Greenhouse Gas
Emission Standards for
Light-Duty Vehicles
Manufacturer Performance Report
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
Agency
EPA-420-R-18-002 January 2018
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
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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Contents
Executive Summary i
1. Introduction 1
A. Why Are We Releasing This Information? 1
B. What Data Are We Publishing? 2
C. How Can CO2 Emissions Credits Be Used? 5
D. Which Manufacturers and Vehicles Are Included in This Report? 6
1. Small Businesses 6
2. Small Volume Manufacturers 6
3. Operationally Independent Manufacturers 8
4. Aggregation of Manufacturers 8
2. Optional GHG Credits From 2009-2011 Model Years 10
3. Credits Reported From the 2012-2016 Model Years 14
A. "2-Cycle" Tailpipe CO2 Emissions 15
B. TLAAS Program Standards 18
C. Credits Based on Alternative Fuel Vehicles 23
1. Advanced Technology Vehicles 23
2. Compressed Natural Gas Vehicles 25
3. Gasoline-Ethanol Flexible Fuel Vehicles 25
D. Credits Based on Air Conditioning Systems 30
1. Air Conditioning Leakage Credits 34
2. Air Conditioning Efficiency Credits 38
E. Credits Based on "Off-Cycle" Technology 41
1. Off-Cycle Credits Based on the Menu 44
2. Off-Cycle Technology Credits Based on 5-Cycle Testing 50
3. Off-Cycle Technology Credits Based on an Alternative Methodology 51
F. Deficits Based on Methane and Nitrous Oxide Standards 52
G. 2016 Model Year Compliance Values 56
H. 2016 Model Year Footprint-Based CO2 Standards 61
I. Overall Compliance Summary 66
4. Credit Transactions 69
5. Compliance Status After the 2016 Model Year 72
Appendix A: Comparing Actual Performance to Rulemaking Projections 77
Appendix B: Vehicle Production Volume & Market Share 82
Appendix C: 2012-2015 Model Year Compliance Values 84
Appendix D: 2016 Model Year Report Credits and Deficits 96
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List of Tables and Figures
Figure ES-1. Industry Performance versus Standards in 2012-2016 Model Years iii
Figure ES-2. Manufacturer Performance and Standards in the 2016 Model Year iv
Table ES-1. Credit Balances at Conclusion of the 2016 Model Year v
Table 1-1. Aggregation of Manufacturers in the 2016 Model Year 9
Table 2-1. Total Reported Early Credits, by Manufacturer and Model Year 11
Table 2-2. Total Reported Early Credits, By Credit Category 12
Table 2-3. 2009 Model Year Credits Which Expired at End of Model Year 2014 13
Table 3-1. "2-cycle" Tailpipe CO2 Production-Weighted Fleet Average Emissions 17
Table 3-2. Production Volumes Assigned to TLAAS Standards 20
Table 3-3. Net Impact from Use of the TLAAS Program 22
Table 3-4. Production Volumes of Advanced Technology Vehicles Using Zero Grams/Mile Incentive 25
Table 3-5. Number of FFV Models by Manufacturer, 2012-2016 Model Years 28
Table 3-6. Production Volume of FFVs by Manufacturer, 2012-2016 Model Years 29
Table 3-7. Credits Accrued from Use of the FFV Incentives, 2012-2015 Model Years 30
Table 3-8. Reported A/C Credits by A/C Credit Type and Model Year 31
Table 3-9. Reported A/C Credits by Manufacturer, 2016 Model Year 32
Table 3-10. Net Impact of A/C Credits, 2012-2016 Model Years 33
Table 3-11. Production of Vehicles Using HFO-1234yf, 2013-2016 Model Years 35
Table 3-12. Reported A/C Leakage Credits by Manufacturer and Fleet, 2016 Model Year 36
Table 3-13. A/C Leakage Credits, 2012-2016 Model Years 37
Table 3-14. Reported A/C Efficiency Credits by Manufacturer and Fleet, 2016 Model Year 39
Table 3-15. A/C Efficiency Credits, 2012-2016 Model Years 40
Table 3-16. Reported Off-Cycle Technology Credits by Manufacturer and Fleet, 2016 Model Year 42
Table 3-17. Off-Cycle Technology Credits by Manufacturer and Fleet, 2012-2016 Model Years 43
Table 3-18. Reported Off-Cycle Technology Credits from the Menu 44
Table 3-19. Off-Cycle Technology Credits from the Menu by Technology, 2016 Model Year 47
Table 3-20. Percent of 2016 Model Year Vehicle Production Volume with Credits from the Menu 49
Table 3-21. Model Year 2016 Off-Cycle Technology Credits from the Menu 50
Table 3-22. Reported Off-Cycle Credits Based on 5-Cycle Testing for GM, by Model Year and Fleet 51
Table 3-23. Reported CFU and N2O Deficits by Manufacturer and Fleet, 2016 Model Year 54
Table 3-24. CFU Deficits by Manufacturer and Fleet, 2012-2016 Model Years 55
Table 3-25. N2O Deficits by Manufacturer and Fleet, 2012-2016 Model Years 55
Table 3-26. 2016 Compliance Values - Combined Passenger Car & Light Truck Fleet 57
Table 3-27. 2016 Compliance Values - Passenger Car Fleet 58
Table 3-28. 2016 Compliance Values - Light Truck Fleet 59
Table 3-29. 2012-2016 Model Year Compliance Values by Manufacturer and Fleet 60
Table 3-30. 2012-2016 Model Year CO2 Standards by Manufacturer and Fleet, 2012-2016 Model Years 63
Table 3-31. Average Footprint by Manufacturer and Fleet, 2012-2016 Model Years 65
Table 3-32. Performance & Credit Summary, 2012-2016 Model Years - Combined Cars and Trucks 66
Table 3-33. Performance & Credit Summary, 2012-2016 Model Years - Passenger Cars 67
Table 3-34. Performance & Credit Summary, 2012-2016 Model Years - Light Trucks 67
Table 3-35. 2016 Model Year Compliance Summary by Manufacturer and Fleet 68
Table 4-1. Cumulative Reported Credit Sales and Purchases 71
Table 5-1. Cumulative Credit Status After the 2016 Model Year 73
Table 5-2. Credits Available After the 2016 Model Year, Reflecting Trades & Transfers 76
Table A-l. Projected CO2 Performance in Rulemaking Analyses for the Combined Passenger Car and Light
Truck Fleet 78
Table A-2. Projected CO2 Performance in Rulemaking Analyses for Passenger Cars 79
Table A-3. Projected CO2 Performance in Rulemaking Analyses for Light Trucks 79
Table A-4. Actual and Projected CO2 Values, Cars and Trucks Combined 81
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81
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
Actual and Projected CO2 Values, Passenger Cars
Actual and Projected CO2 Values, Light Trucks
Vehicle Production Volume by Manufacturer and Vehicle Category, Last Three Years
Vehicle Category Market Share by Manufacturer and Model Year
2012 Compliance Values - Combined Passenger Car & Light Truck Fleet
2012 Compliance Values - Passenger Car Fleet
2012 Compliance Values - Light Truck Fleet
2013 Compliance Values - Combined Passenger Car & Light Truck Fleet
2013 Compliance Values - Passenger Car Fleet
2013 Compliance Values - Light Truck Fleet
2014 Compliance Values - Combined Passenger Car & Light Truck Fleet
2014 Compliance Values - Passenger Car Fleet
2014 Compliance Values - Light Truck Fleet
2015 Compliance Values - Combined Passenger Car & Light Truck Fleet
2015 Compliance Values - Passenger Car Fleet
2015 Compliance Values - Light Truck Fleet
2016 Model Year Reported Credits and Deficits
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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 2016 model year, the fifth and final year of the first
phase of the EPA GHG standards. This report includes data through the end of the 2016
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 Fiat Chrysler Automobiles based on the sale of certain 2014 through
2016 model year vehicles equipped with devices that defeat the vehicles' emission control
systems. In addition, the Department of Justice and EPA have reached a settlement with
Volkswagen over the use of defeat devices for certain 2009 through 2016 model year
vehicles. In this report, EPA uses the CO2 emissions and fuel economy data from the initial
certification of these vehicles. Should the investigation and corrective actions yield different
CO2 and fuel economy data, any relevant changes will be used in future reports. For more
1 Relevant information on the CAFE program can be found on the NHTSA website at NHTSA's CAFE Public Information
Center: http://www.nhtsa.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.
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information on actions to resolve these alleged violations, see www.epa.gov/vw and
www.epa.gov/fca.
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 ®
CrprlrK A D#»firit«;
Tran<:artinn<:
¦h M
Future Credits
& Deficits
Current Compliance
Status
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
remaining from model year 2013 after the 2016 model year would be considered out of
compliance with the 2013 model year standards. As this report will show, there are no
manufacturers that ended 2016 in this position. No manufacturer is yet out of compliance
with the GHG program in any of these first five 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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IThe auto industry generated a GHG deficit in the 2016 model
year, but all major manufacturers comply with the 2016
standards, with some companies using credits from prior years.
Overall industry performance in model year 2016 was 9 grams/mile higher than required by
the 2016 GHG emissions standard. This makes 2016 the first model year in which the
industry generated a GHG emissions deficit, after generating credits in each of the first four
years of EPA's program. The increases in stringency in the standards in the 2015 and 2016
model years were the largest increases in the first phase of EPA's GHG program; since the
2014 model year the standards have decreased by 24 grams/mile. The standards were
intentionally structured with this progression of increasing stringency, as explained in the
rulemaking. A contributing factor to the 9 gram/mile industry-wide gap between
performance and the standard in the 2016 model year was the expiration of flexible fuel
vehicle credits. Due to the credits accumulated in the previous four years and early credits
generated by some manufacturers in the 2009-2011 model years, some of which were used to
offset the 2016 deficit, the industry as a whole does not face any non-compliance issues in
the 2016 model year. See Section 3 for more detail on these values.
Figure ES-1. Industry Performance versus Standards, 2012-2016 Model Years
310
jj
E
300
290
280
1299 | •
03
270
ID
X
U? 260
250
240
•- 1292 | •
Standard
Performance
2012
2013 2014 2015
Model Year
2016
- iii -
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Eight out of the thirteen largest manufacturers generated deficits
relative to their 2016 model year standards, but used credits from
previous model years to comply.
Unlike the previous four years, in which generating credits was the norm, most large
manufacturers (with sales greater than 150,000 vehicles) generated deficits in the 2016
model year. Five of the thirteen manufacturers reported beating their standard, with
compliance margins ranging from 16 grams/mile (Honda) to 1 gram/mile (Hyundai). The
remaining eight generated deficits against their standard due to fleet GHG emissions that
were higher than the standard by amounts ranging from 10 grams/mile (Toyota) to 28
grams/mile (FCA). Note that 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 portray whether or not a manufacturer has complied
with the 2016 model year standards. In fact, the manufacturers that generated a 2016 model
year GHG deficit have reported sufficient credits available from prior model years to be able
to offset that deficit and thus achieve compliance with their respective 2016 model year
standards. More detail about model year 2016 performance is provided in Section 3.
Figure ES-2. Manufacturer Performance and Standards in the 2016 Model Year
320
Standard
Performance
Shown in order of decreasing standards
* FCA and Volkswagen are subjects of an ongoing investigation and/or corrective actions. These data are based on initial
certification data provided to EPA, and are included in industry-wide, "Fleet Total", or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
Note: Rounding may result in differences between charts and tables and the values reported in the text.
. iv -
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3
All large manufacturers concluded Phase 1 of EPA's GHG
standards meeting the standards and with substantial credits
available to use through 2021.
The majority of manufacturers, representing 99 percent of 2016 model year U.S. sales, have
reported compliance with the standards for the 2012-2016 model years. In fact, 19 of 21
manufacturers are reporting a non-negative credit balance going into the 2017 model year,
meaning that these manufacturers have met the standards in all of the 2012-2016 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 2016 model year (such as Volvo) must offset that deficit
by the end of the 2019 model year, or be subject to possible enforcement action. All
manufacturers that initially reported a deficit in the 2012-2013 model years have successfully
offset that deficit, thus no manufacturer is in a position of non-compliance for any model
year at the end of the 2016 model year. The makeup of these credit and deficit balances is
tracked by model year "vintage" as explained in Section 5.
Table ES-1. Credit Balances After the 2016 Model Year (Mg)3
(including credit transfers & trades)4
Manufacturer
Credits Carried to 2017
Manufacturer
Credits Carried to 2017
Toyota
78,078,963
Mercedes
2,991,505
Honda
36,024,476
Mitsubishi
1,755,470
Nissan
26,682,834
Suzuki*
428,242
Ford
22,084,139
Karma Automotive*
58,852
Hyundai
20,583,544
BYD Motors*
4,824
GM
19,666,700
Tesla
576
Subaru
14,498,843
Volvo
(9,218)
Mazda
9,424,551
Jaguar Land Rover
(1,387,781)
Kia
6,011,615
FCAf
19,217,792
BMW
3,202,342
Volkswagenf
All Manufacturers
261,759,183
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
*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 be available.
3 The Megagram (Mg) is a unit of mass equal to 1000 kilograms. It is also referred to as the metric ton or tonne.
4 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.5'0 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.7 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.8 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."9
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
5 A comprehensive description of the EPA GHG program is beyond the scope of this document, thus readers should
consult the regulatory announcements and associated technical documents for a detailed description of the program.
6 NHTSA now provides information to the public regarding fuel economy compliance through a web-accessible public
information center. See https://one.nhtsa.gov/cafe_pic/CAFE_PIC_Home.htm.
7 Proposed Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel
Economy Standards, Proposed Rule, Federal Register 74 (28 September 2009): 49454-49789.
8 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.
9 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final Rule,
Federal Register 75 (7 May 2010): 25469.
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manufacturer (separately for each of the car and truck fleets) under the optional credit
programs, and the associated volumes of vehicles to which those credits apply." We also
suggested that we would likely publish credit transactions, as well as the overall credit or
debit balance for each manufacturer after taking into account the credit and debit carry-
forward provisions and any credit transactions.
In addition to this and prior reports, we continue to release a considerable amount of
information regarding fuel economy, emissions, and vehicle characteristics for each vehicle
model. For example, starting with the 2013 model year, the downloadable data available at
fueleconomy.gov includes CO2 emission values for each vehicle model. In addition, we
release actual vehicle emission test results on the Office of Transportation and Air Quality
website, as well as detailed information on long-term industry-wide CO2, fuel economy, and
technology trends since model year 1975.10 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 2016 model year is the fifth year
manufacturers have been subject to the standards. This report makes comparisons across the
five 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 2016 model year data which form the basis for this report was
required to be submitted to EPA by May 1 of 2017.11 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, 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. The data being reported is subject to change due to future
EPA approvals of "off-cycle" technology credits, credit transactions, correction of errors
discovered by manufacturers or by EPA, or the results of other EPA investigations or actions.
This report does not represent a final approval or validation of credits reported to EPA by
manufacturers.
10 See https://www.epa.gov/compliance-and-fuel-economv-data/data-cars-used-testing-fuel-economv and
https://www.epa.gov/fuel-economv-trends.
11 See 40 CFR 600.512-12.
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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
2012-2016 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 reduced "off-cycle" emissions), as well as the credit transactions between
manufacturers.
Vehicle and fleet average compliance for EPA's GHG program is based on a combination of
CO2, hydrocarbons, and carbon-monoxide emissions (i.e., the carbon-containing exhaust
constituents). This is consistent with the carbon balance methodology used to determine
fuel consumption for the vehicle labeling and CAFE programs. The regulations account for
these total carbon emissions appropriately and refer to the sum of these emissions as the
"carbon-related exhaust emissions," or "CREE." The carbon-containing emissions are
combined on a COz-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 COz-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
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-economy-
trends.
13 The Megagram (Mg) is a unit of mass equal to 1000 kilograms. It is also referred to as the metric ton or tonne.
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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.
Two manufacturers in this report,
FCA and Volkswagen, are affected
by on-going investigations and/or
corrective actions related to alleged
violations of the Clean Air Act
resulting in excess emissions of
oxides of nitrogen (NOx). 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, any relevant changes will be used in future reports.
In 2016 and 2017, the Department of Justice, on behalf of EPA, has resolved a civil
enforcement case, through a series of three partial settlements, against Volkswagen AG,
Audi AG, Dr. Ing. h.c. F. Porsche AG, Volkswagen Group of America, Inc., Volkswagen
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.
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] = ( C02 x VMT x Production ) / 1,000,000
"C02" 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
C02 credit applies.
The C02-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 C02 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
2016 model year fleet covered by this report, the weighted
VMT is 208,946 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.
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Group of America Chattanooga Operations, LLC, and Porsche Cars North America, Inc.
(collectively referred to as Volkswagen). Subject to their reservations, these settlements
resolve allegations that Volkswagen violated the Clean Air Act with the sale of certain model
year 2009-2016 diesel vehicles equipped with defeat devices in the form of computer
software designed to cheat on federal emissions tests. The complaint alleged 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, see
www.epa.gov/vw. New fuel economy and CO2 data is available for some vehicles that have
been modified under the VW consent decree; however, this report does not reflect these
revisions. Any relevant changes will be addressed in future reports.
In 2017, the Department of Justice, on behalf of EPA, filed a civil complaint against FCA
US LLC, Fiat Chrysler Automobiles N.V., V.M. Motori S.p.A., and V.M. North America,
Inc. (collectively referred to as FCA). The complaint alleges that certain diesel vehicles are
equipped with software functions that were not disclosed to regulators during the
certification application process, and that the vehicles contain defeat devices. The complaint
alleges that the undisclosed software functions cause the vehicles' emission control systems
to perform differently, and less effectively, during certain normal driving conditions than on
federal emission tests, resulting in increased oxides of nitrogen (NOx) emissions. For more
information on actions to resolve these violations, see www.epa.gov/fca.
Because the FCA and Volkswagen diesels account for less than 1% of industry production,
updates to the emissions rates, whether they are higher or lower, will not change the broader
trends characterized in this report. Should the investigations and corrective actions yield
different CO2 data, any relevant changes will be addressed in future reports.
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", 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. EPA believes 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.
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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.
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. Finally, the company formally known as
Fisker has changed ownership and has reemerged as Karma Automotive. Karma did not
produce any vehicles in the 2016 model year, but the new ownership retains the credits from
Fisker vehicles sold in the 2012 model year.
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 1,500 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
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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.15
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.10
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 2016 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.17 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 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 and 2016 model years, and because a final
determination of those standards has not been made by EPA, the data from these
15 The deferment applies only to the fleet average C02 standards; these manufacturers are required to meet the
applicable nitrous oxide (N20) and methane (CH4) emission standards.
16 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.
17 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy
Standards, Final Rule, Federal Register 77 (15 October 2012): 62889.
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manufacturers 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
and a valid credit balance can be reported.18
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.19 As an operationally independent manufacturer in model year 2016 with
a low U.S. sales volume (1852 cars in the 2016 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 above.
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 2016 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.
18 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.
19 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 complete for more than a year.
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Table 1-1. Aggregation of Manufacturers
Manufacturer
Manufacturers and Brands Included in U.S. Market
BMW
FCA
Ford
GM
Honda
Jaguar Land Rover
Mercedes
Nissan
Toyota
Volkswagen
BMW, Mini, Rolls-Royce
Alfa Romeo, Chrysler, Dodge, Fiat, Jeep, Maserati, Ram
Ford, Lincoln
Buick, Cadillac, Chevrolet, GMC
Acura, Honda
Jaguar, Land Rover
Maybach, Mercedes-Benz, Smart
Infiniti, Nissan
Lexus, Scion, Toyota
Audi, Bentley, Bugatti, Lamborghini, Porsche, Volkswagen
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 has been considered part of Volkswagen AG and
included in the Volkswagen fleet for compliance purposes.
Additionally, the company formerly known as Fisker has undergone some ownership
changes and is now known as Karma Automotive. Karma did not produce any vehicles in
the 2016 model year, but they appear in this report because the credits generated in the
2012 model year by then Fisker are now held by Karma and continue to be carried forward
under the new ownership.
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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").20
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.
20 Greenhouse Gas Emission Standards for Light-Duty Automobiles: Status of Early Credit Program for Model Years
2009-2011, Compliance Division, Office of Transportation and Air Quality, U.S. Environmental Protection Agency, Report
No. EPA-420-R-13-005, March 2013.
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Additionally, this table is intended to show the credits reported by manufacturers in these
years and does not include the impacts of any credit banking or trading on credit balances.
In particular, the sale of some early credits by some manufacturers (see Section 4), while not
shown in Table 2-1, impacts the 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. Reported Early Credits, by Manufacturer and Model Year (Mg)
Manufacturer
2009
2010
2011
Total
BMW
512,973
359,131
379,418
1,251,522
Ford
8,358,440
7,438,264
319,749
16,116,453
GM
13,009,374
11,455,325
1,045,858
25,510,557
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
-
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
FCAf
6,265,066
5,310,269
(1,164,014)
10,411,321
Volkswagenf
2,243,205
2,811,663
1,386,537
6,441,405
All
98,476,389
96,634,380
38,203,238
233,314,007
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These
data are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the
investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
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Table 2-2. Total Reported Early Credits, By Credit Category
Credit Category
Credits (Mg)
Percent of Total (%)
Tailpipe C02*
198,792,034
85
A/C Leakage
23,429,772
10
A/C Efficiency
8,551,932
4
Off-Cycle
2,540,269
1
Total
233,314,007
100
*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 reports the production
volumes of advanced technology vehicles for the 2009-2016 model years.
Due to concerns expressed by stakeholders during the rulemaking process, EPA placed
certain regulatory restrictions on credits from the 2009 model year.21 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 nearly 100 million Mg of 2009
credits earned by manufacturers, almost 76 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.
21 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. Expired 2009 Model Year Credits
Manufacturer
Credits (Mg)
Toyota
29,732,098
Honda
14,133,353
Nissan
8,190,124
GM
6,894,611
Ford
5,882,011
Hyundai
4,482,649
Kia
2,362,882
Mazda
1,340,917
Mitsubishi
583,146
Subaru
491,789
Suzuki
265,311
BMW
134,791
Volkswagenf
1,404,947
All
75,898,629
Volkswagen is listed separately in this table due to an ongoing investigation
and/or corrective actions. These data are based on initial certification data,
and are included in industry-wide "Total" or "All" values. Should the
investigation and corrective actions yield different C02 data, any relevant
changes 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 2016 model year should be used as the
sole reference from which to determine credit balances and overall performance at the
conclusion of the 2016 model year, and prior reports should generally be considered
obsolete.
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3. Credits Reported From the 2012-2016 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 gram per mile basis as measured on EPA test procedures for each vehicle
model, and (2) fleet-specific gram 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
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of credits and incentive programs would 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
gram per mile impact for each 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 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
gram per mile contribution to a manufacturer's total compliance. However, note that the
gram per mile values are calculated only for the purpose of this report, and are not specific
compliance values defined in or required by 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
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).
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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.
Table 3-1 shows the 2-cycle tailpipe emissions for the car, truck and combined fleets reported
by each manufacturer for the 2012-2016 model years.22 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 2016 relative to model year 2015. Of the 17
manufacturers active in the program in the 2016 model year, excluding the small volume
manufacturers, seven manufacturers increased aggregate 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 small reduction in 2-cycle GHG
emissions from both cars and trucks (3 g/mi for each fleet) led to a small net reduction of 1
g/mi in overall fleet-wide 2-cycle emissions. The overall reduction is lower than the
individual fleet reductions because of a continuing shift of consumers to buying trucks,
which reached 45 percent of the fleet in the 2016 model year.
On a percentage basis the most significant reductions from the 2015 to the 2016 model year
were reported by Hyundai (-5%) and Mazda (-3.1%). Hyundai is interesting because their
truck emissions increased by 15 g/mi and cars decreased by 10 g/mi, but an overall
reduction was achieved because car sales made up 97 percent of Hyundai's fleet in model
year 2016. Volvo's 9.9 percent reduction in CO2 emissions (-33 g/mi) from their truck fleet
led the industry, with Mazda not far behind at 9.1 percent. Kia led the way in the car fleet
with a CO2 reduction of 5.4 percent, with Hyundai following with a reduction of 4.1
percent, and then Ford, GM, and Honda showing reductions relative to model year 2015
between 1 and 3 percent. Jaguar Land Rover and Nissan have made the greatest percentage
reductions in 2-cycle emissions since the first year of the program, demonstrating reductions
of 16 and 17 percent, respectively. Mazda, Mercedes, and Subaru also showed double-digit
reductions of 12, 14, and 13 percent, respectively. Every manufacturer except Toyota
reduced 2-cycle emissions in the first phase of the program, from the 2012 to the 2016
model year (of course, Toyota entered the program in model year 2012 with CO2 emissions
among the lowest of all manufacturers).
22 The values in Table 3-1 do not include the impacts of credits or incentives resulting from air conditioning
improvements and off-cycle technologies. The impacts of these are detailed in subsequent sections. The values do
reflect that direct tailpipe GHG emissions from electricity are zero, as well as the estimated real-world impact of the use
of E85 in flexible fuel vehicles, as described in section 3.C.3. Because the values in this table do not include all credits
and incentives, the table does not describe a manufacturer's actual model year performance or a manufacturer's
compliance status.
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Table 3-1. "2-cycle" Tailpipe CO2 Production-Weighted Fleet Average Emissions (g/mi)
Model Year 2012
Model Year 2013
Model Year 2014
Model Year 2015
Model Year 2016
Manufacturer
Car
Truck
All
Car
Truck
All
Car
Truck All
Car Truck
All
Car
Truck
All
BMW
277
363
302
271
346
292
256
312
270
256
316
270
262
310
276
BYD Motors
0
0
0
0
0
0
No production volume
Coda
0
0
0
0
No production volume
Ford
261
385
315
256
375
321
256
375
315
258
353
311
254
354
311
GM
283
397
331
273
395
325
267
369
314
267
362
321
260
365
319
Honda
237
320
266
228
312
257
228
299
259
217
283
243
213
285
245
Hyundai
243
312
249
238
317
241
247
325
253
246
324
252
236
339
239
Jaguar Land Rover
376
439
426
347
414
399
330
377
369
324
343
339
322
361
356
Karma
102
102
No production volume
Kia
258
324
266
252
301
254
265
330
269
260
327
266
246
330
267
Mazda
241
324
263
232
296
251
220
287
240
217
285
238
214
259
231
Mercedes
316
393
343
296
371
321
285
372
309
273
347
301
269
342
296
Mitsubishi
262
283
267
254
267
258
224
256
236
215
254
228
241
251
248
Nissan
258
382
295
232
340
266
229
335
263
217
307
245
221
297
246
Porsche
325
362
342
309
363
336
Included in Volkswagen
Subaru
257
296
282
254
270
264
250
254
253
241
247
245
244
246
246
Suzuki
267
361
287
266
330
273
No production volume
Tesla
0
0
0
0
0
0
0
0
0
0
Toyota
221
354
273
225
347
278
221
358
274
225
342
279
224
342
279
Volvo
297
343
311
292
348
318
288
348
319
254
333
285
249
300
283
FCAf
300
384
357
289
380
344
298
364
346
275
354
329
288
348
331
Volkswagenf
274
332
282
272
327
279
266
336
280
251
336
269
247
320
264
All
259
369
302
251
360
294
250
349
294
243
336
286
240
332
285
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and
are included in industry-wide "Total" or "All" values. Should the investigation and corrective actions yield different CO2 data, any relevant changes will be used in future
reports.
-17-
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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 was available only to manufacturers with 2009 model year U.S. sales of
less than 400,000 vehicles, and, except as noted below, was available during the 2012-2015
model years. Under this program, a manufacturer was allowed to treat a portion of its fleet
as a separate averaging fleet to which a less stringent CO2 standard applied. Specifically, a
qualifying manufacturer was allowed to 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). No manufacturers used the TLAAS option in the 2016
model year.
All manufacturers that participated 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 were not allowed to 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 2013-2015 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, 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
-18-
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reached the 100,000 vehicle limit in the 2014 model year except for the fact that as of the
2014 model year they were aggregated with the Volkswagen fleet and no longer eligible to
use the TLAAS program.
Table 3-2 shows each manufacturer's reported use of the TLAAS program for the 2012-2015
model years. Note that the total of 283,440 vehicles placed under the less stringent standards
in the program to date represents less than 0.5 percent of the total number of vehicles
produced in the 2012-2016 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 2016. As shown in the previous section, Jaguar Land
Rover and Mercedes reduced their overall 2-cycle tailpipe emissions by 70 and 47 g/mi,
respectively, since the program started in the 2012 model year.
-19-
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Table 3-2. Production Volumes Assigned to HAAS Standards
Model Year 2012
Model Year 2013
Model Year 2014
Model Year 2015
Cumulative
Manufacturer
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
All
Total
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
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
Merged with Volkswagen, no longer eligible for TLAAS
71,355
Volvo
0
0
0
0
0
0
0
0
0
0
12,085
12,085
12,085
Fleet Total
27,857
72,028
99,885
22,052
72,152
94,204
7,616
23,759
31,375
137
57,839
57,976
283,440
-20-
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To understand the impact of the TLAAS program on compliance with EPA's GHG
program, we determined the gram 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. As noted above, no manufacturer used
the TLAAS program in the 2016 model year. 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 was 14 g/mi greater than it would have been without use of
the TLAAS program, as seen in Table 3-3.
-21-
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Table 3-3. Net Impact from Use of the HAAS Program (g/mi)
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Manufacturer
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
All
Jaguar Land Rover
2
76
60
0
40
31
3
13
11
0
38
31
Mercedes
4
22
10
0
27
9
2
13
5
0
12
5
Porsche
66
84
75
63
82
73
Merged with Volkswagen, no longer eligible for TLAAS
Volvo
0
0
0
0
0
0
0
0
0
0
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
-22-
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C. Credits Based on Alternative Fuel Vehicles
EPA's GHG program contains several credits and incentives for dedicated and dual fuel
alternative fuel vehicles. Dedicated alternative fuel vehicles are vehicles that run exclusively
on an alternative fuel (e.g., compressed natural gas, electricity). Dual fuel vehicles can run
both on an alternative fuel and on a conventional fuel such as gasoline; the most common is
the gasoline-ethanol flexible fuel vehicle, which is a dual fuel vehicle that can run on E85 (85
percent ethanol and 15 percent gasoline), or on conventional gasoline, or on a mixture of
both E85 and gasoline in any proportion. Dual fuel vehicles also include vehicles that use
compressed natural gas (CNG) and gasoline, or electricity and gasoline. This section
separately describes three different and uniquely-treated categories of alternative fuel
vehicles: advanced technology vehicles using electricity or hydrogen fuel cells; compressed
natural gas vehicles; and gasoline-ethanol flexible fuel vehicles.
1. Advanced Technology Vehicles
EPA's GHG program contains incentives for advanced technology vehicles. For the 2012-
2016 model years, the incentive program allows electric vehicles and fuel cell vehicles to use
a zero grams 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 2012-2016 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
-23-
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emissions value of about 120 g/mi.23 EPA regulations provide all the information necessary
to calculate a unique net upstream value for each electric or plug-in hybrid electric vehicle.24
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 2012-2016 model years. Without the incentive, however, the
2016 model year 2-cycle fleet average GHG emissions for Tesla would in fact be about 105
g/mi.25 Use of the incentive in Tesla's case in the 2016 model year allowed them to generate
almost 950,000 Mg of additional GHG credits relative to what they would generate by using
the net upstream value of 105 g/mi. Nissan's passenger car fleet benefitted similarly from the
ability of the electric Nissan Leaf to use zero grams per mile instead of the calculated net
upstream value of 82 g/mi.20 As a result, the overall impact on Nissan's passenger car fleet in
the 2016 model year was an improvement of 1.1 g/mi, allowing them to generate about
210,000 Mg of credits more than if the incentive provisions were not in place. The net
impact from Nissan and Tesla on the entire 2016 model year fleet of this incentive is thus
about 1.1 million Mg of credits, or about 0.3 g/mi. While there are other electric vehicles
and plug-in hybrid electric vehicles in the 2016 fleet, as shown in Table 3-4, Nissan and
Tesla account for a substantial fraction of the 2016 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 - produced far more plug-in hybrids than dedicated electric
vehicles in the 2016 model year). Because it is unlikely that the total impact of this incentive
exceeds 0.5 g/mi across the 2016 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 2010-2016 production volumes of advanced technology vehicles that
utilized the zero grams per mile incentive.
23 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final Rule,
Federal Register 75 (7 May 2010): 25435.
24 See 40 CFR 600.113-12(n).
25 Using the calculations prescribed in the regulations, the sales-weighted upstream emissions for Tesla's 2016
passenger cars is 180 grams/mile and the upstream emissions associated with a comparable gasoline vehicle is 75
grams/mile. The difference, or the net upstream emissions of Tesla's 2016 passenger car fleet, is 105 grams/mile.
26 The upstream GHG emission value for the 2016 Nissan Leaf is 144 grams/mile and the upstream emissions associated
with a comparable gasoline vehicle is 62 grams/mile. The difference, or the net upstream emissions of the 2016 Leaf, is
82 grams/mile.
-24-
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Table 3-4. Production Volumes of Advanced Technology Vehicles Using Zero
Grams/Mile Incentive, by Model Year
Model Year
Manufacturer
2010
2011
2012
2013
2014
2015
2016
Total
BMW
-
-
-
-
9,895
11,386
11,755
33,036
BYD Motors
-
-
11
32
50
-
-
93
Coda
-
-
-
37
-
-
-
37
Ford
-
-
653
18,654
18,826
17,384
22,343
77,860
GM
-
4,370
18,355
27,484
25,847
14,847
12,447
103,350
Honda
-
-
-
471
1,635
-
-
2,106
Hyundai
-
-
-
-
-
72
1,432
1,504
Karma
-
-
1,415
-
-
-
-
1,415
Kia
-
-
-
-
-
926
2,788
3,714
Mercedes
-
546
25
880
3,610
3,125
2,365
10,551
Mitsubishi
-
-
1,435
-
219
-
130
1,784
Nissan
-
8,495
11,460
26,167
10,339
33,242
13,128
102,831
Tesla
599
269
2,952
17,813
17,791
24,322
46,058
109,804
Toyota
-
-
452
829
1,218
5,838
-
8,337
Volvo
-
-
-
-
-
-
2,183
2,183
FCAf
-
-
-
2,353
3,404
7,825
4,639
18,221
Volkswagenf
-
-
-
-
755
4,869
12,776
18,400
Total
599
13,680
36,758
94,720
93,589
123,836
132,044
495,226
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
2. Compressed Natural Gas Vehicles
There were no compressed natural gas vehicles (CNG) subject to the GHG standards in the
2016 model year. The Honda Civic CNG was the only CNG vehicle produced for general
purchase by consumers during the first phase of EPA's GHG program, and it was only
available in the 2012-2014 model years, and is a dedicated alternative fuel vehicle. In the
2015 and 2016 model years, 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 2015-2016 model year
GHG standards and thus won't be accounted for in this report.
3. Gasoline-Ethanol Flexible Fuel Vehicles
For the 2012 to 2015 model years, EPA provided GHG credits for flexible fuel vehicles
(FFVs) that corresponded to the statutory fuel economy credits under CAFE. As with the
CAFE program, the GHG program based FFV credits in these years on the assumption that
FFVs operate 50% of the time on the alternative fuel and 50% of the time on conventional
-25-
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fuel, resulting in CO2 emissions that are based on an arithmetic average of alternative fuel
and conventional fuel CO2 emissions. Further, to fully align the credit with the CAFE
program, the CO2 emissions measurement on the alternative fuel was multiplied by a 0.15
factor. The 0.15 factor was 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 was 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 compliance value used in the
manufacturer's fleet average calculation prior to the 2016 model year would be:
[(330x0.15) + 350]
CO, = - = 199.8 g/mi
By temporarily using the CAFE-based approach—including the 0.15 factor—the CO2
emissions value for an FFV was 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. For
example, the FFV compliance value of 199.8 g/mi shown above is 150 g/mi, or 43 percent,
less than the gasoline-only value of 350 g/mi. This was a short-term incentive being provided
to FFVs, available in EPA's GHG program only through the 2015 model year. 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.
Starting in model year 2016, GHG compliance values for FFVs are based on the 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. A guidance letter released in 2014
defined a weighting factor (the "F factor") of 0.14 to use for E85 when weighting E85 and
gasoline CO2 emissions for FFVs in the 2016-2018 model years. EPA estimated that FFVs
would be operating on E85 14 percent of the time in these years.27 This approach could be
thought of as comparable to the "utility factor" weighting method used to weight gasoline
and electricity for plug-in hybrid electric vehicles (PHEV), which projects the percentage of
miles that a PHEV will use electricity based on how many miles a fully-charged PHEV can
drive using grid electricity. Thus, for the example FFV described above, the new equation for
determining the CO2 emissions compliance value for the 2016 model year, reflecting a 0.14
and 0.86 weighting of E85 and gasoline values, respectively, is the following:
CO, = (330x0.14) + (350x0.86) = 347.2 g/mi
Depending on the relative FFV tailpipe emissions values on E85 and gasoline, FFVs can still
represent a CO2 emissions benefit, and can help to lower the emissions of a manufacturer's
fleet, but the overall impact is significantly diminished relative to the magnitude of the
27 EPA Guidance Letter "E85 Flexible Fuel Vehicle Weighting Factor for Model Year 2016-2018 Vehicles," CD-14-18,
November 12, 2014.
-26-
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incentives provided in previous model years. Under the 2016 model year methodology, the
FFV compliance value of 347.2 g/mi in the example above is less than 3 g/mi, or less than
one percent, lower than the gasoline-only value of 350 g/mi. This reduction is about 50
times less relative to the methodology for the 2012 to 2015 model years. This methodology
that is based on the actual emissions performance of FFVs on the EPA test procedures
weighted based on projected fuel use over the life of the vehicle results in a credit that is
substantially less relative to the methodology for the 2012 to 2015 model years.
Six manufacturers produced FFVs in the 2016 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. FFVs started the GHG program in 2012 at about 15 percent of the fleet,
then grew to almost 20 percent of the fleet in the 2014 model year, when production
peaked, and then began to decline in subsequent model years. FFVs make up about eight
percent of the 2016 model year fleet. 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, two of the Toyota
truck models shown in Table 3-5 are made up of two- and four-wheel drive versions of the
Toyota Tundra pickup truck.
Most of these manufacturers focused their FFV production in the truck segment, with trucks
making up almost 70 percent of all FFV production in the 2016 model year. Ford, Toyota,
and Mercedes slightly increased FFV production in the 2016 model year, while FCA and
GM significantly reduced FFV production, and Nissan and Jaguar Land Rover ended FFV
production. Overall, however, FFV production dropped by about 500,000 vehicles relative
to 2015, a drop of about 27 percent.
-27-
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Table 3-5. Number of FFV Models by Manufacturer, 2012-2016 Model
Years
Model
Year
Category
Ford
GM
Jaguar Land
Rover
Mercedes
Nissan
Toyota
+-
5
Volkswagenf
Total
Car
7
19
-
5
-
0
10
4
45
2012
Truck
23
60
-
1
4
2
-
101
All
30
79
-
6
4
2
21
4
146
Car
6
18
4
7
-
0
10
10
55
2013
Truck
23
58
-
1
4
2
13
1
102
All
29
76
4
8
4
2
23
11
157
Car
6
11
6
7
0
0
10
8
48
2014
Truck
21
44
6
1
4
2
11
1
90
All
27
55
12
8
4
2
21
9
138
Car
5
7
5
2
0
0
11
7
37
2015
Truck
7
22
3
1
4
2
11
1
51
All
12
29
8
3
4
2
22
8
88
Car
6
6
0
2
0
0
8
4
26
2016
Truck
11
17
0
2
0
3
6
1
40
All
18
23
0
4
0
3
14
5
66
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These
data are based on initial certification data, and are included in industry-wide "Total" or "AN" values. Should the
investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
-28-
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Table 3-6. Production Volume of FFVs by Manufacturer, 2012-2016 Model
Years
Model
Year
Category
Ford
GM
Jaguar Land
Rover
Mercedes
Nissan
Toyota
+-
5
Volkswagenf
Total
Car
174,597
396,264
-
13,493
-
-
105,174
2,060
691,588
2012
Truck
323,563
511,183
-
8,289
24,154
31,670
453,399
-
1,352,258
All
498,160
907,447
-
21,782
24,154
31,670
558,573
2,060
2,043,846
Car
209,988
374,354
321
34,493
-
-
142,158
30,346
791,660
2013
Truck
546,695
637,576
-
22,082
13,650
33,203
431,359
20,799
1,705,364
All
756,683
1,011,930
321
56,575
13,650
33,203
573,517
51,145
2,497,024
Car
259,189
282,707
2,754
48,597
-
-
76,570
39,375
709,192
2014
Truck
498,245
801,740
32,013
12,079
14,809
56,516
650,617
25,666
2,091,685
All
757,434
1,084,447
34,767
60,676
14,809
56,516
727,187
65,041
2,800,877
Car
140,169
170,959
2,640
12,026
-
-
183,860
28,994
538,648
2015
Truck
296,039
313,961
10,795
5,208
13,565
43,060
585,462
31,987
1,300,077
All
436,208
484,920
13,435
17,234
13,565
43,060
769,322
60,981
1,838,725
Car
137,556
125,079
-
24,782
-
-
115,995
21,237
424,649
2016
Truck
338,099
139,667
-
9,894
-
69,596
313,607
39,212
910,075
All
475,655
264,746
-
34,676
-
69,596
429,602
60,449
1,334,724
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
Table 3-7 shows the impact of the FFV credits on each manufacturer's fleet for the 2012-
2015 model years. Although FFVs, in conjunction with use of the 0.14 usage factor, can
help lower a manufacturer's fleet GHG emissions in the 2016 and later model years, EPA
does not consider the GHG performance-based approach to be a credit or an incentive. The
methodology for 2016 and later FFVs is, like the use of utility factors for PHEVs, considered
to simply be the appropriate methodology by which to calculate emissions on the test
procedures based on the fuels, or mixture of fuels, that FFVs are projected to consume. The
data show that three manufacturers benefitted from FFVs in the 2016 model year.
Compared to fleet performance based only on gasoline test results, FCA and GM used FFVs
to lower their passenger car fleet 2-cycle CO2 emissions by 1 g/mi, while Ford reduced truck
fleet 2-cycle CO2 emissions by 1 g/mi. The overall impact of FFVs on the fleet in 2016 was
negligible, a small fraction of one g/mi. These much smaller impacts will not be reported
separately as credits beginning with the 2016 model year; rather, the impact of FFVs for the
2016 and later model years is "built in" to the 2-cycle tailpipe emissions.
-29-
-------
Table 3-7. Credits Accrued from Use of the FFV Incentives, 2012-2015 Model
Years (g/mi)
Manufacturer
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
All
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
5
0
1
1
18
15
13
6
7
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
3
0
15
6
0
8
4
FCAf
13
21
18
12
21
17
12
19
17
9
15
13
Volkswagenf
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
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
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. Sixteen manufacturers used the A/C credit provisions
- either for leakage reductions, efficiency improvements, or both - as part of their
compliance demonstration in the 2016 model year.
-30-
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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 2016 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-
2016 model years.
Table 3-8. Reported A/C Credits by 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
6,239,573
75%
2,113,939
25%
8,353,512
2010
8,323,159
75%
2,843,761
25%
11,166,920
2011
8,867,040
71%
3,594,232
29%
12,461,272
2012
11,121,450
65%
5,881,319
35%
17,002,769
2013
13,239,784
61%
8,517,721
39%
21,757,505
2014
16,588,243
61%
10,540,350
39%
27,128,593
2015
20,240,734
62%
12,383,461
38%
32,624,195
2016
21,422,607
63%
12,479,386
37%
33,901,993
Total
106,042,590
65%
58,354,169
35%
164,396,759
-31-
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Table 3-9. Reported A/C Credits by Manufacturer, 2016 Model Year
A/C Leakage
A/C Efficiency
Grams/Mile
Credits
Credits
Total A/C Credits
Equivalent of
Manufacturer
(Mg)
(Mg)
(Mg)
Total A/C Credits
BMW
418,678
338,605
757,283
10
Ford
3,154,215
1,411,163
4,565,378
10
GM
3,573,176
2,201,272
5,774,448
11
Honda
2,026,647
1,137,628
3,164,275
8
Hyundai
379,578
537,703
917,281
7
Jaguar Land Rover
425,008
144,567
569,575
22
Kia
380,830
502,748
883,578
6
Mercedes
412,257
365,340
777,597
11
Mitsubishi
86,597
-
86,597
5
Nissan
1,380,015
795,312
2,175,327
8
Subaru
-
335,224
335,224
3
Tesla
-
51,263
51,263
6
Toyota
2,426,563
2,260,189
4,686,752
9
Volvo
127,361
74,919
202,280
11
FCAf
6,047,361
1,910,581
7,957,942
18
Volkswagenf
584,321
412,872
997,193
9
Fleet Total
21,422,607
12,479,386
33,901,993
10
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-32-
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Table 3-10. Net Impact of A/C Credits, 2012-2016 Model Years (g/mi)
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
2016 Model Year
Manufacturer
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
All
BMW
7
11
8
8
11
9
8
11
9
9
11
9
9
11
10
Ford
5
8
6
7
8
8
8
10
9
9
11
10
9
11
10
GM
8
8
8
9
9
9
9
11
10
10
11
10
10
11
11
Honda
3
5
4
4
6
4
4
6
5
4
7
5
9
8
8
Hyundai
4
7
4
5
7
5
6
7
6
6
7
6
7
5
7
Jaguar Land Rover
5
8
7
5
9
8
12
22
21
14
23
21
19
23
22
Kia
5
3
5
5
8
5
6
5
6
6
6
6
6
6
6
Mercedes
9
11
10
9
12
10
10
12
11
11
12
11
11
12
11
Mitsubishi
-
-
-
-
-
-
-
-
-
-
-
-
3
7
5
Nissan
2
4
3
4
4
4
5
6
6
7
8
7
7
9
8
Subaru
2
2
2
1
2
2
1
2
2
3
2
2
3
3
3
Tesla
6
-
6
6
-
6
6
-
6
6
-
6
6
-
6
Toyota
7
6
7
7
7
7
8
7
8
8
8
8
8
11
9
Volvo
11
12
11
10
11
10
8
8
8
8
9
8
8
12
11
FCAf
9
10
10
10
11
10
13
14
14
17
19
19
17
19
18
Volkswagenf
6
9
7
6
10
7
8
12
9
9
12
9
8
12
9
Fleet Total
5
7
6
6
8
7
7
10
8
8
11
9
9
11
10
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and are
included in industry-wide "Total" or "AN" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
-33-
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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.28 This score is based on the
number, performance, and technology of the components, fittings, seals, and hoses of the
A/C system.29 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 gram 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
HFG134a, the refrigerant currently used throughout most of the industry. The use of HFO-
1234yf expanded considerably in the 2014 model year, from 42,384 vehicles in the 2013
model year to 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. The 2016
model year continued to show growth in the use of the new refrigerant, but no new
manufacturers took up the refrigerant in 2016. Although use of HFO-1234yf decreased by
FCA, who continues to produce more vehicles with this refrigerant than any other
manufacturer, GM, Honda, and Jaguar Land Rover all increased their production of vehicles
using it. Honda, in fact, was the principle driver in an almost 25 percent increase in vehicles
using HFO-1234yf in the 2016 model year. Industry-wide, 13 percent of 2016 model year
vehicles are using HFO-1234yf, with FCA accounting for almost 70 percent of vehicles using
the new refrigerant. Jaguar Land Rover continues to have the greatest penetration within
their fleet, using HFO-1234yf in 100 percent of vehicles produced in the 2016 model year.
The net impact on credits is that these manufacturers collectively generated 3.8 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 2.6 million Megagrams more than they
would have had they used HFG134a. Table 3-11 shows the aggregated production volume of
vehicles using HFO-1234yf for the 2012-2016 model years, by manufacturer.
28 See 40 CFR 86.1867-12.
29 The global warming potential (GWP) represents how much a given mass of a chemical contributes to global warming
over a given time period compared to the same mass of carbon dioxide. Carbon dioxide's GWP is defined as 1.0.
-34-
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Table 3-11. Production of Vehicles Using HFO-1234yf, 2013-2016
Model Years
Manufacturer
2013
2014
2015
2016
Total
GM
41,913
30,652
16,298
32,775
121,638
Honda
471
599
541,393
542,463
Jaguar Land Rover
56,604
62,316
114,580
233,500
540,098
1,683,956
1,504,046
Total
42,384
627,953
1,762,570
2,192,794
4,625,701
fFCA is listed separately in this table due to an ongoing investigation and/or corrective actions. These data are
based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the
investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
Fourteen manufacturers reported A/C leakage credits in the 2016 model year, as shown in
Table 3-12. These manufacturers reported more than 20 million Mg of A/C leakage credits
in 2016, accounting for GHG reductions of 6 g/mi across the 2016 vehicle fleet. Table 3-13
shows the leakage credits in grams per mile for the 2012-2016 model years.
-35-
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Table 3-12. Reported A/C Leakage Credits by Manufacturer and
Fleet, 2016 Model Year (Mg)
Grams/mile
Equivalent of
Manufacturer
Car
Truck
Total
Total Credits
BMW
261,750
156,928
418,678
5
Ford
1,202,274
1,951,941
3,154,215
7
GM
1,529,206
2,043,970
3,573,176
7
Honda
1,242,114
784,533
2,026,647
5
Hyundai
372,376
7,202
379,578
3
Jaguar Land Rover
45,546
379,462
425,008
17
Kia
283,543
97,287
380,830
3
Mercedes
236,227
176,030
412,257
6
Mitsubishi
14,092
72,505
86,597
5
Nissan
746,573
633,442
1,380,015
5
Toyota
897,532
1,529,031
2,426,563
5
Volvo
31,954
95,407
127,361
7
FCAf
1,509,550
4,537,811
6,047,361
14
Volkswagenf
392,728
191,593
584,321
Fleet Total
8,765,465
12,657,142
21,422,607
6
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective
actions. These data are based on initial certification data, and are included in industry-wide "Total" or
"All" values. Should the investigation and corrective actions yield different C02 data, any relevant
changes will be used in future reports.
-36-
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Table 3-13. A/C Leakage Credits, 2012-2016 Model Years (g/mi)
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
2016 Model Year
Manufacturer
Car
Truck All
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
All
BMW
4
7
5
4
7
5
4
7
5
5
7
5
5
7
5
Ford
4
7
6
5
7
7
6
8
7
6
8
7
6
8
7
GM
6
7
6
6
7
7
6
7
7
6
7
6
6
7
7
Honda
1
2
2
1
3
2
1
3
2
2
4
2
6
5
5
Hyundai
2
5
2
2
4
2
2
3
2
3
4
3
3
2
3
Jaguar Land
Rover
3
4
4
3
5
4
7
17
15
9
17
15
14
17
17
Kia
2
2
2
2
5
2
2
3
2
2
3
2
3
3
3
Mercedes
4
7
5
4
7
5
5
7
5
5
7
6
5
7
6
Mitsubishi
-
-
-
-
-
-
-
-
-
-
-
-
3
7
5
Nissan
0
2
1
0
2
1
2
4
3
4
6
4
4
7
5
Toyota
3
3
3
3
3
3
4
4
4
4
4
4
3
7
5
Volvo
6
8
7
6
7
7
6
7
7
5
8
6
5
7
7
FCAf
6
8
7
6
8
7
9
10
9
13
15
14
12
15
Volkswagenf
2
4
2
3
5
3
4
7
5
5
7
5
5
7
Fleet Total
3
5
4
3
6
4
4
6
5
5
7
6
5
8
6
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and are
included in industry-wide "Total" or "AN" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
-37-
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2. Air Conditioning Efficiency Credits
Manufacturers that make improvements in their A/C systems to increase efficiency, thus
reducing CO2 emissions due to A/C system operation, may be eligible for A/C efficiency
credits. Most of the additional load on the engine from A/C 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 A/C system, as shown in Table 3-14. These manufacturers reported
a total of more than 12 million Mg of A/C efficiency credits in the 2016 model year,
accounting for about 4 g/mi across the 2016 fleet. Table 3-15 shows the efficiency credits in
grams per mile for the 2012-2016 model years.
-38-
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Table 3-14. Reported A/C Efficiency Credits by Manufacturer and Fleet,
2016 Model Year (Mg)
Grams/Mile
Equivalent of
Manufacturer
Car
Truck
Total
Total Credits
BMW
241,276
97,329
338,605
4
Ford
533,799
877,364
1,411,163
3
GM
877,339
1,323,933
2,201,272
4
Honda
624,733
512,895
1,137,628
3
Hyundai
520,949
16,754
537,703
4
Jaguar Land Rover
18,814
125,753
144,567
6
Kia
381,366
121,382
502,748
3
Mercedes
233,353
131,987
365,340
5
Nissan
562,084
233,228
795,312
3
Subaru
88,364
246,860
335,224
3
Tesla
51,263
51,263
6
Toyota
1,314,746
945,443
2,260,189
5
Volvo
20,754
54,165
74,919
4
FCAf
601,135
1,309,446
1,910,581
4
Volkswagenf
275,942
136,930
412,872
4
Fleet Total
6,345,917
6,133,469
12,479,386
4
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions.
These data are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should
the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
-39-
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Table 3-15. A/C Efficiency Credits, 2012-2016 Model Years (g/mi)
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
2016 Model Year
Manufacturer
Car
Truck All
Car
Truck All
Car
Truck All
Car
Truck All
Car
Truck All
BMW
3
4
3
4
4
4
4
4
4
4
4
4
4
4
4
Ford
0
0
0
2
1
1
2
2
2
3
3
3
3
3
3
GM
2
1
2
3
2
3
3
4
4
3
4
4
4
4
4
Honda
2
3
2
2
3
2
2
3
3
2
3
3
3
3
3
Hyundai
2
2
2
3
4
3
4
4
4
4
4
4
4
4
4
Jaguar Land Rover
2
4
4
2
4
4
5
6
5
5
6
6
6
6
6
Kia
2
1
2
2
3
3
4
2
4
4
3
4
3
3
3
Mercedes
5
5
5
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
3
3
3
Subaru
2
2
2
1
2
2
1
2
2
3
2
2
3
3
3
Tesla
6
-
6
6
-
6
6
-
6
6
-
6
6
-
6
Toyota
4
2
3
4
3
4
5
3
4
4
4
4
5
4
5
Volvo
4
4
4
4
4
4
1
1
1
3
1
2
3
4
4
FCAf
3
2
3
3
3
3
4
4
4
4
5
5
5
4
4
Volkswagenf
4
5
4
4
5
4
4
5
4
4
5
4
3
5
4
Fleet Total
2
2
2
3
2
3
3
3
3
3
4
4
4
4
4
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and are
included in industry-wide "Total" or "AN" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
-40-
-------
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 2014.30 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 2016
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.31 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 2012-2016 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.32 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.33
Table 3-16 shows the total off-cycle technology credits reported by manufacturers in the 2016
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
30 See 40 CFR 86.1869-12(b).
31 See 40 CFR 86.1869-12(c).
32 See 40 CFR 86.1869-12(d).
33 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/vehicle-and-engine-
certification/compliance-information-light-duty-greenhouse-gas-ghg-standards.
-41-
-------
mile equivalent of those credits rounds to 0.0, as shown, as is also the case for Subaru in
model year 2014.
Table 3-16. Reported Off-Cycle Technology Credits by Manufacturer and
Fleet, 2016 Model Year (Mg)
Grams/Mile
Equivalent of Total
Manufacturer
Car
Truck
Total
Credits
BMW
213,889
155,758
369,647
5
Ford
330,086
936,002
1,266,088
3
GM
662,961
1,227,378
1,890,339
3
Honda
354,307
379,221
733,528
2
Hyundai
162,564
21,408
183,972
1
Jaguar Land Rover
10,018
169,333
179,351
7
Kia
146,732
118,830
265,562
2
Mercedes
155,616
81,796
237,412
4
Nissan
339,915
251,409
591,324
2
Subaru
10,458
22,531
32,989
0
Toyota
360,276
762,051
1,122,327
2
FCAf
389,320
2,474,713
2,864,033
Fleet Total
3,136,142
6,600,430
9,736,572
3
fFCA is listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on
initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and corrective
actions yield different C02 data, any relevant changes will be used in future reports.
-42-
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Table 3-17. Off-Cycle Technology Credits by Manufacturer and Fleet, 2012-2016 Model Years (g/mi)
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
2016 Model Year
Manufacturer
Car
Truck All
Car
Truck All
Car
Truck All
Car
Truck All
Car
Truck All
BMW
3
5 3
3
6
4
3
6
4
4
7
4
4
7
5
Ford
1
0 0
1
1
1
2
3
3
2
3
3
2
4
3
GM
1
2 1
1
2
1
1
3
2
2
4
3
3
4
3
Honda
-
-
-
-
-
1
2
1
1
2
2
2
2
2
Hyundai
-
-
-
-
-
1
4
1
1
3
2
1
5
1
Jaguar Land Rover
-
-
-
-
-
2
6
5
2
5
5
3
8
7
Kia
-
-
-
-
-
1
1
1
1
2
1
1
3
2
Mercedes
1
0 0
1
1
1
3
1
2
4
3
3
4
3
4
Nissan
-
-
-
-
-
1
2
2
2
3
2
2
3
2
Subaru
-
-
-
-
-
-
0
0
0
0
0
0
0
0
Toyota
-
-
-
-
-
2
3
3
3
3
3
1
3
2
FCAf
1
2 2
1
3
2
3
7
6
3
7
6
3
8
7
Volkswagenf
1
1 1
1
1
1
Fleet Total
0
1 1
1
1
1
2
4
3
2
4
3
2
4
3
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and are
included in industry-wide "Total" or "AN" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
-43-
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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 2016 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 2016 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, 2016 Model Year (Mg)
Grams/Mile
Equivalent of
Manufacturer
Car
Truck
Total
Total Credits
BMW
213,889
155,758
369,647
5
Ford
330,086
936,002
1,266,088
3
GM
580,113
972,808
1,552,921
3
Honda
354,307
379,221
733,528
2
Hyundai
162,564
21,408
183,972
1
Jaguar Land Rover
10,018
169,333
179,351
7
Kia
146,732
118,830
265,562
2
Mercedes
155,616
81,796
237,412
4
Nissan
339,915
251,409
591,324
2
Subaru
10,458
22,531
32,989
0
Toyota
360,276
762,051
1,122,327
2
FCAf
389,320
2,474,713
2,864,033
Fleet Total
3,053,294
6,345,860
9,399,154
3
fFCA is listed separately in this table due to an ongoing investigation and/or corrective actions. These data are
based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the
investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
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 A/C system by venting hot air, by
-44-
-------
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.
Because this category of credits is capped, the actual credits attributable to each technology
in this category can't be accurately summarized. For example, credits for a car with active
cabin ventilation (2.1 g/mi), active seat ventilation (1.0 g/mi), and reflective paint (0.4 g/mi)
would total to 3.5 g/mi, thus exceeding the cap by 0.5 g/mi. Credits for this car would have
to be truncated at 3.0 g/mi, and there is no non-arbitrary methodology to assign that 3.0
g/mi to the array of technologies involved. It's even possible that a manufacturer with such a
car would not even bother to include credits for paint, since credits from the other two
technologies have already exceeded the cap. Therefore, this report can only detail the credits
derived from the overall category, but not from the individual technologies in the category.
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 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 slazins - 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 ivarmub - These systems use heat from the vehicle that
would typically be wasted (exhaust heat, for example) to warm up key elements of the
-45 -
-------
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.
• High, efficiency exterior lights - These lights reduce the total electric demand, and thus the
fuel consumption and GHG emissions, of the lighting system in comparison to
conventional lighting technologies. Credits are based on the specific lighting locations,
ranging from 0.06 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.
-46-
-------
Table 3-19. Off-Cycle Technology Credits from the Menu by Technology,
2016 Model Year (Mg)*
Grams/Mile
Equivalent of
Off-Cycle Technology
Car
Truck
Total
Total
Active Aerodynamics
Grill shutters
215,801
423,866
639,667
0.2
Ride height adjustment
61
7,075
7,136
0.0
Subtotal:
215,862
430,941
646,803
0.2
Thermal Control Technologies
Passive cabin ventilation
N/A
Active cabin ventilation
N/A
Active seat ventilation
N/A
Glass or glazing
N/A
Solar reflective surface coating
N/A
Subtotal:
922,865
2,616,304
3,539,169
1.0
Engine & Transmission Warmup
Active engine warmup
485,989
1,182,173
1,668,162
0.5
Active transmission warmup
665,715
1,107,216
1,772,931
0.5
Subtotal:
1,151,704
2,289,389
3,441,093
1.0
Other
Engine idle stop-start
396,464
622,385
1,018,849
0.3
High efficiency exterior lights
366,356
386,841
753,197
0.2
Solar panel(s)
43
-
43
0.0
Subtotal:
762,863
1,009,226
1,772,089
0.5
Total
3,053,294
6,345,860
9,399,154
3
*Credits are not always reported by manufacturers in a format that shows the total credits for each technology as we show
here. For the purposes of this report we have used the data from manufacturers to calculate the credits 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
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. Note that a value
of zero indicates use of a technology, but at a rate less than 0.5 percent, thus rounding to
zero. As was the case in the previous model year, there was significant penetration of glass or
glazing technology across these manufacturers, with a majority of them reporting installing
this technology on more than 50 percent of their vehicles, and three manufacturers
approaching a 100 percent implementation rate (FCA, Jaguar Land Rover, and Kia). High
-47-
-------
efficiency lighting is another technology with high penetration across a number of
manufacturers; all manufacturers reported implementation on at least half of their fleet, and
Jaguar Land Rover and BMW at or near 100 percent. Relative to the 2015 model year, the
use of engine idle stop-start systems almost doubled, reaching 10 percent of the 2016 model
year fleet. With 100 percent implementation, Jaguar Land Rover had the highest proportion
of vehicles equipped with engine idle stop-start, with Mercedes following at over 80 percent.
The most "popular" technologies across the manufacturers were high efficiency lights and
engine idle stop-start systems, both of which were employed by more than 10 manufacturers,
followed by active aerodynamic grill shutters and active seat ventilation, which were used by
10 and 9 manufacturers, respectively. Although active seat ventilation was used by many
manufacturers, it remains a technology with limited offering, appearing on only about five
percent of the 2016 model year fleet, with Jaguar Land Rover appearing the outlier with
implementation on more almost 60 percent of their vehicles (this is consistent with this
technology being largely limited to luxury brands or models). The most widely used off-cycle
technology across the fleet was high efficiency lighting, which was installed on almost 10
million vehicles, or about 60 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. As noted previously, it is possible
that some of the thermal control technologies are under-reported due to the cap on the
credits allowed from that category.
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. FCA and Jaguar Land Rover can be singled out as the manufacturers
reporting the greatest benefits from off-cycle technologies (7 g/mi), with most other
manufacturers gaining in the range of 2-4 g/mi from these off-cycle technologies. A closer
look shows different strategies across these manufacturers of varying sizes and product lines.
Jaguar Land Rover used a high penetration of engine idle stop-start and thermal control
technologies to get most of their benefit, while BMW achieved most of theirs by use of
thermal control and active engine warm-up technologies. FCA achieved half of their benefit
from thermal control technologies, and most of the remainder from active engine and
transmission warm-up strategies. Jaguar Land Rover, which, as noted earlier, has made very
large GHG reductions across their fleet since the start of the program, gained half of their 7
g/mi of off-cycle credits through adoption of stop-start systems across the vast majority of
their product line. Only Mercedes has approached this implementation rate for engine idle
stop-start systems, accounting for more than half of their 4 g/mi benefit.
-48-
-------
Table 3-20. Percent of 2016 Model Year Vehicle Production Volume with Credits from the Menu, by
Manufacturer & Technology (%)
Active
Aerodynamics
Thermal Control Technologies
Engine &
Transmission
Warmup
Other
u
Ł
c
00
c
N
01
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00
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.>
u
(A
E
(0
4-"
E
(0
g
Engin
start
-C 01
00
X
X 01
(0
o
to
BMW
3
-
-
94
8
0
-
71
-
3
97
-
Ford
74
-
-
-
-
-
-
30
21
11
59
-
GM
15
-
-
-
9
62
21
26
-
15
67
-
Honda
-
-
-
-
3
-
-
-
79
3
83
-
Hyundai
4
-
-
-
11
69
-
-
37
3
50
-
Jaguar Land Rover
38
-
-
-
58
100
-
-
-
100
100
-
Kia
1
-
-
-
11
99
-
-
37
1
50
-
Mercedes
-
-
-
-
17
5
-
-
-
81
81
-
Nissan
27
-
-
-
5
-
17
16
71
1
66
0
Subaru
34
-
-
-
-
-
-
-
-
-
48
-
Toyota
4
0
-
-
-
-
-
20
-
9
59
-
FCAf
28
2
92
-
11
99
3
51
23
12
69
-
Fleet Total
20
0
11
2
5
30
5
20
23
10
61
0
fFCA is listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and are included in
industry-wide "Total" or "All" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
-49-
-------
Table 3-21. Model Year 2016 Off-Cycle Technology Credits from the Menu, by
Manufacturer and Technology (g/mi)
Active
Aerodynamics
Engine &
Transmission
Warmup
Other
u
01
4->
Ride height
adjustment
01
c
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C
o
o
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u
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warmup
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transmis
warmup
11
01 u
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stop-stai
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4—
01
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X
0
01
4->
X
01
re
Q.
(0
o
in
Total
BMW
0.0
-
1.5
-
2.3
0.1
0.7
5
Ford
1.0
-
0.7
0.6
-
0.4
0.2
-
3
GM
0.1
-
0.5
-
1.7
0.3
0.3
-
3
Honda
-
-
-
1.6
0.0
0.1
0.3
-
2
Hyundai
0.0
-
-
0.6
0.5
0.0
0.1
-
1
Jaguar Land Rover
0.2
-
-
-
2.5
3.6
0.8
-
7
Kia
0.0
-
-
0.8
0.9
0.0
0.1
-
2
Mercedes
-
-
-
-
0.2
2.4
0.9
-
4
Nissan
0.1
-
0.3
1.5
0.1
0.0
0.2
0.0
2
Subaru
0.2
-
-
-
-
-
0.1
-
0
Toyota
0.0
0.0
0.5
-
1.3
0.3
0.2
-
2
0.2
0.0
1.5
0.8
3.4
0.5
0.2
-
Fleet Total
0.2
0.0
0.5
0.5
1.0
0.3
0.2
0.0
3
fFCA is listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial
certification data, and are included in industry-wide "Total" or "AN" values. Should the investigation and corrective actions yield
different C02 data, any relevant changes will be used in future reports.
Note that "0.0" indicates that the manufacturer did implement that technology, but that the overall penetration rate was not high
enough to round to 0.1 g/mi, whereas a dash indicates no use of a given technology by a manufacturer.
2. Off-Cycle Technology Credits Based on 5-Cycle Testing
As was the case in the 2012-2015 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. The 2014 model year GM vehicles receiving this credit were the
eAssist-equipped Buick LaCrosse, Buick Regal, Chevrolet Malibu, and Chevrolet Impala. In
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the 2015 and 2016 model years, die eAssist-equipped vehicles were die Buick LaCrosse,
Buick Regal, and Chevrolet Malibu, totaling almost 100,000 vehicles in the 2016 model
year. 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-
2016 model years are shown in Table 3-22. The calculated fleet-wide grams per mile benefit
would round 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
2016
27,814
-
27,814
Total
162,866
7,289
170,155
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.34 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. 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.35
34 See 40 CFR 86.1869-12(d).
35 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/vehicle-and-engine-
certification/compliance-information-light-duty-greenhouse-gas-ghg-standards.
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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
2014.30 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 A/C compressor made by
Denso with variable crankcase suction valve technology. EPA approved the credits for FCA,
Ford, and GM in September of 20 1 5.37 EPA approved additional credits under this pathway
in January of 2017 for BMW, Ford, GM, and Volkswagen.38
Most of the credits that have been approved have been for credits for previous model years,
and thus won't be included in the detailed reporting in this section for the 2016 model year.
Credit balances have been updated to include retroactive credits that have been reported to
EPA, thus any relevant tables that included data from previous model years will reflect the
addition of these credits. GM is the only manufacturer to report credits via this pathway in
the 2016 model year, for the Denso A/C compressor. They reported 309,604 Mg of credits
from this technology in the 2016 model year.
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 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
36 "EPA Decision Document: Mercedes-Benz Off-cycle Credits for MYs 2012-2016," U.S. EPA-420-R-14-025, Office of
Transportation and Air Quality, September 2014.
37 "EPA Decision Document: Off-cycle Credits for FCA Automobiles, Ford Motor Company, General Motors Corporation,
and Volkswagen Group of America" U.S. EPA-420-R-15-014, Office of Transportation and Air Quality, September 2015.
38 "EPA Decision Document: Off-cycle Credits for BMW Group, Ford Motor Company, and General Motors Corporation,"
U.S. EPA-420-R-17-003, Office of Transportation and Air Quality, January 2017.
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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 COz-equivalent standard option, which
manufacturers may choose in lieu of complying with the cap standards. This COz-equivalent
standard option allows manufacturers to include CH4 and N2O, on a COz-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. Only Mazda and Subaru
chose to use this approach in the 2016 model year.
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. Eight manufacturers made use of the flexibility offered by this approach in the 2016
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 2010-2015 or generated in
2016.
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Table 3-23. Reported CH4 and N2O Deficits by Manufacturer and Fleet, 2016
Model Year (Mg)
Car
Truck
Grams/Mile
Manufacturer
ch4
NzO
ch4
NzO
Total
Equivalent of
Total
BMW
879
6,982
1,130
8,976
17,967
0.2
Ford
8,479
3,489
78,171
56,591
146,730
0.3
GM
2,922
-
11,055
17,554
31,531
0.1
Mazda
-
-
-
6,763
6,763
0.1
Nissan
4,401
56,360
7,320
87,252
155,333
0.6
Toyota
-
18,288
-
24,344
42,632
0.1
FCAf
38
-
5,071
-
5,109
0.0
Volkswagenf
200
1,096
481
3,546
5,323
0.0
Fleet Total
16,919
86,215
103,228
205,026
411,388
0.1
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes 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-
2016 model years. As in all of the tables in this document, the final Fleet Total row indicates
the impact across the entire fleet, including manufacturers and vehicles that did not
participate in the alternative CH4 and/or N2O standards.
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Table 3-24. CH4 Deficits by Manufacturer and Fleet, 2012-2016 Model Years (g/mi)
Manufacturer
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
2016 Model Year
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
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
0.0
0.1
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
0.0
0.3
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
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
0.0
0.1
0.1
0.0
0.1
0.0
FCAf
0.1
0.1
0.1
0.0
0.0
0.0
0.0
0.1
0.1
0.0
0.0
0.0
0.0
0.0
0.0
Volkswagenf
0.6
0.1
0.5
0.5
0.0
0.5
0.5
0.0
0.4
0.0
0.0
0.0
0.0
0.0
0.0
Fleet Total
0.1
0.1
0.1
0.1
0.1
0.1
0.0
0.1
0.1
0.0
0.1
0.0
0.0
0.1
0.0
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and are
included in industry-wide "Total" or "AN" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
Table 3-25. N2O Deficits by Manufacturer and Fleet, 2012-2016 Model Years (g/mi)
Manufacturer
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
2016 Model Year
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
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
0.1
0.4
0.2
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
0.0
0.2
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
0.0
0.1
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
0.0
0.0
0.0
Mazda
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
0.1
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
0.3
0.9
0.5
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
0.1
0.1
0.1
Volkswagenf
1.4
1.2
1.4
1.4
0.7
1.3
1.3
0.8
1.2
0.9
0.4
0.8
0.0
0.1
0.0
Fleet Total
0.1
0.2
0.1
0.2
0.2
0.2
0.2
0.0
0.1
0.1
0.2
0.1
0.0
0.1
0.1
fVolkswagen is listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and are included in
industry-wide "Total" or "All" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
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G. 2016 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
2016 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.39 The final row
shows values for the total 2016 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 A/C and off-cycle credits totaling 13 g/mi, yielding a final compliance value of 298
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.40 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 2016 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.
39 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.
40 Versions of Tables 3-19, 3-20, and 3-21 for the 2012-2014 model years are shown in Appendix C.
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Table 3-26. 2016 Compliance Values - Combined Passenger Car & Light Truck
Fleet (g/mi)
Credits (g/mi)
2-Cycle
CH4&N2O
Manufacturer
Tailpipe
A/C
Off-Cycle
Deficit
Compliance Value
BMW
276
10
5
0
262
Ford
311
10
3
0
298
GM
319
11
3
0
305
Honda
245
8
2
0
234
Hyundai
239
7
1
0
231
Jaguar Land Rover
356
22
7
0
326
Kia
267
6
2
0
259
Mazda
231
0
0
0
231
Mercedes
296
11
4
0
281
Mitsubishi
248
5
0
0
242
Nissan
246
8
2
1
237
Subaru
246
3
0
0
243
Tesla
0
6
0
0
-6
Toyota
279
9
2
0
267
Volvo
283
11
0
0
273
FCAf
331
18
7
0
306
Volkswagenf
264
9
0
0
256
Fleet Total
285
10
3
0
272
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
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Table 3-27. 2016 Compliance Values - Passenger Car Fleet (g/mi)
Credits (g/mi)
2-Cycle
CH4&N2O
Manufacturer
Tailpipe
A/C
Off-Cycle
Deficit
Compliance Value
BMW
262
9
4
0
249
Ford
254
9
2
0
243
GM
260
10
3
0
246
Honda
213
9
2
0
202
Hyundai
236
7
1
0
228
Jaguar Land Rover
322
19
3
0
299
Kia
246
6
1
0
239
Mazda
214
0
0
0
214
Mercedes
269
11
4
0
254
Mitsubishi
241
3
0
0
238
Nissan
221
7
2
0
212
Subaru
244
3
0
0
241
Tesla
6
0
0
-6
Toyota
224
8
1
0
214
Volvo
249
8
0
0
241
FCAf
288
17
3
0
267
Volkswagenf
247
8
0
0
239
Fleet Total
240
9
2
0
229
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
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Table 3-28. 2016 Compliance Values - Light Truck Fleet (g/mi)
Credits (g/mi)
2-Cycle
CH4&N2O
Manufacturer
Tailpipe
A/C
Off-Cycle
Deficit
Compliance Value
BMW
310
11
7
0
292
Ford
354
11
4
1
339
GM
365
11
4
0
350
Honda
285
8
2
0
275
Hyundai
339
5
5
0
329
Jaguar Land Rover
361
23
8
0
330
Kia
330
6
3
0
321
Mazda
259
0
0
0
259
Mercedes
342
12
3
0
326
Mitsubishi
251
7
0
0
244
Nissan
297
9
3
1
286
Subaru
246
3
0
0
243
Toyota
342
11
3
0
328
Volvo
300
12
0
0
288
FCAf
348
19
8
0
321
Volkswagenf
320
12
0
0
308
Fleet Total
332
11
4
0
317
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
Table 3-29 shows the calculated compliance values for each manufacturer's car and truck
fleet for the 2012-2016 model years. As can be seen in the table, the increases in
manufacturer compliance values from 2015 to 2016 outweighed the decreases, leading to a
net increase of 4 g/mi across the fleet of combined cars and trucks.
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Table 3-29. 2012-2016 Model Year Compliance Values by Manufacturer and Fleet, 2012-2016 Model Years
(g/mi)
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
2016 Model Year
Manufacturer
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car Truck
All
Car
Truck
All
BMW
267
348
290
260
329
279
245
295
257
244
300
257
249
292
262
BYD Motors
0
0
0
0
0
0
No production volume
Coda
0
0
0
0
\lo production volume
Ford
247
357
295
239
347
298
237
342
289
239
324
287
243
339
298
GM
263
364
306
253
362
299
246
336
288
247
332
296
246
350
305
Honda
234
315
263
226
306
254
225
291
254
212
275
236
202
275
234
Hyundai
239
305
244
233
310
236
241
315
247
238
313
244
228
329
231
Jaguar Land Rover
371
431
418
337
405
390
316
331
328
308
315
313
299
330
326
Karma Auto
102
102
No production volume
Kia
253
321
261
247
293
249
258
324
262
253
319
258
239
321
259
Mazda
241
324
263
232
296
251
220
287
240
217
285
238
214
259
231
Mercedes
295
366
320
273
346
297
262
342
284
253
327
281
254
326
281
Mitsubishi
262
283
267
254
267
258
224
256
236
215
254
228
238
244
242
Nissan
256
363
288
228
328
260
222
318
253
209
291
235
212
286
237
Porsche
325
362
342
309
363
336
Included in Volkswagen
Subaru
255
294
280
253
268
262
249
252
251
238
244
243
241
243
243
Suzuki
267
361
287
266
330
273
No production volume
Tesla
-6
-6
-6
-6
-6
-6
-6
-6
-6
-6
Toyota
214
339
263
218
332
268
211
333
257
215
323
265
214
328
267
Volvo
286
331
300
282
337
307
280
340
311
246
324
277
241
288
273
FCAf
277
351
327
267
345
314
270
324
309
246
312
291
267
321
306
Volkswagenf
268
323
275
259
301
264
249
309
261
236
311
252
239
308
256
Fleet Total
249
347
287
240
337
278
237
322
274
230
311
268
229
317
272
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and are
included in industry-wide "Total" or "AN" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
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H. 2016 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.41 The footprint "curves" for the 2012-2016 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. 2012-2016 Model Year CO2 Footprint Target Curves
400
2012 Trucks
¦ 2013 Trucks
2014 Trucks
2015 Trucks
B80
2016 Trucks
--2012 Cars
--2013 Cars
2014 Cars
360
2015 Cars
2016 Cars
340
v 320
1 300
2
32
8™ 280
260
240
220
200
20
25
30
35
40
45
50
55
60
65
70
75
Footprint (square feet)
41 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.
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The calculated CO2 standards for the 2012-2016 model years are shown in Table 3-30.
Manufacturers use these unique footprint-based car and truck standards - which are
required by regulation - to determine their compliance status. A third value for each
manufacturer - a sales- and VMT-weighted standard for the combined car and truck fleet -
is provided for convenience and comparative purposes, but it is not a compliance value
required by the regulations. The numerical CO2 standards decreased from 2015 to 2016 for
every manufacturer except Mitsubishi, resulting in an increase in the overall stringency of
the program of 11 g/mi in the 2016 model year.
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Table 3-30. 2012-2016 Model Year CO2 Standards by Manufacturer and Fleet, 2012-2016 Model Years (g/mi)
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
2016 Model Year
Manufacturer
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car Truck
All
Car Truck
All
BMW
269
336
288
263
324
280
258
313
271
244
301
257
235
286
250
BYD Motors
277
0
277
269
0
269
261
0
261
No production volume
Coda
246
0
246
239
0
239
No production volume
Ford
265
364
308
265
355
315
254
345
299
245
329
292
234
315
280
GM
272
369
313
263
360
304
254
357
302
244
336
296
233
318
281
Honda
263
333
288
256
318
278
250
308
275
236
294
258
227
281
251
Hyundai
269
316
273
261
309
263
253
301
257
246
285
249
231
280
233
Jaguar Land Rover
293
400
377
283
354
338
271
332
322
257
338
322
250
288
283
Karma
315
0
315
No production volume
Kia
266
338
274
258
303
259
251
312
255
241
308
247
229
288
243
Mazda
259
323
276
250
311
268
251
300
265
241
285
254
228
271
244
Mercedes
277
360
306
262
354
292
258
330
278
249
311
273
239
290
258
Mitsubishi
261
307
271
249
296
264
236
287
254
225
273
241
219
260
247
Nissan
263
337
285
259
324
280
249
318
271
239
300
258
229
284
247
Porsche
332
422
374
314
410
363
Included in Volkswagen
Subaru
260
309
291
251
299
281
243
289
279
234
276
265
224
262
253
Suzuki
251
325
267
243
296
249
No production volume
Tesla
304
0
304
296
0
296
288
0
288
276
0
276
267
0
267
Toyota
264
342
295
257
330
289
250
326
279
239
305
269
228
292
258
Volvo
272
325
288
264
316
288
258
307
283
247
325
277
238
289
272
FCAf
277
345
323
270
338
311
262
327
309
247
307
288
237
295
278
Volkswagenf
263
327
271
257
317
264
250
311
262
236
297
249
226
279
239
Fleet Total
267
349
299
261
339
292
253
330
287
241
312
274
231
297
263
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and are
included in industry-wide "Total" or "AN" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
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Overall, the standards decreased by 11 g/mi from 2015 to 2016, an increase in stringency
driven by the more stringent target curves for the 2016 model year. However, the target
curves represent only one of several key factors that influence the standards. While increased
stringency overall from one year to the next is expected because of the structure of the target
curves, there are other contributing factors that can result in - and explain - occasional
exceptions that may occur. For example, Table 3-30 shows that Mitsubishi's calculated fleet-
wide standard increased - or became less stringent - by 6 g/mi, despite the fact that their car
and truck standards both increased in stringency. The factor driving this apparent
contradiction is that Mitsubishi's truck production (with standards numerically less stringent
than cars) increased dramatically, from 30 percent in 2015 to 65 percent of their fleet in the
2016 model year.
The average footprint for the overall fleet increased in the 2016 model year by 0.1 square
feet, to 49.5 square feet. The average car footprint remained unchanged at 46.1 square feet,
and the truck footprint decreased by 0.2 square feet to 53.7 square feet, the smallest truck
footprint since the GHG standards took effect. Of the 17 manufacturers shown in Table 3-
31 with 2016 vehicles, fleet average footprint increased for eleven, decreased for four, and
was unchanged for two. Increases in footprint spanned from 0.1 square feet (Toyota) to 2.5
square feet (Volvo). Decreases in footprint ranged from 0.1 square feet (Volkswagen) to 0.9
square feet (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.
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Table 3-31. Average Footprint by Manufacturer and Fleet, 2012-2016 Model Years (square feet)
2012 Model Year
2013 Model Year
2014 Model Year
2015 Model Year
2016 Model Year
Manufacturer
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
All
Car
Truck
All
BMW
45.9
51.4
47.3
46.2
50.8
47.4
47.1
50.4
47.8
46.6
51.0
47.5
47.1
50.6
48.0
BYD Motors
47.9
47.9
47.9
47.9
47.9
47.9
No production volume
Coda
41.5
41.5
41.5
41.5
No production volume
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
46.7
59.0
53.3
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
46.6
59.3
53.3
Honda
45.0
50.5
46.8
44.9
49.3
46.3
45.6
49.2
47.0
45.0
49.1
46.5
45.3
49.6
47.0
Hyundai
46.2
46.4
46.2
46.1
47.0
46.2
46.1
47.5
46.2
47.2
47.0
47.2
46.3
49.2
46.3
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
50.2
51.2
51.0
Karma
58.1
58.1
No production volume
Kia
45.6
51.9
46.2
45.5
45.6
45.5
45.8
50.0
46.1
46.2
52.6
46.7
45.9
51.3
47.1
Mazda
43.9
48.1
44.9
43.6
47.6
44.7
45.6
47.2
46.0
46.1
47.1
46.3
45.4
47.1
46.0
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
47.5
51.7
48.9
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
43.8
44.2
44.1
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
45.8
50.1
47.1
Porsche
44.7
51.8
47.7
43.7
51.9
47.6
Included in Volkswagen
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
44.7
44.8
44.7
Suzuki
42.1
48.7
43.4
41.8
44.0
42.0
No production volume
Tesla
53.6
53.6
53.6
53.6
53.6
53.6
53.6
53.6
53.9
53.9
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
45.5
52.5
48.5
Volvo
46.8
48.6
47.3
46.8
49.0
47.7
47.2
48.9
48.0
47.3
48.0
47.5
47.7
51.4
50.0
FCAf
47.2
53.6
51.4
47.6
54.5
51.5
48.0
54.1
52.2
47.1
52.7
50.7
47.5
53.2
51.4
Volkswagenf
45.2
49.0
45.6
45.2
49.0
45.6
45.5
50.0
46.3
45.1
50.1
46.0
45.1
48.9
45.9
Fleet Total
45.7
54.5
48.8
45.9
54.7
49.1
46.1
55
49.7
46.1
53.9
49.4
46.1
53.7
49.5
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and are
included in industry-wide "Total" or "AN" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
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I. Overall Compliance Summary
Final compliance for the 2012-2016 model years is summarized in Table 3-32 for die 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 standard from the compliance value. This value is negative in the
2012 to 2015 model years, indicating that, overall, the industry was generating credits in
these model years. A positive value for the 2016 model year indicates that the industry
generated a deficit. 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 and credit
generation. In the 2015 model year the bulk of the credit generation was again attributable
to passenger cars, although the trucks also generated credits with a performance value of 311
g/mi and an applicable fleet standard of 312 g/mi. The generation of deficits in the 2016
model year can be traced to the truck fleet, as seen in Table 3-34, whereas passenger cars
generated credits by achieving a performance value slightly lower than the applicable
standard.
Table 3-32. Performance & Credit Summary, 2012-2016 Model Years -
Combined Cars and Trucks (g/mi)*
Credits
Performance
Model
2-Cycle
Off-
CH4&N2O
minus
Year
Tailpipe
FFV
A/C
Cycle
Deficit
Performance
Standard
Standard
2012
302
8.1
6.1
0.7
0.2
287
299
-12
2013
294
7.8
6.9
0.8
0.3
278
292
-13
2014
294
8.9
8.4
2.5
0.2
274
287
-13
2015
286
6.4
9.4
2.7
0.2
268
274
-7
2016
285
-
10.0
2.9
0.1
272
263
9
*Values stated in this table and in the text are correct, although rounding of values may result in some apparent differences.
-66-
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Table 3-33. Performance & Credit Summary, 2012-2016 Model Years -
Passenger Cars (g/mi)*
Credits
Performance
Model
2-Cycle
Off-
CH4&N2O
minus
Year
Tailpipe
FFV
A/C
Cycle
Deficit
Performance
Standard
Standard
2012
259
4.0
5.4
0.4
0.1
249
267
-18
2013
251
4.0
6.3
0.6
0.3
240
261
-20
2014
250
4.6
7.4
1.6
0.3
237
253
-16
2015
243
3.1
8.0
1.9
0.1
230
241
-11
2016
240
-
8.6
1.8
0.1
229
231
-1
*Values stated in this table and in the text are correct, although rounding of values may result in some apparent differences.
Table 3-34. Performance & Credit Summary, 2012-2016 Model Years - Light
Trucks (g/mi)*
Credits
Performance
Model
2-Cycle
Off-
CH4&N2O
minus
Year
Tailpipe
FFV
A/C
Cycle
Deficit
Performance
Standard
Standard
2012
369
14.5
7.3
1.0
0.3
347
349
-2
2013
360
13.8
7.9
1.1
0.3
337
339
-2
2014
349
14.3
9.7
3.6
0.1
322
330
-8
2015
336
10.2
10.9
3.7
0.2
311
312
-1
2016
332
-
11
4
0
317
297
20
*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 2016 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 2016 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. BMW, for
example, generated a 2016 model year deficit because their overall compliance value of 262
g/mi is above their fleet-wide standard of 250 g/mi. Honda, on the other hand, reported net
credits based on a compliance value of 234 g/mi, 16 g/mi lower than their fleet-wide
standard. Note, however, that the generation of a net deficit in the 2016 model year by any
manufacturer does not necessarily indicate that the manufacturer has failed to comply with
the 2016 model year standards. BMW, for example, will offset their 2016 deficit by using
credits either purchased from another manufacturer or generated in previous model years,
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thereby complying with the 2016 standards.42 The final row of Table 3-35 shows the
conclusion that the 2016 model year was a deficit-generating year overall, based on the
compliance value that is 9 g/mi above the 2016 model year standard. A comparison of the
values in the three previous tables to EPA projections for these values is in Appendix A.43
Table 3-35. 2016 Model Year Compliance Summary by Manufacturer and
Fleet (g/mi)
Compliance Value
Standard
Net Compliance
Manufacturer
Car
Truck
All
Car
Truck
All
Car
Truck
All
BMW
249
292
262
235
286
250
14
6
12
Ford
243
339
298
234
315
280
9
24
18
GM
246
350
305
233
318
281
13
32
24
Honda
202
275
234
227
281
251
-25
-6
-16
Hyundai
228
329
231
231
280
233
-3
49
-1
Jaguar Land Rover
299
330
326
250
288
283
49
42
43
Kia
239
321
259
229
288
243
10
33
15
Mazda
214
259
231
228
271
244
-14
-12
-13
Mercedes
254
326
281
239
290
258
15
36
23
Mitsubishi
238
244
242
219
260
247
19
-16
-5
Nissan
212
286
237
229
284
247
-17
2
-10
Subaru
241
243
243
224
262
253
17
-19
-10
Tesla
-6
-6
267
267
-273
-273
Toyota
214
328
267
228
292
258
-14
36
10
Volvo
241
288
273
238
289
272
3
-1
0
FCAf
267
321
306
237
295
278
30
26
27
Volkswagenf
239
308
256
226
279
239
13
29
17
Fleet Total
229
317
272
231
297
263
-1
20
9
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions.
These data are based on initial certification data, and are included in industry-wide "Total" or "AN" values. Should the
investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
42 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.
43 EPA projections are from the previously-referenced rulemakings from May 7, 2010 and October 15, 2012.
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4. Credit Transactions
Credits may be traded among manufacturers with a great deal of flexibility (with the
exception of 2009 model year credits and credits generated by manufacturers using the
TLAAS program, which are restricted to use only within a manufacturer's own fleets). There
are only a few regulatory requirements that relate to credit transactions between
manufacturers (other than the restrictions just noted), and these are generally designed to
protect those involved in these transactions. While it may seem obvious, it is worth stating
that a manufacturer may not trade credits that it does not have. Credits that are available for
trade are only those available (1) at the conclusion of a model year when all the data is
available with which to calculate the number of credits generated by a manufacturer, and not
before; and (2) after a manufacturer has offset any deficits they might have. Credit
transactions that result in a negative credit balance for the selling manufacturer are not
allowed and can result in severe punitive actions. Although a third party may facilitate
transactions, EPA's regulations allow only the automobile manufacturers to engage in credit
transactions and hold credits.
Since the 1990's, many of EPA's vehicle emissions regulatory programs have included the
flexibilities of averaging, banking, and trading (ABT). The incorporation of ABT provisions
in EPA emissions regulations has been generally supported by a wide range of stakeholders:
by manufacturers for the increased flexibility that ABT offers and by environmental groups
because ABT enhances EPA's ability to introduce standards of greater stringency in an
earlier time frame than might otherwise be achieved. Historically, manufacturers tended to
make use of the ability to average emissions and bank emissions credits for use in
subsequent years, but until recently there has been almost no credit trading activity between
companies. The use of trading provisions in EPA's light-duty GHG program is a historic
development, and one that EPA welcomes because we believe it will allow greater GHG
reductions, lower compliance costs, and greater consumer choice.
The credit transactions reported by manufacturers through the 2016 model year are shown
in Table 4-1. Note that 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. As of the close of the 2016 model year, more than 30
million Megagrams of CO2 credits had changed hands. Credit distributions are shown as
negative values, in that a disbursement represents a deduction of credits from 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
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example, that a sale of 2010 credits could potentially be reported to EPA as late as the
reporting deadline for the 2021 model year, and those 2010 credits traded in model year
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.
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Table 4-1. Cumulative Reported Credit Sales and Purchases (Mg)
Manufacturer
Model Year "Vintage
M
Total
2010
2011
2012
2013
2014
2015
2016
Credits Disbursed
Coda
Honda
Nissan
Tesla
Toyota
14,182,329
950,000
35,580
2,507,000
6,590,901
1,345,570
14,192
5,524
250,000
177,941
1,727
1,000,000
1,049,384
1,020,296
831,358
1,337,853
2,452,519
7,251
20,773,230
3,545,570
3,635,246
3,338,358
BMW
2,000,000
-
-
-
-
-
-
2,000,000
T3
01
Ferrari
265,000
265,000
'5
O"
FCA
11,424,329
7,090,901
-
1,049,384
1,020,296
1,337,853
2,452,519
21,922,763
u
<
GM
-
-
5,524
1,727
-
-
-
7,251
01
Jaguar Land Rover
-
39,063
-
-
831,358
-
-
870,421
u
McLaren
6,507
6,507
Mercedes
3,985,580
814,192
427,941
1,000,000
-
-
-
6,227,713
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5. Compliance Status After the 2016 Model Year
Based on the information reported to EPA, the vast majority of manufacturers have
successfully demonstrated compliance with the 2012-2016 model year standards and are
carrying a positive credit balance into the 2017 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 the 2012-2016 model years, the first phase 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 2012-2016 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 2009-2016
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.
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Table 5-1. Cumulative Credit Status After the 2016 Model Year (Mg)
Early Credits
(2009-2011)
2012
2013
2014
2015
2016
Bought, Sold,
Bought, Sold,
Bought, Sold,
Bought, Sold,
Bought, Sold,
Bought, Sold,
Total Carried
Forfeited, or
Forfeited, or
Forfeited, or
Forfeited, or
Forfeited, or
Forfeited,
or
Forward to
Manufacturer
Earned
Expired
Earned
Expired
Earned
Expired
Earned
Expired
Earned
Expired
Earned Expired
2017
Toyota
80,435,498 (32,239,098)
13,163,009
0
9,875,003
0
9,839,348
(831,358)
2,564,396
0
(4,727,835)
0
78,078,963
Honda
35,842,334 (34,906,583)
7,941,932
0
7,307,995
0
6,480,503
0
7,192,274
0
6,166,021
0
36,024,476
Nissan
18,131,200 (10,485,694)
(729,937)
(250,000)
5,190,521
(1,000,000)
4,854,133
0
8,089,026
0
2,883,585
0
26,682,834
Ford
16,116,453
(5,882,011)
4,789,580
0
8,238,561
0
4,843,648
0
2,047,791
0
(8,069,883)
0
22,084,139
Hyundai
14,007,495
(4,482,649)
3,535,510
0
5,777,836
(169,775)
1,113,812
0
647,751
0
153,564
0
20,583,544
GM
25,510,557
(6,894,611)
3,575,173
5,524
2,438,654
1,727
7,823,425
0
396,674
0
(13,190,423)
0
19,666,700
Subaru
5,755,171
(491,789)
646,317
0
1,444,372
0
2,882,640
0
3,044,329
0
1,220,109
0
14,501,149
Mazda
5,482,642
(1,340,917)
734,887
0
786,431
0
1,547,009
0
970,540
0
1,243,959
0
9,424,551
Kia
10,444,192
(2,362,882)
1,303,379
0
1,330,236
(123,956)
(771,893)
0
(1,588,713)
0
(2,218,748)
0
6,011,615
BMW
1,251,522
1,865,209
(110,996)
0
48,709
0
1,075,752
0
26,118
0
(953,972)
0
3,202,342
Mercedes
378,272
4,799,772
(723,216)
427,941
(298,662)
1,000,000
(401,140)
(28,416)
(597,785)
0
(1,565,261)
0
2,991,505
Mitsubishi
1,449,336
(583,146)
57,837
0
58,209
0
351,031
0
348,232
0
73,971
0
1,755,470
Suzuki
876,650
(265,311)
(127,699)
0
(55,398)
0
0
0
0
0
0
0
428,242
Karma Automotive
0
0
58,852
0
0
0
0
0
0
0
0
0
58,852
BYD Motors
0
0
595
0
1,681
0
2,548
0
0
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)
2,452,519 (2,452,519)
576
Coda
0
0
5,524
(5,524)
1,727
(1,727)
0
0
0
0
0
0
0
Volvo
730,187
0
(175,195)
0
(297,006)
0
(183,695)
0
10,872
(85,163)
(9,218)
0
(9,218)
Jaguar Land Rover
0
39,063
(488,109)
0
(716,448)
0
(90,192)
831,358
135,773
0
(1,099,226)
0
(1,387,781)
FCAf
10,411,321
18,515,230
(1,221,514)
0
(1,003,146)
1,049,384
(45,458)
1,020,296
(1,462,661)
1,337,853
(11,836,032) 2,452,519
19,217,792
Volkswagenf
6,441,405
(1,404,947)
(426,200)
0
31,148
0
112,228
0
(385,236)
0
(1,929,790)
0
2,438,608
Fleet Total
233,314,007 (76,170,136)
32,186,594
0
41,437,898
(293,731)
40,453,995
(28,416)
22,777,234
(85,163)
(31,406,660)
0
261,759,183
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data, and are
included in industry-wide "Total" or "All" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in future reports.
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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.44 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
Trucks
1500
-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:
Fleet
2012
Credits
(Mg)
2013
Credits
(Mg)
Cars
Trucks
1500
-500
1000
-1000
Total
(100(3)
Here, the
manufacturer
would have 1000
Mg of 2012 credits
There are multiple choices for a manufacturer faced with such a situation. As shown above,
all deficits are adequately addressed within each model year, and a manufacturer could leave
it at that. Doing so would mean carrying forward the 1000 Mg of credits remaining from
2012 into 2014. There is, however, a smarter - but not mandatory - option. Because the
regulations allow car and truck credits and deficits to be managed as separate "bins," and
because newer credits are generally more valuable than older credits (because they last
longer) it would be smarter for this manufacturer to use the 1000 Mg of credits from 2012 to
offset the deficit of -1000 Mg in the 2013 truck fleet, as shown below:
2012
2013
Credits
Credits
Fleet
(Mg)
(Mg)
Cars
1500
1000
Trucks
-500
-1000
Total
1000
(1000)
Here, the
manufacturer
would have 1000
Mg of 2013 credits
44 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).
-74-
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The bottom line remains the same (1000 Mg of credits are carried into 2014), except that in
this case the credits carried forward have a vintage from the newer 2013 model year.
Theoretically, a manufacturer could use any mix of 2012 and 2013 credits to offset the 2013
truck deficit, in which case the credits remaining to carry forward would be a mix of 2012
and 2013 credits. The value of a given vintage is based on its expiration date, and the
expiration date of 2010-2016 model year credits in EPA's GHG program is fixed at the 2021
model year, meaning that for the 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 2017 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 or 5-1).
With the exception of the 2015 model year, in which Volvo generated credits, they have
consistently been generating deficits in each year. The early credits have been sufficient to
offset almost all of these deficits. A small deficit of about 9200 Mg remains from the 2016
model year. A deficit may be carried forward for three years after the year in which it is
generated, meaning that deficits from the 2016 model year must be reconciled by the end of
the 2019 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 years 2012-2015, Jaguar
Land Rover and Mercedes reported 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).
-75 -
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Table 5-2. Credits Available After the 2016 Model Year, Reflecting Trades & Transfers (Mg)
Total Carried
Forward to
Manufacturer
2010
2011
2012
2013
2014
2015
2016
2017
Toyota
18,943,388
14,651,963
13,163,009
10,336,958
10,139,675
7,231,364
3,612,606
78,078,963
Honda
100
935,651
7,941,932
7,307,995
6,480,503
7,192,274
6,166,021
36,024,476
Nissan
4,653,920
507,179
989,226
4,510,993
4,871,086
8,089,026
3,061,404
26,682,834
Ford
0
2,164,559
4,789,580
8,238,561
4,843,648
2,047,791
0
22,084,139
Hyundai
4,899,895
4,012,969
3,535,510
5,613,813
1,231,344
916,265
373,748
20,583,544
GM
0
4,157,560
3,580,697
2,853,416
7,823,425
1,251,602
0
19,666,700
Subaru
1,578,137
2,876,413
646,317
1,487,331
3,001,354
3,189,186
1,722,411
14,501,149
Mazda
3,201,708
925,179
749,725
786,431
1,547,009
970,540
1,243,959
9,424,551
Kia
0
3,501,956
1,303,379
1,206,280
0
0
0
6,011,615
BMW
1,429,755
444,856
63,382
162,479
1,075,752
26,118
0
3,202,342
Mercedes
591,687
971,877
427,941
1,000,000
0
0
0
2,991,505
Mitsubishi
423,438
302,394
67,976
90,090
351,031
348,232
172,309
1,755,470
Suzuki
329,382
98,860
0
0
0
0
0
428,242
Karma Auto
0
0
58,852
0
0
0
0
58,852
BYD Motors
0
0
595
1,681
2,548
0
0
4,824
Tesla
0
0
576
0
0
0
0
576
Coda
0
0
0
0
0
0
0
0
Volvo
0
0
0
0
0
0
(9,218)
(9,218)
Jaguar Land Rover
0
0
0
0
(134,941)
(153,614)
(1,099,226)
(1,387,781)
FCAf
2,057,965
9,682,875
31,342
1,484,695
1,957,144
1,551,252
2,452,519
19,217,792
Volkswagenf
496,637
1,528,432
60,107
241,204
112,228
0
0
2,438,608
Fleet Total
38,606,012
46,756,216
37,410,146
45,321,927
43,301,806
32,660,036
17,696,533
261,759,183
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data are based on initial certification data,
and are included in industry-wide "Total" or "AN" values. Should the investigation and corrective actions yield different C02 data, any relevant changes will be used in
future reports.
-76-
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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. 45 40 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 projections made a number of
years ago, 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 and footnoted below. 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
use of credits from flexible fuel vehicles (FFV). We also projected relatively high use of
improved A/C systems across the fleet, resulting in projected 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 261 g/mi in the
2016 model year, reducing that by total credits and incentives of about 11 g/mi, thus
yielding a net compliance value of 250 g/mi. We did not make any estimations of the use of
NzO and CH4 alternative standards for two reasons: (1) the overall impact was expected to
45 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final Rule,
Federal Register 75 (7 May 2010): 25469.
46 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.
-77-
-------
be very small, and (2) manufacturers are required to offset deficits accumulated with CO2-
equivalent credits as a result of using this flexibility, thus there is no net impact on the
program.
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)
2-Cycle
Off-
N20&
Model
Tailpipe
FFV
A/C
TLAAS
Cycle
ch4
Year
Emissions
Credit
Credit
Credit
Credit
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
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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
-79-
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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 2012-2016 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 298 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 appendix section that a different methodology is used, specifically to
facilitate an apples-to-apples comparison between actual fleet performance and EPA's
rulemaking 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 subsequent model years, to 10 g/mi
in 2016, because the industry-wide truck fraction of the fleet is higher than projected in the
rulemaking analyses (for more information on footprint trends, see EPA's CO2 and Fuel
Economy Trends report at https://www.epa.gov/fuel-economy-trends).
Tables A-5 and A-6 provide comparative data separately for cars and trucks for the 2012-
2016 model years (though projected values for use of credits by vehicle category are not
available until model year 2016).
-80-
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Table A-4. Actual and Projected CO2 Values, Cars and Trucks Combined (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
298
7.8
6.1
0.6
0.6
0.2
284
296
307
6.5
3.5
1.2
0.0
N/A
295
295
2013
290
7.5
6.9
0.5
0.7
0.3
275
289
298
5.8
5.0
0.9
0.0
N/A
286
286
2014
290
8.5
8.3
0.2
2.4
0.2
271
284
290
5.0
7.5
0.6
0.0
N/A
276
276
2015
282
6.1
9.3
0.3
2.6
0.2
265
272
277
3.7
10.0
0.3
0.0
N/A
263
263
2016
281
0.0
9.9
0.0
2.8
0.1
269
260
261
0.0
10.6
0.1
0.5
N/A
250
250
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
5.4
0.2
0.4
0.1
249
267
N/A
N/A
N/A
N/A
0.0
N/A
263
263
2013
251
4.0
6.3
0.1
0.6
0.3
240
261
N/A
N/A
N/A
N/A
0.0
N/A
256
256
2014
250
4.6
7.4
0.1
1.6
0.3
237
253
N/A
N/A
N/A
N/A
0.0
N/A
247
247
2015
243
3.1
8.0
0.0
1.9
0.1
230
241
N/A
N/A
N/A
N/A
0.0
N/A
236
236
2016
240
0.0
8.6
0.0
1.8
0.1
230
231
235
0.0
10.2
0.0
0.4
N/A
225
225
Table A-6. Actual and Projected CO2 Values, Light Trucks (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
369
14.5
7.3
1.3
1.0
0.3
347
349
N/A
N/A
N/A
N/A
0.0
N/A
346
346
2013
360
13.8
7.9
1.1
1.1
0.3
337
339
N/A
N/A
N/A
N/A
0.0
N/A
337
337
2014
349
14.3
9.7
0.3
3.6
0.1
322
330
N/A
N/A
N/A
N/A
0.0
N/A
326
326
2015
336
10.2
10.9
0.6
3.7
0.2
311
312
N/A
N/A
N/A
N/A
0.0
N/A
312
312
2016
332
0.0
11.4
0.0
4.0
0.2
317
297
310
0.0
11.4
0.0
0.7
N/A
298
298
-81-
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Appendix B: Vehicle Production Volume & Market Share
Table B-l. Vehicle Production Volume by Manufacturer and Vehicle Category, Last Three Years
Manufacturer
Model Year 2014
Model Year 2015
Model Year 2016
Car
Truck
All
Car
Truck
All
Car
Truck
All
BMW
297,388
81,938
379,326
338,704
87,135
425,839
289,036
99,451
388,487
BYD Motors
50
-
50
FCA
648,377
1,446,365
2,094,742
769,687
1,416,487
2,186,174
632,859
1,365,868
1,998,727
Ford
1,258,732
1,075,502
2,334,234
888,604
972,891
1,861,495
978,827
1,127,520
2,106,347
GM
1,556,701
1,164,610
2,721,311
1,331,442
1,525,017
2,856,459
1,222,917
1,354,255
2,577,172
Honda
868,337
577,828
1,446,165
1,020,610
556,864
1,577,474
1,071,532
731,659
1,803,191
Hyundai
509,920
38,441
548,361
604,286
41,839
646,125
698,686
19,927
718,613
Jaguar Land Rover
12,323
55,233
67,556
15,600
54,435
70,035
16,903
97,677
114,580
Kia
507,630
28,757
536,387
626,285
49,219
675,504
562,876
158,062
720,938
Mazda
217,333
78,826
296,159
207,100
78,793
285,893
305,635
153,192
458,827
Mercedes
278,126
92,312
370,438
231,899
123,727
355,626
220,201
109,864
330,065
Mitsubishi
60,679
29,828
90,507
91,822
39,366
131,188
26,172
49,097
75,269
Nissan
935,995
389,639
1,325,634
1,216,392
481,583
1,697,975
943,334
409,137
1,352,471
Subaru
109,078
356,818
465,896
175,352
447,383
622,735
153,926
402,071
555,997
Tesla
17,791
-
17,791
24,322
-
24,322
46,058
-
46,058
Toyota
1,423,148
770,302
2,193,450
1,524,190
1,127,056
2,651,246
1,355,012
1,022,967
2,377,979
Volkswagen
487,086
103,524
590,610
487,108
112,382
599,490
442,775
119,437
562,212
Volvo
16,526
15,063
31,589
43,901
24,284
68,185
32,207
57,283
89,490
All
9,205,220
6,304,986
15,510,206
9,597,304
7,138,461
16,735,765
8,998,956
7,277,467
16,276,423
-82-
-------
Table B-2. Vehicle Category Market Share by Manufacturer and Model Year (%)
Manufacturer
2012
2013
2014
2015
2016
Car
Truck
Car
Truck
Car
Truck
Car
Truck
Car
Truck
BMW
74
26
75
25
78
22
80
20
74
26
BYD Motors
100
0
100
0
100
0
Coda
100
0
100
0
FCA
35
65
43
57
31
69
35
65
32
68
Ford
60
40
49
51
54
46
48
52
46
54
GM
61
39
61
39
57
43
47
53
47
53
Honda
68
32
68
32
60
40
65
35
59
41
Hyundai
93
7
97
3
93
7
94
6
97
3
Jaguar Land Rover
23
77
25
75
18
82
22
78
15
85
Karma Automotive
100
0
Kia
90
10
97
3
95
5
93
7
78
22
Mazda
76
24
73
27
73
27
72
28
67
33
Mercedes
68
32
70
30
75
25
65
35
67
33
Mitsubishi
81
19
70
30
67
33
70
30
35
65
Nissan
73
27
71
29
71
29
72
28
70
30
Porsche
57
43
53
47
Subaru
39
61
41
59
23
77
28
72
28
72
Suzuki
81
19
90
10
Tesla
100
0
100
0
100
0
100
0
100
0
Toyota
64
36
60
40
65
35
57
43
57
43
Volkswagen
89
11
89
11
82
18
81
19
79
21
Volvo
73
27
57
43
52
48
64
36
36
64
All
64
36
64
36
59
41
57
43
55
45
-83-
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Appendix C: 2012-2015 Model Year Compliance Values
Table C-l. 2012 Compliance Values - Combined Passenger Car & Light Truck
Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4 & NzO
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
302
0
8
3
0
290
BYD Motors
0
0
0
0
0
0
Coda
0
0
0
0
0
0
Ford
315
14
6
0
1
295
GM
331
16
8
1
0
306
Honda
266
0
4
0
0
263
Hyundai
249
0
4
0
0
244
Jaguar Land Rover
426
0
7
0
0
418
Karma Automotive
102
0
0
0
102
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
FCAf
357
18
10
2
0
327
Volkswagenf
282
1
7
1
2
Fleet Total
302
8
6
1
0
287
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-84-
-------
Table C-2. 2012 Compliance Values - Passenger Car Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4&N20
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
277
0
7
3
0
267
BYD Motors
0
0
0
0
0
0
Coda
0
0
0
0
0
0
Ford
261
9
5
1
0
247
GM
283
11
8
1
0
263
Honda
237
0
3
0
0
234
Hyundai
243
0
4
0
0
239
Jaguar Land Rover
376
0
5
0
0
371
Karma Automotive
102
0
0
0
102
Kia
258
0
5
0
0
253
Mazda
241
0
0
0
0
241
Mercedes
316
11
9
1
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
FCAf
300
13
9
1
0
277
Volkswagenf
274
1
6
1
2
268
Fleet Total
259
4.0
5
0
0
249
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-85 -
-------
Table C-3. 2012 Compliance Values - Light Truck Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4&N2O
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
363
0
11
5
1
348
Ford
385
21
8
0
1
357
GM
397
23
8
2
0
364
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
366
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
FCAf
384
21
10
2
0
351
Volkswagenf
332
0
9
1
1
323
Fleet Total
369
14
7
1
0
347
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-86-
-------
Table C-4. 2013 Compliance Values - Combined Passenger Car & Light Truck
Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4 & NzO
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
292
0
9
4
0
279
BYD Motors
0
0
0
0
0
0
Coda
0
0
0
0
0
0
Ford
321
15
8
1
1
298
GM
325
15
9
1
0
299
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
Mazda
251
0
0
0
0
251
Mercedes
321
12
10
1
0
297
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
3
7
0
0
268
Volvo
318
0
10
0
0
307
FCAf
344
17
10
2
0
314
Volkswagenf
279
8
7
1
2
264
Fleet Total
294
8
7
1
0
278
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-87-
-------
Table C-5. 2013 Compliance Values - Passenger Car Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4&N20
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
271
0
8
3
0
260
BYD Motors
0
0
0
0
0
0
Coda
0
0
0
0
0
0
Ford
256
9
7
1
0
239
GM
273
10
9
1
0
253
Honda
228
0
4
0
1
226
Hyundai
238
0
5
0
0
233
Jaguar Land Rover
347
5
5
0
0
337
Kia
252
0
5
0
0
247
Mazda
232
0
0
0
0
232
Mercedes
296
12
9
1
0
273
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
225
0
7
0
0
218
Volvo
292
0
10
0
0
282
FCAf
289
12
10
1
0
267
Volkswagenf
272
7
6
1
2
259
Fleet Total
251
4
6
1
0
240
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-88-
-------
Table C-6. 2013 Compliance Values - Light Truck Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4&N2O
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
346
0
11
6
0
329
Ford
375
20
8
1
1
347
GM
395
22
9
2
0
362
Honda
312
0
6
0
0
306
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
1
0
346
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
FCAf
380
21
11
3
0
345
Volkswagenf
327
15
10
1
1
301
Fleet Total
360
14
8
1
0
337
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-89-
-------
Table C-7. 2014 Compliance Values - Combined Passenger Car & Light Truck
Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4 & N20
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
270
0
9
4
1
257
BYD Motors
0
0
0
0
0
0
Ford
315
14
9
3
0
289
GM
314
14
10
2
0
288
Honda
259
0
5
1
1
254
Hyundai
253
0
6
1
0
247
Jaguar Land Rover
369
15
21
5
0
328
Kia
269
0
6
1
0
262
Mazda
240
0
0
0
0
240
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
257
Volvo
319
0
8
0
0
311
FCAf
346
17
14
6
0
309
Volkswagenf
280
11
9
0
2
261
Fleet Total
294
9
8
3
0
274
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-90-
-------
Table C-8. 2014 Compliance Values - Passenger Car Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4&N2O
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
256
0
8
3
1
245
BYD Motors
0
0
0
0
0
0
Ford
256
9
8
2
0
237
GM
267
10
9
1
0
246
Honda
228
0
4
1
1
225
Hyundai
247
0
6
1
0
241
Jaguar Land Rover
330
1
12
2
0
316
Kia
265
0
6
1
0
258
Mazda
220
0
0
0
0
220
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
FCAf
298
12
13
3
0
270
Volkswagenf
266
10
8
0
2
249
Fleet Total
250
5
7
2
0
237
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
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Table C-9. 2014 Compliance Values - Light Truck Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4&N2O
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
312
0
11
6
1
295
Ford
375
20
10
3
0
342
GM
369
19
11
3
0
336
Honda
299
0
6
2
0
291
Hyundai
325
0
7
4
0
315
Jaguar Land Rover
377
18
22
6
0
331
Kia
330
0
5
1
0
324
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
FCAf
364
19
14
7
0
324
Volkswagenf
336
16
12
0
1
309
Fleet Total
349
14
10
4
0
322
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-92-
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Table C-10. 2015 Compliance Values - Combined Passenger Car & Light Truck
Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4 & N20
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
270
0
9
4
0
257
Ford
311
12
10
3
0
287
GM
321
12
10
3
0
296
Honda
243
0
5
2
0
236
Hyundai
252
0
6
2
0
244
Jaguar Land Rover
346
7
21
5
0
313
Kia
266
0
6
1
0
258
Mazda
238
0
0
0
0
238
Mercedes
301
6
11
3
0
281
Mitsubishi
228
0
0
0
0
228
Nissan
245
2
7
2
1
235
Subaru
245
0
2
0
0
243
Tesla
0
0
6
0
0
-6
Toyota
279
4
8
3
0
265
Volvo
285
0
8
0
0
277
FCAf
329
13
19
6
0
291
Volkswagenf
269
8
9
0
1
Fleet Total
286
6
9
3
0
268
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-93-
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Table C-ll. 2015 Compliance Values - Passenger Car Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4 & N20
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
256
0
9
4
0
244
Ford
258
8
9
2
0
239
GM
267
8
10
2
0
247
Honda
217
0
4
1
0
212
Hyundai
246
0
6
1
0
238
Jaguar Land Rover
337
13
14
2
0
308
Kia
260
0
6
1
0
253
Mazda
217
0
0
0
0
217
Mercedes
273
6
11
4
0
253
Mitsubishi
215
0
0
0
0
215
Nissan
217
0
7
2
0
209
Subaru
241
0
3
0
0
238
Tesla
0
0
6
0
0
-6
Toyota
225
0
8
3
0
215
Volvo
254
0
8
0
0
246
FCAf
275
9
17
3
0
246
Volkswagenf
251
7
9
0
1
236
Fleet Total
243
3
8
2
0
230
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-94-
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Table C-12. 2015 Compliance Values - Light Truck Fleet (g/mi)
Credits (g/mi)
2-Cycle
Off-
CH4&N2O
Compliance
Manufacturer
Tailpipe
FFV
A/C
Cycle
Deficit
Value
BMW
316
0
11
7
1
300
Ford
353
15
11
3
0
324
GM
362
15
11
4
0
332
Honda
283
0
7
2
1
275
Hyundai
324
0
7
3
0
313
Jaguar Land Rover
349
6
23
5
0
315
Kia
327
0
6
2
0
319
Mazda
285
0
0
0
0
285
Mercedes
347
5
12
3
0
327
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
FCAf
354
15
19
7
0
312
Volkswagenf
336
13
12
0
0
311
Fleet Total
336
10
11
4
0
311
fFCA and Volkswagen are listed separately in this table due to an ongoing investigation and/or corrective actions. These data
are based on initial certification data, and are included in industry-wide "Total" or "All" values. Should the investigation and
corrective actions yield different C02 data, any relevant changes will be used in future reports.
-95 -
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Appendix D: 2016 Model Year Report Credits and Deficits
Table D-l. 2016 Model Year Reported Credits and Deficits
Manufacturer Pathway Fleet Credit Type
Fleet
Average
(g/mi)
Fleet
Standard
(g/mi)
Production
Volume
Credits (Mg)
BMW
Primary Car
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
N20 Deficit
CH4 Deficit
Advanced
Technology
262
235
289,036
(1,523,835)
261,750
241,276
213,889
(6,982)
(879)
6,292
Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
N20 Deficit
CH4 Deficit
Advanced
Technology
310
286
99,451
(539,100)
156,928
97,329
155,758
(8,976)
(1,130)
5,463
FCA
Primary Car
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
CH4 Deficit
Advanced
Technology
288
237
632,859
631,774
631,223
551
4,639
(6,302,304)
1,509,550
601,135
389,320
(38)
Truck
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
CH4 Deficit
348
295
1,365,868
1,365,868
1,365,148
32,073
(16,350,594)
4,537,811
1,309,446
2,474,713
(5,071)
Ford
Primary Car
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
N20 Deficit
CH4 Deficit
Advanced
Technology
254
234
978,827
(3,822,594)
1,202,274
533,799
330,086
(3,489)
(8,479)
22,343
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Table D-l. 2016 Model Year Reported Credits and Deficits
Manufacturer Pathway Fleet Credit Type
Fleet
Average
(g/mi)
Fleet
Standard
(g/mi)
Production
Volume
Credits (Mg)
Truck
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
N20 Deficit
CH4 Deficit
354
315
1,127,520
(9,932,025)
1,951,941
877,364
936,002
(56,591)
(78,171)
GM
Primary Car
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
CH4 Deficit
Advanced
Technology
260
233
1,222,917
(6,447,375)
1,529,206
877,339
662,961
(2,922)
12,447
Truck
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
N20 Deficit
CH4 Deficit
365
318
1,354,255
(14,376,304)
2,043,970
1,323,933
1,227,378
(17,554)
(11,055)
Honda
Primary Car
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
213
227
1,071,532
2,929,243
1,242,114
624,733
354,307
Truck
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
285
281
731,659
(661,025)
784,533
512,895
379,221
Hyundai
Primary Car
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Advanced
Technology
236
231
698,686
(682,141)
372,376
520,949
162,564
1,432
Truck Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
339
280
19,927
(265,548)
7,202
16,754
21,408
Jaguar Land
Rover
Primary Car Fleet Average
322
250
16,903
(237,639)
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Table D-l. 2016 Model Year Reported Credits and Deficits
Manufacturer Pathway Fleet Credit Type
Fleet Fleet
Average Standard
(g/mi) (g/mi)
Production
Volume
Credits (Mg)
A/C Leakage
A/C Efficiency
Off-Cycle
Truck
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
361
288
97,677
45,546
18,814
10,018
(1,610,513)
379,462
125,753
169,333
Kia
Primary Car
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Advanced
Technology
246
229
Truck
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
330
288
562,876
2,788
158,062
(1,868,460)
283,543
381,366
146,732
(1,499,428)
97,287
121,382
118,830
Mazda
Primary Car Fleet Average
214
228
Truck
Fleet Average
N20 Deficit
259
271
305,635
153,192
835,513
415,209
(6,763)
Mercedes
Primary Car
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Advanced
Technology
269
239
Truck
Fleet Average
A/C Leakage
A/C Efficiency
Off-Cycle
Advanced
Technology
342
290
220,201
2,171
109,864
194
(1,289,920)
236,227
233,353
155,616
(1,290,350)
176,030
131,987
81,796
Mitsubishi
Primary Car
Fleet Average
A/C Leakage
Advanced
Technology
241
219
Truck
Fleet Average
A/C Leakage
251
260
26,172
130
49,097
(112,430)
14,092
99,804
72,505
Nissan
Primary Car Fleet Average
221
229
943,334
1,473,593
-98-
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Table D-l. 2016 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 746,573
A/C Efficiency 562,084
Off-Cycle 339,915
N20 Deficit (56,360)
CH4 Deficit (4,401)
Advanced
Technology 13,128
Truck Fleet Average 297 284 409,137 (1,201,326)
A/C Leakage 633,442
A/C Efficiency 233,228
Off-Cycle 251,409
N20 Deficit (87,252)
CH4 Deficit (7,320)
Subaru Primary Car Fleet Average 244 224 153,926 (601,124)
A/C Efficiency 88,364
_ Off-Cycle _ _ 10,458
Truck Fleet Average 246 262 402,071 1,453,020
A/C Efficiency 246,860
Off-Cycle 16,419
Tesla Primary Car Fleet Average 0 267 46,058 2,401,256
A/C Efficiency 49,058 51,263
Advanced
Technology 46,058
Toyota Primary Car Fleet Average 224 228 1,355,012 1,058,340
A/C Leakage 897,532
A/C Efficiency 1,314,746
Off-Cycle 360,276
_ N20 Deficit _ _ (18,288)
Truck Fleet Average 342 292 1,022,967 (11,552,622)
A/C Leakage 1,529,031
A/C Efficiency 945,443
Off-Cycle 762,051
N2Q Deficit (24,344)
Volkswagen Primary Car Fleet Average 247 226 442,775 (1,815,618)
A/C Leakage 392,728
A/C Efficiency 275,942
N20 Deficit (1,096)
CH4 Deficit (200)
-99-
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Table D-l. 2016 Model Year Reported Credits and Deficits
Fleet Fleet
Average Standard Production
Manufacturer Pathway Fleet Credit Type (g/mi) (g/mi) Volume Credits (Mg)
Advanced
Technology 10,676
Truck Fleet Average 320 279 119,437
A/C Leakage
A/C Efficiency
N20 Deficit
CH4 Deficit
Advanced
Technology
2,100
Volvo
Primary Car Fleet Average
A/C Leakage
A/C Efficiency
249
238
32,207
(69,178)
31,954
20,754
Truck Fleet Average
A/C Leakage
A/C Efficiency
300
289
57,283
(142,320)
95,407
54,165
(1,106,042)
191,593
136,930
(3,546)
(481)
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