Greenhouse Gas
Emission Standards for
Light-Duty Vehicles
Manufacturer Performance Report
for the /_nj
Model Year
Aston Martin
Lotus
McLaren
Tesla
Fisker
Porsche
Toyota
Honda
Mazda
Ford
Subaru
General Motors
Mitsubishi
Nissan
Volkswagen
BMW
Chrysler
Volvo
Mercedes-Benz
Suzuki
Jaguar
Land Rover
Ferrari
Coda
Aston Martin
Lotus
McLaren
Tesla
Fisker
Porsche
&ER&
Environmental
EPA-420-R-15-008a March 2015
Toyota
Honda
Mazda
Ford
Subaru
General Motors
Mitsubishi
Nissan
Volkswagen
BMW
Chrysler
Volvo
Mercedes-Benz
Suzuki
Jaguar
Land Rover
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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
A. WHY ARE WE RELEASING THIS INFORMATION? 1
B. WHAT DATA ARE WE PUBLISHING? 2
C. HOW CAN CO2 EMISSIONS CREDITS BE USED? 4
D. WHICH MANUFACTURERS AND VEHICLES ARE INCLUDED IN THIS REPORT? 5
1. Small Businesses 5
2. Small Volume Manufacturers 6
3. Operationally Independent Manufacturers 6
4. Hyundai and Kia 7
5. Aggregation of Manufacturers 8
2. OPTIONAL GHG CREDITS FROM 2009-2011 MODEL YEARS 10
3. CREDITS REPORTED FROM THE 2012-2013 MODEL YEARS 14
A. "2-CvcLE" TAILPIPE CO2 EMISSIONS 15
B. TLAAS PROGRAM STANDARDS 17
C. CREDITS BASED ON ALTERNATIVE FUEL VEHICLES 20
1. Advanced Technology Vehicles 20
2. Compressed Natural Gas Vehicles 22
3. Gasoline-Ethanol Flexible-Fuel Vehicles 22
D. CREDITS BASED ON AIR CONDITIONING SYSTEMS 25
1. Air Conditioning Leakage Credits 28
2. Air Conditioning Efficiency Credits 30
E. CREDITS BASED ON "OFF-CYCLE" TECHNOLOGY 32
F. DEFICITS BASED ON METHANE AND NITROUS OXIDE STANDARDS 34
G. 2013 MODEL YEAR COMPLIANCE VALUES 36
H. 2013 MODEL YEAR FOOTPRINT-BASED CO2 STANDARDS 40
I. OVERALL COMPLIANCE SUMMARY 44
4. CREDIT TRANSACTIONS 47
5. COMPLIANCE STATUS AFTER THE 2013 MODEL YEAR 49
APPENDIX A: COMPARING ACTUAL PERFORMANCE TO RULEMAKING PROJECTIONS 54
APPENDIX B: VEHICLE PRODUCTION VOLUMES & MARKET SHARE 60
APPENDIX C: 2012 MODEL YEAR COMPLIANCE VALUES 62
APPENDIX D: 2009-2013 MODEL YEAR REPORTED CREDITS AND DEFICITS 65
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List of Tables and Figures
PROCESS FOR DETERMINING A MANUFACTURER'S COMPLIANCE STATUS
INDUSTRY COMPLIANCE VALUES VERSUS STANDARDS IN 2012 AND 2013 MODEL YEARS
MANUFACTURER COMPLIANCE VALUES AND STANDARDS IN THE 2013 MODEL YEAR iv
CREDIT BALANCES AT CONCLUSION OF THE 2013 MODEL YEAR v
USE OF COMPLIANCE PROGRAM FLEXIBILITIES BY MANUFACTURERS IN 2013 MODEL YEAR vi
TABLE 1-1. AGGREGATION OF MANUFACTURERS IN THE 2013 MODEL YEAR 9
TABLE 2-1. TOTAL EARLY CREDITS, BY MANUFACTURER AND MODEL YEAR 12
TABLE 2-2. TOTAL REPORTED EARLY CREDITS, BY CREDIT CATEGORY 12
TABLE 3-1. "2-CYCLE" TAILPIPE CO2 PRODUCTION-WEIGHTED FLEET AVERAGE EMISSIONS 17
TABLE 3-2. PRODUCTION VOLUMES ASSIGNED To TLAAS STANDARDS 19
TABLE 3-3. NET IMPACT FROM USE OF THE TLAAS PROGRAM 20
TABLE 3-4. PRODUCTION VOLUMES OF ADVANCED TECHNOLOGY VEHICLES USING ZERO GRAMS/MILE INCENTIVE 22
TABLE 3-5. NUMBER OF FFV MODELS BY MANUFACTURER, 2012-2013 MODEL YEARS 24
TABLE 3-6. PRODUCTION VOLUME OF FFVs BY MANUFACTURER, 2012-2013 MODEL YEARS 25
TABLE 3-7. NET CREDITS ACCRUED FROM USE OF THE FFV INCENTIVES 25
TABLE 3-8. REPORTED AIR CONDITIONING CREDITS BY A/C CREDIT TYPE AND MODEL YEAR 27
TABLE 3-9. REPORTED AIR CONDITIONING CREDITS BY MANUFACTURER, 2013 MODEL YEAR 27
TABLE 3-10. NET IMPACT OF AIR CONDITIONING CREDITS 28
TABLE 3-11. REPORTED AIR CONDITIONING LEAKAGE CREDITS BY MANUFACTURER AND FLEET, 2013 MODEL YEAR 29
TABLE 3-12. AIR CONDITIONING LEAKAGE CREDITS 30
TABLE 3-13. REPORTED AIR CONDITIONING EFFICIENCY CREDITS BY MANUFACTURER AND FLEET, 2013 MODEL YEAR 31
TABLE 3-14. AIR CONDITIONING EFFICIENCY CREDITS 32
TABLE 3-15. OFF-CYCLE CREDITS REPORTED BY GM 33
TABLE 3-16. REPORTED CH4 AND N2O DEFICITS BY MANUFACTURER AND FLEET, 2013 MODEL YEAR 35
TABLE 3-17. CH4 DEFICITS 35
TABLE 3-18. N2O DEFICITS 36
TABLE 3-19.2013 COMPLIANCE VALUES -COMBINED PASSENGER CAR & LIGHT TRUCK FLEET 37
TABLE 3-20.2013 COMPLIANCE VALUES - PASSENGER CAR FLEET 38
TABLE 3-21.2013 COMPLIANCE VALUES - LIGHT TRUCK FLEET 39
TABLE 3-22.2012-2013 MODEL YEAR COMPLIANCE VALUES BY MANUFACTURER AND FLEET 40
FIGURE 3-1. 2012-2013 MODEL YEAR CO2 FOOTPRINT TARGET CURVES 41
TABLE 3-23.2012-2013 MODEL YEAR CO2 STANDARDS BY MANUFACTURER AND FLEET 42
TABLE 3-24. AVERAGE FOOTPRINT BY MANUFACTURER AND FLEET 43
TABLE 3-25. COMPLIANCE & CREDIT SUMMARY, 2012-2013 MODEL YEARS - COMBINED CARS AND TRUCKS 44
TABLE 3-26. COMPLIANCE & CREDIT SUMMARY, 2012-2013 MODEL YEARS - PASSENGER CARS 44
TABLE 3-27. COMPLIANCE & CREDIT SUMMARY, 2012-2013 MODEL YEARS - LIGHT TRUCKS 45
TABLE 3-28.2013 MODEL YEAR COMPLIANCE SUMMARY BY MANUFACTURER AND FLEET 46
TABLE 4-1. REPORTED CREDIT SALES AND PURCHASES AS OF THE 2013 MODEL YEAR 48
TABLE 5-1. CUMULATIVE CREDIT STATUS AFTER THE 2013 MODEL YEAR 50
TABLE 5-2. CREDITS AVAILABLE AFTER THE 2013 MODEL YEAR, REFLECTING TRADES & TRANSFERS 53
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TABLE A-l. PROJECTED CO2 PERFORMANCE IN RULEMAKING ANALYSES FOR COMBINED PASSENGER CAR AND LIGHT
TRUCK FLEET 55
TABLE A-2. PROJECTED CO2 PERFORMANCE IN RULEMAKING ANALYSES FOR PASSENGER CARS 56
TABLE A-3. PROJECTED CO2 PERFORMANCE IN RULEMAKING ANALYSES FOR LIGHT TRUCKS 56
TABLE A-4. ACTUAL AND PROJECTED CO2 VALUES, CARS AND TRUCKS COMBINED 59
TABLE A-5. ACTUAL AND PROJECTED CO2 VALUES, PASSENGER CARS 59
TABLE A-6. ACTUAL AND PROJECTED CO2 VALUES, LIGHT TRUCKS 59
TABLE B-l. VEHICLE PRODUCTION VOLUMES BY MODEL YEAR 60
TABLE B-2. VEHICLE CATEGORY MARKET SHARE BY MODEL YEAR 61
TABLE C-l. 2012 COMPLIANCE VALUES -COMBINED PASSENGER CAR & LIGHT TRUCK FLEET 62
TABLE C-2. 2012 COMPLIANCE VALUES - PASSENGER CAR FLEET 63
TABLEC-3. 2012 COMPLIANCE VALUES-LIGHT TRUCK FLEET 64
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EXECUTIVE SUMMARY
Background
On May 7, 2010, the Environmental Protection Agency (EPA) and the National Highway Traffic
Safety Administration (NHTSA) issued a joint Final Rule to establish the first phase of a
National Program with new standards for 2012 to 2016 model year light-duty vehicles that
reduce greenhouse gas (GHG) emissions and improve fuel economy. These standards apply to
passenger cars, light-duty trucks, and medium-duty passenger vehicles. Subsequently, on
October 15, 2012, EPA and NHTSA issued standards for GHG emissions and fuel economy of
light-duty vehicles for model years 2017-2025, building on the first phase of the joint National
Program.
EPA is 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.l
This report supersedes previous reports and details manufacturers' performance towards meeting
GHG standards in the 2013 model year, the second year of the increasingly stringent GHG
standards for model years 2012-2025. 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.2
The following figure illustrates the process and the inputs that determine a manufacturer's
compliance with the light-duty vehicle GHG emission standards. Every manufacturer starts at the
same place: by measuring the CO2 tailpipe emissions performance of their vehicles using EPA's
City and Highway test procedures (referred to as the "2-cycle" tests). Then they may choose to
apply a variety of optional technology-based credits to further reduce their fleet GHG emissions
compliance value. Today, the largest quantities of credits generated by manufacturers are for
alternative fuel vehicles (primarily flexible fuel vehicles capable of operating on gasoline and
E85) and for GHG reductions resulting from improved air conditioning systems that reduce
refrigerant leakage and/or improve system efficiency. The 2-cycle tailpipe CO2 value, when
reduced by the net grams/mile equivalent of the optional credits, determines a manufacturer's
model year performance and whether credits or deficits are generated by a manufacturer's model
year fleet.
1 Relevant information on the CAFE program can be found on the NHTSA website: http://www.nhtsa.gov/fuel-
economy.
2 This report and the data upon which it is based can be found and downloaded at http://www.epa.gov/otaq/regs/ld-
hwv/greenhouse/ld-ghg.htm.
l
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Process for Determining a Manufacturer's Compliance Status
Future Credits
& Deficits
Future Credit
"i Transactions
i
Individual model year performance, however, does not directly determine model year
compliance or non-compliance. Manufacturers with deficits in a model year may use credits
carried over from a previous model year to offset the deficit. They may also purchase credits
from another manufacturer. Manufacturers with a deficit at the conclusion of a model year may
also carry that deficit forward into the next model year. Manufacturers must, however, offset any
deficit within three years after the model year in which it was generated. After considering these
additional credits and deficits, EPA determines a manufacturer's current compliance status. For
the 2012 and 2013 model years, there are two ways to describe a manufacturer's compliance
status: (1) they have demonstrated compliance, or (2) they have not yet demonstrated
compliance. No manufacturer is yet out of compliance with the GHG program in the 2012 or
2013 model years; their actions in subsequent years will ultimately determine final compliance.
11
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1
For the second consecutive year, the auto industry
outperformed the GHG standard by a substantial margin
Overall industry compliance in model year 2013 was 12 grams/mile better than required by the
2013 GHG emissions standard. This marks the second consecutive model year of industry
outperforming the standards by a wide margin; industry compliance in 2012 was 11 grams/mile
better than required. This industry-wide performance means that consumers bought vehicles with
lower GHG emissions than required by the EPA 2013 GHG standards. See Section 3 for more
detail on these values.3 Manufacturers continued this level of performance against increasingly
stringent standards. While the industry-wide GHG standard decreased by 7 grams/mile from
2012 to 2013, manufacturers outpaced this increase in stringency by reducing compliance values
by 9 grams/mile in 2013.
Industry Compliance Values versus Standards in 2012 and 2013 Model Years
305
300
295
290
llg/mi
Lower than Standard
7g/mi
12g/mi
Lower than Standard
Standard
Compliance
Value
2012
2013
Model Year
3 Note that although rounding of the values on the chart may produce some apparent inconsistencies, the numbers
reported are correct.
in
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2
Most manufacturers outperformed their individual 2013
standard
Most large manufacturers achieved fleet GHG compliance values lower than required by their
unique 2013 standard and thus generated credits in the 2013 model year. Nine of the 13
manufacturers with sales greater than 100,000 vehicles beat their standard, with margins of
compliance ranging from 27 grams/mile (Hyundai) to 4 grams/mile (GM). The remaining four
manufacturers missed their unique 2013 standard by amounts ranging from 1 to 6 grams/mile,
thus generating deficits, but in all cases these companies shrank their deficit relative to the 2012
model year. More detail about model year 2013 performance is provided in Section 3. The figure
below does not include the impact of credit transfers (within a company) from prior model years
or credit trades (transactions between companies), and thus does not portray whether or not a
manufacturer has complied with 2012 or 2013 model year standards. The four manufacturers
shown that did not outperform their 2013 standard - Fiat Chrysler, Mercedes, BMW, and
Volkswagen - in fact had sufficient credits available from prior model years and thus complied
with the 2012 and 2013 standards.
Manufacturer Compliance Values and Standards in the 2013 Model Year
(from highest to lowest GHG standard]
350
300
250
200
I 15°
ID
ID
100
so
IV
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3
All large manufacturers are in compliance with the 2012 and
2013 GHG standards
The majority of manufacturers, representing more than 99 percent of U.S. sales, are in
compliance with the standards for both the 2012 and 2013 model years. In fact, 21 of 26
manufacturers are carrying a positive credit balance into the 2014 model year, meaning that they
have met both the 2012 and 2013 standards (credits cannot be carried forward if a deficit exists
in a prior model year). The manufacturers currently with deficits in the 2012 and/or 2013 model
year are allowed to carry those deficits forward for three model years, giving them time to
generate or purchase credits to demonstrate compliance with the 2012 and/or 2013 model year
standards. The current status of these manufacturers is neither compliance nor non-compliance -
rather, they have not yet demonstrated compliance. The makeup of these credit and deficit
balances is tracked by model year "vintage" as explained in Section 5. The credit balances shown
below include "early credits" from model year 2009 that may not be sold and may not be used
after the 2014 model year.
Credit Balances at Conclusion of the 2013 Model Year (Mg)4
(including credit transfers & trades]
Manufacturer
Toyota
Honda
GM
Ford
Hyundai
Nissan
Kia
Subaru
Fiat Chrysler
Mazda
Volkswagen
Mitsubishi
Suzuki
Credits Carried to
Model Year 2014
103,484,295
50,234,560
29,185,540
28,546,438
23,186,604
21,641,784
13,016,497
7,597,337
7,279,810
7,003,960
5,789,961
1,565,382
693,553
Manufacturer
BMW
Porsche
Volvo
Mercedes
Fisker
Coda
BYD Motors
Tesla
Ferrari
Lotus
McLaren
Aston Martin
Jaguar Land Rover
Credits Carried to
Model Year 2014
456,812
426,439
268,157
129,312
46,694
7,251
2,276
1,271
(653)
(763)
(3,620)
(4,783)
(927,143)
All Manufacturers
299,626,971
1 The Megagram (Mg) is a unit of mass equal to 1000 kilograms. It is also referred to as the metric ton or tonne.
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4
Manufacturers continue to reduce GHG emissions while using
a wide variety of compliance flexibilities that were designed
EPA designed the standards with a wide range of flexibilities to allow manufacturers to maintain
consumer choice, spur technology innovation, and minimize compliance costs, all while
achieving significant GHG reductions. The flexibilities built into the program include standards
based on vehicle size (or "footprint"), emissions averaging within car and truck fleets, credit
trading between car and truck fleets, optional programs to generate credits, and processes to bank
and/or trade credits. The result is that manufacturers can meet the standards while meeting
consumer demand for a wide variety of vehicles, from high-performance vehicles to fuel-
efficient hybrids, and from full-size pickups to small cars. In addition, the optional credit
programs are facilitating the development and introduction of new technology. GM and Honda,
for example, introduced a new and significantly less harmful air conditioning refrigerant to the
U.S. automotive market in 2013 which lowered GHG emissions and helped them meet the GHG
standards. Credit exchanges within and between companies also provide more flexibility in the
program. Sections 2 through 4 provide more details on the use of the credits and flexibilities by
each manufacturer.
Use of Compliance Program Flexibilities by Manufacturers in 2013 Model Year
Core Design
Elements
Generating Credits
Credit
Transfers &
Trades
QJ
0
Footprint Based Targets
Car and Truck Standards
Fleet Averaging
Banked Early Credits
Air Conditioning
Off-Cycle
Advanced Technology
Flex Fuel Vehicles
CNG Vehicles
Using Banked Credits
Carrying a Deficit to 2014
Trade: Credits Out
Trade: Credits In
Small Company Provisions
CH4& N2O Alternative
X
X
X
X
Thf
anc
cor
X
X
X
X
X
X
se program elements are integral to the program desig
are critical for maintaining consumer choice and reduc
npliance costs while achieving significant GHG reductior
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
\
ing
IS
X
X
X
X
X
X
X
X
X
X
X
X
X
VI
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1. INTRODUCTION
A. 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' performance under EPA's GHG
program. In the two regulatory actions that established the GHG emissions standards for light-
duty vehicles, EPA and NHTSA committed to making certain information public regarding the
compliance of automobile manufacturers with the CO2 and fuel economy standards.5 This report
is the third such report released regarding EPA's 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.6 In April of 2014 we released a report documenting
the GHG performance of manufacturers in the 2012 model year, the first year that GHG
standards were effective for all manufacturers.7 Because of changes that propagate back to prior
model years, such as the credit transactions between manufacturers, this report supersedes
previous reports and should not be compared to past reports.
When EPA and NHTSA issued the proposed rule for the 2012-2016 model year CO2 and fuel
economy standards, the proposal received considerable comment about the need for transparency
regarding implementation of the program, and specifically, regarding compliance
determinations.8 Many comments emphasized the importance of making GHG compliance
information publicly available to ensure such transparency. This was also the case with the
proposal for 2017-2025 model year GHG 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.9 In response to the comments on the proposed rule for
2012-2016 model year standards 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."10
5 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.
6 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.
7 Greenhouse Gas Emission Standards for Light-Duty Vehicles: Manufacturer Performance Report for the 2012
Model Year, Compliance Division, Office of Transportation and Air Quality, U.S. Environmental Protection
Agency, Report No. EPA-420-R-14-011, April 2014.
8 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.
9 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.
10 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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In the final rule for model years 2017-2025, we also committed to expanding the information we
release regarding GHG program compliance, noting in the preamble 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
after taking into account the credit and debit carry-forward provisions and any credit
transactions.
In addition to this and prior reports, we continue to 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 fueleconomy.gov
includes CO2 emission values for each vehicle model. In addition, we release actual vehicle
emission test results at epa.gov/otaq/tcldata.htm. Finally, detailed information on long-term
industry-wide CO2, fuel economy, and technology trends since model year 1975 are at
epa.gov/otaq/fetrends.htm. This latter report does not contain formal compliance data, but rather
focuses on EPA's best estimates of real world CO2 emissions and fuel economy.
B. What 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 2013 model year is the second year manufacturers have been
subject to the standards, and thus it is the first year in which performance measures can be
compared across model years (in this case, 2012 and 2013). This report makes such comparisons
where appropriate. This report supersedes previous reports regarding manufacturer compliance
with EPA's GHG program.
The manufacturer-reported data which form the basis for this report was required to be submitted
to EPA by the end of March of 2014.u 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 tailpipe performance for each vehicle category (which includes
flexible-fuel vehicle credits and credits for other alternative fuels such as compressed natural gas
and electricity), the quantity of optional credits (e.g., based on air conditioning or off-cycle
technology improvements), credit transfers within a manufacturer between car and truck fleets,
credit trades between manufacturers, if applicable, and all the data necessary to calculate these
reported values.
This report first updates and summarizes the credits generated under the early credit provisions,
and then summarizes the data reported by manufacturers for the 2012 and 2013 model years in a
11 See 40 CFR 600.512-12.
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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. This report also
includes data from Hyundai and Kia for the first time in an EPA GHG report, as discussed in
Section l.D.4. The data presented in previous EPA reports has changed due to a number of
factors described in this report, including the addition of Hyundai and Kia, and should no longer
be considered current. For example, the inclusion of Hyundai and Kia data in the updated data
increases the previously reported 2012 model year over-compliance of 10 grams/mile to 11
grams/mile. Values presented in this report are updated to reflect the new data, and previously-
reported values for the 2009-2012 model years should be considered obsolete.
Vehicle and fleet average compliance for EPA's GHG program is based on a combination of
CO2, 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
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
CO2-equivalent basis to determine the CREE value, i.e., adjusting for the relative carbon weight
fraction of the specific emission constituent. Although the regulatory text uses the more accurate
term "CREE" to represent the CCh-equivalent sum of carbon emissions, the term CO2 is used as
shorthand throughout this report as a more familiar term for most readers.
The CO2 standards in EPA's GHG program and the related compliance values in this report
differ from the CO2 values reported in EPA's "Trends" report or on new vehicle fuel economy
labels.12 The Trends report presents CO2 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 CO2 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
unique driving cycles. The CO2 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" methodology, because the results are based on
five different test procedures. The 5-cycle methodology includes 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.
12 "Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975 Through
2014," U.S. EPA-420-R-14-023, Office of Transportation and Air Quality, October 2014. See
http://epa.gov/otaa/fetrends.htm.
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Credits are expressed throughout this report in units of Megagrams (Mg), which is how credits
are reported to EPA by the manufacturers.13 Further, compliance is ultimately determined based
on the balance of Megagrams of credits and/or deficits for a given model year, after accounting
for credit transfers and trades. However, in order to present the impact of these credits in terms
that might be more understandable, we calculate and present a grams per mile equivalent value
where possible (see inset on this page for the methodology used to convert Megagrams to
grams/mile). Where such a value in a table applies to a specific manufacturer, the grams per mile
value represents the impact of credits on the fleet of that specific manufacturer, whereas the final
Fleet Total row displays the grams per mile impact of the total credits across the entire 2012 or
2013 model year fleet of cars, trucks, or combined fleet, 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.14
How We Determine a Grams/Mile Equivalent from Megagrams (Metric Tons) of Credits and Deficits
The Megagrams (Mg) of credits or deficits reported to EPA are determined from values 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] = ( CCh x VMT x Production ) / 1,000,000
"CCh" represents the credits in grams per mile. "VMT" represents 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 CCh credit applies.
The CCh-equivalent of a credit value expressed in Mg is derived by reversing the equation as follows:
CO2[grams/mile] = ( Credits[Mg] x 1,000,000 ) / (VMT x Production )
When using this equation to calculate CCh grams/mile for aggregate car and truck credits, we use a weighted
average of the car and truck VMT values. For example, for the entire 2013 model year fleet covered by this
report, the weighted VMT is 206,253 miles. The weighting is by the proportion of cars or trucks relative to the
total fleet. The weighting may be applied on a manufacturer-specific basis or across the entire fleet,
depending on the data presented in each table. Unless specifically stated, this is always the source of
combined car/truck fleet values in this report.
C. How can COz emissions credits be used?
The ability to earn and bank credits, including early credits, is a fundamental aspect of the
program's 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 excess emission reductions that manufacturers
13 The Megagram (Mg) is a unit of mass equal to 1000 kilograms. It is also referred to as the metric ton or tonne.
14 All of the background documents for EPA's GHG regulations are available on EPA's website at
http://www.epa.gov/otaa/climate/regs-light-dutv.htm.
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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 unique 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.15
D. Which manufacturers and vehicles are included in this report?
The vast majority of manufacturers producing cars and light trucks for U.S. sale are currently
covered by EPA's GHG program and are included in this report. Small businesses are exempted
from the program, and there are other manufacturers included in this report with unique
circumstances, as explained below. The report generally uses the common and recognizable
names for manufacturers, rather than their formal corporate names; "GM" instead of "General
Motors Corporation," "Ford" instead of "Ford Motor Company," Mercedes" instead of
"Mercedes-Benz," and so on.
1. Small Businesses
Small businesses are exempt from EPA's GHG standards given that these businesses would face
unique challenges in meeting the standards. However, the program allows small businesses to
waive their exemption and voluntarily comply with the GHG standards. For example, a small
manufacturer of electric vehicles could choose to comply if they were interested in generating
GHG credits and potentially participating in the credit market. For the purpose of this exemption,
a small business is defined using the criteria of the Small Business Administration (SB A). For
15 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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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.
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 SB A 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.16
To be eligible for deferment in each model year, a manufacturer must demonstrate a good faith
effort 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 was 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. Because of their conditionally exempt
status for the 2012 model year, these three manufacturers were not included in EPA's report that
covered that model year.1? 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. No conditional exemptions were approved for the 2013 model year, thus the three
companies noted above are included in this report and are expected to comply with the
provisions of the program. They may make use of certain flexibilities the program provides for
this category of manufacturers, including temporary relaxed standards and the ability to petition
EPA for alternative standards.
3. Operationally Independent Manufacturers
Some manufacturers, even though they may be wholly or largely owned by another
manufacturer, may consider themselves to be "operationally independent" from the company that
owns them. EPA's GHG program contains provisions that allow these manufacturers to seek
16 The deferment applies only to the fleet average COa standards; these manufacturers are required to meet the
applicable nitrous oxide (N2O) and methane (CH4) emission standards.
17 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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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 was owned by Fiat Chrysler
Automobiles (FCA) during the 2013 model year, petitioned EPA for operationally independent
status, and EPA granted this status to Ferrari starting with the 2012 model year.18 As an
operationally independent manufacturer with a low U.S. sales volume (1,902 cars in the 2013
model year), Ferrari has the same options as the three small volume manufacturers discussed
above. Ferrari was successful in acquiring a sufficient volume of credits from other
manufacturers to entirely offset their 2012 model year deficit, as described Section 4, and, as
seen in this report, the acquired credits also allowed them to substantially address their 2013
model year deficit.
4. Hyundai and Kia
Because of an ongoing investigation into Hyundai and Kia testing methods, their GHG
performance was excluded from EPA's previous GHG reports. Although fuel economy label
values were addressed with downward adjustments, the complete impact on their GHG values
was unknown and potentially dependent on the results of the investigation. The investigation
concluded with the announcement of a settlement on November 3, 2014. Hyundai and Kia will
pay a $100 million civil penalty to resolve alleged Clean Air Act violations based on their sale of
more than 1 million vehicles that collectively will emit approximately 4.75 million metric tons of
greenhouse gases in excess of what the automakers originally certified to the EPA. The
companies will forfeit GHG emission credits in order to be at the same compliance levels that
would have resulted if GHG emissions had been accurately reported for these vehicles in the first
place. The companies also will take measures to prevent future violations. On November 3,
2014, the EPA and the U.S. Department of Justice (DOJ) announced this settlement, and lodged
a consent decree embodying the settlement in the United States District Court for the District of
Columbia.19 The California Air Resources Board joined the United States as a co-plaintiff in this
settlement.20
With the impact of Hyundai and Kia testing issues on their GHG values now established, this
report is now able to include data from these companies going back to the 2009 model year. The
addition of these companies to the underlying data changes some of the fleet-wide results
presented in EPA's 2012 Performance Report; thus we present recalculated 2012 model year
results here so that appropriate comparisons can be made between 2012 and 2013 performance
and credit values. For example, we previously reported that the total fleet-wide over-compliance
18 Fiat Chrysler Automobiles (FCA) announced in October 2014 the intention to spin off Ferrari into a separate,
shareholder-owned company. At the time of writing this report, Fiat Chrysler Automobile executives were
indicating an intention to complete the spin-off in 2015. For the purpose of this report, however, Ferrari was
majority-owned by Fiat Chrysler Automobiles and held operationally independent status in the 2012 and 2013
model years.
19 See http://www2.epa.gov/enforcement/consent-decree-and-complaint-hyundai-and-kia-motor.
20 See http ://www2. epa. gov/enforcement/hyundai-and-kia-clean-air-act-settlement.
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in the 2012 model year was about 10 grams/mile, but the addition of the Hyundai and Kia data
changes this to a value of 11 grams/mile.
As described in the Consent Decree, which was entered by the United States District Court for
the District of Columbia on January 9, 2015, the companies have revised the GHG performance
values for more than one million vehicles and, based on these corrected values, revised their
reporting to EPA to account for the lower GHG performance of the affected vehicles. Most of
the 4.75 million metric tons that must be accounted for by the companies under the Consent
Decree is accounted for by the direct revision of GHG performance values of the affected
vehicles, yielding fewer credits generated in the affected model years than would otherwise have
been generated. The revised performance values do not fully account for the 4.75 million metric
tons, however, and the companies must forfeit additional credits to meet the terms of the Consent
Decree. In other words, the impact of using revised GHG values for affected vehicles reduced
their total credits relative to using uncorrected values by slightly less than 4.75 million Mg,
meaning that the companies must be debited an additional amount to comply with the terms of
the Consent Decree. As a result, Hyundai is forfeiting an additional 161,176 Megagrams and Kia
is forfeiting an additional 123,956 Megagrams. Both reductions will be taken from the 2013
model year balance of each company, as reflected in the cumulative results shown in Section 5.
At the time of publishing this report, Hyundai and Kia had submitted revised GHG reports
pursuant to the Consent Decree. The information from those revised reports appears in this EPA
report. The EPA is in the process of confirming the revised data and any corrections, if any are
necessary, will appear in a subsequent EPA report.
5. Aggregation of Manufacturers
We refer throughout this report to the names of manufacturers at the highest aggregated level,
and it may not be readily apparent who owns whom and which brands, divisions, subsidiaries, or
nameplates are included in the results of a given manufacturer. Table 1-1 shows how
manufacturers are aggregated based on the ownership relationships and vehicle partnerships in
the 2013 model year. Many other manufacturers are covered in the report, but their names and
brands are self-explanatory and thus are not shown in Table 1-1.
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Table 1-1. Aggregation of Manufacturers in the 2013 Model Year
Manufacturer
Manufacturers and Brands Included
BMW
Fiat Chrysler
Ford
GM
Honda
Mercedes
Nissan
Toyota
Volkswagen22
BMW, Mini, Rolls-Royce
Chrysler, Dodge, Fiat, Jeep, Maserati, Ram21
Ford, Lincoln
Buick, Cadillac, Chevrolet, GMC
Acura, Honda
Maybach, Mercedes, Smart
Infinity, Nissan
Lexus, Scion, Toyota
Audi, Bentley, Bugatti, Lamborghini, Volkswagen
21 As explained above, Ferrari was owned by Fiat Chrysler Automobiles in the 2013 model year. However, due to
the approved operational independence status of Ferrari (see Section 1.D.3), Ferrari is treated as a separate
manufacturer for the purposes of compliance with the GHG program and thus is shown as a separate entity in this
report.
22 In 2009 Volkswagen acquired 49.9 percent of Porsche, and 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 and included in
the Volkswagen fleet for compliance purposes.
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2. OPTIONAL GHG CREDITS FROM 2009-2011
MODEL YEARS
One of the 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. Because this was an optional program, without any compliance implications
in these early model years, only those manufacturers that 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 tailpipe CO2 reductions, improvements to air conditioning
systems that reduce refrigerant leakage or improve system efficiency, off-cycle credits for the
implementation of technologies that reduce CO2 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 CO2 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 tailpipe CO2 thresholds below
which manufacturers were able to generate early fleet average credits. For two of the pathways,
the tailpipe 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 tailpipe CO2 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").23
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
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 in the 2012 and later model years. Thus, even manufacturers with a deficit in one or
more of the early model years, (i.e., their tailpipe CO2 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. 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
23 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.
10
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credits by some manufacturers (see Section 4), while not shown in Table 2-1, has affected the
available credit balances of the manufacturers involved in such transactions, as has the use of
early credits to offset future 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 these credits are
permitted in the 2012 and 2013 model years.
In addition to the introduction of Hyundai and Kia in the updated data, there are two other factors
that may have changed the results of some manufacturers relative to what has been reported
previously by EPA. First, during the process of confirming credits with EPA, some
manufacturers discovered minor errors, the correction of which will be reflected in the data
presented in this report. Second, in the regulations establishing the 2017-2025 GHG standards,
EPA updated the method for determining credits for air conditioning refrigerant leakage by
referring to new and revised versions of Society of Automotive Engineers (SAE) technical
procedures. These updated and more accurate procedures became retroactively applicable to the
early credit model years, as well as all future model years.24 Although not required to do so,
some manufacturers chose to revisit their 2009-2011 air conditioning leakage credits and submit
the additional data required to generate credits using the updated SAE and regulatory procedures.
Manufacturers that chose to do so will show an increase in their early air conditioning leakage
credits relative to the credits shown in prior EPA reports.
24 Instead of using default values to describe the rate at which refrigerant permeates a given type of hose, the new
procedures allow the use of actual permeation rates as determined by an established SAE testing and measurement
methodology. Many hoses were out-performing the established default values, leading to lower real-world emission
rates (and thus higher emission credits) than were projected by the original and now superseded methodology.
11
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Table 2-1. Total Early Credits, by Manufacturer and Model Year (Mg)
Manufacturer
Aston Martin
BMW
Fiat Chrysler
Ford
GM
Honda
Hyundai
Kia
Mazda
Mercedes
Mitsubishi
Nissan
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Total
2009
1,547
445,683
5,926,979
8,358,440
13,009,374
14,073,890
4,605,933
3,134,775
1,405,721
96,467
625,166
10,496,712
1,620,769
448,408
0
31,325,738
2,243,205
204,460
98,023,267
2010
676
308,490
4,833,763
7,416,966
11,073,134
14,070,290
5,388,593
2,651,872
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
95,592,281
2011
1,109
250,119
(1,650,535)
300,482
482,321
7,370,928
4,012,969
4,657,545
875,213
157,685
302,394
1,852,749
1,909,106
98,860
14,192
14,651,963
1,386,537
176,462
36,850,099
Total
3,332
1,004,292
9,110,207
16,075,888
24,564,829
35,515,108
14,007,495
10,444,192
5,482,642
378,272
1,449,336
18,131,200
5,755,171
876,650
49,772
80,435,498
6,441,405
740,358
230,465,647
Table 2-2. Total Reported Early Credits, By Credit Category
Credit Category
Tailpipe CCb*
A/C Leakage
A/C Efficiency
Off -Cycle
Total
Credits (Mg)
198,792,034
23,438,974
8,229,007
5,632
230,465,647
Percent of
Total
86%
10%
4%
<0.01%
100%
Tailpipe CCh credits in the early credits program do not include credits
from flexible fuel vehicles.
Early credits from advanced technology vehicles (electric vehicles, plug-in hybrid electric
vehicles, and fuel cell vehicles) may be included in Table 2-2, depending upon how the
manufacturer chose to account for them. 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 calculations using zero grams
per mile to represent the operation using grid electricity (see the discussion of advanced
technology vehicles in Section 3.C for more information regarding this incentive). Alternatively,
the program allowed manufacturers to exclude them from their fleet average in the 2009-2011
model years and carry the vehicles forward into a future model year, where they must be used to
offset a GHG deficit. Four manufacturers had qualifying vehicles in the 2009-2011 model years.
12
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GM and Mercedes chose the latter approach, while Nissan and Tesla chose the former approach.
Advanced technology vehicle credits are discussed in more detail in Section 3.C which also
shows the production volumes of advanced technology vehicles for the 2009-2013 model years.
Again, previous EPA reports regarding EPA's GHG program should serve only as historical
references that are superseded by later reports. Each report is based on the best available data at
the time of publication. This report regarding the 2013 model year, and the accompanying data
for the 2009-2013 model years, should be used as the references from which to determine credit
balances and overall performance at the conclusion of the 2013 model year, and prior reports
should generally be considered obsolete.
13
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3. CREDITS REPORTED FROM THE 2012-2013
MODEL YEARS
The mandatory compliance calculations that manufacturers must perform are: (1) to determine
credits or deficits based on manufacturer-specific, vehicle footprint-based CO2 standards for both
car and truck fleets, and (2) to demonstrate compliance with N2O (nitrous oxide) and CH4
(methane) exhaust emission standards. Compliance with CO2 standards is assessed separately for
car and truck fleets at the end of each model year, using emission standards and fleet average
values determined based on the sales-weighted 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.
Although the minimum requirement is that manufacturers calculate credits (or deficits) based on
fleet average tailpipe CO2 emissions, manufacturers have several options to generate additional
credits as part of their overall strategy to reduce GHG emissions and meet the standards. These
options are described in detail in this report, and include credits for gasoline-ethanol flexible fuel
vehicles, improvements to air conditioning systems that increase efficiency and reduce
refrigerant leakage, reductions in emissions that aren't captured on EPA tests ("off-cycle"
emissions), transitional alternative standards (for eligible low-volume manufacturers), and
advanced technology vehicle incentives. The use of the optional credit provisions varies from
manufacturer to manufacturer (some manufacturers have not availed themselves of the extra
credit options, while others have used some combination of, or all, options available under the
regulations). Although a manufacturer's use of the credit programs is optional, EPA projected
that the standards would be met on a fleet-wide basis by using a combination of reductions in
tailpipe CO2 and use of the additional optional credit and incentive provisions in the regulations.
Compliance with the EPA GHG program is achieved with the use of many different building
blocks, starting with tailpipe emissions levels and, depending on need, strategy, and technology
development and availability, employing one or more credit or incentive programs as additional
elements contributing to compliance. Depending on the manufacturer, certain of these credit and
incentive building blocks may or may not be used. However, all manufacturers start with the
same two mandatory building blocks: (1) GHG emissions on a gram/mile basis as measured on
EPA test procedures, and (2) fleet-specific grams/mile CO2 standards based on the footprint of
models produced in each car and truck fleet in a given model year. If a manufacturer uses no
credits, incentive programs, or alternative standards (if applicable), then we can assess
compliance by comparing the fleet average emissions from the emission tests with the fleet-
specific footprint-based standards. However, most manufacturers are using some credits,
incentives, or alternative standards (if applicable), thus for those manufacturers (and for the
aggregated fleet as a whole) these building blocks must be accounted for before determining
whether or not a standard is met. Indeed, EPA's rulemaking analysis projected that the use of
credits and incentive programs was expected to be an integral part of achieving compliance,
especially in the early years of the program.
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We begin by discussing the "2- IMPORTANT NOTE REGARDING TABLES
cycle tailpipe GHG emissions A/r r. ,, . ,,. , c ,
', ,_ . AX , , , Many of tables in this section have a final row
value (Section 3.A), which is the «-, . T, , , T,, . ,. , , ,, , .
. v . '' ,. Fleet Total This row indicates a value that is
starting point for compliance for , , . ,, , ,, .. , , . , .
TTT , , ., calculated based on the entire model year fleet and is
SrfA^^^it ^dit'ancI nOt SpedflC °nly tO the manufacturers listed in the
ere i an table. For example, not all manufacturers generated
incentive programs, distilling each ,.. f ,.,. . , , , ,, c ,
F & & credits for air conditioning systems, but the final
to an overall grams/mile impact for
"Fleet Total" row in those tables indicates values that
each manufacturer. Section 3 .B are calculated to show the t of air conditioning
describes the temporary lead time credits Qn ^ entire model fle£t
allowance alternative standards c . ,,, * *u _* j
T . . _. _ . _ , ., manufacturers, whether or not they reported air
(TLAAS); Section 3.C describes .... A-+\
\ . ' , , . , . . conditioning credits).
alternative fuel vehicle incentives,
including the temporary flexible
fuel vehicle incentives; Section 3.D describes credits based on air conditioning system
improvements; Section 3.E describes off-cycle emission reductions; and Section 3.F discusses
the impact of alternative methane and nitrous oxide standards. Once these values have been
determined, the 2-cycle tailpipe value is reduced by the total of all the credit and incentive
programs to determine a "compliance value," as described in Section 3.G. Section 3.H describes
the derivation of manufacturer-specific CO2 standards, which leads into Section 3.1 which
concludes Section 3 by comparing the compliance values to the CO2 standards to determine
whether or not a given fleet generates credits or deficits in the 2013 model year. We also show
results aggregated on an industry-wide car and light truck fleet basis and an industry-wide total
combined fleet basis for informational purposes.
This report approaches the description of manufacturer compliance somewhat differently than
did the report for the 2012 model year. Instead of focusing on Megagrams of credits and deficits
(which is how credits are reported to EPA by the manufacturers), this section of the report will
describe compliance (for each manufacturer's car, truck, and combined fleets, as well as for the
aggregated industry) by describing each of the building blocks of compliance and the grams/mile
contribution to a manufacturer's total compliance. However, note that the grams/mile values are
calculated only for the purpose of this report, and are not specific compliance values defined in
the regulations.
A. "2-Cycle" Tailpipe COz Emissions
The starting point for each manufacturer is to test their vehicles on two test procedures defined in
EPA regulations: the Federal Test Procedure (known as the "City" test) and the Highway Fuel
Economy Test (the "Highway" test). These tests produce the raw emissions data that is
ultimately augmented by air conditioning credits, off-cycle credits, incentives for dual fuel
vehicles, and other provisions to produce the total compliance picture for a manufacturer's fleet.
Results from these two tests are averaged together, weighting the City results by 55% and the
Highway results by 45%, to achieve a single value for each vehicle model. A sales-weighted
average of all of the combined city/highway tailpipe values is calculated for each passenger car
and light truck fleet. This value represents the actual tailpipe CO2 emissions of a fleet without the
application of any additional credits or incentives, and as such, comparison with a fleet-specific
CO2 standard would be inappropriate.
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Table 3-1 shows the 2-cycle tailpipe emissions for the car, truck and combined fleets for each
manufacturer, for both the 2012 and 2013 model years.25 Absent the use of credits and
incentives, manufacturers demonstrated overall reductions in tailpipe GHG emissions in both the
car and truck categories in 2013 relative to 2012. On both a grams/mile and percentage basis the
most significant reductions from the 2012 to the 2013 model year came from Jaguar Land Rover
and Nissan, both of which achieved reductions of almost 30 grams/mile in their fleet-wide
tailpipe CO2 emissions. Mercedes and Subaru followed behind with reductions of six percent,
while most other manufacturers came in with more modest reductions of two to five percent. On
the other hand, Ford, Toyota, and Volvo each experienced small increases in overall GHG
emissions in 2013 relative to 2012. Ford, in particular, is an interesting case study that illustrates
the interaction of different inputs and the influence on some of these values. From 2012 to 2013
Ford decreased the CO2 emissions of their car and truck fleets by 5 and 10 grams/mile,
respectively, yet on an overall combined fleet basis their emissions increased by 6 grams/mile
(about two percent) in 2013. What lies behind the 6 grams/mile CO2 overall emissions increase,
when both cars and trucks showed reductions, is a shift in Ford's fleet from 40% trucks in the
2012 model year to 51% trucks in the 2013 model year (see Appendix B for car and truck
production volume data). This shift, combined with the higher VMT of trucks (see inset in
Section l.B for a description of VMT values for cars and trucks), leads to Ford's overall increase
in 2-cycle tailpipe emissions in the 2013 model year, despite showing an improvement in both
car and truck categories. Note that this does not indicate anything in particular about Ford's
overall compliance with the program, which is based upon an aggregation of all credits and
deficits and not solely on the 2-cycle tailpipe emissions shown in Table 3-1. In fact, Ford
continues to generate net credits in both their car and truck fleets and has fully complied with the
standards in both 2012 and 2013 model years.
25 The values in this table do not include the impacts of credits or incentives resulting from FFVs, CNG vehicles, air
conditioning improvements, and off-cycle technologies. The impact of these is detailed in subsequent sections. The
values also reflect that direct tailpipe GHG emissions from electricity are zero. Because the values in this table do
not include these credits and incentives, the table does not describe a manufacturer's actual model year performance
or a manufacturer's compliance position at the end of the 2013 model year.
16
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Table 3-1. "2-cycle" Tailpipe COz Production-Weighted Fleet Average Emissions (g/mi)
Manufacturer
Aston MartinAB
BMW
BYD Motors8
Coda8
Ferrari8
Fiat Chrysler
Fisker8C
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
LotusAB
Mazda
McLarenAB
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla8
Toyota
Volkswagen
Volvo
Fleet Total
Model Year 2012
Cars
111
0
0
494
300
146
261
283
237
243
376
258
241
316
262
258
325
257
267
0
221
274
297
259
Trucks
363
384
385
397
320
312
439
324
324
393
283
382
362
296
361
354
330
343
369
All
302
0
0
494
357
146
315
331
266
249
426
266
263
343
267
295
342
282
287
0
273
281
311
302
Model Year 2013
Cars
444
271
0
0
475
289
256
273
228
238
342
252
334
232
374
296
254
232
309
254
266
0
224
272
292
251
Trucks
346
380
375
395
312
317
414
301
296
371
267
340
363
270
330
347
327
348
360
All
444
292
0
0
475
344
321
325
257
241
398
254
334
251
374
321
258
266
336
264
273
0
278
279
318
294
Change,
2012 to
Cars Trucks
(6)
0
0
(19)
(11)
(5)
(10)
(9)
(5)
(34)
(6)
(9)
(20)
(8)
(26)
(16)
(3)
(1)
0
3
(2)
(5)
(8)
(17)
(4)
(10)
(2)
(8)
5
(25)
(23)
(28)
(22)
(16)
(42)
1
(26)
(31)
(7)
(3)
5
(10)
2013
All
(10)
0
0
(19)
(13)
6
(6)
(9)
(8)
(28)
(12)
(12)
(22)
(9)
(29)
(6)
(18)
(14)
0
5
(2)
7
(8)
AExemptfrom compliance with 2012 model year standards. BOnly manufactures cars. Did not produce any 2013
model year vehicles. This table was updated on March 31, 2015 to correct errors limited to 2-cycle tailpipe CO?
values for manufacturers using the Temporary Lead-time Allowance Alternative Standards (see Section 3.B).
B. TLAAS Program Standards
EPA established the Temporary Lead-time Allowance Alternative Standards (TLAAS) to assist
manufacturers with limited product lines that may be especially challenged in the early years of
EPA's GHG program. The TLAAS program was established to provide additional lead-time for
manufacturers with narrow product offerings which 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.
In the 2012 model year the program was used by Ferrari, Jaguar Land Rover, Mercedes, and
Porsche. Aston Martin, Lotus, and McLaren - companies that were exempt from the 2012
17
-------
standards under the program's small volume manufacturer provisions -joined the program in the
2013 model year and incorporated use of the TLAAS standards in their 2013 model year
compliance.
The TLAAS program applies only to manufacturers with 2009 model year U.S. sales of less than
400,000 vehicles, 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 CO2 standard applies. Specifically, a qualifying
manufacturer may place up to 100,000 vehicles (combined cars and trucks) under the less
stringent standards over the four model years from 2012 through 2015 (i.e., this is a total
allowance, not an annual allowance). The CO2 standard applied to this limited fleet is 1.25 times
- or 25 percent higher than - the standard that would otherwise be calculated for the fleet under
the primary program. Manufacturers with 2009 model year U.S. sales of less than 50,000
vehicles are allowed an additional 150,000 vehicles (for a total of 250,000 vehicles at the 25
percent higher standard), 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 its use only those manufacturers that truly need it. Manufacturers using the
TLAAS program may not sell credits, they may not bank credits that are accrued by their non-
TLAAS fleets, they must use up any banked credits before utilizing a TLAAS fleet, and the
movement of credits between a manufacturer's TLAAS and non-TLAAS fleets is restricted.
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 program in the 2012 and 2013 model
years. The smallest-volume companies (Aston Martin, Ferrari, Lotus, and McLaren) placed all of
their 2013 production into a TLAAS fleet, because they can do so without any risk of exceeding
the applicable limits. Porsche, which has placed all of its 2012 and 2013 vehicles in the TLAAS
program to date (totaling more than 70,000 vehicles), would reach the 100,000 vehicle limit in
the 2014 model year except for the fact that they will be aggregated with the Volkswagen fleet in
the 2014 model year and no longer eligible to use the TLAAS program.
Table 3-2 shows each manufacturer's use of the TLAAS program for the 2012 and 2013 model
years. By virtue of their 2009 model year sales volume being lower than 50,000 vehicles, Jaguar
Land Rover qualifies for the "extended" TLAAS program, and thus they have about 165,000
vehicles remaining to which they may apply the TLAAS standards through the 2016 model year.
Mercedes is subject to the 100,000 vehicle allotment, and thus can distribute about 40,000 more
vehicles into the TLAAS program across the 2014 and 2015 model years. Note that the total of
219,320 vehicles placed under the less stringent standards in the program to date represents less
than one percent of the total vehicles produced in the 2012 and 2013 model years.
While required by the regulations, the complexity of reporting credits and deficits in Megagrams
of CO2 can sometimes obscure the progress that companies are actually making towards
reducing their GHG emissions. The approach we have developed in this report provides the
transparency needed to be able to make these evaluations. Mercedes and Jaguar Land Rover, the
18
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largest of the manufacturers using these temporary and limited alternative standards, both made
substantial progress reducing tailpipe GHG emissions from 2012 to 2013. As shown in the
previous section, Jaguar Land Rover reduced their overall tailpipe emissions by 28 grams/mile,
Mercedes reduced their emissions by 22 grams/mile, Ferrari reduced their tailpipe emissions by
19 grams/mile, and Porsche reduced their tailpipe GHG emissions by a more modest 6
grams/mile.
Table 3-2. Production Volumes Assigned To TLAAS Standards
Manufacturer
Aston Martin
Ferrari
Jaguar Land
Rover
Lotus
McLaren
Mercedes
Porsche
Fleet Total
Model Year 2012
Cars
1,510
12,769
10,585
16,946
41,810
Trucks
32,706
20,230
12,927
65,863
All
1,510
45,475
30,815
29,873
107,673
Model
Year 2013
Cars Trucks
364
1,902
9,410
170
412
6
22,021
34,285
29,464
28,437
19,461
77,362
All
364
1,902
38,874
170
412
28,443
41,482
111,647
Cumulative
Total
364
3,412
84,349
170
412
59,258
71,355
219,320
To understand the impact of the TLAAS program on compliance with EPA's GHG program, we
determined the grams/mile "benefit" achieved by each manufacturer and accrued for each fleet
as a result of using the TLAAS program. For manufacturers placing all their vehicles in a
TLAAS fleet the calculation is easy; it is simply the difference between the TLAAS program
standard and the Primary Program standard that would have otherwise applied. For
manufacturers with a mix of TLAAS and Primary Program vehicles in each fleet, we determined
the difference in the total credits (in Megagrams) for each fleet with the use of TLAAS and
without the use of TLAAS. This difference was then converted to grams/mile, and the resulting
values are shown in Table 3-3. The final row in the table indicates the overall impact from the
use of the TLAAS program on the entirety of the 2012 and 2013 model year fleets, not just the
set of manufacturers enrolled in the TLAAS program. Thus, the overall net impact on the 2013
fleet of the TLAAS program is 0.6 g/mi.
19
-------
Table 3-3. Net Impact From Use Of The TLAAS Program (g/mi)
Manufacturer
Aston Martin
Ferrari
Jaguar Land Rover
Lotus
McLaren
Mercedes
Porsche
Fleet Total
2012 Model Year
Cars
69
73
4
66
0.3
Trucks
64
22
84
1.2
All
69
66
10
75
0.7
2013 Model Year
Cars
64
66
41
62
66
0
63
0.2
Trucks
49
27
82
1.2
All
64
66
47
62
66
9
73
0.6
C. Credits Based On Alternative Fuel Vehicles
EPA's GHG program contains several credits and incentives for dedicated and dual fuel
alternative fuel vehicles. Dedicated alternative fuel vehicles are vehicles that run exclusively on
an alternative fuel (e.g., compressed natural gas, electricity). Dual fuel vehicles can run both on
an alternative fuel and on a conventional fuel such as gasoline; the most common is the gasoline-
ethanol flexible fuel vehicle, which is a dual fuel vehicle that can run on E85 (85 percent ethanol
and 15 percent gasoline), or on conventional gasoline, or on a mixture of both E85 and gasoline
in any proportion. Dual fuel vehicles also include vehicles that use compressed natural gas
(CNG) and gasoline, or electricity and gasoline. This section separately describes three different
and uniquely-treated categories of alternative fuel vehicles: advanced technology vehicles using
electricity or hydrogen fuel cells; compressed natural gas vehicles; and gasoline-ethanol flexible
fuel vehicles.
1. Advanced Technology Vehicles
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 (and,
starting with the 2017 model year, CNG 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. 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 GM and Mercedes selected an
option in the early credit provisions by which they set aside their 2011 model year advanced
technology vehicles for inclusion in a future model year, meaning that the impact of these
vehicles - albeit small - has yet to be seen in any model year.
All manufacturers of advanced technology vehicles in the 2012 and 2013 model years are well
below the cumulative 200,000 vehicle limit for the 2012-2016 model years, thus all
20
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manufacturers remain eligible to continue to use zero grams/mile. If a manufacturer were to
reach the cumulative production limit before the 2017 model year, then advanced technology
vehicles produced beyond the limit must account for the net "upstream" emissions associated
with their vehicles' use of grid electricity relative to vehicles powered by gasoline. Based on
vehicle electricity consumption data (which includes vehicle charging losses) and assumptions
regarding GHG emissions from today's national average electricity generation 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 a typical 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.26
The nature of this incentive is such that it is reflected in the 2-cycle emissions values shown in
Section 3.A. For example, the incentive allows Tesla to record zero grams/mile for their fleet
(see Table 3-1) in the 2013 model year. Without the incentive, however, the 2-cycle fleet average
GHG emissions for Tesla would in fact be about 122 grams/mile.27 Use of the incentive in
Tesla's case allows them to generate an additional 425,000 Mg of GHG credits relative to using
the net upstream value of 122 grams/mile. Nissan's 2013 passenger car fleet benefits similarly
from the ability of the electric Leaf to use zero grams/mile instead of the calculated net upstream
value of 70 grams/mile.28 As a result, the overall impact on Nissan's passenger car fleet is an
improvement of two grams/mile, allowing them to generate almost 360,000 Mg of credits more
than if the incentive provisions were not in place. The net impact from Nissan and Tesla on the
entire 2013 model year fleet of this incentive is thus almost 800,000 Mg of credits, or about 0.3
grams/mile. While there are other electric vehicles and plug-in hybrid electric vehicles in the
2013 fleet, as shown in Table 3-4, Nissan and Tesla account for almost half of the 2013 model
year volume of these vehicles. A few thousand of the remaining vehicles are electric vehicles,
but the majority are plug-in hybrid electric vehicles, which will have a smaller overall impact
than electric vehicles because of their use of gasoline in addition to electricity (the other
companies with larger volumes in this technology segment - GM and Ford - are selling far more
plug-in hybrids than dedicated electric vehicles). Because it is unlikely that the total impact of
this incentive exceeds 0.5 grams/mile across the 2013 model year fleet, we have not carried out
the analysis for all advanced technology vehicles. Determining the net upstream values for plug-
in hybrid electric vehicles is particularly cumbersome and will not add much to an already-
minimal impact, thus we have avoided those analyses for this report. In the future, however, it
may be more important, interesting, and useful to have a complete assessment of the impact of
incentives for these vehicles. Table 3-4 shows the 2010-2013 production volumes of advanced
technology vehicles that applied the zero gram/mile incentive.
26 See 40 CFR 600.113-12, paragraph (n).
27 Using the calculations prescribed in the regulations, the sales-weighted upstream emissions for Tesla's 2013
passenger cars is 205 grams/mile and the upstream emissions associated with a comparable gasoline vehicle is 83
grams/mile. The difference, or the net upstream emissions of Tesla's 2013 passenger car fleet, is 122 grams/mile.
28 The upstream emission value for the Nissan Leaf is 141 grams/mile and the upstream emissions associated with a
comparable gasoline vehicle is 71 grams/mile. The difference, or the net upstream emissions of the 2013 Leaf, is 70
grams/mile.
21
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Table 3-4. Production Volumes of Advanced Technology Vehicles Using Zero
Grams/Mile Incentive, by Model Year
Manufacturer
BYD Motors
Coda
Fiat Chrysler
Fisker
Ford
GM
Honda
Mercedes
Mitsubishi
Nissan
Tesla
Toyota
Total
2010 2011
4,370
546
8,495
599 269
599 13,680
2012
11
1,415
653
18,355
25
1,435
11,460
2,952
452
36,758
2013
32
37
2,353
18,654
27,484
471
880
26,167
17,813
829
94,720
Total
43
37
2,353
1,415
19,307
50,209
471
1,451
1,435
46,122
21,633
1,281
145,757
2. Compressed Natural Gas Vehicles
The Honda Civic CNG was the only compressed natural gas (CNG) vehicle produced for general
purchase by consumers in the 2012 and 2013 model years, and is a dedicated alternative fuel
vehicle. EPA's GHG program contains a temporary incentive for CNG vehicles that applies
through the 2015 model year. This incentive, which parallels the incentive offered these vehicles
in the CAFE program, allows a CNG vehicle to be represented in the fleet average calculation by
a reduced GHG value that is determined by measuring the tailpipe emission of the vehicle and
then multiplying by 0.15. This is effectively the same incentive as under the CAFE program,
except that fuel economy is divided, not multiplied, by 0.15.29 The Civic CNG, which has actual
tailpipe GHG emissions of 162 g/mi, is thus "counted" in Honda's fleet average passenger car
calculation with a GHG emissions value of 24 g/mi. Although the vehicle-specific incentive is
large (a reduction of 138 grams/mile), the net impact on Honda's car fleet is less than 0.01
grams/mile. This does not affect Honda's overall rounded car fleet average performance value,
and likewise has an unnoticeable impact on the overall 2013 model year fleet. If the volume of
CNG vehicles (either dual fuel or dedicated vehicles) increases substantially in the future, it will
become more important for us to be able to separate out the impact of current and future
incentives for these vehicles in a transparent manner.
3. Gasoline-Ethanol Flexible-Fuel Vehicles
The impact of FFVs is easy to determine because we calculate fleet average GHG values both
with and without the incentives in order to ensure that no manufacturer exceeds the maximum
allowable value of the incentive. Under the GHG program, EPA allows FFV credits intended to
29 Use of the 0.15 factor for CNG sunsets after the 2015 model year. Starting with the 2017 model year a production
multiplier incentive becomes effective. See 40 CFR 86.1866-12(b).
22
-------
correspond 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 FFVs operate 50% of the time on the alternative fuel and 50% of
the time on conventional fuel, resulting in CO2 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 factor. The 0.15 factor is used because, under the CAFE
program, 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 of the GHG program.
For example, for a flexible-fuel vehicle that emits 330 g/mi CO2 while operating on E-85 and
350 g/mi CO2 while operating on gasoline, the resulting CO2 level to be used in the
manufacturer's fleet average calculation would be:
[(330 x 0.15) + 350]
CO2 = + =199.8 g/mi
EPA realizes that by temporarily using the CAFE-based approachincluding the 0.15 factor
the CO2 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 "incentive" being provided to FFVs. Under the GHG
program, FFV credits are available only through the 2015 model year; starting in model year
2016, GHG compliance values are based on actual emissions performance of the FFV on
conventional and alternative fuels, weighted by EPA's assessment of the actual use of these fuels
in FFVs.30 In fact, the standards in the early years of the GHG program were developed with an
explicit understanding that manufacturers would make use of this and other incentive and credit
programs to meet the standards.
In the 2013 model year the dual-fuel credit limit in the CAFE program is 1.2 mpg across a
manufacturer's separate car and truck fleets (dedicated alternative fuel vehicles and vehicles that
use electricity are not subject to this limit on credits). In other words, FFVs may not increase a
manufacturer's average fuel economy for its car or truck fleets by more than 1.2 mpg. To parallel
the CAFE limitations, the GHG program contains a similar credit limit, but calculated in terms of
CO2 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 CO2 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 CO2 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 value.
Seven manufacturers produced FFVs in the 2013 model year, as shown below in Tables 3-5 and
3-6. Clearly, Fiat Chrysler Automobiles, Ford, and GM produced the overwhelming majority of
vehicles capable of operating on E85. Note that the number of models shown in Table 3-5 is
based on EPA's "model type" designation (used for EPA Fuel Economy and Environment
30 EPA Guidance Letter "E85 Flexible Fuel Vehicle Weighting Factor for Model Year 2016-2018 Vehicles," CD-
14-18, November 12, 2014.
23
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Labels), and is not equivalent to "nameplate." 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 truck
models shown in Table 3-5 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, and
truck FFV production makes up nearly 70% of all FFV production in the 2013 model year.
While all but Nissan increased FFV production in the 2013 model year, the increases from Ford
and GM account for 80 percent of the overall increase in FFVs from 2012 to 2013. Although a
small producer of FFVs , Volkswagen dramatically increased its investment in FFVs, more than
doubling the number of models and increasing FFV production from about 2,000 in the 2012
model year to more than 50,000 vehicles in the 2013 model year.
Table 3-5. Number of FFV Models by Manufacturer, 2012-2013 Model Years
Model
Year
2012
2013
Category
Car
Truck
All
Car
Truck
All
cu
u
4-1
CD
LL.
10
11
21
10
13
23
o
LL.
7
23
30
6
23
29
§
(D
19
60
79
18
58
76
01
o
<1>
u
01
^
5
1
6
7
1
8
c
CD
z
-
4
4
-
4
4
CD
Q
1-
-
2
2
-
2
2
0)
CuO
CD
I/)
O
**
4
-
4
10
1
11
Total
45
101
146
51
102
153
24
-------
Table 3-6. Production Volume of FFVs by Manufacturer, 2012-2013 Model Years
Model
Year
2012
2013
Category
Car
Truck
All
Car
Truck
All
cu
u
4-1
CD
LL.
105,174
453,399
558,573
142,158
431,359
573,517
o
o
LL.
174,597
323,563
498,160
209,988
546,695
756,683
S
(D
396,264
511,183
907,447
374,354
637,576
1,011,930
01
o
01
u
cu
^
13,493
8,289
21,782
34,493
22,082
56,575
E
CD
vt
vt
Z
-
24,154
24,154
-
13,650
13,650
CD
O
1-
-
31,670
31,670
-
33,203
33,203
0)
CuO
CD
"5
**
2,060
-
2,060
30,346
20,799
51,145
Total
691,588
1,352,258
2,043,846
791,339
1,705,364
2,496,703
Table 3-7 shows the impact of FFVs on each manufacturer's fleet for the 2012 and 2013 model
years. Fiat Chrysler, Ford, GM, and Mercedes all maximized the FFV credit in both car and truck
fleets in the 2013 model year. Volkswagen likewise maximized FFV credits in their truck fleet.
In other words, these manufacturers produced more than enough FFVs - or just enough - to
claim the maximum FFV benefit. Even with Volkswagen's rapid increase in the deployment of
FFVs, the overall impact of FFVs on the fleet as a whole remained steady from 2012 to 2013, at
8 g/mi.
Table 3-7. Net Credits Accrued From Use Of The FFV Incentives (g/mi)
Manufacturer
Fiat Chrysler
Ford
GM
Mercedes
Nissan
Toyota
Volkswagen
Fleet Total
2012 Model Year
Cars
13*
9
11*
11
0
0
1
4
Trucks
21*
21*
23*
15
15
9
0
14
All
18
14
16
13
4
4
1
8
2013 Model Year
Cars
12*
9*
10*
12*
0
0
7
4
Trucks
21*
20*
22*
12*
8
8
15*
14
All
17
15
15
12
3
4
8
8
*Achieved the maximum allowable FFV credit for this fleet.
D. Credits Based on Air Conditioning Systems
Over 99% 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
25
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provide mechanical power to the A/C system (sometimes called "indirect emissions"). The high
global warming potential of the current automotive refrigerant, HFC-134a, 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 CO2. The impacts of refrigerant leakage can be reduced significantly by
systems that incorporate leak-tight components, or, ultimately, by using a refrigerant with a
lower global warming potential. The A/C system also contributes to increased tailpipe CO2
emissions through the additional work required to operate the compressor, fans, and blowers.
This additional power demand is ultimately met by using additional fuel, which is converted into
CO2 by the engine during combustion and exhausted through the tailpipe. These emissions can
be reduced by increasing the overall efficiency of an A/C system, thus reducing the additional
load on the engine from A/C operation, which in turn means a reduction in fuel consumption and
a commensurate reduction in GHG emissions. Manufacturers may generate and use credits for
improved A/C systems in complying with the CO2 fleet average standards in the 2012 and later
model years (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.
Sixteen manufacturers used the A/C credit provisions - either for leakage reductions, efficiency
improvements, or both - as part of their compliance demonstration in the 2013 model year.
The A/C provisions are structured as additional and optional credits, unlike the CO2 standards for
which manufacturers must demonstrate compliance using the EPA exhaust emission test
procedures. The EPA compliance 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 3-8 (note that
because not all manufacturers participated in the early credits program, credit volumes and
percentages from 2009-2011 and 2012-2013 are not comparable). Table 3-9 shows the total air
conditioning credits (combined leakage and efficiency credits, in Megagrams) reported by each
manufacturer in the 2013 model year, and the grams/mile impact across their entire vehicle fleet.
Like the TLAAS program and alternative fuel vehicle incentives, EPA's standards are predicated
in part upon manufacturers earning credits for reducing GHG emissions from A/C systems.
Table 3-10 shows the benefit of air conditioning credits, translated from Megagrams to
grams/mile, for each manufacturer's fleet for the 2012 and 2013 model years.
26
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Table 3-8. Reported Air Conditioning Credits by A/C Credit Type and Model Year
Model Year
2009
2010
2011
2012
2013
Total
Leakage Credits
% of Total
Megagrams A/C Credits
6,247,698 75%
8,323,530 75%
8,867,746 72%
11,096,821 66%
13,229,754 62%
47,765,549 68%
Efficiency Credits
% of Total
Megagrams A/C Credits
2,058,069 25%
2,731,927 25%
3,439,011 28%
5,803,156 34%
8,245,194 38%
22,277,357 32%
Total (Mg)
8,305,767
11,055,457
12,306,757
16,899,977
21,474,948
70,042,906
Table 3-9. Reported Air Conditioning Credits by Manufacturer, 2013 Model Year
Manufacturer
Aston Martin
BMW
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
A/C Leakage
Credits
(Mg)
243
407,741
2,422
2,298,648
3,307,162
3,294,795
569,957
477,903
62,271
286,657
307,679
202,036
1,539,988
369,092
103,160
13,229,754
A/C Efficiency
Credits
(Mg)
384
304,640
1,388
1,014,663
745,248
1,238,996
505,625
603,761
54,345
342,238
314,713
813,915
19,826
1,731,461
498,037
55,954
8,245,194
Total A/C Credits
(Mg)
627
712,381
3,810
3,313,311
4,052,410
4,533,791
1,075,582
1,081,664
116,616
628,895
622,392
1,015,951
19,826
3,271,449
867,129
159,114
21,474,948
Gram/Mile
Equivalent of
Total A/C Credits
9
9
10
10
8
9
4
5
8
5
10
4
6
7
7
10
7
27
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Table 3-10. Net Impact of Air Conditioning Credits (g/mi)
Manufacturer
Aston Martin
BMW
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
2012 Model Year
Cars
7
10
9
5
8
3
4
5
5
9
2
6
7
6
10
6
Trucks
11
10
8
8
4
7
8
4
11
4
6
9
12
8
All
8
10
10
6
8
3
5
7
5
10
3
6
7
7
11
6
2013 Model Year
Cars
9
8
10
10
7
9
3
5
5
5
9
4
6
7
6
10
7
Trucks
11
11
8
9
5
7
9
9
12
4
7
10
11
8
All
9
9
10
10
8
9
4
5
8
5
10
4
6
7
7
10
7
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.31 This score is based on the number,
performance, and technology of the components, fittings, seals, and hoses of the A/C system, and
on the global warming potential (GWP) of the refrigerant.32 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
VMT of the vehicle class (car or truck) and the production volume of the vehicles employing that
A/C system.
In the 2012 model year, all leakage credits were based on improvements to the A/C system
components, e.g., to O-rings, seals, valves, and fittings. In the 2013 model year both GM and
Honda introduced vehicles that further reduce the impacts of A/C system leakage by using HFO-
1234yf, a relatively new low-GWP refrigerant. These two manufacturers are the first to introduce
31 See 40 CFR 86.1867-12.
32 The global warming potential (GWP) represents how much a given mass of a chemical contributes to global
warming over a given time period compared to the same mass of carbon dioxide. Carbon dioxide's GWP is defined
as 1.0.
28
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this refrigerant in U.S. vehicle models. HFO-1234yf has an extremely low GWP of 4, as
compared to a GWP of 1430 for HFC-134a, the refrigerant currently used throughout the
industry. GM introduced HFO-1234yf in the Cadillac XTS and Honda implemented it in the Fit
EV. Although the sales volumes of these vehicles are not high (about 42,000 for the XTS and
about 500 for the Fit EV), the potential of low-GWP refrigerants is readily apparent. Using HFO-
1234yf instead of HFC-134a effectively doubled the leakage credits generated by these models.
For GM this meant a gain in leakage credits of about 56,000 Mg that would not be possible
without the new refrigerant. Given that leakage credits for most manufacturers are in the range of
4-6 grams/mile using HFC-134a, the potential for additional credits - and real-world GHG
reductions - is significant.
Fifteen manufacturers reported A/C leakage credits in the 2013 model year, as shown in Table 3-
11. These manufacturers reported more than 13 million Mg of A/C leakage credits in 2013,
almost one third of the total net credits reported for the model year, and accounting for about 4
grams/mile across the 2013 vehicle fleet. Table 3-12 shows the leakage credits in grams/mile for
the 2012 and 2013 model years.
Table 3-11. Reported Air Conditioning Leakage Credits by Manufacturer and Fleet,
2013 Model Year (Mg)
Manufacturer
Aston Martin
BMW
Ferrari
Fiat Chrysler
Ford
GM*
Honda*
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Toyota
Volkswagen
Volvo
Fleet Total
Car
243
251,534
2,422
796,491
1,237,391
1,775,294
264,376
445,426
8,359
264,796
175,482
38,523
816,463
290,530
51,622
6,418,952
Truck
156,207
1,502,157
2,069,771
1,519,501
305,581
32,477
53,912
21,861
132,197
163,513
723,525
78,562
51,538
6,810,802
Total
243
407,741
2,422
2,298,648
3,307,162
3,294,795
569,957
477,903
62,271
286,657
307,679
202,036
1,539,988
369,092
103,160
13,229,754
Gram/Mile
Equivalent of
Total Credits
3
5
7
7
7
7
2
2
4
2
5
1
3
3
7
4
* Some vehicles equipped with systems using HFO-1234yf, a low-GWP refrigerant.
29
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Table 3-12. Air Conditioning Leakage Credits (g/mi)
Manufacturer
Aston Martin
BMW
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Toyota
Volkswagen
Volvo
Fleet Total
2012 Model Year
Cars
4
6
6
4
6
1
2
3
2
4
0
3
2
6
3
Trucks
7
8
7
7
2
4
4
3
7
2
3
4
8
6
All
5
6
7
6
6
2
2
4
2
5
1
3
2
7
4
2013 Model Year
Cars
3
4
7
6
5
6
1
2
3
2
4
0
3
3
6
4
Trucks
7
8
7
7
3
4
5
6
7
2
3
5
7
6
All
3
5
7
7
7
7
2
2
4
2
5
1
3
3
7
4
2. Air Conditioning Efficiency Credits
Manufacturers that make improvements in their air conditioning systems to increase efficiency,
and thus reduce CO2 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 pressurizes the refrigerant and pumps it 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 CCh). The total tons of credits are then based on the total volume of vehicles in a model year
using these technologies.
Sixteen manufacturers used the provisions that allow credits based on improvements to the
overall efficiency of the A/C system, as shown in Table 3-13. These manufacturers reported a
total of more than 8 million Mg of CO2 A/C efficiency credits in the 2013 model year, or about
20% of the total net credits reported by the industry and accounting for about 3 grams per mile
30
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across the 2013 fleet. Table 3-14 shows the efficiency credits in grams/mile for the 2012 and
2013 model years.
Table 3-13. Reported Air Conditioning Efficiency Credits by Manufacturer and
Fleet, 2013 Model Year (Mg)
Manufacturer
Aston Martin
BMW
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
Car
384
208,519
1,388
421,109
461,932
821,301
324,172
571,743
6,780
329,198
207,180
623,973
19,826
1,053,911
417,724
30,611
5,499,751
Truck
96,121
593,554
283,316
417,695
181,453
32,018
47,565
13,040
107,533
189,942
677,550
80,313
25,343
2,745,443
Total
384
304,640
1,388
1,014,663
745,248
1,238,996
505,625
603,761
54,345
342,238
314,713
813,915
19,826
1,731,461
498,037
55,954
8,245,194
Grams/Mile
Equivalent of
Total Credits
5
4
4
3
1
3
2
3
4
3
5
3
6
4
4
4
3
31
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Table 3-14. Air Conditioning Efficiency Credits (g/mi)
Manufacturer
Aston Martin
BMW
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
2012 Model Year
Cars
3
4
3
0
2
2
3
2
3
5
2
6
4
4
4
2
Trucks
4
2
0
1
2
3
4
1
5
2
2
5
4
2
All
3
4
3
0
2
2
3
4
3
5
2
6
3
4
4
2
2013 Model Year
Cars
5
4
4
3
2
3
2
3
2
3
5
3
6
4
4
4
3
Trucks
4
3
1
2
2
4
4
3
5
2
3
5
4
2
All
5
4
4
3
1
3
2
3
4
3
5
3
6
4
4
4
3
E. Credits Based On "Off-Cycle" Technology
"Off-cycle" emission reductions can be achieved by employing technologies that result in real-
world benefits, but where that benefit is not adequately or entirely captured on the test
procedures used by manufacturers to demonstrate compliance with emission standards. EPA's
light-duty vehicle greenhouse gas program acknowledges these benefits by giving automobile
manufacturers several options for generating "off-cycle" carbon dioxide (CCh) credits. EPA's
light-duty vehicle greenhouse gas (GHG) program provides three pathways by which a
manufacturer may accrue off-cycle CO2 credits. The first is a predetermined list of credit values
for specific off-cycle technologies that may be used beginning in model year 2014.33 This
pathway allows manufacturers to use conservative credit values established by EPA for a wide
range of technologies, with minimal data submittal or testing requirements. In cases where
additional laboratory testing can demonstrate emission benefits, a second pathway allows
manufacturers to use a broader array of emission tests (known as "5-cycle" testing because the
methodology uses five different testing procedures) to demonstrate and justify off-cycle CO2
credits.34 The additional emission tests allow emission benefits to be demonstrated over some
elements of real-world driving not captured by the GHG compliance tests, including high speeds,
rapid accelerations, and cold temperatures. Credits determined according to this methodology do
not undergo additional public review. The third and last pathway allows manufacturers to seek
33See40CFR86.1869-12(b).
34See40CFR86.1869-12(c).
32
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EPA approval to use an alternative methodology for determining the off-cycle CO2 credits.35
This option is only available if the benefit of the technology cannot be adequately demonstrated
using the 5-cycle methodology. Manufacturers may also use this option for model years prior to
2014 to demonstrate off-cycle CO2 reductions for technologies that are on the predetermined list,
or to demonstrate reductions that exceed those available via use of the predetermined list.
As was the case in the 2012 model year, GM is the only manufacturer to have requested and
been granted off-cycle credits. These credits are for a technology used on certain GM gasoline-
electric hybrid vehicles. 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. In the 2013 model year the technology was
applied to GM's full-size hybrid trucks as well as the Buick LaCrosse, Buick Regal, and
Chevrolet Malibu models equipped with GM's "eAssist" technology (about 2,000 trucks and
45,000 cars). These 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. The off-cycle credits reported by GM in the 2009-2013 model years are shown in Table
3-15. The calculated gram/mile benefit rounds to zero because of the low volume of these
credits, thus the table does not display these credits in equivalent grams/mile.
Table 3-15. Off-Cycle Credits Reported by GM
(Mg)
Model Year
2009
2010
2011
2012
2013
Total
Car
-
-
-
4,984
13,330
18,314
Truck
3,329
965
1,338
838
819
7,289
Total
3,329
965
1,338
5,822
14,149
25,603
In the fall of 2013, Mercedes requested off-cycle credits for the following technologies in use or
planned for implementation in the 2012-2016 model years: stop-start systems, high-efficiency
lighting, infrared glass glazing, and active seat ventilation. Per the regulations, EPA sought
public comment on Mercedes' proposed methodology, and considered those public comments in
making a final determination on the level of off-cycle credits for these Mercedes technologies.
EPA approved methodologies for Mercedes to determine these off-cycle credits in September of
35See40CFR86.1869-12(d).
33
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2014.36 Although the credits were approved for use in the 2012-2016 model years, we do not
expect (or require) data to be submitted until the 2014 model year data is due at the end of the
first quarter of 2015. Thus, Mercedes off-cycle credits do not appear in this report and will be
presented in subsequent GHG performance reports issued by EPA.
F. Deficits Based On Methane and Nitrous Oxide Standards
EPA finalized emission standards for methane (CH/t) 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 of CH4 and N2O 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, EPA also allows an alternative CCh-
equivalent standard option, which manufacturers may choose in lieu of complying with the cap
standards. This CCh-equivalent standard option allows manufacturers to include CH4 and N2O,
on a CO2-equivalent basis, in their CO2 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 (which are adjusted to account for their higher global warming potential than CCh), for
all their vehicles. Three manufacturers chose to use this approach in the 2013 model year:
Nissan, Mazda, and Subaru.
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
36 "EPA Decision Document: Mercedes-Benz Off-cycle Credits forMYs 2012-2016," U.S. EPA-420-R-14-025,
Office of Transportation and Air Quality, September 2014. See http://www.epa. gov/otaq/regs/ld-
hwy/greenhouse/documents/420rl4025.pdf.
34
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aspect of this approach is that manufacturers that use it must calculate a deficit (in Megagrams)
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 3-16. 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 2009-2012 or generated in 2013.
Table 3-16. Reported CH4 and N2O Deficits by Manufacturer and Fleet, 2013 Model Year (Mg)
Manufacturer
BMW
Fiat Chrysler
Ford
GM
Volkswagen
Fleet Total
Car
CH4
(5,058)
(12,412)
(27,545)
(57,902)
(102,917)
N2O
(9,795)
(150,195)
(159,990)
Truck
CH4
(1,287)
(190)
(49,342)
(89,000)
(434)
(140,253)
N2O
(5,115)
(252,940)
(10,889)
(268,944)
Total
(6,402)
(5,248)
(324,489)
(116,545)
(219,420)
(672,104)
Grams/Mile
Equivalent of
Total
0.1
0.0
0.6
0.2
1.8
0.2
Tables 3-17 and 3-18 show the gram/mile equivalent CH4 and N2O deficits, respectively, for the
2012 and 2013 model years. As in all of the tables in this document, the final Fleet Total row
indicates the impact across the entire fleet, including manufacturers and vehicles that did not
participate in the alternative CFU and/or N2O standards.
Table 3-17. CH4 Deficits (g/mi)
Manufacturer
BMW
Fiat Chrysler
Ford
GM
Volkswagen
Fleet Total
2012 Model Year
Cars
0.0
0.1
0.1
0.1
0.6
0.1
Trucks
0.3
0.1
0.2
0.4
0.1
0.1
All
0.1
0.1
0.1
0.2
0.5
0.1
2013 Model Year
Cars
0.0
0.0
0.1
0.1
0.5
0.1
Trucks
0.1
0.0
0.2
0.4
0.0
0.1
All
0.0
0.0
0.1
0.2
0.5
0.1
35
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Table 3-18. N2O Deficits (g/mi)
Manufacturer
BMW
Fiat Chrysler
Ford
Volkswagen
Fleet Total
2012 Model Year
Cars Trucks All
0.0 1.1 0.3
0.0 0.0 0.0
0.0 0.9 0.4
1.4 1.2 1.4
0.1 0.2 0.1
2013 Model Year
Cars Trucks All
0.0 0.2 0.1
0.0 0.0 0.0
0.0 0.9 0.5
1.4 0.7 1.3
0.1 0.2 0.1
G. 2013 Model Year Compliance Values
As described at the outset of this section, there are a number of "building blocks" that are
assembled to describe a manufacturer's performance in a given model year. These elements
cumulatively make up a manufacturer's "compliance value," i.e., the performance value specific
to a given model year and fleet that is compared to an emissions standard (or target) to determine
whether a fleet generates a net credit or deficit balance in that model year. Table 3-19
summarizes all of these building blocks (described in previous sections) for the 2013 model year
fleet for each manufacturer. The values in Table 3-19 are calculated for each manufacturer's
combined car and truck fleet by weighting car and truck values according to the relative
production volumes and VMT of cars and trucks.37 The final row shows values for the total 2013
fleet. Note that the compliance value for each manufacturer can be derived from the values in the
table by applying the credits and deficits to the 2-cycle tailpipe value.38 For example,
Volkswagen's 2-cycle tailpipe emissions of 279 grams/mile is reduced by applying FFV and A/C
credits totaling 15 grams/mile and then increased by 2 grams/mile as a result of their use of N2O
and CH4 alternative standards, yielding a final compliance value of 266 grams/mile (any
apparent mathematical differences are the result of rounding). Tables 3-20 and 3-21 show the
same information for car and truck fleets, respectively.39 The resulting compliance values can
then be compared to the target values for each fleet to determine whether a manufacturer
generates credits or deficits in the 2013 model year.
37 The compliance and target values do not represent official regulatory values. Regulatory target values are
determined separately for car and truck fleets. The compliance value is not a regulatory value, but rather is a
calculated value based on each manufacturers' unique car and truck sales weighting for a given model year, and is
shown as a way of portraying the cumulative impact of a manufacturer's tailpipe performance and any optional
credits used by a manufacturer.
38 This is true for all except manufacturers using the Temporary Lead-time Allowance Alternative Standards. The
TLAAS credit shown is an accurate representation of the "benefit" received from using less stringent standards, but
because it is not an actual credit but rather an adjustment to the standard, it is not deducted from the 2-cycle tailpipe
value like other credits.
39 Versions of Tables 3-19, 3-20, and 3-21 for the 2012 model year are shown in Appendix C.
36
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Table 3-19. 2013 Compliance Values - Combined Passenger Car & Light Truck Fleet
(g/mi)
Manufacturer
Aston Martin
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Lotus
Mazda
McLaren
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla40
Toyota
Volkswagen
Volvo
Fleet Total
2-Cycle
Tailpipe
444
292
0
0
475
344
321
325
257
241
398
254
334
251
374
321
258
266
336
264
273
0
278
279
318
294
FFV
0
0
0
0
0
17
15
15
0
0
0
0
0
0
0
12
0
3
0
0
0
0
4
8
0
8
Credits
TLAAS
64
0
0
0
66
0
0
0
0
0
47
0
62
0
66
9
0
0
73
0
0
0
0
0
0
1
(g/mi)
A/C
9
9
0
0
10
10
8
9
4
5
8
5
0
0
0
10
0
4
0
0
0
6
7
7
10
7
Off-
Cycle
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
CH4&
N2O
Deficit
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
Compliance
Value
435
283
0
0
465
316
299
301
254
236
390
248
334
251
374
299
258
260
336
264
273
-6
268
266
307
279
This table was updated on March 31, 2015 to correct errors limited to 2-cycle tailpipe CC>2 values for
manufacturers using the Temporary Lead-time Allowance Alternative Standards (see Section 3.B).
40 Tesla manufactures only electric vehicles. As explained in section 3.C. 1, a temporary incentive for electric
vehicles allows electric vehicle tailpipe emissions to be set equal to zero grams/mile, as shown in this table. An
artifact of this is that Tesla's compliance value is represented by a negative number after applying air conditioning
credits.
37
-------
Table 3-20. 2013 Compliance Values - Passenger Car Fleet (g/mi)
Manufacturer
Aston Martin
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Lotus
Mazda
McLaren
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla41
Toyota
Volkswagen
Volvo
Fleet Total
2-Cycle
Tailpipe
444
271
0
0
475
289
256
273
228
238
342
252
334
232
374
296
254
232
309
254
266
0
224
111
292
251
FFV
0
0
0
0
0
12
9
10
0
0
0
0
0
0
0
12
0
0
0
0
0
0
0
7
0
4
Credits
TLAAS
64
0
0
0
66
0
0
0
0
0
41
0
62
0
66
0
0
0
63
0
0
0
0
0
0
0
(g/mi)
A/C
9
8
0
0
10
10
7
9
3
5
5
5
0
0
0
9
0
4
0
0
0
6
7
6
10
7
Off-
Cycle
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
CH4&
N2O
Deficit
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
Compliance
Value
435
263
0
0
465
268
240
254
225
233
337
247
334
232
374
275
254
228
309
254
266
-6
217
260
282
241
This table was updated on March 31, 2015 to correct errors limited to 2-cycle tailpipe CC>2 values for
manufacturers using the Temporary Lead-time Allowance Alternative Standards (see Section 3.B).
41 Tesla manufactures only electric vehicles. As explained in section 3.C. 1, a temporary incentive for electric
vehicles allows electric vehicle tailpipe emissions to be set equal to zero grams/mile, as shown in this table. An
artifact of this is that Tesla's compliance value is represented by a negative number after applying air conditioning
credits.
38
-------
Table 3-21. 2013 Compliance Values - Light Truck Fleet (g/mi)
Manufacturer
BMW
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mazda
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Toyota
Volkswagen
Volvo
Fleet Total
2-Cycle
Tailpipe
346
380
375
395
312
317
414
301
296
371
267
340
363
270
330
347
327
348
360
FFV
0
21
20
22
0
0
0
0
0
12
0
8
0
0
0
8
15
0
14
Credits
TLAAS
0
0
0
0
0
0
49
0
0
27
0
0
82
0
0
0
0
0
1
(g/mi)
A/C
11
11
8
9
5
7
9
9
0
12
0
4
0
0
0
7
10
11
8
Off-
Cycle
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
CH4&
N2O
Deficit
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Compliance
Value
335
348
348
364
307
310
405
292
296
347
267
328
363
270
330
332
302
337
339
This table was updated on March 31, 2015 to correct errors limited to 2-cycle tailpipe CC>2 values for
manufacturers using the Temporary Lead-time Allowance Alternative Standards (see Section 3.B).
Table 3-22 shows the calculated compliance values for each manufacturer's car and truck fleet
for the 2012 and 2013 model years. As can be seen in the table, there were widespread decreases
in compliance values from 2012 to 2013, resulting in a net decrease of 8 grams/mile (about three
percent) across the fleet of combined cars and trucks.
39
-------
Table 3-22. 2012-2013 Model Year Compliance Values by Manufacturer and Fleet
(g/mi)
Manufacturer
Aston Martin
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Fisker
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Lotus
Mazda
McLaren
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla42
Toyota
Volkswagen
Volvo
Fleet Total
2012
Cars
270
0
0
484
278
146
248
264
234
239
371
253
241
295
262
256
325
257
267
-6
214
269
287
249
Model
Trucks
353
353
357
366
316
305
431
320
324
367
283
363
362
296
361
339
322
331
348
Year
All
294
0
0
484
329
146
295
307
263
244
419
261
263
320
267
288
342
282
287
-6
263
276
300
288
2013 Model
Cars
435
263
0
0
465
268
240
254
225
233
337
247
334
232
374
275
254
228
309
254
266
-6
217
260
282
241
Trucks
335
348
348
364
307
310
405
292
296
347
267
328
363
270
330
332
303
337
339
Year
All
435
283
0
0
465
316
299
301
254
236
390
248
334
251
374
299
258
260
336
264
273
-6
268
266
308
279
Change
Cars
-7
0
0
-19
-10
-8
-10
-9
-6
-34
-6
-9
-21
-8
-28
-16
-3
-1
0
3
-9
-5
-9
: 2012 to
Trucks
-18
-5
-10
-2
-9
5
-26
-28
-28
-19
-16
-36
1
-26
-31
-7
-19
6
-10
2013
All
-11
0
0
-19
-13
4
-7
-9
-8
-29
-12
-12
-22
-8
-28
-6
-18
-14
0
5
-10
8
-9
H. 2013 Model Year Footprint-Based COz Standards
The final values needed to determine the relative performance for a manufacturer in a model year
are the emissions standards that apply to each manufacturer's fleets in that model year. At the
end of each model year, manufacturers calculate unique CO2 standards for each fleet (cars and
42 Tesla manufactures only electric vehicles. As explained in section 3.C.I, a temporary incentive for electric
vehicles allows electric vehicle tailpipe emissions to be set equal to zero grams/mile, as shown in this table. An
artifact of this is that Tesla's compliance value is represented by a negative number after applying air conditioning
credits.
40
-------
trucks) using equations specified in the regulations based on the footprint of their vehicles.43 The
footprint "curves" for the 2012 and 2013 model years are shown in Figure 3-1. The unique CO2
standard for each manufacturer's fleet is a production-weighted average of the CO2 target values
determined from the curves based on all of the unique footprint values for the vehicles in a
manufacture's fleet.
Figure 3-1. 2012-2013 Model Year CO2 Footprint Target Curves
400
380
2012 Trucks
2013 Trucks
2012 Cars
2013 Cars
200
45 50
Footprint (square feet)
The calculated CO2 standards for the 2012 and 2013 model years are shown in Table 3-23.
Manufacturers use these unique footprint-based car and truck standards - which are required by
regulation - to determine their compliance status. A third value for each manufacturer - a sales-
and VMT-weighted standard for the combined car and truck fleet - is provided for convenience
and comparative purposes, but it is not a compliance value required by the regulations. Similar
to the compliance values described in the previous section, there were widespread decreases in
the CO2 standards from 2012 to 2013, representing an increase in the overall stringency of the
program.
43 A vehicle's footprint is defined specifically in regulations as the product of vehicle track width and wheelbase, but
it can be simply viewed as the area of the rectangle enclosed by the four points where the tires touch the ground.
41
-------
Table 3-23. 2012-2013 Model Year CO2 Standards by Manufacturer and Fleet (g/mi)
Manufacturer
Aston Martin
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Fisker
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Lotus
Mazda
McLaren
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
2012
Cars
269
111
246
345
111
315
265
111
263
269
364
266
259
111
261
263
332
260
251
304
264
263
111
267
Model
Trucks
336
345
364
369
333
316
388
338
323
360
307
337
422
309
325
342
327
325
348
Year
All
288
111
246
345
323
315
308
313
288
273
383
274
276
306
271
285
374
291
267
304
295
271
288
299
2013 Model
Cars
321
263
269
239
331
270
265
263
256
261
324
258
311
250
329
262
249
259
314
251
243
296
257
257
264
261
Trucks
324
338
355
360
318
309
362
303
311
354
296
324
410
299
296
329
317
316
339
Year
All
321
280
269
239
331
311
315
304
278
263
353
259
311
268
329
292
264
280
363
281
249
296
289
264
288
292
Change
Cars
-6
-8
-7
-14
-7
0
-9
-7
-8
-40
-8
-9
-15
-12
-4
-18
-9
-8
-8
-7
-6
-8
-6
: 2012 to
Trucks
-12
-7
-9
-9
-15
-7
-26
-35
-12
-6
-11
-13
-12
-10
-29
-13
-10
-9
-9
2013
All
-8
-8
-7
-14
-12
6
-9
-10
-10
-30
-15
-8
-14
-7
-5
-12
-10
-18
-8
-6
-7
0
-7
Overall, the standards decreased by 7 grams/mile from 2012 to 2013, an increase in stringency
driven by the more stringent target curves for the 2013 model year. However, the target curves
represent only one of several key factors that influence the standards. While increased stringency
overall from one year to the next is expected because of the structure of the target curves, there
are other contributing factors that can result in - and explain - occasional exceptions that may
occur. For example, Table 3-23 shows that the standard for Ford cars remained steady from 2012
to 2013, a phenomenon that is based on an increase in the average footprint of Ford cars in the
2013 model year, as seen in Table 3-24.
Of the 22 manufacturers in the program in 2012 and 2013, fleet average footprint increased for
seven, decreased for 12, and was unchanged for three. Increases in footprint ranged from 0.1
square feet for several manufacturers to 2.5 square feet for Ford (driven in part by Ford's
42
-------
increase in truck share in 2013). The average footprint for the overall fleet increased by 0.3
square feet from 2012 to 2013. Note that an increase in footprint does not necessarily indicate
that manufacturers built larger vehicles in 2013; because the footprint is weighted by production
volume, an increase could also occur with no change to the fleet but as a result of increased
consumer demand for larger vehicles. Thus an increase in footprint could be a result of either of
these factors independently, or a mix of both factors.
Table 3-24. Average Footprint by Manufacturer and Fleet (square feet)
Manufacturer
Aston Martin
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Fisker
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Lotus
Mazda
McLaren
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
2012
Cars
45.9
47.9
41.5
47.8
47.2
58.1
45.3
46.9
45.0
46.4
51.0
45.6
43.9
46.5
44.5
45.0
44.7
44.3
42.1
53.6
45.0
45.0
46.8
45.7
Model
Trucks
51.4
53.6
59.4
60.1
50.5
46.4
48.4
51.9
48.1
51.9
44.0
51.6
51.8
44.7
48.7
53.4
49.0
48.6
54.5
Year
All
47.3
47.9
41.5
47.8
51.4
58.1
50.9
52.0
46.8
46.4
49.0
46.2
44.9
48.2
44.4
46.8
47.7
44.5
43.4
53.6
48.0
45.5
47.3
48.8
2013 Model
Cars
45.2
46.2
47.9
41.5
47.1
47.6
47.0
46.5
44.9
46.1
50.8
45.4
47.1
43.6
46.6
45.4
43.6
45.8
43.7
44.0
41.8
53.6
45.1
45.2
46.8
45.9
Trucks
50.8
54.5
59.5
60.4
49.3
47.0
48.2
45.6
47.0
51.5
43.9
50.8
51.9
44.6
44.0
52.5
49.0
49.0
54.8
Year
All
45.2
47.4
47.9
41.5
47.1
51.5
53.4
51.9
46.3
46.2
48.8
45.4
47.1
44.4
46.6
47.3
43.7
47.2
47.6
44.4
42.0
53.6
48.1
45.6
47.7
49.1
Change
Cars
0.3
0.0
(0.7)
0.4
1.7
(0.4)
(o.i)
(0.3)
(0.2)
(0.2)
(0.3)
(1.1)
(0.9)
0.8
(1.0)
(0.3)
(0.3)
0.0
0.1
0.2
0.0
0.2
: 2012 to
Trucks
(0.6)
0.9
0.1
0.3
(1.2)
0.6
(0.2)
(6.3)
(1.1)
(0.4)
(o.i)
(0.8)
0.1
(o.i)
(4.7)
(0.9)
0.0
0.4
0.3
2013
All
0.1
0.0
(0.7)
0.1
2.5
(o.i)
(0.5)
(0.2)
(0.2)
(0.8)
(0.5)
(0.9)
(0.7)
0.4
(o.i)
(o.i)
(1.4)
0.0
0.1
0.1
0.4
0.3
43
-------
I. Overall Compliance Summary
Final compliance for the 2012 and 2013 model years is summarized in Table 3-25 for the overall
model year fleet, and separately for cars and trucks in Tables 3-26 and 3-27, respectively. As in
the tables in Section 3.G, these show how the 2-cycle tailpipe values and the credit are used to
"build" the overall compliance value, which is then compared to the model year standards
described in Section 3.H. Overall, manufacturers outperformed the 2013 standard by 12
grams/mile, slightly better but comparable to their compliance margin in 2012 of 11
grams/mile.44 In both the 2012 and 2013 model years, however, the industry's over-compliance
was entirely driven by the 18-20 grams/mile compliance margin seen in the car fleet, since the
truck compliance values essentially equaled the overall fleet standards.
Table 3-25. Compliance & Credit Summary, 2012-2013 Model Years - Combined Cars and
Trucks (g/mi)*
Model
Year
2012
2013
2-Cycle
Tailpipe
302
294
Credits
FFV
8
8
TLAAS
1
1
A/C
6
7
Off-Cycle
0
0
CH4 & N2O
Deficit
0
0
Compliance
Value
288
279
Standard
299
292
*Values stated in this table and in the text are correct, although rounding of values may result in some
apparent differences.
Table 3-26. Compliance & Credit Summary, 2012-2013 Model Years - Passenger Cars
(g/mi)*
Model
Year
2012
2013
2-Cyde
Tailpipe
259
251
Credits
FFV
4
4
TLAAS
0
0
A/C
6
7
Off-Cycle
0
0
CH4 & N2O
Deficit
0
0
Compliance
Value
249
241
Standard
267
261
*Values stated in this table and in the text are correct, although rounding of values may result in some
apparent differences.
44 Note that the rounded values in the tables may produce values that differ from those in the text as a result of
rounding. For example, the correct difference between the 2013 standard and compliance value is 12 grams/mile,
although the rounded values in the table would produce a difference of 13 grams/mile.
44
-------
Table 3-27. Compliance & Credit Summary, 2012-2013 Model Years - Light Trucks (g/mi)*
Model
Year
2012
2013
2-Cycle
Tailpipe
369
360
Credits
FFV
14
14
TLAAS
1
1
A/C
8
8
Off-Cycle
0
0
CH4 & N2O
Deficit
0
0
Compliance
Value
348
339
Standard
348
339
*Values stated in this table and in the text are correct, although rounding of values may result in some
apparent differences.
This table was updated on March 31, 2015 to correct errors limited to 2-cycle tailpipe CC>2 values for
manufacturers using the Temporary Lead-time Allowance Alternative Standards (see Section 3.B).
A comparison between compliance values and target values for each manufacturer and fleet is
shown in Table 3-28. The final row shows values for the total 2013 fleet. The comparison of the
compliance and target values in Table 3-28, shown in the "Net Compliance" columns, indicates
whether a manufacturer generated net credits or deficits in the 2013 model year. Negative values
indicate over-compliance with the standards, or compliance values that are lower than the targets
by the stated value. Positive values are thus an indication of compliance values that exceed (i.e.,
do not comply with) the applicable standards. Fiat Chrysler, for example, generated a 2013
model year deficit because their overall compliance value of 316 grams/mile is above their fleet-
wide target of 311 grams/mile. Ford, on the other hand, reported net credits based on a
compliance value of 299 grams/mile, 16 grams/mile lower than the fleet-wide target. Note,
however, that the generation of a net deficit in the 2013 model by any manufacturer does not
necessarily indicate that the manufacturer has failed to comply with the 2013 model year
standards. Fiat Chrysler, for example, will be able to offset their 2013 deficit by using credits
generated in previous model years, thereby complying with the 2013 standards.45 The final row
of Table 3-28 shows the conclusion that manufacturers over-complied with the 2013 model year
standards by 12 grams/mile. The table also shows that the vast majority of this over-compliance
came from passenger cars, with light trucks overall beating the standard by one gram/mile. A
comparison of the values in the three previous tables to EPA projections for these values is in
Appendix A.
45 This section deals only with manufacturer performance within a model year, and does not consider the
implications on compliance of the use of credits or deficits from previous model years or of sold and purchased
credits. See Section 5 for a discussion of the current compliance status of each manufacturer that considers all of
these factors.
45
-------
Table 3-28. 2013 Model Year Compliance Summary by Manufacturer and Fleet (g/mi)
Manufacturer
Aston Martin
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Lotus
Mazda
McLaren
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
Compliance Value
Cars
435
263
0
0
465
268
240
254
225
233
337
247
334
232
374
275
254
228
309
254
266
-6
217
260
282
241
Trucks
335
348
348
364
307
310
405
292
296
347
267
328
363
270
330
332
303
337
339
All
435
283
0
0
465
316
299
301
254
236
390
248
334
251
374
299
258
260
336
264
273
-6
268
266
308
279
Target Value
Cars
321
263
269
239
331
270
265
263
256
261
324
258
311
250
329
262
249
259
314
251
243
296
257
257
264
261
Trucks
324
338
355
360
318
309
362
303
311
354
296
324
410
299
296
329
317
316
339
All
321
280
269
239
331
311
315
304
278
263
353
259
311
268
329
292
264
280
363
281
249
296
289
264
288
292
Net
Cars
114
0
-269
-239
134
-3
-25
-9
-31
-28
13
-11
23
-18
45
13
5
-31
-5
3
23
-302
-40
3
18
-20
Compliance
Trucks
11
10
-7
4
-11
1
43
-11
-15
-7
-29
4
-47
-29
34
3
-15
21
-1
All
114
3
-269
-239
134
5
-15
-4
-24
-27
36
-11
23
-17
45
6
-6
-20
-26
-17
24
-302
-21
1
20
-12
46
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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 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 an 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 through the 2013 model year are shown in
Table 4-1.46 As of the close of the 2013 model year, just over 2.5 million Megagrams of CO2
credits had changed hands. Credit distributions are shown as negative values, in that a
disbursement represents a deduction of credits of the specified model year for the selling
manufacturer. Credit acquisitions are indicated as positive values because acquiring 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. The
vintage always travels with the credits, regardless of when a transaction takes place and in what
model year the credits are ultimately used. A manufacturer with 2010 model year credits can
hold them until 2021, meaning, for example, that a sale of 2010 credits could potentially be
reported to EPA as late as the reporting deadline for the 2021 model year, and those 2010 credits
could be used by the buyer to offset deficits from the 2018-2021 model years. The overall impact
of these credit transactions on the compliance position of each manufacturer is discussed in
46 There may be 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 2013 model year data) those transactions will
be reported in the 2014 model year reports of the manufacturers involved, and thus will be included in EPA's
performance report regarding the 2014 model year.
47
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Section 5, which pulls together all the credits and deficits, including early credits, discussed in
the preceding sections. Note that each value in the table is simply an indication of the quantity of
credits from a given model year that has been acquired or disbursed by a manufacturer, and thus
may represent multiple transactions with multiple buyers or sellers.
Table 4-1. Reported Credit Sales and Purchases as of the 2013 Model Year (Mg)
Credits
Disbursed
Credits
Acquired
Manufacturer
Honda
Nissan
Tesla
Fiat Chrysler
Ferrari
Mercedes
2010
(434,383)
(200,000)
(35,580)
144,383
90,000
435,580
Model Year
2011
(500,000)
(14,192)
500,000
14,192
"Vintage"
2012 2013
(250,000)
(177,941) (1,048,689)
1,048,689
427,941
Total
(434,383)
(950,000)
(1,276,402)
1,693,072
90,000
877,713
48
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5. COMPLIANCE STATUS AFTER THE 2013 MODEL
YEAR
The vast majority of manufacturers have successfully demonstrated compliance with the 2012
and 2013 model year standards and are carrying a positive credit balance into the 2014 model
year. The manufacturers that are in compliance with both model years represent more than 99
percent of total U.S. car and light truck sales in these first two model years of EPA's GHG
standards. Table 5-1 shows one view of the accumulated credits for each manufacturer. Each
manufacturer with a positive balance in the final column is, by definition, in compliance with the
2012 and 2013 model years (because all deficits must be offset before carrying credits forward).
Table 5-1 shows the total credits (or deficits) for each manufacturer in the last column. Table 5-1
also shows the credits (or deficits) generated by each manufacturer in the 2009-2013 model
years, as well as the net impact of credit transactions on each manufacturer's credit balance.
However, to fully understand the current compliance position of each manufacturer, we also
need to know the makeup of the credit balance in terms of the origin, or vintage, of the credits.
Knowing the vintage is important both for credits and deficits, because we need to know when
credits expire and must be forfeited, and we need to know when a manufacturer is in violation of
the regulations as a result of failing to offset a deficit within the required time frame.
Ferrari, as shown in Table 5-1, is a relatively simple example. They purchased 90,000 Mg of
2010 credits (we know the vintage from Section 4). These credits were more than sufficient to
offset their 2012 deficit of 40,983 Mg. Because Ferrari generated a deficit in 2012 that they
subsequently erased with purchased credits, Ferrari has complied with the 2012 standards.
Ferrari then was able to carry 49,017 Mg of credits remaining from their purchase of 90,000 into
the 2013 model year. Those credits were subsequently applied to their 2013 deficit, but were not
sufficient to wholly offset the 2013 deficit, leaving Ferrari with an unresolved 2013 deficit of
653 Mg. Table 5-1 does not show the movement of credits between fleets and model years, thus
Ferrari is shown with a 2012 deficit, and there is no indication of the vintage of the small deficit
that they are carrying into the 2014 model year.
49
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Table 5-1. Cumulative Credit Status After The 2013 Model Year (Mg)
Manufacturer
Toyota
Honda
GM
Ford
Hyundai
Nissan
Kia
Subaru
Fiat Chrysler
Mazda
Volkswagen
Mitsubishi
Suzuki
BMW
Porsche
Volvo
Mercedes
Fisker
Coda
BYD Motors
Tesla
Ferrari
Lotus
McLaren
Aston Martin
Jaguar Land
Rover
Fleet Total
Early Credits (2009-2011)
Bought or
Earned Sold
80,435,498
35,515,108 (434,383)
24,564,829
16,075,888
14,007,495
18,131,200 (700,000)
10,444,192
5,755,171
9,110,207 644,383
5,482,642
6,441,405
1,449,336
876,650
1,004,292
-
740,358
378,272 449,772
-
-
-
49,772 (49,772)
90,000
-
-
3,332
-
230,465,647
2012
Bought or
Earned Sold
13,163,009
7,851,251
2,872,354
4,641,001
3,566,721
(729,937) (250,000)
1,343,373
543,316
(1,892,184)
734,887
(502,495)
57,837
(127,699)
(287,861)
198,348
(175,195)
(748,793) 427,941
46,694
5,524
595
178,517 (177,941)
(40,983)
-
-
-
(424,032)
30,274,248
2013
Bought, Sold,
Earned or Forfeited
9,885,788
7,302,584
1,748,357
7,829,549
5,782,163 (169,775)*
5,190,521
1,352,888 (123,956)*
1,298,850
(1,631,285) 1,048,689
786,431
(148,949)
58,209
(55,398)
(259,619)
228,091
(297,006)
(377,880)
-
1,727
1,681
1,049,384 (1,048,689)
(49,670)
(763)
(3,620)
(8,115)
(503,111)
39,180,807 (293,731)
Total Carried
Forward to 2014
103,484,295
50,234,560
29,185,540
28,546,438
23,186,604
21,641,784
13,016,497
7,597,337
7,279,810
7,003,960
5,789,961
1,565,382
693,553
456,812
426,439
268,157
129,312
46,694
7,251
2,276
1,271
(653)
(763)
(3,620)
(4,783)
(927,143)
299,626,971
* Forfeited per the requirements of a federal Consent Decree. See Section I.D.4.
50
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Because manufacturers accumulate car and truck credits separately, and because they are
allowed to move credits around between cars and trucks, the situation can get far more complex
than seen in the Ferrari example.47 Consider this example, where a manufacturer generates 1500
Mg of car credits and a -500 Mg deficit in trucks in 2012, and where credits all have a 5-year
lifespan:
2012 Credits
Fleet (Mg)
Cars 1500
Trucks -500
Total 1000
The manufacturer must use the car credits to offset the truck deficit in this case, because there are
no credits available from prior model years to use, and credits cannot be carried forward until
deficits are addressed. Thus the manufacturer carries a balance of 1000 Mg of credits from 2012
into 2013. Then in this example let's assume that in 2013 they generate 1000 Mg of credits in the
car fleet and a deficit of -1000 Mg in the truck fleet, as shown below:
2012 Credits 2013 Credits
Fleet (Mg) (Mg)
Cars 1500 1000
Trucks -500 -1000
Total /T000"\0
Here, the manufacturer
Id have 1000 Mg of
There are multiple choices for a manufacturer faced with such a situation. As shown above, all
deficits are adequately addressed within each model year, and a manufacturer could leave it at
that. Doing so would mean carrying forward the 1000 Mg of credits remaining from 2012 into
2014. There is, however, a smarter - but not mandatory - option. Because the regulations allow
car and truck credits and deficits to be managed as separate "bins," and because newer credits are
generally more valuable than older credits (because they last longer) it would be smarter for this
manufacturer to use the 1000 Mg of credits from 2012 to offset the deficit of -1000 Mg in the
2013 truck fleet, as shown below:
2012 Credits 2013 Credits
Fleet (Mg)
Here, the manufacturer
would have 1000 Mg of
2013 credits
Total teett
The bottom line remains the same (1000 Mg of credits are carried into 2014), except that in this
case the credits carried forward have a vintage from the newer 2013 model year. Theoretically, a
manufacturer could use any mix of 2012 and 2013 credits to offset the 2013 truck deficit, in
which case the credits remaining to carry forward would be a mix of 2012 and 2013 credits. The
value of a given vintage is based on its expiration date, and the expiration date of 2010-2016
model year credits in EPA's GHG program is fixed at the 2021 model year, meaning that for the
47 Note that the regulations require that all credits and deficits within a vehicle class (passenger cars or light trucks)
are aggregated before transfers between vehicle classes occur. See 40 CFR 86.1865-12(k)(5).
51
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2010-2016 model years it is less important to treat credits in this way. Nevertheless, this "first in,
first out" accounting method is being used to determine the makeup of credit balances held by
manufacturers (unless a manufacturer expresses a preference for an alternative accounting). It is
challenging to display all the credit transfers, transactions, and vintages in a single data table in
an easily understandable manner. However, we can display the current state of each
manufacturer and the vintage of all the credits currently held by each manufacturer.
Table 5-2 reveals the credit balances for each manufacturer, after adjusting for credit transactions
and transfers, by the vintage of the credits held by the manufacturer. The model year column
headings represent the vintages that make up the total credits (or deficit) being carried forward
into the 2014 model year. This table shows, for example, the extent to which some manufacturers
have used credits from prior model years. BMW, for example, generated almost 6 million Mg of
early credits in the 2009 model year, and Table 5-2 makes it clear that all of those, and about half
of their 2010 credits, have been used to offset deficits in the 2012 and 2013 model years. It also
shows that there is only one manufacturer (Jaguar Land Rover) that has not yet complied with
the 2012 standards and is thus carrying forward a deficit from 2012. All other manufacturers
have a balance of zero or greater in 2012, thus all others have demonstrated compliance with the
2012 model year standards. In addition to Jaguar Land Rover, four other small manufacturers are
carrying forward a deficit from the 2013 model year, and have thus not yet demonstrated
compliance with the 2013 model year standards. None of the five manufacturers with deficits
going into the 2014 model year are out of compliance with the program. A deficit from the 2012
model year can be carried forward for three years after the year in which it is generated, meaning
that Jaguar Land Rover must reconcile their deficit by the time they report their 2015 model year
results to EPA. Similarly, deficits from the 2013 model year do not have be offset until the end
of the 2016 model year.
Note that Tables 5-1 and 5-2 over-simplify the data with respect to the manufacturers using the
TLAAS program in order to present the data concisely. Jaguar Land Rover and Mercedes have
vehicles subject to the primary standards and subject to the less stringent TLAAS standards, yet
for the purpose of these tables we have aggregated the credits accumulated in both the primary
and TLAAS fleets into a single row in the table. Although they are not separated for the purposes
of these tables, 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. The data we are making available online and in this report will identify
the source of each credit (e.g., whether from the Primary or TLAAS fleets).
52
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Table 5-2. Credits Available After the 2013 Model Year, Reflecting Trades & Transfers (Mg)
Manufacturer
Toyota
Honda
GM
Ford
Hyundai
Nissan
Kia
Subaru
Fiat Chrysler
Mazda
Volkswagen
Mitsubishi
Suzuki
BMW
Porsche
Volvo
Mercedes
Fisker
Coda
BYD Motors
Tesla
Ferrari
Lotus
McLaren
Aston Martin
Jaguar Land
Rover
Fleet Total
2009*
30,658,662
14,073,890
6,473,623
5,882,011
4,601,633
8,207,077
3,134,775
568,109
-
1,340,917
1,150,976
583,146
265,311
-
-
-
76,940,130
2010
34,457,797
13,635,907
11,073,134
7,416,966
5,388,593
5,581,739
2,651,872
2,225,296
3,308,200
3,201,708
2,811,663
521,776
329,382
141,255
-
-
92,745,288
2011
14,651,963
7,370,928
6,184,049
2,776,911
4,012,969
1,352,749
4,657,545
2,876,413
2,605,453
925,179
1,528,432
302,394
98,860
315,557
268,157
-
49,927,559
2012
13,163,009
7,851,251
2,872,354
4,641,001
3,566,721
989,226
1,343,373
543,316
-
749,725
74,076
67,976
-
-
198,348
-
103,557
46,694
5,524
595
576
(424,032)
35,793,290
2013
10,552,864
7,302,584
2,582,380
7,829,549
5,616,688
5,510,993
1,228,932
1,384,203
1,366,157
786,431
224,814
90,090
-
-
228,091
-
25,755
1,727
1,681
695
(653)
(763)
(3,620)
(4,783)
(503,111)
44,220,704
Total Carried
Forward to 2014
103,484,295
50,234,560
29,185,540
28,546,438
23,186,604
21,641,784
13,016,497
7,597,337
7,279,810
7,003,960
5,789,961
1,565,382
693,553
456,812
426,439
268,157
129,312
46,694
7,251
2,276
1,271
(653)
(763)
(3,620)
(4,783)
(927,143)
299,626,971
*2009 model year credits may not be traded to another manufacturer. They are also unavailable for use
after the 2014 model year.
53
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APPENDIX A: COMPARING ACTUAL PERFORMANCE TO RULEMAKING
PROJECTIONS
As described in Section 1, EPA's GHG program was promulgated in two regulatory actions
conducted jointly with NHTSA. The first rulemaking established standards for the 2012-2016
model years, and the second rulemaking set standards for the 2017 and later model years. 48 49 In
each of these rulemakings we included tables summarizing our projections of what the fleet-wide
standards would be and how we expected manufacturers would comply with the standards. When
evaluating these projections and how they compare to the actual performance as described in this
report, consider that the projections for the 2012-2016 model years were finalized in early 2010,
and the 2017 and later projections were determined in the middle of 2012. The projections were
made with the best available information at the time, but it should not be surprising that actual
performance differs from the rulemaking projections. Factors such as consumer preferences,
technology innovation, fuel prices, and manufacturer behavior can change in unanticipated ways,
leading current, actual performance to diverge from projections made in the past. While a
comparison of actual performance to projections is interesting, and helps illuminate whether or
not the program is achieving its expected benefits, this is secondary in the context of this report,
which is focused on actual compliance. Compliance of manufacturers with EPA's standards is
not determined by comparing current model year results to past projections, but is instead
determined by comparing achieved compliance values to the regulatory footprint-based standards
covered in Sections 1-5 of this report.
Table A-l shows key projected values for the combined car and truck fleet for the 2012-2025
model years. All of the values in this table (and Tables A-2 and A-3) come directly from the
regulatory actions noted above. Note that we projected that the industry, on average, would
comply exactly with the target, i.e., the compliance value equals the target value in each model
year. This table illustrates a fundamental principle: EPA projections from the rulemaking
analysis assumed manufacturers would achieve significant GHG emission reductions (and hence
compliance) through a variety of technologies. In the early years, until the incentive is phased
out in the 2016 model year, we projected significant production of flexible fuel vehicles (FFV).
We also projected relatively high production of reduced GHG air conditioning systems across
the fleet, resulting in reductions ranging from 3.5 grams/mile in 2012 and increasing to over 20
grams/mile late in the program. As shown in Table A-l, we projected that manufacturers would
start with a 2-cycle tailpipe value of 298 grams/mile in the 2013 model year, reducing that by
total credits and incentives of about 12 grams/mile, thus yielding a net compliance value of 286
grams/mile. We did not make any estimations of the use of N2O and CH4 alternative standards
for two reasons: (1) the overall impact was expected to be very small, and (2) manufacturers are
required to offset deficits accumulated with CCh-equivalent credits as a result of using this
flexibility, thus there is no net impact on the program.
48 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.
49 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.
54
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Tables A-2 and A-3 show the same projected values as Table A-l, but separately for cars and
trucks, respectively. In the regulatory action establishing the standards we did not publish car-
and truck-specific estimated values for the 2-cycle tailpipe emissions or the use of credits and
incentives in the 2012-2015 model years, thus these values are shown as N/A in these tables.
Table A-l. Projected COz Performance in Rulemaking Analyses for Combined
Passenger Car and Light Truck Fleet (g/mi)
Model
Year
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2-Cycle
Tailpipe
Emissions
307
298
290
111
261
256
249
242
234
222
212
203
194
186
FFV
Credit
6.5
5.8
5.0
3.7
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
A/C
Credit
3.5
5.0
7.5
10.0
10.6
12.5
14.9
17.5
19.2
20.8
20.8
20.8
20.6
20.6
TLAAS
Credit
1.2
0.9
0.6
0.3
0.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Off-
Cycle
Credit
0.0
0.0
0.0
0.0
0.5
0.6
0.8
0.9
1.0
1.1
1.4
1.7
1.9
2.3
N2O&
CH4
Deficit
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Compliance
295
286
276
263
250
243
234
223
214
200
190
181
172
163
Target
295
286
276
263
250
243
234
223
214
200
190
181
172
163
55
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Table A-2. Projected COz Performance in Rulemaking Analyses for Passenger Cars
(g/mi)
Model
Year
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
Table
Model
Year
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2-Cycle
Tailpipe
Emissions
N/A
N/A
N/A
N/A
235
226
218
210
201
193
184
177
170
163
FFV
Credit
N/A
N/A
N/A
N/A
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
A-3. Projected CO2
(g/mi)
2-Cycle
Tailpipe
Emissions
N/A
N/A
N/A
N/A
310
308
304
299
294
276
264
253
242
233
FFV
Credit
N/A
N/A
N/A
N/A
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
A/C
Credit
N/A
N/A
N/A
N/A
10.2
12.8
14.3
15.8
17.3
18.8
18.8
18.8
18.8
18.8
TLAAS
Credit
N/A
N/A
N/A
N/A
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Performance in
A/C
Credit
N/A
N/A
N/A
N/A
11.4
12.0
16.0
20.6
22.5
24.4
24.4
24.4
24.4
24.4
TLAAS
Credit
N/A
N/A
N/A
N/A
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Off-
Cycle
Credit
N/A
N/A
N/A
N/A
0.4
0.5
0.6
0.7
0.8
0.8
0.9
1.0
1.1
1.4
N2O&
CH4
Deficit
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Compliance
263
256
247
236
225
213
203
193
183
173
164
157
150
143
Rulemaking Analyses for Light
Off-
Cycle
Credit
N/A
N/A
N/A
N/A
0.7
0.9
1.0
1.2
1.4
1.5
2.2
2.9
3.6
4.3
N2O&
CH4
Deficit
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Compliance
346
337
326
312
298
295
287
278
270
250
238
226
214
204
Target
263
256
247
236
225
213
203
193
183
173
164
157
150
143
Trucks
Target
346
337
326
312
298
295
287
278
270
250
238
226
214
204
56
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Table A-4 shows a comparison of the projected values (in Tables A-l, A-2, and A-3) with the
actual performance for the 2012 and 2013 model years for the combined car and truck fleet. As is
the case throughout this report, values for the combined fleet of cars and trucks are calculated as
a weighted average of the individual car and truck fleet values. However, the methodology used
for weighting and combining car and truck values in this section differs from the methodology
used elsewhere in this report. As noted in Section 1, the general methodology used in this report
to create a complete fleet value from separate car and truck fleet values incorporates weighting
by the relative lifetime vehicle miles traveled (VMT) of cars and trucks (lifetime VMT values for
cars and trucks are specified in the regulations as 195,264 and 225,865 miles, respectively).
Because credits are calculated based on differing car and truck VMT values, the methodology for
combining car and truck grams/mile values must include weighting by VMT for the result to be
internally and mathematically consistent with the total Megagrams of credits generated by the
fleet. However, past rulemaking projections for the combined car and truck fleet were
determined by weighting car and truck fleet values by their relative production only, ignoring the
impact of VMT. In order to provide an accurate comparison, the actual performance values in
Table A-4 are calculated in the same manner as the projected values: without weighting by
VMT. For this reason the actual values in Table A-4 are not the same as values with the same
labels presented elsewhere in this report. For example, the 2012 model year 2-cycle tailpipe
value in Table A-4 is 299 grams/mile, whereas the same metric is shown as 302 grams/mile in
Table 3-1. Both of these values are correct, as the former is not VMT-weighted and the latter is
VMT-weighted. It is only within this section that a different methodology is used, specifically to
facilitate an apples-to-apples comparison between actual fleet performance and EPA's
projections. Note that values for the car and truck fleets are identical to those shown elsewhere in
the report; only the values for the combined fleet will differ based on the different methods of
calculating combined values from the individual car and truck values.
Table A-4 shows that actual industry-wide compliance targets for the combined car and truck
fleets are slightly higher than EPA's projections for both model year 2012 (by 1 gram/mile) and
model year 2013 (by 3 grams/mile). This is because actual industry-wide footprint values are
slightly higher than projected in the rulemaking analyses (for more information on footprint
trends, see EPA's CO2 and Fuel Economy Trends report at epa.gov/otaq/fetrends.htm).
More important, however, is that despite these slightly higher targets, actual industry-wide 2-
cycle tailpipe emissions and overall compliance values are significantly lower than projected in
the past EPA rulemaking analyses. Actual industry-wide 2-cycle tailpipe emissions performance
was 8-9 grams/mile lower than the projected values in the 2012 and 2013 model years.
Accounting for slightly higher flexible fuel vehicle and air conditioning credits and slightly
lower TLAAS credits than projected, the actual industry-wide compliance values were 11
grams/mile lower in model year 2012 and 10 grams/mile lower in model year 2013, relative to
the rulemaking projections. This means that, other things being equal (such as new vehicle sales
and VMT), the aggregate CO2 emissions reductions from the first two years of the program have
been larger than projected by EPA in the rulemaking analyses. It also reinforces that the industry
had a compliance "cushion" in these two years, and is earning credits that are being banked for
possible future use.
57
-------
Tables A-5 and A-6 provide comparative data separately for cars and trucks for the 2012 and
2013 model years (though projected values for use of credits by vehicle category are not
available until model year 2016). For cars, the directional impacts are similar to those for the
combined car and truck fleet, i.e., the actual targets are higher than projected and the actual
compliance values are much lower (15 grams/mile in 2013). The actual targets are also higher
than the projected targets for the truck fleet, but in this case the actual compliance values are
slightly higher than projected (2 grams/mile in 2013).
58
-------
Table A-4. Actual and Projected COz Values, Cars and Trucks Combined (g/mi)
Model
Year
2012
2013
ACTUAL (COMBINED FLEET NOT VMT-WEIGHTED)
2-Cycle
Tailpipe
298
290
FFV A/C TLAAS
Credit Credit Credit
7.7 6.4 0.6
7.5 7.1 0.6
Off- N2O
Cycle & CH4
Credit Deficit Compliance
0.0 0.2 284
0.0 0.2 276
Target
296
289
PROJECTED
2-Cycle
Tailpipe
307
298
FFV
Credit
6.5
5.8
A/C
Credit
3.5
5.0
TLAAS
Credit
1.2
0.9
Off- N2O
Cycle & CH4
Credit Deficit
0.0 N/A
0.0 N/A
Compliance
295
286
Target
295
286
This table was updated on March 31, 2015 to correct errors limited to 2-cycle tailpipe CC>2 values for manufacturers using the Temporary Lead-time
Allowance Alternative Standards (see Section 3.B).
Table A-5. Actual and Projected COz Values, Passenger Cars (g/mi]
Model
Year
2012
2013
ACTUAL
2-Cycle FFV
Tailpipe Credit
259 4.0
251 4.0
A/C TLAAS
Credit Credit
5.7 0.3
6.5 0.2
Off- N2O
Cycle & CH4
Credit Deficit
0.0 0.1
0.0 0.1
Compliance
249
241
Target
267
261
PROJECTED
2-Cycle
Tailpipe
N/A
N/A
FFV A/C
Credit Credit
N/A N/A
N/A N/A
Off-
TLAAS Cycle
Credit Credit
N/A N/A
N/A N/A
N2O
&CH4
Deficit
N/A
N/A
Compliance
263
256
Target
263
256
Table A-6. Actual and Projected COz Values, Light Trucks (g/mi]
Model
Year
2012
2013
ACTUAL
2-Cycle
Tailpipe
369
360
FFV
Credit
14.5
13.7
A/C TLAAS
Credit Credit
7.5 1.2
8.2 1.2
Off- N2O
Cycle & CH4
Credit Deficit
0.0 0.3
0.0 0.3
Compliance
348
339
Target
348
339
PROJECTED
2-Cycle FFV
Tailpipe Credit
N/A N/A
N/A N/A
A/C TLAAS
Credit Credit
N/A N/A
N/A N/A
Off- N2O
Cycle & CH4
Credit Deficit
N/A N/A
N/A N/A
Compliance
346
337
Target
346
337
This table was updated on March 31, 2015 to correct errors limited to 2-cycle tailpipe CC>2 values for manufacturers using the Temporary Lead-time
Allowance Alternative Standards (see Section 3.B).
59
-------
APPENDIX B: VEHICLE PRODUCTION VOLUMES & MARKET SHARE
Table B-l. Vehicle Production Volumes by Model Year
Manufacturer
Aston Martin^6
BMW
BYD Motors6
Coda6
Ferrari8
Fiat Chrysler
Fisker6C
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Lotus^6
Mazda
McLaren^6
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla6
Toyota
Volkswagen
Volvo
All
Model Year 2012
Car
n/a
191,154
11
115
1,510
538,887
1,415
1,052,721
1,449,244
1,047,165
630,418
12,769
439,191
n/a
213,308
0
173,832
51,927
896,278
16,946
106,152
25,266
2,952
1,298,021
500,690
52,375
8,702,347
Truck
n/a
65,856
0
0
0
994,996
0
701,602
915,130
493,414
47,766
41,792
48,612
n/a
65,696
0
81,573
12,540
331,886
12,927
163,860
5,997
0
722,227
64,882
19,432
4,790,188
All
n/a
257,010
11
115
1,510
1,533,883
1,415
1,754,323
2,364,374
1,540,579
678,184
54,561
487,803
n/a
279,004
0
255,405
64,467
1,228,164
29,873
270,012
31,263
2,952
2,020,248
565,572
71,807
13,492,535
Model Year 2013
Car
364
303,319
32
37
1,902
654,845
n/a
1,166,975
1,432,131
1,021,800
1,061,950
16,051
611,414
170
164,862
412
207,957
32,654
919,647
22,021
145,705
10,427
17,813
1,347,436
559,448
42,072
9,741,444
Truck
0
98,969
0
0
0
852,653 1,
n/a
1,234,018 2,
913,765 2,
472,569 1,
38,073 1,
47,532
16,980
0
61,093
0
89,041
13,754
372,970 1,
19,461
211,326
1,116
0
915,658 2,
68,414
31,282
5,458,674 15,
All
364
402,288
32
37
1,902
507,498
n/a
400,993
345,896
494,369
100,023
63,583
628,394
170
225,955
412
296,998
46,408
292,617
41,482
357,031
11,543
17,813
263,094
627,862
73,354
200,118
A Exempt from compliance with 2012 model year standards. B Only manufactures cars. c Did not
produce any 2013 model year vehicles.
60
-------
Table B-2. Vehicle Category Market Share by Model Year
Manufacturer
Aston Martin^6
BMW
BYD Motors6
Coda6
Ferrari8
Fiat Chrysler
Fisker6C
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Lotus^6
Mazda
McLaren^6
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla6
Toyota
Volkswagen
Volvo
All
2012
Car%
74%
100%
35%
100%
35%
100%
60%
61%
68%
93%
23%
90%
76%
68%
81%
73%
57%
39%
81%
100%
64%
89%
73%
64%
Truck %
26%
0%
65%
0%
65%
0%
40%
39%
32%
7%
77%
10%
24%
32%
19%
27%
43%
61%
19%
0%
36%
11%
27%
36%
2013
Car%
100%
75%
100%
43%
100%
43%
49%
61%
68%
97%
25%
97%
100%
73%
100%
70%
70%
71%
53%
41%
90%
100%
60%
89%
57%
64%
Truck %
0%
25%
0%
57%
0%
57%
51%
39%
32%
3%
75%
3%
0%
27%
0%
30%
30%
29%
47%
59%
10%
0%
40%
11%
43%
36%
A Exempt from compliance with 2012 model year standards. B Only
manufactures cars. c Did not produce any 2013 model year vehicles.
61
-------
APPENDIX C: 2012 MODEL YEAR COMPLIANCE VALUES
Table C-l. 2012 Compliance Values - Combined Passenger Car & Light Truck Fleet
(g/mi)
Manufacturer
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Fisker
Ford
General Motors
Honda
Hyundai
Jaguar Land Rover
Kia
Mazda
Mercedes-Benz
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
2-Cycle
Tailpipe
302
0
0
494
357
146
315
331
266
249
426
266
263
343
267
295
342
282
287
0
273
281
311
302
FFV
0
0
0
0
18
0
14
16
0
0
0
0
0
13
0
4
0
0
0
0
4
1
0
8
Credits
TLAAS
0
0
0
69
0
0
0
0
0
0
66
0
0
10
0
0
75
0
0
0
0
0
0
1
(g/mi)
A/C
8
0
0
10
10
0
6
8
3
5
7
5
0
10
0
3
0
0
0
6
7
7
11
6
Off-
Cycle
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
CH4&
N2O
Deficit
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
Compliance
Value
294
0
0
484
329
146
295
307
263
244
419
260
263
320
267
288
342
282
287
-6
263
276
300
288
This table was updated on March 31, 2015 to correct errors limited to 2-cycle tailpipe CC>2 values for
manufacturers using the Temporary Lead-time Allowance Alternative Standards (see Section 3.B).
62
-------
Table C-2. 2012 Compliance Values-Passenger Car Fleet (g/mi)
Manufacturer
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Fisker
Ford
General Motors
Honda
Hyundai
Jaguar Land Rover
Kia
Mazda
Mercedes-Benz
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
2-Cycle
Tailpipe
111
0
0
494
300
146
261
283
237
243
376
258
241
316
262
258
325
257
267
0
221
274
297
259
FFV
0
0
0
0
13
0
9
11
0
0
0
0
0
11
0
0
0
0
0
0
0
1
0
4
Credits
TLAAS
0
0
0
69
0
0
0
0
0
0
73
0
0
4
0
0
66
0
0
0
0
0
0
0
(g/mi)
A/C
7
0
0
10
9
0
5
8
3
4
5
5
0
9
0
2
0
0
0
6
7
6
10
6
Off-
Cycle
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
CH4&
N2O
Deficit
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
Compliance
Value
270
0
0
484
278
146
248
264
234
239
371
253
241
295
262
256
325
257
267
-6
214
269
287
249
This table was updated on March 31, 2015 to correct errors limited to 2-cycle tailpipe CC>2 values for
manufacturers using the Temporary Lead-time Allowance Alternative Standards (see Section 3.B).
63
-------
Table C-3. 2012 Compliance Values - Light Truck Fleet (g/mi)
Manufacturer
BMW
Fiat Chrysler
Ford
General Motors
Honda
Hyundai
Jaguar Land Rover
Kia
Mazda
Mercedes-Benz
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Toyota
Volkswagen
Volvo
Fleet Total
2-Cycle
Tailpipe
363
384
385
397
320
312
439
324
324
393
283
382
362
296
361
354
330
343
369
FFV
0
21
21
23
0
0
0
0
0
15
0
15
0
0
0
9
0
0
14
Credits
TLAAS
0
0
0
0
0
0
64
0
0
22
0
0
84
0
0
0
0
0
1
(g/mi)
A/C
11
10
8
8
4
7
8
4
0
11
0
4
0
0
0
6
9
12
8
Off-
Cycle
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
CH4&
N2O
Deficit
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Compliance
Value
353
353
357
366
316
305
431
320
324
367
283
363
362
296
361
339
322
331
348
This table was updated on March 31, 2015 to correct errors limited to 2-cycle tailpipe CC>2 values for
manufacturers using the Temporary Lead-time Allowance Alternative Standards (see Section 3.B).
64
-------
APPENDIX D: 2013 MODEL YEAR REPORTED CREDITS AND DEFICITS
Table D-l.
Manufacturer
Aston Martin
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Ford
2013 Model Year Reported Credits and Deficits
Pathway Fleet Credit Type
TLAAS Car Fleet Average
A/C Leakage
A/C Efficiency
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
Advanced
Technology
Primary Car Fleet Average
Advanced
Technology
TLAAS Car Fleet Average
A/C Leakage
A/C Efficiency
Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Advanced
Technology
CH4 Deficit
Truck Fleet Average
A/C Leakage
A/C Efficiency
CH4 Deficit
Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Advanced
Technology
CH4 Deficit
Fleet
Fleet
Average Standard
(g/mi) (g/mi)
444
0
0
271
0
0
346
0
0
0
0
0
0
0
0
475
0
0
277
0
0
0
0
359
0
0
0
247
0
0
0
0
321
0
0
263
0
0
324
0
0
0
0
269
0
239
0
331
0
0
270
0
0
0
0
338
0
0
0
265
0
0
0
0
Production
Volume
364
364
364
303,319
302,969
303,319
98,969
98,969
98969
3800
3800
32
32
37
37
1,902
1,902
1,902
654,845
652,065
652,065
2,353
132,555
852,653
852,653
852,653
6,730
1166975
1,166,975
716,500
18,551
201,807
Credits (Mg)
-8,742
243
384
-473,818
251,534
208,519
-491,780
156,207
96121
-1287
-5,115
1,681
0
1,727
0
-53,480
2,422
1,388
-895,074
796,491
421,109
0
-5,058
-4044274
1,502,157
593,554
-190
4101628
1,237,391
461,932
0
-12,412
65
-------
Table D-l. 2013 Model Year Reported Credits and Deficits
Manufacturer Pathway Fleet Credit Type
N2O Deficit
Truck Fleet Average
A/C Leakage
A/C Efficiency
Advanced
Technology
CH4 Deficit
N2O Deficit
GM 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
Advanced
Technology
Truck Fleet Average
A/C Leakage
A/C Efficiency
Hyundai Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Truck Fleet Average
A/C Leakage
A/C Efficiency
Jaguar Land
Rover Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Truck Fleet Average
A/C Leakage
Fleet
Fleet
Average Standard
(g/mi) (g/mi)
0
355
0
0
0
0
0
263
0
0
0
0
0
373
0
0
0
0
228
0
0
0
312
0
0
238
0
0
317
0
0
319
0
0
312
0
0
355
0
0
0
0
0
263
0
0
0
0
0
360
0
0
0
0
256
0
0
0
318
0
0
261
0
0
309
0
0
287
0
0
306
0
Production
Volume
11,222
1,234,018
1,234,018
1,016,037
103
546,764
261,005
1,432,131
1,431,320
1,393,351
27,484
376,185
45,511
913,765
913,765
897,210
621,051
2,134
1,021,800
0
0
471
472,569
0
0
1,061,950
1,061,950
1,061,950
38,073
38,073
38,073
6,641
6,641
6,641
18,068
18,068
Credits (Mg)
-9,795
0
2,069,771
283316
0
-49,342
-252940
0
1,775,294
821,301
0
-27,545
13,330
-2683038
1,519,501
417,695
-89,000
819
5,586,581
264,376
324,172
0
640,421
305,581
181,453
4,769,294
445,426
571,743
-68,795
32,477
32,018
-41,496
3,376
2,305
-24,486
24,894
66
-------
Table D-l. 2013 Model Year Reported Credits and Deficits
Manufacturer Pathway Fleet Credit Type
A/C Efficiency
TLAAS Car Fleet Average
A/C Leakage
A/C Efficiency
Truck Fleet Average
A/C Leakage
A/C Efficiency
Kia Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Truck Fleet Average
A/C Leakage
A/C Efficiency
Lotus TLAAS Car Fleet Average
Mazda Primary Car Fleet Average
Truck Fleet Average
McLaren TLAAS Car Fleet Average
Mercedes Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Advanced
Technology
Truck Fleet Average
A/C Leakage
A/C Efficiency
TLAAS Car Fleet Average
A/C Leakage
A/C Efficiency
Truck Fleet Average
A/C Leakage
A/C Efficiency
Mitsubishi Primary Car Fleet Average
Truck Fleet Average
Nissan Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Advanced
Technology
Truck Fleet Average
A/C Leakage
Fleet Fleet
Average Standard Production
(g/mi) (g/mi) Volume
0
358
0
0
477
0
0
252
0
0
301
0
0
334
232
296
374
284
0
0
0
326
0
0
322
0
0
430
0
0
254
267
232
0
0
0
332
0
0
350
0
0
396
0
0
258
0
0
303
0
0
311
250
311
329
262
0
0
0
321
0
0
344
0
0
424
0
0
249
296
259
0
0
0
324
0
18,068
9,410
9,410
9,410
29,464
29,464
29,464
611,414
591064
611414
16980
16,980
16980
170
164,862
61093
412
207,951
207956
207076
880
60,604
66,540
66,540
6
1
1
28,437
22,501
22,501
32,654
13,754
919,647
205,189
919,647
26,167
372,970
351,733
Credits (Mg)
17,255
-14,699
4,983
4,475
-539,046
29,018
30,310
716,323
264,796
329,198
7670
21,861
13,040
-763
579,449
206,982
-3,620
-893,318
175,477
207,174
0
-68442
102,127
73,347
26
5
6
-38,538
30,070
34,186
-31,881
90,090
4,848,497
38,523
623,973
0
-673,927
163,513
67
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Table D-l. 2013 Model Year Reported Credits and Deficits
Manufacturer
Porsche
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
Pathway Fleet Credit Type
A/C Efficiency
TLAAS Car Fleet Average
Truck Fleet Average
Primary Car Fleet Average
Truck Fleet Average
Primary Car Fleet Average
Truck Fleet Average
Primary Car Fleet Average
A/C Efficiency
Advanced
Technology
Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Advanced
Technology
Truck Fleet Average
A/C Leakage
A/C Efficiency
Primary Car Fleet Average
A/C Leakage
A/C Efficiency
CH4 Deficit
N2O Deficit
Truck Fleet Average
A/C Leakage
A/C Efficiency
CH4 Deficit
N2O Deficit
Primary Car Fleet Average
A/C Leakage
A/C Efficiency
Truck Fleet Average
A/C Leakage
A/C Efficiency
Fleet
Fleet
Average Standard
(g/mi) (g/mi)
0
309
363
254
270
266
330
0
0
0
224
0
0
0
339
0
0
265
0
0
0
0
312
0
0
0
0
292
0
0
348
0
0
0
314
410
251
299
243
296
296
0
0
257
0
0
0
329
0
0
257
0
0
0
0
317
0
0
0
0
264
0
0
316
0
0
Production
Volume
372,681
22,021
19461
145705
211326
10,427
1116
17813
17,813
17813
1347436
1347436
1347436
829
915658
902403
915658
559448
0
0
0
0
68,414
0
0
0
0
42072
42072
42072
31282
31282
31282
Credits (Mg)
189942
21,500
206,591
-85,353
1384203
-46,828
-8,570
1,029,558
19,826
0
8,682,490
816,463
1,053,911
0
-2,068,151
723,525
677,550
-873,920
290,530
417,724
-57,902
-150,195
77,262
78,562
80313
-434
-10889
-230024
51622
30611
-226096
51538
25343
68
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