 Flexible Fuel and Natural Gas Vehicle Credits 22
3.2 CREDITS BASED ON AIR CONDITIONING SYSTEMS 25
3.2.1 Air Conditioning Leakage Credits 28
3.2.2 Air Conditioning Efficiency Credits 29
3.3 "OFF-CYCLE" CREDITS 30
3.4 ADVANCED TECHNOLOGY VEHICLE INCENTIVES 31
3.5 METHANE AND NITROUS OXIDE STANDARDS 32
3.6 2012 MODEL YEAR PERFORMANCE SUMMARY 33
4 CREDIT TRANSACTIONS 39
5 COMPLIANCE STATUS AFTER THE 2012 MODEL YEAR 41
APPENDIX: 2012 MODEL YEAR CREDITS AND DEFICITS 45
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List of Tables and Figures
Process for Determining a Manufacturer's 2012 Model Year Compliance Status ii
2012 Model Year Performance - Does Not Include Impact of Credit Trades or Credit Transfers from Prior
Model Years iii
Status of Manufacturers at the Conclusion of the 2012 Model Year - Includes the Impact of Credit
Trades and Credit Transfers from Prior Model Years vi
Table 1.4.5-1. Aggregation of Manufacturers in the 2012 Model Year 7
Table 2-1. Early Credits, by Manufacturer and Model Year (Mg) 9
Table 2-2. Total Reported Early Credits, By Credit Source 9
Table 3-1. Total Reported Credits for the 2012 Model Year, By Credit Source 12
Table 3-2. Total Reported Deficits for the 2012 Model Year, By Deficit Source 13
Table 3-3. Total Net Credits for the 2012 Model Year, By Credit Source 13
Table 3.1-1. Reported Fleet Average Credits by Manufacturer and Fleet, 2012 Model Year 15
Table 3.1-2. Total 2012 Model Year Fleet Average Car Credits - Top Five Manufacturers in Primary
Program 16
Table 3.1-3. Total 2012 Model Year Fleet Average Truck Credits - All Manufacturers in Primary
Program 16
Figure 3.1.1-1. 2012 Model Year Footprint Target Curves 18
Table 3.1.1-1. Reported Fleet Average Credit Detail for Manufacturers with Primary Program Fleets,
2012 Model Year 19
Table 3.1.2-1. Reported Fleet Average Credit Detail for TLAAS Program Fleets, 2012 Model Year 21
Table 3.1.3-1. Production of FFVs and CNG vehicles by Manufacturer, 2012 Model Year 24
Table 3.1.3-2. Fleet Average GHG Benefits from FFV Production, by Manufacturer and Fleet 25
Figure 3.2-1. A/C Credits Relative to Total Credits Earned by Manufacturers for 2009-2012 Model
Years (millions of Mg) 27
Table 3.2-1. Reported Air Conditioning Credits by A/C Credit Type and Model Year (Mg) 27
Table 3.2-2. Reported Air Conditioning Credits by Manufacturer, 2012 Model Year(Mg) 28
Table 3.2.1-1. Reported Air Conditioning Leakage Credits by Manufacturer and Fleet, 2012 Model Year
(Mg) 29
Table 3.2.2-1. Reported Air Conditioning Efficiency Credits by Manufacturer and Fleet, 2012 Model
Year(Mg) 30
Table 3.3-1. Reported Off-Cycle Credits by Manufacturer and Fleet, 2012 Model Year (Mg) 31
Table 3.4-1. Production Volumes of Advanced Technology Vehicles Using Zero Gram/Mile Incentive,
by Model year 32
Table 3.5-1. Reported CH4 and N2O Deficits by Manufacturer and Fleet, 2012 Model Year (Mg) 33
Table 3.6-1. 2012 Model Year Aggregate Performance, Gram/Mile Equivalent - Cars 35
Table 3.6-2. 2012 Model Year Aggregate Performance, Gram/Mile Equivalent - Trucks 36
Figure 3.6-1. 2012 Model Year Performance & Standard by Manufacturer and Average Footprint - Car
Fleets 37
Figure 3.6-2. 2012 Model Year Performance & Standard by Manufacturer and Average Footprint -
Truck Fleets 38
Table 4-1. Reported Credit Sales and Purchases as of the 2012 Model Year (Mg) 40
Table 5-1. Cumulative Credit Status by Manufacturer at Conclusion of 2012 Model Year (Mg) 43
Table 5-2. Model Year Makeup of Volkswagen's Total Credit Balance 44
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Executive Summary
On May 7, 2010, the Environmental Protection Agency (EPA) and the National Highway Traffic
Safety Administration (NHTSA) issued a joint Final Rule to establish a National Program with
new standards for light-duty vehicles that reduce greenhouse gas emissions and improve fuel
economy.l EPA finalized greenhouse gas emissions (GHG) standards under its authority in the
Clean Air Act, and NHTSA finalized Corporate Average Fuel Economy (CAFE) standards under
the Energy Policy and Conservation Act of 1975, as amended (EPCA). These standards apply to
passenger cars, light-duty trucks, and medium-duty passenger vehicles, covering model years
2012 through 2016, and represent the first phase of the EPA and NHTSA joint harmonized
National Program. On October 15, 2012, EPA and NHTSA issued a subsequent rulemaking
further reducing greenhouse gas emissions and improving the fuel economy of light-duty
vehicles for model years 2017-2025, building on the success of the first phase of the joint
National Program.
In March 2013, EPA released a report documenting manufacturers' use of the early credit
provisions allowed under the GHG standards for the 2009-2011 model years.3 EPA is releasing
this subsequent report as part of our continuing commitment to provide the public with
transparent and timely information about manufacturers' compliance with the GHG program.
This report summarizes the information presented in the March 2013 report and presents
substantial detail regarding the performance of the manufacturers towards meeting GHG
standards in the 2012 model year - the first model year of the standards. As was the case with the
March 2013 report, we are excluding Hyundai and Kia data because of the ongoing investigation
into their testing methods. This report is also a reference for users of the GHG credits data,
which we are making available in formats appropriate for importing into spreadsheets or
database applications.4 Similarly, information on the CAFE program can be downloaded from
the NHTSA website.5
The 2012 model year was the first year of a 14-year program to reduce the greenhouse gas
emissions from new light-duty vehicles. Because the program allows credits and deficits to be
carried into future years, at the close of the 2012 model year no manufacturer is considered to be
out of compliance with the program. We intend to report annually on the status of manufacturers
and their compliance with the program.
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 The CO2 standards for the 2022-2025 model years are subject to future evaluation under 40 CFR 86.1818-12(h),
which describes the "mid-term evaluation" process. This mid-term evaluation, which will be completed by April 1,
2018, will include an opportunity for public comment and will be carried out jointly with NHTSA as they are
similarly required to evaluate the augural CAFE standards for model years 2022-2025 under their regulations. EPA
and NHTSA also expect to involve the California Air Resources Board, recognizing the agency's interest "in
maintaining the National Program to address GHG emissions and fuel economy" (see 77 FR 62628, October 15,
2012).
3 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,
Report No. EPA-420-R-13-005, March 2013.
4 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.
5 http://www.nhtsa.gov/fuel-economy.
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Process for Determining a Manufacturer's 2012 Model Year Compliance Status
2012
tailpipe CO2
credits/deficits
(includes (-F-V credits)
2012
air conditioning
Credits
2012 methane
and nitrous
oxide deficits
Statu
Conclusion 01
2012 Model Year
2013-2015 Performance
&
2013-2015 Credit
Transactions
N
There are a number of inputs and a multi-year process to determine manufacturer compliance
with the light-duty vehicle GHG emission standards. The majority of this report focuses on
detailing the 2012 performance of manufacturers, which includes the following:
• CC>2 exhaust emission performance, including credits for flexible fuel vehicles, relative to
a fleet average CO2 standard (resulting in credits or deficits);
• GHG reductions (credits) from improvements to air conditioning systems that reduce
refrigerant leakage or improve system efficiency;
• "Off-cycle" CO2 emission reductions (credits) from technology improvements that can't
be sufficiently measured by EPA test procedures; and
• GHG deficits from meeting alternative methane or nitrous oxide standards.
The aggregation of all of these elements represents a manufacturer's 2012 model year
performance. But this is only an intermediate step, a single model year snapshot, the results of
11
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which do not define compliance or lack thereof. Once the 2012 model year performance is
determined, a manufacturer can apply credits available from prior model years (in the case of the
2012 model year, these are credits from the 2009-2011 optional early credits program). In
addition, a manufacturer may purchase credits from another manufacturer. When credits from
these two sources are added to credits (or deficits) resulting from 2012 model year performance,
the result is the status at the conclusion of the 2012 model year. This status is discussed in the
concluding section of this report. Finally, because a 2012 model year deficit can be carried
forward into the 2015 model year, compliance with the 2012 model year standards can't be fully
assessed until the end of the 2015 model year. Thus compliance with the 2012 model year may
depend on performance in each of the 2013-2015 model years as well as on credit purchases
made in those model years.
2012 Model Year Performance - Does Not Include Impact of Credit
Trades or Credit Transfers from Prior Model Years
Manufacturer
Tesla
Coda
Fisker
Porsche*
Toyota
Honda
Mazda
Ford
Subaru
General Motors
Mitsubishi
Nissan
Volkswagen
BMW
Chrysler
Volvo
Mercedes-Benz*
Suzuki
Jaguar Land Rover*
Ferrari*
Total
* These companies are using a
their fleet to be subject to less
2012 Total
Vehicle
Production
2,952
115
1,415
29,873
2,020,248
1,540,579
279,004
1,754,323
270,012
2,364,374
64,467
1,228,164
565,572
257,010
1,533,883
71,807
255,405
31,263
54,561
1,510
12,326,537
Net 2012
Credits
(Mg)
178,517
5,524
46,694
198,348
13,163,009
7,851,251
734,887
4,333,951
543,316
2,872,354
57,837
(729,937)
(502,495)
(291,272)
(1,892,184)
(175,195)
(748,723)
(127,699)
(424,032)
(40,983)
25,053,168
temporary program that allows all
stringent standards. See Section 3.
Grams/Mile
Equivalent
309.7
246.0
169.0
31.8
31.6
24.9
13.0
11.9
9.4
5.9
4.5
(2.9)
(4.5)
(5.6)
(5.7)
(12.0)
(14.3)
(20.3)
(35.5)
(139.0)
9.8
or part of
1.2.
Manufacturers cumulatively generated almost 39 million Megagrams (metric tons, or Mg) of
GHG credits in the 2012 model year, as well as almost 14 million Mg of deficits, yielding a net
in
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positive total for the model year of about 25 million Mg of GHG credits, as shown above.6 On a
gram per mile basis, this quantity of credits represents a net industry over-compliance with the
2012 model year CC>2 standards of about 10 grams/mile. This industry-wide over-compliance
means that consumers bought vehicles with lower greenhouse gas emissions than the 2012 model
year standards required.
In this first year a credit trading market emerged within the program. Six manufacturers
participated in credit transactions as buyers or sellers of credits. This is the first time in an EPA
light-duty vehicle emissions standards program that credit trading activity has occurred on such a
scale, and it is clear that buying credits may be an important way for some manufacturers to
bring their fleet into compliance and an incentive for other manufacturers to bring lower GHG
vehicles to market early. Credit trading activity is detailed in this report.
Manufacturers widely utilized the optional provisions in the program that allow them to generate
CO2 credits. This is especially true of the optional flexible fuel vehicle (FFV) and air
conditioning (A/C) credits, which EPA anticipated would be widely used in the early years of the
program.7 Only one manufacturer reported off-cycle credits (which had been previously
approved by EPA, as required) but the volume of these credits is less than 0.03 percent of the
total net credit volume.
In the rulemaking for the 2012-2016 model years, we projected a fleet-wide standard of 295
grams/mile and that the industry as a whole would just meet that level (including the use of air
conditioning and FFV credits).8 In fact, the fleet-wide 2012 model year standard (based on sales
and footprint values for individual models) was 296 grams/mile, or 1 gram/mile higher than what
we predicted. However, the actual performance for the 2012 model year was 286 grams/mile, or
9 grams/mile better than our rulemaking projection.9 The 2012 standard also represents a
significant level of greenhouse gas reductions relative to the performance of manufacturers in the
2011 model year. Overall, the industry lowered tailpipe GHG emissions in model year 2012
relative to 2011 by about 19 grams/mile.10
6 Because of the division between cars and tracks, the total credits and total deficits cannot be determined from this
table, which shows only the net credits by manufacturer. Total credits and deficits are described in Section 3, Tables
3-1 and 3-2.
7 Credits for flexible fuel vehicles are similar to those in the CAFE program, but are only applicable through the
2015 model year. See Section 4.1.3 for more information.
8 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final
Rule, Federal Register 75 (7 May 2010): 25324-25728. See Table I.B.2-4, page 25331.
9 For the purpose of making an appropriate comparison to the ralemaking values, the fleet-wide values cited in this
paragraph include Hyundai and Kia data, using estimates for some vehicles subject to the ongoing EPA enforcement
action. Final model year 2011-2013 values for Hyundai and Kia have not been determined.
10 "Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975 Through
2013," U.S. EPA-420-R-13-011, Office of Transportation and Air Quality, December 2013 (Table 4.5, p. 38).
Because this is the first year of the GHG program, there is no national data from the 2011 model year for
comparison, thus in this first year we are referencing EPA's "Trends" report for a year-to-year comparison. While
the Trends report does not provide formal compliance data, Table 4.5 of the Trends report shows that unadjusted,
industry-wide (including Hyundai and Kia) CO2 emissions (not reflecting any credits) were 19 grams/mile lower in
model year 2012 relative to model year 2011. Part of this reduction reflects a higher car share of the market in 2012;
unadjusted car fleet CO2 emissions dropped by 17 grams/mile and unadjusted track fleet CO2 emissions decreased
by four grams/mile. In subsequent years we will be able to compare year-to-year data from EPA's GHG program.
iv
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Looking at the 2012 model year performance only (i.e., what manufacturers did with 2012
models, as represented by the center top arrow in the figure above), half the manufacturers had a
net deficit. However, the early optional credits from the 2009-2011 model years and credit
purchases enabled all but one manufacturer to offset 2012 model year deficits and have credits
remaining to carry forward to use in a future model year.
After accounting for the transfer of credits from the early credit program (2009-2011 model
years), and for credits from optional credit provisions and credit transactions with other
manufacturers, all but one manufacturer (Jaguar Land Rover) finished the 2012 model year with
credits remaining to carry over to use in the 2013 or later model years. The table below shows
the compliance status of each manufacturer at the conclusion of the 2012 model year.
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Status of Manufacturers at the Conclusion of the 2012 Model Year - Includes
the Impact of Credit Trades and Credit Transfers from Prior Model Years
Manufacturer
Toyota
Honda
General Motors
Ford
Nissan
Chrysler
Subaru
Mazda
Volkswagen
Mitsubishi
Suzuki
BMW
Volvo
Porsche
Mercedes-Benz
Fisker
Ferrari
Coda
Tesla*
Jaguar Land Rover
Total
Credits from 2009-
2011 Model Years
(Mg)
80,266,189
35,425,108
24,564,829
15,296,436
17,631,200
9,610,207
5,755,171
5,482,642
6,441,405
1,449,336
876,650
884,903
740,358
-
428,044
-
90,000
-
-
-
204,942,478
Total Credits from
2012 Model Year
(Mg)*
13,163,009
7,851,251
2,872,354
4,333,951
(979,937)
(1,892,184)
543,316
734,887
(502,495)
57,837
(127,699)
(291,272)
(175,195)
198,348
(320,782)
46,694
(40,983)
5,524
576
(424,0
25,053,168
Net Credits Carried
Forward to 2013
Model Year
(MgT
93,429,198
43,276,359
27,437,183
19,630,387
16,651,263
7,718,023
6,298,487
6,217,529
5,938,910
1,507,173
748,951
593,631
565,163
198,348
107,262
46,694
49,017
5,524
576
(424,032)
229,995,646
* Credits include all those available and used by the manufacturer, including credits from flexible
fuel vehicles, air conditioning systems, off-cycle technologies, and deficits from CH4 and N20
standards.
Includes the impact of credit trades with other manufacturers, if any.
Tesla generated credits in the 2010-2012 model years, but sold all of them. They also sold most
of their 2012 model year credits. See Sections 2 and 3.1.1.
VI
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1 Introduction
1.1 Why are we releasing this information?
We are releasing this report as part of our continuing commitment to provide the public with
transparent and timely information about manufacturers' compliance with the GHG program.
Previously, in March of 2013 we released a report documenting manufacturers' use of the early
credit provisions allowed under the light-duty vehicle GHG program.n In the two regulatory
actions that established the greenhouse gas emissions standards for light-duty vehicles, EPA and
NHTSA committed to making certain information public regarding the compliance of
automobile manufacturers with the CC>2 and fuel economy standards while safeguarding
1 9 1 ^
confidential business information, as required by regulation.
When EPA and NHTSA issued the proposed rule for the 2012-2016 model year CC>2 and fuel
economy standards, the proposal received considerable comment about the need for transparency
regarding implementation of the program, and specifically, regarding compliance
determinations.14 Many comments emphasized the importance of making greenhouse gas
compliance information publicly available to ensure such transparency. This was also the case
with the proposal for 2017-2025 model year greenhouse gas standards, in which we reiterated
our commitment to the principle of transparency and to disseminating as much information as we
are reasonably, practically, and legally able to provide.15 In response to the comments 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" and that we would ".. .reassess data release needs
and opportunities once the program is underway."16
We also committed 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." We also suggested that we would likely
publish credit transactions, as well as the overall credit or debit balance for each manufacturer
11 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, Report No. EPA-420-R-13-005, March 2013.
12 See 40 CFR Part 2, Subpart B, Confidentiality of Business Information.
13 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.
14 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.
15 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.
16 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final
Rule, Federal Register 75 (7 May 2010): 25469.
1
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after taking into account the credit and debit carry-forward provisions and any credit
transactions.
In addition to this report, 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
CO2 emission values for each vehicle model. In addition, we release actual vehicle emission test
results at www.epa.gov/otaq/tcldata.htm.
1.2 What new data are we publishing?
The EPA GHG program requires compliance with progressively more stringent GHG standards
for the 2012 through 2025 model years. The program includes certain flexibilities, several of
which were 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. The conclusion of the 2012 model year represents the close of the first
year in which the standards applied, and thus it is the first year in which data is available from all
manufacturers producing light-duty vehicles for U.S. sale (the early credit provisions were
optional and, while used by a majority of manufacturers, were not universally used, as
documented in EPA's March of 2013 report).17
The manufacturer-reported data which forms the basis for this report was required to be
submitted to EPA by the end of March of 2013.18 A number of manufacturers requested and
were granted extensions of the deadline of 30-60 days. The data reported by each manufacturer
includes the calculated manufacturer-specific footprint-based CO2 standard for each vehicle
category (car and truck), the actual fleet-average performance for each vehicle category (which
includes flexible-fuel vehicle credits), the quantity of optional credits (e.g., based on air
conditioning or off-cycle improvements), credit transfers within a manufacturer between car and
truck fleets, or credit trades between manufacturers, and all the data necessary to calculate these
reported values.
This report first summarizes the credits generated under the early credit provisions (see EPA's
March 2013 report for additional detail regarding the early credits), and then summarizes the
data reported by manufacturers for the 2012 model year in a variety of ways. This includes
separately detailing manufacturers' use of the flexibilities included in the program (e.g., credits
for air conditioning improvements or production of flexible-fuel vehicles), as well as the credit
transactions between manufacturers.
Vehicle and fleet average compliance for EPA's GHG program is based on a combination of
CC>2, hydrocarbons, and carbon-monoxide emissions (i.e., the carbon-containing exhaust
constituents). This is consistent with the carbon balance methodology used to determine fuel
consumption for the vehicle labeling and CAFE programs. The regulations account for these
17 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, Report No. EPA-420-R-13-005, March 2013.
18 See 40 CFR 600.512-12.
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total carbon emissions appropriately and refer to the sum of these emissions as the "carbon-
related exhaust emissions," or "CREE." The carbon-containing emissions are combined on a
C (^-equivalent basis to determine the CREE value, i.e., adjusting for the relative global
warming potential of the specific emission constituent. Although the regulatory text uses the
more accurate term "CREE" to represent the CO2-equivalent sum of carbon emissions, the term
CC>2 is used as shorthand throughout this report as a more familiar term for most readers.
The CC>2 standards in EPA's GHG program and the related compliance values in this report
differ from the CC>2 values reported in EPA's "Trends" report or on new vehicle fuel economy
labels.19 The Trends report presents CC>2 and fuel economy values that are based on EPA's label
methodology, which is designed to provide EPA's best estimate of the fuel economy and GHG
emissions that an average driver will achieve in actual real-world driving. EPA's CC>2 standards,
like the CAFE standards, are not adjusted to reflect real world driving. Instead, the GHG
standards and compliance values are based on the results achieved on EPA's city and highway
tests, weighted 55 and 45 percent, respectively. Results from these two tests are commonly
referred to as the "2-cycle" test procedures, in that they are based on weighted results from two
driving cycles. Adjusted CC>2 values that appear in the Trends report and on the EPA fuel
economy window stickers will be about 25 percent higher than those in this report, and are based
on what is frequently referred to as the "5-cycle" test procedures, because the final results are
based on five different test
procedures. The 5-cycle
procedures include tests that
capture the impacts of aggressive
driving, cold temperatures, and
hot temperatures with air
conditioning operating, among
other factors. None of these
factors are reflected in the 2-cycle
tests used to determine
compliance with CAFE and GHG
standards.
Credits are expressed throughout
this report in units of metric tons,
also known as Megagrams (Mg).
However, in order to present the
impact of these credits in terms
that might be more
understandable to some readers,
in a number of places we have
calculated and presented a gram
per mile equivalent value. Where
such a value in a table applies to a
How We Determine a Grams/Mile Equivalent from Megagrams (Metric
Tons) of Credits/Deficits
The Megagrams (Mg) of credits or deficits are determined from a value
expressed in grams/mile. For example, fleet average credits/deficits are
based on the difference between the fleet standard and the fleet average
performance, each of which is expressed in grams/mile. The general form
of the equation is:
Credits[Mg] = ( C02 x VMT x Production ) / 1,000,000
C02 represents the credits in grams per mile. VMT is the total lifetime
miles, which we specified in the regulations as 195,264 miles for cars and
225,865 for trucks. Production represents the production volume to which
the C02 credit applies.
The C02 equivalent of a credit value expressed in Mg is derived by
reversing the equation as follows:
C02[grams/mile] = ( Credits[Mg] x 1,000,000 ) / ( VMT x Production )
When using this equation to calculate C02 grams/mile for aggregate car
and truck credits, we use a VMT value a weighted average of the VMT car
and truck value. For example, for the entire 2012 model year fleet covered
by this report, the weighted VMT is 206,916 miles. The weighting is by the
proportion of cars or trucks relative to the total fleet. The weighting might
be manufacturer-specific or for the entirety of the 2012 fleet, depending
on the data presented in each table.
"Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975 Through
2013," U.S. EPA-420-R-13-011, Office of Transportation and Air Quality, December 2013. See
http://epa.gov/otaq/fetrends.htm.
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specific manufacturer, the gram per mile value represents the impact of credits on the fleet of
that specific manufacturer, whereas the Total or Summary rows of tables display the gram per
mile impact of the total credits across the entire 2012 model year fleet of cars and trucks,
whichever may be applicable. Finally, this report does not attempt to summarize or explain all of
the elements or details of EPA's GHG program. Readers should consult EPA's final regulations
and supporting documents for additional information.20
1.3 How can CO2 emissions credits be used?
The ability to earn and bank credits, including early credits, is a fundamental aspect of the
program design intended to give manufacturers flexibility 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. Credits represent surplus emission reductions that manufacturers
achieve beyond those required by regulation under EPA's program. 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 allows additional flexibility, encourages earlier introduction 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 traded 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 still held by a manufacturer after
the 2014 model year will expire and be forfeited. 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.21
20 All of the background documents for EPA's GHG regulations are available on EPA's website at
http://www.epa.gov/otaq/climate/regs-light-dutv.htm.
21 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 from which early credits could be generated are less stringent
than the comparable CAFE standards in effect for that model year.
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1.4 Which manufacturers and vehicles are included in this report?
The vast majority of manufacturers producing cars and light trucks for U.S. sale are covered by
EPA's GHG program and are included in this report. However, there are some exceptions, as
explained below.
1.4.1 Small Businesses
Small businesses are exempt from EPA's GHG standards given that these businesses would face
unique challenges in meeting EPA's GHG standards. However, the program allows small
businesses to waive their exemption and voluntarily comply with the GHG standards. For the
purpose of this exemption, a small business is defined using the criteria of the Small Business
Administration (SBA). For vehicle manufacturers, SBA's definition of a small business is any
firm with less than 1,000 employees. These businesses account for less than 0.1 percent of the
total car and light truck sales in the U.S., thus this exemption has a negligible impact on overall
GHG reductions.
1.4.2 Small Volume Manufacturers
Similar to small businesses, some very small volume manufacturers (i.e., manufacturers with
limited product lines and production volumes that do not meet the SBA definition of a small
business) would likely find the GHG standards to be extremely challenging and potentially
infeasible. Given the unique feasibility issues faced by these manufacturers, EPA deferred
establishing CO2 standards for model years 2012-2016 for manufacturers with annual U.S. sales
of less than 5,000 vehicles. This deferment is a conditional exemption for these manufacturers
for which EPA approval must be requested and granted, not a blanket automatic exemption.22
As part of a request for a conditional exemption, which must be done for each model year,
eligible manufacturers must demonstrate good faith efforts to attempt to secure GHG credits to
the extent credits are reasonably available from other manufacturers. Credits, if available, would
be used to offset the difference between a company's baseline emissions and what their
obligations would be under the GHG footprint-based standards. Three manufacturers - Aston
Martin, Lotus, and McLaren - requested and received a conditional exemption for the 2012
model year. Because the 2012 model year is the first model year of the program, and because
companies seeking conditional exemptions were required to submit their requests to EPA prior to
the start of the 2012 model year, it is not surprising that a credit market had not yet developed,
despite inquiries made by these three companies of manufacturers that were holding credits. The
only manufacturers with any credits at the time were those with optional early credits, and most
were likely awaiting the conclusion of the 2012 model year to better evaluate their ability to sell
credits. Since then, however, it has become clear that some manufacturers are willing to sell
credits, and we have seen a number of credit transactions take place, as described in Section 4 of
this report. As a consequence, EPA expects small volume manufacturers may be able to purchase
credits and use them to comply with the standards in the 2013 and later model years. However,
22 The deferment applies only to the fleet average CO2 standards; these manufacturers are required to meet the
applicable nitrous oxide (N2O) and methane (CH4) emission standards.
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because of their conditionally exempt status for the 2012 model year, these manufacturers are not
included in this report.23
1.4.3 Operationally Independent Manufacturers
Some manufacturers, even though they may be wholly or largely owned by another
manufacturer, consider themselves to be "operationally independent" from the company that
owns them. EPA's GHG program contains provisions that allow these manufacturers to seek
separate and independent treatment under the GHG standards, rather than be considered as part
of their parent company. Manufacturers wishing to obtain operationally independent status are
required to submit very detailed information to EPA regarding their business structure, financial
operations, manufacturing operations, and management structure. The information in an
application for operationally independent status must also be verified by an independent third
party qualified to make such evaluations. Ferrari, which is owned by Fiat, petitioned EPA for
operationally independent status, and EPA granted this status to Ferrari starting with the 2012
model year. As an operationally independent manufacturer with a low U.S. sales volume (1,510
2012 model year cars), Ferrari has the same options as the three small volume manufacturers
discussed above, and could petition for a conditional exemption. Ferrari was successful in
purchasing a sufficient volume of credits from other manufacturers to offset their 2012 model
year deficit, as described Section 4.
1.4.4 Hyundai and Kia
On November 2, 2012, EPA announced that Hyundai and Kia would lower their fuel economy
label estimates for many vehicle models as the result of an EPA investigation of test data.
Hyundai and Kia submitted corrected fuel economy and CC>2 emissions data to EPA for the
2011-2013 model years and re-labeled many of their model year 2012 and 2013 vehicle models
on the market. For the changes in fuel economy label values for individual vehicles, see
http://www.epa.gov/fueleconomy/labelchange.htm. Since EPA's investigation into Hyundai and
Kia data is continuing, Hyundai and Kia-specific values are excluded from the tables in this
report. These companies have submitted 2012 model year reports, as required, but because of the
possibility that the outcome of EPA's investigation could impact the credits accrued by these
companies, the credit values and fleet performance of these companies are not being reported.
These companies will appear in future reports after the conclusion of EPA's investigation.
1.4.5 Aggregation of Manufacturers
We refer throughout this report to the names of manufacturers at the highest aggregated level,
and it may not necessarily be readily apparent who owns who and which brands or
manufacturers are included in the results of a given manufacturer. Table 1.4.5-1 shows how
manufacturers are aggregated based on the ownership relationships and vehicle partnerships in
the 2012 model year.
23 Conditional exemptions are available only through the 2016 model year, after which manufacturers must comply
with the GHG program standards or petition EPA for alternative manufacturer-specific GHG standards. The three
manufacturers noted here have already submitted applications requesting alternative standards, and EPA is in the
process of reviewing those applications.
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Table 1.4.5-1. Aggregation of Manufacturers in the 2012 Model Year
Manufacturer Manufacturers and Brands Included
BMW BMW, Mini, Rolls-Royce
Chrysler Chrysler, Dodge, Fiat, Jeep, Maserati, Ram, VW Routan minivan
Ford Ford, Lincoln
General Motors Buick, Cadillac, Chevrolet, GMC, Saab 9-4x
Honda Acura, Honda
Mercedes-Benz Maybach, Mercedes-Benz, Smart
Toyota Lexus, Scion Toyota
Volkswagen24 Audi, Bentley, Bugatti, Lamborghini, Volkswagen
24 In 2009 Volkswagen acquired 49.9 percent of Porsche, then in 2012 purchased the remaining 51.1 percent,
resulting in Volkswagen's full ownership of Porsche. EPA regulations allow for a reasonable transition period in the
case of mergers such as this, requiring that Volkswagen AG (including Porsche) meet the GHG standards as a single
entity "beginning with the model year that is numerically two years greater than the calendar year in which the
merger/acquisitions(s) took place." This means that Porsche will be considered a separate entity under the GHG
program for the 2012 and 2013 model years, and in 2014 will be considered part of Volkswagen AG.
7
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2 Optional Early GHG Credits from 2009-2011 Model Years
One of flexibilities in the GHG program 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 was 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.
Early credits were 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 "2-cycle" test procedures, and introduction of advanced technology vehicles
(i.e., electric, fuel cell, and plug-in hybrid electric vehicles). The optional early credits program
allowed manufacturers to select from four pathways that provided opportunities for early credit
generation through over-compliance with a fleet average CC>2 level specified by EPA in the
regulations. Manufacturers wishing to earn early credits selected one of these four pathways, and
the selected pathway was followed for the three model years of 2009-2011. Since EPA's GHG
standards did not begin until model year 2012, EPA established fleet average thresholds below
which manufacturers were able to generate early fleet average credits. For two of the pathways,
the emission levels below which credits were available were equivalent to the GHG standards
established by California prior to the adoption of the EPA GHG program. Two additional
pathways included credits based on over-compliance with CO2 levels equivalent to the CAFE
standards in states that did not adopt the California GHG standards. In March of 2013, EPA
released a report documenting manufacturers' use of the early credit provisions allowed under
the GHG program (the "early credits report").25
Table 2-1 summarizes the credits (or deficits) reported by manufacturers in each of the three
model years for each participating manufacturer and shows the total net early credits for each
manufacturer. The early credits program required that participating manufacturers determine
fleet average credits for each of the three model years under their selected pathway, and that they
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 was a positive value. Other than Hyundai and Kia, both of which generated early credits
but which are excluded from this report, manufacturers not listed in Table 2-1 chose not to
participate in the early credits program. Additionally, this table is intended to show the credits
reported by manufacturers in these years and does not include the impacts of any credit banking
or trading on credit balances. In particular, the sale of some early credits by some manufacturers,
as discussed later in this report, while not shown in Table 2-1, will affect the available credit
balances of the manufacturers involved in such transactions, as will the use of early credits to
25 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, Report No. EPA-420-R-13-005, March 2013.
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offset 2012 model year deficits. Table 2-2 shows the total early credits reported by each
participating manufacturer, broken down by the type of credit reported. Note that the early
credits program did not include credits for flexible-fuel vehicles, whereas in the 2012 model year
the fleet average credit category does include these credits.
Table 2-1. Early Credits, by Manufacturer and Model Year (Mg)
Manufacturer
BMW
Chrysler
Ford
General Motors
Honda
Mazda
Mercedes-Benz
Mitsubishi
Nissan
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Total
2009
409,854
5,926,979
8,252,113
13,009,374
14,073,890
1,405,721
96,467
625,166
10,496,712
1,620,769
448,408
-
31,325,738
2,243,205
204,460
90,138,856
2010
280,450
4,833,763
7,093,702
11,073,134
14,070,290
3,201,708
124,120
521,776
5,781,739
2,225,296
329,382
35,580
34,457,797
2,811,663
359,436
87,199,836
2011
194,599
(1,650,535)
(49,379)
482,321
7,370,928
875,213
157,685
302,394
1,852,749
1,909,106
98,860
14,192
14,482,654
1,386,537
176,462
27,603,786
Total
884,903
9,110,207
15,296,436
24,564,829
35,515,108
5,482,642
378,272
1,449,336
18,131,200
5,755,171
876,650
49,772
80,266,189
6,441,405
740,358
204,942,478
Notes:
(1) The early credits program did not allow credits from flexible fuel vehicles, thus no such credits are
reflected in this table.
(2) Some of the values in this table will not match those reported in EPA's March 2013 report because of
errors that were discovered and corrected after the March 2013 report was released.
Table 2-2. Total Reported Early Credits, By Credit Source
Credit Source
Fleet Average*
A/C Leakage
A/C Efficiency
Off-Cycle
Advanced Technology Vehicles
Total
Credits (Mg)
174,340,347
22,368,872
8,227,627
5,632
0
204,942,478
Percent of Tola l(%)
85.1
10.9
4.0
0.0
0.0
100.0
* Fleet average credits in the early credits program do not include credits from
flexible fuel vehicles.
Early credits from advanced technology vehicles are not specifically identifiable. In these early
credit years, manufacturers producing advanced technology vehicles had two options available to
them. They could simply incorporate these vehicles into their fleet averaging in the relevant
model year (2009-2011), using zero grams per mile to represent the operation using grid
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electricity (see the discussion of advanced technology vehicles in Section 3.4 for more
information regarding this incentive). Alternatively, the program provides an option for
manufacturers to exclude them from their fleet average in the 2009-2011 model years and
essentially carry the vehicles forward into a future model year, where they must be used to offset
a GHG deficit. General Motors and Mercedes-Benz chose the latter approach, while Nissan
chose the former approach for their production of the Leaf electric car. Tesla, the only other
manufacturer with qualifying vehicles, obviously used the former approach and generated credits
in the 2010 and 2011 model year (carrying vehicles into a future model year would serve them
no purpose since those vehicles have to be used to offset a deficit, and as a manufacturer solely
of electric vehicles, Tesla will never accumulate a deficit). These credits are discussed in more
detail in Section 3.4, which also presents production volumes of advanced technology vehicles
for the 2009-2012 model years.
Finally, because of the fluid nature of credits from one year to the next, the March 2013 early
credits report should serve as an historical reference based on performance at the end of the 2011
model year. This subsequent report regarding the 2012 model year, and the accompanying data
for the 2009-2012 model years, should be used as the references from which to determine credit
balances and overall performance at the conclusion of the 2012 model year.
10
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3 Credits Reported From the 2012 Model Year
The mandatory compliance calculations that manufacturers must perform are (1) to determine
whether or not they comply with manufacturer-specific, vehicle footprint-based CC>2 standards,
and (2) to demonstrate compliance with N2O and CH4 exhaust emission standards. Compliance
with fleet average CO2 standards must be done separately for car and truck fleets at the end of
each model year, using emission standards and fleet average values determined based on the
actual production volumes of the model year. Compliance with N2O and CH4 standards is
typically done in conjunction with emission tests for other pollutants, although there are
additional options as described later in this report.
Manufacturers have several options to generate additional credits as part of their overall strategy
to meet the standards. There are two distinct types of credit programs within the GHG program.
One type of credit directly lowers a manufacturer's actual fleet average by virtue of being
applied within the methodology for calculating the fleet average emissions. Examples of this
type of credit include the credits available for flexible fuel vehicles and the advanced technology
vehicle provisions that allow use of zero grams/mile for electric operation. Using this type of
credit directly affects (lowers) a manufacturer's fleet average tailpipe emissions, and thus the
fleet average calculation will be improved (i.e., by further increasing fleet average-based credits,
or by eliminating a fleet average-based deficit that might otherwise be accrued). The second type
of credit is independent of the calculation of a manufacturer's fleet average tailpipe values.
Rather than giving credit by improving a manufacturer's fleet average via a credit mechanism,
these credits (in megagrams) are calculated separately and are simply added to the
manufacturer's overall "bank" of credits (or deficit, thereby reducing the deficit). This second
type of credit includes credits for improvements to air conditioning system refrigerant leakage
and/or efficiency, and implementation of technologies that reduce CO2 emissions over driving
conditions not captured by the test procedures used for compliance with the CC>2 standards (i.e.,
"off-cycle" reductions).
In the 2012 model year, manufacturers reported total credits of almost 39 million Mg. About 40
percent of these were accrued through the use of the optional credit programs for air conditioning
systems, indicating a significant, real-world benefit as a result of the introduction of the
technologies underlying these optional credit programs. Table 3-1 summarizes all the credits
reported as earned in the 2012 model year, by the type of credit. Table 3.1 also reports a gram
per mile equivalent of the credits, which are expressed in Mg. The credits are expressed in
Megagrams (or, metric tons) because values in Megagrams can be determined for car and truck
categories using a methodology that accounts for the differences in lifetime mileage, and thus
results in a credit unit value that can be traded and transferred across categories without further
adjustment. Credits expressed in grams per mile are not as easily transferrable and would require
complicated adjustments in the event of transfers, and rather than try to manage and verify these
calculations for every credit transfer, EPA chose to define credits in units that can be free of such
calculations. A one gram per mile CC>2 reduction on a truck, for example, is worth more to the
environment because trucks are driven more miles than cars, as reflected in the lifetime mileage
values that EPA uses to determine the credits in Megagrams. To determine the gram per mile
equivalents of the Megagram values in Table 3-1, a weighted vehicle miles traveled (VMT)
value was calculated by weighting the car and truck VMT values used by the regulation (195,264
11
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and 225,865 miles for cars and trucks, respectively) by the actual proportions of cars and trucks
in the 2012 fleet (62 and 38 percent, respectively).
Table 3-1. Total Reported Credits for the 2012 Model Year, By
Credit Source
Credit Source
Fleet Average*
A/C Leakage
A/C Efficiency
Off-Cycle
Total
Credits (Mg)
23,143,347
10,316,338
5,202,895
5,822
38,668,402
Grams/Mile Equivalent
9.1
4.0
2.0
0.0
15.2
* Fleet average emissions include the effect of FFVs, which under the regulations are
part of the fleet average calculation. The independent impact of FFVs is described in
Section 3.1.3.
As seen in Table 3-1, the gram per mile equivalent values indicate what appears to be an industry
"over-compliance" with the CC>2 standards by about 15 grams/mile. However, Table 3-1 reports
only credits that were earned; the actual industry over-compliance is based on net credits, thus
taking into account any deficits that were also generated in the model year. Some manufacturers
failed to meet their 2012 model year CO2 standards in either one or both of their fleets (car and
truck), and thus generated fleet average deficits for the 2012 model year, which are not reported
in Table 3-1, but are shown in Table 3-2 (these are the existing deficits before the use of credits
carried over from a prior model or of purchased credits). Also not reported in Table 3-1 are
deficits generated as a result of manufacturers' use of alternative N2O and CH4 exhaust emission
standards, which must be offset with CO2-equivalent credits (taking into account the differing -
and higher - global warming potential of these emissions). Table 3-2 shows the total deficits (or
negative credits) reported by the industry in the 2012 model year, in Megagrams and a
grams/mile equivalent.
26 Car and track production volumes are shown in tables in Section 3.1.1. As noted earlier, Hyundai and Kia data.
including production volumes, are excluded from the analysis in this report. If their production volumes were
included, the proportions of cars and tracks would be 64 and 36 percent, respectively.
12
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Table 3-2. Total Reported Deficits for the 2012 Model Year, By
Deficit Source
Deficit Source Deficit (Mg) Grams/Mile Equivalent
Fleet Average*
N2O Alternative Standards
CH4 Alternative Standards
Total
(13,058,365)
(320,723)
(236,146)
(13,615,234)
(5.1)
(0.1)
(0.1)
(5.3)
* Fleet average emissions include the effect of FFVs, which under the regulations are
part of the fleet average calculation. The independent impact of FFVs is described in
Section 3.1.3.
The deficits reported by manufacturers combined with the credits result in total net credits for the
2012 model year of about 25 million Mg, as shown in Table 3-3 (the sum of values from Tables
3-1 and 3-2), yielding a net industry over-compliance with the 2012 model year CC>2 standards of
about 10 grams/mile. For the summary purposes of Table 3-3, the tailpipe CC>2 and FFV credits
(as described in Section 3.1.3) are shown separately, whereas they are combined in the previous
two tables. For additional simplicity the two categories of air conditioning credits are combined
into a single row, and the N2O and CFLi deficits are similarly combined. Thus, across the fleet,
manufacturers over-complied with the 2012 standards by about 10 g/mi, indicating that
consumers purchased vehicles with lower GHG emissions than were needed to meet the 2012
model year standards. The over-compliance of 10 g/mi indicates that CO2 tailpipe emissions
overall were about 5 g/mi better than the projections that EPA made in 2010.
Table 3-3. Total Net Credits for the 2012 Model Year, By Credit
Source
Credit Source
Tailpipe C02
Flexible Fuel Vehicles (FFV)
A/C Leakage & Efficiency
Off-Cycle
N2O & CH4 Deficits
Total
Credits (Mg)
(12,396,998)
22,481,980
15,519,223
5,822
(556,869)
25,053,168
Grams/Mile Equivalent
(4.9)
8.8
6.1
0.0
(0.2)
9.8
3.1 Credits Based on Fleet Average Tailpipe GHG Emissions
Fleet average CO2 credits are based on the difference between the applicable footprint-based
CC>2 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
27 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final
Rule, Federal Register 75 (7 May 2010): 25324-25728. See Table I.B.2-4, page 25331.
13
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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} = -
Fleet average credits are earned by a manufacturer's fleet that performs better than the applicable
fleet average exhaust emission standard. Manufacturers calculate their fleet average standards
(separate standards are calculated for cars and trucks) using the footprint-based equations
established in the regulations. A manufacturer's actual end-of-year fleet average is calculated
similarly to the way in which CAFE values are calculated. First, manufacturers determine a CO2-
equivalent value for each vehicle model type based on laboratory testing over the EPA city and
highway test cycles. The C (^-equivalent value is a summation of the measured carbon-
containing constituents of the exhaust emissions on a CO2-equivalent basis. For gasoline and
diesel vehicles this simply involves measurement of total hydrocarbons and carbon monoxide in
addition to CC>2.28 Second, manufacturers calculate a fleet average by weighting the CC>2 exhaust
emissions for each model type by the production of that model type, as they do for the CAFE
program. Again, this is done separately for cars and trucks. Finally, the manufacturer will
compare its calculated standard with the fleet average CO2 exhaust emissions performance that is
actually achieved to determine the credits (or debits) that are generated, using the equation
above. Both the determination of the applicable standard and the actual fleet average
performance is done after the model year is complete and using final model year vehicle
production data. Because manufacturers enter all the data necessary for these calculations into
EPA's compliance data system (known as "Verify"), and because the data system performs these
calculations, EPA has confidence that the calculations are being performed correctly and can be
checked against the manufacturers' calculated results.
Manufacturers reported net fleet average credits totaling about 10 million Mg across the entire
2012 fleet, as shown in Table 3.1-1. These credits and deficits are based strictly on the exhaust
emissions performance of each model as measured on EPA's City and Highway test procedures,
and do not include the impact of air conditioning, credit transactions with other companies, and
other optional credits (some of which are integral to the compliance strategy of some
manufacturers). The fleet average credits discussed in this section also include credits resulting
from the production of flexible-fuel vehicles. The credit for these vehicles is based on an
adjustment to the exhaust emission test results, and thus the resulting credits become part of the
fleet average calculation. Section 3.1.3 discusses the impact of flexible-fuel vehicles and breaks
out their impact from the overall fleet average credits described in this section. It is important to
note that this table, and the discussion in this section, relate only to fleet average credits and
deficits (i.e., the credits resulting from comparing the fleet average exhaust emission test results
- including flexible-fuel vehicles - to the calculated footprint-based CC>2 standard), and thus do
not illustrate the final 2012 model year cumulative performance of the manufacturers. A
28 The calculation becomes somewhat more complex for alternative fuel vehicles due to the different nature of their
exhaust emissions. For example, for ethanol-fueled vehicles, the emission tests must measure ethanol, methanol,
formaldehyde, and acetaldehyde in addition to CO2.
14
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manufacturer's final position at the end of the model year includes all additional credits from the
optional credit programs and/or from credit transactions.
As Table 3.1-1 shows, for the 2012 model year alone about half of the companies generated net
fleet average credits, while the remaining half accumulated net deficits in 2012. Overall across
the industry the car fleet created net industry credits in the 2012 model year, although only half
the manufacturers were responsible for more than offsetting the deficits of the others to create
more than 17 million Mg of credits in the car fleet. Note that three manufacturers (Ford, Honda,
and Toyota) were responsible for 90 percent of the total car credits that were accumulated. A
different story emerged in the truck fleet, however, where the majority of manufacturers reported
deficits, leading to an industry overall net deficit in the light truck sector.
Table 3.1-1. Reported Fleet Average Credits by Manufacturer and Fleet, 2012 Model Year
Fleet Average Credits (Mg)
Manufacturer
Tesla
Coda
Fisker
Porsche*
Toyota
Honda
Mazda
Subaru
Ford
Mitsubishi
General Motors
Nissan
Volkswagen
BMW
Chrysler
Suzuki
Volvo
Mercedes-Benz*
Jaguar Land
Rover*
Ferrari*
Total
Car
175,231
5,524
46,694
23,163
10,898,641
5,316,314
749,725
62,183
2,672,261
(10,139)
0
875,054
(977,667)
(298,604)
(1,052,252)
(78,937)
(255,674)
(939,200)
(29,920)
(43,932)
17,138,465
Truck
0
0
0
175,185
(489,377)
1,448,784
(14,838)
481,133
0
67,976
(1,033,479)
(2,248,843)
(43,964)
(401,613)
(4,045,226)
(48,762)
(79,002)
(338,423)
(483,034)
0
(7,053,483)
Grams/Mile
Equivalent of Total
Total Credits
175,231
5,524
46,694
198,348
10,409,264
6,765,098
734,887
543,316
2,672,261
57,837
(1,033,479)
(1,373,789)
(1,021,631)
(700,217)
(5,097,478)
(127,699)
(334,676)
(1,277,623)
(512,954)
(43,932)
10,084,982
304.0
246.0
169.0
31.8
25.0
21.4
13.0
9.4
7.3
4.5
(2.1)
(5.5)
(9.1)
(13.4)
(15.4)
(20.3)
(22.5)
(24.4)
(43.0)
(149.0)
4.0
* These companies
stringent standards
used a temporary program that allowed all or part of their fleet to be subject to less
, See Section 3.1.2.
As noted above, only a few manufacturers accounted for a majority of the credits generated in
the overall car fleet. Table 3.1-2 shows the top five generators of car credits, indicating that these
five manufacturers accounted for 99 percent of the total car credits generated by the industry in
15
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the 2012 model year. Note that this table illustrates that a larger quantity of credits does not
necessarily imply that a manufacturer has achieved better performance relative to its unique,
manufacturer-specific footprint-based fleet average CO2 standard. This is because the credits are
based on production volume; thus, a relatively small number of credits can mean very good
performance relative to the standards. For example, while Mazda accounts for only four percent
of the reported fleet average credits on a per vehicle basis, Mazda over-complied significantly
with an 18 grams/mile per vehicle car credit.
Table 3.1-3 shows the four manufacturers that generated credits in the truck fleet. Honda
generated almost three quarters of the 2012 model year truck credits, while Subaru almost made
up the remaining quarter, with Mitsubishi accounting for several percent and Ford "breaking
even" on their trucks (meaning that their fleet average performance matched their calculated
footprint-based CO2 standard). Tables 3.1-2 and 3.1-3 exclude those manufacturers meeting
alternative less stringent standards as described in Section 3.1.2.
Table 3.1-2. Total 2012 Model Year Fleet Average Car Credits - Top Five
Manufacturers in Primary Program
Manufacturer
Toyota
Honda
Ford
Nissan
Mazda
Total
Fleet Average
Credits (Mg)
10,898,641
5,316,314
2,672,261
875,054
749,725
20,511,995
Percent of Total
Car Credits
52%
26%
13%
4%
4%
99%
Grams/Mile
Equivalent for
Car Fleet
43.0
26.0
13.0
5.0
18.0
N/A
Table 3.1-3. Total 2012 Model Year Fleet Average Truck Credits - All
Manufacturers in Primary Program
Manufacturer
Honda
Subaru
Mitsubishi
Ford
Total
Fleet Average
Credits (Mg)
1,448,784
481,133
67,976
-
1,997,893
Grams/Mile
Percent of Total Equivalent for Car
Truck Credits
73%
24%
3%
0%
100%
Fleet
13.0
13.0
24.1
0.0
N/A
Further details regarding fleet average credits are provided later in this report. In particular, while
Table 3.1-1 shows the broad picture of manufacturers' compliance with fleet average exhaust
standards (including the impact of flexible-fuel vehicle credits), there are some important
underlying details. For example, several manufacturers made use of the Temporary Lead-time
Allowance Alternative Standards (TLAAS) program, which allows some lower volume
16
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manufacturers to apply less stringent standards to a limited number of vehicles in the early model
years of the program. These manufacturers, their credits, and the limitations of the TLAAS
program are discussed in Section 3.1.2. And, as noted above, Table 3.1-1 is simply a reflection of
how well manufacturers did in meeting their footprint-based fleet average standards without the
application of additional credits from air conditioning, off-cycle technologies, or credit
purchases.
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 manufacturer-specific fleet
average emission standards and the reported fleet average performance for each manufacturer.
3.1.1 Manufacturers in the Primary Standards Program
The fleet average credits described above were generated by manufacturers complying with
different sets of emission standards as allowed under the regulations. Most manufacturers are
required to comply with the "primary" emission standards, meaning those that are the default
mandatory standards in the regulations. Several manufacturers qualify for an alternative, less
stringent set of standards, known as the Temporary Lead-Time Allowance Alternative Standards
(TLAAS). For the 2012 model year, the primary standards program includes vehicles from all
manufacturers except Ferrari and Porsche, both of which assigned all of their 2012 production
into the TLAAS program. Two other manufacturers with vehicles in the TLAAS program -
Jaguar-Land Rover and Mercedes-Benz - also have vehicles within the Primary program, and
these Primary program vehicles are shown in Table 3.1.1-1. The compliance of these
manufacturers and a more detailed description of the TLAAS program is in the following
section. Table 3.1.1-1 lays out the details of fleet average credits and deficits accumulated by
manufacturers with vehicles in the primary standards program. As described in the following
section, the TLAAS program is available only to a limited number of lower volume
manufacturers who qualify for the program based on 2009 model year sales volumes. Most
manufacturers do not qualify for the TLAAS program, and must demonstrate compliance with
the base primary program as described in the regulations.
At the end of each model year, manufacturers perform two significant calculations, the results of
which are displayed in Table 3.1.1-1. Using the vehicle footprint equations and the specified
parameters in the regulations that define the footprint "curves" (which are graphically displayed
in Figure 3.1.1-1 for the 2012 model year), manufacturers must determine the CC>2 fleet average
standard applicable to each vehicle category (car and truck). Each standard is a post-model year
sales-weighting of the CO2 values (as described by the footprint target curves shown in Figure
3.1.1-1) for all of the footprint values in a manufacturer's fleet. Manufacturers also determine a
fleet average CO2 value, reflecting their actual performance for a model year and separately for
cars and trucks, by weighting the CC>2 emissions value for each model by the sales of that model.
Finally, using these emission values coupled with the production volume for each vehicle
category (shown in Table 3.1.1-1), fleet average based credits or deficits are calculated using the
equation specified in Section 3.1. The resulting values include FFV credits, but do not include air
conditioning and other credits and therefore are not final compliance values. The CC>2 standards
and fleet average values shown in the bottom row of Table 3.1.1 are production-weighted
averages of the manufacturer-specific values.
17
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Figure 3.1.1-1. 2012 Model Year Footprint Target Curves
400
375
200
40
45 50 55 60
Footprint (square feet]
65
70
18
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Table 3.1.1-1. Reported Fleet Average Credit Detail for Manufacturers with Primary Program Fleets, 2012 Model Year
Car
Manufacturer
BMW
Chrysler
Coda
Fisker
Ford
General
Motors
Honda
Jaguar Land
Rover
Mazda
Mercedes-
Benz
Mitsubishi
Nissan
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Total
CO2
Standard
(g/mi)
269
111
246
315
265
111
263
N/A
259
271
261
263
260
251
304
264
263
111
Average
(g/mi)
277
287
0
146
252
111
237
N/A
241
298
262
258
257
267
0
221
273
297
Production
Volume
191,154
538,887
115
1,415
1,052,721
1,449,244
1,047,165
N/A
213,308
163,247
51,927
896,278
106,152
25,266
2,952
1,298,021
500,690
52,375
7,590,917
Credits (Mg)
(298,604)
(1,052,252)
5,524
46,694
2,672,261
0
5,316,314
N/A
749,725
(860,659)
(10,139)
875,054
62,183
(78,937)
175,231
10,898,641
(977,667)
(255,674)
17,267,695
Truck
C02
Standard
(g/mi)
336
345
N/A
N/A
364
369
333
316
323
335
307
337
309
325
N/A
342
327
325
Average
(g/mi)
363
363
N/A
N/A
364
374
320
303
324
368
283
367
296
361
N/A
345
330
343
Production
Volume
65,856
994,996
N/A
N/A
701,602
915,130
493,414
9,086
65,696
61,343
12,540
331,886
163,860
5,997
N/A
722,227
64,882
19,432
4,627,947
Credits (Mg)
(401,613)
(4,045,226)
N/A
N/A
0
(1,033,479)
1,448,784
26,679
(14,838)
(457,223)
67,976
(2,248,843)
481,133
(48,762)
N/A
(489,377)
(43,964)
(79,002)
(6,837,755)
Total
Production
Volume
257,010
1,533,883
115
1,415
1,754,323
2,364,374
1,540,579
9,086
279,004
224,590
64,467
1,228,164
270,012
31,263
2,952
2,020,248
565,572
71,807
12,218,864
Credits (Mg)
(700,217)
(5,097,478)
5,524
46,694
2,672,261
(1,033,479)
6,765,098
26,679
734,887
(1,317,882)
57,837
(1,373,789)
543,316
(127,699)
175,231
10,409,264
(1,021,631)
(334,676)
10,429,940
Note: This table shows only the inputs and results of the fleet average credit calculation. It does not include credits from air conditioning or other
programs and does not completely represent either the cumulative performance of a manufacturer in the 2012 model year or their final status at the
end of the model year.
19
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3.1.2 Manufacturers in the TLAAS Program
EPA established the Temporary Lead-time Alternative Allowance Standards (TLAAS) to assist
manufacturers with limited product lines that may be especially challenged in the early years of
EPA's GHG program. Manufacturers with narrow product offerings may not be able to take full
advantage of averaging or other program flexibilities due to the limited scope of the types of
vehicles they sell, and they may need additional lead time.
The TLAAS program applies only to manufacturers with 2009 model year U.S. sales of less than
400,000, and, except as noted below, is available during the 2012-2015 model years. Under this
program, a manufacturer is allowed to treat a portion of its fleet as a separate averaging fleet to
which a less stringent CC>2 standard applies. Specifically, a qualifying manufacturer may put up
to 100,000 vehicles (combined cars and trucks) under the less stringent standards over the four
model years from 2012 through 2015 (this is a total allowance, not an annual allowance). The
CC>2 standard applied to this limited fleet is 1.25 times the standard that would otherwise be
calculated for the fleet under the primary program (i.e., the TLAAS standard is 25 percent
higher). Manufacturers with 2009 model year U.S. sales between 5,000 and 50,000 vehicles are
allowed an additional 150,000 vehicles (for a total of 250,000), and can extend the program
through the 2016 model year (for a total eligibility of five model years).
All manufacturers participating in the TLAAS program are subject to a number of restrictions
designed to ensure only those manufacturers that truly need it use it. Under the TLAAS program
manufacturers may not sell credits, they may not bank credits that are achieved by their non-
TLAAS fleets, they must use up any banked credits before utilizing a TLAAS fleet, and the
movement of credits between a participating manufacturer's TLAAS and non-TLAAS fleets is
restricted.
The fleet average details for manufacturers participating in the TLAAS program are shown in
Table 3.1.2-1. There are four possible fleets for emissions averaging and credit or deficit
calculation under the TLAAS program: both cars and trucks in either the Primary or TLAAS
program. Manufacturers employed a variety of strategies in the use of the TLAAS standards.
Jaguar-Land Rover placed all of their cars and about 75 percent of their trucks in TLAAS fleets,
using almost half of their initial allocation of 100,000 vehicles. Mercedes-Benz, with higher
production volumes of cars and trucks than the other manufacturers using the TLAAS standards,
limited their TLAAS fleets to about one third of the allowed allocation of 100,000 vehicles,
leaving them room to continue use of the TLAAS standards in upcoming model years. Ferrari
and Porsche, with the lowest production volumes of these four participating manufacturers,
placed all of their vehicles under the TLAAS standards. Table 3.1.2-1 provides details for the
vehicles that these four manufacturers placed in TLAAS fleets. As noted earlier, both Mercedes-
Benz and Jaguar-Land Rover also have vehicles that are not subject to the less stringent TLAAS
standards and are instead subject to Primary program standards. Their Primary program vehicles
are included above in Table 3.1.1-1.
20
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Table 3.1.2-1. Reported Fleet Average Credit Detail for TLAAS Program Fleets, 2012 Model Year
Manufacturer
Ferrari
Jaguar Land
Rover
Mercedes-
Benz
Porsche
Total
Standard
(g/mi)
345
364
368
332
Average
(g/mi)
494
376
406
325
Car
Production
Volume
1,510
12,769
10,585
16,946
41,810
Credits (Mg)
(43,932)
(29,920)
(78,541)
23,163
(129,230)
Truck
Standard
(g/mi)
-
408
434
422
Average
(g/mi)
-
477
408
362
Production
Volume
-
32,706
20,230
12,927
65,863
Credits
(Mg)
-
(509,713)
118,800
175,185
(215,728)
Total
Production
Volume
1,510
45,475
30,815
29,873
107,673
Credits
(Mg)
(43,932)
(539,633)
40,259
198,348
(344,958)
21
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3.1.3 Flexible Fuel and Natural Gas Vehicle Credits
Unlike the optional credits reported in the following sections of this report, which are
independently calculated and separate from the fleet average credits, flexible fuel vehicles (FFV)
and compressed natural gas (CNG) vehicle credits are essentially built in to the fleet average
calculation and thus require some additional explanation and documentation. FFV credits are
included in the values shown in Sections 3.1.1 and 3.1.2, although they are not separately
identifiable in those sections. EPA's GHG program contains credits for flexible-fuel vehicles
(FFVs) and alternative fuel vehicles starting in the 2012 model year. FFVs are dual-fuel vehicles,
i.e., vehicles that can run both on an alternative fuel and conventional fuel. Most FFVs are E-85
vehicles, which can run on a mixture of up to 85 percent ethanol and the remainder gasoline.
Dedicated alternative fuel vehicles are vehicles that run exclusively on an alternative fuel (e.g.,
compressed natural gas).
EPA's GHG program requires that FFV and other, similar alternative fuel vehicle credits be
calculated as a part of the calculation of a manufacturer's overall fleet average greenhouse gas
exhaust emissions. Under the GHG program, EPA allows FFV credits corresponding to the
amounts allowed in the CAFE program under the statutory provisions, but only for the 2012 to
2015 model years. As with the CAFE program, the GHG program bases FFV credits on the
assumption that the vehicles would operate 50% of the time on the alternative fuel and 50% of
the time on conventional fuel, resulting in CC>2 emissions that are based on an arithmetic average
of alternative fuel and conventional fuel CO2 emissions. The CO2 emissions measurement on the
alternative fuel is multiplied by a 0.15 volumetric conversion factor. Through this mechanism a
gallon of alternative fuel is deemed to contain 0.15 gallons of gasoline fuel. Again, this approach
is only applicable for the 2012-2015 model years.
For example, for a flexible-fuel vehicle that emits 330 g/mi CC>2 while operating on E-85 and
350 g/mi CC>2 while operating on gasoline, the resulting CC>2 level to be used in the
manufacturer's fleet average calculation would be:
[(330 x 0.15) + 350]
CO2 = —^ =199.8 g/mi
L^
EPA realizes that by using the CAFE approach—including the 0.15 factor—the CC>2 emissions
value for the vehicle is calculated to be significantly lower than it actually would be otherwise,
even if the vehicle were assumed to operate on the alternative fuel at all times. This represents
the short-term "credit" being provided to FFVs. Under the GHG program, FFV credits are
available only through the 2015 model year; starting in model year 2016, EPA's GHG program
will allow FFV credits only based on a demonstration that the alternative fuel is actually being
used in the vehicles and the actual GHG performance for the vehicle run on that alternative fuel.
Similarly, the GHG credit for dedicated alternative fuel vehicles, such as those that use CNG, is
calculated by measuring the CO2 emissions and then multiplying those emissions by 0.15. Again,
this is a short-term credit that expires after the 2015 model year, at which point the GHG
performance becomes the actual measured emissions of the vehicle without adjustment. And, as
noted earlier, EPA's standards are predicated on the use of FFV credits in the early model years
of the program.
22
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In the 2012 model year the dual-fuel credit limit in the CAFE program is 1.2 mpg across a
manufacturer's fleet (dedicated alternative fuel vehicles are not subject to this limit on credits).
In other words, FFVs may not increase a manufacturer's average fuel economy by more than 1.2
mpg. To parallel the CAFE limitations, the GHG program contains a similar credit limit, but
calculated in CC>2 space based on each manufacturer's unique fleet average performance. EPA
chose this approach because of the non-linearity between mpg and CO2 emissions. For example,
a 1.2 mpg increase from a base of 15 mpg represents a CC>2 decrease of about 44 g/mi, while a
1.2 mpg increase from a base of 30 mpg represents a CO2 decrease of about 11 g/mi. Thus, the
CC>2 reduction that manufacturers may get from the FFV credits for a given fleet is limited to the
CO2 value comparable to 1.2 mpg and is calculated from a manufacturer's specific fleet average
performance.
As noted earlier, the FFV and CNG credits are included in the calculation of the fleet average
CO2 emission values. For example, Ford's fleet average for its car fleet of 252 g/mi as shown in
Table 3.1.1-1 includes these credits, i.e., without the FFV credit Ford's fleet average would be
higher than 252 g/mi. Seven manufacturers produced FFVs in the 2012 model year to varying
degrees, as shown below in Table 3.1.3-1. Clearly, Chrysler, Ford, and General Motors are
currently the most invested in ethanol as an alternative fuel, producing the overwhelming
majority of vehicles capable of operating on E85. Note that the number of models is based on
EPA's "model type" designation, and is not equivalent to "nameplate" as some might tend to
think of it. Generally speaking, a model type is a unique combination of a nameplate (e.g.,
Silverado), an engine (e.g., 6 cylinder), a drive system (e.g., 4 wheel drive), and a transmission
(e.g., 6-speed automatic). Thus a single nameplate that is offered with two engines, in both two-
and four-wheel drive, and in manual and automatic transmissions, will result in eight different
model types. For example, the four Nissan FFV models shown in Table 3.1.3-1 are made up of
two- and four-wheel drive versions of two nameplates, the Titan and the Armada. Most of these
manufacturers tended to focus their FFV production in the truck segment. Of General Motors' 80
FFV model types, only ten are cars. Six of Ford's 28 FFV model types are cars, as are seven of
Chrysler's 18 FFV model types. Nissan and Toyota's FFVs are exclusively trucks, while the
European companies tended to focus their limited number of FFVs in the car category.29
29 See the downloadable fuel economy data at http://www.fueleconomy.gov/feg/download.shtml.
23
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Table 3.1.3-1. Production of FFVs and CNG vehicles by Manufacturer, 2012
Model Year
Manufacturer
Chrysler
Ford
General Motors
Honda1
Mercedes-Benz
Nissan
Toyota
Volkswagen
Total
No. of
Models
18
28
80
1
6
4
2
5
151
FFV&
Cars
105,174
174,567
520,116
3,307
13,096
2,060
815,013
CNG Production
Trucks
453,399
323,430
511,141
8,289
24,154
31,670
1,352,083
Volume
Total
558,573
497,997
1,031,257
3,307
21,385
24,154
2,060
2,135,426
1 Honda is the only major manufacturer selling a mass-production CNG vehicle, the Civic
Natural Gas AT. All other vehicles in this table are gasoline-ethanol FFVs.
Table 3.1.3-2 shows the results of the calculations described above for each manufacturer with
FFV sales in the 2012 model year. Column B is the fleet average CO2 value calculated for each
fleet as if each FFV in that fleet is operated only on gasoline, i.e., the emissions value for each
FFV ignores operation on E85. This is the fleet value that represents no impact as a result of
FFVs. Column C is the fleet average CC>2 value that incorporates the full effect of the FFV
credits without any limitation, using the 0.15 factor for E85 CC>2 emissions and an even 50/50
weighting of this value with the gasoline CC>2 emissions value. However, because the EPA GHG
program limits the benefit that manufacturers can get from this FFV calculation, this column
does not necessarily represent the final fleet average for a manufacturer.
As described above, EPA requires that the benefit of FFVs be limited, as it is in the CAFE
program. This limit, which is based on a manufacturer's baseline value (Column B), is shown in
Column D. Thus, FFVs can allow a manufacturer to reduce their baseline emissions value by no
more than the amount in Column D. For example, if the benefit were not capped, General Motors
could reduce their truck fleet average CC>2 emissions by 100 g/mi (i.e., from 397 to 297 g/mi).
However, they are limited to a more modest reduction of 23 g/mi, leading to a final truck fleet
average of 374 g/mi. Chrysler, Ford, and General Motors have routinely maximized their FFV
benefit in the CAFE program, thus it is no surprise, given the parallel construct of the GHG
program, that this is also the case under the GHG program. These companies have, in fact, been
producing far more FFVs than are required to maximize the CAFE or GHG benefit. The
Japanese and European manufacturers, on the other hand, have not historically ventured into
FFV production to the extent that the Detroit-based companies have. For example, Toyota could
"claim" almost 18 g/mi of FFV credits, and yet their FFV sales only give them 9 g/mi, half of the
total amount they would be allowed under the regulatory limits. The total volume of credits
accounted for by FFVs is equivalent to 8.8 grams/mile across the entire 2012 model year fleet of
vehicles.
Note that reporting of FFV credits, like a number of aspects of the GHG program, could be
complicated by the use of the TLAAS program by some manufacturers. However, Mercedes-
24
-------
Benz (the only manufacturer using the TLAAS standards that produces FFVs) placed all of their
FFVs in the Primary fleets, and none in the TLAAS fleets. Thus their entries in Table 3.1.3-2
reflect only the vehicles in the Primary fleets. If they had placed FFVs in the TLAAS fleets, the
calculations would be essentially the same as for any other fleet, with the difference being a 25
percent less stringent standard and some additional restrictions on the use of credits. Thus FFV
benefits can accrue to a TLAAS fleet, and, like any fleet, are reflected in the final fleet average
value used to determine compliance for a given fleet (Primary or TLAAS), as is shown in Table
3.1.3-2.
No credits can be individually attributed to the Honda CNG vehicle. Because of its relatively low
sales volume, the overall rounded fleet average for Honda's car fleet is unaffected by the credited
GHG value for the 2012 CNG Civic.
Table 3.1.3-2. Fleet Average GHG Benefits from FFV Production, by Manufacturer and Fleet
Manufacturer
Chrysler
Ford
General Motors
Mercedes-Benz
Nissan
Toyota
Volkswagen
A
Fleet
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Truck
Truck
Car
B
Baseline
(g/mi)
300
384
261
385
283
397
310
388
382
354
274
C
With
FFVs
(g/mi)
274
315
242
304
236
297
298
368
367
345
273
D
Allowed
Benefit
(g/mi)
13
21
9
21
11
23
14
22
21
18
10
E
Final Fleet
Average
(g/mi)
287
363
252
364
272
374
298
368
367
345
273
F
Final FFV
Credit
(g/mi)
13
21
9
21
11
23
12
20
15
9
1
Total
Gram per mile equivalent
impact across entire
industry fleet
G
FFV Credits (Mg)
1,367,928
4,719,430
1,850,027
3,327,814
3,112,837
4,754,004
382,515
277,105
1,124,421
1,468,132
97,767
22,481,980
8.8
3.2 Credits Based on 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 impact on global warming than emissions of a
similar amount of CC>2. The impacts of refrigerant leakage can be reduced significantly by
systems that incorporate leak-tight components, or, ultimately, by using a refrigerant with a
25
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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 CC>2 fleet average standards taking effect in the
2012 model year (or otherwise to be able to bank or trade the credits). These provisions were
also used in the 2009-2011 model years to generate early credits, prior to the 2012 model year.
As was the case with the early credit program, a majority of manufacturers chose to use the A/C
credit provisions as part of their compliance demonstration in the 2012 model year. The same
manufacturers who used these provisions to generate early credits also reported A/C credits in
the 2012 model year, and Ferrari and Jaguar Land Rover (not early credit participants) also
reported A/C credits in 2012, bringing the number of manufacturers who are reporting credits for
A/C systems to thirteen. Most manufacturers who also reported credits for the 2009-2011 model
years were able to increase their A/C credits in 2012 relative to the early credit years. In fact, as
the A/C credits have increased and the fleet average credits have decreased due to increasingly
stringent emission targets over the 2009-2012 model years, the A/C credits now represent a
significant portion of the overall reported credits, as shown in Figure 3.2-1. The values reflected
in Figure 3.2-1 are the total industry credits for those eleven manufacturers with continuous use
of A/C credits in the 2009-2012 model years. For those eleven manufacturers as a whole, the
total A/C credits have risen in importance to the point where they make up about 60 percent of
the total credits generated.
26
-------
Figure 3.2-1. A/C Credits Relative to Total Credits Earned by Manufacturers for 2009-2012
Model Years (millions of Mg]
I A/C • Total Other Credits
2009
2010 2011
Model Year
2012
The A/C provisions are structured as additional and optional credits, unlike the CO2 standards for
which manufacturers must 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 technologies that result in real-world reductions in GHG emissions. A summary of the air
conditioning credits reported by the industry for all model years, including the early credit
program years, is shown in Table 3.2-1, and Table 3.2-2 shows the total air conditioning credits
(combined leakage and efficiency credits) reported by each manufacturer in the 2012 model year.
Table 3.2-1. Reported Air Conditioning Credits by A/C Credit Type and Model Year
(Mg)
A/C Credit Type
A/C Efficiency
A/C Leakage
Total A/C
2009
2,057,396
6,104,668
8,162,064
2010
2,731,622
7,971,855
10,703,477
2011
3,438,609
8,292,349
11,730,958
2012
5,202,895
10,316,338
15,519,233
Total
13,430,522
32,685,210
46,115,732
27
-------
Table 3.2-2. Reported Air Conditioning Credits by Manufacturer, 2012 Model Year(Mg)
Manufacturer
BMW
Chrysler
Ferrari
Ford
General Motors
Honda
Jaguar Land Rover
Mercedes-Benz
Nissan
Tesla
Toyota
Volkswagen
Volvo
Total
A/C Leakage
Credits
248,044
2,400,958
1,858
1,752,555
3,071,779
536,504
46,310
269,939
184,909
-
1,425,968
280,173
97,321
10,316,338
A/C Efficiency
Credits
180,516
833,053
1,091
102,848
929,844
549,649
42,612
258,961
458,943
3,286
1,327,777
452,155
62,160
5,202,895
Total A/C
Credits
428,560
3,234,011
2,949
1,855,403
4,001,643
1,086,153
88,922
528,900
643,852
3,286
2,753,745
732,328
159,481
15,519,233
Gram/Mile
Equivalent of
Total A/C Credits
8.2
9.8
10.0
5.1
8.2
3.4
7.5
10.1
2.6
5.7
6.6
6.5
10.9
6.1
3.2.1 Air Conditioning Leakage Credits
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,
performance, 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. The score 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. All
leakage credits in the 2012 model year are based on improvements to the components to reduce
leakage and not on the use of alternative low-GWP refrigerants.
Twelve manufacturers reported A/C leakage credits in the 2012 model year, as shown in Table
3.2.1-1. These manufacturers reported more than 10 million Mg of A/C leakage credits in 2012,
or about one quarter of all reported credits.
28
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Table 3.2.1-1. Reported Air Conditioning Leakage Credits by Manufacturer and
Fleet, 2012 Model Year (Mg)
Manufacturer
BMW
Chrysler
Ferrari
Ford
General Motors
Honda
Jaguar Land Rover
Mercedes-Benz
Nissan
Toyota
Volkswagen
Volvo
Total
Car
146,683
652,554
1,858
648,752
1,597,485
282,652
6,634
144,381
37,027
872,335
221,065
64,281
4,675,707
Truck
101,361
1;748,404
-
1,103,803
1,474,314
253,852
39,676
125,558
147,882
553,633
59,108
33,040
5,640,631
Total
248,044
2,400,958
1,858
1,752,555
3,071,779
536,504
46,310
269,939
184,909
1,425,968
280,173
97,321
10,316,338
Gram/Mile
Equivalent of
Total Credits
4.8
7.3
6.3
4.8
6.3
1.7
3.9
5.2
0.7
3.4
2.5
6.7
4.0
3.2.2 Air Conditioning Efficiency Credits
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 technological 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 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.
Thirteen manufacturers used the provisions that allow credits based on improvements to the
overall efficiency of the A/C system, as shown in Table 3.2.2-1. These manufacturers reported a
total of about 5 million Mg of CC>2 credits in the 2012 model year, or almost 13% of the total
credits reported by the industry and accounting for about two grams per mile across the 2012
fleet (see Table 3-1).
29
-------
Table 3.2.2-1. Reported Air Conditioning Efficiency Credits by
Manufacturer and Fleet, 2012 Model Year (Mg)
Manufacturer
BMW
Chrysler
Ferrari
Ford
General Motors
Honda
Jaguar Land Rover
Mercedes-Benz
Nissan
Tesla
Toyota
Volkswagen
Volvo
Total
Car
116,556
323,190
1,091
40,776
652,193
360,193
4,771
175,884
327,145
3,286
924,609
374,795
43,280
3,347,769
Truck
63,960
509,863
-
62,072
277,651
189,456
37,841
83,077
131,798
N/A
403,168
77,360
18,880
1,855,126
Total
180,516
833,053
1,091
102,848
929,844
549,649
42,612
258,961
458,943
3,286
1,327,777
452,155
62,160
5,202,895
Gram/Mile
Equivalent of
Total Credits
3.5
2.5
3.7
0.3
1.9
1.7
3.6
4.9
1.8
5.7
3.2
4.0
4.3
2.0
3.3 "Off-Cycle" Credits
General Motors (GM) requested, and was subsequently granted, off-cycle credits for a
technology used on certain gasoline-electric hybrid vehicles. The off-cycle credits reported by
GM are shown in Table 3.3-1. The low volume of these credits is not sufficient to generate a
gram per mile equivalent benefit that can be separately calculated for the GM fleet. 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. GM received off-cycle credits in the early
credits program for hybrid full size pick-up trucks that were equipped with this technology. In
the 2012 model year, the technology was expanded to include two Buick hybrid passenger car
models. 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, resulting in real-world fuel savings. 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.
30
-------
In the fall of 2013, Mercedes-Benz requested additional, off-cycle credits for their stop-start
systems for the 2012-2015 model years. However, at the time of this report, those credits have
not been approved by EPA, and are thus not included in this report. Readers can find additional
information regarding this credit application on EPA's website at http://epa.gov/otaq/regs/ld-
hwy/greenhouse/1 d-ghg. htm.
Table 3.3-1. Reported Off-Cycle Credits by Manufacturer and
Fleet, 2012 Model Year (Mg)
Manufacturer
GM
Total
Car
4,984
4,984
Truck
838
838
Total
5,822
5,822
3.4 Advanced Technology Vehicle Incentives
EPA's GHG program contains incentives for advanced technology vehicles. Specifically, these
incentives apply to electric vehicles, plug-in hybrid electric vehicles, and fuel cell vehicles. For
the 2012-2016 model years, the incentive program allows electric vehicles and fuel cell vehicles
to use a zero grams/mile compliance value, and plug-in hybrid electric vehicles may use zero
grams/mile to represent the use of grid electricity (i.e., only emissions are "counted" from the
gasoline engine operation). Use of the zero grams/mile option is limited to the first 200,000
qualified vehicles produced by a manufacturer in the 2012-2016 model years. This limitation can
be expanded to 300,000 vehicles for any manufacturer that produced at least 25,000 qualifying
vehicles in the 2012 model year. However, no manufacturers reached the 25,000 vehicle
threshold for the 2012 model year. Electric vehicles, fuel cell vehicles, and plug-in hybrid
electric vehicles that were included in a manufacturer's calculations of early credits also count
against the production limits. As noted in Section 2, both General Motors and Mercedes-Benz
selected a path that allows them to carry their 2011 model year production of advanced
technology vehicles into the 2012 or later model years, where the low emissions of those
vehicles (the Chevrolet Volt, the Mercedes-Benz smart fortwo electric vehicles, and the
Mercedes-Benz F-Cell fuel cell vehicle) could help them address an emissions deficit. Neither
company used these vehicles in their 2012 fleet average calculations. The use of these vehicles
will be noted in a future EPA report for the model year in which they are used.
After a manufacturer reaches the production volume limits they may no longer use zero
grams/mile, and must instead account for the net "upstream" emissions associated with their use
of grid electricity relative to vehicles powered by gasoline. Based on the GHG emissions from
today's national average electricity generation and other key assumptions related to vehicle
electricity consumption, vehicle charging losses, and grid transmission losses, a midsize electric
vehicle might have upstream GHG emissions of about 180 grams/mile, compared to the
upstream GHG emissions of atypical midsize gasoline car of about 60 grams/mile. Thus, the
electric vehicle would have a net upstream emissions value of about 120 grams/mile. EPA
regulations provide all the information necessary to calculate a unique net upstream value for
each electric or plug-in hybrid electric vehicle.
-------
Table 3.4-1. Production Volumes of Advanced Technology Vehicles
Using Zero Gram/Mile Incentive, by Model year
Manufacturer
Coda
Fisker
Ford
General Motors
Mercedes-Benz
Mitsubishi
Nissan
Tesla
Toyota
Total
2010 2011
4,370
1,169
8,495
599 269
599 14,303
2012
115
1,415
653
18,355
25
1,435
11,460
2,952
452
36,747
Total
115
1,415
653
22,725
1,194
1,435
19,955
3,820
452
51,649
3.5 Methane and Nitrous Oxide Standards
EPA finalized emission standards for methane (CH4) and nitrous oxide (N2O) emissions as part
of the rule setting the 2012-2016 model year GHG standards. The standards that were set in that
rulemaking were 0.010 grams/mile for N2O and 0.030 grams/mile for CH4. These standards were
established to cap emissions of GHGs, given that current levels are generally significantly below
these established standards. These capping standards were intended to prevent future increases in
emissions of these GHGs, and were generally not expected to result in the application of new
technologies or significant costs for manufacturers using current designs.
There are three different ways for a manufacturer to demonstrate compliance with these
standards. First, and used by most manufacturers, manufacturers may demonstrate compliance
with these standards with test data as they do for all other non-GHG emission standards. Because
there are no credits or deficits involved with this approach, and there are no consequences with
respect to the CO2 fleet average calculation, the manufacturers are not required to submit this
data as part of their GHG reporting and hence this GHG compliance report does not include
information from manufacturers using this option. Second, as part of the 2012-2016 rulemaking,
EPA also finalized an alternative C (^-equivalent standard option, which manufacturers may
choose in lieu of complying with the cap standards. This C (^-equivalent standard option allows
manufacturers to include CH4 and N2O, on a C(^-equivalent basis, in their CC>2 emissions fleet
average compliance level. This is done without adjusting the fleet average CO2 standard to
account for the addition of CH4 and N2O emissions. Manufacturers that choose this option are
required to include the CH4 and N2O emissions of all their vehicles for the purpose of calculating
their fleet average. In other words, the value of CREE (the carbon-related exhaust emissions, as
described earlier) for these manufacturers will include CO2, hydrocarbons, and carbon monoxide,
as well as CH4 and N2O emissions, for all their vehicles. Three manufacturers chose to use this
approach in the 2012 model year: Mazda, Nissan, and Subaru. For these manufacturers, the
calculated fleet average values shown in Table 3.1.1-1 thus include CH4 and N2O.
32
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A third alternative to meeting the CH4 and N2O standards was initially limited to the 2012-2014
model years, but was subsequently expanded to include all model years of the program. Under
this approach, manufacturers can essentially define an alternative, less stringent CH4 and/or N2O
standard for any vehicle that may have difficulty meeting the specific standards. This alternative
standard is treated as any other emission standard in that it must be met for the full useful life of
the vehicle. This method provides some additional flexibility relative to the other two options in
that (1) a manufacturer can target specific vehicles for alternative standards without incurring a
fleet-wide impact, and (2) CH4 and N2O are delinked, in that a manufacturer can meet the default
regulatory standard for one and select an alternative standard for the other. However, the key
aspect of this approach is that manufacturers that use it must calculate a deficit based on the less
stringent standards and on the production volumes of the vehicles to which those standards
apply. Five manufacturers made use of the flexibility offered by this approach, as shown in Table
3.5-1. Like any other deficit, these deficits must ultimately be offset by CO2 credits. While these
deficits could be carried forward to the next three model years like other deficits, all of the
manufacturers using this approach were able to cover these incremental deficits with credits,
either carried forward from 2009-2011 or generated in 2012. On an industry-wide basis, the
deficits associated with CFLi and N2O are relatively small, making up about four percent of the
industry-wide accumulated deficits (see Table 3-2).
Table 3.5-1.
Reported CH4 and N2O Deficits by Manufacturer and Fleet, 2012 Model
Year (Mg)
Manufacturer
BMW
Chrysler
Ford
General Motors
Volkswagen
Total
Car
CH4
N/A
(8,804)
(13,440)
(28,110)
(56,497)
(106,851)
N2O
N/A
N/A
(2,714)
N/A
(138,267)
(140,981)
Truck
CH4
(3,944)
(19,913)
(30,401)
(73,522)
(1,515)
(129,295)
N2O
(15,671)
N/A
(147,158)
N/A
(16,913)
(179,742)
Total
(19,615)
(28,717)
(193,713)
(101,632)
(213,192)
(556,869)
Gram/Mile
Equivalent
(0.4)
(0.1)
(0.5)
(0.2)
(0.2)
3.6 2012 Model Year Performance Summary
The complete assessment of a manufacturer's performance in the 2012 model year, before
applying early 2009-2011 credits or purchased credits, is represented by the accumulated credits
and deficits described in sections 3.1-3.5. It is the cumulative effect of all of these credits and
deficits that determines how a manufacturer's 2012 model year car and truck fleets did in
comparison to their 2012 car and truck standards. We generally report these credits and deficits
in Megagrams, as they are calculated under the regulations, occasionally converting to a gram
per mile equivalent. In this section, we exclusively report values in grams per mile, deriving a
"final performance value" that can be compared on equal terms with the footprint-based fleet
standards.30 Table 3.6-1 shows the derivation of this final performance value for cars and Table
Note that when EPA established the 2012-2016 standards we projected that manufacturers would use substantial
credits from flexible fuel vehicles and air conditioning systems to meet those standards. See 75 FR 25400 (May 7.
2010), where Table III.A.3-2 projects 6.5 grams/mile of FFV credits and 3.5 grams/mile of A/C credits across the
33
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3.6-2 shows the same for trucks, for each manufacturer. The second column of numeric data
shows the most basic of values, the starting point for all manufacturers: the fleet average tailpipe
CO2 emissions without any credits applied. The central columns then show the gram/per mile
impact of each type of credit or deficit, and finally, the total gram/mile impact of all credits. The
two rightmost columns show each manufacturer's final performance value - the starting tailpipe
value minus the total of the gram/mile credits - and the applicable footprint-based standard. Note
that a calculation of total tons of credits or deficits by using the difference between the final
performance value and the standard will yield a value very close to the total tons of credits
reported in Table 5-1, but because of the rounding used in transforming credits to grams/mile and
the rounding of the values to the nearest gram/mile, the results will not always be in complete
agreement.
fleet. Note that Table III.A.3-2 also projects a combined (car plus truck) emissions standard in 2012 of 295
grams/mile (reflecting use of FFV and A/C credits) and that the actual 2012 fleet achieved a lower performance
value of 286 grams/mile.
34
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Table 3.6-1. 2012 Model Year Aggregate Performance, Gram/Mile Equivalent - Cars
Manufacturer
BMW
Chrysler
Coda
Ferrari*
Fisker
Ford
General Motors
Honda
Jaguar Land
Rover*
Mazda
Mercedes
Benz*
Mitsubishi
Nissan
Porsche*
Subaru
Suzuki
Tesla31
Toyota
Volkswagen
Volvo
All
Fleet
Average
Footprint
(sq. ft.)
45.9
47.2
41.5
47.8
58.1
45.3
46.9
45.0
51.0
43.9
46.5
44.5
45.0
44.7
44.3
42.1
53.6
45.0
45.0
46.8
45.6
C02
Tailpipe,
No
Credits
277
300
0
494
146
261
283
237
376
241
316
262
258
325
257
267
0
221
274
297
260
Gram/Mile Equivalent of Credits
FFV
13
9
11
11
1
5
A/C
7.1
9.3
10.0
3.4
7.9
3.1
4.6
9.4
2.1
5.7
7.1
6.1
10.5
5.4
CH4&
N2O
-0.1
-0.1
-0.1
-2.0
-0.2
Total of
All
Credits
7.1
22.2
0
10.0
0
12.3
18.8
3.1
4.6
0
20.4
0
2.1
0
0
0
5.7
7.1
5.1
10.5
9.8
2012 Model Year
Final
Performance
Value
270
278
0
484
146
249
264
234
371
241
308
262
256
325
257
267
0
214
269
286
250
Standard
269
277
246
345
315
265
272
263
364
259
277
261
263
332
260
251
304
264
263
272
267
*These manufacturers are participating in the TLAAS program and are meeting alternative standards for all or a
portion of their car fleet, as described in Section 3.1.2. Where these manufacturers have cars in both Primary
and TLAAS fleets, for the purpose of this table we have calculated values for the total car fleet by merging
values from the Primary and TLAAS fleets, weighted by the production in each fleet.
31 Tesla exclusively manufactures electric vehicles. Under EPA regulations, the default calculation of emissions for
electric vehicles is a non-zero value that accounts for the net upstream emissions of electric power generation
relative to the upstream emissions of a gasoline vehicle (see 40 CFR 600.113-12(n)). However, under the temporary
incentives in the regulations for electrified vehicles, Tesla and other manufacturers of such vehicles are allowed to
use a value of zero grams/mile as long as cumulative production of such vehicles remains below the 200,000
manufacturer-specific vehicle production cap for the 2012-2016 model years. When Tesla's additional air
conditioning credits are applied, the methodology described here would indicate a negative emissions performance
value, which is counterintuitive. This is an artifact of (1) the temporary incentives established in the regulations, (2)
the fact that Tesla makes only electric vehicles, and (3) that Tesla production in model year 2012 remains below the
vehicle production cap discussed above. Thus we have set Tesla's performance in this table to zero grams/mile
rather than a negative value. This treatment will change if and when electric vehicle production exceeds the vehicle
production cap for model years 2012-2016.
35
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Table 3.6-2. 2012 Model Year Aggregate Performance, Gram/Mile Equivalent - Trucks
Manufacturer*
BMW
Chrysler
Ford
General Motors
Honda
Jaguar Land
Rover*
Mazda
Mercedes
Benz*
Mitsubishi
Nissan
Porsche*
Subaru
Suzuki
Toyota
Volkswagen
Volvo
All
Fleet
Average
Footprint
(sq. ft.)
51.4
53.6
59.4
60.1
50.5
48.4
48.1
51.9
44.0
51.6
51.8
44.7
48.7
53.4
49.0
48.6
54.6
C02
Tailpipe,
No
Credits
363
384
385
397
320
439
324
393
283
382
362
296
361
354
330
343
370
Gram/Mile Equivalent of Credits
FFV
21
21
23
15
15
9
15
A/C
11.1
10.0
7.4
8.5
4.0
8.2
11.3
3.7
5.9
9.3
11.8
7.1
CH4&
N2O
-1.3
-0.1
-1.1
-0.4
-1.3
-0.3
Total of
All
Credits
9.8
30.9
27.3
31.1
4.0
8.2
0
26.3
0
18.7
0
0
0
14.9
8.0
11.8
21.6
2012 Model Year
Final
Performance
Value
353
353
358
366
316
431
324
367
283
363
362
296
361
339
322
331
349
Standard
336
345
364
369
333
388
323
360
307
337
422
309
325
342
327
325
349
*These manufacturers are participating in the TLAAS program and are meeting alternative standards for all or a
portion of their truck fleet, as described in Section 3.1.2. Where these manufacturers have trucks in both
Primary and TLAAS fleets, for the purpose of this table we have calculated values for the total truck fleet by
merging values from the Primary and TLAAS fleets, weighted by the production in each fleet.
Figures 3.6-1 and 3.6-2 show the final performance values and the standards from the previous
tables relative to the fleet average footprint of each manufacturer's car and truck fleets. These
figures also add an extra dimension showing the fraction of a manufacturer's fleet that is either
cars or trucks, as well as indicating by color whether the manufacturer is accruing credits or
deficits in the fleet represented on the figure. To make Figure 3.6-1 more easily legible we have
restricted the axes such that manufacturers with very low (Coda, Tesla, Fisker) or very high
(Ferrari, Jaguar Land Rover, Porsche) CC>2 values or footprint values are not shown, but all the
manufacturer data is included in Table 3.6-1. Similarly, Porsche's high emission standard for
trucks results in their exclusion from Figure 3.6-2, but their data is shown in Table 3.6-2.
36
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Figure 3.6-1. 2012 Model Year Performance & Standard by Manufacturer and Average
Footprint - Car Fleets
300
290
280
270
= 260
I 250
•SB
3240
u
230
220
210
200
£ ^ • • • Deficits
ooooo standard
9 0 • • • Cred/fc
1.0 0.8 0.6 0.4 0.2
Manufacturer Car Fleet Fraction
(Car Production/Total Production)
• Volvo
i tChryJcr
BMW
.^Volkswagen 4 ° 9
Suzuki
Mitsubishi;
General Motors
I
Subaru
Nissan
Mazda
Ford
Honda
Toyota
42
43
44 45
Footprint (sq. ft.)
46
47
48
These manufacturers are participating in the TLAAS program and are meeting alternative standards for all or a
portion of their car fleet, as described in Section 3.1.2. Where these manufacturers have cars in both Primary and
TLAAS fleets, for the purpose of this chart we have calculated values for the total car fleet by merging values from
the Primary and TLAAS fleets, weighted by the production in each fleet.
37
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Figure 3.6-2. 2012 Model Year Performance & Standard by Manufacturer and Average
Footprint - Truck Fleets
380
370
360
350
= 340
I 330
§320
310
300
290
280
Suzuki
Nissan ^ Mercedes-Benz*
f i
Volvc
general Motors
i Chrysler
Ford
Toyota
Mazdag * "jvolkswiagen
Honda
Subaru
9 9 • • •Deficits
ooooo Standard
Credits
1.0 0.8 0.6 0.4 0.2
Manufacturer Truck Fleet Fraction
(Truck Production/Total Production)
• Mitsubishi
42 44 46 48 50 52 54
Footprint (sq. ft.)
56
58
60
62
These manufacturers are participating in the TLAAS program and are meeting alternative standards for all or a
portion of their car fleet, as described in Section 3.1.2. Where these manufacturers have cars in both Primary and
TLAAS fleets, for the purpose of this chart we have calculated values for the total car fleet by merging values from
the Primary and TLAAS fleets, weighted by the production in each fleet.
38
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4 Credit Transactions
Credits may be traded among manufacturers with a great deal of flexibility (with the exception of
2009 model year credits and credits generated by manufacturers using the TLAAS program,
which are restricted to use only within a manufacturer's own fleets). There are only a few
regulatory requirements that relate to credit transactions between manufacturers (other than the
restrictions just noted), and these are generally designed to protect those involved in these
transactions. While it may seem obvious, it is worth stating that a manufacturer may not trade
credits that it does not have. Credits that are available for trade are only those available (1) at the
conclusion of a model year when all the data is available with which to calculate the number of
credits generated by a manufacturer, and not before; and (2) after a manufacturer has offset any
deficits they might have. Credit transactions that result in a negative credit balance for the selling
manufacturer are not allowed and can result in severe punitive actions. Although a third party
may facilitate transactions, EPA's regulations allow only the automobile manufacturers to
engage in credit transactions and hold credits.
Since the 1990's, many of EPA's vehicle emissions regulatory programs have included the
flexibilities of averaging, banking, and trading (ABT). The incorporation of ABT provisions in
EPA emissions regulations has been generally universally supported by a wide range of
stakeholders; by manufacturers for the increased flexibility that ABT offers, and by
environmental groups because ABT enhances EPA's ability to introduce standards of greater
stringency in an earlier time frame than might otherwise be achieved. Historically manufacturers
tended to make use of the ability to average emissions and bank emissions credits for use in
subsequent years, but until now there has been almost no credit trading activity between
companies. The use of trading provisions in EPA's light-duty GHG program is a historic
development, and one that EPA welcomes because we believe it will allow greater GHG
reductions, lower compliance costs, and greater consumer choice.
The credit transactions reported by manufacturers in their 2012 model year reporting documents
are shown in Table 4-1.32 Credit sales are shown as negative values, in that a sale represents a
deduction of credits of the specified model year for the selling manufacturer. Credit purchases
are indicated as positive values because buying credits represents an increase in credits for the
purchasing manufacturer. The model year represents the "vintage" of the credits that were sold,
i.e., the model year from which the credits originated. As noted in Section 2, these transactions
are not reflected there or elsewhere in this report because the primary intent of this report is to
provide details regarding the credits and deficits generated by manufacturers. The overall impact
of these credit transactions on the compliance position of each manufacturer is discussed in
Section 5, which pulls together all the credits and deficits that have been discussed in preceding
sections. Note that each value in the table may represent multiple transactions.
32 EPA is aware of additional credit transactions that have occurred, or that are expected to occur, but because of the
timing of those transactions (after the manufacturers submitted their 2012 model year data) they will be reported in
the 2013 model year reports of the manufacturers involved, and thus will be included in EPA's 2013 model year
report.
39
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Table 4-1. Reported Credit Sales and Purchases as of the 2012 Model Year (Mg)
CREDITS
SOLD
CREDITS
PURCHASED
Manufacturer
Honda
Nissan
Tesla
Chrysler
Ferrari
Mercedes-Benz
2010
90,000
35,580
90,000
35,580
Model Year
2011 2012
500,000 250,000
14,192 177,941
500,000
14,192 427,941
Total
90,000
750,000
227,713
500,000
90,000
477,713
40
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5 Compliance Status after the 2012 Model Year
There are several important points to make regarding the 2012 model year and the compliance of
manufacturers following the 2012 model year, the first year of the EPA GHG program for light-
duty vehicles and light-duty trucks. First, readers should avoid making conclusions or projections
regarding a manufacturer's status based on this single snapshot of performance. This is the first
year of a multi-year fleet-averaging program in which manufacturers are able to carry forward
credits and deficits, move credits between their car and truck fleets, buy credits from other
manufacturers, and generate several types of additional optional credits. It is possible, for
example, for a manufacturer to routinely fall short of meeting the fleet average tailpipe emissions
targets yet remain in total compliance with the program. Further, manufacturers are introducing
new, more fuel-efficient technologies each year, as we can see already in the 2013 and 2014
model year vehicles that have been introduced following the 2012 model year covered by this
report. Second, compliance is based on the total credit picture, as shown in Table 5-1, in which
the totality of fleet average credits or deficits, optional credits, and credit transactions is
considered.
In this first year, all manufacturers are, by definition, in compliance with the program. This
report should be thought of not as a compliance report, since it makes no conclusions regarding
compliance or lack thereof. Instead, it should be thought of as a performance report, since it
documents the performance of manufacturers as they work towards the long-term goal of
complying with EPA's program. For example, while it is fair to say that nine manufacturers were
unable to meet their car and/or truck fleet average CC>2 standards applicable in the 2012 model
year, this fact in isolation has no meaning with respect to the overall compliance position of
these manufacturers. All but one of these manufacturers were able to offset any resulting 2012
model year deficit through GHG reductions achieved through other means and the application of
optional credits generated from those reductions. Generating a fleet average tailpipe deficit does
not, in and of itself, indicate lack of compliance with EPA's program, which seeks GHG
reductions in all aspects of the vehicles. And for the single manufacturer still remaining with a
net deficit after accounting for all early and optional credits, a deficit does not necessarily mean
lack of compliance with the program. In this first year of the program especially, a deficit does
not imply a failure to comply with the program because of the ability to carry a deficit forward
for up to three model years after the year in which the deficit was generated.
Table 5-1 shows the net GHG status for each manufacturer as of the completion of the 2012
model year. As noted above, the status as of the 2012 model year can only be determined after
assessing everything a manufacturer has done, including participation in the voluntary credit
programs and in credit transactions with other manufacturers. All of these elements, which have
been detailed in previous sections of this report, are summarized in Table 5-1, in which the right-
most column shows the net overall credits for each manufacturer remaining at the end of the
2012 model year. At the end of each model year, all credits and deficits discussed in previous
sections of this report are accumulated within each vehicle category (car and truck), as shown for
the 2012 model year in Table 5-1. Then, if a deficit is remaining for the model year, the
manufacturers must apply available credits to offset that deficit (a deficit may not be carried
forward if there are credits available to offset the deficit). Table 5-1 shows the use of early
credits and purchased credits to offset 2012 deficits. For example, BMW accumulated total
deficits of 291,272 Mg in the 2012 model year. We know, from Table 2-1, that they entered the
41
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2012 model year with 884,903 Mg of early credits. Table 5-1 shows the transfer of 291,272 Mg
of those early credits to the 2012 model year to offset the deficit from that model year, leaving
BMW with 593,631 Mg of early credits remaining, all of which can be carried over to the 2013
model year.
Note that Table 5-1 is an over-simplification, especially with respect to manufacturers with
vehicles in the TLAAS program, in that the credits from all of the fleets are aggregated into one
row in the table. However, it does accurately reflect the net credits at the end of the 2012 model
year. Ferrari is another case that bears some explanation. As shown in Section 4, Ferrari
purchased 90,000 Mg of credits, with a "vintage" of 2010. Ferrari did not generate early credits,
but because of the vintage of these purchased credits they appear in the 2009-2011 model year
column of the table. Ferrari used 40,893 Mg of these credits to offset their 2012 deficit, leaving
49,017 Mg remaining to carry forward to 2013. Similarly, Chrysler's purchase of 500,000 Mg of
credits simply adds to their early credits total because of the vintage of the purchased credits
(2010 model year). As the table shows, with one exception, manufacturers ended the 2012 model
year with net credits to carry forward to the 2013 model year. Note that the early credits (2009-
2011 model years) are shown with less detail than the 2012 model year credits. A detailed
breakdown of the early credits was presented in EPA's March 2013 report and is not repeated
here. (However, it is important to note that the impacts of transactions involving credits from the
early credit years are included in the balances for those model years in Table 5-1.) Note also that
for those manufacturers participating in the TLAAS program, as described in Section 3.1.2 of
this report, the credits of the Primary and TLAAS fleets are combined in Table 5-1. Although
they are not separated for the purposes of Table 5-1, EPA maintains careful records (as do the
manufacturers) of the credits within the Primary and TLAAS programs, as is necessary because
of the different treatment and restrictions for the different fleets. And the data we are making
available with this report will specifically identify the source of each credit (e.g., whether from
the Primary or TLAAS fleets). Finally, note that this table does not show the specific activity of
transferring credits to offset deficits and the resulting model year credit balances, although these
offsetting transactions are implied in the number in the final column. However, especially with
future model years in which credits will have differing expiration dates depending on the model
year the credits were generated, EPA will maintain a correct accounting not just of the total
credits held by a manufacturer, but the model year of origin of each of those credits. Finally,
although the sales of credits that were generated in the early model years of 2009-2011 are not
specifically shown, their impact on the balances in those early model years is reflected in the
values in Table 5-1.
42
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Table 5-1. Cumulative Credit Status by Manufacturer at Conclusion of 2012 Model Year (Mg)
Manufacturer
BMW
Chrysler
Coda
Ferrari*
Fisker
Ford
General Motors
Honda
Jaguar Land
Rover*
Mazda
Mercedes-Benz*
Mitsubishi
Nissan
Porsche*
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Total
Early Credits After
Trades & Transfers
(2009-2011)
593,631
7,718,023
-
49,017
-
15,296,436
24,564,829
35,425,108
-
5,467,804
-
1,439,197
15,662,037
-
5,755,171
748,951
-
80,266,189
5,864,834
565,163
199,416,390
2012 Model Year Credits
Car
(35,365)
(85,312)
5,524
(40,983)
46,694
3,345,635
2,226,552
5,959,159
(18,515)
749,725
(618,935)
(10,139)
1,239,226
23,163
62,183
(78,937)
178,517
12,695,585
(576,571)
(148,113)
24,919,093
Traded
Truck Credits
(255,907)
(1,806,872)
-
-
-
988,316
645,802
1,892,092
(405,517)
(14,838)
(129,788) 427,941
67,976
(1,969,163) (250,000)
175,185
481,133
(48,762)
(177,941)
467,424
74,076
(27,082)
134,075
Transfer from
Early Credits
291,272
1,892,184
-
40,983
14,838
428,044
10,139
1,969,163
127,699
576,571
175,195
5,526,088
Total Carried
Forward to 2013
593,631
7,718,023
5,524
49,017
46,694
19,630,387
27,437,183
43,276,359
(424,032)
6,217,529
107,262
1,507,173
16,651,263
198,348
6,298,487
748,951
576
93,429,198
5,938,910
565,163
229,985,646
These manufacturers are participating in the TLAAS program and are meeting alternative standards for all or a portion of their truck fleet, as
described in Section 3.1.2. Where these manufacturers have trucks in both Primary and TLAAS fleets, for the purpose of this table we have calculated
values for the total truck fleet by merging values from the Primary and TLAAS fleets, weighted by the production in each fleet.
43
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Volkswagen can be a useful illustrative example of how credits can be transferred, both across
vehicle categories and across model years. Volkswagen, as shown in Table 5-1, ends the 2012
model year with net credits in their truck fleet and a net deficit in their car fleet. The regulations
allow the two fleets to be treated individually, thus Volkswagen is not required to use their 2012
truck credits to partially offset their 2012 car deficit. Instead, Volkswagen will likely choose to
keep those 2012 truck credits and instead offset their car deficit with the oldest credits in their
"bank," because those are the credits that will expire first and thus should be used first (2009
credits expire at the end of the 2014 model year, but 2012 credits expire at the end of the 2021
model year, thus the 2012 credits are more valuable than those from 2009, because they can be
retained for a longer time). In Volkswagen's case, they have more than enough credits from the
2009 model year (2,243,205 Mg) to offset their 2012 car deficit (576,571 Mg). In this way they
retain their more valuable 2012 credits generated by their truck fleet, and going forward to the
2013 model year their available credits to carry forward from the 2009 model year will be
reduced by 576,571 Mg (i.e., by the 2012 car deficit). Table 5-2 illustrates the breakdown of
credits by model year that Volkswagen will be carrying forward to the 2013 model year (to either
use, trade, or continue carrying to 2014). Note that the overall balance is identical to that shown
in Table 5-1, but that the credits available to carry forward from each model year is not
necessarily equal to the quantity of credits generated in each model year.
Table 5-2. Model Year Makeup of Volkswagen's
Total Credit Balance
Model Year
2009
2010
2011
2012
Total
Credits (Mg)
1,666,634
2,811,663
1,386,537
74,076
5,938,910
Any manufacturer that concluded the 2012 model year a net deficit after applying early credits
and/or credit purchases is required to offset that deficit by the end of the 2015 model year. In
future reports such as this one, which EPA intends to issue on an annual basis, readers will be
able to see the evolving status of manufacturers and their overall progress towards meeting the
requirements of EPA's light-duty vehicle GHG standards.
44
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Appendix: 2012 Model Year Credits and Deficits
Manufacturer
BMW
Chrysler
Coda
Ferrari
Fisker
Ford
Pathway Fleet Credit Type
Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Truck Fleet Average
A/C Leakage
A/C Efficiency
CH4 Deficit
N2O Deficit
Primary Car Fleet Average
A/C Leakage
A/C Efficiency
CH4 Deficit
Truck Fleet Average
A/C Leakage
A/C Efficiency
CH4 Deficit
Primary Car Fleet Average
Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Primary Car Fleet Average
Advanced Technology
Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Advanced Technology
Fleet
Average
(g/mi)
111
363
287
363
0
494
146
252
Fleet
Standard
(g/mi)
269
336
111
345
246
276
315
265
Production
Volume
191,154
191,101
191,154
65,856
65,856
65,856
11,641
11,641
538,887
536,415
536,415
187,106
994,996
994,996
994,996
427,450
115
1,510
1,415
1,415
1,052,721
1,052,721
197,889
653
Credits (Mg)
(298,604)
146,683
116,556
(401,613)
101,361
63,960
(3,944)
(15,671)
(1,052,252)
652,554
323,190
(8,804)
(4,045,226)
1;748,404
509,863
(19,913)
5,524
(64,277)
1,858
1,091
46,694
2,672,261
648,752
40,776
45
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Manufacturer Pathway Fleet Credit Type
CH4 Deficit
N2O Deficit
Truck Fleet Average
A/C Leakage
A/C Efficiency
CH4 Deficit
N2O Deficit
General Motors Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Advanced Technology
CH4 Deficit
Off -Cycle
Truck Fleet Average
A/C Leakage
A/C Efficiency
CH4 Deficit
Off-Cycle
Honda Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Truck Fleet Average
A/C Leakage
A/C Efficiency
Jaguar Land Rover Primary Truck Fleet Average
A/C Leakage
A/C Efficiency
TLAAS Car Fleet Average
A/C Leakage
A/C Efficiency
Fleet Fleet
Average Standard Production
(g/mi) (g/mi) Volume
174,597
3,110
364 364 701,602
701,602
437,204
402,710
145,756
272 272 1,449,244
1,449,244
1,417,421
18,355
383,896
17,016
374 369 915,130
915,130
827,037
515,380
2,176
237 263 1,047,165
1,035,238
1,046,684
320 333 493,414
493,414
493,414
303 316 9,086
9,086
9,086
376 364 12,769
12,769
12,769
Credits (Mg)
(13,440)
(2,714)
0
1,103,803
62,072
(30,401)
(147,158)
0
1,597,485
652,193
(28,110)
4,984
(1,033,479)
1,474,314
277,651
(73,522)
838
5,316,314
282,652
360,193
1,448,784
253,852
189,456
26,679
12,518
7,593
(29,920)
6,634
4,771
46
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Manufacturer Pathway Fleet
Truck
Mazda Primary Car
Truck
Mercedes-Benz Primary Car
Transfer
Truck
TLAAS Car
Truck
Mitsubishi Primary Car
Truck
Nissan Primary Car
Transfer
Truck
Credit Type
Fleet Average
A/C Leakage
A/C Efficiency
Fleet Average
Fleet Average
Fleet Average
A/C Leakage
A/C Efficiency
Advanced Technology
Transfer
Fleet Average
A/C Leakage
A/C Efficiency
Fleet Average
A/C Leakage
A/C Efficiency
Fleet Average
A/C Leakage
A/C Efficiency
Fleet Average
Advanced Technology
Fleet Average
Fleet Average
A/C Leakage
A/C Efficiency
Advanced Technology
Transfer
Fleet Average
A/C Leakage
A/C Efficiency
Fleet
Average
(g/mi)
477
241
324
298
368
406
408
262
283
258
367
Fleet
Standard
(g/mi)
408
259
323
271
335
368
434
261
307
263
337
Production
Volume
32,706
32,706
32,706
213,308
65,696
163,247
50
61,343
10,585
20,230
51,927
1,435
12,540
896,278
287,947
896,278
11,460
331,886
257,063
331,769
Credits (Mg)
(509,713)
27,158
30,248
749,725
(14,838)
(860,659)
139,794
167,018
427,941
(457,223)
97,267
65,016
(78,541)
4,587
8,866
118,800
28,291
18,061
(10,139)
67,976
875,054
37,027
327,145
(250,000)
(2,248,843)
147,882
131,798
47
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Manufacturer
Porsche
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Pathway Fleet
TLAAS Car
Truck
Primary Car
Truck
Primary Car
Truck
Primary Car
Transfer
Primary Car
Truck
Primary Car
Truck
Primary Car
Credit Type
Fleet Average
Fleet Average
Fleet Average
Fleet Average
Fleet Average
Fleet Average
Fleet Average
A/C Efficiency
Advanced Technology
Transfer
Fleet Average
A/C Leakage
A/C Efficiency
Advanced Technology
Fleet Average
A/C Leakage
A/C Efficiency
Fleet Average
A/C Leakage
A/C Efficiency
CH4 Deficit
N2O Deficit
Fleet Average
A/C Leakage
A/C Efficiency
CH4 Deficit
N2O Deficit
Fleet Average
A/C Leakage
Fleet
Average
(g/mi)
325
362
257
296
267
361
0
221
345
273
330
297
Fleet
Standard
(g/mi)
332
422
260
309
251
325
304
264
342
263
327
272
Production
Volume
16,946
12,927
106,152
163,860
25,266
5,997
2,952
2,952
2,952
1,298,021
452
722,227
500,690
64,882
52,375
52,375
Credits (Mg)
23,163
175,185
62,183
481,133
(78,937)
(48,762)
175,231
3,286
(177,941)
10,898,641
872,335
924,609
(489,377)
553,633
403,168
(977,667)
221,065
374,795
(56,497)
(138,267)
(43,964)
59,108
77,360
(1,515)
(16,913)
(255,674)
64,281
48
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Manufacturer
Pathway Fleet Credit Type
Fleet
Average
(g/mi)
Fleet
Standard
(g/mi)
Production
Volume
Credits (Mg)
Truck
A/C Efficiency
Fleet Average
A/C Leakage
A/C Efficiency
343
325
52,375
19,432
19,432
19,432
43,280
(79,002)
33,040
18,880
49
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