Final Phase 1 EPA Heavy-Duty Vehicle
and Engine Greenhouse Gas Emissions
Compliance Report (Model Years 2014-20)



£%	United States

Environmental Protect
Agency


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Final Phase 1 EPA Heavy-Duty Vehicle
and Engine Greenhouse Gas Emissions
Compliance Report (Model Years 2014-20)

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.

Compliance Division
Office of Transportation and Air Quality
U.S. Environmental Protection Agency

NOTICE

4>EPA

United States
Environmental Protection
Agency

EPA-420-R-22-028
November 2022


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Table of Contents

1.	Executive Summary	1

2.	Program Background and Description	2

a.	Heavy-Duty Vehicles	3

b.	Heavy-Duty Engines	3

c.	Additional Credit Programs	4

3.	Model Year 2020 Heavy-Duty Vehicle Compliance	5

a.	Compliance of Heavy-Duty Vocational Vehicles Produced by Manufacturers Not Participating in
Averaging, Banking and Trading	5

b.	Compliance of Heavy-Duty Vocational Vehicles Produced by Manufacturers Participating in
Averaging, Banking and Trading	6

c.	Compliance of Heavy-Duty Combination Tractors Produced by Manufacturers Participating in
Averaging, Banking and Trading	16

d.	Heavy-Duty Vehicle Compliance Summary	21

4.	Model Year 2020 Heavy-Duty Compression Ignition (CI) Engine Compliance	24

5.	Conclusions	31

Appendix A: Credit Activity Overview for Each Model Year	32

Optional Early Model Year 2013 Heavy-Duty Vehicle and CI Engine Summary	32

Model Year 2014 Heavy-Duty Vehicle and CI Engine Summary	32

Model Year 2015 Heavy-Duty Vehicle and CI Engine Summary	33

Model Year 2016 Heavy-Duty Vehicle and CI Engine Summary	34

Model Year 2017 Heavy-Duty Vehicle and CI Engine Summary	34

Model Year 2018 Heavy-Duty Vehicle and CI Engine Summary	34

Model Year 2019 Heavy-Duty Vehicle and CI Engine Summary	35

Model Year 2020 Heavy-Duty Vehicle and CI Engine Summary	35

Appendix B: Individual Manufacturer Detailed Credit Summaries	37


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1. Executive Summary

This report is part of the U.S. Environmental Protection Agency's (EPA's) commitment to provide the
public with information about the heavy-duty vehicle and engine manufacturers' performance in
meeting the agency's greenhouse gas emission (GHG) standards. It updates an otherwise largely similar
report that EPA previously issued covering program compliance through model year 2018 by adding the
results for the 2019 and 2020 model years. Where appropriate this report also extends the explanations
and conclusions we draw from the information updated by the addition of these two latest model years.
In 2011, EPA, along with the Department of Transportation's National Highway Traffic Safety
Administration (NHTSA), adopted the first-ever greenhouse gas emission and fuel efficiency standards
for heavy-duty engines and vehicles. The comprehensive program the agencies created was designed to
address the intertwined challenges of reducing dependence upon oil, achieving energy security, and the
amelioration of global climate change. The program also served to enhance American competitiveness
and job creation, benefit consumers and businesses by reducing the costs of transportation of goods,
and spur growth in the clean energy sector. The Phase 1 Heavy-Duty Vehicle and Engine Greenhouse
Gas Rule became mandatory in 2014 and fully phased-in by the 2017 model year. The objective of the
Phase 1 program was to reduce GHG emissions from the heavy-duty sector, the transportation sector's
second largest contributor to GHG emissions. The program aimed to expand the use of more efficient
commercially available technologies.

The commercial transportation industries that use the products covered through these regulations are
incredibly diverse with a wide range of operating and use patterns. As a result, the heavy-duty vehicle
and engine industry is itself quite diverse and offers an almost unbelievable range of different products
and options in order to best serve the needs of their customers. EPA and NHTSA in developing the
Phase 1 program, included a number of design elements intended to improve fuel consumption and
lower GHG emissions without limiting the ability of manufacturers to offer the diverse range of products
their customers expected and need. These flexibilities were expected to provide sufficient lead time for
manufacturers to make necessary technological improvements, help increase the rate of which new
technologies can be implemented, and reduce the overall cost of the program, without compromising
overall environmental objectives. The primary flexibility is an engine and vehicle averaging, banking,
and trading (ABT) program in which C02 credits may be generated for vehicles/engines that overachieve,
relative to the standards. With these ABT provisions, manufacturers can offer the right product for the
right consumer need (some of which may over or under perform against the fleet average GHG
standards), balance market fluctuations impacting their sales volumes, and still move the entire fleet of
vehicles toward increasing levels of energy efficiency and lower GHG emissions The EPA ABT program
allows for emission credits to be averaged, banked, or traded within each of the "averaging sets"
described in this report, allowing manufacturers the opportunity to comply on a fleet average basis with
the emission standards. Participation in this ABT program is optional and manufacturers can
alternatively choose to certify all of their heavy-duty vehicles/engines to meet the applicable standards.

This report provides an overview of the GHG compliance status of manufacturers of heavy-duty
combination tractors, vocational vehicles, and the engines that power these vehicles. Heavy-duty
combination tractors are the semi-trucks that typically pull trailers and are built to mainly move freight.
Vocational vehicles consist of a very wide variety of truck and bus types including delivery, refuse, utility,
dump, cement, transit bus, shuttle bus, school bus, emergency vehicles, motor homes, tow trucks, and
many more. This report summarizes the current C02 credit situation at the conclusion of the Phase 1
portion (Model Year 2020) of the rulemaking (optional in model year 2013 then mandatory beginning in

1


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model year 2014) to the new GHG standards for each manufacturer participating in either of the vehicle
or engine ABT programs.

The success of the heavy-duty GHG program as documented in the pages of this report is measured in
the industry's ability to create the systems and processes necessary to demonstrate compliance with the
program, improve their products to lower their GHG emissions and fuel consumption, and finally
through their reporting to the Agency demonstrate that the fleet of vehicles they produced complied
with the aggregated fleet standards. It is a significant accomplishment that the entire industry was able
to implement and begin complying with this program and has demonstrated through their reporting
that GHG emissions have been reduced to such an extent that all manufacturers are compliant and most
have created significant credit banks reflecting better overall fleet performance than the agencies
originally projected in setting up the program.

This report documents that all manufacturers (both for vehicles and engines) are not merely compliant,
but that all manufacturers have generated a positive banked credit balance through model year 2020 in
each of the three averaging sets for vehicles and engines. This clearly demonstrates full compliance of
the Phase 1 regulatory requirements and the new standards that became mandatory in model year 2014
(summarized in Tables 1 and 11 of Section 3 in this report).

The Phase 2 Heavy-Duty Vehicle and Engine Greenhouse Gas Rule was adopted in 2016 and began
implementation with the 2021 model year. In designing the Phase 2 program, EPA considered credit
balances in the Phase 1 program and concluded that manufacturers should be allowed to largely carry
the Phase 1 credit balances into the Phase 2 program. However, some restrictions were adopted for
certain circumstances, primarily to avoid the potential for credit disparities to disrupt the competitive
marketplace. Nevertheless, the amount of credits potentially being carried into the Phase 2 program
was deemed sufficiently large to be considered in setting the stringency of the Phase 2 standards
(i.e., the Phase 2 standards are more stringent than they otherwise would have been had manufacturers
not demonstrated the ability to over comply with the Phase 1 standards).

2. Program Background and Description

On September 15, 2011, the Environmental Agency (EPA) and the National Highway Traffic Safety
Administration (NHTSA) issued a joint Final Rule that established the first phase of a national program
with new greenhouse gas (GHG) and fuel economy standards for 2014 and later model year heavy-duty
vehicles and engines.1 The "Phase 1" standards established by this rule apply to medium- and
heavy-duty vehicles, including (1) combination tractors, (2) heavy-duty pickup trucks and vans,
and (3) vocational vehicles as well as another set of GHG standards for the engines that drive these
vehicles. The Phase 1 standards apply to all on-road vehicles rated at a gross vehicle weight at or
above 8,500 pounds (Classes 2b-8), and the engines that power them, except those covered by the light-
duty GHG standards and heavy-duty pickup trucks and vans (Classes 2b-3) which are certified using a
chassis dynamometer.

The Phase 1 rule provides some flexibility to manufacturers in how they can comply with these new GHG
standards. The primary flexibility is an engine and vehicle averaging, banking, and trading (ABT)

1 Federal Register "Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines
and Vehicles; Final Rule" dated September 15, 2011

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program in which C02 credits may be generated for certain groups of vehicles/engines that overachieve,
relative to the standards. These credits may be used to offset other groups of vehicles/engines that
underachieve, relative to the standards. The EPA ABT program allows for emission credits to be
averaged, banked, or traded within each of the "averaging sets" (to be described), allowing
manufacturers the opportunity to comply on average with the emission standards.

This report provides an overview of the GHG compliance status of manufacturers of heavy-duty
combination tractors, vocational vehicles, and the engines that power these vehicles at the conclusion
of the Phase 1 period (model year 2020). Heavy-duty combination tractors are the semi-trucks that
typically pull trailers and are built to mainly move freight. Vocational vehicles consist of a very wide
variety of truck and bus types including delivery, refuse, utility, dump, cement, transit bus, shuttle bus,
school bus, emergency vehicles, motor homes, tow trucks, and many more. Even for cases in which
engine and vehicle credits are both generated by a single corporate entity, engine and vehicle credits
are segregated within the regulatory program and in this report.

a.	Heavy-Duty Vehicles

The manufacturers of combination tractors and vocational vehicles demonstrated compliance with the
GHG standards using a Greenhouse Gas Emissions Model (GEM), developed by EPA and used to
calculate a vehicle's tailpipe C02 emissions. The C02 emissions calculation performed by GEM required
input parameters for each vehicle, provided to the GEM model by the manufacturer. The calculated C02
value was then compared to the corresponding C02 standard for that vehicle classification in order to
determine compliance.

There are three weight-based vehicle averaging sets for the two vehicle regulatory categories included
in this report (combination tractors and vocational vehicles). The three averaging sets for these vehicles
are:

1.	Light Heavy-Duty (Class 2b-5 vocational vehicles only)

2.	Medium Heavy-Duty (Class 6-7 vocational vehicles and Class 7 tractors)

3.	Heavy Heavy-Duty (Class 8 vocational vehicles and tractors)

C02 standards for tractors and vocational vehicles vary based on averaging set and vehicle classification.
The standards for all these vehicles and averaging sets can be found in Title 40 of the Code of Federal
Regulations (CFR), Part 1037, Subpart B and are summarized later in this report. As described previously,
manufacturers used the GEM model to estimate the C02 emissions level of a heavy-duty vehicle. This
estimated value was then compared to the standard to determine if the vehicle either generated or
consumed C02 credits for compliance. Credits generated in this process for one vehicle could then be
used to offset any credit deficits produced by another vehicle, but only within the averaging set.

b.	Heavy-Duty Engines

The emissions from the engines that power combination tractors and vocational vehicles are measured
using an engine dynamometer. The engines are operated on the dynamometer over two different duty
cycles, one simulating urban driving and another simulating steady-state highway operation. C02 and
other pollutants are directly measured on these cycles for certification purposes. The measured C02
levels are compared to a set of engine standards to determine compliance. Engines must also meet
standards for two additional GHG pollutants produced during engine combustion: N20 (nitrous oxide),

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and CH4 (methane). The measured emissions levels of N20 and CH4 are also compared to a set of
standards developed by EPA to determine compliance.

The structure of the ABT program for heavy-duty engines is similar to the vehicle program previously
described. Each engine produced is certified to a certain set of GHG standards based on the engine's
application (either tractor or vocational vehicle use). The manufacturer must test these engines on an
engine dynamometer and measure GHG emissions (C02, N20, and CH4) over two specific operating
cycles: the transient Federal Test Procedure (FTP), and the steady-state Ramped Modal Cycle (RMC).
The C02 emissions measured over the FTP cycle are used to determine compliance if the intended
engine application is for a vocational vehicle. Similarly, if the intended application of the engine is for a
tractor, then the C02 emissions level measured over the RMC cycle is compared to the standard to
determine compliance. N20 and CH4 emissions levels are only measured over the FTP cycle and
compared to the applicable standard for each. C02 credits, generated by an engine test result that is
overachieving, relative to the standard may be used to offset any credit deficits in the same averaging
set. There are four averaging sets for heavy-duty engines, which are:

1.	Light Heavy-Duty Compression Ignition (CI) (intended for use in Class 2b-5 vocational vehicles)

2.	Medium Heavy-Duty CI (intended for use in Class 6-7 vocational vehicles or Class 7 tractors)

3.	Heavy Heavy-Duty CI (intended for use in Class 8 vocational vehicles or tractors)

4.	All Heavy-Duty Spark Ignition (SI)2

Similar to vehicles, there are different C02 standards within each averaging set for engines. The
differences in the C02 standards are based upon the intended service of the engine, that being either
for vocational or tractor use.3 The standards for N20 and CH4 are the same for all heavy-duty CI engines
regardless of averaging set or intended application.4 Any credits or deficits generated by N20 and CH4
are converted into equivalent C02 values by using specified conversion factors and included in the "Net"
C02 values presented in the following tables. The nuances of this process will be described in more
detail in Section 4 of this document.

c. Additional Credit Programs

EPA also adopted three optional C02 credit provisions in the Phase 1 rule: an early credit program, an
"off-cycle" credit program, and an advanced technology credit program.

The early credit option was for manufacturers who demonstrated that their products overachieved,
relative to the standards prior to the model year that the Phase 1 standards became effective. This
program allowed the manufacturers to certify their heavy-duty vehicles and CI engines in model year
2013, before the GHG standards became mandatory in model year 2014. As an incentive, any C02
credits generated using this option received a bonus 1.5X multiplier for model year 2013 only. Several
manufacturers took advantage of this opportunity and the summary tables for model year 2013 are also
included in the following credit summary tables.

The "off-cycle" credit program is intended to promote the development of innovative technologies that
reduce vehicle C02 emissions, but for which the benefits are not accounted for when using the GEM
model (for vehicles) or not captured on the FTP and/or RMC test procedures (for engines). These off-

2	The engines produced in the Heavy-Duty SI averaging set are not included in this report

3	See 40CFR 1036 Subpart B.

4	See 40CFR 1036 Subpart B.

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cycle credits are in addition to those credits being generated by C02 compliance (conventional credits)
as previously described.

The advanced technology credit option is intended to promote implementation of advanced
technologies, such as hybrid powertrains, engines with Rankine cycle waste heat recovery systems and
electric or fuel cell vehicles. These advanced technology (AT) credits not only have a 1.5X multiplier,
but, unlike other credits, they may be used to offset deficits in any averaging set in either the heavy-
duty vehicle or engine sectors through model year 2020. AT credits generated in model year 2021 and
later will be restricted to use only within the averaging set in which they were generated. Because of
the unique and flexible nature of these credits, they must be tracked separately from the GEM
generated "conventional" and off-cycle credits and thus are presented separately in the tables of
this report.

3. Model Year 2020 Heavy-Duty Vehicle Compliance

a. Compliance of Heavy-Duty Vocational Vehicles Produced by Manufacturers Not
Participating in Averaging, Banking and Trading

Model year 2014 was the first mandatory year for certifying heavy-duty vehicles to GHG standards. As
part of the certification process, manufacturers could voluntarily participate in the GHG ABT program.
Manufacturers participating in the ABT program are required to submit a report to EPA that includes
production volume information and other vehicle data needed to determine the net C02 credits
produced in each averaging set of their vehicle fleet. Manufacturers choosing to not participate in the
ABT program simply certify their entire vehicle fleet to the standards, meaning that every one of their
vehicles produced is required to meet the standard without the flexibility of the ABT program. Through
model year 2020 the following ten manufacturers chose not to participate in the ABT program for the
entirety of Phase 1 instead choosing to produce all of their vehicles with emissions at or below the
applicable vehicle standards: Alexander Dennis, An Yuan Bus, ARBOC Specialty, BYD Auto, CHTC USA,
Dennis Eagle, Envirotech Drives, Green Power Motor, Irizar Sociedad, and Lion Bus. Again, the ABT
program is voluntary, and the manufacturers that chose not to participate are in full compliance with
the new GHG standards for their vehicles. Manufacturers not using the ABT program are still required
to provide EPA with an end-of-year production volume report describing certain vehicle parameters for
each vehicle produced during the model year to determine compliance with the program standards, as
all manufacturers are required to submit.

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b. Compliance of Heavy-Duty Vocational Vehicles Produced by Manufacturers
Participating in Averaging, Banking and Trading

Table 1 presents the applicable C02 emissions standards for heavy-duty vehicles applicable for model
years 2014-20. The standards are presented for five vehicle regulatory subcategories which are:

1.	Light heavy-duty (LHD) vocational vehicles (there is not a LHD tractor classification, therefore
the entire LHD subcategory consists of only vocational vehicles)

2.	Medium heavy-duty (MHD) vocational vehicles

3.	Heavy heavy-duty (HHD) vocational vehicles

4.	MHD vocational tractors (defined in Part 1037.630)

5.	HHD vocational tractors (defined in Part 1037.630)

Each of these regulatory subcategories will have a separate table later in this report detailing the credits
generated during model years 2013-20 for each manufacturer producing vehicles in this subcategory.

Table 1. Heavy Duty Vehicle GHG Emissions Standards for Model Years 2014-20.



GVWR

C02 (g/ton-mile)

C02 (g/ton-mile)

Payload

Useful Life

Roof Height

Vehicle Type

(lbs)

MY 2014-16

MY 2017-20

(tons)

(miles)

(inches)

Vocational Vehicles













LHD Class 2b-5

8,501 -19,500

388

373

2.85

~110,000

N/A

MHD Class 5-7

19,501-33,000

234

225

5.60

185,000

N/A

HHD Class 8

Greater than 33,000

226

222

7.50

435,000

N/A

Tractors













Class 7 Low-Roof All Cabs

26,001 - 33,000

107

104

12.50

185,000

120 or less

Class 7 Mid-Roof All Cabs

26,001 - 33,000

119

115

12.50

185,000

121-147

Class 7 High-Roof All Cabs

26,001-33,000

124

120

12.50

185,000

I

148 or greater

Class 8 Low-Roof Day Cab

Greater than 33,000

81

80

19.00

435,000

120 or less

Class 8 Low-Roof Sleeper Cab

Greater than 33,000

68

66

19.00

435,000

120 or less

Class 8 Mid-Roof Day Cab

Greater than 33,000

88

86

19.00

435,000

121-147

Class 8 Mid-Roof Sleeper Cab

Greater than 33,000

76

73

19.00

435,000

121-147

Class 8 High-Roof Day Cab

Greater than 33,000

92

89

19.00

435,000

148 or greater

Class 8 High-Roof Sleeper Cab

Greater than 33,000

75

72

19.00

435,000

148 or greater

* Useful Life Changed to 150,000 miles for LHD Vehicles Starting in Model Year 2021

View this table at a larger text size by visiting:

https://www.epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

Presented in Table 1 are the gross vehicle weight ratings that define the appropriate averaging set for
any given vehicle. In addition, Payload and Useful Life values are presented for each vehicle regulatory
subcategory. Payload and Useful Life values are required in order to calculate ABT credits for a given
vehicle. Vocational tractors are included as separate regulatory subcategories in this report because
unique requirements exist for these vehicles. These unique requirements reflect the unique customer
needs for vocational tractors which in turn dictate a different level of GHG performance and appropriate
GHG standard. In regards to credit generation, vocational tractors are treated the same as other
vocational vehicles in their respective averaging set.

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Equation 1 is used to calculate C02 credits in each vehicle regulatory subcategory in the subsequent
tables:

Eq. 1: Vehicle Credit Calculation

C02 credits (Mg) = (Std-FEL) X (Payload Tons) X (Volume) X (UL) X (10A-6)

Where:

STD = the emission standard associated with the specific tractor or vocational regulatory
subcategory (g/ton-mile)

FEL = the family emission limit for the vehicle subfamily as calculated by the GEM model (g/ton-
mile)

Payload Tons = the prescribed payload for each class of vehicle in tons (2.85 tons for light heavy-
duty vocational vehicles, 5.6 tons for medium heavy-duty vocational vehicles, 7.5 tons for heavy
heavy-duty vocational vehicles, 12.5 tons for medium heavy-duty tractors, and 19 tons for heavy
heavy-duty tractors)

Volume = U.S. directed production volume of the vehicle subfamily. For example, if you produce
three configurations with the same FEL, the subfamily production volume would be the sum of
the production volumes for these three configurations

UL = useful life of the vehicle (110,000 miles for light heavy-duty vehicles, 185,000 for medium
heavy-duty vehicles, and 435,000 for heavy heavy-duty vehicles). The Useful Life value for light-
heavy duty vehicles was changed as part of the Phase 2 rulemaking but are calculated using the
Phase 1 value (110,000 miles) in this report. Banked credit balances shown have been adjusted
using the new useful life value for LHD vehicles and was conducted at the end of model year
2020 (last year of Phase 1 program) to determine the adjusted credit values carried forward into
the Phase 2 program (described in more detail later in this report).

Vehicles with an agency-approved off-cycle technology receive an additional credit multiplier for each
vehicle equipped with the approved technology. These off-cycle credits are similar to the C02 credits
generated by conventional vehicles in that they can only be used within the averaging set in which they
were generated. The off-cycle credits are calculated separately from the conventional credits and are
determined based upon the additional GHG benefit achieved through the use of the technology beyond
the FEL established for that vehicle using the GEM model (conventional credits). Since off-cycle credits
are utilized and limited in the same ways as conventional credits, they are combined and presented as a
single credit value in this report for each regulatory subcategory of vehicles. Both conventional and off-
cycle credits have a 5-year life which means that they have to be used within five model years after the
one in which they were generated, or they will expire. Navistar and Autocar were the only heavy-duty
vehicle manufacturer to generate any off-cycle credits during the entirety of the Phase 1 program.
Navistar generated some of their credits from an approved off-cycle technology, and both Navistar and
Autocar generated off-cycle credits beginning in model year 2018 using the interim provisions provided
by the Phase 2 rulemaking presented in Section 1037.150(y) for enhanced credit generation carrying
into the Phase 2 program.

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As discussed previously, hybrid vehicles with regenerative braking, vehicles equipped with Rankine-cycle
engines, electric vehicles, and fuel cell vehicles qualify to generate advanced technology (AT) credits.
These credits may be utilized differently than the conventional and off-cycle credits previously
discussed. AT credits may not only be used to offset credit deficits in the averaging set in which they
were generated (just like conventional and off-cycle credits) but may also be used to offset deficits in
any other averaging set. This flexibility is extended to any credit deficits in the heavy-duty vehicle sector
and to the heavy-duty engine sector (this flexibility of AT credits does not extend to the Phase 2
program beginning with MY2021 and these credits will be restricted for use only in the averaging set in
which they were generated). These AT credits have a 1.5X multiplier for each credit generated.
Advanced technology credits are also calculated separately based on the additional benefit they provide
beyond the GEM calculated FEL of the vehicle resulting in a combination of conventional and AT credits
for each of these vehicles. Only this extra benefit of the AT receives the 1.5X multiplier as previously
described. Ten manufacturers (Blue Bird, Chanje, Gillig, Mitsubishi Fuso, Motor Coach Industries, New
Flyer, PACCAR, Van Hool, Volvo Group, and XOS Trucks) generated advanced technology vehicle credits
in model years 2013-20 as the following tables will indicate.

Tables 2-1 through 2-5 present a summary of the ABT credits generated by each vocational vehicle
manufacturer participating in the ABT program during model years 2013-20 in the five vocational
regulatory subcategories previously described. Manufacturer names are abbreviated versions of their
full legal names in all of the tables and text of this report. This data is for those vehicles that were not
certified on a chassis dynamometer but used only the GEM certification model. The first column of each
model year represents the combined conventional and off-cycle credits generated by each manufacturer
which were calculated using the GEM determined FEL value of C02 for each vehicle in that regulatory
subcategory. Off-cycle credits were calculated by applying the off-cycle improvement factor to the GEM
determined FEL value for additional credits for these technologies. The second column of each model
year represents the AT credits generated for each manufacturer in that regulatory subcategory which is
calculated based only on the AT improvement for each vehicle beyond the FEL determined by GEM. In
all cases, a blank cell in any column means that the manufacturer did not produce any vehicles in that
regulatory subcategory or model year. Because of the size of each of these tables, they are laid out in
two sections. The upper section covers credits generated in model years 2013-17, and the lower section
covers model years 2018-20 including aggregate columns at the end totaling all generated credits from
the model years presented. There is also a link at the bottom of each table to allow the reader to view
these tables in a larger format for ease of viewing.

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Table 2-1. LHD Vocational Vehicles: GHG Credits (Mg C02) Generated Summary -
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MliU&hM fwso
Miliii Comti tad.

m

is*

7,072

1367
52.743

til



68,127
IMi



3*7
•iM.lfO

11,650

7^72



MavbSar, Inc.
Hrw Flfn
Oifckmli

WtlXAfi, ht_

kmanbauai Mtrtin.
ieatan Frr

a



63



90*



am

*33*



T n axlorpui anion
Tiffin Muliit ttuiw
VarHuof



















HMu MP

ACSTiUtii



















TOTALS

EiH/bUti

7,5*6

210,7151



270,716



M17.4S*

«u*



View this table at a larger text size by visiting:

https://www.epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

9


-------
Table 2-2. MHD Vocational Vehicles: GHG Credits (Mg C02) Generated Summary -
Model Years 2013-20.



MY 2013

MV 2014

MY 2015

MY 2016

MY 2017



Cccyertonsi

Ad\anted

Conventions!

Advanced

Corwtkmal

Advanced

Corvertnnai

Atf»anced

Corventiorel

Advanced



Plus Off-Cycle

T«2WK»ia^f-

?«_=OfT-Cyde

T«3ww»gY

PtsOff-Cyde

Teaifwagy

Pis Off-Cycle

TeSsrwaogy

pile orr-cycK

TBOTraiogy

Manufacturer

Create Generated

Create Gererated

Credtr Generated

Crerits Gererated

Credit Gererated

Credits Gefraated

Creats Generated

Credits Generated

Credits Generated

Credits Generated

Autocar y





















SHue am JL





33,034



69,126



71,126



70511



I' "r ;





















Oryswf Grwo





















Sairrifcr C»3ies





















airnierTnxlcs

72JB7



64,601



106234



170,177



206.7133



E-Qne





















3 Dorado





















EVQ Bus





















Fre

=ord Mater





64.631



47,426



70,123



142.110



General Mouses





















•aii^LLC





43S



3S6



126



53



-ino MwvjfBctjinj





















-ina Motors





















sun: Motors





















fevateH Motile





















MhaifctS* Pjso





















Motor Coedi ind.





















tavistar, Ire

—: :c4







63.534



34 000



127 .ISC'



•JewRyer









174



236



124



Dd->;:h
PACCAR, inc

2JSO



1? !2I



23542



26545



32,122



Boserteuer Motor;





















Spa"tBLi Pre
7ere». Cnroanrtsor





















Trflfn Motor Home:





U3&















Van Hool





















Voko Group





















iDSTnidB





















TOTALS

217,221

	»

204.508

»

315.502

	°

392,246

»

585,191

»



MY 2013

MY Z019

MY

2020

TOTAL



Conweitiawl

Advanced

ConuentioraJ

Advanced

Corvertionsl

Atfvancefl

CornerNkral

Advanced



PlusOTC^de

TeclVKiQgy

P«le Off-Cycle

TecSwoogy

PLcOffHCyde

Tedwra®gv

?i_c0ff-0,cie

Tetfmoto^y

Manufacturer

Cr«3tr Gererated

Crecrt: Gererated

Crecrte Gererated

Crecrfc Generated

Credits Generated

Credrt: Generated

Crecits Ge-nerated

Credits Gerverated

Autocar

534



€37



775



L50C



Sue Srd Bcdy

64.333



43,023

1382

36 30C-

9,913

413,373

12.253

Qwji

















Qrysar Gp>jd

















Doimw Co&rhK

















DoimterT'ijdcs

54;



243 256



360,475



1,393,444



£-Qr»e

















3 Dorac©

















EVO Bus

















^ffTBraFre

















=ord Motor

74,621



106,W2



120,433



632,422



General Motors





2,563



4043



7,010



Sill- LUC













1.003



Hi no K'teeYjfactxin-





6.237



23



6,262



-ino Motor:





17,608



4,0S6



21,704



!9LffiU MOtOfS

7,623



3,025



10301



22,933



 Coraorntor

















"iffr Motor Homes













12J6



'Wfi Hool

















Volvo Group









3,063



3,063



XQSThids









21

3,463

21

3,463

TOTALS

520,926

	2

6B7.2S31

2,332

1,035,388

17,057

3,955,733

13,465

View this table at a larger text size by visiting:

https://www.epa.gov/svstem/files/documents/2022-ll/420r22Q28-report-tables.pdf.

10


-------
Table 2-3. HHD Vocational Vehicles: GHG Credits (Mg C02) Generated Summary -
Model Years 2013-20.



MY 2013

MY 2014

MY 2015

MY 2016

MY 2017



Corivertonal

Advanced

Conventional

Advanced

Conventional Advanced

CorwH-iTHmei

Advanced

ConvwrMirvsl

Ad\arotd



ftusGff-Cyde

Teawvow^

PJusOff-Cycte

T«*BW*ogy

PteOff-Cyde Tedrawtogy

Plus Off-Cycfc

Tedrtrwiogy

Pijs Off-Cycie

Tedhawiogy

Manufacturer

Great: Generated

Create Generated

Credits Generated

Great; Generated

Greats Generated Great: Gewrated

Great; Gerwrated

Great: Gerwrated

Crest: Gewated

Credits Generated

Autccsr



















3 >.e 3rd &>3>





24,740



2B.435

30,34£



34.142



Zr-r

Qvysiar Group



















Darnier CoKfte:



















SairiierTnjdci

1B7 350



IB 3.121



211373

297.355



3344-32



E-3-:





4.-267



0

0



3.657



3 Ooraco





3,771



3,109

6,323



2,334



EVDBus





23GG



1233

14.74



1390



FerraraFire















1A36



ford Ntator











zn



2,711



General Matorc



















a'li-LLC





22,357



20,162

22490



28470

1033

Hino MaeufBtl'.rinj



















Hod Motors



















n-2L M0tDT3



















XcNVati Vbtile











3,002



3430



Mnsutitfj Pjso



















Motor Coaei IncL





1B3±2



18.973

20,436



17^57



Hiatfrtsr, Ire

186,934







44,343

60,566



S7392



!\Je*vF»yef









14,003

31,520



30,763

23463

li.f- ::r





9,163



10,033

12,755



8,434



PACCAR, Jnc

28,467



ft£2 Gas



2EE.222

313,336



333.730



scGeronuer MDtor:



















Soartan Pre



















"ere* Coreoratcr





4.033



4,160

12,241



1333



"Mr Motor Home:





17,180













VST HOOI















31343



Group





128,370



181,910

23"=."



196302



'DSThJCte



















TOTALS

4CB3H

*

5S2J17

C

B 29,0361 0

1,053,536

0

1.121,158

24,158



MY 201S

MY2D19

MY 2020

TOTAL



Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventransl

Advanced



PtusOff-Cyde

TC£fV«asgy

PlucOfT-Cyde

Tednrtttafjy

PlueOfT-Cyde

TeSmotogv

PLb Off-Cycle

TBdvniogy

Vanufactj-er

Credits Generated

Create Generated

Credit Generated

Create Ger-rated

Credits Generated

Credits Generated

Croats Generated

Credits Goarated

Autocar

moos



122 514



77..450



360,113



Sue 3>rd EkxJr

24.512

3jce

13,323

77;077

17,113

36,717

174.523

223,102

CJiarje

















Qhryser Gnyjs

















Dnimer Coaches





175







179



DaimerTrudts

250,565



423,942



t SO 2 533



2,731,975



£-One

iHQlS



3J33



V £.,.354



33..5G0



El Do (TOO

6..43C



7,027



6,350



40,536



SVOBus

is:











6 552



reTansFre

3B1



L230



626



5 :53



?ofd Motor

2,936



2,736



2469



10.J71



3ene*al Motors

















Sli-LLC

36,537

3,056

33.363



23.316



1B9,437

4,131

Hino Manufatf_rin»





10







10



Hino MOt'DTI





463







4S3



teuzxi Motors

















KQvtftdi Mobile

2,617



2,026



3..061



13,935



Virai bitf* Ftiso

















Voter Coacfi Irfi.

32,067



23,204



43,025

2JK6

175,040

2,«6

¦Ja si star. Inc

106,522



136,326



273.153



516.-3C6



tewRyer

31261

164,413

33,979

170,266

37.213

90,453

17MS3

448,463

j.l-' ::t-

19,426



21=63



34,465



116333



saccar, mc

413.134



316,072



531,302

1,057

3,012,331

1037

Roseriasuer Motors









4563



4,5-53



Spartan Fire









6,045



5,045



tere* CDOoratoTr

2^13



2,320



1S4*



2E31S



Tiffin Motor Homes













17,130



Var< Hoot

26-360



27,764



29,013

1.013

114.560

1,013

V0h>D Group

243,065



236,701



302,436

3,236

1,727.247

3-236

»DS 7rjcte

















TOTALS

i,402,992

176,341

mai

247.345

2,827,34

236.344

9.BS9.J33

es,oc>a

View this table at a larger text size by visiting:

https://www,epa.gov/svstem/files/documents/2022-ll/420r22028-report-tables.pdf.

11


-------
Table 2-4. MHD Vocational Tractors: GHG Credits (Mg C02) Generated Summary-
Model Years 2013-20.



MY 2013

MY 2014

MY 2015

Mr 2016

MY 2017



Conventional

Advance a

Conventions

Advanced

Conventions

A cve-iced

Conventional

A chanced

Conventional

Advanced



Plus Off-Cycle

Technology

Pfcis Off-Cycle

Technology

Plus Off-Cycle

Tecfcnotogy

Plus Off-Cyde

Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Crests Generated

Create Generated

Credit; Gere rated

Credits Generated

Credits Generated

Credits Generated

Credits Generatec

Credits Generated

Credits Generated

Autocar





















DaimlerTructi

1 046



1-SOS



2,916



2,160



3.341



Fore Motor













-26



76



Hino Motor;





















Kovatch Moaile





















Navistar, Inc.





















PACCAR. Inc.

1,742



1333



1,272



662



643



Volvo Group





















TOTALS

2,788

0

3,163

0

4,188

0

2,794

0

4,562

0



MY 2018

MY 2019

MY 2020

TOTAL



Conventional

Advanced

Conventional

Advanced

Conventional

Aevanced

Conventional

Advanced



Plus Off-Cycle

Technology

Pius Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Credit; Generated

Credits Generated

Credit; Gene rate 0

Credits Generated

Credits Generated

Credits Generated

Credits Generatec

Autocar

















Daimler Truds

I..309



2,097



5,391



20,768



Fore Motor

38



33



96



13;



Hino Motors

















novated Moaile

















Navistar, Inc.

2,487



2,333



3,945



10,971



PACCAR. Inc.

993



1,493



1,374



9,740



Volvo Group

















TOTALS

5,049

0

6,162

0

13,010

0

41.71S

0

View this table at a larger text size by visiting:

https://www,epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

Table 2-5. HHD Vocational Tractors: GHG Credits (Mg C02) Generated Summary-
Model Years 2013-20.



MY 2013

MY 2014

MY 2015

MY 2016

MY 2017



Conventonal

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



P>J5 Off-Cycle

Technology

Pius Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

G*edrt; Generated

Credits Generated

C-edits Generated

Credits Generated

Autocar





















DairnlerTrucJ;

23,163







23.617



34,633



21,630



Fore Motor













32



25



Hino Motors





















Kovatch Mooile





















Navistar, Inc.





















PACCAR. Inc.

4341



46..4B4



66.314



41,703



30,221



Volvo Group





113,331

26.981



23.992



18.104



TOTALS

27,504

0

175,721

0

116,912

0

100.337

0

70,092

0



MY 2018

MY 2019

MY 2020

TOTAL



Conventional

Advanced

Conventional Advanced

Conventional

Advanced

Conventional

Advanced



Phis Off-Cyde

Technology

P»ji Off-Cyde Technology

Plus Off-Cyde

Techno Jogy

Plus Off-Cyde

Technology

Manufacturer

Creets Generated

Credits Generated

Create Generated Credits Generated

Credits Generated

Grate Generated

Credits Generated

Credits Generated

Autocar

12.J31



24373

IS,776







DairnlerTrucJs

40,716



34,940

91,771



306,161



Ford Motor

124



43

36



2S4



Hino Motor:





1,002





iflOB



K watch Moaile

26









1.-



Navistar, Inc.

11,4-BS



H821

32,333



78,862



PACCAR, Inc.

32,748



34,771

76.917



373.301



Volvo Group

49,162



33,943

90,877



336,610



TOTALS

172,795

0

184^04 0

330,930

0

1,17S,B4S

0

View this table at a larger text size by visiting:

https://www,epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

For the most part, each manufacturer produced a positive number of conventional ABT credits in each
of the five regulatory subcategories for vocational vehicles presented in tables 2-1 through 2-5,
indicating that the manufacturers produced vocational vehicle fleets which were compliant with the
regulations in model years 2013-20. As will be observed later in this report, any credit deficit generated

12


-------
in one vehicle regulatory category above may be offset with vehicles produced in another category
generating positive credits as long as both are within the same averaging set. For example, the credit
deficit generated by Ford in model year 2016 with MHD vocational tractors (Table 2-4) was more than
offset by positive credits generated by Ford's MHD vocational vehicles from the same model year (Table
2-2).

The reader of this report should, however exercise caution in interpreting the data. The very purpose of
the ABT program design is to allow customers and manufacturers to find the right balance of vehicle
attributes and low GHG technologies to best serve the often unique needs of individual customer
applications while in aggregate improving the overall fleet GHG performance. As some manufacturers
may specialize in products for particular market segments with inherently different GHG performance,
their credit balance is as likely to reflect those market needs as it is to reflect anything about a
manufacturer's ability to produce low GHG technologies.

Table 3 combines all the ABT credits generated in the five individual vocational vehicle regulatory
subcategories into their appropriate averaging sets for each model year to date. As described
previously, conventional and off-cycle credits are considered similar based on their restriction of being
used only within the averaging set in which they were generated. Therefore, they are combined in
Table 3. AT credits have much more flexibility in their use and are tracked separately. Table 3 also
includes aggregate totals of all credits generated during model years 2013-20 in each averaging set for
reference. These totals are merely an aggregate total of credits generated during model years 2013-
2020 and are not reflective of the current amount of banked credits available to each manufacturer for
future use in the Phase 2 program (discussed more later).

Table 3 indicates that all manufacturers demonstrated compliance with the GHG regulations for model
years 2013-20 vocational vehicles based on the positive credit status in each averaging set for each
model year. Credits generated by manufacturers may be banked for future use and have a 5-year life (a
credit may be used for any of the five model years after the year in which it was generated). If a credit is
not utilized within the five model year period, its value expires and it is removed from a manufacturer's
available balance.

13


-------
Table 3. All Heavy-Duty Vocational Vehicles: GHG Credits (Mg C02) Generated Summary-
Model Years 2013-20.



J22S	i		SSdii	<	Siii		HOH		:	!ilSi	2S«i		!	»£•£		i-i.

View this table at a larger text size by visiting:

https://www,epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

Table 4 presents the banked credit balances for each manufacturer in each of the three vocational
vehicle averaging sets at the conclusion of Phase 1 (model year 2020). For the most part, Table 4 was
generated by adding credits generated from each model year in each averaging set for model years 2013
through 2020 while removing the unused expired credits generated in model years 2013-2015. The
Phase 2 rulemaking also provided an interim provision for extended credit life for LHD and MHD
vocational vehicle credits generated in model years 2018-2021 that affects the life of certain credits in
Table 4 below. Specifically, the vocational vehicle credits generated in the LHD and MHD averaging sets
below from model years 2018-2021 for all manufacturers are no longer limited to a 5-year credit life but
will remain available for compliance use through model year 2027 as described in Part 1037.150(y).
Similarly, those manufacturers below that qualify as small manufacturers (meet the small business
criteria specified in 13 CFR 121.201) receive a similar credit life extension for all of their vehicles (both
vocational vehicles and tractors) certified in model years 2018-2021. The only two manufacturers that
qualify as small manufacturers in the vehicle ABT program through model year 2020 are Autocar and
XOS Trucks.

In the event that any other activity occurred with credits generated, Appendix A at the end of this report
presents a list of such activity plus other notes effecting credit generation and use for each model year
that resulted in a change of these banked credits. In addition, Appendix B contains links to additional
spreadsheets for each manufacturer participating in the ABT program that details all credit activity
involving the generated credits for each model year to date presented in this report. These detailed

14


-------
spreadsheets summarize any credit activity at the conclusion of Phase 1 involving such transactions as
credit trades, expired credits, error corrections/adjustments, etc. As noted previously, there are no C02
deficits in any averaging set in Table 4, thus showing full compliance to the Phase 1 GHG vocational
vehicle regulations for each manufacturer participating in the ABT program through model year 2020.

Table 4. All Heavy-Duty Vocational Vehicles: GHG Credits (Mg C02)
Banked Summary - Through Model Year 2020.



LHD

MHD

HHD





Conventional

Conventional

Conventional

Advanced



Plus Off-Cycle

Plus Off-Cycle

Plus Off-Cycle

Technology

Manufacturer

Credit Balance

Credit Balance

Credit Balance

Credit Balance

Autocar



1,800

422,398



Blue Bird Body



288,215

121,646

235,397

Chanje







6,679

Chrysler Group

119,629







Daimler Coaches





179



Daimler Trucks



1,165,000

2,392,809



E-One





29,333



El Dorado





29,776



EVO Bus





2,799



Ferrara Fire





3,893



Ford Motor

527,410

520,530

11,157



General Motors

15,372

7,010





Gillig LLC



179

146,898

4,131

Hino Manufacturing



6,262

10



Hino Motors

5,395

21,704

1,491



Isuzu Motors

401,940

22,955





Kovatch Mobile





16,072



Mitsubishi Fuso

10,670





9,618

Motor Coach Ind.





141,723

2,046

Navistar, Inc.

1,236

951,306

763,571



New Flyer



410

164,840

448,463

Oshkosh





97,112



PACCAR, Inc.

484

256,035

2,789,388

4,746

Rosenbauer Motors





4,365



Spartan Fire





6,049



Terex Corporation





20,103



Tiffin Motor Homes



0

0



Van Hool





114,680

1,013

Volvo Group



3,063

1,633,045

5,236

XOS Trucks



21



3,465

TOTALS

1,082,136

3,244,490

8,913,337

720,794

View this table at a larger text size by visiting:

https://www.epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

15


-------
c. Compliance of Heavy-Duty Combination Tractors Produced by Manufacturers
Participating in Averaging, Banking and Trading

A similar summary format is used in this section to describe the heavy-duty tractor sector as was used
for the vocational vehicle sector. Table 5 presents the C02 emissions standards for heavy-duty tractors
applicable for model years 2014-20. The standards are presented for the nine tractor regulatory
subcategories. Each regulatory subcategory has a separate table in this section detailing the credits
generated during model years 2013-20 for each manufacturer active in the subcategory. All Class 7
tractors fall in the MHD averaging set and all the Class 8 tractors fall in the HHD averaging set in the
following tables. In addition to the C02 standard for each tractor subcategory, the table also contains
payload and useful life data that is used in the ABT credit calculations for this sector. The roof height
data is not relevant to credit calculations but is presented as a reference for the reader.

Table 5. Heavy-Duty Vehicle GHG Emissions Standards for Model Years 2014-20.

I

GVWR

C02 (g/ton-mile)

C02 (g/ton-miie)

Payload

Useful Life

Roof Height

Vehicle Type

(lbs)

MY 2014-16

MY 2017-20

(tons)

(miles)

(inches)

Vocational Vehicles













LHD Class 2b-5

8,501 -19,500

388

373

2.85

*110,000

N/A

MHD Class 6-7

19,501 - 33,000

234

225

5.60

185,000

N/A

HHD Class 8

Greater than 33,000

226

222

7.50

435,000

N/A

Tractors













Class 7 Low-Roof All Cabs

26,001 - 33,000

107

104

12.50

185,000

120 or less

Class 7 Mid-Roof All Cabs

26,001 - 33,000

119

115

12.50

185,000

121-147

Class 7 High-Roof All Cabs

26,001 - 33,000

124

120

12.50

185,000

148 or greater

Class 8 Low-Roof Day Cab

Greater than 33,000

81

80

19.00

435,000

120 or less

Class 8 Low-Roof Sleeper Cab

Greater than 33,000

68

66

19.00

435,000

120 or less

Class 8 Mid-Roof Day Cab

Greater than 33,000

88

86

19.00

435,000

121-147

Class 8 Mid-Roof Sleeper Cab

Greater than 33,000

76

73

19.00

435,000

121-147

Class 8 High-Roof Day Cab

Greater than 33,000

92

89

19.00

435,000

148 or greater

Class 8 High-Roof Sleeper Cab

Greater than 33,000

75

72

19.00

435,000

148 or greater

* Useful Life Changed to 150,000 miles for LHD Vehicles Starting in Model Year 2021

View this table at a larger text size by visiting:

https://www.epa.gOv/svstem/files/documents/2022-ll/420r22028-report-tables.pdf.

Tables 6-1 through 6-9 present a summary of the ABT credits generated by each tractor manufacturer
participating in the ABT program in model years 2013-20 in each of the nine tractor regulatory
subcategories. All of these vehicles were certified using the GEM model. The layout of these tables is
similar to those presented for vocational vehicles. The first column represents the conventional plus off-
cycle credits generated by each manufacturer, which were calculated using the GEM-determined C02
FEL value for each vehicle in that regulatory subcategory. There are only four manufacturers that certify
tractors, and each of these four manufacturers is participating in the ABT credit program. Only Navistar
produced tractors that generated any off-cycle credits included in the following tables. Both PACCAR
and Volvo Group became the first manufacturers to generate AT credits for tractors starting in model
year 2020. As was the case before, a blank cell in any column means that the manufacturer did not
produce any vehicles in that regulatory subcategory during the applicable model year.

16


-------
Table 6-1. MHD Tractors - Class 7 Low-Roof All Cabs: GHG Credits (Mg C02) Generated Summary -
Model Years 2013-20.



MY 2013

MY 2014

MY 2015

MY 2016

MY 2017



Conventions!

Advancec

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Dairr lerTrucks

-2.720



All



241



81



-217



Navistar, Inc.

2,410







511



45S



937



PACCAR. Inc.





32



-25



69S



160



Volvo Group





















TOTALS

-310

0

950

0

727

0

1,237

0

880

0



















MY 2018

MY 2019

MY 2020

TOTAl







Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced







Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology





Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated





Daim ler Trucks

99



356



722



-520







Navistar, Inc.

1,004



645



2.990



8,955







PACCAR, Inc.

-155



56



516



1,284







Volvo Group





















TOTALS

948

0

1,057

0

4,230

0

9,719

0





View this table at a larger text size by visiting:

https://www.epa.gov/sYstem/files/documents/2022-ll/420r22028-report-tabies.pdf.

Table 6-2. MHD Tractors - Class 7 Mid-Roof All Cabs: GHG Credits (Mg C02) Generated Summary -
Model Years 2013-20.



MY 2013

MY 2014

MY 2015

MY 2016

MY 2017



Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Plus Off-Cyde

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimier Trucks

7,219



11,056



10,656



12,076



5,848



Navistar, Inc.









23



12



143



PACCAR, Inc.









-5



5



5



Vofvo Group





















TOTALS

7,219

0

11,056

0

10,674

0

12,093

0

5,996

0



MY 2018

MY 2019

MY 2020

TOTAL



Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cycle

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Pius Off-Cycle

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

5,141



8,360



16,583



76,939



Navistar, Inc.

16



13



37



244



PACCAR, Inc.





-5



-9



-9



Vorvo Group

















TOTALS

5,157

0

8,368

0

16,611

0

77,174

0

View this table at a larger text size by visiting:

https://www.epa.gov/svstem/files/documents/2022-ll/420r22028-report-tables.pdf.

Table 6-3. MHD Tractors - Class 7 High-Roof All Cabs: GHG Credits (Mg C02) Generated Summary -
Model Years 2013-20.



MY 2013

MY 2014

MY 2015

MY 2016

MY 2017



Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

37,428



49,409



38,973



50,366



33,097



Navistar, Inc.

396







6,487



15,621



10,709



PACCAR, Inc.





-9



435



-1,085



-3,346



Volvo Group





















TOTALS

37,824

0

49,400

0

45,895

0

64,902

0

40.460

0



MY 2018

MY 2019

MY 2020

TOTAL



Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

61,679



67,685



68,457



407,094



Navistar, Inc.

5,208



21,395



44,775



104,591



PACCAR, Inc.

-1,727



-2,629



-1,027



-9,388



Volvo Group

















TOTALS

65,160

0

86,451

0

112,205

0

502,297

0

View this table at a larger text size by visiting:

https://www.epa.gov/svstem/files/documents/2022-ll/420r22028-report-tables.pdf.

17


-------
Table 6-4. HHD Tractors - Class 8 Low-Roof Day Cabs: GHG Credits (Mg C02) Generated Summary-
Model Years 2013-20.



MY 2013

MY 2014

MY 2015

MY 2016

MY 2017



Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

-21,423



33,721



10,521



31,539



49,755



Navistar, Inc.

29,780







8,637



9,001



27,729



PACCAR, inc.





4,885



63,136



83,931



134,645



Volvo Group





8,538



24,307



31,655



48,722



TOTALS

8,357

0

47,144

0

106,601

0

156,126

0

260,851

0



MY 2018

MY 2019

MY 2020

TOTAL



Conventional

Advanced

Conventional

Advanced

Conventionaf

Advanced

Conventional

Advanced



Plus Off-Cycle

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

58,599



91,717



150,894



405,323



Navistar, Inc.

30,531



47,251



84,791



237,720



PACCAR, irtc

187,144



237,065



419,945

9,547

1,130,751

9,547

Volvo Group

53,532



72,335



136,885



375,974



TOTALS

329,806

0

448,368

0

792,515

9,547

2,149,768

9,547

View this table at a larger text size by visiting:

https://www.epa.gov/system/files/documents/2022-ll/420r22028-report-tabies.pdf.

Table 6-5. HHD Tractors - Class 8 Mid-Roof Day Cabs: GHG Credits (Mg C02) Generated Summary-
Model Years 2013-20.



MY 2013

MY 2014

MY 2015

MY 2016

MY 2017



Conventional

Advanced

Conventionai

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cycle

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

72,562



83,162



87,196



98.940



60,566



Navistar, Inc.





















PACCAR, Inc





49



1,529



529



1,099



Volvo Group





















TOTALS

72,562

0

83,211

0

88,725

0

99,469

0

61,665

0



MY 2018

MY 2019

MY 2020

TOTAL



Conventionai

Advanced

Conventionai

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

103,040



138,042



231,205



874,713



Navistar, Inc.

















PACCAR, Inc

1,488



860



1,405



6,959



Volvo Group

















TOTALS

104,528

0

138,902

0

232,610

0

881,672

0

View this table at a larger text size by visiting:

https://www.epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

Table 6-6. HHD Tractors - Class 8 High-Roof Day Cabs: GHG Credits (Mg C02) Generated Summary-
Model Years 2013-20.



MY 2013

MY 2014

MY 2015

MY 2016

MY 2017



Conventional

Advanced

Conventional Advanced

Conventional

Advanced

Conventionai

Advanced

Conventional

Advanced



Plus Off-Cyde

Technology

Plus Off-Cyde Technology

Plus Off-Cyde

Technology

Plus Off-Cycle

Technology

Plus Off-Cyde

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

265,827



284,531

412,663



520,976



320,054



Navistar, Inc.

179,814





164,002



234,544



176,953



PACCAR, Inc





4,918

78,360



93,451



126,000



Volvo Group





72,335

218,981



438,194



274,067



TOTALS

445,641

0

361,784 0

874,006

0

1,287,165

0

897,074

0



MY 2018

MY 2019

MY 2020

TOTAL



Conventionai

Advanced

Conventionai

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Cretfits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

364,288



461,237



846,468



3,476,044



Navistar, Inc.

154,448



245,132



457.046



1,611,939



PACCAR, Inc

175,284



167,763



301,582



947,358



Volvo Group

265,323



313,566



578,252

14,270

2,160,718

14,270

TOTALS

959,343

0

1,187,698

0

2,183,348

14,270

8,196,059

14,270

View this table at a larger text size by visiting:

https://www.epa.gOv/system/files/documents/2022-ll/420r22028-report-tables.pdf.

18


-------
Table 6-7, HHD Tractors - Class 8 Low-Roof Sleeper Cabs: GHG Credits (Mg C02) Generated Summary -
Model Years 2013-20.



MY 2013

MY 2014

MY 2015

MY 2016

MY 2017 j



Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

-49,180



-31,746



-56,226



-29,713



-3,818



Navistar, Inc.









-5,736



-3.827



-3,240



PACCAR, irxi





-6,662



-110,230



-72,839



-36,655



Volvo Group





-12,422



-13,942

-13,546



-6,686



TOTALS

-49,180

0

-50,830

0

-186,134

0

-119,925

0

-50,399

0



MY 2018

MY 2019

MY 2020

TOTAL



Conventional

Advanced

Conventional

Advanced

Conventional Advanced

Conventional

Advanced



Plus Off-Cycle

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde Technology

Plus Off-Cycle

Technology

Manufacturer

Credits Generated

Crec&ts Generated

Credits Generated

Credits Generated

Credits Generated Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

-6,753



-8,323



-11,877

-197,636



Navistar, Inc.

-2,190



-3,926



-5,356

-24,275



PACCAR, Inc.

-51,375



-79,947



-161,168

-518,876



Volvo Group

-6,579



-5,670



-15,241

-74,086



TOTALS

-66,897

0

-97,866

0

-193,642 0

-814873

0

View this table at a larger text size by visiting:

https://www.epa.gov/svstem/files/documents/2022-ll/420r22028-report-tables.pdf.

Table 6-8. HHD Tractors - Class 8 Mid-Roof Sleeper Cabs: GHG Credits (Mg C02) Generated Summary -
Model Years 2013-20.



MY 2013

MY 2014

MY 2015

MY 2016

MY 2017



Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional Advanced



Plus Off-Cycle

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

C redits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated Credits Generated

Daimler Trucks

-169,077



-74,550



-79,790



-112,197



-94,271

Navistar, Inc.









-43,813



-35,317



-26,886

PACCAR, Inc.





-14,513



-225,237



-239,495



-180,970

Voi vo Group





-37,498



-47,532



-50,177

-29,332

TOTALS

-169,077

0

-126,561

0

-396372

0

-437,186

0

-331,459 0



MY 2018

MY 2019

MY 2020

TOTAL



Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Pius Off-Cyde

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

-94,287



-114,999



-223,610



-962,781



Navistar, Inc

-27,382



-42,482



-63,657



-239,537



PACCAR, Inc.

-212,551



-311,376



-573,847



-1,757,989



Volvo Group

-33,192



-33,911



-68,302



-299,944



TOTALS

-367,412

0

-502,768

0

-929416

0

-3,260,251

0

View this table at a larger text size by visiting:

https://www.epa.gov/svstem/files/documents/2022-ll/420r22028-report-tables.pdf.

Table 6-9. HHD Tractors - Class 8 High-Roof Sleeper Cabs: GHG Credits (Mg C02) Generated
Summary - Model Years 2013-20.



MY 2013

MY 2014

MY 2015

MY 2016

MY 2017



Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cycle

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

967,290



879,024



877,908



1,669,315



612,114



Navistar, Inc









326,906



283,242



78,889



PACCAR, Inc





6,438



202,484



532,340



255,298



Volvo Group





3,876



244,933



675,812



173,053



TOTALS

967,290

0

889,338

0

1,652,231

0

3,160,709

0

1,119,354

0



MY 2018

MY 2019

MY 2020

TOTAL



Conventional

Advanced

Conventional

Advanced

Conventional

Advanced

Conventional

Advanced



Plus Off-Cyde

Technology

Phis Off-Cyde

Technology

Plus Off-Cyde

Technology

Plus Off-Cyde

Technology

Manufacturer

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated

Daimler Trucks

611,660



814,937



1,788,050



8,220,298



Navistar, Inc.

149,142



319,756



406,613



1,564,548



PACCAR, Inc

247,785



412,043



843,270



2,499,658



Volvo Group

173,722



305,251



603,279



2,179,926



TOTALS

1,182,309

0

1,851,987

0

3,641,212

0

14,464,430

0

View this table at a larger text size by visiting:

https://www.epa.gov/svstem/files/documents/2022-ll/420r22028-report-tables.pdf.

19


-------
As is allowed under the ABT program, some of these regulatory subcategories display a credit (or
compliance) deficit for a given manufacturer and model year. These deficits are summarized in the
appropriate averaging set regardless of the regulatory subcategory in which they were produced. A
manufacturer's compliance determination is made at each averaging set. For example, the credit
deficits generated by each manufacturer in the Class 8 Mid-Roof Sleeper Cabs subcategory (Table 6-8)
can be offset by the positive credits generated in the Class 8 High-Roof Sleeper Cabs subcategory (Table
6-9) or any other HHD vehicle subcategory. Taking this one step farther, the credits generated in each
averaging set in the tractor sector will also get combined with the respective averaging set credits
generated in the vocational vehicle sector in the subsequent section of this report.

Table 7 combines all the credits generated in the individual tractor subcategories from Tables 6-1
through 6-9 into their appropriate averaging sets. As previously described, conventional and off-cycle
credits are considered similar based on the restriction of applicability only within the averaging set in
which they were generated, so they are combined in Table 7. AT credits have much more flexibility in
their use and are kept separate in Table 7, summarizing all tractors through model year 2020. This table
shows that PACCAR created a credit deficit in the MHD averaging set in the tractor sector during
multiple model years. As the next section will show, PACCAR is still compliant for these model years in
the MHD vehicle averaging set because these credits still need to be combined with those generated in
the vocational vehicle sector for each averaging set (again compliance to the standards is done on the
averaging set level for all vehicles produced in that averaging set). The other three manufacturers show
compliance to the tractor GHG regulations for each model year based on the positive credit generation
in each tractor averaging set.

Table 7. All Heavy-Duty Tractors: GHG Credits (Mg C02) Generated Summary - Model Years 2013-20.

wr 2013

HHD Ccrwenoono:

RusCfP-Cfoe

imierTnsos
P4CCM. rc.

TOTALS

MY 2014

PlusOfr-CfOe Piuson-Cycle Teawtongy

MY 2015

O CanraiGarel
Plus Off-Cycle Plus Off-Cyae

49,270	i.232,272

- ::i	449.956

403	11042

426,747

57.29ft	2.135X67

Phc Off-Cycle
edits Senerated
62.323	2.172.260

16.091	427643

-322	397517

1.321-532
78.232	4.146352

32,722
11,789

-3,122

299,416
1,957,065

Daimler ThjOs
PACCM.X.

TOTfllS

PUsOff-Cyoe

66,919

1J336.M7
6,227	304MS

-1.8S2	347,774

usoir-cyae	Ptusoff-qoe Teamcscjy

neratee	Credit: SensrBleS credits Gewotei

76.400	1.322611

-2,573	426AOS

MY 2020

Ftus CXT-Cyae PlusQffCyoe

Ssrerated C
2,781431
879,437
831.186
1,234373
5.726,627

usQ^Cyde PKeWKyae Teairanojf
its Generated Credits SercratM

423.312	tl.313.S62

113,789	3.130353

-SOU	2.307438	9.347

4,342322	14,270

View this table at a larger text size by visiting:

https://www.epa.gov/svstem/files/docurnents/2022-ll/420r22028-report-tables.pdf.

Table 8 presents the banked credit balances for each tractor manufacturer in each of the two applicable
averaging sets at the conclusion of Phase 1 or model year 2020. Similar to Table 4 for vocational
vehicles, Table 8 for tractors was generated by adding the credits generated from each model year in
each averaging set for model years 2013 through 2020 while removing the unused expired credits
generated in model year 2013-15. There was not a credit life extension provision similar to vocational
vehicles in the tractor sector unless the manufacturer qualified as a small manufacturer meeting the
small business criteria. All banked tractor credits in the table below expire after a 5-year life. Appendix
A at the end of this report presents a more detailed breakdown of each of these credit calculations for
each model year that resulted in a change of these banked credits. In addition, Appendix B contains
links to spreadsheets for each manufacturer participating in the ABT program that details all credit
activity related to the generated credits for each model year to date. These detailed spreadsheets

20


-------
summarize any credit activity involving such transactions as credit trades, expired credits,
corrections/adjustments, etc. and the subsequent number of banked credits available for future use. In
summary, there are no C02 deficits in any tractor averaging set in Table 8, thus showing full compliance
to the Phase 1 GHG tractor vehicle regulations for each manufacturer participating in the ABT program
through the conclusion of the Phase 1 program (model year 2020).

Table 8. All Heavy-Duty Tractors: GHG Credits (Mg C02)
Banked Summary - Through Model Year 2020.



MHD

HHD





Conventional

Conventional

Advanced



Plus Off-Cycle

Plus Off-Cycle

Technology

Manufacturer

Credit Balance

Credit Balance

Credit Balance

Daimler Trucks

330,332

8,323,549



Navistar, Inc.

103,962

2,490,805



PACCAR, Inc.

0

2,302,701

9,547

Volvo Group



3,881,012

14,270

TOTALS

434,294

16,998,067

23,817

View this table at a larger text size by visiting:

https://www.epa.gov/svstem/files/documents/2022-ll/420r22028-report-tables.pdf.

d. Heavy-Duty Vehicle Compliance Summary

Table 9 presents a comprehensive summary of credits earned in model years 2013-20 in each of the
three heavy-duty vehicle averaging sets that can be carried over to subsequent model years for use.

This table was generated by adding the credits earned in each averaging set in the vocational vehicle
sector (Table 3) to those earned in the tractor sector (Table 7) for each model year. AT credits are again
tracked separately due to their flexibility of use in future model years. It is at the averaging set level that
any deficits need to be offset by using previous model year credits. If no positive credits are available
from the previous model years in the appropriate averaging set, a manufacturer must reconcile any
deficit within three model years from the model year in which the deficit was generated as described in
Part 1037.745.

21


-------
Table 9. Heavy-Duty Vehicles Averaging Set Summary: GHG Credits (Mg C02) Generated Summary -
Model Years 2013-20.





















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"¦»«











—







-

a**H

MWW







gj



-

*"

WW



**

a









T"

4MM

MjO*





UMM

¦tun

Uk



UMH

W.

un







"JW







~rr™







urn,



•is

M





£







i'™









ctr"



—







—



-

-

—

«*'

,jm



"-e



«
UN*











MA
nsio















-







SS









	aaj

	

WW"

	-s-





	Hllid

	HUB



	LSI-

	-id



...

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View this table at a larger text size by visiting:

https://www,epa.gov/svstem/files/documents/2022-ll/420r22028-report-tables.pdf.

Based on the positive credit totals for each manufacturer in each of the averaging sets for each model
year, compliance to the Phase 1 GHG regulations for the entire heavy-duty vehicle industry occurred. If
a deficit credit situation had appeared in any averaging sets in Table 9, this deficit would need to be
remedied first with any banked credits carried forward from previous model years or within the next
three model years in order to show compliance with the Phase I GHG program.

Table 10 presents the banked credit balances for each manufacturer in the three heavy-duty vehicle
averaging sets after the conclusion of model year 2020. All the manufacturers participating in the ABT
program carry positive credit balances in all the averaging sets at the conclusion of model year 2020
thus showing all manufacturers are compliant with the Phase 1 GHG heavy-duty vehicle standards
through the entirety of the Phase 1 program (model years 2014-2020). The banked credit totals in this
table fully carry forward into the Phase 2 program with no reductions. The LHD averaging set banked
credit values have also been adjusted for an increased useful life of 150,000 miles. For a more detailed
analysis on how these banked credit values were determined, please review the spreadsheets in
Appendix B that summarize all credit activities for each manufacturer individually from model years
2013-20.

22


-------
Table 10. Heavy-Duty Vehicles Averaging Set Summary: GHG Credits
(Mg C02) Banked Summary - Through Model Year 2020.



LHD

MHD

HHD





Conventional

Conventional

Conventional

Advanced



Plus Off-Cycle

Plus Off-Cycle

Plus Off-Cycle

Technology

Manufacturer

Credit Balance

Credit Balance

Credit Balance

Credit Balance

Autocar



1800

422,398



Blue Bird Body



288,215

121,646

235,397

Chanje







6,679

Chrysler Group

119,629







Daimler Coaches





179



Daimler Trucks



1,495,332

10,716,358



E-One





29,333



El Dorado





29,776



EVO Bus





2,799



Ferrara Fire





3,893



Ford Motor

527,410

520,530

11,157



General Motors

15,372

7,010





Gillig LLC



179

146,898

4,131

Hino Manufacturing



6,262

10



Hino Motors

5,395

21,704

1,491



Isuzu Motors

401,940

22,955





Kovatch Mobile





16,072



Mitsubishi Fuso

10,670





9,618

Motor Coach Ind.





141,723

2,046

Navistar, Inc.

1,236

1,055,268

3,254,376

0

New Flyer



410

164,840

448,463

Oshkosh





97,112



PACCAR, Inc.

484

256,035

5,092,089

14,293

Rosenbauer Motors





4,365



Spartan Fire





6,049



Terex Corporation





20,103



Tiffin Motor Homes



0

0



Van Hool





114,680

1,013

Volvo Group



3,063

5,514,057

19,506

XOS Trucks



21



3,465

TOTALS

1,082,136

3,678,784

25,911,404

744,611

View this table at a larger text size by visiting:

https://www.epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.


-------
4. Model Year 2020 Heavy-Duty Compression Ignition (CI)

Engine Compliance

The new GHG requirements in the heavy-duty compression ignition (CI) engine sector are very similar to
those already discussed in the heavy-duty vehicle sector. Model year 2014 was also the first mandatory
year for certifying heavy-duty CI engines to GHG standards. Manufacturers could also voluntarily
participate in a GHG ABT program which required them to submit the same two reports as the vehicle
manufacturers listed in Table 10. The ABT report submitted by the engine manufacturers would allow
the determination of credits generated in each averaging set as well as determining the intended
application of each engine as equipped in either a vocational vehicle or a tractor. If a manufacturer
chose not to participate in the ABT program, they were still required to provide an end-of-year
production volume report down to individual engine serial number. Of the ten on-highway CI engine
manufacturers certifying their products with EPA during model years 2013-2020, two manufacturers
chose not to participate in the GHG ABT program (Hino Motors and General Motors). This means that
each of their engine products had GHG performance at, or below, the applicable fleet average standard
for the regulatory category, and hence, all of their products are compliant with the applicable model
year GHG standards without the use of the ABT provisions.

Equation 2 is used to calculate C02 credits in each engine averaging set in the subsequent tables:
Eq. 2: Engine Credit Calculation

C02 credits (Mg) = (Std-FCL) X (CF) X (Volume) X (UL) X (10A-6)

Where:

STD = the emission standard in g/hp-hr

FCL = the family compliance limit for the engine family in g/hp-hr measured over the transient
test cycle for vocational engines or the RMC for tractor engines rounded to the same decimal
places as the emission standard

CF = a transient cycle conversion factor (hp-hr/mile) calculated by dividing the total (integrated)
horsepower-hours over the duty cycle (average of either vocational or tractor engine
configurations weighted by their production volumes) by 6.5 miles for compression ignition
engines. This represents the average work performed by the vocational/tractor engine in the
family over the mileage represented by operation over the appropriate duty cycle.

Volume = the number of engines eligible to participate in the ABT program with the given
engine family during the model year.

UL = useful life for the given engine family in miles (110,000 miles for light heavy-duty engines,
185,000 for medium heavy-duty engines, and 435,000 for heavy heavy-duty engines). Similar to
HD vehicles, beginning with model year 2021, the useful life for light heavy-duty engines has
also been changed to 150,000 miles. The credits presented in this report were calculated using

24


-------
the original value of 110,000 mile applicable for Phase 1 and were adjusted at the conclusion of
model year 2020 for carry over into Phase 2 (discussed further below).

Table 11 presents the applicable C02 emissions standards for heavy-duty CI engines applicable for model
years 2014-2020. The standards are presented for five regulatory subcategories which are:

1.	Light Heavy-Duty (LHD) Total (there is not a LHD tractor classification, so vocational application
represents the total in the LHD averaging set)

2.	Medium Heavy-Duty (MHD) with Vocational Application

3.	Medium Heavy-Duty (MHD) with Tractor Application

4.	Heavy Heavy-Duty (HHD) with Vocational Application

5.	Heavy Heavy-Duty (HHD) with Tractor Application

Table 11. Heavy-Duty Engine GHG Emissions Standards for Model Years 2014-20.



Model Years 2014-16



Model Years 2017-20



LHD CI

MHD CI

HHD CI

I

LHD CI

MHD CI

HHD CI

GHG Emissions Standards - Vocationals











Carbon Dioxide C02

600

600

567

576

576

555

Nitrous Oxide N20

0.10

0.10

0.10

0.10

0.10

0.10

Methane CH4

0.10

0.10

0.10

0.10

0.10

0.10

Test Cycle Required for C02 (FTP or RMC)

FTP

FTP

FTP

FTP

FTP

FTP

GHG Emissions Standards - Tractors













Carbon Dioxide C02

N/A

502

475

N/A

487

460

Nitrous Oxide N20

N/A

0.10

0.10

N/A

0.10

0.10

Methane CH4

N/A

0.10

0.10

N/A

0.10

0.10

Test Cycle Required for C02 (FTP or RMC)

N/A

RMC

RMC

N/A

RMC

RMC

Other Relevant Info













Vehicle Class

Class 2b-5

Class 6-7

Class 8

Class 2b-5

Class 6-7

Class 8

GVWR (lbs)

Less than 19,501

19,501 - 33,000

Greater than 33,000

Less than 19,501

19,501 - 33,000

Greater than 33,000

Useful Life (miles)

110.000*

185,000

435.000

110.000*

185.000

435,000

Test Cycle Required for N20 and CH4 measurement is always FTP regardless of vocational or tractor application

* Useful Life for LHD Engines Changed to 150,000 Starting in Model Year 2021

View this table at a larger text size by visiting:

https://www.epa.gov/svstem/files/docurnents/2022-ll/420r22028-report-tables.pdf.

Similar to the heavy-duty vehicle sector, engines with an agency-approved off-cycle technology receive
an additional credit multiplier for each engine equipped with the technology.5 These off-cycle credits
are similar to C02 credits generated by conventional engines in that they can only be used within the
averaging set in which they were generated. These off-cycle credits are calculated separately from
conventional credits and are determined by the incremental GHG benefit the technology contributes
beyond the FCL established for that engine using the engine dynamometer certification testing
procedure. Since these off-cycle credits are similar to conventional credits in how they can be used,
they are presented together in this report for each regulatory subcategory of CI engines. Both
conventional and off-cycle credits have a 5-year life similar to the vehicle sector which means that they
have to be used within five model years after the one in which they were generated, or they will expire.
There were no off-cycle credits generated by any heavy-duty CI engine manufacturer during the entirety
of the Phase 1 program (model years 2013 through 2020), so the credit values presented in the
following tables were "conventional only" for every model year.

5 See 40CFR 1036.610

25


-------
Similar to the provision described in the heavy-duty vehicle sector, AT credits can also be generated in
the heavy-duty engine sector in the Phase 1 program only. A manufacturer can generate AT credits for
hybrid powertrains that include energy storage systems and regenerative braking (including
regenerative engine braking) and for engines that include Rankine-cycle (or other bottoming cycle)
exhaust energy recovery systems. There were no engines certified that generated AT credits in the
entirety of the Phase 1 program (model years 2013 through 2020), so the tables displaying engine credit
information will not contain columns for those credits as they are all zero. The Phase 2 program
beginning with model year 2021 no longer allows engine certifiers to generate AT credits. The
generation of off-cycle credits remains an option for manufacturers carrying over into Phase 2.

Tables 12-1 through 12-3 summarize the model year 2013-2020 credits generated for each
manufacturer in the heavy-duty CI engine sector that certified using an engine dynamometer. Heavy-
duty engines installed in chassis certified vehicles are not included in this report. The credits produced
in each averaging set (LHD, MHD, and HHD) are presented separately as well as being further broken
down by the intended application of the engine as either tractor or vocational (again all LHD engines are
considered vocational only engines, so no tractor engine credits are applicable). Although spark ignited
(SI) engines are a separate averaging set in the heavy-duty sector, these engines are not included in this
report. There were also no off-cycle or advanced technology credits generated to date, so only
conventional engine credits are presented in the following tables. As was the case before, a blank cell in
any column means that the manufacturer did not produce any engines in that regulatory subcategory
for each model year.

26


-------
Table 12-1. LHD CI Engine Averaging Set: GHG Credits (Mg C02) Generated Summary -
Model Years 2013-20.



MY 2013

MY2014

MY 2015

MY2016

MY2017



Vocational Engine

Vocational Engine

Vocational Engine

Vocational Engine

Vocational Engine



Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated



Net C02

Net C02

Net C02

Net C02

Net C02

Manufacturer











Cummins Inc.











Detroit Diesel











Ford Motor



252,236

217,062

161,215

11,289

FPT Powertrain



1,215



6,492

-456

Isuzu Motors





56,886

54,534



Navistar, Inc.



-681







PACCAR, Inc.











Volvo Group











TOTALS

0

252,770

273,948

222,241

10,833



MY2018

MY2019

MY2020

TOTAL



Vocational Engine

Vocational Engine

Vocational Engine

Vocational Engine



Credits Generated

Credits Generated

Credits Generated

Credits Generated



Net C02

Net C02

Net C02

Net C02

Manufacturer









Cummins Inc.









Detroit Diesel









Ford Motor

9,003

22,124

359,461

1,032,390

FPT Powertrain







7,251

Isuzu Motors



8,983

4,599

125,002

Navistar, Inc.



28,161

35,577

63,057

PACCAR, Inc.









Volvo Group









TOTALS

9,003

59,268

399,637

1,227,700

View this table at a larger text size by visiting:

https://www.epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

27


-------
Table 12-2. MHD CI Engine Averaging Set: GHG Credits (Mg C02) Generated Summary -
Model Years 2013-20.



MY 2013

MY2014

MY 2015

MY201E

MY2017



Vocational Engine

Troop" Enjre

Vocational Ermine

Tractor Engine

Vocational Engine

Tractor Ermine

Vocational Engirve

Tractor Engine

V oration al Ermine

Tractor Engine



Credit; Generated

Credrtskien crated

Credits Generated

Credits Sereratee

Credits Generated

Cr«tts Generated

Credits Generated

Credits Generated

Credits Generatec

Credits Gereratee



NetCOZ

Net COZ

Net CO2

Net CO!

Net CO 2

Met C02

MetCC2

NetCOZ

Net C02

Net C02

Manufacturer





















Cummins inc.

2,431,930

36,721

3,410.512

43,789

4.133 JSS

13,649

739,201

-11,977

2517,425

-4,467

Detroit Diesel

















19,455



Ford Motor













26,163

-1,694

16,742

-1,034

ft Powertrain





















Isuel Motors





















Naviitar. Inc.





-6211

-1,043

83,030

-30

70,179

-167

1,732



PACCAR, Inc.





















VoVo Gtcjd





















TOTALS

2,431.980

36,721

3,404,701

42,741

*.-216,425

15,799

855545

-13,333

2555,422

•5.301



MY2018

MY2019

MV202Q

TOTAL



Vocatonal Ermine

Tractor Engine

Vocational Ermine

Tractor Enpne

Vocational Engine

Tractor Ermine

Vocational Engine

Tractor Engine



Credits Generated

Credits Generated

C-edits Gereratec

Crests Generated

Creccts Generated

Credits Generated

Credit; Generated

Credits Generated



Net CO 2

NetCOZ

NetCOZ

NetC02

NetC02

NetCOZ

NetCOZ

Netcoz

Manufacturer

















Cummins mc.

2.0435B6

s.oce

2120,435

-12,263

1,962.331

-12.431

1S.1B1.B16

64,227

Detroit Diese!

33573

-686

263,433

MSI

41503

27B

3B3.133

1,061

Ford Motor

£7524



36,753



71,427



169,041

-2,728

FT Powertrain









0







Isuzu Motors

















Navistar, Inc













148,730



PACCAR, mc

















v'o^o Gt&jd

















TOTALS

2.119.1B5

3510

2,«S,£95

-10.734

2,075,736

-12.153

19,834,742

61.295

View this table at a larger text size by visiting:

https://www.epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

Table 12-3. HHD CI Engine Averaging Set: GHG Credits (Mg C02) Generated Summary -
Model Years 2013-20.



MY 2013

MY2014

MY 2015

MY2016

MY 2017



Vocational Engine
Credits Generated
Net C02

Tractor Engine
Credits Generated
Net C02

Vocational Engine
Credits Generated
Net C02

Tractor Engine
Credits Generated
Net C02

Vocational Engine
Credits Generated
Net C02

Tractor Engine
Credits Generated
Net C02

Vocational Engine
Credits Generated
Net C02

Tractor Engine
Credits Generated
Net C02

Vocational Engine
Credits Generated
Net C02

Tractor Engine
Credits Generated
Net C02

Manufacturer



















Cummins lnc.y
Detroit Diesei
Ford Motor

452,659
447,299

2,354,276
1,231,159

502,112
612,654

3,160,240
2,041,851

441,967
685,880

1,639,452
2,312,587

-531,266
492,178

-874,489
512,697

581,624
788,844

-308,689
395,642

FPT Powertrain
Isuzu Motors



















Navistar, Inc.
PACCAR, Inc.
Volvo Group





130,740
326,065
409,923

-53,184
34,426
834,350

158,828
537,598
1,176,895

4,234
67,663
610,293

110,497
718,430
399,166

5,619
71,794
467,712

53,616
730,166
682,271

3,014
33,112
-438,947

TOTALS

899,958

3,585,435

1,981494

6,017,683

3,001,168

4,634,229

1,189,005

183,333

2,836,521

-315,868



MY2018

MY2019

MY2020

TOTAL



Vocational Engine

Tractor Engine

Vocational Engine Tractor Engine

Vocational Engine

Tractor Engine

Vocational Engine

Tractor Engine



Credits Generated

Credits Generated

Credits Generated Credits Generated

Credits Generated

Credits Generated

Credits Generated

Credits Generated



NetC02

Net C02

Net C02 Net C02

Net C02

Net C02

Net C02

Net C02

Manufacturer













Cummins Inc.

108,061

75,513

899,669 77,690

747,117

250,436

3,201,943

6,374,429

Detroit Diesel

891,787

743,510

1,041,857 768,702

-122,071

-71,985

4,838,428

7,934,163

Ford Motor















FPT Powertrain















Isuzu Motors















Navistar, Inc

113,836

58,919

237,206 62,769

158,145

37,718

962,868

119,089

PACCAR, Inc.

875,172

47,235

1,175,446 275,695

266,169

-209,767

4,629,046

320,158

Volvo Group

604,416

-202,446

794,938 -195,230

5,477

-167,529

4,073,086

908,203

TOTALS

2,593,272

722,731

4,149,116 989,626

1,054,837

-161,127

17,705,371

15,656,042

View this table at a larger text size by visiting:

https://www.epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

One significant difference between the heavy-duty vehicle and heavy-duty engine regulatory programs
is that C02 is not the only GHG pollutant for which a heavy-duty manufacturer is required to meet a

28


-------
standard for certification (as viewed in Table 11). Nitrous oxide (N20) and methane (CH4) are also
regulated constituents in the heavy-duty engine program. N20 and CH4 credit deficits for one engine
family must be offset by C02 credits generated by the same or another family within the same averaging
set. Any credit deficit from N20 or CH4 is converted into an equivalent C02 value using the Global
Warming Potential (GWP) value for either pollutant. N20 has a GWP value of 298, meaning that a 1 Mg
N20 deficit needs to be offset by 298 Mg of C02 credits. Similarly, the GWP value for CH4 in Phase 1 is 25
(this value changes to 34 beginning in model year 2021), and these deficits also need to be offset by
equivalent C02 credits. One additional regulatory option from previous model years was the possibility
of generating additional C02 credits when certifying to N20 levels below 0.04 g/hp-hr during model
years 2014-2016 only. Beginning in model year 2017, C02 credits could no longer be generated from
N20 for compliance. However, any N20 deficits generated must be offset using C02 credits in 2017 and
future years. CH4 has no option for generating credits. Similar to N20, CH4 deficits may be offset with
equivalent C02 credits. The credit values presented in Table 12 are "Net C02" credits which means that
any N20 and CH4 deficits have already been accounted for in the credit calculations. Again, there were
no off-cycle or AT credits generated for any engine manufacturer in model years 2013 through 2020.

In certain instances, presented in Tables 12-1 through 12-3, a manufacturer demonstrated a deficit in
either the tractor or vocational engine regulatory category as allowed under the program. These deficits
would first be offset using any available credits generated in either the vocational or tractor category
within the same model year. If the available credits were not enough to offset the deficit, banked
credits from a previous model year would need to be used.

Table 13 summarizes the credits generated in model years 2013-20 for each manufacturer in each of the
averaging set. Note that the regulations regarding ABT credit generation do not differentiate between
tractor or vocational vehicle application. Table 13 was generated by summing vocational and tractor
credits generated from each individual model year in each averaging set for model years 2013 through
2020. There were a few cases in which a manufacturer generated a deficit in an averaging set. In each
of these cases, the deficit was offset by using banked credits from a previous model year. One example
of note is that of the deficits in both the LHD and MHD engine averaging sets generated in model year
2014 by Navistar. As presented in the table, there were no credits available to Navistar to offset these
deficits at the time. In this case Navistar demonstrated compliance by using advanced technology
credits generated in model year 2014 from the heavy-duty vehicle sector (specifically LHD category) to
offset both of these deficits. In the other cases where a manufacturer ran a deficit (Cummins and FPT
Powertrain for instance), these deficits were offset by just using banked engine credits available to them
from a previous model year.

Another note for Table 13 below is that three manufacturers (Detroit Diesel, PACCAR, and Volvo Group)
chose to certify their model year 2020 engine products using the interim provision provided in the Phase
2 rulemaking (Part 1036.150(p)). The use of this optional interim provision required the certification of
model year 2020 MHD and HHD engines to the more stringent model year 2021 Phase 2 standards early
in exchange for an extended credit life. Specifically, manufacturers that chose this option will have their
banked credits in the MHD and HHD engine averaging sets from model years 2018 and beyond available
for compliance use through model year 2030 (no expiration in 5 years). This interim provision was not
available for engines in the LHD averaging set. The use of this interim provision resulted in both Detroit
Diesel and Volvo Group generating a HHD engine credit deficit in model year 2020 which was offset by
using banked credits from a previous year. However, the credit balances now available from model
years 2018 and beyond will not expire in 5 years and will be available for use in any model year through
2030.

29


-------
Table 13. All Heavy-Duty CI Engines - Averaging Set Summary: GHG Credits (Mg C02) Generated
Summary - Model Years 2013-20.

etCDJ	Met CC2

*468.701	2jC6.H3

252.770	3.447^g

747.224
24.471

77? 7*1	841,707

3«,27S
:3"333

NetC02	Net C02

2.312,962	Z72J35

1.732.J	•

763,278

2349.921	2320.653

Create GenerMec Create Senerstee

J.CB4.Si	1S3.374

34,677	1.633.297

t732«

2.106.194
36 "Hi

uum

399.706
9.138.742

1^27.700	19.946.C37	33361.413

View this table at a larger text size by visiting:

https://www.epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

Appendix A at the end of this report presents a more detailed list of credit activities (e.g., error
corrections) plus other notes effecting credit generation and use for each model year that resulted in a
change of any banked credits. In addition, Appendix B contains links to spreadsheets for each
manufacturer participating in the ABT program that details any credit activity to the generated credits
presented in the tables above for each model year to date. These detailed spreadsheets summarize all
credit activity involving such transactions as credit trades, expired credits, error corrections, etc. and the
subsequent number of banked credits available for future use.

Table 14 presents the cumulative credit balances (banked credits) for each engine manufacturer in each
of the three averaging sets at the conclusion of model year 2020. There are no deficits in any averaging
set of Table 14 showing that all manufacturers were able to comply with the GHG heavy-duty CI engine
standards for the entirety of the Phase 1 program (model years 2014 through 2020). All engine
manufacturers have positive credit balances for use in compliance to the GHG standards for future
model years of the Phase 2 program.

In addition to the optional early certification provision to the Phase 2 standards described above, there
were two other provisions in the Phase 2 rulemaking that affected credit balance values presented in
Table 14 below. Similar as the vehicle ABT program, all banked engine credits in the LHD averaging set
were multiplied by a value of 1.36 for the increased useful life provision for these engines increasing
from 110,000 to 150,000 miles. The other provision affecting banked engine credits in the table below
was the limitation of vocational engine credits carrying into the Phase 2 program starting in model year
2021 as described in Part 1036.701(j). Vocational engine banked credits (tractor engine credits carried
through fully into Phase 2) were reduced for only those generated in the MHD and HHD averaging sets
using the standards provided in Part 1036.701(j). The C02 standards provided in this section were much
more stringent than the original applicable standards and resulted in extensive reductions to the
quantity of banked credits carried over into model year 2021 (Phase 2). For a more detailed analysis of
this reduction, please see the credit summary spreadsheets in Appendix B which present the magnitude
of these reductions for each manufacture in the ABT program.

30


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Table 14. All Heavy-Duty CI Engines - Averaging Set Summary:
GHG Credits (Mg C02) Banked Summary - Through Model Year 2020.









Advanced



LHD

MHD

HHD

Technology



Credit Balance

Credit Balance

Credit Balance

Credit Balance



Net C02

Net C02

Net C02

Net C02

Manufacturer









Cummins Inc.



3,338,125

403,639



Detroit Diesel



259,503

3,243,179



Ford Motor

765,805

15,759





FPT Powertrain

8,829







Isuzu Motors

92,638

0





Navistar, Inc.

86,684

0

312,984



PACCAR, Inc.





2,028,708



Volvo Group





467,712



TOTALS

953,956

3,613,387

6,456,222

0

View this table at a larger text size by visiting:

https://www.epa.gov/system/files/documents/2022-ll/420r22028-report-tables.pdf.

5. Conclusions

As indicated previously, the success of the Phase 1 heavy-duty GHG program as documented in the
pages of this report has been measured in the industry's ability to create the systems and processes
necessary to demonstrate compliance with the program, improve their products to lower their GHG
emissions and fuel consumption, as well as to document through submission of reports that the fleet of
vehicles they produced complies with the aggregated fleet standards. It is a significant accomplishment
that the entire industry was able to implement and begin complying with this program and has
demonstrated through their reporting that GHG emissions have been reduced to such an extent that all
manufacturers are compliant and most have created significant credit banks reflecting better overall
fleet performance than the agencies originally projected in setting up the program.

This report documents that all manufacturers were not merely compliant for the entirety of the Phase 1
program, but that all manufacturers have generated a positive banked credit balance moving into Phase
2 program in each of the three averaging sets for vehicles. This clearly demonstrates full compliance
with the new standards that became mandatory in model year 2014 (summarized in Table 10 Section 3
of this report). EPA expects more manufacturers to participate in the vehicle ABT program beginning in
Phase 2 as small manufacturers that qualify as small businesses will no longer be exempt for certification
as they were for the entirety of the Phase 1 program. Similarly, all heavy-duty engine manufacturers
also show full compliance through model year 2020 with the engine GHG standards (summarized in
Table 14 Section 3 of this report).

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Appendix A: Credit Activity Overview for Each Model Year

Optional Early Model Year 2013 Heavy-Duty Vehicle and CI Engine Summary

EPA's Phase 1 GHG program allows manufacturers to certify their vehicles to the Phase 1 GHG standards
a model year early to earn additional credits. As an incentive, the credits that were generated from
early certification are multiplied by XI.5, for the 2013 model year only. Three vehicle manufacturers
(Daimler Trucks, Navistar, and PACCAR) chose to utilize this option, generating early credits in model
year 2013. The credits generated by these manufacturers in model year 2013 were carried forward to
subsequent model years for use. There were no vehicles certified in model year 2013 that generated
either IT or AT credits.

One requirement for utilizing this early certification option was that a manufacturer must certify their
entire product line within a regulatory subcategory so that they could not just pick the credit generating
vehicles/engines within a subcategory for certification. Similarly, as previously described, these credit
totals for each regulatory subcategory were then combined at the averaging set level. The only
difference at this point regarding early model year 2013 certification is that any averaging set resulting
in a credit deficit would be reset to zero as the regulations state that a manufacturer can't generate a
deficit if early certifying (Part 1037.150). This was indeed the case involving Navistar vehicles for model
year 2013 where their LHD vehicle averaging set resulted in a credit deficit of -1,056 Mg C02. This value
was reset to zero in the various tables of this report which carried forward to model year 2014.

These credits generated in model year 2013 were then banked for future use through model year 2018.
Any model year 2013 credits that were not used to offset any credit deficit generated before or during
model year 2018 expired as this represents the extent of their five-year lifetime. The amount of expired
credits for each manufacturer can again be viewed in the detailed manufacturer spreadsheets available
in Appendix B.

The Phase 1 rule provided the same optional credit earning opportunity for engines as for vehicles by
allowing manufacturers to certify a year early (model year 2013) to the mandatory GHG standards
starting January 1, 2014 while earning a bonus 1.5X multiplier on any credits earned early in model year
2013. Two heavy-duty engine manufacturers (Cummins and Detroit Diesel) made use of this option and
certified their engines in model year 2013. However, both Cummins and Detroit Diesel chose to certify
using the Alternate Phase-In option described in 40 CFR § 1036.150, which does not allow for the 1.5X
multiplier on model year 2013 generated credits. Similar to vehicles, these banked credits carried
forward to offset any credit deficits through model year 2018 at which point they expired. The amount
of expired credits for each manufacturer can again be viewed in the detailed manufacturer spreadsheets
available in Appendix B.

Model Year 2014 Heavy-Duty Vehicle and CI Engine Summary

Beginning on January 1, 2014, manufacturers were required to certify their heavy-duty vehicles and
engines to the Phase 1 GHG standards. The credits generated in model year 2014 could be banked for
future use through model year 2019. If not used to offset any credit deficit generated before or during
model year 2019, these model year 2014 generated credits will expire as this represents the extent of
their five-year lifetime.

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Navistar certified AT vehicles in model year 2014, utilizing an interim provision in the regulations (Part
1037.150) that allowed manufacturers to certify electric vehicles produced in model years before 2014
to the 2014 model year GHG standards for AT credit generation. Electric vehicles have a defined FEL of
zero for the purpose of computing these AT credits. Using this interim provision, Navistar certified some
LHD electric vehicles in model year 2014 that were produced during model years 2010-2012 which
generated 8,393 Mg C02 of AT credits.

Another point to note is that Navistar pulled ahead their model year 2014 vehicle production start date
to better align their engine and vehicle product cycles. Therefore, no ABT information for conventional
and off-cycle vehicles is presented for model year 2014. The bulk of the vehicles that they did produce
during the model year 2014 timeframe showed up in the model year 2015 data. The only vehicles
showing up in this model year data for Navistar are the previously referenced LHD electric vehicles.

Navistar also utilized the alternate C02 standard described in 40 CFR § 1036.620 for certifying their LHD
engine family. When using this provision, they are not allowed to generate any C02 credits to help
offset a CH4 deficit generated within this family. When converted to an equivalent C02 basis, the
magnitude of this deficit was 681 Mg C02 in the LHD averaging set. Navistar also produced a similar C02
deficit of 7,259 Mg C02 in the MHD engine averaging set this time due to an N20 deficit. As the
spreadsheet available in Appendix B will indicate, Navistar offset these deficits using AT credits earned in
the heavy-duty vehicle sector previously described in this appendix. After offsetting these two engine
deficits, Navistar was left with a balance of 453 Mg C02 of AT credits from the original 8,393 Mg amount
generated in the heavy-duty vehicle sector. There were no other credit deficits generated by other
manufacturers in any other engine/vehicle averaging set for this model year.

Model Year 2015 Heavy-Duty Vehicle and CI Engine Summary

Beginning on January 1, 2014, manufacturers were required to certify their heavy-duty vehicles and
engines to the Phase 1 GHG standards. The credits generated in model year 2015 can be banked for
future use through model year 2020. If not used to offset any credit deficit generated before or during
model year 2020, these model year 2015 generated credits will expire as this represents the extent of
their five-year lifetime.

Tiffin Motor Homes opted to not participate in the heavy-duty vehicle ABT program starting this model
year, but their MHD and HHD vocational vehicle ABT credits generated in model year 2014 will remain
available to them for use through the 2019 model year.

PACCAR resubmitted their model year 2014 ABT report in order to correct an error that reduced the
credits generated in the HHD tractor engine sector by 225 Mg C02for that year. This correction was
submitted after EPA finalized the model year 2014 credit values in the spreadsheet found in Appendix B,
therefore, this correction is reflected in the subsequent model year 2015 data as can be viewed in the
spreadsheet available in Appendix B.

Navistar became the first manufacturer to receive EPA and NHTSA approval on an off-cycle technology
and began generating additional credits using this technology in model year 2015. Navistar remains the
only manufacture to receive approval on an off-cycle technology during the Phase 1 program.

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Also reflected in model year 2015 is that FPT Industrial did not certify any engines this year, Isuzu joined
the heavy-duty engine ABT program and New Flyer joined the heavy-duty vehicle ABT program. There
were no credit deficits generated in any engine/vehicle averaging set this model year.

Model Year 2016 Heavy-Duty Vehicle and CI Engine Summary

The credits generated in model year 2016 can be banked for future use through model year 2021. If not
used to offset any credit deficit generated before or during model year 2021, these model year 2016
generated credits will expire as this represents the extent of their five-year lifetime.

Cummins reported a credit deficit in the HHD engine averaging set of -1,405,755 Mg C02 which was
offset using banked credits generated from previous model years. There were no other credit deficits
generated in any other engine/vehicle averaging set this model year. During model year 2016 Kovatch
joined the vehicle ABT program this model year and Ford introduced MHD engine products.

Model Year 2017 Heavy-Duty Vehicle and CI Engine Summary

The credits generated in model year 2017 can be banked for future use through model year 2022. If not
used to offset any credit deficit generated before or during model year 2022, these model year 2017
generated credits will expire as this represents the extent of their five-year lifetime.

C02 emissions standards became more stringent this model year, as indicated in the standards setting
sections of Part 1036 for engines, Part 1037 for vehicles, and in the standards tables provided earlier in
this report. The more stringent standards potentially resulted in reduced credit generation for a certain
vehicle/engine.

Fiat Powertrain had the sole deficit generated in the engine and vehicle averaging sets, with a
magnitude of 456 Mg in the LHD engine averaging set. The deficit was offset using banked credits
available from a previous model year.

New Flyer, Gillig, and Chanje generated AT credits during model year 2017. They were the first to do so
since Navistar used the interim provision during model year 2014. Additionally, Kovatch and Ford
began certifying vocational tractors while Chanje, New Flyer, Van Hool, Kovatch, and Ferrara Fire joined
the vehicle ABT program.

Model Year 2018 Heavy-Duty Vehicle and CI Engine Summary

The credits generated in model year 2018 may be banked for future use through model year 2023. If
not used to offset any credit deficit generated before or during model year 2023, these model year 2018
generated credits will expire as this represents the extent of their five-year lifetime.

Model year 2018 represented the first model year in which credits earned during the program were
expired. Credits earned during model year 2013 expired if not used prior to the completion of model
year 2018. The quantity of expired credits are presented in the detailed credit activity spreadsheets for
each manufacturer found in Appendix B.

Cummins submitted revised reports during this model year timeframe. The reports reflected increased
declared C02 values for a single engine tractor family for model years 2013 through 2016. This higher

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C02 value subsequently resulted in a reduction of the credits generated during these four model years.
These credit reductions can also be viewed in the detailed credit summary spreadsheet included in
Appendix B.

Model year 2018 was the first year that vehicle manufacturers were able to use pre-approved off-cycle
credit generation paths provided in the Phase 2 rulemaking described in Part 1037.150. These pre-
approved off-cycle credit generation options do not require prior approval from both EPA and NHTSA
and were available to manufacturers as interim provisions allowed for enhanced credit generation
starting in model year 2018. Autocar joined the ABT program using the small business provisions of Part
1037.150(y)(3) to begin generating enhanced credits for natural-gas fueled vehicles in model year 2018.
These provisions were added in the Phase 2 rulemaking and were optional for manufacturers to use
early in the Phase 1 program to generate additional credits before converting to the Phase 2 program
starting in model year 2021.

There were no credit deficits generated during model year 2018 in any of the engine or vehicle
averaging sets. Two additional manufacturers (Blue Bird and Mitsubishi Fuso) began generating AT
credits this year joining New Flyer, Gillig, and Chanje.

Model Year 2019 Heavy-Duty Vehicle and CI Engine Summary

The credits generated in model year 2019 may be banked for future use through model year 2024. If
not used to offset any credit deficit generated before or during model year 2023, these model year 2019
generated credits will expire as this represents the extent of their five-year lifetime.

Navistar and Autocar continued as the only vehicle manufacturers to generate off-cycle credits.

Bluebird and New Flyer were the only vehicle manufacturers to generate AT credits this model year.

Hino Motors, Hino Manufacturing, and Daimler Coaches joined the vehicle ABT program this model year.
GM began to certify vehicles again under Part 1037 and participated in the ABT program. Isuzu Motors
also rejoined the engine ABT program this model year.

Model Year 2020 Heavy-Duty Vehicle and CI Engine Summary

The credits generated in model year 2020 may be banked for future use through model year 2025. If
not used to offset any credit deficit generated before or during model year 2025, these model year 2020
generated credits will expire as this represents the extent of their five-year lifetime. This was also the
last model year of the Phase 1 program. The Phase 2 rulemaking provided some additional provisions
regarding banked credits carrying over into model year 2021 which represents the first year of the Phase
2 program as described below.

The first of these provisions involved the increase of the LHD engine and vehicle useful life from 110,000
miles to 150,000 miles. As a result, all banked credits in these averaging sets were multiplied by a value
of 1.36 and carried into Phase 2. This rulemaking also provided an interim provision for extended credit
life for LHD and MHD vocational vehicles generated in model years 2018-2021 for all manufacturers
participating in ABT. Such credits are no longer limited to a 5-year credit life and will remain available
for compliance use through model year 2027 as described in Part 1037.150(y). This provision was only
for vocational vehicles produced during model years 2018-2021, and tractor vehicle credits generated
during these same model years remain restricted to the same 5-year credit life limitation as before. An
additional provision in the Phase 2 rulemaking also allows small manufacturers meeting the small

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business criteria specified in 13 CFR 121.201 to have an extended life for all of their credits generated by
both vocational and tractor vehicles. Specifically, all vehicle credits generated during model years 2018-
2021 can be used for compliance through model year 2027 by these qualifying small manufacturers.
There were only two qualifying small manufacturers that optionally participated in the vehicle ABT
program during the entirety of Phase 1 which were Autocar and XOS Trucks.

The engine sector had two other revisions provided by the Phase 2 rulemaking that affected banked
credits which could be carried into model year 2021. The first of these was an optional certification path
in model year 2020 involving certifying early to the Phase 2 standards in exchange for an extended
credit life for only MHD and HHD engines (both vocational and tractor engines). Specifically, if
manufacturers optionally chose to certify all of their MHD and HHD engines early in model year 2020 to
the 2021 standards, then any banked credits in these two averaging sets from model years 2018-2024
would have an extended credit life for compliance use through model year 2030 as described in Part
1036.150(p). All other banked credits remained limited to the 5-year credit life limitation. Three
manufacturers chose this optional path which included Detroit Diesel, PACCAR, and Volvo Group.

The second revision to banked credits which could be carried into model year 2021 involved banked
credits associated with MHD and HHD vocational engines. The initial rulemaking did not allow for any of
these vocational engine credits generated in Phase 1 to be carried though into Phase 2 (starting with
model year 2021). However, the subsequent Technical Amendments to this rule allowed for a limited
quantity of banked credits from these engines to be carried forward. Part 1036.701(j) allowed for the
adjustment of vocational engine banked credits from Phase 1 to be carried into model year 2021.
Specifically, new emissions standards were provided in this part for MHD and HHD vocational engines
only that required a recalculation of model year 2016-20 generated credits that were allowed to carry
over into Phase 2 (LHD and all tractor credits were unaffected and carried over fully into Phase 2).

Those certifying early to the Phase 2 standards as described in the paragraph above were not subjected
to a reduction of vocational engine credits for model year 2020 only (model years 2016-19 still resulted
in reductions). Appendix B provides a more detailed description as to the magnitude of these
reductions for each manufacturer.

Rosenbauer Motors, Spartan Fire, and XOS Trucks were new to the vehicle ABT program this model year.
Navistar and Autocar remain the only vehicle manufacturers that produced off-cycle credits during the
entirety of the Phase 1 program. Volvo Group and PACCAR became the first tractor manufacturers to
generate AT credits this model year. Other vehicle manufacturers generating AT vocational vehicle
credits were Bluebird, PACCAR, XOS Trucks, Motorcoach Industries, New Flyer, Van Hool, and Volvo
Group.

Both Detroit Diesel and Volvo Group generated a credit deficit in the HHD engine averaging set which
was offset by using banked credits from a previous year. Hino Motors did not certify any engines this
model year. Isuzu Motors certified engines in the MHD averaging set for the first time, however, these
engines were certified at the standard and thus did not generate any credits.

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Appendix B: Individual Manufacturer Detailed Credit Summaries

Readers of this report should use the following link to obtain the credit summary for each participating
manufacturer: (https://nepis.epa.gov/Exe/ZyPDF.cgi/P1016962.PDF?Dockey=P1016962.PDF).

Each summary includes, for each model year of participation the current balance of banked credits in
each of the vehicle and engine averaging sets presented in this report. There are two tabs to each
spreadsheet, one being for heavy-duty engines and the other for vehicles. These spreadsheets are also
sent to each manufacturer participating in the ABT program that determines their current credit status
with EPA. NHTSA uses a separate credit tracking system for their credit program and provides separate
summaries to each manufacturer.

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