Addendum to Final Phase 1
EPA Heavy-Duty Vehicle and Engine
Greenhouse Gas Emissions
Compliance Report (Model Year 2021)



£%	United States

Environmental Protect
Agency


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Addendum to Final Phase 1
EPA Heavy-Duty Vehicle and Engine
Greenhouse Gets Emissions Compliance
Report (Model Year 2021)

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-22-028A
June 2023


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This addendum to the "Final Phase 1 Heavy-Duty Vehicle and Engine Greenhouse Gas Emissions
Compliance Report (Model Years 2014 - 2020)" supplements the report with Model Year 2021 data.

This addendum 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. The comprehensive, previously
published report is located on the EPA website: https://www.epa.gov/compliance-and-fuel-economy-
data/epa-heavy-duty-vehicle-and-engine-greenhouse-gas-emissions. EPA recognizes significant
stakeholder interest in the compliance status of manufacturers subject to the regulatory programs. We
are providing this supplemental data summary in advance of the next full report, anticipated to be
published in late 2024 or early 2025.

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 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 available after 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 quantity 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).

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 and 2 programs, 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


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emissions. The EPA ABT program allows for emission credits to be averaged, banked, or traded within
each of the "averaging sets" described in this interim 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 addendum 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 addendum also summarizes the current C02 credit situation at the conclusion of
Model Year 2021 (the first year of the Phase 2 program) for each manufacturer participating in either of
the vehicle or engine ABT programs.

Phase 2 also introduced new vehicle averaging sets for certain types of vocational vehicles by allowing a
manufacturer to optionally certify using the custom chassis provisions of 40 CFR Part 1037. Banking of
excess credits is not allowed for these custom chassis vehicles at the conclusion of a model year. The
vehicle manufacturer must have a positive number of credits or they are deemed non-compliant for the
year. Any excess credits are not able to be banked and carried over for use in future model years. The
credits earned for these custom chassis averaging sets are not presented in this interim report as each
manufacturer that certified using the custom chassis provisions was compliant in Model Year 2021 by
either having a positive credit balance in each of these averaging sets or by using Phase 1 Advanced
Technology credits to offset a negative credit balance. Please refer to the report referenced above for a
better description of Phase 1 Advanced Technology credits and their continued flexibility within the
Phase 2 program.

The success of the heavy-duty GHG program 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.

Table 1 of this addendum documents that all vehicle manufacturers are not merely compliant, but that
all manufacturers participating in ABT have generated a positive banked credit balance through model
year 2021 in each of the three averaging sets for vehicles. This table also presents currently available
Phase 1 Advanced Technology banked credits which maintain their flexibility into the Phase 2 program
until they expire (see report referenced above for additional information about these flexibilities).
Similarly, Table 2 shows the updated credit balance values for all engine manufacturers in each of the
three averaging sets (Heavy-Duty Spark Ignition engines are not part of this report) after model year
2021 (there were no Advanced Technology credits generated in Phase 1 so there is no corresponding
column in this table to reflect those credits). All engine manufacturers except for one have zero or
positive credit balances in each of the averaging sets. A negative balance is allowed by the regulations,


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however, a manufacturer having a negative credit balance may utilize three model years to achieve a
zero or positive credit balance.

Table 1

Heavy-Duty Vehicles Averaging Set Summary

GHG Credits (Mg C02) Banked Summary - Through Model Year 2021



LHD

MHD

HHD

Total



Total Credit

Total Credit

Total Credit

Phase 1 AT

Manufacturer

Balance

Balance

Balance

Credit
Balance

ARBOC Specialty



108





Autocar



1,952

195,804



Battle Motors







3,259

Blue Bird Body



217,089

91,298

233,725

Chanje







6,679

Chrysler Group

413,935







Daimler Coaches





179



Daimler Trucks



1,311,389

10,142,882



E-One





29,333



El Dorado





24,474



EVO Bus





1,625



Ferrara Fire





3,893



Ford Motor

2,277,561

1,057,001

10,854



General Motors

58,009

45,613





Gillig LLC



53

762,042

4,131

Hino Manufacturing



6,262

10



Hino Motors

5,395

50,869

1,491



Isuzu Motors

588,878

41,388





Kovatch Mobile





13,070



Mitsubishi Fuso

9,470





9,618

Motor Coach Ind.





121,267

2,046

Navistar, Inc.

7,881

1,360,471

2,958,796



New Flyer



124

133,220

448,463

Nikola





95,510



Oshkosh





84,313



PACCAR, Inc.

396

337,860

4,333,929

14,293

Rosenbauer Motors





4,365



Spartan Fire





6,049



Terex Corporation





7,862



Van Hool





153,806

1,013

Volvo Group



128,930

4,170,310

8,707

XOS Trucks



21



68,500

TOTALS

3,361,525

4,559,130

23,346,382

800,434


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Table 2

All Heavy-Duty CI Engines - Averaging Set Summary

GHG Credits (Mg C02) Banked Summary - Through Model Year 2021



LHD

MHD

HHD



Credit Balance

Credit Balance

Credit Balance

Manufacturer

Net C02

Net C02

Net C02

Cummins



3,695,252

1,858,808

Detroit Diesel



314,105

1,491,734

Ford Motor

706,665

-10,662



Fiat Powertrain

0





Isuzu Motors

18,472





Navistar

86,684

0

126,184

PACCAR





1,775,307

Volvo Group





0

TOTALS

811,821

3,998,695

5,252,033


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