Greenhouse Gas
Emission Standards for
Light-Duty Vehicles
Manufacturer Performance Report
n
Model Year
Aston Martin
Lotus
McLaren
Tesla
Kia
BYD Motors
Toyota
Honda
Mazda
Ford
Subaru
General Motors
Mitsubishi
Nissan
Volkswagen
BMW
Fiat Chrysler
Volvo
Mercedes-Benz
Suzuki
Jaguar
Land Rover
Ferrari
Hyundai
Coda
Fisker
Porsche
Aston Martin
Lotus
McLaren
v>EPA
United States
Environmental Protection
k Agency
EPA-420-R-16-014 November 2016
Tesla
Kia
BYD Motors
Toyota
Honda
Mazda
Ford
Subaru
General Motors
Mitsubishi
Nissan
Volkswagen
BMW
Fiat Chrysler
Volvo
Mercedes-Benz
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Greenhouse Gas
Emission Standards for
Light-Duty Vehicles
Manufacturer Performance Report
for the
n
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 5
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 2012-2015 Model Years 13
A. "2-Cycle" Tailpipe CO2 Emissions 14
B. TLAAS Program Standards 17
C. Credits Based on Alternative Fuel Vehicles 22
1. Advanced Technology Vehicles 22
2. Compressed Natural Gas Vehicles 24
3. Gasoline-Ethanol Flexible-Fuel Vehicles 25
D. Credits Based on Air Conditioning Systems 28
1. Air Conditioning Leakage Credits 32
2. Air Conditioning Efficiency Credits 35
E. Credits Based on "Off-Cycle" Technology 38
1. Off-Cycle Credits Based on the Menu 41
2. Off-Cycle Technology Credits Based on 5-Cycle Testing 47
3. Off-Cycle Technology Credits Based on an Alternative Methodology 47
F. Deficits Based on Methane and Nitrous Oxide Standards 48
G. 2015 Model Year Compliance Values 52
H. 2015 Model Year Footprint-Based CO2 Standards 57
I. Overall Compliance Summary 62
4. Credit Transactions 65
5. Compliance Status After the 2015 Model Year 68
Appendix A: Comparing Actual Performance to Rulemaking Projections 73
Appendix B: Three-Year Vehicle Production Volume & Market Share 79
Appendix C: 2012-2014 Model Year Compliance Values 81
Appendix D: 2015 Model Year Report Credits and Deficits 90
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List of Tables and Figures
Industry Compliance Values versus Standards in 2012-2015 Model Years iii
Manufacturer Compliance Values and Standards in the 2015 Model Year iv
Credit Balances at Conclusion of the 2015 Model Year v
Table 1-1. Aggregation of Manufacturers in the 2015 Model Year 8
Table 2-1. Total Reported Early Credits, by Manufacturer and Model Year 10
Table 2-2. Total Reported Early Credits, By Credit Category 11
Table 2-3. 2009 Model Year Credits Which Expired at End of Model Year 2014 12
Table 3-1. "2-cycle" Tailpipe CO2 Production-Weighted Fleet Average Emissions 16
Table 3-2. Production Volumes Assigned to TLAAS Standards 19
Table 3-3. Net Impact from Use of the TLAAS Program 21
Table 3-4. Production Volumes of Advanced Technology Vehicles Using Zero Grams/Mile Incentive, by Model
Year 24
Table 3-5. Number of FFV Models by Manufacturer, 2012-2015 Model Years 27
Table 3-6. Production Volume of FFVs by Manufacturer, 2012-2015 Model Years 27
Table 3-7. Net Credits Accrued from Use of the FFV Incentives, 2012-2015 Model Years 28
Table 3-8. Reported A/C Credits by A/C Credit Type and Model Year 29
Table 3-9. Reported A/C Credits by Manufacturer, 2015 Model Year 30
Table 3-10. Net Impact of A/C Credits, 2012-2015 Model Years 31
Table 3-11. Production of Vehicles Using HFO-1234yf, 2013-2015 Model Years 33
Table 3-12. Reported A/C Leakage Credits by Manufacturer and Fleet, 2015 Model Year 33
Table 3-13. A/C Leakage Credits, 2012-2015 Model Years 34
Table 3-14. Reported A/C Efficiency Credits by Manufacturer and Fleet, 2015 Model Year 36
Table 3-15. A/C Efficiency Credits, 2012-2015 Model Years 37
Table 3-16. Reported Off-Cycle Technology Credits by Manufacturer and Fleet, 2015 Model Year 39
Table 3-17. Off-Cycle Technology Credits by Manufacturer and Fleet, 2012-2015 Model Years 40
Table 3-18. Reported Off-Cycle Technology Credits from the Menu, by Manufacturer and Fleet, 2015 Model
Year 41
Table 3-19. Off-Cycle Technology Credits from the Menu by Technology, 2015 Model Year 43
Table 3-20. Percent of 2015 Model Year Vehicle Production Volume with Credits from the Menu, by
Manufacturer & Technology 45
Table 3-21. Model Year 2015 Off-Cycle Technology Credits from the Menu, by Manufacturer and Technology .46
Table 3-22. Reported Off-Cycle Credits Based on 5-Cycle Testing for GM, by Model Year and Fleet 47
Table 3-23. Reported CFU and N2O Deficits by Manufacturer and Fleet, 2015 Model Year 50
Table 3-24. CFU Deficits by Manufacturer and Fleet, 2012-2015 Model Years 51
Table 3-25. N2O Deficits by Manufacturer and Fleet, 2012-2015 Model Years 51
Table 3-26. 2015 Compliance Values - Combined Passenger Car & Light Truck Fleet 53
Table 3-27. 2015 Compliance Values - Passenger Car Fleet 54
Table 3-28. 2015 Compliance Values - Light Truck Fleet 55
Table 3-29. 2012-2015 Model Year Compliance Values by Manufacturer and Fleet, 2012-2015 Model Years 56
Table 3-30. 2012-2015 Model Year CO2 Standards by Manufacturer and Fleet, 2012-2015 Model Years 59
Table 3-31. Average Footprint by Manufacturer and Fleet, 2012-2015 Model Years 61
Table 3-32. Compliance & Credit Summary, 2012-2015 Model Years - Combined Cars and Trucks 62
Table 3-33. Compliance & Credit Summary, 2012-2015 Model Years - Passenger Cars 63
Table 3-34. Compliance & Credit Summary, 2012-2015 Model Years - Light Trucks 63
Table 3-35. 2015 Model Year Compliance Summary by Manufacturer and Fleet 64
Table 4-1. Cumulative Reported Credit Sales and Purchases 67
Table 5-1. Cumulative Credit Status After the 2015 Model Year 69
Table 5-2. Credits Available After the 2015 Model Year, Reflecting Trades & Transfers 72
Table A-l. Projected CO2 Performance in Rulemaking Analyses for the Combined Passenger Car and Light Truck
Fleet 74
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Table A-2. Projected CO2 Performance in Rulemaking Analyses for Passenger Cars 75
Table A-3. Projected CO2 Performance in Rulemaking Analyses for Light Trucks 75
Table A-4. Actual and Projected CO2 Values, Cars and Trucks Combined 78
Table A-5. Actual and Projected CO2 Values, Passenger Cars 78
Table A-6. Actual and Projected CO2 Values, Light Trucks 78
Table B-l. Vehicle Production Volume by Manufacturer and Vehicle Category 79
Table B-2. Vehicle Category Market Share by Manufacturer and Model Year 80
Table C-l. 2012 Compliance Values - Combined Passenger Car & Light Truck Fleet 81
Table C-2. 2012 Compliance Values - Passenger Car Fleet 82
Table C-3. 2012 Compliance Values - Light Truck Fleet 83
Table C-4. 2013 Compliance Values - Combined Passenger Car & Light Truck Fleet 84
Table C-5. 2013 Compliance Values - Passenger Car Fleet 85
Table C-6. 2013 Compliance Values - Light Truck Fleet 86
Table C-7. 2014 Compliance Values - Combined Passenger Car & Light Truck Fleet 87
Table C-8. 2014 Compliance Values - Passenger Car Fleet 88
Table C-9. 2014 Compliance Values - Light Truck Fleet 89
Table D-l. 2015 Model Year Reported Credits and Deficits 90
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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.1
This report supersedes previous reports and details manufacturers' performance towards meeting
GHG standards in the 2015 model year, the fourth year of the GHG standards which become
increasingly stringent in each model year from 2012 through 2025. All data are final through the
end of the 2015 model year. Some values from previous model years may have changed based
on changes or corrections to the historical data.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 per 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 the Department of Justice, on behalf of EPA, alleged violations of the
Clean Air Act by Volkswagen and certain subsidiaries based on the sale of certain model year
2009-2016 diesel vehicles equipped with software designed to cheat on federal emissions tests.
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. For more information on actions to resolve these violations, see
www.epa.gov/vw.
1 Relevant information on the CAFE program can be found on the NHTSA website at NHTSA's CAFE Public
Information Center: http://www.nlitsa.gov/CAFE PIC/CAFE PIC Home.htm.
2 This report summarizes data as it was reported to EPA by the manufacturers and does not necessarily represent
final EPA decisions or positions regarding the data or the compliance status of manufacturers.
i
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Process for Determining a Manufacturer's Compliance Status
2-Cycle
Tailpipe
C02
Credits
Alternative Fuel Vehicles
Air Conditioning
Off-Cycle
Deficits
Methane & Nitrous
Oxide Deficits
Overall Model Year
Performance
Prior Model Year
Credits & Deficits
Credit
Transactions
Current Compliance
Status
Future Credits
& Deficits
V
Future Credit
Transactions
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 to avoid enforcement
action. After considering these additional credits and deficits, EPA determines a manufacturer's
current compliance status. For example, a manufacturer with a deficit from 2012 remaining after
the 2015 model year would be considered out of compliance with the 2012 model year standards.
There are no manufacturers that ended 2015 in this position. Jaguar Land Rover, for example,
successfully offset 2012 and 2013 deficits by the end of the 2015 model year and is thus in
compliance with the program to date. No manufacturer is yet out of compliance with the GHG
program in these first four model years; their performance in subsequent years, and whether
deficits can be successfully offset using future credits (either generated or acquired) will
ultimately determine final compliance.
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For the fourth consecutive year, the auto industry
outperformed the GHG standard by a substantial margin
Overall industry performance in model year 2015 was 7 g/mi better than required by the 2015
GHG emissions standard. This marks the fourth consecutive model year of industry
outperforming the standards by a sizeable margin. This industry-wide performance means that
manufacturers are offering and consumers continue to buy vehicles with lower GHG emissions
than required by the EPA standards. Manufacturers continued this level of performance against
standards that increased dramatically in stringency in model year 2015. The standards increased
in stringency by 13 g/mi relative to model year 2014; to put this in perspective, the total
cumulative increase in stringency since the start of the program is 25 g/mi. Although the
"compliance margin" narrowed to 7 g/mi, this remains notable in the face of a continuing
increase in truck market share combined with the increased stringency. See Section 3 for more
detail on these values.3
Industry Compliance Values versus Standards in 2012-2015 Model Years
300
295
290
J? 285
E
CO
E
ro
e?
x
e?
280
275
270
265
260
255
250
11 g/mi
lower than
target
2012
7 g/mi
12 g/mi
lower than
target
15 g/mi
13 g/mi
lower than
target
2013 2014
Model Year
Compliance Standard
I Compliance Value
13 g/mi
tarset
2015
3 Note that although rounding of the values on the chart may produce some apparent inconsistencies, the numbers
reported are correct.
ill
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Most manufacturers outperformed their individual 2015
standard
Most large manufacturers achieved fleet GHG compliance values equal to or lower than required
by their unique 2015 standard. Nine of the twelve manufacturers with sales greater than 150,000
vehicles reported meeting or beating their standard, with margins of compliance ranging from 23
g/mi (Nissan and Subaru) to exactly meeting their standard with no margin (BMW). Three
manufacturers (FCA, Mercedes, and Kia) missed their unique 2015 standards by 3, 11, and 12
g/mi, respectively, thus generating net deficits in the 2015 model year. The figure below does not
include the impact of credit transfers reported from prior model years (within a company) or
reported credit trades (transactions between companies), and thus does not necessarily portray
whether or not a manufacturer has complied with the 2015 model year standards. The three
manufacturers that did not outperform their 2015 standard in fact have reported sufficient credits
from prior model years to be able to report compliance with their respective 2015 model year
standards. More detail about model year 2015 performance is provided in Section 3.
Manufacturer Compliance Values and Standards in the 2015 Model Year
(from highest to lowest GHG standard)
350
Compliance Standard
Compliance Value
Note: Volkswagen is not included in this figure due to an ongoing investigation. Based on the initial compliance data,
Volkswagen's Compliance Standard is 249 g/mi and their Compliance Value is 252 g/mi. Should the investigation and
corrective actions yield different CO2 data, the revised data will be used in future reports.
iv
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3 All large manufacturers are in compliance with the 2012-2015
GHG standards
The majority of manufacturers, representing more than 99 percent of 2015 model year U.S. sales,
have reported compliance with the standards for the 2012-2015 model years. In fact, 19 of 20
manufacturers are reporting a non-negative credit balance going into the 2016 model year,
meaning that these manufacturers have met the standards in all of the 2012-2015 model years
(credits cannot be carried forward if a deficit exists in a prior model year). Manufacturers are
allowed to carry deficits forward for three model years. Thus, a manufacturer with a deficit from
the 2012 model year must have offset that deficit by the end of the 2015 model year, or else be
subject to possible enforcement action. All manufacturers that initially reported a deficit in the
2012 model year have successfully offset that deficit, thus no manufacturer is in a position of
non-compliance for any model year at the end of the 2015 model year. 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 2015 Model Year (Mg)4
(including credit transfers & trades)5
Manufacturer
Credits Carried to 2016
Manufacturer
Credits Carried to 2016
Toyota
82,996,367
Mercedesf
629,434
Honda
38,347,521
Suzuki*
428,242
GM
31,060,500
Fisker*
46,694
Ford
30,604,147
BYD Motors*
4,824
Nissan
24,561,976
Tesla
576
FCA
21,918,309
Coda*
0
Hyundai
20,338,163
Volvof
0
Subaru
13,281,040
Jaguar Land Roverf
(288,555)
Kia
8,173,661
Aston Martin^
N/A
Mazda
8,180,592
Ferrarif*
N/A
BMW
3,558,682
Lotusf**
N/A
Mitsubishi
1,681,499
McLarenf*
N/A
All Manufacturers
285,523,672
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 4,224,082 Mg. Should the investigation and corrective actions yield different C02 data,
the revised data will be used in future reports.
fThese 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.
*These companies are small volume manufacturers which have petitioned EPA for alternative standards that may be used
starting in the 2015 model year. Credits or deficits for these companies will not be reported until that process is complete
and final applicable standards are known.
*Although these companies produced no vehicles for the U.S. market 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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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 new GHG emissions and fuel economy
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 fifth such report released regarding EPA's GHG program.
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.8 Many comments emphasized the importance of making GHG compliance
information publicly available to ensure such transparency. This was also the case with the
proposal for 2017-2025 model year GHG standards, in which we reiterated our commitment to
the principle of transparency and to disseminating as much information as we are reasonably,
practically, and legally able to provide.9 In response to the comments on the proposed rule for
2012-2016 model year standards we noted that our public release of data could include ".. GHG
performance and compliance trends information, such as annual status of credit balances or
debits, use of various credit programs, attained fleet average emission levels compared with
standards, and final compliance status for a model year after credit reconciliation occurs" and
that we would ".. .reassess data release needs and opportunities once the program is
underway."10
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
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.
7 NHTSA now provides information to the public regarding fuel economy compliance through a web-accessible
public information center. See http://www.nlitsa.gov/CAFE_PIC/CAFE_PIC_Home.htm.
8 Proposed Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate
Average Fuel Economy Standards, Proposed Rule, Federal Register 74 (28 September 2009): 49454-49789.
9 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy
Standards, Final Rule, Federal Register 77 (15 October 2012): 62889.
111 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final
Rule, Federal Register 75 (7 May 2010): 25469.
1
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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 2015 model year is the fourth year manufacturers have been
subject to the standards. This report makes comparisons across the four complete model years of
the GHG program where appropriate. This report contains updated data for previous model years
and 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 2016.11 The data reported by each manufacturer includes the calculated
manufacturer-specific footprint-based CO2 standard for each vehicle category (car and truck), the
actual fleet-average tailpipe performance for each vehicle category (which includes flexible-fuel
vehicle credits and credits for other alternative fuels such as compressed natural gas and
electricity), the quantity of optional credits (e.g., based on air conditioning or off-cycle
technology improvements), credit transfers within a manufacturer between car and truck fleets,
credit trades between manufacturers, if applicable, and all the data necessary to calculate these
reported values.
This report first updates and summarizes the credits reported by manufacturers under the early
credit provisions, and then summarizes the data reported by manufacturers for the 2012-2015
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-
11 See 40 CFR 600.512-12.
2
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related exhaust emissions," or "CREE." The carbon-containing emissions are combined on a
C02-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 C02-equivalent sum of carbon emissions, the term CO2 is
used as shorthand throughout this report as a more familiar term for most readers.
The CO2 standards in EPA's GHG program and the related compliance values in this report
differ from the CO2 values reported in EPA's "Trends" report or on new vehicle fuel economy
labels.12 The Trends report presents CO2 and fuel economy values that are based on EPA's label
methodology, which is designed to provide EPA's best estimate of the fuel economy and GHG
emissions that an average driver will achieve in actual real-world driving. EPA's CO2 standards,
like the CAFE standards, are not adjusted to reflect real world driving. Instead, the GHG
standards and compliance values are based on the results achieved on EPA's city and highway
tests, weighted 55 and 45 percent, respectively. These tests are conducted under ideal driving
conditions and do not reflect a number of driver and environmental conditions that impact real
world fuel economy. 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.13 Further, compliance is ultimately determined based
on the balance of Megagrams of credits and/or deficits for a given model year, after accounting
for credit transfers and trades. 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
present a grams per mile equivalent value where possible (see inset on this page for the
methodology used to convert Megagrams to grams per mile).14 Where such a value in a table
applies to a specific manufacturer, the grams per mile value represents the impact of credits on
the fleet of that specific manufacturer, whereas the final Fleet Total row displays the grams per
mile impact of the total credits across the entire model year fleet of cars, trucks, or combined
fleet, whichever may be applicable. Finally, this report does not attempt to summarize or explain
all of the elements or details of EPA's GHG program. Readers should consult EPA's final
regulations and supporting documents for additional information.
12 "Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975 through 2016.
U.S. EPA-420-R-16-010, Office of Transportation and Air Quality, November 2016. See https://www.epa.gov/fuel-
econo my/trends-report.
13 The Megagram (Mg) is a unit of mass equal to 1000 kilograms. It is also referred to as the metric ton or tonne.
14 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.
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In 2016, the Department of Justice, on behalf of EPA, alleged violations of the Clean Air Act by
Volkswagen AG, Audi AG, Volkswagen Group of America, Inc., Volkswagen Group of
America Chattanooga Operations, LLC, Porsche AG, and Porsche Cars North America, Inc. for
alleged violations of the Clean Air Act. The U.S. complaint alleges that certain model year 2009-
2016 diesel vehicles are equipped with defeat devices in the form of computer software designed
to cheat on federal emissions tests, and that during normal vehicle operation and use, the cars
emit levels of oxides of nitrogen (NOx) significantly in excess of the EPA compliant levels. For
more information on actions to resolve violations, see www.epa.gov/vw. Oxides of nitrogen
emissions are not directly related to tailpipe CO2 emissions or fuel economy. 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,
updates to the emissions rates higher or lower will not change the broader trends characterized in
this report.
C. How Can CO2 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",
How We Determine a Grams per 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
per 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 per mile. The general
form of the equation is:
Credits [Mg] = ( CO2 x VMT x Production ) / 1,000,000
"CO2" represents the credit in grams per mile. "VMT" represents the total lifetime miles, which we
specified in the regulations as 195,264 miles for cars and 225,865 for trucks. "Production" represents the
production volume to which the CO2 credit applies.
The CCh-equivalent of a credit value expressed in Mg is derived by reversing the equation as follows:
CO2 [g/mi] = ( Credits[Mg] x 1,000,000 ) / (VMT x Production )
When using this equation to calculate CO2 grams per mile for aggregate car and truck credits, we use a
weighted average of the car and truck VMT values. For example, for the entire 2015 model year fleet
covered by this report, the weighted VMT is 208,317 miles. The weighting is by the proportion of cars or
trucks relative to the total fleet. The weighting may be applied on a manufacturer-specific basis or across
the entire fleet, depending on the data presented in each table. Unless specifically stated, this is always
the source of combined car/truck fleet values in this report.
4
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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.15
D. Which Manufacturers and Vehicles Are Included in This Report?
The vast majority of manufacturers producing cars and light trucks for U.S. sale are currently
covered by EPA's GHG program and are included in this report. Small businesses are exempted
from the GHG program (but not from the CAFE 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," "FCA" instead of "Fiat Chrysler
Automobiles," "Ford" instead of "Ford Motor Company," Mercedes" instead of "Mercedes-
Benz," and so on.
1. Small Businesses
Small businesses are exempt from EPA's GHG standards given that these businesses would face
unique challenges in meeting the standards. However, the program allows small businesses to
waive their exemption and voluntarily comply with the GHG standards. For example, a small
manufacturer of electric vehicles could choose to comply if they were interested in generating
GHG credits and potentially participating in the credit market. For the purpose of this exemption,
a small business is defined using the criteria of the Small Business Administration (SBA). For
vehicle manufacturers, SBA's definition of a small business is any firm with less than 1,000
15 These restrictions for the 2009 model year were established based on concerns that such credits might provide a
"windfall" since the California light truck standards from which early credits could be generated are less stringent
than the comparable CAFE standards in effect for that model year. See Section 2 for more information.
5
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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 SBA definition of a small
business) would likely find the GHG standards to be extremely challenging and potentially
infeasible. Given the unique feasibility issues faced by these manufacturers, EPA deferred
establishing CO2 standards for model years 2012-2016 for manufacturers with annual U.S. sales
of less than 5,000 vehicles.16
To be eligible for deferment in each model year, a manufacturer must demonstrate a good faith
effort to attempt to secure GHG credits to the extent credits are reasonably available from other
manufacturers. Credits, if available, would be used to offset the difference between a company's
baseline emissions and what their obligations would be under the GHG footprint-based
standards. Three manufacturers - Aston Martin, Lotus, and McLaren - requested and received a
conditional exemption for the 2012 model year. Because the 2012 model year was the first model
year of the program, and because companies seeking conditional exemptions were required to
submit their requests to EPA prior to the start of the 2012 model year, it is not surprising that a
credit market had not yet developed, despite inquiries made by these three companies of
manufacturers that were holding credits. The only manufacturers with any credits at the time
were those with optional early credits, and most were likely awaiting the conclusion of the 2012
model year to better evaluate their ability to sell credits. Because of their conditionally exempt
status for the 2012 model year, these three manufacturers were not included in EPA's report that
covered that model year.17 Since then, however, 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 2015 model year.
Small volume manufacturers may continue to 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.
Acknowledging the greater challenge that small volume manufacturers might face in meeting
CO2 standards compared to large manufacturers because they only produce a few vehicle
models, EPA proposed and finalized a pathway allowing them to apply for alternative GHG
emissions standards applicable to the 2017 and later model years.18 Small volume manufacturers
with annual U.S. sales of less than 5,000 vehicles may apply for alternative standards for up to
five model years at a time, and the standards that EPA establishes for model year 2017 may
16 The deferment applies only to the fleet average CO2 standards; these manufacturers are required to meet the
applicable nitrous oxide (N20) and methane (CH4) emission standards.
17 Conditional exemptions are available only through the 2016 model year, after which manufacturers must comply
with the GHG program standards or petition EPA for alternative manufacturer-specific GHG standards. The three
manufacturers noted here have already submitted applications requesting alternative standards, and EPA is in the
process of reviewing those applications.
18 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.
6
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optionally be met by the manufacturers in the 2015 and 2016 model years. Four manufacturers
have applied for alternative standards: Aston Martin, Ferrari, Lotus, and McLaren. Because of
the likelihood that these manufacturers will choose to meet the alternative standards in the 2015
model year, and because a final determination of those standards has not been made by EPA, the
data from these manufacturers for model year 2015 have been excluded from this report. A
future edition of this report will present the data from these four companies once the applicable
standards are established.19
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 FCA during the 2015
model year, petitioned EPA for operationally independent status, and EPA granted this status to
Ferrari starting with the 2012 model year.20 As an operationally independent manufacturer in
model year 2015 with a low U.S. sales volume (2775 cars in the 2015 model year), Ferrari has
the same options as the three small volume manufacturers discussed above. However, Ferrari is
not included in this report for reasons described below in section l.D.2.
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 2015 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.
19 The regulations specify the requirements for the supporting technical data and information that a manufacturer
must submit to EPA as part of its application. The process for considering such applications includes a draft
determination published by EPA followed by a public comment period of 30 days after which EPA will issue a final
determination establishing alternative standards for the manufacturer.
211 FCA 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 FCA
and held operationally independent status for the 2015 model year.
7
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Table 1-1. Aggregation of Manufacturers in the 2015 Model Year
Manufacturer
Manufacturers and Brands Included in U.S. Market
BMW
BMW, Mini, Rolls-Royce
FCA21
Chrysler, Dodge, Fiat, Jeep, Maserati, Ram
Ford
Ford, Lincoln
GM
Buick, Cadillac, Chevrolet, GMC
Honda
Acura, Honda
Jaguar Land Rover
Jaguar, Land Rover
Mercedes
Maybach, Mercedes-Benz, Smart
Nissan
Infiniti, Nissan
Toyota
Lexus, Scion, Toyota
Volkswagen22
Audi, Bentley, Bugatti, Lamborghini, Porsche, Volkswagen
21 Ferrari was owned by FCA in the 2015 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 2015 model year.
22 In 2009 Volkswagen acquired 49.9 percent of Porsche, and in 2012 purchased the remaining 51.1 percent,
resulting in Volkswagen's full ownership of Porsche. EPA regulations allow for a reasonable transition period in the
case of mergers such as this, requiring that Volkswagen AG (including Porsche) meet the GHG standards as a single
entity "beginning with the model year that is numerically two years greater than the calendar year in which the
merger/acquisitions(s) took place." This means that Porsche was considered a separate entity under the GHG
program for the 2012 and 2013 model years, but beginning with the 2014 model year lias been considered part of
Volkswagen AG and included in the Volkswagen fleet for compliance purposes.
8
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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. Also included in the data in this section
are off-cycle credits approved by EPA; see Section 3.E for more information regarding these
credits.
Early credits were earned through tailpipe CO2 reductions, improvements to air conditioning
systems that reduce refrigerant leakage or improve system efficiency, off-cycle credits for the
implementation of technologies that reduce CO2 emissions over driving conditions not captured
by the "2-cycle" test procedures, and introduction of advanced technology vehicles (i.e., electric,
fuel cell, and plug-in hybrid electric vehicles). The optional early credits program allowed
manufacturers to select from four pathways that provided opportunities for early credit
generation through over-compliance with a fleet average CO2 level specified by EPA in the
regulations. Manufacturers wishing to earn early credits selected one of these four pathways, and
the selected pathway was followed for the three model years of 2009-2011. Since EPA's GHG
standards did not begin until model year 2012, EPA established tailpipe CO2 thresholds below
which manufacturers were able to generate early fleet average credits. For two of the pathways,
the tailpipe emission levels below which credits were available were equivalent to the GHG
standards established by California prior to the adoption of the EPA GHG program. Two
additional pathways included tailpipe CO2 credits based on over-compliance with CO2 levels
equivalent to the CAFE standards in states that did not adopt the California GHG standards. In
March of 2013, EPA released a report documenting manufacturers' use of the early credit
provisions allowed under the GHG program (the "early credits report").23
Table 2-1 summarizes the credits (or deficits) reported by manufacturers in each of the three
model years for each participating manufacturer and shows the total net early credits for each
manufacturer. The early credits program required that participating manufacturers determine
credits for each of the three model years under their selected pathway, and that they carry
forward their net credits from the three early years to apply to compliance with EPA's GHG
standards in the 2012 and later model years. Thus, even manufacturers with a deficit in one or
more of the early model years, (i.e., their tailpipe CO2 performance was worse than the
applicable emissions threshold under the selected pathway) could benefit from the early credits
program if their net credits over the three years was a positive value. Manufacturers not listed in
Table 2-1 chose not to participate in the early credits program. Additionally, this table is
intended to show the credits reported by manufacturers in these years and does not include the
23 Greenhouse Gas Emission Standards for Light-Duty Automobiles: Status of Early Credit Program for Model
Years 2009-2011, Compliance Division, Office of Transportation and Air Quality, U.S. Enviromnental Protection
Agency, Report No. EPA-420-R-13-005, March 2013.
9
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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
available credit balances of the manufacturers involved in such transactions, as has the use of
early credits to offset future model year deficits. Further, while credits from the 2009 model year
may be used for compliance in 2014, any remaining unused 2009 model year credits expired
after model year 2014 and were not carried forward into the 2015 or later model years. 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 Reported Early Credits, by Manufacturer and Model Year (Mg)
Manufacturer
2009*
2010
2011
Total
Aston Martin
1,547
676
1,109
3,332
BMW
445,683
308,490
250,119
1,004,292
FCA
6,265,066
5,310,269
(1,164,014)
10,411,321
Ford
8,358,440
7,416,966
300,482
16,075,888
GM
13,009,374
11,073,134
482,321
24,564,829
Honda
14,133,353
14,182,429
7,526,552
35,842,334
Hyundai
4,605,933
5,388,593
4,012,969
14,007,495
Kia
3,134,775
2,651,872
4,657,545
10,444,192
Mazda
1,405,721
3,201,708
875,213
5,482,642
Mercedes
96,467
124,120
157,685
378,272
Mitsubishi
625,166
521,776
302,394
1,449,336
Nissan
10,496,712
5,781,739
1,852,749
18,131,200
Subaru
1,620,769
2,225,296
1,909,106
5,755,171
Suzuki
448,408
329,382
98,860
876,650
Tesla
0
35,580
14,192
49,772
Toyota
31,325,738
34,457,797
14,651,963
80,435,498
Volvo
194,289
359,436
176,462
730,187
Total
96,167,441
93,369,263
36,105,707
225,642,411
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. Should the investigation and corrective actions yield different C02 data, the revised data will be used in
future reports.
*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 have been removed from a manufacturer's credit bank.
10
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Table 2-2. Total Reported Early Credits, By Credit Category
Credit Category
Credits (Mg)
Percent of Total (%)
Tailpipe C02*
193,666,127
86%
A/C Leakage
22,978,713
10%
A/C Efficiency
7,690,825
4%
Off-Cycle
1,306,746
0%
Total
225,642,411
100%
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. Should
the investigation and corrective actions yield different C02 data, the revised data will be
used in future reports.
*Tailpipe C02 credits in the early credits program do not include credits from
flexible fuel vehicles.
Early credits from advanced technology vehicles (electric vehicles, plug-in hybrid electric
vehicles, and fuel cell vehicles) may be included in Table 2-2, depending upon how the
manufacturer chose to account for them. In these early credit years, manufacturers producing
advanced technology vehicles had two options available to them. They could simply incorporate
these vehicles into their fleet averaging in the relevant model year calculations using zero grams
per mile to represent the operation using grid electricity (see the discussion of advanced
technology vehicles in Section 3.C for more information regarding this incentive). Alternatively,
the program allowed manufacturers to exclude them from their fleet average in the 2009-2011
model years and carry the vehicles forward into a future model year, where they must be used to
offset a GHG deficit. Four manufacturers had qualifying vehicles in the 2009-2011 model years.
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 2009-2015 model years.
Due to concerns expressed by stakeholders during the rulemaking process, EPA placed certain
regulatory restrictions on credits from the 2009 model year.24 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 could
not be carried forward to the 2015 model year, and were removed from each manufacturer's
bank of credits. Note that of the almost 96 million Mg of 2009 credits earned by manufacturers,
almost 74 million Mg, or more than 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.
24 Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards, Final Rule,
Federal Register 75 (7 May 2010): 25324, 25328.
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Table 2-3. 2009 Model Year Credits Which
Expired at End of Model Year 2014
Manufacturer
Credits (Mg)
Toyota
29,523,399
Honda
14,133,353
Nissan
8,190,124
GM
6,473,623
Ford
5,882,011
Hyundai
4,481,690
Kia
2,324,161
Mazda
1,340,917
Mitsubishi
583,146
Subaru
491,789
Suzuki
265,311
Total
73,689,524
Note: Volkswagen is not included in this table due to an ongoing
investigation. Based on the original compliance data, 1,292,972 Mg of
Volkswagen's 2009 credits expired. Should the investigation and
corrective actions yield different CO2 data, the revised data will be
used in future reports.
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 2015 model year, and the accompanying data
as reported by manufacturers for the 2009-2015 model years, should be used as the references
from which to determine credit balances and overall performance at the conclusion of the 2015
model year, and prior reports should generally be considered obsolete.
12
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3. Credits Reported From the 2012-2015 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 per mile basis as measured
on EPA test procedures for each vehicle model, and (2) fleet-specific grams per 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 per mile impact for each
13
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manufacturer. Section 3.B describes
the temporary lead time allowance
alternative standards (TLAAS);
Section 3.C describes alternative
fuel vehicle incentives, including
the temporary flexible fuel vehicle
incentives; Section 3.D describes
credits based on air conditioning
system improvements; Section 3.E
describes off-cycle emission
reductions; and Section 3.F
discusses the impact of alternative
methane and nitrous oxide
standards. Once these values have
been determined, the 2-cycle tailpipe value is reduced by the total of all the credit and incentive
programs to determine a "compliance value," as described in Section 3.G. Section 3.H describes
the derivation of manufacturer-specific CO2 standards, which leads into Section 3.1, which
concludes Section 3, by comparing the compliance values to the CO2 standards to determine
whether or not a given fleet generates credits or deficits in the a 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
previous model year reports. 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 per mile contribution to a
manufacturer's total compliance. However, note that the grams per 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 CO2 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.
Important Note Regarding Tables
Many of tables in this section have a final row labeled
"Fleet Total." This row indicates a value that is
calculated based on the entire model year fleet and is
not specific only to the manufacturers listed in the
table. For example, not all manufacturers generated
credits for air conditioning systems, but the final
"Fleet Total" row in those tables indicates values that
are calculated to show the impact of air conditioning
credits on the entire model year fleet (i.e., across all
manufacturers, whether or not they reported air
conditioning credits).
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 2012-2015 model years.25 Absent the use of credits and incentives,
manufacturers demonstrated overall reductions in tailpipe GHG emissions in both the car and
truck fleets in model year 2015 relative to model year 2014. Of the 16 manufacturers active in
the program in the 2015 model year and excluding the small volume manufacturers, only GM
and Toyota increased fleet average tailpipe CO2 emissions, while the remainder reported either
no change or a decrease in the 2-cycle tailpipe emissions from their fleet. Across the industry, a
modest reduction in 2-cycle GHG emissions from cars (7 g/mi) and a sizeable reduction in 2-
cycle emissions from trucks (14 g/mi) led to a net reduction of 8 g/mi in overall fleet-wide 2-
cycle emissions. This overall reduction occurred even though the truck market share increased
from 41 to 43 percent in the 2015 model year (see Appendix B for car and truck production
data).
On a percentage basis the most significant reductions from the 2014 to the 2015 model year were
reported by Volvo (-10.7%), Nissan (-6.9%), and Honda (-6.3%). Despite reducing truck tailpipe
CO2 emissions by 16 g/mi, Toyota's overall fleet 2-cycle tailpipe emissions were up by almost
two percent, or 5 g/mi. This is likely due to an increase in car emissions of 4 g/mi coupled with a
sizeable increase in Toyota's truck production share from 35 to 43 percent. FCA and Mercedes
also made sizable gains across the board in both car and truck fleets, and Jaguar Land Rover
continued to reduce emissions, especially in the truck segment. Jaguar Land Rover and Nissan
have made the greatest percentage reductions in 2-cycle emissions - 17% - since the first year of
the program.
25 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
Model Year 2012
Model Year 2013
Model Year 2014
Model Year 2015
Change, 2014 to 2015
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Aston Martin
N/A.
See section
l.D.2.
444
444
454
454
N/A. See section l.D.2.
N/A
BMW
277
363
302
271
346
292
256
312
270
256
316
270
0
4
0
BYD Motors
0
0
0
0
0
0
No production
N/A
Coda
0
0
0
0
No production
No production
N/A
FCA
300
384
357
289
380
344
298
364
346
275
354
329
-23
-10
-17
Ferrari
494
494
475
475
484
484
N/A. See section l.D.2.
N/A
Fisker
146
146
No production
No production
No production
N/A
Ford
261
385
315
256
375
321
256
375
315
258
353
311
2
-22
-4
GM
283
397
331
273
395
325
266
369
314
266
362
321
0
-7
7
Honda
237
320
266
228
312
257
228
299
259
217
283
243
-11
-16
-16
Hyundai
243
312
249
238
317
241
247
325
253
246
324
252
-1
-1
-1
Jaguar Land Rover
376
439
426
347
414
399
330
377
369
337
358
354
7
-19
-15
Kia
258
324
266
252
301
254
265
330
269
260
327
266
-5
-3
-3
Lotus
N/A.
See section
l.D.2.
334
334
338
338
No production
N/A
Mazda
241
324
263
232
296
251
220
287
240
217
285
238
-3
-2
-2
McLaren
N/A.
See section
l.D.2.
374
374
372
372
N/A. See section l.D.2.
N/A
Mercedes
316
393
343
296
371
321
285
372
309
273
347
301
-12
-25
-8
Mitsubishi
262
283
267
254
267
258
224
256
236
215
254
228
-9
-2
-8
Nissan
258
382
295
232
340
266
229
335
263
217
307
245
-12
-28
-18
Porsche
325
362
342
309
363
336
N/A
See section l.D.4.
N/A. See section l.D.4.
N/A
Subaru
257
296
282
254
270
264
250
254
253
241
247
245
-9
-7
-8
Suzuki
267
361
287
266
330
273
No production
No production
N/A
Tesla
0
0
0
0
0
0
0
0
0
0
Toyota
221
354
273
224
347
278
221
358
274
225
342
279
4
-16
5
Volvo
297
343
311
292
348
318
288
348
319
254
333
285
-34
-15
-34
Fleet Total
259
369
302
251
360
294
250
349
294
243
336
286
-7
-14
-8
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance data, Volkswagen's 2015 model year 2-cycle tailpipe values are 251 g/mi
for cars, 336 g/mi for trucks, and 269 g/mi for the combined fleet. Should the investigation and corrective actions yield different C02 data, the revised data will be used in future
reports.
16
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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 2013-2015 model year
compliance. Volvo placed a small fraction of their 2015 fleet, all trucks, under the TLAAS
standards.
The TLAAS program is available 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. Providing that certain conditions are met, manufacturers with 2009 model
year U.S. sales of less than 50,000 vehicles may be allowed an additional 150,000 vehicles (for a
total of 250,000 vehicles at the 25 percent higher standard), and may be able to 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 2015
model years. The smallest-volume companies (Aston Martin, Ferrari, Lotus, and McLaren)
placed all of their 2013-2014 production into a TLAAS fleet, because they can do so without any
risk of exceeding the applicable limits. As noted in section 1.D.2, 2015 model year data from
these companies is not included in this report. Porsche, which placed all of its 2012 and 2013
vehicles in the TLAAS program (totaling more than 70,000 vehicles), would have reached the
100,000 vehicle limit in the 2014 model year except for the fact that as of the 2014 model year
they are aggregated with the Volkswagen fleet and no longer eligible to use the TLAAS
program.
17
-------
Table 3-2 shows each manufacturer's reported use of the TLAAS program for the 2012-2015
model years. Note that the total of 291,930 vehicles placed under the less stringent standards in
the program to date represents less than one percent of the total vehicles produced in the 2012-
2015 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 2015. As shown in the previous section, Jaguar Land Rover and Mercedes reduced
their overall 2-cycle tailpipe emissions by 72 and 42 g/mi, respectively, since the program started
in the 2012 model year.
18
-------
Table 3-2. Production Volumes Assigned to TLAAS Standards
Manufacturer
Model Year 2012
Model Year 2013
Model Year 2014
Model Year 2015
Cumulative
Total
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Cars Trucks All
Aston Martin
364
364
1,272
1,272
N/A. See section l.D.2.
1,636
Ferrari
1,510
1,510
1,902
1,902
2,301
2,301
N/A. See section l.D.2.
5,713
Jaguar Land Rover
326
38,871
39,197
25
24,254
24,279
521
9,019
9,540
19 26,965 26,984
100,000
Lotus
170
170
280
280
No production
450
McLaren
412
412
279
279
N/A. See section l.D.2.
691
Mercedes
10,585
20,230
30,815
6
28,437
28,443
7,095
14,740
21,835
118 18,789 18,907
100,000
Porsche
16,946
12,927
29,873
22,021
19,461
41,482
N/A. See section
l.D.4.
N/A. See section l.D.4.
71,355
Volvo
12,085 12,085
12,085
Fleet Total
29,367
72,028
101,395
24,900
72,152
97,052
11,748
23,759
35,507
137 57,839 57,976
291,930
-------
To understand the impact of the TLAAS program on compliance with EPA's GHG program, we
determined the grams per 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 per 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 entire model year fleet, not just the set of
manufacturers enrolled in the TLAAS program. Thus, the overall net impact on the 2015 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,
Volvo's 2015 model year fleet average standard against which they must demonstrate
compliance is 14 g/mi greater than it would be without use of the TLAAS program, as seen in
Table 3-3.
20
-------
Table 3-3. Net Impact from Use of the TLAAS Program (g/mi)
Manufacturer
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Cars Trucks All
Cars Trucks All
Cars Trucks All
Cars Trucks All
Aston Martin
Ferrari
Jaguar Land Rover
Lotus
McLaren
Mercedes
Porsche*
Volvo
69 69
2 76 60
4 22 10
66 84 75
64 64
66 66
40 31
62 62
66 66
0 27 9
63 82 73
65 65
65 65
3 13 11
60 60
64 64
2 13 5
N/A
N/A. See section l.D.2.
N/A. See section l.D.2.
38 31
N/A. See section l.D.2.
N/A. See section l.D.2.
12 5
N/A
36 14
Fleet Total
0.2 1.3 0.6
0.2 1.1 0.5
0.1 0.3 0.2
0.0 0.6 0.3
*For the purposes of the EPA GHG program, Porsche was aggregated with Volkswagen as of the 2014 model year and is no longer eligible to use the TLAAS
standards.
21
-------
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. Note that despite excluding Volkswagen from many tables for reasons described in
Section 1, they are included in this section because none of the vehicles described in this section
on alternative fuel vehicles are impacted by the ongoing investigation.
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 per mile compliance value, and plug-in hybrid electric vehicles may use a zero grams per
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 per mile option is limited to the first 200,000 qualified
vehicles produced by a manufacturer in the 2012-2016 model years. Electric vehicles, fuel cell
vehicles, and plug-in hybrid electric vehicles that were included in a manufacturer's calculations
of early credits also count against the production limits. As noted in Section 2, both GM and
Mercedes selected an option in the early credit provisions by which they 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 2012-2015 model years are well below
the cumulative 200,000 vehicle limit for the 2012-2016 model years, thus all manufacturers
remain eligible to continue to use zero grams per 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 g/mi,
compared to the upstream GHG emissions of a typical midsize gasoline car of about 60 g/mi.
Thus, the electric vehicle would have a net upstream emissions value of about 120 g/mi.26 EPA
26 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final
Rule, Federal Register 75 (7 May 2010): 25435.
22
-------
regulations provide all the information necessary to calculate a unique net upstream value for
each electric or plug-in hybrid electric vehicle.27
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 per mile for their fleet
(see Table 3-1) in the 2012-2015 model years. Without the incentive, however, the 2015 model
year 2-cycle fleet average GHG emissions for Tesla would in fact be about 103 g/mi.28 Use of
the incentive in Tesla's case in the 2015 model year allows them to generate almost 490,000 Mg
of additional GHG credits relative to what they would generate by using the net upstream value
of 103 g/mi. Nissan's passenger car fleet benefits similarly from the ability of the electric Leaf to
use zero grams per mile instead of the calculated net upstream value of 72 g/mi.29 As a result, the
overall impact on Nissan's passenger car fleet in the 2015 model year is an improvement of 2.0
g/mi, allowing them to generate almost 470,000 Mg of credits more than if the incentive
provisions were not in place. The net impact from Nissan and Tesla on the entire 2015 model
year fleet of this incentive is thus about 960,000 Mg of credits, or about 0.3 g/mi. While there are
other electric vehicles and plug-in hybrid electric vehicles in the 2015 fleet, as shown in Table 3-
4, Nissan and Tesla account for a substantial fraction of the 2015 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 g/mi across the 2015 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 2010-2015 production volumes of
advanced technology vehicles that utilized the zero grams per mile incentive.
27 See 40 CFR 600.113-12(n).
28 Using the calculations prescribed in the regulations, the sales-weighted upstream emissions for Tesla's 2015
passenger cars is 183 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 2015 passenger car fleet, is 103 grams/mile.
29 The upstream GHG emission value for the Nissan Leaf is 143 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 72 grams/mile.
23
-------
Table 3-4. Production Volumes of Advanced Technology Vehicles Using Zero
Grams/Mile Incentive, by Model Year
Manufacturer
2010
2011
2012
2013
2014
2015
Total
BMW
-
-
-
-
9,895
11,386
21,281
BYD Motors
-
-
11
32
50
-
93
Coda
-
-
-
37
-
-
37
FCA
-
-
-
2,353
3,404
7,825
13,582
Fisker
-
-
1,415
-
-
-
1,415
Ford
-
-
653
18,654
18,826
17,384
55,517
GM
-
4,370
18,355
27,484
25,847
14,847
90,903
Honda
-
-
-
471
1,635
2,106
Hyundai
72
72
Kia
-
-
-
-
-
926
926
McLaren
-
-
-
-
43
N/A
43
Mercedes
-
546
25
880
3,610
3,125
8,186
Mitsubishi
-
-
1,435
-
219
-
1,654
Nissan
-
8,495
11,460
26,167
10,339
33,242
89,703
Tesla
599
269
2,952
17,813
17,791
24,322
63,746
Toyota
-
-
452
829
1,218
-
8,337
Volkswagen
-
-
-
-
755
4,869
5,624
Total
599
13,680
36,306
93,891
91,659
113,129
349,264
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.
In the 2015 model year, in addition to the CNG-powered Honda Civic, Quantum Technologies
offered a dual fuel (CNG and gasoline) version of GM's Chevrolet Impala through an agreement
with GM. Quantum Technologies is exempt from GHG standards under the small business
provisions (although they could opt in if they chose), and as a result these vehicles were not
subject to 2015 model year GHG standards and won't be accounted for in this report. 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 0.15.30 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
311 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).
24
-------
vehicle-specific incentive is large (a reduction of 138 g/mi), the net impact on Honda's car fleet
is about 0.1 g/mi due to the low production volume of the Civic CNG (a few hundred in model
year 2015). This does not affect Honda's overall rounded car fleet average performance value,
and likewise has an unnoticeable impact on the overall 2015 model year fleet. If the volume of
CNG vehicles (either dual fuel or dedicated vehicles) increases substantially in the future, it will
become more important for us to be able to separate out the impact of current and future
incentives for these vehicles in a transparent manner.
3. Gasoline-Ethanol Flexible-Fuel Vehicles
The impact of 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's implementing statutes, 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]
C02 = ^ =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.31 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 2015 model year the dual-fuel credit limit in the CAFE program is 1.0 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
31 EPA Guidance Letter "E85 Flexible Fuel Vehicle Weighting Factor for Model Year 2016-2018 Vehicles," CD-
14-18, November 12, 2014.
25
-------
manufacturer's average fuel economy for its car or truck fleets by more than 1.0 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 1.0 mpg increase
from a base of 15 mpg represents a CO2 decrease of about 37 g/mi, while a 1.0 mpg increase
from a base of 30 mpg represents a CO2 decrease of about 10 g/ mi. Thus, the CO2 reduction that
manufacturers may get from the FFV credits for a given fleet is limited to the CO2 value
comparable to 1.0 mpg and is calculated from a manufacturer's specific fleet average
performance value.
Eight manufacturers produced FFVs in the 2015 model year, as shown below in Tables 3-5 and
3-6. Clearly, FCA, Ford, and GM produced the overwhelming majority of vehicles capable of
operating on E85. While almost 20 percent of model year 2014 vehicles were FFVs, this dropped
to about 10 percent in the 2015 model year. 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, with trucks
making up 70 percent of all FFV production in the 2015 model year. With the exception of FCA,
all of these manufacturers reduced FFV production in the 2015 model year, bringing almost one
million fewer FFVs to market relative to the previous model year, or an overall decrease of about
34 percent. FCA increased their FFV production by about 40,000 vehicles; making more than
one third of their 2015 model year vehicles capable of using E85.
26
-------
Table 3-5. Number of FFV Models by Manufacturer, 2012-2015 Model Years
Model
Year
Category
FCA
Ford
GM
Jaguar Land
Rover
Mercedes
Nissan
Toyota
Volkswagen
Total
Car
10
7
19
-
5
-
-
4
45
2012
Truck
11
23
60
-
1
4
2
-
101
All
21
30
79
-
6
4
2
4
146
Car
10
6
18
4
7
-
-
10
55
2013
Truck
13
23
58
-
1
4
2
1
102
All
23
29
76
4
8
4
2
11
157
Car
10
6
11
6
7
0
0
8
48
2014
Truck
11
21
44
6
1
4
2
1
90
All
21
27
55
12
8
4
2
9
138
Car
11
5
7
5
2
0
0
7
37
2015
Truck
11
7
22
3
1
4
2
1
51
All
22
12
29
8
3
4
2
8
88
Table 3-6. Production Volume of FFVs by Manufacturer, 2012-2015 Model Years
Model Year
Category
FCA
Ford
GM
Jaguar Land
Rover
Mercedes
Nissan
Toyota
Volkswagen
Total
Car
105,174
174,597
396,264
-
13,493
-
-
2,060
691,588
2012
Truck
453,399
323,563
511,183
-
8,289
24,154
31,670
-
1,352,258
All
558,573
498,160
907,447
-
21,782
24,154
31,670
2,060
2,043,846
Car
142,158
209,988
374,354
321
34,493
-
-
30,346
791,660
2013
Truck
431,359
546,695
637,576
-
22,082
13,650
33,203
20,799
1,705,364
All
573,517
756,683
1,011,930
321
56,575
13,650
33,203
51,145
2,497,024
Car
76,570
259,189
282,707
2,754
48,597
-
-
39,375
709,192
2014
Truck
650,617
498,245
801,740
32,013
12,079
14,809
56,516
25,666
2,091,685
All
727,187
757,434
1,084,447
34,767
60,676
14,809
56,516
65,041
2,800,877
Car
183,860
140,169
170,959
2,640
12,026
-
-
28,994
538,648
2015
Truck
585,462
296,039
313,961
10,795
5,208
13,565
43,060
31,987
1,300,077
All
769,322
436,208
484,920
13,435
17,234
13,565
43,060
60,981
1,838,725
Table 3-7 shows the impact of FFVs on each manufacturer's fleet for the 2012-2015 model
years. FCA, Ford, GM, and Jaguar Land Rover all maximized the FFV credit in both car and
truck fleets in the 2015 model year. In other words, these manufacturers produced at least
27
-------
enough FFVs to claim the maximum FFV benefit. The overall impact of FFVs on the fleet as a
whole decreased by one third, from 9 g/mi in model year 2014 to 2015 to 6 g/mi in model year
2015.
Table 3-7. Net Credits Accrued from Use of the FFV Incentives, 2012-2015 Model Years
(g/mi)
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Manufacturer
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
FCA
13*
21*
18
12*
21*
17
12*
19*
17
g*
15*
13
Ford
9
21*
14
9*
20*
15
9*
20*
14
8*
15*
12
GM
11*
23*
16
10*
22*
15
10*
19*
14
8*
15*
12
Jaguar Land
Rover
0
0
0
3
0
1
17*
20*
20
13*
15*
15
Mercedes
11
15
13
12*
12*
12
11*
17*
12
6
5
6
Nissan
0
15
4
0
8
3
0
8
3
0
6
2
Toyota
0
9
4
0
8
4
0
15
6
0
8
4
Volkswagen
1
0
1
7
15
8
10
16
11
7
13
8
Fleet Total
4
14
8
4
14
8
5
14
9
3
10
6
*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
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 2015 model year.
28
-------
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 A/C 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 2012-2015 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 2015 model year, and the grams per 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 A/C credits, translated from Megagrams to grams per mile, for each
manufacturer's fleet for the 2012-2015 model years. Note that despite excluding Volkswagen
from many tables for reasons described in Section 1, they are included in this section because
A/C efficiency and leakage credits are not related to the issues impacted by the ongoing
investigation.
Table 3-8. Reported A/C Credits by A/C Credit Type and Model Year
Leakage Credits
Efficiency Credits
Model
% of Annual
% of Annual
Year
Mg
A/C Total
Mg
A/C Total
Total (Mg)
2009
6,240,447
75
2,114,612
25
8,355,059
2010
8,323,530
75
2,844,066
25
11,167,596
2011
8,867,747
71
3,594,634
29
12,462,381
2012
11,123,308
66
5,746,946
34
16,870,254
2013
13,247,100
61
8,312,771
39
21,559,871
2014
16,594,532
62
10,254,684
38
26,849,216
2015
20,310,354
63
12,015,495
37
32,325,849
Total
84,707,018
65
44,883,208
35
129,590,226
29
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Table 3-9. Reported A/C Credits by Manufacturer, 2015 Model Year
Manufacturer
A/C Leakage
Credits
(Mg)
A/C Efficiency
Credits
(Mg)
Total A/C Credits
(Mg)
Grams/Mile
Equivalent of
Total A/C
Credits
BMW
435,612
359,565
795,177
9
FCA
6,577,374
2,180,199
8,757,573
19
Ford
2,772,342
1,167,130
3,939,472
10
GM
3,917,396
2,377,604
6,295,000
10
Honda
801,558
561,065
1,362,623
4
Hyundai
334,897
426,865
761,762
6
Jaguar Land Rover
236,457
84,793
321,250
21
Kia
293,366
437,914
731,280
5
Mercedes
438,975
398,795
837,770
11
Nissan
1,556,903
946,394
2,503,297
7
Subaru
-
332,498
332,498
2
Tesla
-
27,071
27,071
6
Toyota
2,244,059
2,172,823
4,416,882
8
Volkswagen
615,178
513,487
1,128,665
9
Volvo
86,237
29,292
115,529
8
Fleet Total
20,310,354
12,015,495
32,325,849
9
30
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Table 3-10. Net Impact of A/C Credits, 2012-2015 Model Years (g/mi)
Manufacturer
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Cars
Trucks All
Cars
Trucks All
Cars
Trucks All
Cars
Trucks All
Aston Martin
-
-
-
6
-
6
6
-
6
N/A. See section l.D.2.
BMW
7
11
8
8
11
9
8
11
9
9
11
9
Ferrari
10
-
10
10
-
10
11
-
11
N/A. See section l.D.2.
FCA
9
10
10
10
11
10
13
14
14
17
19
19
Ford
5
8
6
7
8
8
8
10
9
9
11
10
GM
8
8
8
9
9
9
9
11
10
10
11
10
Honda
2
5
3
3
5
4
3
5
4
3
6
4
Hyundai
4
7
4
5
7
5
5
7
5
6
7
6
Jaguar Land Rover
5
8
7
5
9
8
12
22
21
14
23
21
Kia
5
3
5
5
8
5
5
5
5
5
6
5
Mercedes
9
11
10
9
12
10
10
12
11
11
12
11
Nissan
2
4
3
4
4
4
5
6
6
7
8
7
Subaru
2
2
2
1
2
2
1
2
2
3
2
2
Tesla
6
-
6
6
-
6
6
-
6
6
-
6
Toyota
7
6
7
7
7
7
8
7
8
8
8
8
Volkswagen
6
9
7
6
10
7
8
12
9
9
12
9
Volvo
11
12
11
10
11
10
8
8
8
8
9
8
Fleet Total
5
7
6
6
8
7
7
10
8
8
11
9
31
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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.32 This score is based on the number,
performance, and technology of the components, fittings, seals, and hoses of the A/C system.33
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 per
mile credit value based on the global warming potential (GWP) of the refrigerant, for
consistency with the units of GHG exhaust emissions. The grams per 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, as no manufacturer had yet introduced a
new low-GWP refrigerant in the U.S. 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-
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 Honda
dropped the Fit EV in model year 2015 and GM sales of models using HFO-1234yf declined,
both FCA and Jaguar Land Rover increased their offerings of vehicles using HFO-1234yf,
contributing to a tripling of the number of vehicles using this refrigerant in the 2015 model year.
FCA more than tripled the volume of vehicles using the new refrigerant, to the point where more
than 75 percent of 2015 model year FCA vehicles are using it. Industry-wide, more than ten
percent of 2015 model year vehicles are using HFO-1234yf, with FCA accounting for more than
95 percent of those. Jaguar Land Rover continues to have the greatest penetration within their
fleet, using HFO-1234yf in almost 90 percent of vehicles produced in the 2015 model year. The
net impact on credits is that these manufacturers collectively generated about 3 million more
Megagrams of A/C leakage credits than they would have generated by using HFC-134a. FCA
accounts for most of these credits, accumulating almost 2.9 million Megagrams more than they
would have using HFC-134a. Table 3-11 shows the production volume of models using HFO-
1234yf for the 2012-2015 model years, by manufacturer.
32 See 40 CFR 86.1867-12.
33 The global wanning potential (GWP) represents how much a given mass of a chemical contributes to global
wanning over a given time period compared to the same mass of carbon dioxide. Carbon dioxide's GWP is defined
as 1.0.
32
-------
Table 3-11. Production of Vehicles Using HFO-1234yf, 2013-2015
Model Years
Manufacturer
2013
2014
2015
Total
Ferrari
394
N/A
394
FCA
540,098
1,683,956
2,224,054
GM
41,913
30,652
16,298
88,863
Honda
471
599
1,070
Jaguar Land Rover
56,604
62,316
118,920
Total
42,384
628,347
1,762,985
2,433,716
Thirteen manufacturers reported A/C leakage credits in the 2015 model year, as shown in Table
3-12. These manufacturers reported more than 20 million Mg of A/C leakage credits in 2015,
accounting for GHG reductions of about 6 g/mi across the 2015 vehicle fleet. Table 3-13 shows
the leakage credits in grams per mile for the 2012-2015 model years.
Table 3-12. Reported A/C Leakage Credits by Manufacturer and Fleet, 2015
Model Year (Mg)
Manufacturer
Car
Truck
Total
Grams/mile
Equivalent of
Total Credits
BMW
298,951
136,661
435,612
5
FCA*
1,904,927
4,672,447
6,577,374
14
Ford
1,087,338
1,685,004
2,772,342
7
GM*
1,643,372
2,274,024
3,917,396
6
Honda
315,425
486,133
801,558
2
Hyundai
301,255
33,642
334,897
3
Jaguar Land Rover*
27,395
209,062
236,457
15
Kia
260,945
32,421
293,366
2
Mercedes
246,447
192,528
438,975
6
Nissan
900,624
656,279
1,556,903
4
Toyota
1,132,635
1,111,424
2,244,059
4
Volkswagen
435,715
179,463
615,178
5
Volvo
43,455
42,782
86,237
6
Fleet Total
8,598,484
11,711,870
20,310,354
6
* Some vehicles equipped with systems using HFO-1234yf, a low-GWP refrigerant.
33
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Table 3-13. A/C Leakage Credits, 2012-2015 Model Years (g/mi)
Manufacturer
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Cars
Trucks All
Cars
Trucks All
Cars
Trucks All
Cars
Trucks All
Aston Martin
-
-
-
3
-
3
3
-
3
N/A.Seesectionl.D.2.
BMW
4
7
5
4
7
5
4
7
5
5
7
5
Ferrari*
6
-
6
7
-
7
8
-
8
N/A.
Seesectionl.D.2.
FCA*
6
8
7
6
8
7
9
10
9
13
15
14
Ford
4
7
6
5
7
7
6
8
7
6
8
7
GM*
6
7
6
6
7
7
6
7
7
6
7
6
Honda*
1
2
2
1
3
2
1
3
2
2
4
2
Hyundai
2
5
2
2
4
2
2
3
2
3
4
3
Jaguar Land Rover*
3
4
4
3
5
4
7
17
15
9
17
15
Kia
2
2
2
2
5
2
2
3
2
2
3
2
Mercedes
4
7
5
4
7
5
5
7
5
5
7
6
Nissan
0
2
1
0
2
1
2
4
3
4
6
4
Toyota
3
3
3
3
3
3
4
4
4
4
4
4
Volkswagen
2
4
2
3
5
3
4
7
5
5
7
5
Volvo
6
8
7
6
7
7
6
7
7
5
8
6
Fleet Total
3
5
4
3
6
4
4
6
5
5
7
6
* Some vehicles equipped with systems using HFO-1234yf, a low-GWP refrigerant.
34
-------
2. Air Conditioning Efficiency Credits
Manufacturers that make improvements in their AJC systems to increase efficiency, thus
reducing CO2 emissions due to AJC system operation, may be eligible for AJC efficiency credits.
Most of the additional load on the engine from AJC 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 per mile of CO2). Credits are capped at 5.7 g/mi for all vehicles in the
2012-2016 model years, and at 5.0 and 7.2 g/mi for cars and trucks, respectively, in the 2017 and
later model years. The total tons of credits are then based on the total volume of vehicles in a
model year using these technologies.
Fifteen manufacturers used the provisions that allow credits based on improvements to the
overall efficiency of the AJC system, as shown in Table 3-14. These manufacturers reported a
total of more than 12 million Mg of CO2 AJC efficiency credits in the 2015 model year,
accounting for about 3 g/mi across the 2015 fleet. Table 3-15 shows the efficiency credits in
grams per mile for the 2012-2015 model years.
35
-------
Table 3-14. Reported A/C Efficiency Credits by Manufacturer and Fleet, 2015 Model
Year (Mg)
Manufacturer
Car
Truck
Total
Grams/Mile
Equivalent of
Total Credits
BMW
274,938
84,627
359,565
4
FCA
673,129
1,507,070
2,180,199
5
Ford
488,390
678,740
1,167,130
3
GM
874,646
1,502,958
2,377,604
4
Honda
292,252
268,813
561,065
2
Hyundai
391,740
35,125
426,865
3
Jaguar Land Rover
15,515
69,278
84,793
6
Kia
400,117
37,797
437,914
3
Mercedes
247,753
151,042
398,795
5
Nissan
717,255
229,139
946,394
3
Subaru
89,553
242,945
332,498
2
Tesla
27,071
27,071
6
Toyota
1,246,673
926,150
2,172,823
4
Volkswagen
383,978
129,509
513,487
4
Volvo
21,613
7,679
29,292
2
Fleet Total
6,144,623
5,870,872
12,015,495
3
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Table 3-15. A/C Efficiency Credits, 2012-2015 Model Years (g/mi)
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Manufacturer
Cars
Trucks All
Cars
Trucks All
Cars
Trucks All
Cars
Trucks All
Aston Martin
-
-
-
3
-
3
3
-
3
N/A. See section l.D.2.
BMW
3
4
3
4
4
4
4
4
4
4
4 4
Ferrari
4
-
4
4
-
4
4
-
4
N/A. See section l.D.2.
FCA
3
2
3
3
3
3
4
4
4
4
5 5
Ford
0
0
0
2
1
1
2
2
2
3
3 3
GM
2
1
2
3
2
3
3
4
4
3
4 4
Honda
1
3
2
1
2
2
1
2
2
1
2 2
Hyundai
2
2
2
3
4
3
3
4
3
3
4 3
Jaguar Land Rover
2
4
4
2
4
4
5
6
5
5
6 6
Kia
2
1
2
2
3
3
3
2
3
3
3 3
Mercedes
5
5
5
5
5
5
5
5
5
5
5 5
Nissan
2
2
2
3
2
3
3
2
3
3
2 3
Subaru
2
2
2
1
2
2
1
2
2
3
2 2
Tesla
6
-
6
6
-
6
6
-
6
6
6
Toyota
4
2
3
4
3
4
5
3
4
4
4 4
Volkswagen
4
5
4
4
5
4
4
5
4
4
5 4
Volvo
4
4
4
4
4
4
1
1
1
3
1 2
Fleet Total
2
2
2
3
2
3
3
3
3
3
4 3
37
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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 2014.34 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 2015 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.35 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. GM is currently the only manufacturer to
have used this pathway in the 2012-2015 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.36 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.37
Table 3-16 shows the total off-cycle technology credits reported by manufacturers in the 2015
model year and the grams per mile impact on their respective fleets. Clearly the technologies
involved are currently implemented to varying degrees across manufacturers, accounting for
anywhere from zero g/mi (the manufacturers not shown in Table 3-16) to 6.1 g/mi for FCA. Off-
cycle credits from these 12 manufacturers accounted for a benefit of 3 g/mi across the entire
2015 model year fleet.
Table 3-17 shows the off-cycle credits in grams per mile for the 2012-2015 model years.
Although GM did generate off-cycle credits in the 2012 and 2013 model years, the grams per
mile equivalent of those credits rounds to 0.0, as shown, as is also the case for Subaru in model
year 2014.
34 See 40 CFR 86.1869-12(b).
35 See 40 CFR 86.1869-12(c).
36 See 40 CFR 86.1869-12(d).
37 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 https://www.epa.gov/veliicle-and-engine-
certification/compliance-infonnation-light-duty-greenliouse-gas-ghg-standards.
38
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Table 3-16. Reported Off-Cycle Technology Credits by Manufacturer and Fleet, 2015 Model
Year (Mg)
Manufacturer
Car
Truck
Total
Grams/Mile Equivalent
of Total Credits
BMW
233,580
128,762
362,342
4.2
FCA
490,904
2,385,988
2,876,892
6.1
Ford
670,668
1,523,766
2,194,434
5.6
GM
546,666
1,275,676
1,822,342
3.0
Honda
283,518
219,000
502,518
1.5
Hyundai
166,386
30,158
196,544
1.5
Jaguar Land Rover
7,573
67,230
74,803
4.9
Kia
134,413
23,639
158,052
1.2
Nissan
385,132
313,793
698,925
2.0
Subaru
5,270
15,844
21,114
0.2
Toyota
694,951
683,450
1,378,401
2.5
Fleet Total
3,619,061
6,667,306
10,286,367
3.0
39
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Table 3-17. Off-Cycle Technology Credits by Manufacturer and Fleet, 2012-2015 Model Years (g/mi)
Manufacturer
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Cars Trucks All
Cars Trucks All
Cars
Trucks
All
Cars
Trucks
All
BMW
-
-
3.2
6.1
3.9
3.5
6.5
4.2
FCA
1.1 2.5 2.0
0.9 2.6 2.0
3.3
7.2
6.1
3.3
7.5
6.1
Ford
-
-
2.0
3.2
2.6
3.9
6.9
5.6
GM
q
o
q
o
q
d
q
d
q
d
q
d
0.8
1.7
1.2
2.1
3.7
3.0
Honda
-
-
1.0
1.8
1.4
1.4
1.7
1.5
Hyundai
-
-
0.8
3.6
1.0
1.4
3.2
1.5
Jaguar Land Rover
-
-
2.2
5.5
5.0
2.5
5.5
4.9
Kia
-
-
1.3
1.3
1.3
1.1
2.1
1.2
Mercedes
-
-
2.6
1.2
2.2
-
-
-
Nissan
-
-
1.4
2.4
1.8
1.6
2.9
2.0
Subaru
-
-
-
0.0
0.0
0.2
0.2
0.2
Toyota
-
-
2.1
3.3
2.5
2.3
2.7
2.5
Fleet Total
0.1 0.5 0.2
o
o
k
o
N>
1.5
3.4
2.3
1.9
4.1
3.0
Note that "0.0" indicates that the manufacturer did report off-cycle credits, but that the overall volume was not high enough to round to 0.1 g/mi, whereas a dash
indicates no off-cycle credits reported.
40
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1. Off-Cycle Credits Based on the Menu
Starting with 2014 models, manufacturers have an 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 95 percent of 2015 off-cycle credits were generated
via this pathway, and for all but GM it was the sole pathway used to generate off-cycle credits.
The impact of credits from this pathway on a manufacturer's fleet is capped at 10 g/mi, meaning
that any single vehicle might accumulate more than 10 g/mi, but the cumulative effect on a
single manufacturer's fleet may not exceed a credit, or reduction, of more than 10 g/mi.
Table 3-18 shows the total off-cycle credits based on the menu pathway reported by
manufacturers in the 2015 model year and the grams per mile impact on their respective fleets.
Table 3-18. Reported Off-Cycle Technology Credits from the Menu, by
Manufacturer and Fleet, 2015 Model Year (Mg)
Manufacturer
Car
Truck
Total
Grams/Mile
Equivalent of
Total Credits
BMW
233,580
128,763
362,342
4.2
FCA
490,904
2,385,988
2,876,892
6.1
Ford
670,668
1,523,766
2,194,434
5.6
GM
469,086
934,921
1,404,007
2.3
Honda
283,518
219,000
502,518
1.5
Hyundai
166,386
30,158
196,544
1.5
Jaguar Land Rover
7,573
67,230
74,803
4.9
Kia
134,413
23,639
158,052
1.2
Nissan
385,132
313,793
698,925
2.0
Subaru
5,270
15,844
21,114
0.2
Toyota
694,947
683,447
1,378,401
2.5
Fleet Total
3,541,476
6,326,548
9,868,031
2.8
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 AJC system by venting hot air, by moving
heat away from passengers, or by reducing cabin 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 g/mi for cars and 4.3 g/mi for trucks. The per-vehicle grams per
mile credit varies between cars and trucks; for example, the credit available for active seat
ventilation is 1 g/mi for cars and 1.3 g/mi for trucks. The regulations clearly define each
41
-------
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
variable and 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 A/C
system. Thermal control technologies are subject to a per-vehicle cap on credits of 3.0
g/mi for cars and 4.3 g/mi for trucks.
o Active and passive cabin ventilation -Active systems use mechanical means to
vent the interior, while passive systems rely on ventilation through convective air
flow. Credits range from 1.7 to 2.8 g/mi.
o Active seat ventilation - These systems move air through the seating surface,
transferring heat away from the vehicle occupants. Credits are 1.0 g/mi for cars
and 1.3 g/mi 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 g/mi for cars and 0.5 g/mi 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. Systems that use a single
heat-exchanging loop that serves both transmission and engine warmup functions are
eligible for either engine or transmission warmup credits, but not both.
o Active engine warmup - Uses waste heat from the engine to warm up the engine.
Credits are 1.5 g/mi for cars and 3.2 g/mi for trucks,
o Active transmission warmup - Uses waste heat from the engine to warm up the
transmission. Credits are 1.5 g/mi for cars and 3.2 g/mi 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 are not eligible for credits.
Credits range from 1.5 to 4.4 g/mi, 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.
42
-------
• Hish 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 g/mi for turn signals and parking lights to 0.38 g/mi for low beams.
The total of all lighting credits may not exceed 1.0 g/mi.
• 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.
Table 3-19. Off-Cycle Technology Credits from the Menu by Technology, 2015 Model Year
(Mg)*
Off-Cycle Technology
Car
Truck
Total
Grams/Mile
Equivalent of
Total
Active Aerodynamics
Grill shutters
175,320
237,232
412,552
0.1
Ride height adjustment
152
7,718
7,870
0.0
Subtotal:
175,472
244,950
420,422
0.1
Thermal Control Technologies
Passive cabin ventilation
516,953
1,155,743
1,672,695
0.5
Active cabin ventilation
123,168
55,107
178,275
0.1
Active seat ventilation
165,206
341,314
506,520
0.1
Glass or glazing
515,465
1,665,290
2,180,755
0.6
Solar reflective surface coating
83,016
96,799
179,815
0.1
Subtotal:
1,403,808
3,314,253
4,718,060
1.4
Engine & Transmission Warmup
Active engine warmup
527,335
1,202,927
1,730,262
0.5
Active transmission warmup
964,822
1,036,414
2,001,239
0.6
Subtotal:
1,492,157
2,239,344
3,731,501
1.1
Other
Engine idle stop-start
223,100
251,370
474,469
0.1
High efficiency exterior lights
246,904
276,634
523,538
0.2
Solar panel(s)
41
-
41
0.0
Subtotal:
470,045
528,004
998,048
0.3
Total
3,541,482
6,326,551
9,868,031
2.8
*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
shown 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
43
-------
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 four
manufacturers approaching a 100 percent implementation rate (FCA, GM, Jaguar Land Rover,
and Kia). High efficiency lighting is another technology with high penetration across a number
of manufacturers, with seven manufacturers reporting implementation on at least half of 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. With 98 percent implementation,
Jaguar Land Rover had the highest proportion of vehicles equipped with engine idle stop-start.
The most "popular" technologies across the manufacturers were high efficiency lights and active
seat ventilation, both of which were employed by at least 10 manufacturers, followed by engine
idle stop-start, which was 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 2015 model year fleet, with Jaguar Land Rover appearing the outlier with
implementation on more than 50 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 8.7 million vehicles (more than half of the 2015 fleet),
and high efficiency lighting, which was installed on 8.2 million vehicles, or about 50 percent of
the fleet. FCA was the leader in terms of the number of technologies used to generate off-cycle
credits, gaining GHG reductions from ten unique technologies implemented at varying rates
across their fleets. FCA used every menu technology except active cabin ventilation and solar
panels.
Table 3-21 shows the grams per 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. BMW, FCA, Ford, and Jaguar Land Rover can be singled out as the manufacturers
reporting the greatest benefits from off-cycle technologies, from 4.2 to 6.1 g/mi, while the
remaining manufacturers achieved between 1 and 3 g/mi. A closer look shows different
strategies across these manufacturers of varying sizes and product lines. FCA and Ford achieved
the benefits of 6.1 and 5.6 g/mi, respectively, largely through their reported use of passive cabin
ventilation, glass or glazing, and active engine warmup systems, with the remainder coming from
other technologies. BMW was the only manufacturer using active cabin ventilation, with a 91
percent implementation rate and accounting for half of their 4.2 g/mi total off-cycle credits.
BMW was also the leader in penetration of active engine warmup systems, which accounted for
1.5 g/mi, and runner-up in the use of high-efficiency lighting, bringing them another 0.6 g/mi.
Jaguar Land Rover, which, as noted earlier, has made very large GHG reductions across their
fleet since the start of the program, gained more than half of their 4.9 g/mi 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.
44
-------
Table 3-20. Percent of 2015 Model Year Vehicle Production Volume with Credits from the Menu, by Manufacturer &
Technology (%)
Active
Aerodynamics
Thermal Control Technologies
Engine &
Transmission
Warmup
Other
V)
£
M
C
OJ txo
> ,c
a>
£
UT
Manufacturer
Grill shuttei
Ride height
adjustment
Passive cabi
ventilation
Active cabir
ventilation
Active seat
ventilation
TO
bjo
*_
o
U)
U)
TO
15
u ro
(U o
U
a; a,
u
CD
9 =
i/l in
Active engir
warmup
Active
transmissio
warmup
Engine idle
stop-start
u —
M— i-
•5.9
-£ Ol
BO 4-*
~ X
X ai
"ai
£
ro
a.
ro
o
LO
BMW
0.0
0.0
0.0
91.0
7.5
0.3
0.0
74.4
0.0
0.0
96.9
0.0
FCA
29.0
3.0
95.0
0.0
5.9
97.4
1.6
55.2
10.5
5.2
66.5
0.0
Ford
60.0
0.0
100.0
0.0
23.5
0.0
0.0
50.1
26.1
9.3
76.8
0.0
GM
9.7
0.0
0.0
0.0
16.5
99.5
38.6
14.4
0.0
8.8
40.0
0.0
Honda
0.0
0.0
0.0
0.0
1.0
0.0
0.0
0.0
72.2
1.5
57.8
0.0
Hyundai
4.9
0.0
0.0
0.0
18.3
89.0
0.0
0.0
52.6
2.7
22.3
0.0
Jaguar Land Rover
0.0
0.0
0.0
0.0
50.7
99.0
0.0
0.0
0.0
97.6
100.0
0.0
Kia
2.2
0.0
0.0
0.0
19.5
99.7
0.0
0.0
16.5
1.9
52.7
0.0
Nissan
9.3
0.0
0.0
0.0
3.3
0.0
15.8
20.8
64.9
0.1
47.2
0.1
Subaru
32.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.1
0.0
Toyota
0.0
0.2
0.0
0.0
23.5
90.5
30.2
9.2
49.8
11.4
56.2
0.0
Fleet Total
14.6
0.4
23.5
2.3
12.2
51.9
13.2
20.7
28.2
5.8
49.1
0.0
45
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Table 3-21. Model Year 2015 Off-Cycle Technology Credits from the Menu, by Manufacturer and Technology (g/mi)
Active
Aerodynamics
Thermal Control Technologies
Engine &
Transmission
Warmup
Other
Ol
oo
>»
(A
c
c
Ol
c
u
c
IA
a3
4-"
4-"
3
4-> 4-«
-E C
M>
c
o
c
15
(D
U
U
<
c
u
<
c
\r>
i/>
(O
e?
N
(D
CUO
(0
o
to
(0
H-
3
(A
>
u
<
E
k.
(0
5
>
u
<
c
(D
•*-*
E
ro
5
c
"5b
E
LU
Q.
O
4-"
(A
£
.top
I
'Z
-------
2. Off-Cycle Technology Credits Based on 5-Cycle Testing
As was the case in the 2012-2014 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. In the 2015 model year, the eAssist-equipped vehicles
were the Buick LaCrosse, Buick Regal, and Chevrolet Malibu. 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 2009-2015 model years are shown in Table 3-22. The
calculated grams per mile benefit rounds to zero because of the low volume of these credits, thus
the table does not display these credits in equivalent grams per mile.
Table 3-22. Reported Off-Cycle Credits Based on 5-Cycle
Testing for GM, by Model Year and Fleet (Mg)
Model Year
Car
Truck
Total
2009
-
3,329
3,329
2010
-
965
965
2011
-
1,338
1,338
2012
4,984
838
5,822
2013
13,330
819
14,149
2014
46,505
-
46,505
2015
70,233
70,233
Total
135,052
7,289
142,341
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.38 This
38 See 40 CFR 86.1869-12(d).
47
-------
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. 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.39
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 2014.40
Subsequently, FCA, Ford, and GM requested off-cycle credits under this pathway. FCA 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 AJC compressor made by Denso with variable
crankcase suction valve technology. EPA approved the credits for FCA, Ford, and GM in
September of 2015.41 FCA reported 2,599,923 Megagrams of off-cycle credits to EPA for the
2009-2013 model years, and the totals for those model years have been revised and reflected in
this report where appropriate. In the 2015 model year, GM reported earning 348,102 Mg of
credits from the Denso A/C compressor.
More recently, EPA published a notice in the Federal Register on September 2, 2016, requesting
comments on methodologies for off-cycle credits submitted by BMW, Ford, GM, and
Volkswagen.42 The comment period closed on October 3, 2016, and as of the writing of this
report, EPA is evaluating comments and drafting a decision document. If approved, these credits
would appear in a future edition of this report to the extent that manufacturers claim them.
F. Deficits Based on Methane and Nitrous Oxide Standards
EPA finalized emission standards for methane (CH4) and nitrous oxide (N2O) emissions as part
of the rule setting the 2012-2016 model year GHG standards. The standards that were set in that
rulemaking were 0.010 g/mi for N2O and 0.030 g/mi 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
39 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 https://www.epa.gov/veliicle-and-engine-
certification/compliance-information-light-duty-greenhouse-gas-ghg-standards.
411 "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.
41 "EPA Decision Document: Off-cycle Credits for FCA Automobiles, Ford Motor Company, and General Motors
Corporation" U.S. EPA-420-R-15-014, Office of Transportation and Air Quality, September 2015.
42 Alternative Method for Calculating Off-cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions
Program: Applications from BMW Group, Ford Motor Company, General Motors Corporation, and Volkswagen
Group of America, Federal Register 81 (2 September 2016): 60694.
48
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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-
equivalent standard option, which manufacturers may choose in lieu of complying with the cap
standards. This C02-equivalent standard option allows manufacturers to include CH4 and N2O,
on a C02-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 CO2), for
all their vehicles. Analyses of emissions data have shown that use of this option may add
approximately 3 g/mi to a manufacturer's fleet average. Two manufacturers chose to use this
approach in the 2015 model year: 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. Seven manufacturers made use of the flexibility offered
by this approach in the 2015 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 2010-2014 or
generated in 2015.
49
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Table 3-23. Reported CH4 and N2O Deficits by Manufacturer and Fleet, 2015 Model Year (Mg)
Car
Truck
Grams/Mile
Manufacturer
ch4
N20
ch4
N20
Total
Equivalent of
Total
BMW
1,497
11,894
3,259
25,900
42,550
0.5
FCA
10
-
3,650
-
3,660
0.0
Ford
8,804
6,793
53,350
30,635
99,582
0.3
GM
1,930
1,371
12,128
-
15,429
0.0
Honda
-
22,766
-
71,956
94,722
0.3
Nissan
81,821
6,865
125,680
10,543
224,909
0.6
Toyota
-
14,844
-
8,896
23,740
0.0
Fleet Total
94,383
146,761
198,878
157,592
597,614
0.2
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance data,
Volkswagen had car deficits of 321 and 82,288 Mg for CH4 and N20, respectively, and truck deficits of 811 and 9,662 Mg for
CH4 and N20, respectively, for a total of 93,022 Mg and a fleet impact of 0.8 g/mi. Should the investigation and corrective
actions yield different C02 data, the revised data will be used in future reports.
Tables 3-24 and 3-25 show the grams per mile equivalent CH4 and N2O deficits for the 2012-
2015 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/orN20 standards.
50
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Table 3-24. CH4 Deficits by Manufacturer and Fleet, 2012-2015 Model Years (g/mi)
Manufacturer
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
BMW
0.0
0.3
0.1
0.0
0.1
0.0
0.1
0.1
0.1
0.0
0.2
0.1
FCA
0.1
0.1
0.1
0.0
0.0
0.0
0.0
0.1
0.1
0.0
0.0
0.0
Ford
0.1
0.2
0.1
0.1
0.2
0.1
0.1
0.2
0.1
0.1
0.2
0.2
GM
0.1
0.4
0.2
0.1
0.4
0.2
0.0
0.2
0.1
0.0
0.0
0.0
Nissan
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.3
1.2
0.6
Fleet Total
0.1
0.1
0.1
0.1
0.1
0.1
0.0
0.1
0.1
0.1
0.1
0.1
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance data, Volkswagen has a 2015 CH4 deficit of 0.0 g/mi for
cars, 0.0 g/mi for trucks, and 0.0 g/mi for their total fleet. Should the investigation and corrective actions yield different C02 data, the revised data will be used in future
reports.
Table 3-25. N2O Deficits by Manufacturer and Fleet, 2012-2015 Model Years (g/mi)
Manufacturer
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
BMW
0.0
1.1
0.3
0.0
0.2
0.1
0.6
0.6
0.6
0.2
1.3
0.4
Ford
0.0
0.9
0.4
0.0
0.9
0.5
0.0
0.1
0.1
0.0
0.1
0.1
GM
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Honda
0.0
0.0
0.0
1.2
0.0
0.8
1.4
0.0
0.8
0.1
0.6
0.3
Nissan
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
0.1
Toyota
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Fleet Total
0.1
0.2
0.1
0.2
0.2
0.2
0.2
0.0
0.1
0.1
0.1
0.1
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance data, Volkswagen has a 2015 N20 deficit of 0.9 g/mi for
cars, 0.4 g/mi for trucks, and 0.8 g/mi for their total fleet. Should the investigation and corrective actions yield different C02 data, the revised data will be used in future
reports.
51
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G. 2015 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 2015 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.43 The final row shows values for the total 2015
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 311 g/mi is reduced by applying FFV, A/C, and off-cycle credits
totaling 28 g/mi, yielding a final compliance value of 284 g/mi (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.44 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 2015 model year. Again, these values are not regulatory values, but are calculated from the
Megagrams of credits reported by the manufacturers to EPA and presented this way to more
easily communicate compliance in understandable metrics.
43 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 Versions of Tables 3-19, 3-20, and 3-21 for the 2012-2014 model years are shown in Appendix C.
52
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Table 3-26. 2015 Compliance Values - Combined Passenger Car & Light Truck
Fleet (g/mi)
Credits (g/mi)
ch4&
2-Cycle
Off-
N20
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
270
0
9
4
0
257
FCA
329
13
19
6
0
291
Ford
311
12
10
6
0
284
GM
321
12
10
3
0
295
Honda
243
0
4
2
0
237
Hyundai
252
0
6
1
0
244
Jaguar Land Rover
354
15
21
5
0
313
Kia
266
0
5
1
0
259
Mazda
238
0
0
0
0
238
Mercedes
301
6
11
0
0
284
Mitsubishi
228
0
0
0
0
228
Nissan
245
2
7
2
1
235
Subaru
245
0
2
0
0
243
Tesla45
0
0
6
0
0
-6
Toyota
279
4
8
2
0
265
Volvo
285
0
8
0
0
277
Fleet Total
286
6
9
3
0
267
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance
data, Volkswagen has a 2-cycle tailpipe value of 269 g/mi, an FFV credit of 8 g/mi, an A/C credit of 9 g/mi, a CH4
and N20 deficit of 1 g/mi, and a compliance value of 252 g/mi. Should the investigation and corrective actions
yield different C02 data, the revised data will be used in future reports.
45 Tesla manufactures only electric vehicles. As explained in section 3.C. 1, a temporary incentive for electric
vehicles allows electric vehicle tailpipe emissions to be set equal to zero grams/mile, as shown in this table. An
artifact of this is that Tesla's compliance value is represented by a negative grams/mile value after applying air
conditioning credits.
53
-------
Table 3-27. 2015 Compliance Values - Passenger Car Fleet (g/mi)
Credits (g/mi)
ch4&
2-Cycle
Off-
N20
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
256
0
9
4
0
244
FCA
275
9
17
3
0
246
Ford
258
8
9
4
0
237
GM
266
8
10
2
0
246
Honda
217
0
3
1
0
213
Hyundai
246
0
6
1
0
239
Jaguar Land Rover
337
13
14
2
0
308
Kia
260
0
5
1
0
254
Mazda
217
0
0
0
0
217
Mercedes
273
6
11
0
0
256
Mitsubishi
215
0
0
0
0
215
Nissan
217
0
7
2
0
209
Subaru
241
0
3
0
0
238
Tesla*
0
6
0
0
-6
Toyota
225
0
8
2
0
215
Volvo
254
0
8
0
0
246
Fleet Total
243
3
8
2
0
230
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance
data, Volkswagen has a passenger car 2-cycle tailpipe value of 251 g/mi, an FFV credit of 7 g/mi, an A/C credit
of 9 g/mi, a CH4 and N20 deficit of 1 g/mi, and a compliance value of 236 g/mi. Should the investigation and
corrective actions yield different C02 data, the revised data will be used in future reports.
*Tesla manufactures only electric vehicles. As explained in section 3.C.1, a temporary incentive for electric
vehicles allows electric vehicle tailpipe emissions to be set equal to zero g/mi, as shown in this table. An
artifact of this is that Tesla's compliance value is represented by a negative number after applying A/C credits.
54
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Table 3-28. 2015 Compliance Values - Light Truck Fleet (g/mi)
Credits (g/mi)
ch4&
2-Cycle
Off-
N20
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
316
0
11
7
1
300
FCA
354
15
19
7
0
312
Ford
353
15
11
7
0
321
GM
362
15
11
4
0
332
Honda
283
0
6
2
1
276
Hyundai
324
0
7
3
0
314
Jaguar Land Rover
358
15
23
5
0
315
Kia
327
0
6
2
0
319
Mazda
285
0
0
0
0
285
Mercedes
347
5
12
0
0
329
Mitsubishi
254
0
0
0
0
254
Nissan
307
6
8
3
1
291
Subaru
247
0
2
0
0
244
Toyota
342
8
8
3
0
323
Volvo
333
0
9
0
0
324
Fleet Total
336
10
11
4
0
311
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance
data, Volkswagen has a light truck 2-cycle tailpipe value of 336 g/mi, an FFV credit of 13 g/mi, an A/C credit of
12 g/mi, a CH4 and N20 deficit of 0 g/mi, and a compliance value of 311 g/mi. Should the investigation and
corrective actions yield different C02 data, the revised data will be used in future reports.
Table 3-29 shows the calculated compliance values for each manufacturer's car and truck fleet
for the 2012-2015 model years. As can be seen in the table, the decreases in manufacturer
compliance values from 2014 to 2015 outweighed the increases, leading to a net decrease of 7
g/mi across the fleet of combined cars and trucks.
55
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Table 3-29. 2012-2015 Model Year Compliance Values by Manufacturer and Fleet, 2012-2015 Model Years (g/mi)
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Manufacturer
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Aston Martin
N/A. See section
l.D.2.
438
0
438
448
0
448
N/A
See section 1.
D.2.
BMW
270
353
294
263
335
283
245
295
257
244
300
257
BYD Motors
0
0
0
0
0
0
0
0
0
No production
Coda
0
0
0
0
0
0
No production
No production
Ferrari
484
0
484
465
0
465
473
0
473
N/A
See section 1.
D.2.
FCA
277
351
327
267
345
314
270
324
309
246
312
291
Fisker
146
0
146
No production
No production
No production
Ford
248
357
295
240
348
299
237
342
289
237
321
284
GM
264
366
307
254
364
301
246
337
288
246
332
295
Honda
235
315
263
227
307
254
226
292
254
213
276
237
Hyundai
239
305
244
233
310
236
241
315
247
239
314
244
Jaguar Land Rover
371
431
418
337
405
390
316
331
328
308
315
313
Kia
253
321
261
247
293
249
259
325
263
254
319
259
Lotus
N/A. See section
l.D.2.
334
0
334
338
0
338
N/A
See section 1.
D.2.
Mazda
241
324
263
232
296
251
220
287
240
217
285
238
McLaren
N/A. See section
l.D.2.
374
0
374
372
0
372
N/A
See section 1.
D.2.
Mercedes
295
367
320
275
347
299
262
342
284
256
329
284
Mitsubishi
262
283
267
254
267
258
224
256
236
215
254
228
Nissan
256
363
288
228
328
260
222
318
253
209
291
235
Porsche
325
362
342
309
363
336
N/A. See section l.D.4.
N/A
See section 1.
D.4.
Subaru
255
294
280
253
268
262
249
252
251
238
244
243
Suzuki
267
361
287
266
330
273
No production
No production
Tesla
-6
0
-6
-6
0
-6
-6
0
-6
-6
0
-6
Toyota
214
339
263
217
332
268
211
333
258
215
323
265
Volvo
286
331
300
282
337
307
280
340
311
246
324
277
Fleet Total
249
347
288
241
338
279
237
322
274
230
311
267
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance data, in the 2015 model year
Volkswagen had compliance values of 236, 311, and 252 g/mi for cars, trucks, and all vehicles, respectively. Should the investigation and corrective actions
yield different C02 data, the revised data will be used in future reports.
56
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H. 2015 Model Year Footprint-Based CO2 Standards
The final values needed to determine the relative performance for a manufacturer in a model year
are the emissions standards that apply to each manufacturer's fleets in that model year. At the
end of each model year, manufacturers calculate unique CO2 standards for each fleet (cars and
trucks) using equations specified in the regulations based on the footprint of their vehicles.46 The
footprint "curves" for the 2012-2015 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. 2012-2015 Model Year CO2 Footprint Target Curves
400
2012 Trucks
2013 Trucks
380
2014 Trucks
360
2015 Trucks
— 2012 Cars
340
— 2013 Cars
v 320
2014 Cars
2015 Cars
E 300
2
.op
p? 280
260
240
220
200
20
25
30
35
40
45
Footprint (square feet)
50
55
60
65
70
75
80
The calculated CO2 standards for the 2012-2015 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-
46 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.
57
-------
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 2014 to 2015 outweighed the increases, resulting in an increase in the overall
stringency of the program of about 13 g/mi.
58
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Table 3-30. 2012-2015 Model Year CO2 Standards by Manufacturer and Fleet, 2012-2015 Model Years (g/mi)
Manufacturer
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Aston Martin*
N/A. See section
l.D.2.
321
321
324
324
N/A. See section 1.
D.2.
BMW
269
336
288
263
324
280
258
313
271
244
301
257
BYD Motors
277
277
269
269
261
261
No production
Coda
246
246
239
239
No production
No production
Ferrari*
345
345
331
331
324
324
N/A. See section 1.
D.2.
FCA
277
345
323
270
338
311
262
327
309
247
307
288
Fisker
315
315
No production
No production
No production
Ford
265
364
308
265
355
315
254
345
299
245
329
292
GM
272
369
313
263
360
304
254
357
302
244
336
296
Honda
263
333
288
256
318
278
250
308
275
236
293
258
Hyundai
269
316
273
261
309
263
253
301
257
246
285
249
Jaguar Land Rover*
364
388
383
324
362
353
335
361
357
257
338
322
Kia
266
338
274
258
303
259
251
312
255
241
308
247
Lotus*
N/A. See section
l.D.2.
311
311
300
300
No production
Mazda
259
323
276
250
311
268
251
300
265
241
285
254
McLaren*
N/A. See section
l.D.2.
329
329
319
319
N/A. See section 1.
D.2.
Mercedes*
277
360
306
262
354
292
258
330
278
249
311
273
Mitsubishi
261
307
271
249
296
264
236
287
254
225
273
241
Nissan
263
337
285
259
324
280
249
318
271
239
300
258
Porsche
332
422
374
314
410
363
N/A. See section l.D.4.
N/A. See section 1.
D.4.
Subaru
260
309
291
251
299
281
243
289
279
234
276
265
Suzuki
251
325
267
243
296
249
No production
No production
Tesla
304
304
296
296
288
288
276
0
276
Toyota
264
342
295
257
329
289
250
326
279
239
305
269
Volvo*
272
325
288
264
316
288
258
307
283
247
325
277
Fleet Total
267
348
299
261
339
292
253
330
287
241
312
274
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance data, in the 2015 model year Volkswagen had C02 standards of
236, 297, and 249 g/mi for cars, trucks, and all vehicles, respectively. Should the investigation and corrective actions yield different C02 data, the revised data will be used in
future reports.
*Some or all vehicles subject to temporary less stringent TLAAS standards. See section 3.B.
59
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Overall, the standards decreased by 13 g/mi from 2014 to 2015, an increase in stringency driven
by the more stringent target curves for the 2015 model year. This increase in stringency in a
single model year is greater than the total stringency increases in all previous model years
combined. 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 Volvo trucks increased - got less stringent - from 2014 to 2015. This is because Volvo put
some vehicles in the less stringent TLAAS standards in model year 2015 (the only year in which
they have done so), and the net impact is a decrease in stringency. Volvo did not increase their
overall footprint and nor did they sell more trucks, either of which could increase their GHG
standard. In fact, their car footprint stayed about the same as in 2014, their truck footprint
decreased by almost a full square foot, and their truck sales were down relative to cars from the
2014 model year.
The average footprint for the overall fleet decreased in the 2015 model year by 0.3 square feet, to
49.4 square feet. The average car footprint remained unchanged at 46.1 square feet, and the truck
footprint decreased by 1.1 square feet to 53.9 square feet, the smallest truck footprint since the
GHG standards took effect. Of the 17 manufacturers shown in Table 3-31, fleet average footprint
increased for seven, decreased for nine, and was unchanged for one. Increases in footprint ranged
from 0.3 square feet (Mazda) to 1.0 square foot (Hyundai). Note that a change in the overall fleet
footprint does not necessarily indicate that manufacturers built smaller or larger vehicles;
because the footprint is weighted by production volume, shifts in volumes can result in a change
to an overall fleet footprint. Thus, a change in footprint could be a result of either of these factors
independently, or more likely, a mix of both factors.
60
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Table 3-31. Average Footprint by Manufacturer and Fleet, 2012-2015 Model Years (square feet)
Manufacturer
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Change: 2014 to 2015
Cars Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
Aston Martin
N/A. See
section
l.D.2.
45.2
45.2
47.5
47.5
N/A. See section 1.
D.2.
N/A
BMW
45.9
51.4
47.3
46.2
5 0.8
47.4
47.1
50.4
47.8
46.6
51
47.5
-0.5
0.6
-0.3
BYD Motors
47.9
47.9
47.9
47.9
47.9
47.9
No production
N/A
Coda
41.5
41.5
41.5
41.5
No
production
No production
N/A
Ferrari
47.8
47.8
47.1
47.1
47.4
47.4
N/A. See section 1.
D.2.
N/A
FCA
47.2
53.6
51.4
47.6
54.5
51.5
48.0
54.1
52.2
47.1
52.7
50.7
-0.9
-1.4
-1.5
Fisker
58.1
58.1
No production
No
production
No
production
N/A
Ford
45.3
59.4
50.9
47.0
59.5
53.4
46.4
59.4
52.4
46.8
58.9
53.1
0.4
-0.5
0.7
GM
46.9
60.1
52.0
46.5
60.4
51.9
46.3
62.6
53.2
46.7
60.3
53.9
0.4
-2.3
0.7
Honda
45.0
50.5
46.8
44.9
49.3
46.3
45.6
49.2
47.0
45
49.1
46.5
-0.6
-0.1
-0.5
Hyundai
46.4
46.4
46.4
46.1
47.0
46.2
46.1
47.5
46.2
47.2
47
47.2
1.1
-0.5
1
Jaguar Land Rover
51.0
48.4
49.0
50.8
48.2
48.8
49.3
52.0
51.5
49.6
50.6
50.4
0.3
-1.4
-1.1
Kia
45.6
51.9
46.2
45.4
45.6
45.4
45.8
50.0
46.1
46.2
52.6
46.7
0.4
2.6
0.6
Lotus
N/A. See
section
l.D.2.
47.1
47.1
43.5
43.5
No
production
N/A
Mazda
43.9
48.1
44.9
43.6
47.0
44.4
45.6
47.2
46.0
46.1
47.1
46.3
0.5
-0.1
0.3
McLaren
N/A. See
section
l.D.2.
46.6
46.6
46.6
46.6
N/A. See section 1.
D.2.
N/A
Mercedes
46.5
51.9
48.2
45.4
51.5
47.3
46.6
51.4
47.8
47.3
50.4
48.4
0.7
-1
0.6
Mitsubishi
44.5
44.0
44.4
43.6
43.9
43.7
41.5
44.0
42.3
41.3
43.9
42.1
-0.2
-0.1
-0.2
Nissan
45.0
51.6
46.8
45.8
50.8
47.2
45.4
51.6
47.2
45.8
50.6
47.1
0.4
-1
-0.1
Porsche
44.7
51.8
47.7
43.7
51.9
47.6
N/A. See section l.D.4.
N/A. See section 1.
D.4.
N/A
Subaru
44.3
44.7
44.5
44.0
44.6
44.4
44.1
44.4
44.3
44.7
44.7
44.7
0.6
0.3
0.4
Suzuki
42.1
48.7
43.4
41.8
44.0
42.0
No production
No production
N/A
Tesla
53.6
53.6
53.6
53.6
53.6
53.6
53.6
53.6
0
0
Toyota
45.0
53.4
48.0
45.1
52.5
48.1
45.6
54.1
48.6
45.6
52.2
48.4
0
-1.9
-0.2
Volkswagen
45.2
49
45.6
45.2
49
45.6
45.5
50
46.3
45.1
50.1
46
-0.4
0.1
-0.3
Volvo
46.8
48.6
47.3
46.8
49.0
47.7
47.2
48.9
48.0
47.3
48
47.5
0.1
-0.9
-0.5
Fleet Total
45.7
54.5
48.8
45.9
54.8
49.1
46.1
55.0
49.7
46.1
53.9
49.4
0
-1.1
-0.3
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance data, Volkswagen footprint values were 45.1, 50.1, and 46.0 square feet
for cars, trucks, and the total fleet, respectively, in the 2015 model year. Should the investigation and corrective actions yield different C02 data, the revised data will be used in future
reports.
61
-------
I. Overall Compliance Summary
Final compliance for the 2012-2015 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 2012-2015 model years, is a
positive value, thus indicating over-compliance with the standards. Overall, manufacturers
outperformed the 2015 standard by 7 g/mi.47 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 g/mi, thus contributing to the overall fleet compliance margin. In the 2015
model year the bulk of the over-compliance can again be attributed to passenger cars, although
the trucks remained in compliance with their applicable fleet standard of 312 g/mi, and some
manufacturers (Jaguar Land Rover, Subaru) over-complied in their truck fleet with a greater
margin than in their car fleet.
Table 3-32. Compliance & Credit Summary, 2012-2015 Model Years - Combined Cars and
Trucks (g/mi)*
Credits
Model
2-Cycle
Off-
CH4&N2O
Compliance
Standard -
Year
Tailpipe
FFV
A/C
Cycle
Deficit
Value
Standard
Compliance
2012
302
8.1
6.1
0.2
0.2
288
299
11
2013
294
7.8
6.9
0.2
0.3
279
292
12
2014
294
8.9
8.3
2.3
0.2
274
287
13
2015
286
6.4
9.3
3.0
0.2
267
274
7
*Values stated in this table and in the text are correct, although rounding of values may result in some
apparent differences.
47 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.
62
-------
Table 3-33. Compliance & Credit Summary, 2012-2015 Model Years - Passenger Cars
(g/mi)*
Credits
Model
2-Cycle
Off-
CH4&N2O
Compliance
Standard -
Year
Tailpipe
FFV
A/C
Cycle
Deficit
Value
Standard
Compliance
2012
259
4.0
5.3
0.1
0.1
249
267
17
2013
251
4.0
6.2
0.1
0.3
241
261
20
2014
250
4.6
7.3
1.5
0.3
237
253
16
2015
243
3.1
7.9
1.9
0.1
230
241
11
*Values stated in this table and in the text are correct, although rounding of values may result in some
apparent differences.
Table 3-34. Compliance & Credit Summary, 2012-2015 Model Years - Light Trucks (g/mi)*
Credits
Model
2-Cycle
Off-
CH4&N2O
Compliance
Standard -
Year
Tailpipe
FFV
A/C
Cycle
Deficit
Value
Standard
Compliance
2012
369
14.5
7.2
0.5
0.3
347
348
1
2013
360
13.7
7.9
0.4
0.3
338
339
1
2014
349
14.3
9.6
3.4
0.1
322
330
8
2015
336
10.3
10.9
4.1
0.2
311
312
1
*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 2015 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 2015 model year. Negative values
indicate over-compliance with the standards, or compliance values that are lower than the
standard by the stated value. Positive values are thus an indication of compliance values that
exceed (i.e., do not meet) the applicable standards. Kia, for example, generated a 2015 model
year deficit because their overall compliance value of 259 g/mi is above their fleet-wide standard
of 247 g/mi. Ford, on the other hand, reported net credits based on a compliance value of 284
g/mi, 8 g/mi lower than their fleet-wide standard of 292 g/mi. Note, however, that the generation
of a net deficit in the 2015 model year by any manufacturer does not necessarily indicate that the
manufacturer has failed to comply with the 2015 model year standards. Kia, for example, will
offset their 2015 deficit by using credits generated in previous model years, thereby complying
with the 2015 standards.48 The final row of Table 3-35 shows the conclusion that manufacturers
over-complied with the 2015 model year standards by 7 g/mi. A comparison of the values in the
three previous tables to EPA projections for these values is in Appendix A.49
48 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.
49 EPA projections are from the previously-referenced rulemakings from May 7, 2010 and October 15, 2012.
63
-------
Table 3-35. 2015 Model Year Compliance Summary by Manufacturer and Fleet (g/mi)
Manufacturer
Compliance Value
Standard
Net Compliance
Cars
Trucks
All
Cars
Trucks
All
Cars
Trucks
All
BMW
244
300
257
244
301
257
0
-1
0
FCA
246
312
291
247
307
288
-1
5
3
Ford
237
321
284
245
329
292
-8
-8
-8
GM
246
332
295
244
336
296
2
-4
-1
Honda
213
276
237
236
293
258
-23
-17
-21
Hyundai
239
314
244
246
285
249
-7
29
-5
Jaguar Land Rover
308
315
313
257
338
322
50
-24
-9
Kia
254
319
259
241
308
247
13
11
12
Mazda
217
285
238
241
285
254
-24
0
-17
Mercedes
256
329
284
249
311
273
7
18
11
Mitsubishi
215
254
228
225
273
241
-10
-19
-13
Nissan
209
291
235
239
300
258
-30
-9
-23
Subaru
238
244
243
234
276
265
4
-32
-23
Tesla
-6
0
-6
276
0
276
-282
0
-282
Toyota
215
323
265
239
305
269
-24
18
-5
Volvo
246
324
277
247
325
277
-1
-1
-1
Fleet Total
230
311
267
241
312
274
-11
-1
-7
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance data, in
the 2015 model year Volkswagen had net compliance values of 0,14, and 3 g/mi for cars, trucks, and all vehicles,
respectively. Should the investigation and corrective actions yield different CO2 data, the revised data will be used in
future reports.
64
-------
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 2015 model year are shown in
Table 4-1.50 As of the close of the 2015 model year, almost 19 million Megagrams of CO2
credits had changed hands, almost doubling since publication of the 2014 model year report.
BMW and GM were new entrants in the buyer's market, and Coda both entered the credit
seller's market and abandoned the automotive manufacturing business, selling their remaining
credits while under Chapter 11 bankruptcy. 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
511 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.
65
-------
reported to EPA as late as the reporting deadline for the 2021 model year, and those 2010 credits
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.
66
-------
Table 4-1. Cumulative Reported Credit Sales and Purchases (Mg)
Manufacturer
2010
2011
Model Year
2012
"Vintage"
2013
2014
2015
Total
T3
01
Coda
-
-
(5,524)
(1,727)
-
-
(7,251)
3
¦Q
Honda
(11,290,234)
-
-
-
-
-
(11,290,234)
5
w
Nissan
(200,000)
(1,342,683)
(250,000)
(1,000,000)
-
-
(2,792,683)
T3
01
Tesla
(35,580)
(14,192)
(177,941)
(1,049,384)
(1,020,296)
(1,337,853)
(3,635,246)
Toyota
(2,507,000)
-
-
-
(831,358)
-
(3,338,358)
BMW
2,000,000
-
-
-
-
-
2,000,000
T3
Ferrari
265,000
-
-
-
-
-
265,000
01
'5
O"
FCA
11,332,234
500,000
-
1,049,384
1,020,296
1,337,853
15,239,767
u
<
i/i
01
u
GM
Jaguar Land
Rover
McLaren
-
39,063
3,620
5,524
1,727
831,358
-
7,251
39,063
3,620
Mercedes
43,580
814,192
427,941
1,000,000
2,677,713
67
-------
5. Compliance Status After the 2015 Model Year
Based on the information reported to EPA, the vast majority of manufacturers have successfully
demonstrated compliance with the 2012-2015 model year standards and are carrying a positive
credit balance into the 2016 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 2012-2015 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 2009-2015 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.
68
-------
Table 5-1. Cumulative Credit Status After the 2015 Model Year (Mg)
Early Credits (2009-2011)
2012
2013
2014
2015
Total Carried
Forward to
2016
Manufacturer
Earned
Bought,
Sold, or
Expired
Earned
Bought or
Sold
Earned
Bought,
Sold, or
Forfeited
Earned
Bought or
Sold
Earned
Bought or
Sold
Toyota
80,435,498
(32,030,399)
13,163,009
0
9,885,788
0
9,817,927
(831,358)
2,555,902
0
82,996,367
Honda
35,842,334
(25,423,587)
7,789,618
0
7,078,795
0
6,245,702
0
6,814,659
0
38,347,521
GM
24,564,829
(6,473,623)
2,872,354
5,524
1,748,357
1,727
7,668,105
0
673,227
0
31,060,500
Ford
16,075,888
(5,882,011)
4,641,115
0
7,785,193
0
4,794,878
0
3,189,084
0
30,604,147
Nissan
18,131,200
(9,732,807)
(729,937)
(250,000)
5,190,521
(1,000,000)
4,859,073
0
8,093,926
0
24,561,976
FCA
10,411,321
11,832,234
(1,221,514)
0
(1,003,146)
1,049,384
(45,458)
1,020,296
(1,462,661)
1,337,853
21,918,309
Hyundai
14,007,495
(4,481,690)
3,535,510
0
5,777,836
(169,775)
1,079,030
0
589,757
0
20,338,163
Subaru
5,755,171
(491,789)
646,317
0
1,444,372
0
2,882,640
0
3,044,329
0
13,281,040
Mazda
5,482,642
(1,340,917)
734,887
0
786,431
0
1,547,009
0
970,540
0
8,180,592
Kia
10,444,192
(2,324,161)
1,303,379
0
1,330,236
(123,956)
(810,614)
0
(1,645,415)
0
8,173,661
BMW
1,004,292
2,000,000
(287,861)
0
(259,619)
0
1,075,752
0
26,118
0
3,558,682
Mitsubishi
1,449,336
(583,146)
57,837
0
58,209
0
351,031
0
348,232
0
1,681,499
Mercedes
378,272
1,249,772
(748,793)
427,941
(377,880)
1,000,000
(401,140)
0
(837,315)
0
629,434
Suzuki
876,650
(265,311)
(127,699)
0
(55,398)
0
0
0
0
0
428,242
Fisker
0
0
46,694
0
0
0
0
0
0
0
46,694
BYD Motors
0
0
595
0
1,681
0
2,548
0
0
0
4,824
Tesla
49,772
(49,772)
178,517
(177,941)
1,049,384
(1,049,384)
1,020,296
(1,020,296)
1,337,853
(1,337,853)
576
Volvo
730,187
0
(175,195)
0
(297,006)
0
(183,695)
0
10,872
0
0
Coda
0
0
5,524
(5,524)
1,727
(1,727)
0
0
0
0
0
Jaguar Land
Rover
0
39,063
(488,109)
0
(716,448)
0
(90,192)
831,358
135,773
0
(288,555)
Fleet Total
225,642,411
(73,689,524)
31,155,265
0
39,366,665
(293,731)
39,710,332
0
23,729,218
0
285,523,672
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance data, Volkswagen earned a deficit of 385,236 Mg of in model
year 2015 and will carry 5,517,054 Mg into model year 2016. Should the investigation and corrective actions yield different C02 data, the revised data will be used in future
reports.
*Forfeited per the requirements of a federal Consent Decree.
69
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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.51 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:
Here, the manufacturer
would have 1000 Mg of
2012 credits
2012 Credits 2013 Credits
Fleet (Mg) (Mg)
Cars 1500 1000
Trucks -500 -1000
Total (1000) 0
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:
Here, the
manufacturer would
have 1000 Mg of 2013
2012 Credits 2013 Credits
Fleet (Mg)
Cars 1500
Trucks -500
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
51 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).
70
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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 2016 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 carried a positive balance into
the 2015 model year, to which they added some credits reported from the 2015 model year. 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. In model year 2015, 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).
71
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Table 5-2. Credits Available After the 2015 Model Year, Reflecting Trades & Transfers (Mg)
Total Carried
Forward to
Manufacturer
2010
2011
2012
2013
2014
2015
2016
Toyota
27,280,612
14,651,963
13,163,009
10,552,864
10,121,832
7,226,087
82,996,367
Honda
2,892,195
7,526,552
7,789,618
7,078,795
6,245,702
6,814,659
38,347,521
GM
10,494,759
6,184,049
2,877,878
2,584,107
7,668,105
1,251,602
31,060,500
Ford
7,416,966
2,776,911
4,641,115
7,785,193
4,794,878
3,189,084
30,604,147
Nissan
5,581,739
510,066
989,226
4,510,993
4,876,026
8,093,926
24,561,976
FCA
13,801,905
3,091,974
31,340
1,484,694
1,957,144
1,551,252
21,918,309
Hyundai
5,118,969
4,012,969
3,535,510
5,613,813
1,197,521
859,381
20,338,163
FCA
11,837,685
2,605,453
0
1,366,852
1,957,144
1,551,252
19,318,386
Subaru
2,080,439
2,876,413
646,317
1,487,331
3,001,354
3,189,186
13,281,040
Mazda
3,201,708
925,179
749,725
786,431
1,547,009
970,540
8,180,592
Kia
1,006,457
4,657,545
1,303,379
1,206,280
0
0
8,173,661
BMW
2,141,255
315,557
0
0
1,075,752
26,118
3,558,682
Mitsubishi
521,776
302,394
67,976
90,090
351,031
348,232
1,681,499
Mercedes
0
0
0
629,434
0
0
629,434
Suzuki
329,382
98,860
0
0
0
0
428,242
Fisker
0
0
46,694
0
0
0
46,694
BYD Motors
2,276
0
0
0
2,548
0
4,824
Tesla
0
0
576
0
0
0
576
Coda
0
0
0
0
0
0
0
Volvo
0
0
0
0
0
0
0
Jaguar Land
Rover
0
0
0
0
(134,941)
(153,614)
(288,555)
Fleet Total
84,329,968
49,316,969
35,916,441
44,029,094
42,780,363
33,325,297
285,523,672
Note: Volkswagen is not included in this table due to an ongoing investigation. Based on the initial compliance data, Volkswagen
will carry 4,224,082 Mg into model year 2016. Should the investigation and corrective actions yield different C02 data, the revised data will
be used in future reports.
72
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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.52 53 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 AJC systems across the fleet,
resulting in reductions ranging from 3.5 g/mi in 2012 and increasing to over 20 g/mi late in the
program. As shown in Table A-l, we projected that manufacturers would start with a 2-cycle
tailpipe value of 277 g/mi in the 2015 model year, reducing that by total credits and incentives of
about 14 g/mi, thus yielding a net compliance value of 263 g/mi. 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 C02-equivalent credits as a result of using this flexibility, thus there is no net
impact on the program.
52 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.
53 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.
73
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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 CO2 Performance in Rulemaking Analyses for the Combined
Passenger Car and Light Truck Fleet (g/mi)
Model
Year
2-Cycle
Tailpipe
Emissions
FFV
Credit
A/C
Credit
TLAAS
Credit
Off-
Cycle
Credit
N20&
ch4
Deficit
Compliance
Standard
2012
307
6.5
3.5
1.2
0.0
N/A
295
295
2013
298
5.8
5.0
0.9
0.0
N/A
286
286
2014
290
5.0
7.5
0.6
0.0
N/A
276
276
2015
277
3.7
10.0
0.3
0.0
N/A
263
263
2016
261
0.0
10.6
0.1
0.5
N/A
250
250
2017
256
0.0
12.5
0.0
0.6
N/A
243
243
2018
249
0.0
14.9
0.0
0.8
N/A
234
234
2019
242
0.0
17.5
0.0
0.9
N/A
223
223
2020
234
0.0
19.2
0.0
1.0
N/A
214
214
2021
222
0.0
20.8
0.0
1.1
N/A
200
200
2022
212
0.0
20.8
0.0
1.4
N/A
190
190
2023
203
0.0
20.8
0.0
1.7
N/A
181
181
2024
194
0.0
20.6
0.0
1.9
N/A
172
172
2025
186
0.0
20.6
0.0
2.3
N/A
163
163
74
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Table A-2. Projected CO2 Performance in Rulemaking Analyses for Passenger Cars
(g/mi)
2-Cycle
Off-
N20&
Model
Tailpipe
FFV
A/C
TLAAS
Cycle
ch4
Year
Emissions
Credit
Credit
Credit
Credit
Deficit
Compliance
Standard
2012
N/A
N/A
N/A
N/A
N/A
N/A
263
263
2013
N/A
N/A
N/A
N/A
N/A
N/A
256
256
2014
N/A
N/A
N/A
N/A
N/A
N/A
247
247
2015
N/A
N/A
N/A
N/A
N/A
N/A
236
236
2016
235
0.0
10.2
0.0
0.4
N/A
225
225
2017
226
0.0
12.8
0.0
0.5
N/A
213
213
2018
218
0.0
14.3
0.0
0.6
N/A
203
203
2019
210
0.0
15.8
0.0
0.7
N/A
193
193
2020
201
0.0
17.3
0.0
0.8
N/A
183
183
2021
193
0.0
18.8
0.0
0.8
N/A
173
173
2022
184
0.0
18.8
0.0
0.9
N/A
164
164
2023
177
0.0
18.8
0.0
1.0
N/A
157
157
2024
170
0.0
18.8
0.0
1.1
N/A
150
150
2025
163
0.0
18.8
0.0
1.4
N/A
143
143
Table A-3. Projected CO2 Performance in Rulemaking Analyses for Light Trucks
(g/mi)
2-Cycle
Off-
N20&
Model
Tailpipe
FFV
A/C
TLAAS
Cycle
ch4
Year
Emissions
Credit
Credit
Credit
Credit
Deficit
Compliance
Standard
2012
N/A
N/A
N/A
N/A
N/A
N/A
346
346
2013
N/A
N/A
N/A
N/A
N/A
N/A
337
337
2014
N/A
N/A
N/A
N/A
N/A
N/A
326
326
2015
N/A
N/A
N/A
N/A
N/A
N/A
312
312
2016
310
0.0
11.4
0.0
0.7
N/A
298
298
2017
308
0.0
12.0
0.0
0.9
N/A
295
295
2018
304
0.0
16.0
0.0
1.0
N/A
287
287
2019
299
0.0
20.6
0.0
1.2
N/A
278
278
2020
294
0.0
22.5
0.0
1.4
N/A
270
270
2021
276
0.0
24.4
0.0
1.5
N/A
250
250
2022
264
0.0
24.4
0.0
2.2
N/A
238
238
2023
253
0.0
24.4
0.0
2.9
N/A
226
226
2024
242
0.0
24.4
0.0
3.6
N/A
214
214
2025
233
0.0
24.4
0.0
4.3
N/A
204
204
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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 2012-2015 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 per 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 g/mi, whereas the same metric is shown as 302 g/mi 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 g/mi) and model
year 2013 (by 3 g/mi). This gap grew further in the 2014 and 2015 model years, to 8 and then 9
g/mi, 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 higher targets, actual industry-wide overall
compliance values have been consistently lower than projected in the EPA rulemaking analyses
for the first three years of the program, and in 2015 the actual compliance value was essentially
the same as projected for model year 2015. Actual industry-wide 2-cycle tailpipe emissions
performance was 8-9 g/mi lower than the projected values in the 2012 and 2013 model years,
and equal to the projected value in the 2014 model year. However, in the 2015 model year, 2-
cycle emissions exceeded our projections by 5 g/mi. In model year 2015, flexible fuel and off-
cycle credits were higher than projected, while AJC credits were slightly lower than projected.
Most important, based on these 2-cycle emissions values, it is apparent that the cumulative
impact of the first four years of the program is that aggregate CO2 emissions reductions have
been slightly larger than projected by EPA, i.e., the lower-than-projected values in model years
2012 and 2013 more than offset the higher-than-projected value in model year 2015.
76
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Tables A-5 and A-6 provide comparative data separately for cars and trucks for the 2012-2015
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 lower (6 g/mi in 2015). The actual targets were also higher than the projected targets for the
truck fleet until the 2015 model year, when the actual fleet value equals the projected value. For
trucks, however, actual compliance values were slightly higher than projected for the first two
years, but have slightly outperformed the projected values in model years 2014 and 2015.
77
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Table A-4. Actual and Projected CO2 Values, Cars and Trucks Combined (g/mi)
ACTUAL
PROJECTED
Off-
N2O&
Off-
N20&
Model
2-Cycle
FFV
A/C
TLAAS
Cycle
CH4
2-Cycle
FFV
A/C
TLAAS
Cycle
CH4
Year
Tailpipe
Credit
Credit
Credit
Credit
Deficit
Compliance
Target
Tailpipe
Credit
Credit
Credit
Credit
Deficit
Compliance
Target
2012
298
7.8
6.0
0.6
0.2
0.2
284
296
307
6.5
3.5
1.2
0.0
N/A
295
295
2013
290
7.5
6.8
0.5
0.2
0.3
276
289
298
5.8
5.0
0.9
0.0
N/A
286
286
2014
290
8.5
8.3
0.2
2.3
0.2
271
284
290
5.0
7.5
0.6
0.0
N/A
276
276
2015
282
6.2
9.2
0.3
2.9
0.2
264
271
277
3.7
10.0
0.3
0.0
N/A
263
263
Table A-5. Actual and Projected CO2 Values, Passenger Cars (g/mi)
ACTUAL
PROJECTED
Off-
N2O&
Off-
N2O&
Model
2-Cycle
FFV
A/C
TLAAS
Cycle
ch4
2-Cycle
FFV
A/C
TLAAS
Cycle
CH4
Year
Tailpipe
Credit
Credit
Credit
Credit
Deficit
Compliance
Target
Tailpipe
Credit
Credit
Credit
Credit
Deficit
Compliance
Target
2012
259
4.0
5.3
0.2
0.1
0.1
249
267
N/A
N/A
N/A
N/A
N/A
N/A
263
263
2013
251
4.0
6.2
0.2
0.1
0.3
241
261
N/A
N/A
N/A
N/A
N/A
N/A
256
256
2014
250
4.6
7.3
0.1
1.5
0.3
237
253
N/A
N/A
N/A
N/A
N/A
N/A
247
247
2015
243
3.1
7.9
0.0
1.9
0.1
230
241
N/A
N/A
N/A
N/A
N/A
N/A
236
236
Table A-6. Actual and Projected CO2 Values, Light Trucks (g/mi)
ACTUAL
PROJECTED
Off-
N2O&
Off-
N20&
Model
2-Cycle
FFV
A/C
TLAAS
Cycle
CH4
2-Cycle
FFV
A/C
TLAAS
Cycle
ch4
Year
Tailpipe
Credit
Credit
Credit
Credit
Deficit
Compliance
Target
Tailpipe
Credit
Credit
Credit
Credit
Deficit
Compliance
Target
2012
369
14.5
7.2
1.3
0.5
0.3
347
349
N/A
N/A
N/A
N/A
0.0
N/A
346
346
2013
360
13.7
7.9
1.1
0.4
0.3
338
339
N/A
N/A
N/A
N/A
0.0
N/A
337
337
2014
349
14.3
9.6
0.3
3.4
0.1
322
330
N/A
N/A
N/A
N/A
0.0
N/A
326
326
2015
336
10.3
10.9
0.6
4.1
0.2
311
312
N/A
N/A
N/A
N/A
0.0
N/A
312
312
78
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Appendix B: Three-Year Vehicle Production Volume & Market Share
Table B-l. Vehicle Production Volume by Manufacturer and Vehicle Category
Manufacturer
Model Year 2013
Model Year 2014
Model Year 2015
Car
Truck
All
Car
Truck
All
Car
Truck
All
BMW
303,319
98,969
402,288
297,388
81,938
379,326
338,704
87,135
425,839
BYD Motors
32
-
32
50
-
50
Coda
37
-
37
FCA
654,845
852,653
1,507,498
648,377
1,446,365
2,094,742
769,687
1,416,487
2,186,174
Ford
1,166,975
1,234,018
2,400,993
1,258,732
1,075,502
2,334,234
888,604
972,891
1,861,495
GM
1,432,131
913,765
2,345,896
1,556,701
1,164,610
2,721,311
1,331,442
1,525,017
2,856,459
Honda
1,021,800
472,569
1,494,369
868,337
577,828
1,446,165
1,020,610
556,864
1,577,474
Hyundai
1,061,950
38,073
1,100,023
509,920
38,441
548,361
604,286
41,839
646,125
Jaguar Land Rover
16,051
47,532
63,583
12,323
55,233
67,556
15,600
54,435
70,035
Kia
611,414
16,980
628,394
507,630
28,757
536,387
626,285
49,219
675,504
Mazda
164,862
61,093
225,955
217,333
78,826
296,159
207,100
78,793
285,893
Mercedes
207,957
89,041
296,998
278,126
92,312
370,438
231,899
123,727
355,626
Mitsubishi
32,654
13,754
46,408
60,679
29,828
90,507
91,822
39,366
131,188
Nissan
919,647
372,970
1,292,617
935,995
389,639
1,325,634
1,216,392
481,583
1,697,975
PorscheA
22,021
19,461
41,482
Subaru
145,705
211,326
357,031
109,078
356,818
465,896
175,352
447,383
622,735
Suzuki
10,427
1,116
11,543
Tesla
17,813
-
17,813
17,791
-
17,791
24,322
-
24,322
Toyota
1,347,436
915,658
2,263,094
1,420,641
772,809
2,193,450
1,524,190
1,127,056
2,651,246
Volkswagen
559,448
68,414
627,862
487,086
103,524
590,610
487,108
112,382
599,490
Volvo
42,072
31,282
73,354
16,526
15,063
31,589
43,901
24,284
68,185
All
9,738,596
5,458,674
15,197,270
9,202,713
6,307,493
15,510,206
9,597,304
7,138,461
16,735,765
A Aggregated with Volkswagen starting with the 2014 model year.
79
-------
Table B-2. Vehicle Category Market Share by Manufacturer and Model Year (%)
Manufacturer
2012
2013
2014
2015
Car% Truck %
Car% Truck %
Car% Truck %
Car% Truck %
BMW
74
26
75
25
78
22
80
20
BYD Motors
100
0
100
0
100
0
Coda
100
0
100
0
FCA
35
65
43
57
31
69
35
65
Fisker
100
0
Ford
60
40
49
51
54
46
48
52
GM
61
39
61
39
57
43
47
53
Honda
68
32
68
32
60
40
65
35
Hyundai
93
7
97
3
93
7
94
6
Jaguar Land Rover
23
77
25
75
18
82
22
78
Kia
90
10
97
3
95
5
93
7
Mazda
76
24
73
27
73
27
72
28
Mercedes
68
32
70
30
75
25
65
35
Mitsubishi
81
19
70
30
67
33
70
30
Nissan
73
27
71
29
71
29
72
28
Porsche
57
43
53
47
Subaru
39
61
41
59
23
77
28
72
Suzuki
81
19
90
10
Tesla
100
0
100
0
100
0
100
0
Toyota
64
36
60
40
65
35
57
43
Volkswagen
89
11
89
11
82
18
81
19
Volvo
73
27
57
43
52
48
64
36
All
64
36
64
36
59
41
57
43
80
-------
Appendix C: 2012-2014 Model Year Compliance Values
Table C-l. 2012 Compliance Values - Combined Passenger Car & Light Truck
Fleet (g/mi)
Credits (g/mi)
ch4&
2-Cycle
Off-
N20
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
302
0
8
0
0
294
BYD Motors
0
0
0
0
0
0
Coda
0
0
0
0
0
0
Ferrari
494
0
10
0
0
484
FCA
357
18
10
2
0
327
Fisker
146
0
0
0
0
146
Ford
315
14
6
0
1
295
GM
331
16
8
0
0
307
Honda
266
0
3
0
0
263
Hyundai
249
0
4
0
0
244
Jaguar Land Rover
426
0
7
0
0
418
Kia
266
0
5
0
0
261
Mazda
263
0
0
0
0
263
Mercedes
343
13
10
0
0
320
Mitsubishi
267
0
0
0
0
267
Nissan
295
4
3
0
0
288
Porsche
342
0
0
0
0
342
Subaru
282
0
2
0
0
280
Suzuki
287
0
0
0
0
287
Tesla
0
0
6
0
0
-6
Toyota
273
4
7
0
0
263
Volvo
311
0
11
0
0
300
Fleet Total
302
8
6
0
0
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 CH4
and N20 deficit of 2 g/mi, and a compliance value of 276 g/mi. Should the investigation and corrective actions
yield different C02 data, the revised data will be used in future reports.
81
-------
Table C-2. 2012 Compliance Values - Passenger Car Fleet (g/mi)
Manufacturer
2-Cycle
Tailpipe
Credits (g/mi)
ch4&
NzO
Deficit
Compliance
Value
FFV
A/C
Off-
Cycle
BMW
277
0
7
0
0
270
BYD Motors
0
0
0
0
0
0
Coda
0
0
0
0
0
0
Ferrari
494
0
10
0
0
484
FCA
300
13
9
1
0
277
Fisker
146
0
0
0
0
146
Ford
261
9
5
0
0
248
GM
283
11
8
0
0
264
Honda
237
0
2
0
0
235
Hyundai
243
0
4
0
0
239
Jaguar Land Rover
376
0
5
0
0
371
Kia
258
0
5
0
0
253
Mazda
241
0
0
0
0
241
Mercedes
316
11
9
0
0
295
Mitsubishi
262
0
0
0
0
262
Nissan
258
0
2
0
0
256
Porsche
325
0
0
0
0
325
Subaru
257
0
2
0
0
255
Suzuki
267
0
0
0
0
267
Tesla
0
0
6
0
0
-6
Toyota
221
0
7
0
0
214
Volvo
297
0
11
0
0
286
Fleet Total
259
4
5
0
0
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. Should the
investigation and corrective actions yield different C02 data, the revised data will be used in future reports.
82
-------
Table C-3. 2012 Compliance Values - Light Truck Fleet (g/mi)
Manufacturer
2-Cycle
Tailpipe
Credits (g/mi)
ch4&
N20
Deficit
Compliance
Value
FFV
A/C
Off-
Cycle
BMW
363
0
11
0
1
353
FCA
384
21
10
2
0
351
Ford
385
21
8
0
1
357
GM
397
23
8
0
0
366
Honda
320
0
5
0
0
315
Hyundai
312
0
7
0
0
305
Jaguar Land Rover
439
0
8
0
0
431
Kia
324
0
3
0
0
321
Mazda
324
0
0
0
0
324
Mercedes
393
15
11
0
0
367
Mitsubishi
283
0
0
0
0
283
Nissan
382
15
4
0
0
363
Porsche
362
0
0
0
0
362
Subaru
296
0
2
0
0
294
Suzuki
361
0
0
0
0
361
Toyota
354
9
6
0
0
339
Volvo
343
0
12
0
0
331
Fleet Total
369
14
7
0
0
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. Should the
investigation and corrective actions yield different C02 data, the revised data will be used in future reports.
83
-------
Table C-4. 2013 Compliance Values - Combined Passenger Car & Light Truck
Fleet (g/mi)
Manufacturer
2-Cycle
Tailpipe
Credits (g/mi)
ch4&
NzO
Deficit
Compliance
Value
FFV
A/C
Off-
Cycle
Aston Martin
444
0
6
0
0
438
BMW
292
0
9
0
0
283
BYD Motors
0
0
0
0
0
0
Coda
0
0
0
0
0
0
Ferrari
475
0
10
0
0
465
FCA
344
17
10
2
0
314
Ford
321
15
8
0
1
299
GM
325
15
9
0
0
301
Honda
257
0
4
0
1
254
Hyundai
241
0
5
0
0
236
Jaguar Land Rover
399
1
8
0
0
390
Kia
254
0
5
0
0
249
Lotus
334
0
0
0
0
334
Mazda
251
0
0
0
0
251
McLaren
374
0
0
0
0
374
Mercedes
321
12
10
0
0
299
Mitsubishi
258
0
0
0
0
258
Nissan
266
3
4
0
0
260
Porsche
336
0
0
0
0
336
Subaru
264
0
2
0
0
262
Suzuki
273
0
0
0
0
273
Tesla
0
0
6
0
0
-6
Toyota
278
4
7
0
0
268
Volvo
318
0
10
0
0
307
Fleet Total
294
8
7
0
0
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 N20 deficit of 2 g/mi, and a compliance value of 266 g/mi. Should the investigation and corrective actions
yield different C02 data, the revised data will be used in future reports.
84
-------
Table C-5. 2013 Compliance Values - Passenger Car Fleet (g/mi)
Manufacturer
2-Cycle
Tailpipe
Credits (g/mi)
CH4&N20
Deficit
Compliance
Value
FFV
A/C
Off-Cycle
Aston Martin
444
0
6
0
0
438
BMW
271
0
8
0
0
263
BYD Motors
0
0
0
0
0
0
Coda
0
0
0
0
0
0
Ferrari
475
0
10
0
0
465
FCA
289
12
10
1
0
267
Ford
256
9
7
0
0
240
GM
273
10
9
0
0
254
Honda
228
0
3
0
1
227
Hyundai
238
0
5
0
0
233
Jaguar Land Rover
347
5
5
0
0
337
Kia
252
0
5
0
0
247
Lotus
334
0
0
0
0
334
Mazda
232
0
0
0
0
232
McLaren
374
0
0
0
0
374
Mercedes
296
12
9
0
0
275
Mitsubishi
254
0
0
0
0
254
Nissan
232
0
4
0
0
228
Porsche
309
0
0
0
0
309
Subaru
254
0
1
0
0
253
Suzuki
266
0
0
0
0
266
Tesla
0
0
6
0
0
-6
Toyota
224
0
7
0
0
217
Volvo
292
0
10
0
0
282
Fleet Total
251
4
6
0
0
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 CH4 and
N20 deficit of 2 g/mi, and a compliance value of 260 g/mi. Should the investigation and corrective actions yield different C02
data, the revised data will be used in future reports.
85
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Table C-6. 2013 Compliance Values - Light Truck Fleet (g/mi)
Credits (g/mi)
ch4&
2-Cycle
Off-
N20
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
346
0
11
0
0
335
FCA
380
21
11
3
0
345
Ford
375
20
8
0
1
348
GM
395
22
9
0
0
364
Honda
312
0
5
0
0
307
Hyundai
317
0
7
0
0
310
Jaguar Land Rover
414
0
9
0
0
405
Kia
301
0
8
0
0
293
Mazda
296
0
0
0
0
296
Mercedes
371
12
12
0
0
347
Mitsubishi
267
0
0
0
0
267
Nissan
340
8
4
0
0
328
Porsche
363
0
0
0
0
363
Subaru
270
0
2
0
0
268
Suzuki
330
0
0
0
0
330
Toyota
347
8
7
0
0
332
Volvo
348
0
11
0
0
337
Fleet Total
360
14
8
0
0
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. Should the
investigation and corrective actions yield different C02 data, the revised data will be used in future reports.
86
-------
Table C-7. 2014 Compliance Values - Combined Passenger Car & Light Truck
Fleet (g/mi)
Manufacturer
2-Cycle
Tailpipe
Credits (g/mi)
ch4&
N20
Deficit
Compliance
Value
FFV
A/C
Off-
Cycle
Aston Martin
454
0
6
0
0
448
BMW
270
0
9
4
1
257
BYD Motors
0
0
0
0
0
0
Ferrari
484
0
11
0
0
473
FCA
346
17
14
6
0
309
Ford
315
14
9
3
0
289
GM
314
14
10
1
0
288
Honda
259
0
4
1
1
254
Hyundai
253
0
5
1
0
247
Jaguar Land Rover
369
15
21
5
0
328
Kia
269
0
5
1
0
263
Lotus
338
0
0
0
0
338
Mazda
240
0
0
0
0
240
McLaren
372
0
0
0
0
372
Mercedes
309
12
11
2
0
284
Mitsubishi
236
0
0
0
0
236
Nissan
263
3
6
2
0
253
Subaru
253
0
2
0
0
251
Tesla
0
0
6
0
0
-6
Toyota
274
6
8
3
0
258
Volvo
319
0
8
0
0
311
Fleet Total
294
9
8
2
0
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 9 g/mi, an A/C credit of 8 g/mi, a CH4
and N20 deficit of 2 g/mi, and a compliance value of 274 g/mi. Should the investigation and corrective actions
yield different C02 data, the revised data will be used in future reports.
87
-------
Table C-8. 2014 Compliance Values - Passenger Car Fleet (g/mi)
Manufacturer
2-Cycle
Tailpipe
Credits (g/mi)
CH4&N2O
Deficit
Compliance
Value
FFV
A/C
Off-Cycle
Aston Martin
454
0
6
0
0
448
BMW
256
0
8
3
1
245
BYD Motors
0
0
0
0
0
0
Ferrari
484
0
11
0
0
473
FCA
298
12
13
3
0
270
Ford
256
9
8
2
0
237
GM
266
10
9
1
0
246
Honda
228
0
3
1
1
226
Hyundai
247
0
5
1
0
241
Jaguar Land Rover
330
1
12
2
0
316
Kia
265
0
5
1
0
259
Lotus
338
0
0
0
0
338
Mazda
220
0
0
0
0
220
McLaren
372
0
0
0
0
372
Mercedes
285
11
10
3
0
262
Mitsubishi
224
0
0
0
0
224
Nissan
229
0
5
1
0
222
Subaru
250
0
1
0
0
249
Tesla
0
0
6
0
0
-6
Toyota
221
0
8
2
0
211
Volvo
288
0
8
0
0
280
Fleet Total
250
5
7
1
0
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 5 g/mi, an A/C credit of 7 g/mi, a CH4 and
N2O deficit of 1 g/mi, and a compliance value of 237 g/mi. Should the investigation and corrective actions yield different C02
data, the revised data will be used in future reports.
88
-------
Table C-9. 2014 Compliance Values - Light Truck Fleet (g/mi)
Credits (g/mi)
ch4&
2-Cycle
Off-
N20
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
312
0
11
6
1
295
FCA
364
19
14
7
0
324
Ford
375
20
10
3
0
342
GM
369
19
11
2
0
337
Honda
299
0
5
2
0
292
Hyundai
325
0
7
4
0
315
Jaguar Land Rover
377
18
22
6
0
331
Kia
330
0
5
1
0
325
Mazda
287
0
0
0
0
287
Mercedes
372
17
12
1
0
342
Mitsubishi
256
0
0
0
0
256
Nissan
335
8
6
2
0
318
Subaru
254
0
2
0
0
252
Toyota
358
15
7
3
0
333
Volvo
348
0
8
0
0
340
Fleet Total
360
14
8
0
0
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 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. Should the
investigation and corrective actions yield different C02 data, the revised data will be used in future reports.
89
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Appendix D: 2015 Model Year Report Credits and
Deficits
Table D-l.
2015 Model Year Reported Credits and Deficits
Fleet Fleet
Average Standard
Production
Manufacturer
Pathway
Fleet
Credit Type
(g/mi) (g/mi)
Volume
Credits (Mg)
BMW
Primary
Car
Fleet Average
256 244
338,704
(793,640)
A/C Leakage
298,951
A/C Efficiency
274,938
Off-Cycle
233,580
N2O Deficit
(11,894)
CH4 Deficit
(1,497)
Advanced
Technology
11,386
Truck
Fleet Average
316 301
87,135
(295,211)
A/C Leakage
136,661
A/C Efficiency
84,627
Off-Cycle
128,762
N20 Deficit
(25,900)
CH4 Deficit
(3,259)
FCA
Primary
Car
Fleet Average
266 247
769,687
(2,855,551)
A/C Leakage
1,904,927
A/C Efficiency
673,129
Off-Cycle
490,904
CH4 Deficit
(10)
Advanced
Technology
7,825
Truck
Fleet Average
339 307
1,416,487
(10,237,915)
A/C Leakage
4,672,447
A/C Efficiency
1,507,070
Off-Cycle
2,385,988
CH4 Deficit
(3,650)
Ford
Primary
Car
Fleet Average
250 245
888,604
(867,562)
A/C Leakage
1,087,338
A/C Efficiency
488,390
Off-Cycle
670,668
N20 Deficit
(6,793)
CH4 Deficit
(8,804)
Advanced
Technology
17,384
Truck
Fleet Average
338 329
972,891
(1,977,678)
90
-------
Table D-l. 2015 Model Year Reported Credits and Deficits
Fleet Fleet
Average Standard
Manufacturer Pathway Fleet Credit Type (g/mi) (g/mi)
Production
Volume
Credits (Mg)
A/C Leakage
1,685,004
A/C Efficiency
678,740
Off-Cycle
1,523,766
N20 Deficit
(30,635)
CH4 Deficit
(53,350)
GM Primary
Car
Fleet Average
258
244
1,331,442
(3,639,758)
A/C Leakage
1,643,372
A/C Efficiency
874,646
Off-Cycle
546,666
N20 Deficit
(1,371)
CH4 Deficit
(1,930)
Advanced
Technology
14,847
Truck
Fleet Average
347
336
1,525,017
(3,788,928)
A/C Leakage
2,274,024
A/C Efficiency
1,502,958
Off-Cycle
1,275,676
CH4 Deficit
(12,128)
Honda Primary
Car
Fleet Average
217
236
1,020,610
3,786,479
A/C Leakage
315,425
A/C Efficiency
292,252
Off-Cycle
283,518
N20 Deficit
(22,766)
Truck
Fleet Average
283
293
556,864
1,257,761
A/C Leakage
486,133
A/C Efficiency
268,813
Off-Cycle
219,000
N20 Deficit
(71,956)
Hyundai Primary
Car
Fleet Average
246
246
604,286
0
A/C Leakage
301,255
A/C Efficiency
391,740
Off-Cycle
166,386
Advanced
Technology
72
Truck
Fleet Average
324
285
41,839
(368,549)
A/C Leakage
33,642
A/C Efficiency
35,125
Off-Cycle
30,158
Jaguar Land
Rover
Primary Car
Fleet Average
324
257
15,581
(203,841)
91
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Table D-l. 2015 Model Year Reported Credits and Deficits
Fleet Fleet
Average Standard Production
Manufacturer Pathway
Fleet
Credit Type
(g/mi)
(g/mi)
Volume
Credits (Mg)
A/C Leakage
27,385
A/C Efficiency
15,499
Off-Cycle
7,562
Truck
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
305
293
27,470
(74,454)
104,305
34,562
32,524
TLAAS
Car
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
388
319
19
(256)
10
16
11
Truck
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
381
384
26,965
18,271
104,757
34,716
34,706
Kia Primary
Car
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Advanced
Technology
260
241
626,285
926
(2,323,527)
260,945
400,117
134,413
Truck
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
327
308
49,219
(211,220)
32,421
37,797
23,639
Mazda Primary
Car
Fleet Average
217
241
207,100
970,540
Truck
Fleet Average
285
285
78,793
0
Mercedes Primary
Car
Fleet Average
A/C Leakage
A/C Efficiency
Advanced
Technology
267
249
231,781
3,125
(814,653)
246,345
247,626
Truck
Fleet Average
A/C Leakage
A/C Efficiency
325
297
104,938
(663,651)
171,932
129,377
TLAAS
Car
Fleet Average
A/C Leakage
A/C Efficiency
377
309
118
(1,567)
102
127
Truck
Fleet Average
A/C Leakage
435
389
18,789
(195,214)
20,596
92
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Table D-l. 2015 Model Year Reported Credits and Deficits
Fleet Fleet
Average Standard Production
Manufacturer Pathway
Fleet
Credit Type
(g/mi)
(g/mi)
Volume
Credits (Mg)
A/C Efficiency
21,665
Mitsubishi Primary
Car
Fleet Average
215
225
91,822
179,295
Truck
Fleet Average
254
273
39,366
168,937
Nissan Primary
Car
Fleet Average
217
239
1,216,392
5,225,386
A/C Leakage
900,624
A/C Efficiency
717,255
Off-Cycle
385,132
N20 Deficit
(6,865)
CH4 Deficit
(81,821)
Advanced
Technology
33,242
Truck
Fleet Average
301
300
481,583
(108,773)
A/C Leakage
656,279
A/C Efficiency
229,139
Off-Cycle
313,793
N20 Deficit
(10,543)
CH4 Deficit
(125,680)
Subaru Primary
Car
Fleet Average
241
234
175,352
(239,680)
A/C Efficiency
89,553
Off-Cycle
5,270
Truck
Fleet Average
247
276
447,383
2,930,397
A/C Efficiency
242,945
Off-Cycle
15,844
Tesla Primary
Car
Fleet Average
0
276
24,322
1,310,782
A/C Efficiency
27,071
Advanced
Technology
24,322
Toyota Primary
Car
Fleet Average
225
239
1,524,190
4,166,672
A/C Leakage
1,132,635
A/C Efficiency
1,246,673
Off-Cycle
694,951
N20 Deficit
(14,844)
Advanced
Technology
Truck
Fleet Average
334
305
1,127,056
(7,382,313)
A/C Leakage
1,111,424
A/C Efficiency
926,150
Off-Cycle
683,450
N20 Deficit
(8,896)
Volvo Primary
Car
Fleet Average
254
247
43,901
(60,006)
93
-------
Table D-l.
2015 Model Year Reported Credits and Deficits
Fleet
Fleet
Average
Standard
Production
Manufacturer
Pathway
Fleet
Credit Type
(g/mi)
(g/mi)
Volume
Credits (Mg)
A/C Leakage
43,455
A/C Efficiency
21,613
Truck
Fleet Average
A/C Leakage
A/C Efficiency
327
289
12,199
(104,702)
21,491
3,858
TLAAS
Truck
Fleet Average
A/C Leakage
A/C Efficiency
339
361
12,085
60,051
21,291
3,821
94
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