Greenhouse Gas
Emission Standards for
Light-Duty Vehicles
Manufacturer Performance Report
for the
Model Year
Aston Martin
Lotus
Tesla
BYD Motors
Toyota
Mazda
Ford
Subaru
General Motors
Mitsubishi
Nissan
Volkswagen
BMW
Fiat Chrysler
Volvo
Mercedes-Benz
Suzuki
Jaguar
Land Rover
Ferrari
Hyundai
Aston Martin
Lotus
Tesla
BYD Motors
United States
Environmental Protection
Agency
EPA-420-R-15-026 December 2015
Toyota
Mazda
Ford
Subaru
General Motors
Mitsubishi
Nissan
Volkswagen
BMW
Fiat 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 /
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 6
2. Small Volume Manufacturers 6
3. Operationally Independent Manufacturers 7
4. Aggregation of Manufacturers 7
2. Optional GHG Credits From 2009-2011 Model Years 9
3. Credits Reported From the 2012-2014 Model Years 13
A. "2-Cycle" Tailpipe CO2 Emissions 14
B. TLAAS Program Standards 17
C. Credits Based on Alternative Fuel Vehicles 19
1. Advanced Technology Vehicles 19
2. Compressed Natural Gas Vehicles 21
3. Gasoline-Ethanol Flexible-Fuel Vehicles 22
D. Credits Based on Air Conditioning Systems 24
1. Air Conditioning Leakage Credits 27
Air Conditioning Efficiency Credits 30
Credits Based on "Off-Cycle" Technology 32
1. Off-Cycle Credits Based on the Menu 34
2. Off-Cycle Technology Credits Based on 5-Cycle Testing 41
3. Off-Cycle Technology Credits Based on an Alternative Methodology 41
F. Deficits Based on Methane and Nitrous Oxide Standards 42
G. 2014 Model Year Compliance Values 44
H. 2014 Model Year Footprint-Based CO2 Standards 49
I. Overall Compliance Summary 54
4. Credit Transactions 57
5. Compliance Status After the 2014 Model Year 59
Appendix A: Comparing Actual Performance to Rulemaking Projections 64
Appendix B: Vehicle Production Volume & Market Share 70
Appendix C: 2012-2013 Model Year Compliance Values 72
Appendix D: 2014 Model Year Report Credits and Deficits 78
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LIST OF TABLES AND FIGURES
Industry Compliance Values versus Standards in 2012-2014 Model Years iii
Manufacturer Compliance Values and Standards in the 2014 Model Year iv
Credit Balances at Conclusion of the 2014 Model Year v
Use of Compliance Program Flexibilities vi
Table 1-1. Aggregation of Manufacturers in the 2014 Model Year 8
Table 2-1. Total Early Credits, by Manufacturer and Model Year 10
Table 2-2. Total Reported Early Credits, By Credit Category 10
Table 2-3. Expired 2009 Model Year Credits 11
Table 3-1. "2-cycle" Tailpipe CO2 Production-Weighted Fleet Average Emissions 16
Table 3-2. Production Volumes Assigned toTLAAS Standards 18
Table 3-3. Net Impact from Use of theTLAAS Program 19
Table 3-4. Production Volumes of Advanced Technology Vehicles Using Zero Grams/Mile Incentive, by Model
Year 21
Table 3-5. Number of FFV Models by Manufacturer, 2012-2014 Model Years 23
Table 3-6. Production Volume of FFVs by Manufacturer, 2012-2014 Model Years 24
Table 3-7. Net Credits Accrued from Use of the FFV Incentives 24
Table 3-8. Reported Air Conditioning Credits by A/C Credit Type and Model Year 26
Table 3-9. Reported Air Conditioning Credits by Manufacturer, 2014 Model Year 26
Table 3-10. Net Impact of Air Conditioning Credits 27
Table 3-11. Production of Vehicles Using HFO-1234yf, 2013-2014 Model Years 28
Table 3-12. Reported Air Conditioning Leakage Credits by Manufacturer and Fleet, 2014 Model Year 29
Table 3-13. Air Conditioning Leakage Credits 30
Table 3-14. Reported Air Conditioning Efficiency Credits by Manufacturer and Fleet, 2014 Model Year 31
Table 3-15. Air Conditioning Efficiency Credits 32
Table 3-16. Reported Off-Cycle Technology Credits by Manufacturer and Fleet, 2014 Model Year (Mg) 33
Table 3-17. Off-Cycle Technology Credits 34
Table 3-18. Reported Off-Cycle Technology Credits from the Menu, by Manufacturer and Fleet, 2014 Model
Year 35
Table 3-19. Off-Cycle Technology Credits from the Menu by Technology, 2014 Model Year 37
Table 3-20. Percent of 2014 Model Year Vehicle Production Volume with Credits from the Menu, by
Manufacturer & Technology 39
Table 3-21. Off-Cycle Technology Credits from the Menu, by Manufacturer and Technology 40
Table 3-22. Reported Off-Cycle Credits Based on 5-Cycle Testing 41
Table 3-23. Reported cm and N2O Deficits by Manufacturer and Fleet, 2014 Model Year 43
Table 3-24. CH4 Deficits 44
Table 3-25. N2O Deficits 44
Table 3-26. 2014 Compliance Values - Combined Passenger Car & Light Truck Fleet 46
Table 3-27. 2014 Compliance Values - Passenger Car Fleet 47
Table 3-28. 2014 Compliance Values- Light Truck Fleet 48
Table 3-29. 2012-2014 Model Year Compliance Values by Manufacturer and Fleet 49
Table 3-30. 2012-2014 Model Year CO2 Standards by Manufacturer and Fleet 51
Table 3-31. Average Footprint by Manufacturer and Fleet 53
Table 3-32. Compliance & Credit Summary, 2012-2014 Model Years - Combined Cars and Trucks 54
Table 3-33. Compliance & Credit Summary, 2012-2014 Model Years- Passenger Cars 54
Table 3-34. Compliance & Credit Summary, 2012-2014 Model Years- Light Trucks 55
Table 3-35. 2014 Model Year Compliance Summary by Manufacturer and Fleet 56
Table 4-1. Reported Credit Sales and Purchases as of the 2014 Model Year 58
Table 5-1. Cumulative Credit Status After the 2014 Model Year 60
Table 5-2. Credits Available After the 2014 Model Year, Reflecting Trades & Transfers 63
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Table A-l. Projected CCh Performance in Rulemaking Analyses for the Combined Passenger Car and Light Truck
Fleet 65
Table A-2. Projected CCh Performance in Rulemaking Analyses for Passenger Cars 66
Table A-3. Projected CCh Performance in Rulemaking Analyses for Light Trucks 66
Table A-4. Actual and Projected CCh Values, Cars and Trucks Combined 69
Table A-5. Actual and Projected COz Values, Passenger Cars 69
Table A-6. Actual and Projected COz Values, Light Trucks 69
Table B-l. Vehicle Production Volume by Manufacturer and Vehicle Category 70
Table B-2. Vehicle Category Market Share by Manufacturer and Model Year 71
Table C-l. 2012 Compliance Values - Combined Passenger Car & Light Truck Fleet 72
Table C-2. 2012 Compliance Values - Passenger Car Fleet 73
Table C-3. 2012 Compliance Values- Light Truck Fleet 74
Table C-4. 2013 Compliance Values - Combined Passenger Car & Light Truck Fleet 75
Table C-5. 2013 Compliance Values - Passenger Car Fleet 76
Table C-6. 2013 Compliance Values - Light Truck Fleet 77
Table D-l. 2014 Model Year Reported Credits and Deficits 78
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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 2014 model year, the third year of the GHG standards which become
increasingly stringent in each model year from 2012 through 2025. Some values from previous
model years may have changed based on changes or corrections to the historical data. 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. 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.
It is important to note that EPA has issued notices of violation to Volkswagen alleging that
certain MY 2009-2016 diesel vehicles are in violation of the Clean Air Act for excess oxides of
nitrogen emissions (see www.epa.gov/vw). In this report, EPA uses the CO2 emissions data from
the initial certification of these vehicles. Should the investigation and corrective actions yield
different CO2 data, the revised data will be used in future reports.
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://www3 .epa. gov/otaa/climate/ghg-report.htm.
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Process for Determining a Manufacturer's Compliance Status
Alternative Fuel Vehicles
Air Conditioning
Off-Cycle
2-Cycle
Tailpipe
C02
Deficits
Methane & Nitrous
Oxide Deficits
Prior Model Year
Credits & Deficits
Overall Model •
Performance
Credit
Transactions
Current Co .
Status
Future Credits
& Deficits
"N /'*
j
i
i
Future Credit
Transactions
r::::::::::;::::::::.7j
Final Compliance
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 a 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 through 2014 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 these first three
model years; their performance in subsequent years will ultimately determine final compliance.
11
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1
For the third consecutive year, the auto industry outperformed
the GHG standard by a substantial margin
Overall industry compliance in model year 2014 was 13 grams/mile better than required by the
2014 GHG emissions standard. This marks the third consecutive model year of industry
outperforming the standards by a wide margin; industry over-compliance in 2013 was 12
grams/mile and in 2012 was 11 grams/mile better than required. This industry-wide performance
means that consumers continue to buy vehicles with lower GHG emissions than required by the
EPA 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
standards decreased by 5 grams/mile from 2013 to 2014, manufacturers matched this increase in
stringency by reducing compliance values by 5 grams/mile in 2014.
Industry Compliance Values versus Standards in 2012-2014 Model Years
305
300
295
^290
E
"^T 285
E
nj
jib 280
e>
5 275
270
265
260
11 g/mi
lower than target
• Compliance Standard
i Compliance Value
7 g/mi
5 g/mi
12 g/mi
lower than target
13 g/mi
lower than target
2012
2013
Model Year
2014
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 2014
standard
Most large manufacturers achieved fleet GHG compliance values equal to or lower than required
by their unique 2014 standard. Ten of the twelve manufacturers with sales greater than 100,000
vehicles reported meeting or beating their standard, with margins of compliance ranging from 28
grams/mile (Subaru) to exactly meeting their standard with no margin (Fiat Chrysler). Two
manufacturers, Mercedes and Kia, missed their unique 2014 standards by 5 and 8 grams/mile,
respectively, thus generating deficits in the 2014 model year. More detail about model year 2014
performance is provided in Section 3. The figure below does not include the impact of credit
transfers (within a company) reported from prior model years or reported credit trades
(transactions between companies), and thus does not portray whether or not a manufacturer has
complied with 2014 model year standards. The manufacturers that did not outperform their 2014
standard - Mercedes and Kia - in fact have reported sufficient credits from prior model years to
be in compliance with their respective 2014 model year standards.
Manufacturer Compliance Values and Standards in the 2014 Model Year
(from highest to lowest GHG standard)
350
300
250
—-
o
E 200
M
E
'2
oo
r iso
' Compliance Standard
I Compliance Value
100
50
„
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3
All large manufacturers are in compliance with the 2012-2014
GHG standards
The majority of manufacturers, representing more than 99 percent of U.S. sales, have reported
compliance with the standards for the 2012-2014 model years. In fact, 20 of 24 manufacturers
are reporting a positive credit balance going into the 2015 model year, meaning that these
manufacturers have met the standards in all of the 2012-2014 model years (credits cannot be
carried forward if a deficit exists in a prior model year). The manufacturers currently reporting
deficits in any or all of the 2012-2014 model years are allowed to carry those deficits forward for
three model years, giving them time to generate or purchase credits to demonstrate compliance
with the 2012-2014 model year standards. Thus, a manufacturer with a deficit remaining from
the 2012 model year has until the end of the 2015 model year to offset that deficit. The current
status of manufacturers carrying a deficit into the 2015 model year is neither compliance nor
non-compliance - rather, they have not yet fully demonstrated compliance. The makeup of these
credit and deficit balances is tracked by model year "vintage" as explained in Section 5.
Credit Balances at Conclusion of the 2014 Model Year (Mg)4
(including credit transfers & trades)5
Manufacturer
Toyota
Honda
GM
Ford
Hyundai
Nissan
Fiat Chrysler
Subaru
Kia
Mazda
BMW
Mitsubishi
All Manufacturers
Credits Carried to 2015
81,271,823
39,233,010
30,380,022
27,509,054
19,727,364
17,810,733
13,759,576
10,236,711
9,819,076
7,160,086
1,532,564
1,333,267
Manufacturer
Suzuki*
Mercedes*
Ferrari
Volvo
Fisker*
Coda*
BYD Motors
Tesla
Lotus*
McLaren*
Aston Martin*
Jaguar Land Rover*
Credits Carried to 2015
428,242
228,172
107,613
74,291
46,694
7,251
4,824
1,965
(2,841)
(6,507)
(35,844)
(509,745)
264,868,614
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance data,
Volkswagen has a credit balance of 4,751,213 Mg.
*These companies are using a temporary program for limited-volume manufacturers that allows some vehicles to be subject
to less stringent standards. See Section 3.B.
*Although these companies produced no vehicles for the U.S. in the most recent model year, the credits generated in
previous model years continue to exist.
4 The Megagram (Mg) is a unit of mass equal to 1000 kilograms. It is also referred to as the metric ton or tonne.
5 This table does not include unused credits from the 2009 model year, which expired at the end of the 2014 model
year. See Section 2 for more information.
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4
Manufacturers continue to reduce GHG emissions while using a
wide variety of compliance flexibilities that were designed into
the program
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 through use of GHG-
reducing technologies, 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. For example, manufacturers generated credits for using air
conditioning and off-cycle technology credits. Off-cycle technologies included stop-start, active
engine and transmission warm-up strategies, high efficiency exterior lighting, and window
glazing that reduces solar load to the vehicle's interior volume. Five manufacturers have also
now introduced a new and significantly lower-GHG air conditioning refrigerant to the U.S.
automotive market, reducing GHG emissions and helping 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
<^
Core Design
Elements
Generating Credits
Credit
Transfers &
Trades
OJ
.c
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 2015
Trade: Credits Out
Trade: Credits In
Small Company Provisions
CH4 & N2O Alternative
X
X
X
X
X
- Th<
an<
X
X
X
X
X
X
X
;se program elements are integral to the program desig
J are critical for maintaining consumer choice and redu(
npliance costs while achieving significant GHG reductio
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
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X
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_
A
X
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X
X
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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.6'7 This
report is the fourth 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.8 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,9 and in March of 2015 we released a report
documenting GHG performance in the 2013 model year.10 Because of changes that propagate
back to prior model years, such as the buying and selling of credits by manufacturers, prior
reports should be considered obsolete and are superseded by this report.
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.11 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.12 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
6 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.
7 NHTSA now provides information to the public regarding fuel economy compliance through a web-accessible
public information center. See http://www.nhtsa.gov/CAFE_PIC/CAFE_PIC_Home.htm.
8 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.
9 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.
10 Greenhouse Gas Emission Standards for Light-Duty Vehicles: Manufacturer Performance Report for the 2013
Model Year, Compliance Division, Office of Transportation and Air Quality, U.S. Environmental Protection
Agency, Report No. EPA-420-R-15-008a, March 2015.
11 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.
12 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.
1
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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."13
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 2014 model year is the third year manufacturers have been subject
to the standards. This report makes comparisons across the three complete model years of the
GHG program 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 May 1 of 2015.14 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,
13 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final
Rule, Federal Register 75 (7 May 2010): 25469.
14 See 40 CFR 600.512-12.
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credit trades between manufacturers, if applicable, and all the data necessary to calculate these
reported values.
This report first updates and summarizes the credits reported by manufacturers under the early
credit provisions, and then summarizes the data reported by manufacturers for the 2012-2014
model years in a variety of ways. This includes separately detailing manufacturers' reported use
of the flexibilities included in the program (e.g., credits for air conditioning improvements or
production of flexible-fuel vehicles), as well as the credit transactions between manufacturers.
Vehicle and fleet average compliance for EPA's GHG program is based on a combination of
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 each 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.15 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.
Credits are expressed throughout this report in units of Megagrams (Mg), which is how credits
are reported to EPA by the manufacturers.16 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. In order to present the impact of these credits in terms that might
be more understandable and are comparable equitably across manufacturers, we calculate and
15 "Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975 Through
2015," U.S. EPA-420-R-15-016, Office of Transportation and Air Quality, December 2015. See
http://epa.gov/otaq/fetrends.htm.
16 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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present a grams/mile equivalent value where possible (see inset on this page for the methodology
used to convert Megagrams to grams/mile).1? Where such a value in a table applies to a specific
manufacturer, the grams/mile value represents the impact of credits on the fleet of that specific
manufacturer, whereas the final Fleet Total row displays the grams/mile impact of the total
credits across the entire 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
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] = ( CO2 x VMT x Production ) / 1,000,000
"CCh" represents the credit in grams/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 2014 model year fleet
covered by this report, the weighted VMT is 207,705 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 reoort.
documents for additional information.18
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
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",
17 The quantity of Megagrams generated by a manufacturer is based on production volume, thus, larger
manufacturers will produce larger balances of credits or deficits. Because of the connection to production volume,
comparing Megagrams across manufacturers isn't meaningful, e.g., a higher volume of credits in Megagrams does
not necessarily indicate better performance relative to the standard relative to other manufacturers with fewer
credits.
18 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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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 reports 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 2015 model years may be carried forward and used through the 2021 model year.
Credits from the 2009 model year and 2016 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 have expired and have been removed from the manufacturer's credit bank.
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.19
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.
On September 18, 2015, EPA issued a notice of violation of the Clean Air Act to Volkswagen
alleging that certain model year 2009-2015 Volkswagen and Audi vehicles equipped with 4-
cylinder diesel engines include "defeat device" software that results in up to 40 times higher
oxides of nitrogen pollution in real world driving than on EPA emissions tests. On November 2,
2015, EPA issued a second Notice of Violation to Volkswagen alleging that certain model year
2014-2016 Volkswagen, Audi, and Porsche 6-cylinder diesel vehicles are similarly in violation
of the Clean Air Act.20 These alleged violations are now the subject of an ongoing EPA
investigation. Oxides of nitrogen emissions are not directly related to tailpipe CO2 emissions, but
19 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. See Section 2 for more information.
20 See www.epa.gov/vw for more information.
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corrective actions taken by Volkswagen could impact CO2 data. In this report, EPA uses the CO2
emissions data from the initial certification of these vehicles. Should the investigation and
corrective actions yield different CO2 data, the revised data will be used in future reports.
Because Volkswagen diesels account for less than 1% of industry production, data changes are
expected to have a negligible impact on industry-wide values.
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
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.21
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.22 Since then, however, it has become clear that some manufacturers are
21 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.
22 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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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 2014 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
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 2014 model year, petitioned EPA for operationally independent
status, and EPA granted this status to Ferrari starting with the 2012 model year.23 As an
operationally independent manufacturer with a low U.S. sales volume (2,301 cars in the 2014
model year), Ferrari has the same options as the three small volume manufacturers discussed
above. Ferrari has been successful in purchasing credits from other manufacturers to entirely
offset their deficits, complying with the 2012-2014 standards and carrying credits into the 2015
model year.
4. Aggregation of Manufacturers
We refer throughout this report to the names of manufacturers at the highest aggregated level,
and it may not necessarily be readily apparent who owns 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 2014 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.
23 Fiat Chrysler Automobiles announced in October 2014 the intention to spin off Ferrari into a separate,
shareholder-owned company. At the time of writing this report, the spin-off has been completed and Ferrari is now
trading on the New York Stock Exchange as an independent company. For the purpose of this report, however,
Ferrari was majority-owned by Fiat Chrysler Automobiles and held operationally independent status for the 2014
model year.
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Table 1-1. Aggregation of Manufacturers in the 2014 Model Year
Manufacturer
Manufacturers and Brands Included
BMW
Fiat Chrysler24
Ford
GM
Honda
Mercedes
Nissan
Toyota
Volkswagen25
BMW, Mini, Rolls-Royce
Chrysler, Dodge, Fiat, Jeep, Maserati, Ram
Ford, Lincoln
Buick, Cadillac, Chevrolet, GMC
Acura, Honda
Maybach, Mercedes-Benz, Smart
Infiniti, Nissan
Lexus, Scion, Toyota
Audi, Bentley, Bugatti, Lamborghini, Porsche, Volkswagen
24 Ferrari was owned by Fiat Chrysler Automobiles in the 2014 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 in the 2014 model year and thus is shown as a separate entity in this
report.
25 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 was considered a separate entity under the GHG
program for the 2012 and 2013 model years, but in the 2014 model year is 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").26
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
credits by some manufacturers (see Section 4), while not shown in Table 2-1, impacts the
26 Greenhouse Gas Emission Standards for Light-Duty Automobiles: Status of Early Credit Program for Model
Years 2009-2011, Compliance Division, Office of Transportation and Air Quality, U.S. Environmental Protection
Agency, Report No. EPA-420-R-13-005, March 2013.
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available credit balances of the manufacturers involved in such transactions, as has the use of
early credits to offset future model year deficits. Additionally, while credits from the 2009 model
year may be used for compliance in 2014, any remaining unused 2009 model year credits will
expire and may not be carried forward into the 2015 model year. 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 2012-2015 model years.
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
Volvo
Total
2009*
1,547
445,683
5,926,979
8,358,440
13,009,374
14,133,353
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
194,289
98,072,559
2010
676
308,490
4,833,763
7,416,966
11,073,134
14,182,429
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
359,436
95,704,420
2011
1,109
250,119
(1,650,535)
300,482
482,321
7,539,750
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
176,462
37,018,921
Total
3,332
1,004,292
9,110,207
16,075,888
24,564,829
35,855,532
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
730,187
230,795,900
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original
compliance data, Volkswagen generated early credits of 2,243,205 Mg in 2009, 2,811,663 Mg in 2010, and
1,386,537 in 2011, for a total of 6,441,405 Mg.
*Credits from the 2009 model year not used to offset deficits in the 2012-2014 model years expired at the
end of the 2014 model year and will be removed from a manufacturer's credit bank.
Table 2-2. Total Reported Early Credits, By Credit Category
Credit Category
Tailpipe CO2*
A/C Leakage
A/C Efficiency
Off -Cycle
Total
Credits (Mg)
198,792,034
23,431,724
8,566,510
5,632
230,795,900
Percent of Tola l(%)
86%
10%
4%
0%
100%
*Tailpipe C02 credits in the early credits program do not include credits from
flexible fuel vehicles.
10
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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/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.
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 2009-2014 model years.
Due to concerns expressed by stakeholders during the rulemaking process, EPA placed certain
regulatory restrictions on credits from the 2009 model year.27 Specifically, 2009 model year
credits may not be traded to another company, and they retained a 5 year credit life. Thus, any
unused 2009 model year credits expired at the end of the 2014 model year. Table 2-3 shows the
credits left unused by each manufacturer at the end of the 2014 model year. These credits may
not be carried forward to the 2015 model year, and shall be removed from each manufacturer's
bank of credits. Note that of the 98 million Mg of 2009 credits earned by manufacturers, almost
75 million Mg, or about 75 percent, were never used and have now expired. The expired credits
also amount to about one third of the total early credits accumulated by manufacturers in the
2009-2011 model years.
Table 2-3. Expired 2009 Model Year Credits
Manufacturer
Toyota
Honda
Nissan
GM
Ford
Hyundai
Kia
Mazda
VW
Mitsubishi
Subaru
Suzuki
Total
Credits (Mg)
29,523,399
14,133,353
8,190,124
6,473,623
5,882,011
4,476,176
2,282,680
1,390,883
1,150,976
583,146
491,789
265,311
74,843,471
27 Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards, Final Rule,
Federal Register 75 (7 May 2010): 25324, 25328.
11
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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 2014 model year, and the accompanying data
as reported by manufacturers for the 2009-2014 model years, should be used as the references
from which to determine credit balances and overall performance at the conclusion of the 2014
model year, and prior reports should generally be considered obsolete.
12
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3. CREDITS REPORTED FROM THE 2012-2014 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, some 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 grams/mile basis as measured on
EPA test procedures for each vehicle model, 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 production-weighted 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.
We begin by discussing the "2-cycle" tailpipe GHG emissions value (Section 3.A), which is the
starting point for compliance for every manufacturer. We then detail each of the different credit
and incentive programs, distilling each to an overall grams/mile impact for each manufacturer.
13
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Section 3.B describes the temporary
lead time allowance alternative
standards (TLAAS); Section 3.C
on air conditioning system
IMPORTANT NoTE mGARDING TABLES
Many of tables in this section have a final row
"Fleet Total" This row indicates a value that is
describes alternative fuel vehicle ii^ju j *u *• ji n*j-
. , ,. , calculated based on the entire model year fleet and is
incentives, including the temporary n(jt ific ^ tQ ^ manufacturers Usted in the
flexible fuel vehicle incentives; 4 ui T- i A n r-^ ^j
. _^ , ., ,- , , table. For example, not all manufacturers generated
Section 3.D describes credits based ,-, f • ,-,• • , , ,,,c ,
credits for air conditioning systems, but the final
"Fleet Total" row in those tables indicates values that
improvements; Section 3 .E are calculated to ghow the • t of air conditioning
descnbes off-cycle emission ,.. ,, .. , , a . r ,,
. . J credits on the entire model year fleet (i.e., across all
reductions; and Section 3.F f . ,,, ..u ^. A •
,. ' . „ , . manufacturers, whether or not they reported air
discusses the impact of alternative ,.,. . ,-. ^
, , . . , conditioning credits).
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 2014 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 in the same manner as did the
report for the 2013 model year. Instead of focusing on Megagrams of credits and deficits (which
is how credits are reported to EPA by the manufacturers), this report describes 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 reported to
EPA, which is then 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 produced by a
manufacturer. A sales-weighted average of all of the combined city/highway tailpipe values is
calculated for each passenger car and light truck fleet and reported to EPA. 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.
14
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Table 3-1 shows the 2-cycle tailpipe emissions for the car, truck and combined fleets reported by
each manufacturer for the 2012-2014 model years.28 Absent the use of credits and incentives,
manufacturers demonstrated overall reductions in tailpipe GHG emissions in both the car and
truck categories in 2014 relative to 2013. Manufacturers were split almost evenly between those
with an increase and those demonstrating a decrease in 2-cycle GHG emissions relative to model
year 2013. Across the industry, a small reduction in 2-cycle GHG emissions from cars (1 g/mi)
and a sizeable reduction in 2-cycle emissions from trucks (10 g/mi) led to a net of no change in
overall fleet-wide 2-cycle emissions. Despite the reductions in car and truck emissions, the fleet
2-cycle emissions overall did not change from 2013 to 2014 because of an industry-wide
increase in truck production in the 2014 model year to 41 percent of the fleet, up from 36 percent
relative to the 2013 model year fleet (see Appendix A for car and truck production data).
On a percentage basis the most significant reductions from the 2013 to the 2014 model year were
reported by Mitsubishi (-8.8%), BMW (-7.6%), and Jaguar Land Rover (-6.0%). Both Hyundai
and Kia reported increases in fleet CO2 emissions, but those appear to be largely due to unusual
division of production volume for those companies across the 2013 and 2014 model years.
Hyundai passenger cars, particularly some of their low-GHG models, had a long production
model year in 2013 and a short 2014 model year. As a result, Hyundai's production of cars was
over 1 million units in the 2013 model year, then dropped to about half that in the 2014 model
year, while truck production remained steady across the two model years. In addition to this
unusual distribution across model years, and as was the case in the 2013 model year, the impact
of shifts in car and truck production can be seen in the 2-cycle data (see Appendix A for car and
truck production volume data). For example, note that Ford did not reduce emissions from either
their car or truck fleets, yet reported an overall combined fleet reduction of 6 g/mi. This derives
from a shift from 49 percent cars in the 2013 model year to 54 percent cars in the 2014 model
year (the opposite of the industry-wide trend from 2013 to 2014).
28 The values in Table 3-1 do not include the impacts of credits or incentives resulting from FFVs, CNG vehicles, air
conditioning improvements, and off-cycle technologies. The impacts of these are 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 status.
15
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Table 3-1. "2-cycle" Tailpipe CO2 Production-Weighted Fleet Average Emissions (g/mi)
Manufacturer
Aston MartinA
BMW
BYD Motors
Coda8
Ferrari
Fiat Chrysler
Fisker8
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
LotusA
Mazda
McLaren*
Mercedes
Mitsubishi
Nissan
Porschec
Subaru
Suzuki8
Tesla
Toyota
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
297
259
Trucks
363
384
385
397
320
312
439
324
324
393
283
382
362
296
361
354
343
369
All
302
0
0
494
357
146
315
331
266
249
426
266
263
343
267
295
342
282
287
0
273
311
302
Model Year 2013
Cars
444
271
0
0
475
289
256
273
228
238
345
252
334
232
374
296
254
232
309
254
266
0
224
292
251
Trucks
346
380
375
395
312
317
414
301
296
371
267
340
363
270
330
347
348
360
All
444
292
0
0
475
344
321
325
257
241
399
254
334
251
374
321
258
266
336
264
273
0
278
318
294
Model Year 2014
Cars
454
256
0
484
298
256
266
228
247
347
265
338
220
372
285
224
229
250
0
221
288
250
Trucks
312
364
375
369
299
325
379
330
287
372
256
335
254
358
348
349
All
454
270
0
484
346
315
314
259
253
374
269
338
240
372
309
236
263
253
0
274
319
294
Change,
2013 to 2014
Cars Trucks All
10
-15
0
9
9
0
-7
0
9
2
13
4
-12
-2
-11
-30
-3
-4
0
-3
-4
-1
10
-34 -22
0
9
-16 2
0 -6
-26 -11
-13 2
8 12
-35 -24
29 15
4
-9 -11
-2
1 -12
-11 -23
-5 -3
-16 -11
0
11 -4
0 1
-10 0
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on
tailpipe values are 266 g/mi for cars, 336 g/mi for trucks, and 280 g/mi for the combined
A Exempt from compliance with 2012 model year standards.
B No production in 2013 and/or 2014 model years.
c Starting with the 2014 model year, Porsche vehicles are incorporated into Volkswagen.
the original compliance data, Volkswagen's 2014 model year 2-cycle
fleet.
16
-------
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
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 and 2014 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 by 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 through 2014
model years. The smallest-volume companies (Aston Martin, Ferrari, Lotus, and McLaren)
placed all of their 2013 and 2014 production into a TLAAS fleet, because they can do so without
any risk of exceeding the applicable limits. Porsche, which 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 are now 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 reported use of the TLAAS program for the 2012-2014
model years. Note that the total of 286,740 vehicles placed under the less stringent standards in
17
-------
the program to date represents less than one percent of the total vehicles produced in the 2012-
2014 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. For example, Mercedes-Benz and
Jaguar Land Rover, the largest of the manufacturers using these temporary and limited
alternative standards, have both made substantial progress reducing tailpipe GHG emissions
from 2012 to 2014. As shown in the previous section, Jaguar Land Rover and Mercedes reduced
their overall tailpipe emissions by 52 and 34 grams/mile, respectively, since the program started
in the 2012 model year.
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
364
1,902
9,410
170
412
6
22,021
34,285
Trucks
29,464
28,437
19,461
77,362
All
364
1,902
38,874
170
412
28,443
41,482
111,647
Model Year 2014
Cars
1,272
2,301
12,323
280
279
7,095
23,550
Trucks
0
0
29,130
0
0
14,740
43,870
All
1,272
2,301
41,453
280
279
21,835
0
67,420
Cumulative
Total
1,636
5,713
125,802
450
691
81,093
71,355
286,740
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 model year, not just the set of manufacturers
enrolled in the TLAAS program. Thus, the overall net impact on the 2014 fleet of the TLAAS
program is 0.3 g/mi. Unlike other credits, the impact of the TLAAS program is not an adjustment
to 2-cycle emissions, but rather, an adjustment to the standard. For example, Aston Martin's fleet
average standard against which they must demonstrate compliance is 65 grams/mile greater than
it would be without use of the TLAAS program.
18
-------
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
Cars Trucks
69
73 64
4 22
66 84
0.3 1.2
Year
All
69
66
10
75
0.7
2013 Model
Cars Trucks
64
66
41 49
62
66
0 27
63 82
0.2 1.2
Year
All
64
66
47
62
66
9
73
0.6
2014 Model
Cars Trucks
65
65
67 42
60
64
2 13
0.2 0.6
Year
All
65
65
46
60
64
5
0.3
*For the purposes of the EPA GHG program, Porsche is aggregated with Volkswagen as of the 2014 model year and is no
longer eligible to use the TLAAS standards.
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. 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 a zero grams/mile
value for the portion of operation attributed to the use of grid electricity (i.e., only emissions
from the portion of operation attributed to gasoline engine operation are "counted" for the
compliance value). 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 General
Motors and Mercedes-Benz selected an option in the early credit provisions by which they could
choose to set aside their relatively small 2011 model year advanced technology vehicle
production for inclusion in a future model year yet to be determined.
All manufacturers of advanced technology vehicles in the 2012-2014 model years are well below
the cumulative 200,000 vehicle limit for the 2012-2016 model years, thus all manufacturers
19
-------
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.29 EPA regulations provide all the information necessary to calculate a unique net
upstream value for each electric or plug-in hybrid electric vehicle.30
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 2012-2014 model years. Without the incentive, however, the 2014 model
year 2-cycle fleet average GHG emissions for Tesla would in fact be about 123 grams/mile.31
Use of the incentive in Tesla's case in the 2014 model year allows them to generate just over
427,000 Mg of additional GHG credits relative to using the net upstream value of 123
grams/mile. Nissan's 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.32 As a result,
the overall impact on Nissan's passenger car fleet in the 2014 model year is an improvement of
about one gram/mile, allowing them to generate almost 142,000 Mg of credits more than if the
incentive provisions were not in place. The net impact from Nissan and Tesla on the entire 2014
model year fleet of this incentive is thus about 569,000 Mg of credits, or about 0.2 grams/mile.
While there are other electric vehicles and plug-in hybrid electric vehicles in the 2014 fleet, as
shown in Table 3-4, Nissan and Tesla account for a substantial fraction of the 2014 model year
volume of these vehicles. A few thousand of the remaining advanced technology vehicles are
electric vehicles, but the majority of the remaining vehicles 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 of advanced technology vehicles
- General Motors and Ford - produce 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
2014 model year fleet, we have not carried out the analysis for all advanced technology vehicles.
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 2010-2014
production volumes of advanced technology vehicles that utilized the zero grams/mile incentive.
29 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final
Rule, Federal Register 75 (7 May 2010): 25435.
30 See 40 CFR600.113-12(n).
31 Using the calculations prescribed in the regulations, the sales-weighted upstream emissions for Tesla's 2014
passenger cars is 203 grams/mile and the upstream emissions associated with a comparable gasoline vehicle is 80
grams/mile. The difference, or the net upstream emissions of Tesla's 2014 passenger car fleet, is 123 grams/mile.
32 The upstream GHG 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 2014
Leaf, is 70 grams/mile.
20
-------
Table 3-4. Production Volumes of Advanced Technology Vehicles Using Zero Grams/Mile
Incentive, by Model Year
Manufacturer
BMW
BYD Motors
Coda
Fiat Chrysler
Fisker
Ford
GM
Honda
Mercedes
Mitsubishi
Nissan
Tesla
Toyota
Volkswagen
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 1
27,484
471
880
-
26,167
17,813
829
-
94,720
2014
9,895
50
-
3,404
-
18,826
25,847
1,635
3,610
219
10,339
17,791
1,218
755
93,589
Total
9,895
93
37
5,757
1,415
38,133
76,056
2,106
5,061
1,654
56,461
39,424
2,499
755
239,346
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 2012-2014 model years, and is a dedicated alternative fuel vehicle.
EPA's GHG program contains a temporary incentive for CNG vehicles (for both dedicated and
dual fuel 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 emissions 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
0.15.33 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 about 0.1 grams/mile due to the low production volume of the Civic CNG
(about 750 in model year 2014). This does not affect Honda's overall rounded car fleet average
performance value, and likewise has an unnoticeable impact on the overall 2014 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.
33 Use of the 0.15 factor for GHG compliance for dedicated and dual fuel CNG vehicles sunsets after the 2015
model year. Starting with the 2017 model year a production multiplier incentive becomes effective. See the
regulations at 40 CFR 86.1866-12(b).
21
-------
3. Gasoline-Ethanol Flexible-Fuel Vehicles
The impact of ethanol flexible fuel vehicles (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 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 E85 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 approach—including 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.34 In fact, the standards in the early years of the GHG program were developed with an
explicit understanding that some manufacturers would make use of this and other incentive and
credit programs to meet the standards.
In the 2014 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
34 EPA Guidance Letter "E85 Flexible Fuel Vehicle Weighting Factor for Model Year 2016-2018 Vehicles," CD-
14-18, November 12, 2014.
22
-------
comparable to 1.2 mpg and is calculated from a manufacturer's specific fleet average
performance value.
Eight manufacturers produced FFVs in the 2014 model year, as shown below in Tables 3-5 and
3-6. Clearly, Fiat Chrysler, Ford, and General Motors produced the overwhelming majority of
vehicles capable of operating on E85. Jaguar Land Rover was a new entrant in this field in the
2013 model year, and tripled the number of models capable of operating on E85 in the 2014
model year. Overall, almost 20 percent of model year 2014 vehicles were FFVs. 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 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 focused their FFV production in the truck segment, and truck FFV
production made up 75 percent of all FFV production in the 2014 model year. All of these
manufacturers increased FFV production in the 2014 model year, bringing over 300,000 more
FFVs to market relative to the previous model year, or an increase of about 12 percent. Increases
in FFV production from Fiat Chrysler and General Motors accounted for almost 75 percent of
the overall increase in FFVs from 2013 to 2014. Volkswagen continued to grow FFV production
from very few in the 2012 model year (about 2,000) to more than 65,000 in model year 2014,
and Jaguar Land Rover tripled their offerings in model year 2014.
Table 3-5. Number of FFV Models by Manufacturer, 2012-2014 Model Years
Model
Year
2012
2013
2014
Category
Car
Truck
All
Car
Truck
All
Car
Truck
All
cu
«*•
_£
u
_co
iZ
10
11
21
10
13
23
10
11
21
^
k.
o
LL.
7
23
30
6
23
29
6
21
27
1
19
60
79
18
58
76
11
44
55
•o
CD
•^
3 SJ
f I
-
-
-
4
-
4
6
6
12
01
•o
U
01
5
1
6
7
1
8
7
1
8
c
(0
_(/>
-
4
4
-
4
4
0
4
4
CD
O
o
-
2
2
-
2
2
0
2
2
E
01
00
jg
"o
4
-
4
10
1
11
8
1
9
Total
45
101
146
55
102
157
48
90
138
23
-------
Table 3-6. Production Volume of FFVs by Manufacturer, 2012-2014 Model Years
Model
Year Category
Car
2012 Truck
All
Car
2013 Truck
All
Car
2014 Truck
All
Fiat Chrysler
105,174
453,399
558,573
142,158
431,359
573,517
76,570
650,617
727,187
?
o
u.
174,597
323,563
498,160
209,988
546,695
756,683
259,189
498,245
757,434
5
UJ
396,264
511,183
907,447
374,354
637,576
1,011,930
282,707
801,740
1,084,447
1
Jaguar Land
-
-
-
321
-
321
2,754
32,013
34,767
Mercedes
13,493
8,289
21,782
34,493
22,082
56,575
48,597
12,079
60,676
c
5
VI
Z
-
24,154
24,154
-
13,650
13,650
-
14,809
14,809
|
1
-
31,670
31,670
-
33,203
33,203
-
56,516
56,516
Volkswagen
2,060
-
2,060
30,346
20,799
51,145
39,375
25,666
65,041
Total
691,588
1,352,258
2,043,846
791,660
1,705,364
2,497,024
709,192
2,091,685
2,800,877
Table 3-7 shows the impact of FFVs on each manufacturer's fleet for the 2012-2014 model
years. Fiat Chrysler, Ford, GM, Jaguar Land Rover, Mercedes, and Volkswagen all maximized
the FFV credit in both car and truck fleets in the 2014 model year. In other words, these
manufacturers produced at least enough FFVs to claim the maximum FFV benefit. The overall
impact of FFVs on the fleet as a whole increased slightly from 2013 to 2014 to 9 g/mi.
Table 3-7. Net Credits Accrued from Use of the FFV Incentives (g/mi)
Manufacturer
Fiat Chrysler
Ford
GM
Jaguar Land Rover
Mercedes
Nissan
Toyota
Fleet Total
2012
Cars
13*
9
11*
0
11
0
0
4
Model
Trucks
21*
21*
23*
0
15
15
9
14
Year
All
18
14
16
0
13
4
4
8
2013
Cars
12*
9*
10*
3
12*
0
0
4
Model
Trucks
21*
20*
22*
0
12*
8
8
14
Year
All
17
15
15
1
12
3
4
8
2014
Cars
12*
9*
10*
17*
11*
0
0
5
Model
Trucks
19*
20*
19*
20*
17*
8
15
14
Year
All
17
14
14
20
12
3
6
9
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance data,
Volkswagen's 2014 model year FFV credits are 10 g/mi for cars, 16 g/mi for trucks, and 11 g/mi for the combined fleet.
*Achieved the maximum allowable FFV credit for this fleet.
D. Credits Based on Air Conditioning Systems
The vast majority of 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
24
-------
provide mechanical power to the A/C system (sometimes called "indirect emissions"). The high
global warming potential (GWP) of the current predominant 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 by the engine 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. Seventeen manufacturers used the A/C credit
provisions - either for leakage reductions, efficiency improvements, or both - as part of their
compliance demonstration in the 2014 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 2012-2014 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 2014 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 2012-2014 model years.
25
-------
Table 3-8. Reported Air Conditioning Credits by A/C Credit Type and Model Year
Model
Year
2009
2010
2011
2012
2013
2014
Total
Leakage Credits
Mg
6,240,447
8,323,530
8,867,747
11,123,194
13,235,125
16,594,532
64,384,575
% of Annual
A/C Total
75%
75%
71%
66%
61%
62%
66%
Efficiency
Mg
2,114,612
2,844,066
3,607,832
5,746,946
8,369,102
10,309,246
32,991,804
Credits
% of Annual
A/C Total
25%
25%
29%
34%
39%
38%
34%
Total (Mg)
8,355,059
11,167,596
12,475,579
16,870,140
21,604,227
26,903,778
97,376,379
Table 3-9. Reported Air Conditioning Credits by Manufacturer, 2014 Model Year
Manufacturer
Aston Martin
BMW
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Subaru
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
A/C Leakage
Credits
(Mg)
783
387,463
3,408
4,300,656
3,259,377
3,796,223
626,840
224,140
224,490
227,101
390,814
763,891
-
-
1,765,121
578,993
45,232
16,594,532
A/C Efficiency
Credits
(Mg)
645
311,060
1,746
1,839,994
1,115,851
2,017,104
529,963
354,113
81,610
333,683
404,636
753,995
209,944
19,801
1,829,014
498,716
7,371
10,309,246
Total A/C Credits
(Mg)
1,428
698,523
5,154
6,140,650
4,375,228
5,813,327
1,156,803
578,253
306,100
560,784
795,450
1,517,886
209,944
19,801
3,594,135
1,077,709
52,603
26,903,778
Grams/Mile
Equivalent of
Total A/C
Credits
6
9
11
14
9
10
4
5
21
5
11
6
2
6
8
9
8
8
26
-------
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
Subaru
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
2012
Cars
0
7
10
9
5
8
2
4
5
5
9
2
2
6
7
6
11
5
Model
Trucks
0
11
0
10
8
8
5
7
8
3
11
4
2
0
6
9
12
7
Year
All
0
8
10
10
6
8
3
4
7
5
10
3
2
6
7
7
11
6
2013
Cars
6
8
10
10
7
9
3
5
5
5
9
4
1
6
7
6
10
6
Model
Trucks
0
11
0
11
8
9
5
7
9
8
12
4
2
0
7
10
11
8
Year
All
6
9
10
10
8
9
4
5
8
5
10
4
2
6
7
7
10
7
2014
Cars
6
8
11
13
8
9
3
5
12
5
10
5
1
6
8
8
8
7
Model
Trucks
0
11
0
14
10
11
5
7
22
5
12
6
2
0
7
12
8
10
Year
All
6
9
11
14
9
10
4
5
21
5
11
6
2
6
8
9
8
8
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.35 This score is based on the number,
performance, and technology of the components, fittings, seals, and hoses of the A/C system.36
This score, which is determined in grams per year, is calculated using the procedures specified
by the SAE Surface Vehicle Standard J2727. The score is subsequently converted to a
grams/mile credit value based on the global warming potential (GWP) of the refrigerant, 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, General Motors
and Honda introduced vehicles that further reduced the impacts of A/C system leakage by using
HFO-1234yf, a relatively new low-GWP refrigerant. These two manufacturers were the first to
introduce this refrigerant in U.S. vehicle models (the Cadillac XTS and the Honda Fit EV). HFO-
35 See 40 CFR 86.1867-12.
36 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.
27
-------
1234yf has an extremely low GWP of 4, as compared to a GWP of 1430 for HFC-134a, the
refrigerant currently used throughout most of the industry. The use of HFO-1234yf expanded
considerably in the 2014 model year, from two manufacturers and 42,384 vehicles in the 2013
model year, to five manufacturers and 628,347 vehicles in the 2014 model year (although a large
increase, this is still less than 5 percent of the total 2014 model year production). Fiat Chrysler
accounted for 86 percent of these vehicles, introducing HFO-1234yf across a number of models,
including the 300, Challenger, Charger, Cherokee, Dart, and Ram 1500 trucks. Jaguar Land
Rover achieved the greatest penetration within their fleet, using F£FO-1234yf in approximately
80 percent of Jaguar Land Rover vehicles produced in the 2014 model year. The net impact on
credits is that these manufacturers collectively generated about 1.1 million more Megagrams of
air conditioning leakage credits than they would have generated by using FtFC-134a. Table 3-11
shows the production volume of models using HFO-1234yf for the 2012-2014 model years, by
manufacturer.
Table 3-11. Production of Vehicles Using HFO-1234yf,
2013-2014 Model Years
Manufacturer
Ferrari
Fiat Chrysler
GM
Honda
Jaguar Land Rover
Total
2013
41,913
471
42,384
2014
394
540,098
30,652
599
56,604
628,347
Total
394
540,098
72,565
1,070
56,604
670,731
Fifteen manufacturers reported A/C leakage credits in the 2014 model year, as shown in Table 3-
12. These manufacturers reported more than 16.5 million Mg of A/C leakage credits in 2014,
accounting for more than 40 percent of the total net credits reported for the model year, and
accounting for GHG reductions of about 5 grams/mile across the 2014 vehicle fleet. Table 3-13
shows the leakage credits in grams/mile for the 2012-2014 model years.
28
-------
Table 3-12. Reported Air Conditioning Leakage Credits by Manufacturer and
Fleet, 2014 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
783
256,260
3,408
1,113,855
1,412,435
1,918,074
225,990
199,151
15,850
208,197
251,860
414,968
1,045,084
423,705
20,330
7,509,950
Truck
131,203
3,186,801
1,846,942
1,878,149
400,850
24,989
208,640
18,904
138,954
348,923
720,037
155,288
24,902
9,084,582
Total
783
387,463
3,408
4,300,656
3,259,377
3,796,223
626,840
224,140
224,490
227,101
390,814
763,891
1,765,121
578,993
45,232
16,594,532
Grams/mile
Equivalent of
Total Credits
3
5
8
9
7
7
2
2
15
2
5
3
4
5
7
5
' Some vehicles equipped with systems using HFO-1234yf, a low-GWP refrigerant.
29
-------
Table 3-13. 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
Cars
-
4
6
6
4
6
1
2
3
2
4
0
3
2
6
3
Model
Trucks
-
7
-
8
7
7
2
5
4
2
7
2
3
4
8
5
Year
All
-
5
6
7
6
6
2
2
4
2
5
1
3
2
7
4
2013
Cars
3
4
7
6
5
6
1
2
3
2
4
0
3
3
6
3
Model
Trucks
-
7
-
8
7
7
3
4
5
5
7
2
3
5
7
6
Year
All
3
5
7
7
7
7
2
2
4
2
5
1
3
3
7
4
2014
Cars
3
4
8
9
6
6
1
2
7
2
5
2
4
4
6
4
Model
Trucks
-
7
-
10
8
7
3
3
17
3
7
4
4
7
7
6
Year
All
3
5
8
9
7
7
2
2
15
2
5
3
4
5
7
5
* Some vehicles equipped with systems using HFO-1234yf, a low-GWP refrigerant.
2. Air Conditioning Efficiency Credits
Manufacturers that make improvements in their air conditioning systems to increase efficiency,
thus reducing 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.
Seventeen manufacturers used the provisions that allow credits based on improvements to the
overall efficiency of the A/C system, as shown in Table 3-14. These manufacturers reported a
total of more than 10 million Mg of CO2 A/C efficiency credits in the 2014 model year, making
up about 25 percent of the total net credits reported by the industry and accounting for about 3
30
-------
grams/mile across the 2014 fleet. Table 3-15 shows the efficiency credits in grams/mile for the
2012-2014 model years.
Table 3-14. Reported Air Conditioning Efficiency Credits by Manufacturer and Fleet,
2014 Model Year (Mg)
Manufacturer
Aston Martin
BMW
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Subaru
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
Car
645
231,480
1,746
526,044
518,730
950,133
241,401
320,839
12,478
322,330
293,107
542,001
30,379
19,801
1,284,578
376,957
4,517
5,677,166
Truck
79,580
1,313,950
597,121
1,066,971
288,562
33,274
69,132
11,353
111,529
211,994
179,565
544,436
121,759
2,854
4,632,080
Total
645
311,060
1,746
1,839,994
1,115,851
2,017,104
529,963
354,113
81,610
333,683
404,636
753,995
209,944
19,801
1,829,014
498,716
7,371
10,309,246
Grams/Mile
Equivalent of
Total Credits
3
4
4
4
2
4
2
3
5
3
5
3
2
6
4
4
1
3
31
-------
Table 3-15. Air Conditioning Efficiency Credits (g/mi)
Manufacturer
Aston Martin
BMW
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Subaru
Tesla
Toyota
Volkswagen
Volvo
Fleet Total
2012
Cars
-
3
4
3
0
2
1
2
2
2
5
2
2
6
4
4
4
2
Model
Trucks
-
4
-
2
0
1
3
2
4
1
5
2
2
-
2
5
4
2
Year
All
-
3
4
3
0
2
2
2
4
2
5
2
2
6
3
4
4
2
2013
Cars
3
4
4
3
2
3
1
3
2
2
5
3
1
6
4
4
4
3
Model
Trucks
-
4
-
3
1
2
2
4
4
3
5
2
2
-
3
5
4
2
Year
All
3
4
4
3
1
3
2
3
4
3
5
3
2
6
4
4
4
3
2014
Cars
3
4
4
4
2
3
1
3
5
3
5
3
1
6
5
4
1
3
Model
Trucks
-
4
-
4
2
4
2
4
6
2
5
2
2
-
3
5
1
3
Year
All
3
4
4
4
2
4
2
3
5
3
5
3
2
6
4
4
1
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 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 three
pathways by which a manufacturer may accrue off-cycle CO2 credits. The first is a
predetermined list or "menu" of credit values for specific off-cycle technologies that may be
used beginning in model year 2014.3? This pathway allows manufacturers to use conservative
credit values established by EPA for a wide range of off-cycle technologies, with minimal data
submittal or testing requirements. This pathway was widely used in the 2014 model year. 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.38 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. General Motors is currently the only
37See40CFR86.1869-12(b).
38See40CFR86.1869-12(c).
32
-------
manufacturer to have used this pathway in the 2012-2014 model years. The third and last
pathway allows manufacturers to seek EPA approval to use an alternative methodology for
determining the off-cycle technology CO2 credits.39 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 off-cycle technologies that are on the menu, or to demonstrate reductions that
exceed those available via use of the menu. Several manufacturers have petitioned for and been
granted credits using this pathway, however, no credits have been reported to date from this
pathway, thus they will be included in a subsequent report.40
Table 3-16 shows the total off-cycle technology credits reported by manufacturers in the 2014
model year and the grams/mile impact on their respective fleets. Clearly the technologies
involved are currently implemented to varying degrees across manufacturers, accounting for
anywhere from zero grams/mile (the manufacturers not shown in Table 3-16) to 6.1 grams/mile
for Fiat Chrysler. Off-cycle credits from these 12 manufacturers accounted for a benefit of 2.3
grams/mile across the entire 2014 model year fleet.
Table 3-17 shows the off-cycle credits in grams/mile for the 2012-2014 model years. Although
GM did generate off-cycle credits in the 2012 and 2013 model years, the grams/mile equivalent
of those credits rounds to 0.0, as shown, as is also the case for Subaru in model year 2014.
Table 3-16. Reported Off-Cycle Technology Credits by Manufacturer and Fleet, 2014 Model
Year (Mg)
Manufacturer
BMW
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Subaru
Toyota
Fleet Total
Car
183,103
416,894
501,470
228,888
164,811
59,075
5,315
88,313
143,849
263,734
-
578,927
2,634,379
Truck
113,537
2,361,453
769,099
457,702
239,134
26,111
69,170
3,428
24,232
214,182
1,045
567,623
4,846,716
Grams/Mile Equivalent
Total of Total Credits
296,640
2,778,347
1,270,569
686,590
403,945
85,186
74,485
91,741
168,081
477,916
1,045
1,146,550
7,481,095
3.9
6.1
2.6
1.2
1.3
0.8
5.0
0.9
2.2
1.8
0.0
2.5
2.3
39 See 40 CFR 86.1869-12(d).
40 EPA maintains a web page on which we publish the manufacturers' applications for these credits, the relevant
Federal Register notices, and the EPA decision documents. See http://www3.epa. gov/otaq/regs/ld-
hwY/greenhouse/ld-ghg.htm.
33
-------
Table 3-17. Off-Cycle Technology Credits (g/mi)
Manufacturer
BMW
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Subaru
Toyota
Fleet Total
2012 Model Year
Cars Trucks All
.
-
-
0.0 0.0 0.0
-
-
-
-
-
-
-
-
0.0 0.0 0.0
2013 Model Year
Cars Trucks All
.
-
-
0.0 0.0 0.0
-
-
-
-
-
-
-
-
0.0 0.0 0.0
2014 Model Year
Cars Trucks All
3.2 6.1 3.9
3.3 7.2 6.1
2.0 3.2 2.6
0.8 1.7 1.2
1.0 1.8 1.3
0.6 3.0 0.8
2.2 5.5 5.0
0.9 0.5 0.9
2.6 1.2 2.2
1.4 2.4 1.8
0.0 0.0
2.1 3.3 2.5
1.5 3.4 2.3
1. Off-Cycle Credits Based on the Menu
Starting with 2014 models, manufacturers have a new option for generating GHG credits, in the
form of "default" credit values specified in the regulations (a "menu" of technologies with credit
values, or the calculation method for such values, clearly defined) for certain off-cycle
technologies installed on vehicles. More than 99 percent of 2014 off-cycle credits were generated
via this pathway, as it was the only pathway used by all manufacturers except GM. Thus, except
for GM, the values in the tables below will be identical to the tables above that summarize all
2014 off-cycle credits. Although this will change in future years as manufacturers submit data
for credits from the other pathways, we expect that the menu credit pathway may always be the
largest generator of off-cycle credits. The impact of credits from this pathway on a
manufacturer's fleet is capped at 10 grams/mile, meaning that any single vehicle might
accumulate more than 10 grams/mile, but the cumulative effect on a single manufacturer may not
exceed a credit, or reduction, of more than 10 grams/mile.
Table 3-18 shows the total off-cycle credits based on the menu pathway reported by
manufacturers in the 2014 model year and the grams/mile impact on their respective fleets.
34
-------
Table 3-18. Reported Off-Cycle Technology Credits from the Menu, by
Manufacturer and Fleet, 2014 Model Year (Mg)
Manufacturer
BMW
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Subaru
Toyota
Fleet Total
Car
183,103
416,894
501,470
182,383
164,811
59,075
5,315
88,313
143,849
263,734
578,927
2,587,874
Truck
113,537
2,361,453
769,099
457,702
239,134
26,111
69,170
3,428
24,232
214,182
1,045
567,623
4,846,716
Total
296,640
2,778,347
1,270,569
640,085
403,945
85,186
74,485
91,741
168,081
477,916
1,045
1,146,550
7,434,590
Grams/Mile
Equivalent of
Total Credits
3.9
6.1
2.6
1.1
1.3
0.8
5.0
0.9
2.2
1.8
0.0
2.5
2.3
Tables 3-19 and 3-20 provide details regarding the specific off-cycle technologies, including
how many credits were reported for each technology, and the implementation rate of each off-
cycle technology by manufacturers. Several of these technologies are "thermal control
technologies" in that they reduce the demand on the air conditioning system by venting hot air,
by moving heat away from passengers, or by reducing external heating from the sun. Due to
expected synergistic effects of the thermal technologies, the credits from the group of thermal
control technologies are capped at 3.0 grams/mile for cars and 4.3 grams/mile for trucks. The
per-vehicle grams/mile credit varies between cars and trucks; for example, the credit available
for active seat ventilation is 1 gram/mile for cars and 1.3 grams/mile for trucks. The regulations
clearly define each technology and any requirements that apply for the technology to generate
credits. The definitions may be summarized as follows:
• Active aerodynamics - These technologies are automatically activated to improve the
aerodynamics of a vehicle under certain conditions. These include grill shutters, which
allow air to flow around the vehicle more efficiently, and suspension systems that
improve air flow at higher speeds by reducing the height of the vehicle. Credits are based
on the measured improvement in the coefficient of drag, a test metric that reflects the
efficiency of airflow around a vehicle.
• Thermal control technologies - These systems reduce the air temperature of the vehicle
interior, lowering GHG tailpipe emissions by reducing the fuel demand on the air
conditioning system. Thermal control technologies are subject to a per-vehicle cap on
credits of 3.0 grams/mile for cars and 4.3 grams/mile for trucks.
o Active and passive cabin ventilation -Active systems use mechanical means to
vent the interior, while passive systems rely on convective air flow. Credits
range from 1.7 to 2.8 grams/mile.
35
-------
o Active seat ventilation - These systems move air through the seating surface,
transferring heat away from the vehicle occupants. Credits are 1.0 gram/mile for
cars and 1.3 grams/mile for trucks.
o Glass or glazing - Credits are available for glass or glazing technologies that
reduce the total solar transmittance through the glass, thus reducing the heat from
the sun that reaches the occupants. The credits are calculated based on the
measured solar transmittance through the glass and on the total area of glass on
the vehicle.
o Solar reflective surface coating - Credits are available for solar reflective surface
coating (e.g., paint) that reflects at least 65 percent of the infrared solar energy.
Credits are 0.4 grams/mile for cars and 0.5 grams/mile for trucks.
Active engine and transmission warmup - These systems use heat from the vehicle that
would typically be wasted (exhaust heat, for example) to warm up key elements of the
engine, allowing a faster transition to warm operation. A warmed up engine and/or
transmission consumes less fuel and emits less tailpipe CO2.
o Active engine warmup - Uses waste heat from the engine to warm up the engine.
Credits are 1.5 grams/mile for cars and 3.2 grams/mile for trucks.
o Active transmission warmup - Uses waste heat from the engine to warm up the
transmission. Credits are 1.5 grams/mile for cars and 3.2 grams/mile for trucks.
Engine idle stop-start - These systems allow the engine to turn off when the vehicle is at
a stop (e.g., at a stoplight), automatically restarting the engine when the driver releases
the brake and/or applies pressure to the accelerator. If equipped with a switch to disable
the system, EPA must determine that the predominant operating mode of the system is
the "on" setting (defaulting to "on" every time the key is turned on is one basis for such
a determination). Thus some vehicles with these systems, such as those from BMW, are
not eligible for credits. Credits range from 1.5 to 4.4 grams/mile, and depend on whether
the system is equipped with an additional technology that allows heat, when demanded,
to continue to be circulated to the vehicle occupants when the engine is off during a stop-
start event.
High efficiency exterior lights - These lights reduce the total electric demand, and thus
the fuel consumption and GHG emissions, of the lighting system in comparison to
conventional lighting technologies. Credits are based on the specific lighting locations,
ranging from 0.06 grams/mile for turn signals and parking lights to 0.38 grams/mile for
low beams. The total of all lighting credits may not exceed 1.0 grams/mile.
Solar panels- Vehicles that use batteries for propulsion, such as electric, plug-in hybrid
electric, and hybrid vehicles may receive credits for solar panels that are used to charge
the battery directly or to provide power directly to essential vehicle systems (e.g.,
heating and cooling systems). Credits are based on the rated power of the solar panels.
36
-------
Table 3-19. Off-Cycle Technology Credits from the Menu by Technology, 2014 Model Year
(Mg)*
Off-Cycle Technology
Active Aerodynamics
Grill shutters
Ride height adjustment
Subtotal:
Thermal Control Technologies
Passive cabin ventilation
Active cabin ventilation
Active seat ventilation
Glass or glazing
Solar reflective surface coating
Subtotal:
Engine & Transmission Warmup
Active engine warmup
Active transmission warmup
Subtotal:
Other
Engine idle stop-start
High efficiency exterior lights
Solar panel(s)
Subtotal:
Total
Car
164,456
36
164,492
246,308
98,289
112,383
418,977
60,597
936,554
314,339
673,553
987,892
291,797
207,265
41
499,103
2,588,041
Truck
60,336
9128
69,464
721,833
51,819
209,826
1,798,350
57,310
2,839,138
811,804
939,597
1,751,401
60,982
126,938
-
187,920
4,847,923
Total
224,792
9164
233,956
968,141
150,108
322,209
2,217,327
117,907
3,775,692
1,126,143
1,613,150
2,739,293
352,779
334,203
41
687,023
7,435,964
Grams/Mile
Equivalent of
Total
0.1
0.0
0.1
0.3
0.0
0.1
0.7
0.0
1.2
0.3
0.5
0.9
0.1
0.1
0.0
0.2
2.3
*Credits are not always reported by manufacturers in a format that shows the total credits for each technology as
we show here. For the purposes of this report we have used the data from manufacturers to calculate the credits in
this table.
Table 3-20 shows the percent of each manufacturers' production volume using each of the
"menu" technologies, i.e., the penetration rate of a given technology within a manufacturer's
fleet. The totals of the manufacturer rows are not provided, as they would sum to more than
100% and are not meaningful values, reflecting only that some vehicles are equipped with
multiple off-cycle technologies. The data is not currently collected in a format across all
manufacturers that allows a determination of how many vehicles have at least one off-cycle
technology or how many technologies are on a given vehicle, thus the total would only indicate
how many individual technologies were used to generate credits. However, the implementation
rates are still useful and reveal some interesting things. For example, there was significant
penetration of glass or glazing technology across these manufacturers, with more than half of
them reporting installing this technology on more than 50 percent of their vehicles, and three
manufacturers approaching a 100 percent implementation rate (Fiat Chrysler, Ford, and Jaguar
Land Rover). High efficiency lighting is another technology with high penetration across a
number of manufacturers, with six manufacturers reporting implementation on at least half of
37
-------
their fleet, and Jaguar Land Rover and BMW at or near 100 percent. Traditionally the domain of
hybrid gas-electric vehicles, engine idle stop-start is making inroads across conventional
vehicles, to a significant degree with some manufacturers. Jaguar Land Rover and Mercedes had
the highest proportion of vehicles equipped with engine idle stop-start, with 93 and 65 percent,
respectively. The most "popular" technologies across the manufacturers were high efficiency
lights and active seat ventilation, both of which were employed by 11 of 12 manufacturers,
followed by glass or glazing, used by 9 manufacturers. Although active seat ventilation was used
by many manufacturers, it remains a technology with limited offering, appearing on only about
ten percent of the 2014 model year fleet, with Jaguar Land Rover appearing the outlier with
implementation on more than 60 percent of their vehicles (this is consistent with this technology
being largely limited to luxury brands or models). The most widely used technologies across the
fleet were glass or glazing, appearing on 7.8 million vehicles (more than half of the 2014 fleet),
and high efficiency lighting, which was installed on 6.7 million vehicles, or about 40 percent of
the fleet. Toyota and Fiat Chrysler were the leaders in terms of the number of technologies used
to generate off-cycle credits, each gaining GHG reductions from nine unique technologies
implemented at varying rates across their fleets. Fiat Chrysler used every menu technology
except ride height adjustment, active cabin ventilation, and solar panels, where Toyota used all
but grill shutters, active cabin ventilation, and solar panels.
Table 3-21 shows the grams/mile benefit that each manufacturer accrued from each off-cycle
technology. Like the preceding table, this demonstrates the mix of technologies being used
across the manufacturers and the extent to which each technology benefits each manufacturer's
fleet. Fiat Chrysler, Jaguar Land Rover, and BMW can be singled out as the manufacturers
showing the greatest benefits from off-cycle technologies, from 3.9 to 6.4 grams/mile, while
most of the remaining manufacturers achieved between 1 and 2.5 grams/mile. A closer look
shows different strategies across these manufacturers of varying sizes and product lines. Fiat
Chrysler achieved the manufacturer-leading benefit of 6.1 grams/mile largely through use of
passive cabin ventilation, glass or glazing, and active engine warmup systems, with the
remainder coming from active transmission warmup systems, high-efficiency lights, and active
seat ventilation. Their implementation rate of passive cabin ventilation of almost 100 percent is
notable, as the next highest implementation rate of such systems is Toyota, with an 11.4 percent
use rate of passive cabin ventilation. Fiat Chrysler's penetration rate of glass/glazing and active
engine warmup systems, although high, is in line with that of other manufacturers. BMW was the
only manufacturer using active cabin ventilation, with an 85 percent implementation rate and
accounting for about half of their 3.9 grams/mile total off-cycle credits. BMW was also the
leader in penetration of active engine warmup systems, which accounted for 1.6 grams/mile, and
runner-up in the use of high-efficiency lighting, bringing them another 0.3 grams/mile. Jaguar
Land Rover, which, as noted earlier, has made very large GHG reductions across their fleet since
the start of the program, gained half of their 5.0 grams/mile of off-cycle credits through adoption
of stop-start systems across the vast majority of their product line. No other manufacturer has
approached this penetration rate except Mercedes, with 65 percent of their vehicles using stop-
start systems. Most of BMW's remaining 2.5 grams/mile came from active seat ventilation and
glass/glazing, where in both cases Jaguar Land Rover is the industry leader in implementation.
38
-------
Table 3-20. Percent of 2014 Model Year Vehicle Production Volume with Credits from the Menu, by Manufacturer &
Technology (%)
Active
Aerodynamics
U)
| 1
U) ^™
= D
Manufacturer u '<*
BMW 0.0
Fiat Chrysler 16.4
Ford 38.4
GM 6.7
Honda 0.0
Hyundai 2.1
Jaguar Land Rover 0.0
Kia 1.8
Mercedes 0.0
Nissan 4.6
Subaru 2.0
Toyota 0.0
Fleet Total 9.8
01
c
tn
U)
3
as
0.0
3.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
0.0
c
!i
HI -M
S.a
•« *;
U) C
ra 01
Q. >
0.0
99.3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
11.4
15.0
Thermal
|p
U +•»
01.2
.>'•!=
Cg
< >
85.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
2.1
Control Technologies
SP
U) +•*
01.2
.>'•!=
Cg
< >
2.5
1.8
12.8
13.3
0.9
12.1
62.6
15.8
8.7
4.9
0.0
13.5
9.6
M
_c
N
as
no
^
o
U)
U)
as
13
2.9
99.3
97.2
52.3
0.0
84.4
98.1
76.1
3.9
0.0
0.0
52.9
50.7
>.£
'+-» +•*
ss
^ u
Qi ...
2 2
SJS
•S^
5S
0.0
1.3
12.5
15.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
25.5
8.7
Engine &
Transmission
Warmup
01
_c
01 Q.
Ol 5 O)
> E •£
y (0 y
^ 5 ^
78.5
58.0
9.6
0.0
0.0
0.0
0.0
0.0
0.0
19.5
0.0
9.2
14.2
Q
[/) «
_ Q.
E i
c E
hi
0.0
11.7
16.2
0.0
58.5
16.7
0.0
22.7
0.0
55.7
0.0
53.8
23.2
Other
01
^t
•- as
£«
•|>Q-
M0
LLJ to
0.0
0.0
3.4
6.7
0.0
0.0
93.0
0.6
65.3
0.9
0.0
12.5
5.5
S--3
.2 "M
'u —
it i;
•S.2
^ oi
.SP«
I OJ
98.1
73.3
52.9
28.2
28.2
36.2
100.0
59.5
35.7
50.1
0.0
44.5
43.0
"uT
"3
£
as
a.
^
as
5
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
0.0
0.0
0.0
39
-------
Table 3-21. Off-Cycle Technology Credits from the Menu, by Manufacturer and Technology (g/mi)
Manufacturer
BMW
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mercedes
Nissan
Subaru
Toyota
Fleet Total
Active
Aerodynamics
Grill shutters
Ride height
adjustment
-
0.1 0.0
0.3
0.0
-
0.0
-
0.0
-
0.0
0.0
0.0
0.1 0.0
Thermal Control Technologies
Ol OD
= >.£
•— C 4-> 4->
.Q c •- c +J c UCD
5.1 S.I S.I £8
§s SS ss OM s:g
si Bs Bs a'H *•£
re g Cg Cg "re o ^
Q. > <> <> 13 00 (/>(/>
2.0 0.0 0.0
2.0 - 0.0 1.8 0.0
0.2 1.3 0.1
0.2 0.7 0.1
0.0
0.1 0.3
0.8 1.2
0.2 0.3
0.1 0.1
0.1
-
0.2 - 0.2 0.6 0.1
0.3 0.0 0.1 0.7 0.0
Engine &
Transmission
Warmup
= §
t "i
go. .520.
o> 3 E > <« E
'^ *~ '^ = *~
u ns u re re
< g . — .
= £ ^2.
"5
5 C "= c
gg is a
ft |1 1
LLI u> X 01 tO
0.3
0.0 0.2
0.1 0.1
0.1 0.1
0.1
0.0
2.5 0.5
0.0 0.1
1.7 0.4
0.0 0.2 0.0
-
0.2 0.1
0.1 0.1 0.0
Total
3.9
6.1
2.6
1.2
1.3
0.8
5.0
0.9
2.2
1.8
0.0
2.5
2.3
Note that "0.0" indicates that the manufacturer did implement that technology, but that the overall penetration rate was not high enough to round to 0.1 grams/mile,
whereas a dash indicates no use of a given technology by a manufacturer.
40
-------
2. Off-Cycle Technology Credits Based on 5-Cycle Testing
As was the case in the 2012 and 2013 model years, GM is the only manufacturer to have
requested and been granted off-cycle credits based on 5-cycle testing. These credits are for an
off-cycle 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). The 2014 model year GM vehicles receiving this credit
were the eAssist-equipped Buick LaCrosse, Buick Regal, Chevrolet Malibu, and Chevrolet
Impala, totaling almost 160,000 vehicles. 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 compliance test methods. The off-cycle credits reported by GM in the 2009-2013
model years are shown in Table 3-22. The calculated grams/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 3-22. Reported Off-Cycle Credits Based on 5-Cycle
Testing (Mg)
Model Year
2009
2010
2011
2012
2013
2014
Total
Car
-
-
-
4,984
13,330
46,505
64,819
Truck
3,329
965
1,338
838
819
-
7,289
Total
3,329
965
1,338
5,822
14,149
46,505
72,108
3. Off-Cycle Technology Credits Based on an Alternative Methodology
This third pathway for off-cycle technology credits allows manufacturers to seek EPA approval
to use an alternative methodology for determining the off-cycle technology CO2 credits.41 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
41See40CFR86.1869-12(d).
41
-------
to demonstrate off-cycle CO2 reductions for off-cycle technologies that are on the menu, or to
demonstrate reductions that exceed those available via use of the menu. The regulations require
that EPA seek public comment on and publish each manufacturer's application for credits sought
using this pathway. Several manufacturers have petitioned for and been granted credits using this
pathway.42 However, no credits in this category have yet been reported to EPA, and thus they are
not included in this report. EPA anticipates that these credits will be reported in the 2015 model
year GHG Performance Report.
In the fall of 2013, Mercedes requested off-cycle credits for the following off-cycle 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. EPA approved
methodologies for Mercedes to determine these off-cycle credits in September of 2014.43
Subsequently, Fiat Chrysler, Ford, and GM requested off-cycle credits under this pathway. Fiat
Chrysler and Ford submitted applications for off-cycle credits from high efficiency exterior
lighting, solar reflective glass/glazing, solar reflective paint, and active seat ventilation. Ford's
application also demonstrated off-cycle benefits from active aerodynamic improvements (grill
shutters), active transmission warm-up, active engine warm-up technologies, and engine idle
stop-start. GM's application described the real-world benefits of an air conditioning compressor
with variable crankcase suction valve technology. EPA approved the credits for Fiat Chrysler,
Ford, and GM in September of 2015.44
F. Deficits Based on Methane and Nitrous Oxide Standards
EPA finalized emission standards for methane (CFU) 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 CO2-
42 EPA maintains a web page on which we publish the manufacturers' applications for these credits, the relevant
Federal Register notices, and the EPA decision documents. See http://www3.epa.gov/otaq/regs/ld-
hwv/greenhouse/ld-ghg.htm.
43 "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-
hwv/greenhouse/documents/420rl4025.pdf.
44 "EPA Decision Document: Off-cycle Credits for Fiat Chrysler Automobiles, Ford Motor Company, and General
Motors Corporation," U.S. EPA-420-R-15-014, Office of Transportation and Air Quality, September 2015. See
http://www3.epa.gov/otaq/regs/ld-hwy/greenhouse/documents/420rl5014.pdf.
42
-------
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. Analyses of emissions data have shown that use of this option may add
approximately 3 grams/mile to a manufacturer's fleet average. Four manufacturers chose to use
this approach in the 2014 model year: Lotus, Nissan, Mazda, and Subaru.
The third option for complying with the CH4 and N2O standards was initially limited to the 2012-
2014 model years, but was subsequently expanded to include all model years of the program.
Under this approach, manufacturers can essentially define an alternative, less stringent CH4
and/or N2O standard for any vehicle that may have difficulty meeting the specific standards. This
alternative standard is treated as any other emission standard in that it must be met for the full
useful life of the vehicle. This method provides some additional flexibility relative to the other
two options in that (1) a manufacturer can target specific vehicles for alternative standards
without incurring a fleet-wide impact, and (2) CH4 and N2O are delinked, in that a manufacturer
can meet the default regulatory standard for one and select an alternative standard for the other.
However, the key aspect of this approach is that manufacturers that use it must calculate a deficit
(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 in the 2014 model year, as shown in Table 3-23. 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 2009-2013 or
generated in 2014.
Table 3-23. Reported CH4 and N2O Deficits by Manufacturer and Fleet, 2014 Model Year (Mg)
Manufacturer
BMW
Fiat Chrysler
Ford
GM
Honda
Fleet Total
Car
CH4
4,677
755
14,512
14,061
78,580
N2O
37,167
-
5,272
7,384
224,693
394,897
Truck
CH4
1,365
46,268
44,119
43,744
136,418
N2O
10,847
-
28,579
-
57,925
Total
54,056
47,023
92,482
65,189
224,693
667,820
Grams/Mile
Equivalent of
Total
0.7
0.1
0.2
0.1
0.7
0.2
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance data,
Volkswagen had car deficits of 44,575 and 120,381 Mg for CH4 and N20, respectively, and truck deficits of 922 and 18,499 Mg
for CH4 and N20, respectively, for a total of 184,377 Mg and a fleet impact of 1.6 g/mi.
43
-------
Tables 3-24 and 3-25 show the grams/mile equivalent CH4 and N2O deficits for the 2012-2014
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 CH4 and/or N2O standards.
Table 3-24. CH4 Deficits (g/mi)
Manufacturer
BMW
Fiat Chrysler
Ford
GM
Fleet Total
2012 Model Year
Cars Trucks All
0.0 0.3 0.1
0.1 0.1 0.1
0.1 0.2 0.1
0.1 0.4 0.2
0.1 0.1 0.1
2013 Model Year
Cars Trucks All
0.0 0.1 0.0
0.0 0.0 0.0
0.1 0.2 0.1
0.1 0.4 0.2
0.1 0.1 0.1
2014 Model Year
Cars Trucks All
0.1 0.1 0.1
0.0 0.1 0.1
0.1 0.2 0.1
0.0 0.2 0.1
0.0 0.1 0.1
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance data,
Volkswagen has a CH4 deficit of 0.5 g/mi for cars, 0.0 g/mi for trucks, and 0.4 g/mi for their total fleet.
Table 3-25. N2O Deficits (g/mi)
Manufacturer
BMW
Ford
GM
Honda
Fleet Total
2012 Model Year
Cars Trucks All
0.0 1.1 0.3
0.0 0.9 0.4
0.0 0.0 0.0
0.0 0.0 0.0
0.1 0.2 0.1
2013 Model Year
Cars Trucks All
0.0 0.2 0.1
0.0 0.9 0.5
0.0 0.0 0.0
1.1 0.0 0.7
0.2 0.2 0.2
2014 Model Year
Cars Trucks All
0.6 0.6 0.6
0.0 0.1 0.1
0.0 0.0 0.0
1.3 0.0 0.7
0.2 0.0 0.1
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance data,
Volkswagen has an N20 deficit of 1.3 g/mi for cars, 0.8 g/mi for trucks, and 1.2 g/mi for their total fleet.
G. 2014 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 3-26
summarizes all of these building blocks (described in previous sections) for the 2014 model year
fleet for each manufacturer. The values in Table 3-26 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.45 The final row shows values for the total 2014
45 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.
44
-------
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. For example, Ford's 2-
cycle tailpipe emissions of 315 grams/mile is reduced by applying FFV, A/C, and off-cycle
credits totaling 26 grams/mile, yielding a final compliance value of 289 grams/mile (any
apparent mathematical differences are the result of rounding). Tables 3-27 and 3-28 show the
same information for car and truck fleets, respectively.46 The resulting compliance values can
then be compared to the target values for each fleet to determine whether a manufacturer will
report credits or deficits in the 2014 model year. Again, these values are not regulatory values,
but are calculated from the Megagrams of credits reported by the manufacturers to EPA.
46 Versions of Tables 3-19, 3-20, and 3-21 for the 2012 and 2013 model years are shown in Appendix C.
45
-------
Table 3-26. 2014 Compliance Values - Combined Passenger Car & Light Truck
Fleet (g/mi)
Manufacturer
Aston Martin
BMW
BYD Motors
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Lotus
Mazda
McLaren
Mercedes
Mitsubishi
Nissan
Subaru
Tesla47
Toyota
Volvo
Fleet Total
2-Cycle
Tailpipe
454
270
0
484
346
315
314
259
253
374
269
338
240
372
309
236
263
253
0
274
319
294
Credits (g/mi)
FFV
0
0
0
0
17
14
14
0
0
20
0
0
0
0
12
0
3
0
0
6
0
9
A/C
6
9
0
11
14
9
10
4
5
21
5
0
0
0
11
0
6
2
6
8
8
8
Off-
Cycle
0
4
0
0
6
3
1
1
1
5
1
0
0
0
2
0
2
0
0
3
0
2
CH4&
N2O
Deficit
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Compliance
Value
448
257
0
473
309
289
288
254
247
329
263
338
240
372
284
236
253
251
-6
258
311
274
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance
data, Volkswagen has a 2-cycle tailpipe value of 280 g/mi, an FFV credit of 11 g/mi, an A/C credit of 9 g/mi, a
CH4 and N20 deficit of 2 g/mi, and a compliance value of 261 g/mi.
47 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.
46
-------
Table 3-27. 2014 Compliance Values-Passenger Car Fleet (g/mi)
Manufacturer
Aston Martin
BMW
BYD Motors
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Lotus
Mazda
McLaren
Mercedes
Mitsubishi
Nissan
Subaru
Tesla48
Toyota
Volvo
Fleet Total
2-Cycle
Tailpipe
454
256
0
484
298
256
266
228
247
347
265
338
220
372
285
224
229
250
0
221
288
250
FFV
0
0
0
0
12
9
10
0
0
17
0
0
0
0
11
0
0
0
0
0
0
5
Credits
(g/mi)
Off-
A/C Cycle
6
8
0
11
13
8
9
3
5
12
5
0
0
0
10
0
5
1
6
8
8
7
0
3
0
0
3
2
1
1
1
2
1
0
0
0
3
0
1
0
0
2
0
1
CH4&
N2O
Deficit
0
1
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Compliance
Value
448
245
0
473
270
237
246
226
241
316
259
338
220
372
262
224
222
249
-6
211
280
237
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original
compliance data, Volkswagen has a passenger car 2-cycle tailpipe value of 266 g/mi, an FFV credit of 10 g/mi,
an A/C credit of 8 g/mi, a CFU and IX^O deficit of 2 g/mi, and a compliance value of 249 g/mi.
48 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.
47
-------
Table 3-28. 2014 Compliance Values - Light Truck Fleet (g/mi)
Manufacturer
BMW
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mazda
Mercedes
Mitsubishi
Nissan
Subaru
Toyota
Volvo
Fleet Total
2-Cycle
Tailpipe
312
364
375
369
299
325
379
330
287
372
256
335
254
358
348
349
Credits (g/mi)
FFV
0
19
20
19
0
0
20
0
0
17
0
8
0
15
0
14
A/C
11
14
10
11
5
7
22
5
0
12
0
6
2
7
8
10
Off-
Cycle
6
7
3
2
2
3
6
1
0
1
0
2
0
3
0
3
CH4&
N2O
Deficit
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Compliance
Value
295
324
342
337
292
315
332
325
287
342
256
318
252
333
340
322
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original
compliance data, Volkswagen has a light truck 2-cycle tailpipe value of 336 g/mi, an FFV credit of 16 g/mi, an
A/C credit of 12 g/mi, a CH4 and N20 deficit of 1 g/mi, and a compliance value of 309 g/mi.
Table 3-29 shows the calculated compliance values for each manufacturer's car and truck fleet
for the 2012-2014 model years. As can be seen in the table, the decreases in manufacturer
compliance values from 2013 to 2014 outweighed the increases, leading to a net decrease of 5
grams/mile across the fleet of combined cars and trucks.
48
-------
Table 3-29. 2012-2014 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
Tesla49
Toyota
Volvo
Fleet Total
2012
Cars
270
0
0
484
278
146
248
264
235
239
371
253
241
295
262
256
325
257
267
-6
214
286
249
Model
Trucks
353
353
357
366
315
305
431
321
324
367
283
363
362
296
361
339
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
300
288
2013 Model
Cars
438
263
0
0
465
268
240
254
225
233
337
247
334
232
374
275
254
228
309
254
266
-6
217
282
241
Trucks
335
348
348
364
307
310
405
293
296
347
267
328
363
270
330
332
337
338
Year
All
438
283
0
0
465
316
299
301
254
236
390
249
334
251
374
299
258
260
336
264
273
-6
268
307
279
2014
Cars
448
245
0
473
270
237
246
226
241
316
259
338
220
372
262
224
222
249
-6
211
280
237
Model
Trucks
295
324
342
337
292
315
332
325
287
342
256
318
252
334
340
322
Year
All
448
257
0
473
309
289
288
254
247
329
263
338
240
372
284
236
253
251
-6
258
311
274
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance data,
in the 2014 model year Volkswagen had compliance values of 237, 322, and 274 grams/mile for cars, trucks, and all
vehicles, respectively.
H. 2014 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
49 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.
49
-------
end of each model year, manufacturers calculate unique CO2 standards for each fleet (cars and
trucks) using equations specified in the regulations based on the footprint of their vehicles.50 The
footprint "curves" for the 2012-2014 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
manufacturer's fleet. Trends in the overall average footprint value are thus important because of
the direct impact on the stringency of the GHG standards.
Figure 3-1. 2012-2014 Model Year CO2 Footprint Target Curves
400
380
360
340
320
§ 300
JSS
IN
8 280
260
240
220
2012 Trucks
2013 Trucks
2014 Trucks
2012 Cars
2013 Cars
2014 Cars
200
20 25 30 35 40 45 50 55
Footprint (square feet)
60
65
70
75
80
The calculated CO2 standards for the 2012-2014 model years are shown in Table 3-30.
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, the decreases in the manufacturers'
CO2 standards from 2013 to 2014 outweighed the increases, resulting in an increase in the
overall stringency of the program of about 5 grams/mile.
50 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.
50
-------
Table 3-30. 2012-2014 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
Volvo
Fleet Total
2012
Cars
269
111
246
345
111
315
265
Til
263
269
364
266
259
111
261
263
332
260
251
304
264
111
267
Model
Trucks
336
345
364
369
333
316
388
338
323
360
307
337
422
309
325
342
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
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
264
261
Trucks
324
338
355
360
318
309
362
303
311
354
296
324
410
299
296
329
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
288
292
2014
Cars
324
258
261
324
262
254
254
250
253
335
251
300
251
319
258
236
249
243
288
250
258
253
Model
Trucks
313
327
345
357
308
301
361
312
300
330
287
318
289
326
307
330
Year
All
324
271
261
324
309
299
302
275
257
357
255
300
265
319
278
254
271
279
288
279
283
287
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance data,
in the 2014 model year Volkswagen had C02 standards of 250, 330, and 287 grams/mile for cars, trucks, and all
vehicles, respectively.
*Some or all vehicles subject to temporary less stringent TLAAS standards. See section 3.B.
Overall, the standards decreased by 5 grams/mile from 2013 to 2014, an increase in stringency
driven by the more stringent target curves for the 2014 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 3-30 shows that the standard for Mazda cars increased - got less
stringent - from 2013 to 2014, a phenomenon that is based on an increase of 2 square feet in the
average footprint of Mazda cars in the 2014 model year, as seen in Table 3-31.
51
-------
The average footprint for the overall fleet increased in the 2014 model year by 0.6 square feet, to
49.7 square feet, the highest in the three years of the National Program. The car and truck fleet
footprints increased by 0.2 and 0.3 square feet, respectively, but the overall shift by consumers
towards trucks contributed substantially to the 0.6 square foot increase of the entire 2014 fleet.
Of the 22 manufacturers in the program in 2013 and 2014, fleet average footprint increased for
13, decreased for 3, and was unchanged for 6. Increases in footprint ranged from 0.3 square feet
(Ferrari, Volvo) to 2.7 square feet (Jaguar Land Rover). Ford, Mitsubishi, and Subaru defied the
industry trend and demonstrated decreases in footprint in their 2014 fleets. Note that an increase
in the overall fleet footprint does not necessarily indicate that manufacturers built larger vehicles
in 2014; because the footprint is weighted by production volume, an increase could also occur
with no change to the vehicles 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 more
likely, a mix of both factors.
52
-------
Table 3-31. Average Footprint by Manufacturer and Fleet (square feet)
2012
Manufacturer Cars
Aston Martin
BMW 45.9
BYD Motors 47.9
Coda 41.5
Ferrari 47.8
Fiat Chrysler 47.2
Fisker 58.1
Ford 45.3
GM 46.9
Honda 45.0
Hyundai 46.4
Jaguar Land Rover 51.0
Kia 45.6
Lotus
Mazda 43.9
McLaren
Mercedes 46.5
Mitsubishi 44.5
Nissan 45.0
Porsche 44.7
Subaru 44.3
Suzuki 42.1
Tesla 53.6
Toyota 45.0
Volkswagen 45.0
Volvo 46.8
Fleet Total 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
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
Model
Trucks
5 0.8
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
2014
Cars
47.5
47.1
47.9
47.4
48.0
46.4
46.3
45.6
46.1
49.3
45.8
43.5
45.6
46.6
46.6
41.5
45.4
44.1
53.6
45.6
45.5
47.2
46.1
Model
Trucks
50.4
54.1
59.4
62.6
49.2
47.5
52.0
50.0
47.2
51.4
44.0
51.6
44.4
54.1
50.0
48.9
55.0
Year
All
47.5
47.8
47.9
47.4
52.2
52.4
53.2
47.0
46.2
51.5
46.1
43.5
46.0
46.6
47.8
42.3
47.2
44.3
53.6
48.6
46.3
48.0
49.7
Change
Cars
2.3
0.9
0
0.3
0.4
-0.6
-0.2
0.7
0
-1.5
0.3
0
2
0
1.2
-2.1
-0.4
0.1
0
0.5
0.3
0.4
0.2
: 2013 to
Trucks
-0.4
-0.4
-0.1
2.2
-0.1
0.5
3.8
4.4
-0.4
-0.1
0.1
0.8
-0.2
1.6
1
-0.1
0.3
2014
All
2.3
0.4
0
0.3
0.7
-1
1.3
0.7
0
2.7
0.6
0
1.3
0
0.5
-1.4
0
-0.1
0
0.5
0.7
0.3
0.6
53
-------
I. Overall Compliance Summary
Final compliance for the 2012-2014 model years is summarized in Table 3-32 for the overall
model year fleet, and separately for cars and trucks in Tables 3-33 and 3-34, respectively. As in
the tables in Section 3.G, these show how the 2-cycle tailpipe values and the credits are used to
"build" the overall compliance value, which is then compared to the model year standards
described in Section 3.H. The tables also show, in the final column, the value achieved by
subtracting the compliance value from the standard, which, for the 2012-2014 model years is a
positive value, indicating over-compliance with the standards. Overall, manufacturers
outperformed the 2014 standard by 13 grams/mile.51 In both the 2012 and 2013 model years, the
industry's over-compliance was almost entirely driven by the compliance margin seen in the car
fleet, since the truck compliance values essentially equaled the overall fleet standards. This was
not true for the 2014 model year, where the truck fleet achieved a compliance margin relative to
the truck standard of 8 grams/mile, thus contributing to the overall fleet compliance margin.
Table 3-32. Compliance & Credit Summary, 2012-2014 Model Years - Combined Cars and
Trucks (g/mi)*
Model
Year
2012
2013
2014
2-Cycle
Tailpipe
302
294
294
Credits
FFV
8.1
7.8
8.9
A/C
6.1
6.9
8.3
Off-
Cycle
0.0
0.0
2.3
CH4&N2O
Deficit
0.2
0.3
0.2
Compliance
Value
288
279
274
Standard
299
292
287
Standard -
Compliance
11
12
13
*Values stated in this table and in the text are correct, although rounding of values may result in some
apparent differences.
Table 3-33. Compliance & Credit Summary, 2012-2014 Model Years - Passenger Cars
(g/mi)*
Model
Year
2012
2013
2014
2-Cycle
Tailpipe
259
251
250
Credits
FFV
4.0
4.0
4.6
A/C
5.3
6.2
7.3
Off-
Cycle
0.0
0.0
1.5
CH4&N2O
Deficit
0.1
0.3
0.3
Compliance
Value
249
241
237
Standard
267
261
253
Standard -
Compliance
17
20
16
*Values stated in this table and in the text are correct, although rounding of values may result in some
apparent differences.
51 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 values is in fact 12
grams/mile, although the rounded values in the table produce a difference of 13 grams/mile.
54
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Table 3-34. Compliance & Credit Summary, 2012-2014 Model Years - Light Trucks (g/mi)*
Model
Year
2012
2013
2014
2-Cycle
Tailpipe
369
360
349
Credits
FFV
14.5
13.7
14.3
A/C
7.2
7.9
9.6
Off-
Cycle
0.0
0.0
3.4
CH4&N2O
Deficit
0.3
0.3
0.1
Compliance
Value
348
338
322
Standard
348
339
330
Standard -
Compliance
1
1
8
*Values stated in this table and in the text are correct, although rounding of values may result in some
apparent differences.
A comparison between compliance values and standards for each manufacturer and fleet is
shown in Table 3-35. The final row shows values for the total 2014 fleet. The comparison of the
compliance and standards in Table 3-35, shown in the "Net Compliance" columns, indicates
whether a manufacturer generated net credits or deficits in the 2014 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. Kia, for example, generated a 2014 model year
deficit because their overall compliance value of 263 grams/mile is above their fleet-wide target
of 255 grams/mile. Ford, on the other hand, reported net credits based on a compliance value of
289 grams/mile, 10 grams/mile lower than their fleet-wide standard of 299 grams/mile. Note,
however, that the generation of a net deficit in the 2014 model by any manufacturer does not
necessarily indicate that the manufacturer has failed to comply with the 2014 model year
standards. Kia, for example, will offset their 2014 deficit by using credits generated in previous
model years, thereby complying with the 2014 standards.52 The final row of Table 3-35 shows
the conclusion that manufacturers over-complied with the 2014 model year standards by 13
grams/mile. A comparison of the values in the three previous tables to EPA projections for these
values is in Appendix A.
52 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.
55
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Table 3-35. 2014 Model Year Compliance Summary by Manufacturer and Fleet (g/mi)
Manufacturer
Aston Martin
BMW
BYD Motors
Ferrari
Fiat Chrysler
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Lotus
Mazda
McLaren
Mercedes
Mitsubishi
Nissan
Subaru
Tesla
Toyota
Volvo
Fleet Total
Compliance Value
Cars
448
245
0
473
270
237
246
226
241
316
259
338
220
372
262
224
222
249
-6
211
280
237
Trucks
0
295
0
0
324
342
337
292
315
332
325
0
287
0
342
256
318
252
0
333
340
322
All
448
257
0
473
309
289
288
254
247
329
263
338
240
372
284
236
253
251
-6
258
311
274
Standard
Cars
324
258
261
324
262
254
254
250
253
335
251
300
251
319
258
236
249
243
288
250
258
253
Trucks
0
313
0
0
327
345
357
308
301
361
312
0
300
0
330
287
318
289
0
326
307
330
All
324
271
261
324
309
299
302
275
257
357
255
300
265
319
278
254
271
279
288
279
283
287
Net
Cars
124
-13
-261
149
8
-17
-8
-24
-12
-19
8
38
-31
53
3
-12
-27
6
-294
-39
22
-16
Compliance
Trucks
0
-18
0
0
-3
-3
-20
-16
14
-30
13
0
-13
0
11
-31
0
-37
0
7
33
-8
All
124
-14
-261
149
0
-10
-14
-21
-10
-28
8
38
-26
53
5
-19
-18
-28
-294
-22
28
-13
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance data,
in the 2014 model year Volkswagen had net compliance values of -1, -2, and -1 grams/mile for cars, trucks, and all
vehicles, respectively.
56
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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 recently
there has been almost no credit trading activity between companies. The use of trading
provisions in EPA's light-duty GHG program is a historic development, and one that EPA
welcomes because we believe it will allow greater GHG reductions, lower compliance costs, and
greater consumer choice.
The credit transactions reported by manufacturers through the 2014 model year are shown in
Table 4-1.53 As of the close of the 2014 model year, almost 10 million Megagrams of CO2
credits had changed hands, almost a four-fold increase relative to the volume previously
reported. Toyota was a new entrant in the credit transfer market, although the credit recipients
remain the same as previously reported. 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
53 Manufacturers do not report transactions to EPA as they occur. Thus there may be additional credit transactions
that have occurred that are not reported here, but because of the timing of those transactions (after the manufacturers
submitted their 2014 model year data) those transactions will be reported in the 2015 model year reports of the
manufacturers involved, and thus will be included in EPA's performance report regarding the 2015 model year.
57
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traded in MY 2021 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 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 2014 Model Year (Mg)
Credits
Disbursed
•o
~ £
1 1
"*
Manufacturer
Honda
Nissan
Tesla
Toyota
Ferrari
Fiat Chrysler
Mercedes
2010
(3,609,383)
(200,000)
(35,580)
(2,507,000)
265,000
5,651,383
435,580
Model
2011
(1,000,000)
(14,192)
-
500,000
514,192
Year
"Vintage"
2012 2013 2014
(250
(177
,000)
,941) (1,048,689) (1,019,602)
.
-
1,048,689 1,019,602
427,941
Total
(3,609,383)
(1,450,000)
(2,296,004)
(2,507,000)
265,000
8,219,674
1,377,713
58
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5. COMPLIANCE STATUS AFTER THE 2014 MODEL YEAR
Based on the information reported to EPA, the vast majority of manufacturers have successfully
demonstrated compliance with the 2012-2014 model year standards and are carrying a positive
credit balance into the 2015 model year. The manufacturers that report compliance with all
model years represent more than 99 percent of all cars and light trucks produced for U.S. sale in
these first three model years of EPA's GHG standards. Table 5-1 shows one view of the
accumulated credits for each manufacturer. Each manufacturer reporting a positive balance in the
final column is, by definition, in compliance with the 2012-2014 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 2009-2014 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 265,000 Mg of
2010 credits (we know the vintage from Section 4). These credits were more than sufficient to
offset their total accumulated deficits from the 2012-2014 model years, leaving them with credits
remaining (from the 2010 model year). Because Ferrari generated deficits in the 2012-2014
model years that they subsequently erased with purchased credits, Ferrari has complied with the
2012-2014 standards.
59
-------
Table 5-1. Cumulative Credit Status After the 2014 Model Year (Mg)
Manufacturer
Toyota
Honda
GM
Ford
Hyundai
Nissan
Fiat Chrysler
Subaru
Kia
Mazda
BMW
Mitsubishi
Suzuki
Mercedes
Ferrari
Volvo
Fisker
Coda
BYD Motors
Tesla
Lotus
McLaren
Aston Martin
Jaguar Land
Rover
Fleet Total
Early Credits (2009-2011)
Bought,
Sold, or
Earned Expired
80,435,498 (32,030,399)
35,855,532 (17,742,736)
24,564,829 (6,473,623)
16,075,888 (5,882,011)
14,007,495 (4,476,176)
18,131,200 (9,390,124)
9,110,207 6,151,383
5,755,171 (491,789)
10,444,192 (2,282,680)
5,482,642 (1,390,883)
1,004,292 0
1,449,336 (583,146)
876,650 (265,311)
378,272 949,772
0 265,000
730,187 0
0 0
0 0
0 0
49,772 (49,772)
0 0
0 0
3,332 0
0 0
230,795,900 (74,843,471)
2012
Bought or
Earned Sold
13,163,009 0
7,789,618 0
2,872,354 0
4,641,001 0
3,535,510 0
(729,937) (250,000)
(1,892,184) 0
646,317 0
1,303,379 0
734,887 0
(287,861) 0
57,837 0
(127,699) 0
(748,793) 427,941
(40,983) 0
(175,195) 0
46,694 0
5,524 0
595 0
178,517 (177,941)
0 0
0 0
0 0
(424,032) 0
30,046,063 0
2013
Bought,
Sold, or
Earned Forfeited
9,885,788 0
7,089,732 0
1,748,357 0
7,829,549 0
5,777,836 (169,775)*
5,190,521 0
(1,631,285) 1,048,689
1,444,372 0
1,330,236 (123,956)*
786,431 0
(259,619) 0
58,209 0
(55,398) 0
(377,880) 0
(49,670) 0
(297,006) 0
0 0
1,727 0
1,681 0
1,049,384 (1,048,689)
(763) 0
(3,620) 0
(8,315) 0
(503,111) 0
38,858,207 (293,731)
2014
Bought or
Earned Sold
9,817,927 0
6,240,864 0
7,668,105 0
4,844,627 0
1,052,474 0
4,859,073 0
(46,836) 1,019,602
2,882,640 0
(852,095) 0
1,547,009 0
1,075,752 0
351,031 0
0 0
(401,140) 0
(66,734) 0
(183,695) 0
0 0
0 0
2,548 0
1,020,296 (1,019,602)
(2,078) 0
(2,887) 0
(30,861) 0
417,398 0
40,305,646 0
Total Carried
Forward to
2015
81,271,823
39,233,010
30,380,022
27,509,054
19,727,364
17,810,733
13,759,576
10,236,711
9,819,076
7,160,086
1,532,564
1,333,267
428,242
228,172
107,613
74,291
46,694
7,251
4,824
1,965
(2,841)
(6,507)
(35,844)
(509,745)
264,868,614
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance data, Volkswagen earned 112,228 Mg of credits in
model year 2014 and will carry 4,751,213 Mg into model year 2015.
*Forfeited per the requirements of a federal Consent Decree.
60
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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.54 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 0
Here, the manufacturer
would have 1000 Mg of
2012 credits
^000)
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)
Cars 1500
Trucks -500
Here, the
manufacturer would
have 1000 Mg of 2013
Total 1000 1000
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
54 Note that the regulations require that all credits and deficits within a vehicle class (passenger cars or light trucks)
be aggregated before transfers between vehicle classes may occur. See 40 CFR 86.1865-12(k)(5).
61
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model year credits in EPA's GHG program is fixed at the 2021 model year, meaning that for the
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 reported by the manufacturer. The model year column
headings represent the vintages that make up the total credits (or deficit) being carried forward
into the 2015 model year. This table shows, for example, the extent to which some manufacturers
have used credits from prior model years. Volvo, for example, reported generating about 730,000
early credits (see Table 2-1). They have used all the 2009 and 2010 credits and most of the 2011
credits to offset deficits in the 2012-2014 model years, and thus carrying a positive balance into
the 2015 model year. There are four manufacturers - Lotus, McLaren, Aston Martin, and Jaguar
Land Rover - carrying a deficit into the 2015 model year, meaning that they have not yet
established compliance in all previous model years. Lotus and McLaren have deficits from both
the 2013 and 2014 model years to resolve, while Aston Martin used early credits to comply with
their 2013 standard and thus is only in deficit for the 2014 model year. Jaguar Land Rover
generated credits in the 2014 model year, which were used to offset deficits from early model
years, although not entirely, as shown by the deficit remaining from 2013. A deficit may be
carried forward for three years after the year in which it is generated, meaning that deficits from
the 2013 model year must be reconciled by 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).
62
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Table 5-2. Credits Available After the 2014 Model Year, Reflecting Trades & Transfers
(Mg)
Manufacturer
Toyota
Honda
GM
Ford
Hyundai
Nissan
Kia
Subaru
Fiat Chrysler
Mazda
Mitsubishi
Suzuki
BMW
Volvo
Mercedes
Fisker
Coda
BYD Motors
Tesla
Ferrari
Lotus
McLaren
Aston Martin
Jaguar Land Rover
Fleet Total
2010
31,950,797
10,573,046
11,073,134
7,416,966
5,388,593
5,581,739
2,651,872
2,225,296
7,832,726
3,201,708
521,776
329,382
141,255
0
0
0
0
0
0
107,613
0
0
0
0
91,807,566
2011
14,651,963
7,539,750
6,184,049
2,776,911
4,012,969
852,749
4,657,545
2,876,413
2,605,453
875,213
302,394
98,860
315,557
74,291
0
0
0
0
0
0
0
0
0
0
49,352,549
2012
13,163,009
7,789,618
2,872,354
4,641,001
3,535,510
989,226
1,303,379
646,317
0
749,725
67,976
0
0
0
141,497
46,694
5,524
595
576
0
0
0
0
0
36,027,077
2013
10,552,864
7,089,732
2,582,380
7,829,549
5,613,813
5,510,993
1,206,280
1,487,331
1,366,157
786,431
90,090
0
0
0
25,755
0
1,727
1,681
695
0
(763)
(3,620)
(4,983)
(509,745)
43,851,181
2014
10,953,190
6,240,864
7,668,105
4,844,627
1,176,479
4,876,026
0
3,001,354
1,955,240
1,547,009
351,031
0
1,075,752
0
60,920
0
0
2,548
694
0
(2,078)
(2,887)
(30,861)
0
43,830,241
Total Carried
Forward to
2015
81,271,823
39,233,010
30,380,022
27,509,054
19,727,364
17,810,733
9,819,076
10,236,711
13,759,576
7,160,086
1,333,267
428,242
1,532,564
74,291
228,172
46,694
7,251
4,824
1,965
107,613
(2,841)
(6,507)
(35,844)
(509,745)
264,868,614
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance
data, Volkswagen will carry 4,751,213 Mg into model year 2015.
63
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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.55 56 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 290 grams/mile in the 2014 model year, reducing that by
total credits and incentives of about 14 grams/mile, thus yielding a net compliance value of 276
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.
55 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.
56 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.
64
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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 the 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
Standard
295
286
276
263
250
243
234
223
214
200
190
181
172
163
65
-------
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
Standard
263
256
247
236
225
213
203
193
183
173
164
157
150
143
Trucks
Standard
346
337
326
312
298
295
287
278
270
250
238
226
214
204
66
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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 2012-2014 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 Chapter 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 gap grew further in the 2014 model year, to 8
grams/mile, likely because industry-wide footprint values and the truck fraction of the fleet are
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 have been consistently lower than
projected in the 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, and 5 grams/mile lower in the 2014 model year. 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. Although this gap
shrunk in 2014 to 5 grams/mile, this means that, other things being equal (such as new vehicle
sales and VMT), the aggregate CO2 emissions reductions from the first three 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 three years, and is earning credits that are
being banked for possible future use.
67
-------
Tables A-5 and A-6 provide comparative data separately for cars and trucks for the 2012-2014
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 (10 grams/mile in 2014). 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 in the 2012 and 2013 model years and lower than projected in the 2014 model year.
68
-------
Table A-4. Actual and Projected COz Values, Cars and Trucks Combined (g/mi)
Model
Year
2012
2013
2014
ACTUAL
2-Cycle
Tailpipe
298
290
290
FFV A/C
Credit Credit
7.8 6.0
7.5 6.8
8.6 8.3
TLAAS
Credit
0.6
0.6
0.3
Off- N2O &
Cycle CH4
Credit Deficit
0.0 0.2
0.0 0.3
2.3 0.2
Compliance
284
276
271
Target
296
289
284
PROJECTED
2-Cycle
Tailpipe
307
298
290
FFV A/C
Credit Credit
6.5 3.5
5.8 5.0
5.0 7.5
TLAAS
Credit
1.2
0.9
0.6
Off- N2O &
Cycle CH4
Credit Deficit
0.0 N/A
0.0 N/A
0.0 N/A
Compliance Target
295 295
286 286
276 276
Table A-5. Actual and Projected COz Values, Passenger Cars (g/mi)
Model
Year
2012
2013
2014
ACTUAL
2-Cycle
Tailpipe
259
251
250
FFV A/C
Credit Credit
4.0 5.3
4.0 6.2
4.6 7.3
TLAAS
Credit
0.3
0.2
0.2
Off- N2O &
Cycle CH4
Credit Deficit
0.0 0.1
0.0 0.3
1.5 0.3
Compliance
249
241
237
Target
267
261
253
PROJECTED
2-Cycle
Tailpipe
N/A
N/A
N/A
FFV A/C
Credit Credit
N/A N/A
N/A N/A
N/A N/A
TLAAS
Credit
N/A
N/A
N/A
Off- N2O &
Cycle CH4
Credit Deficit
0.0 N/A
0.0 N/A
0.0 N/A
Compliance Target
263 263
256 256
247 247
Table A-6. Actual and Projected COz Values, Light Trucks (g/mi]
Model
Year
2012
2013
2014
ACTUAL
2-Cycle
Tailpipe
369
360
349
FFV A/C
Credit Credit
14.5 7.2
13.7 7.9
14.3 9.6
TLAAS
Credit
1.2
1.2
0.6
Off- N2O &
Cycle CH4
Credit Deficit
0.0 0.3
0.0 0.3
3.4 0.1
Compliance
348
338
322
Target
348
339
330
PROJECTED
2-Cycle
Tailpipe
N/A
N/A
N/A
FFV A/C
Credit Credit
N/A N/A
N/A N/A
N/A N/A
TLAAS
Credit
N/A
N/A
N/A
Off- N2O &
Cycle CH4
Credit Deficit
0.0 N/A
0.0 N/A
0.0 N/A
Compliance Target
346 346
337 337
326 326
69
-------
APPENDIX B: VEHICLE PRODUCTION VOLUME & MARKET SHARE
Table B-l. Vehicle Production Volume by Manufacturer and Vehicle Category
Manufacturer
Aston MartinA
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Fisker
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
LotusA
Mazda
McLaren*
Mercedes
Mitsubishi
Nissan
Porsche8
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
All
Model Year 2012
Car
191,154
11
115
1,510
538,887
1,415
1,052,721
1,449,244
1,047,165
580,904
12,769
443,751
213,308
173,832
51,927
896,278
16,946
106,152
25,266
2,952
1,298,021
500,690
52,375
8,657,393
Truck
65,856
-
-
-
994,996
-
701,602
915,130
493,414
46,097
41,792
49,250
65,696
81,573
12,540
331,886
12,927
163,860
5,997
-
722,227
64,882
19,432
4,789,157
All
257,010
11
115
1,510
1,533,883
1,415
1,754,323
2,364,374
1,540,579
627,001
54,561
493,001
279,004
255,405
64,467
1,228,164
29,873
270,012
31,263
2,952
2,020,248
565,572
71,807
13,446,550
Model Year 2013
Car
364
303,319
32
37
1,902
654,845
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
-
98,969
-
-
-
852,653
1,234,018
913,765
472,569
38,073
47,532
16,980
-
61,093
-
89,041
13,754
372,970
19,461
211,326
1,116
-
915,658
68,414
31,282
5,458,674
All
364
402,288
32
37
1,902
1,507,498
2,400,993
2,345,896
1,494,369
1,100,023
63,583
628,394
170
225,955
412
296,998
46,408
1,292,617
41,482
357,031
11,543
17,813
2,263,094
627,862
73,354
15,200,118
Model Year 2014
Car
1,272
297,388
50
2,301
648,377
1,258,732
1,556,701
868,337
509,920
12,323
507,630
280
217,333
279
278,126
60,679
935,995
109,078
17,791
1,420,641
487,086
16,526
9,206,845
Truck
-
81,938
-
-
1,446,365
1,075,502
1,164,610
577,828
38,441
55,233
28,757
-
78,826
-
92,312
29,828
389,639
356,818
-
772,809
103,524
15,063
6,307,493
All
1,272
379,326
50
2,301
2,094,742
2,334,234
2,721,311
1,446,165
548,361
67,556
536,387
280
296,159
279
370,438
90,507
1,325,634
465,896
17,791
2,193,450
590,610
31,589
15,514,338
A Exempt from compliance with 2012 model year standards.
B Aggregated with Volkswagen starting with the 2014 model year.
70
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Table B-2. Vehicle Category Market Share by Manufacturer and Model Year (%]
Manufacturer
Aston MartinA
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Fisker
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
LotusA
Mazda
McLarenA
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla
Toyota
Volkswagen
Volvo
All
2012
Car%
74%
100%
100%
100%
35%
100%
60%
61%
68%
93%
23%
90%
76%
68%
81%
73%
57%
39%
81%
100%
64%
89%
73%
64%
Truck %
26%
0%
0%
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%
100%
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%
0%
0%
57%
51%
39%
32%
3%
75%
3%
0%
27%
0%
30%
30%
29%
47%
59%
10%
0%
40%
11%
43%
36%
2014
Car%
100%
78%
100%
100%
31%
54%
57%
60%
93%
18%
95%
100%
73%
100%
75%
67%
71%
23%
100%
65%
82%
52%
59%
Truck %
0%
22%
0%
0%
69%
46%
43%
40%
7%
82%
5%
0%
27%
0%
25%
33%
29%
77%
0%
35%
18%
48%
41%
1 Exempt from compliance with 2012 model year standards.
71
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APPENDIX C: 2012-2013 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
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mazda
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla
Toyota
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
311
302
Credits (g/mi)
FFV
0
0
0
0
18
0
14
16
0
0
0
0
0
13
0
4
0
0
0
0
4
0
8
A/C
8
0
0
10
10
0
6
8
3
4
7
5
0
10
0
3
0
2
0
6
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
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
Compliance
Value
294
0
0
484
329
146
295
307
263
244
419
261
263
320
267
288
342
280
287
-6
263
300
288
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance
data, Volkswagen has a 2-cycle tailpipe value of 281 g/mi, an FFV credit of 1 g/mi, an A/C credit of 7 g/mi, a CFU
and IX^O deficit of 2 g/mi, and a compliance value of 276 g/mi.
72
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Table C-2. 2012 Compliance Values-Passenger Car Fleet (g/mi)
Manufacturer
BMW
BYD Motors
Coda
Ferrari
Fiat Chrysler
Fisker
Ford
GM
Honda
Hyundai
Jaguar Land Rover
Kia
Mazda
Mercedes
Mitsubishi
Nissan
Porsche
Subaru
Suzuki
Tesla
Toyota
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
297
259
FFV
0
0
0
0
13
0
9
11
0
0
0
0
0
11
0
0
0
0
0
0
0
0
4
Credits
(g/mi)
Off-
A/C Cycle
7
0
0
10
9
0
5
8
2
4
5
5
0
9
0
2
0
2
0
6
7
11
5
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
Compliance
Value
270
0
0
484
278
146
248
264
235
239
371
253
241
295
262
256
325
255
267
-6
214
286
249
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original
compliance data, Volkswagen has a passenger car 2-cycle tailpipe value of 274 g/mi, an FFV credit of 1 g/mi, an
A/C credit of 6 g/mi, a CH4 and N20 deficit of 2 g/mi, and a compliance value of 269 g/mi.
73
-------
Table C-3. 2012 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
Volvo
Fleet Total
2-Cycle
Tailpipe
363
384
385
397
320
312
439
324
324
393
283
382
362
296
361
354
343
369
Credits (g/mi)
FFV
0
21
21
23
0
0
0
0
0
15
0
15
0
0
0
9
0
14
A/C
11
10
8
8
5
7
8
3
0
11
0
4
0
2
0
6
12
7
Off-
Cycle
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
CH4&
N2O
Deficit
1
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Compliance
Value
353
353
357
366
315
305
431
321
324
367
283
363
362
294
361
339
331
348
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original
compliance data, Volkswagen has a light truck 2-cycle tailpipe value of 330 g/mi, an FFV credit of 0 g/mi, an
A/C credit of 9 g/mi, a CH4 and N20 deficit of 1 g/mi, and a compliance value of 322 g/mi.
74
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Table C-4. 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
Tesla
Toyota
Volvo
Fleet Total
2-Cycle
Tailpipe
444
292
0
0
475
344
321
325
257
241
399
254
334
251
374
321
258
266
336
264
273
0
278
318
294
Credits (g/mi)
FFV
0
0
0
0
0
17
15
15
0
0
1
0
0
0
0
12
0
3
0
0
0
0
4
0
8
A/C
6
9
0
0
10
10
8
9
4
5
8
5
0
0
0
10
0
4
0
2
0
6
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
CH4&
N2O
Deficit
0
0
0
0
0
0
1
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Compliance
Value
438
283
0
0
465
316
299
301
254
236
390
249
334
251
374
299
258
260
336
262
273
-6
268
307
279
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance
data, Volkswagen has a 2-cycle tailpipe value of 279 g/mi, an FFV credit of 8 g/mi, an A/C credit of 7 g/mi, a CH4
and IX^O deficit of 2 g/mi, and a compliance value of 266 g/mi.
75
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Table C-5. 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
Tesla
Toyota
Volvo
Fleet Total
2-Cycle
Tailpipe
444
271
0
0
475
289
256
273
228
238
345
252
334
232
374
296
254
232
309
254
266
0
224
292
251
Credits (g/mi)
FFV
0
0
0
0
0
12
9
10
0
0
3
0
0
0
0
12
0
0
0
0
0
0
0
0
4
A/C
6
8
0
0
10
10
7
9
3
5
5
5
0
0
0
9
0
4
0
1
0
6
7
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
0
CH4&N2O
Deficit
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Compliance
Value
438
263
0
0
465
268
240
254
226
233
337
247
334
232
374
275
254
228
309
253
266
-6
217
282
241
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original compliance data,
Volkswagen has a passenger car 2-cycle tailpipe value of 272 g/mi, an FFV credit of 7 g/mi, an A/C credit of 6 g/mi, a CFU and
IX^O deficit of 2 g/mi, and a compliance value of 260 g/mi.
76
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Table C-6. 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
Volvo
Fleet Total
2-Cycle
Tailpipe
346
380
375
395
312
317
414
301
296
371
267
340
363
270
330
347
348
360
Credits (g/mi)
FFV
0
21
20
22
0
0
0
0
0
12
0
8
0
0
0
8
0
14
A/C
11
11
8
9
5
7
9
8
0
12
0
4
0
2
0
7
11
8
Off-
Cycle
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
CH4&
N2O
Deficit
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Compliance
Value
335
348
348
364
307
310
405
293
296
347
267
328
363
268
330
332
337
338
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the original
compliance data, Volkswagen has a light truck 2-cycle tailpipe value of 327 g/mi, an FFV credit of 15 g/mi, an
A/C credit of 10 g/mi, a CH4 and N20 deficit of 1 g/mi, and a compliance value of 302 g/mi.
77
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APPENDIX D: 2014 MODEL YEAR REPORT CREDITS AND
DEFICITS
Table D-l. 2014 Model Year Reported Credits and Deficits
Fleet Fleet
Average Standard
Manufacturer Pathway Fleet Credit Type (g/mi) (g/mi)
Aston Martin TLAAS Car Fleet Average 454 324
A/C Leakage
A/C Efficiency
BMW Primary Truck Fleet Average 312 313
A/C Leakage
A/C Efficiency
Off-Cycle
N2O Deficit
CH4 Deficit
Car Fleet Average 256 258
A/C Leakage
A/C Efficiency
Off-Cycle
N2O Deficit
CH4 Deficit
Advanced
Technology
BYD Motors Primary Car Fleet Average 0 261
Advanced
Technology
Ferrari TLAAS Car Fleet Average 484 324
A/C Leakage
A/C Efficiency
Fiat Chrysler Primary Truck Fleet Average 345 327
A/C Leakage
A/C Efficiency
Off-Cycle
CH4 Deficit
Car Fleet Average 286 262
A/C Leakage
A/C Efficiency
Off-Cycle
CH4 Deficit
Advanced
Technology
Production
Volume
1,272
1,272
1,272
81,938
81,938
81,938
81,938
297,388
297,226
297,388
297,388
9,895
50
50
2,301
1,446,365
1,446,365
1,446,365
316,255
648,377
633,882
633,065
25,775
3,404
Credits (Mg)
(32,289)
783
645
18,507
131,203
79,580
113,537
(10,847)
(1,365)
116,138
256,260
231,480
183,103
(37,167)
(4,677)
2,548
(71,888)
3,408
1,746
(5,880,298)
3,186,801
1,313,950
2,361,453
(46,268)
(3,038,512)
1,113,855
526,044
416,894
(755)
78
-------
Table D-l. 2014 Model Year Reported Credits and Deficits
Manufacturer Pathway Fleet Credit Type
Ford Primary Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
N2O Deficit
CH4 Deficit
Car Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
N2O Deficit
CH4 Deficit
Advanced
Technology
GM Primary Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
CH4 Deficit
Car Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
N2O Deficit
CH4 Deficit
Advanced
Technology
Honda Primary Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Car Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
N2O Deficit
Advanced
Technology
Hyundai Primary Truck Fleet Average
A/C Leakage
Fleet Fleet
Average Standard Production
(g/mi) (g/mi) Volume
355 345 1,075,502
1,075,502
1,024,234
28,307
498,539
247 254 1,258,732
1,258,732
876,873
6,041
259,189
18,826
350 357 1,164,610
1,164,610
1,143,432
786,583
256 254 1,556,701
1,552,552
1,454,276
10,575
192,022
25,847
299 308 577,828
577,828
577,828
316,393
228 250 868,337
863,817
868,336
792,892
1,635
325 301 38,441
38,441
Credits (Mg)
(2,429,183)
1,846,942
597,121
769,099
(28,579)
(44,119)
1,720,495
1,412,435
518,730
501,470
(5,272)
(14,512)
1,841,312
1,878,149
1,066,971
457,702
(43,744)
(607,935)
1,918,074
950,133
228,888
(7,384)
(14,061)
1,174,600
400,850
288,562
239,134
3,730,209
225,990
241,401
164,811
(224,693)
(208,379)
24,989
79
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Table D-l. 2014 Model Year Reported Credits and Deficits
Manufacturer
Jaguar Land
Rover
Kia
Lotus
Mazda
McLaren
Mercedes
Pathway Fleet Credit Type
A/C Efficiency
Off-Cycle
Car Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Primary Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
TLAAS Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Car Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Primary Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Car Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
TLAAS Car Fleet Average
Primary Truck Fleet Average
Car Fleet Average
TLAAS Car Fleet Average
Primary Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Car Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Fleet Fleet
Average Standard Production
(g/mi) (g/mi) Volume
38,441
38,441
247 253 509,920
509,920
509,920
424,458
334 317 26,103
382 401 29,130
330 335 12,323
330 312 28,757
28,757
14,783
18,801
265 251 507,630
478,225
507,627
430,849
338 300 280
287 300 78,826
220 251 217,333
372 319 279
340 315 77,572
274 257 271,031
Credits (Mg)
33,274
26,111
597,414
199,151
320,839
59,075
(100,228)
101,406
33,606
32,693
125,010
107,234
35,526
36,477
12,031
15,850
12,478
5,315
(116,914)
18,904
11,353
3,428
(1,387,706)
208,197
322,330
88,313
(2,078)
231,452
1,315,557
(2,887)
(438,020)
123,285
93,551
24,078
(899,684)
245,585
285,704
139,554
80
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Table D-l. 2014 Model Year Reported Credits and Deficits
Manufacturer
Mitsubishi
Nissan
Subaru
Tesla
Toyota
Pathway Fleet Credit Type
Advanced
Technology
TLAAS Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Car Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Primary Truck Fleet Average
Car Fleet Average
Advanced
Technology
Primary Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Car Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Advanced
Technology
Primary Truck Fleet Average
A/C Efficiency
Off-Cycle
Car Fleet Average
A/C Efficiency
Primary Car Fleet Average
A/C Efficiency
Advanced
Technology
Primary Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Car Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Fleet Fleet
Average Standard Production
(g/mi) (g/mi) Volume Credits (Mg)
3,610
433 412 14,740 (69,914)
15,669
17,978
154
284 315 7,095 42,947
6,275
7,403
4,295
256 287 29,828 208,850
224 236 60,679 142,181
219
327 318 389,639 (792,052)
348,923
211,994
214,182
229 249 935,995 3,655,323
414,968
542,001
263,734
10,339
254 289 356,818 2,820,744
179,565
1,045
250 243 109,078 (149,093)
30,379
0 288 17,791 1,000,495
19,801
17,791
343 326 772,809 (2,967,359)
720,037
544,436
567,623
221 250 1,420,641 8,044,601
1,045,084
1,284,578
578,927
81
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Table D-l. 2014 Model Year Reported Credits and Deficits
Manufacturer Pathway Fleet Credit Type
Advanced
Technology
Volkswagen Primary Truck Fleet Average
A/C Leakage
A/C Efficiency
N2O Deficit
CH4 Deficit
Car Fleet Average
A/C Leakage
A/C Efficiency
N2O Deficit
CH4 Deficit
Advanced
Technology
Volvo Primary Truck Fleet Average
A/C Leakage
A/C Efficiency
Car Fleet Average
A/C Leakage
A/C Efficiency
Fleet Fleet
Average Standard Production
(g/mi) (g/mi) Volume Credits (Mg)
1,218
320 311 103,524 (210,442)
155,288
121,759
(18,499)
(922)
256 250 487,086 (570,662)
423,705
376,957
(120,381)
(44,575)
755
348 307 15,063 (139,490)
24,902
2,854
288 258 16,526 (96,808)
20,330
4,517
82
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