Greenhouse Gas Emission Standards for 

Light-Duty Automobiles: 

Status of Early Credit Program for 

Model Years 2009-2011
NOTICE

This technical report does not necessarily represent final EPA decisions or 

positions. It is intended to present technical analysis of issues using data 

that are currently available. The purpose in the release of such reports is to 

facilitate the exchange of technical information and to inform the public of 

technical developments.

Compliance Division

Office of Transportation and Air Quality

U.S. Environmental Protection Agency

Greenhouse Gas Emission Standards for 

Light-Duty Automobiles: 

Status of Early Credit Program for 

Model Years 2009-2011

EPA-420-R-13-005

March 2013
i 

Executive Summary

On May 7, 2010, the Environmental Protection Agency (EPA) published a final regulation that 

laid out the first-ever national greenhouse gas (GHG) emissions standards under the Clean Air 

Act.1 The standards in this first regulation, which apply to light-duty vehicles, light-duty trucks, 

and medium-duty passenger vehicles, cover the 2012 through 2016 model years. Subsequently, 

on October 15, 2012, EPA published regulations that will require auto manufacturers to achieve 

additional GHG emissions reductions in the 2017 through 2025 model years.2 These rules were 

established jointly with the National Highway Traffic Safety Administration (NHTSA), which 

established parallel standards for Corporate Average Fuel Economy (CAFE). Collectively the 

EPA GHG standards and NHTSA CAFE standards are known as the National Program.

EPA’s GHG program, which will now progressively lower the average new vehicle GHG 

emissions in each model year from 2012 through 2025, includes a number of flexibilities 

designed to provide sufficient lead time for manufacturers to make technological improvements 

and to reduce the overall cost of the program, without compromising overall environmental 

objectives. One of these flexibilities is an optional program that allows manufacturers with 

superior greenhouse gas emission reduction performance to generate early credits in the 2009-

2011 model years. The early credits program provided a valuable incentive for manufacturers 

that have implemented GHG-reducing technologies in excess of either the CAFE or California 

GHG standards prior to the 2012 model year. These early credits represent surplus reductions 

that were not otherwise required by law, and will allow manufacturers to more effectively 

transition to the increasingly stringent GHG standards. EPA’s early credits program is also an 

important example of how the GHG and CAFE programs were aligned to achieve a coordinated 

National Program.3

Early credits may be earned through fleet average carbon dioxide (CO2) reductions, 

improvements to air conditioning systems that reduce refrigerant leakage or improve system 

efficiency, introduction of advanced technology vehicles (i.e., electric, fuel cell, and plug-in 

hybrid electric vehicles), and implementation of technologies that reduce CO2 emissions over 

driving conditions not captured by the test procedures used for compliance with the CO2

standards (i.e., “off-cycle” reductions). 

Manufacturers that chose to participate in the early credits program submitted documentation in 

early 2012, as required under the regulations. Seventeen manufacturers chose to participate in

one or more elements of the early credits program, reporting some 209 million metric tons of 

CO2 credits over the three model years covered by the program.4 Some companies qualified for 

the full range of types of early credits allowed, while others only reported fleet average based 

 

1 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final 

Rule, Federal Register 75 (7 May 2010): 25324-25728. 2 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy 

Standards, Final Rule, Federal Register 77 (15 October 2012): 62624-63200. 3 Under the CAFE program, manufacturers that have been outperforming the CAFE standards in the same time 

period will be approaching the increasingly stringent CAFE standards with credits accumulated in the same model 

years as the early GHG credits program. 

4 In this report, credits are expressed in the identical units of metric tons or Megagrams (Mg). 1,000,000 grams = 

1,000 kilograms = 1 Megagram = 1 metric ton. 
ii

credits or air conditioning credits. As expected, and consistent with the intent of the early credits 

program, sixteen manufacturers reported generating credits through fleet average reductions, 

which accounts for most of the early credits reported by the industry (180.2 million metric tons). 

Ten manufacturers reported credits resulting from improvements to the efficiency of air 

conditioning systems (8.1 million metric tons), and nine reported credits for air conditioning 

systems with low refrigerant leakage technology (20.8 million metric tons). One manufacturer 

provided details describing early off-cycle credits (5,632 metric tons). 

This report summarizes and explains the credits reported by each manufacturer in the 2009-2011 

model years, as well as explaining the options for earning and using early credits. This report is 

also intended to be used as a reference for users of the early credits data, which we are making 

available in formats appropriate for importing into spreadsheets or database applications.5 EPA 

is neither making any assumptions regarding the potential disposition of these 209 million metric

tons of early GHG credits nor attempting to speculate at this time on how manufacturers will 

choose to use these accumulated early credits over the applicable credit lifetimes. However, we 

believe that most manufacturers will be taking a long-term view by using their accumulated 

credits judiciously to plan a smooth pathway to the increasingly stringent GHG emission 

standards in the future. Table 1 shows the total early credits reported by the industry, broken 

down by the type of credit. 

A comprehensive description of the EPA GHG program is beyond the scope of this document, 

thus readers should consult the regulatory announcements and associated technical documents 

for a detailed description of the program. See http://www.epa.gov/otaq/climate/regs-lightduty.htm. 

TABLE 1. TOTAL REPORTED EARLY CREDITS, BY 

TYPE OF CREDIT

Credit Type Credits 

(Mg)

Percent of 

Total (%)

Fleet Average 180.179.993 86.15

A/C Leakage 20,834,078 9.96

A/C Efficiency 8,136,185 3.89

Off-Cycle 5,632 0.00

Total 209,155,888 100.00

 

5 This report and the data upon which it is based can be found and downloaded at http://www.epa.gov/otaq/regs/ldhwy/greenhouse/ld-ghg.htm.
1 

I. Introduction

A. Why are we releasing this information?

EPA is releasing this report as part of our commitment to provide the public with transparent and 

timely information about manufacturers’ compliance with the GHG program. In the two EPA 

regulations that established the greenhouse gas emissions standards for light-duty vehicles, we

committed to making certain information public regarding the compliance of automobile 

manufacturers with the program. At the same time, we committed to maintaining our practice of 

strongly safeguarding confidential business information, as required by regulation.6

When we issued the proposed rule for the 2012-2016 model year standards, we received 

considerable comment about the need for transparency regarding implementation of the program, 

and specifically, regarding our compliance determinations.7 Many comments emphasized the 

importance of making greenhouse gas compliance information publicly available to ensure such 

transparency. In the preamble to the final regulation, we noted that our public release of data 

could include “...GHG performance and compliance trends information, such as annual status of 

credit balances or debits, use of various credit programs, attained fleet average emission levels 

compared with standards, and final compliance status for a model year after credit reconciliation 

occurs.” We further noted that we would “...reassess data release needs and opportunities once 

the program is underway.”8

 

As was the case with the 2012-2016 model year rule, the proposal for 2017-2025 model year 

GHG standards received a number of comments again stressing the need for transparency in the 

implementation of the GHG standards.9 Our response in the final rule indicated our continued 

commitment to the principle of transparency and to disseminating as much information as we are 

reasonably, practically, and legally able to provide. 10 We noted that we already release a 

considerable amount of information regarding fuel economy, emissions, and vehicle 

characteristics for each vehicle model. For example, starting with the 2013 model year, the 

downloadable data available at www.fueleconomy.gov includes CO2 emission values for each 

vehicle model. In addition, actual test results are released by EPA at 

http://www.epa.gov/otaq/tcldata.htm. We also stated our commitment to further expanding the 

information we release regarding GHG program compliance, noting in the preamble to the model 

year 2017-2025 final rule that “...EPA intends to publish the applicable fleet average standards 

(for cars and for trucks) and the actual fleet performance for each manufacturer, and the resulting 

credits or debits.” Further, we stated that we anticipate publishing “...the amount of credits 

generated by each manufacturer (separately for each of the car and truck fleets) under the 

optional credit programs, and the associated volumes of vehicles to which those credits apply.” 

 

6 See 40 CFR Part 2, Subpart B, Confidentiality of Business Information.

7 Proposed Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate 

Average Fuel Economy Standards, Proposed Rule, Federal Register 74 (28 September 2009): 49454-49789. 8 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final 

Rule, Federal Register 75 (7 May 2010): 25469. 9 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy 

Standards, Proposed Rule, Federal Register 76 (1 December 2011): 74854-75420. 10 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel 

Economy Standards, Final Rule, Federal Register 77 (15 October 2012): 62889.
2 

We also suggested that we would likely publish credit transactions, as well as the overall credit 

or debit balance for each manufacturer after taking into account the credit and debit carryforward provisions and any credit transactions. 

Finally, we noted in the model year 2017-2025 final rule preamble that our first public release 

would likely be a summary of the 2009-2011 early credits reported by manufacturers. 

Subsequent reports will likely be more comprehensive because all manufacturers are required to 

submit data and compliance requirements begin to take effect. We expect that our data 

publication will evolve over time, as the program progresses and as we gather feedback about 

our reporting from stakeholders, and as our data systems and those of manufacturers make 

necessary adaptations to the new requirements. Manufacturers must submit final compliance 

reports regarding the 2012 model year in March of 2013. Later in 2013, after we complete a 

thorough review of the documentation and calculations received from manufacturers, we expect 

to publish data for the 2012 model year. 

B. What data are we publishing?

The EPA GHG program, which requires compliance with progressively more stringent GHG 

standards starting with the 2012 model year and concluding with the 2025 model year, includes 

certain flexibilities designed to provide sufficient lead time for manufacturers to make 

technological improvements and to reduce the overall cost of the program, without 

compromising overall environmental objectives. One of these flexibilities is an optional program 

that allowed manufacturers with superior greenhouse gas emission reduction performance to 

generate credits in the 2009-2011 model years, prior to the 2012 model year (the “early credits 

program”). Because this is an optional program, without any compliance implications in these 

early model years, only those manufacturers who achieved emissions performance beyond that 

required by existing California or CAFE standards chose to provide data; thus the data does not 

include information for all manufacturers. The first opportunity to review data from all 

manufacturers will be later in the 2013 calendar year, when we receive compliance reports for 

the 2012 model year. While there are factors that could lead to revisions to the early credits data

(e.g., future credit transactions between manufacturers), the data presented in this report is 

believed to be stable as of the date of publication. Any changes, should they occur, will be 

reflected in updates to the downloadable data and in subsequent EPA reports. 

This report will give a broad overview of the optional early credits program to facilitate an 

understanding of the early credits data that we are releasing. However, the early credits program

is complex, with many regulatory nuances, and readers are encouraged to consult the regulations 

for detailed and specific information.11 

Early credits may be earned through fleet average CO2 reductions, improvements to air 

conditioning systems that reduce refrigerant leakage or improve system efficiency, off-cycle 

credits for the implementation of technologies that reduce CO2 emissions over driving conditions 

not captured by the test procedures used to show compliance with the CO2 standards, and 

introduction of advanced technology vehicles (i.e., electric, fuel cell, and plug-in hybrid electric 

 

11 See 40 CFR 86.1871-12. 
3 

vehicles). The most complex aspect of the optional early credits program is the multiplicity of 

“pathways” that a manufacturer may select to earn credits based on their corporate fleet average 

tailpipe CO2 emissions performance. The program has four pathways that provide opportunities 

for early credit generation through over-compliance with a fleet average CO2 level specified by 

EPA in the regulations. Since EPA’s GHG standards do not begin until model year 2012, EPA 

established fleet average thresholds below which manufacturers could generate early fleet 

average credits. Manufacturers wishing to earn early credits must select one of these four 

pathways, and the selected pathway must be followed for the three model years of 2009-2011. 

For two of the pathways, the emission levels below which credits are available are equivalent to 

the GHG standards established by California prior to the adoption of the EPA GHG program. 

Two additional pathways include credits based on over-compliance with CO2 levels equivalent to 

the CAFE standards in states that did not adopt the California GHG standards. These four 

pathways are described in more detail in section II.12 

C. How many early credits were reported? 

Table 2 summarizes the credits (or deficits) reported by manufacturers in each of the three model 

years for each participating manufacturer. Credits are expressed in units of metric tons, or 

Megagrams (Mg). The early credits program requires that participating manufacturers determine 

fleet average credits for each of the three model years under their selected pathway, and that they 

may carry forward their net credits from the three early years to apply to compliance with EPA’s 

GHG standards. Thus, even manufacturers with a deficit in one or more of the early model years, 

(i.e., their fleet average performance was worse than the applicable emissions threshold under the 

selected pathway) could benefit from the early credits program if their net credits over the three 

years is a positive value. Manufacturers not listed in Table 1 have thus far elected not to

participate in the early credits program. Due to the ongoing investigation of the emissions and 

fuel economy testing methods of Hyundai and Kia, the outcome of which could impact the 

credits accrued by these companies, credit values for Hyundai and Kia are not being reported. 

They will appear in future reports after the conclusion of the investigation. 

 

12 The California GHG standards and CAFE MPG standards included provisions for model years 2009-2011 

allowing credits to be carried forward to later model years. By adopting early credit provisions under the GHG 

program, EPA maintained some level of consistency with these pre-existing programs.
4 

TABLE 2. EARLY GHG CREDITS REPORTED BY MODEL YEAR AND 

MANUFACTURER (MG) 

Manufacturer

Model Year

2009 2010 2011 Total 

BMW 409,854 280,450 194,599 884,903

Chrysler 5,583,013 4,337,613 (2,129,654) 7,790,972

Daimler 96,467 124,120 157,685 378,272

Ford 8,252,113 7,093,702 (49,379) 15,296,436

GM 13,009,374 11,073,134 493,068 24,575,576

Honda 14,073,890 14,070,290 7,370,928 35,515,108

Mazda 1,405,721 3,201,708 875,213 5,482,642

Mitsubishi 625,166 521,776 302,394 1,449,336

Nissan 10,496,712 5,781,739 1,852,749 18,131,200

Subaru 1,620,769 2,225,296 1,909,106 5,755,171

Suzuki 448,408 329,382 98,860 876,650

Tesla 35,580 14,192 49,772

Toyota 31,325,738 34,457,797 20,322,300 86,105,835

Volkswagen 2,243,205 2,811,663 1,386,537 6,441,405

Volvo 119,583 237,398 65,629 422,610

Industry Total 89,710,013 86,581,648 32,864,227 209,155,888 

D. How can these credits be used?

The ability to earn and bank credits, including early credits, is a fundamental aspect of the 

program design intended to assist manufacturers in meeting the 2012-2016 model year standards, 

as well as to aid in the transition to the progressively more stringent standards in the 2017-2025 

model years. In establishing the early credits program, EPA wanted to maintain consistency with 

the ability to generate and carry forward credits under both the CAFE standards and the 

California standards for the 2009-2011 model years. These credits represent surplus emission 

reductions that manufacturers achieved in addition to those required by law under either the 

California or CAFE standards. The early credits program gives manufacturers additional 

flexibility to transition into the 2012 and later GHG standards with a bank of credits available. 

Credit banking, as well as emissions averaging and credit trading (collectively termed 

Averaging, Banking, and Trading, or “ABT”) have been an important part of many mobile 

source programs under the Clean Air Act. These programs help manufacturers in planning and 

implementing the orderly phase-in of emissions control technology in their production, 

consistent with their typical redesign schedules. These provisions are an integral part of the 

standard-setting itself, and not just an add-on to help reduce costs. In many cases, ABT programs 

address issues of cost or technical feasibility which might otherwise arise, allowing EPA to set a 

standard that is more stringent than could be achieved without the flexibility provided by ABT 

programs. We believe that the net effect of the ABT provisions, including the early credits, 
5 

allows additional flexibility, encourages earlier penetration of emission reduction technologies 

than might otherwise occur, and does so without reducing the overall effectiveness of the 

program. 

Credits (or deficits) are calculated separately for cars and trucks. If a manufacturer has a net 

deficit in either the car or truck category, existing credits must be applied towards that deficit. 

Although a deficit may be carried forward up to three years, under no circumstances is a 

manufacturer allowed to carry forward a deficit if they have credits available with which to 

offset the deficit. If credits remain after addressing any deficits, those credits may be “banked” 

for use in a future year, or sold or otherwise transferred to another manufacturer. Credits earned 

in the 2010 through 2016 model years may be carried forward and used through the 2021 model 

year. Credits from the 2009 model year and 2017 and later model years may only be carried 

forward for five years. Thus, any early credits from the 2009 model year that remain after the 

2014 model year will expire. In addition, credits from the 2009 model year may only be used 

within a manufacturer’s fleet, and may not be traded to another manufacturer. These restrictions 

for the 2009 model year were established based on concerns that such credits might provide a 

“windfall” since the California light truck standards are less stringent than the comparable CAFE 

standards in effect for that model year.

At this point it is difficult to make any assumptions regarding the disposition of these 209 million 

tons of reported early GHG credits. One could create any number of hypothetical scenarios that 

show these credits being used in a variety of ways (e.g., across the industry, within a single 

company, across all model years of the program, within a single model year, within or between 

car and truck fleets, etc.). EPA is not attempting to speculate at this time on how manufacturers 

will choose to use these reported credits over the applicable credit lifetimes. However, we 

continue to believe that most manufacturers will be taking a long-term view of the increasingly 

stringent standards in the future and will use their accumulated credits judiciously to plan a 

smooth pathway to the low emissions required through the 2025 model year. We do not expect 

manufacturers to use these credits injudiciously, e.g., to make short-term adjustments to shift 

their fleet to less efficient vehicles or to broadly delay the introduction of technologies, as doing 

so could jeopardize long-term compliance and increase the risk of facing future enforcement 

actions. We plan to make data on the use of credits, including credit trades among manufacturers, 

available in future credit reports. 

However, one easy translation to make is to determine what a given exceedance of an emission 

standard “costs” in terms of tons of credits. The calculation of fleet average credits (described in 

more detail in the next section) is the same for cars and trucks with the exception that the 

expected lifetime mileage (vehicle miles traveled, or VMT) differs between cars and trucks. 

Because trucks are assumed to have a greater lifetime VMT (225,865 miles) than cars (195,264 

miles), a given gram per mile of “non-compliance” in a truck fleet will require more credits (in 

tons) to offset. Given these VMT differences, one car that is one gram per mile above the 

standard will cost 0.195 metric tons of credits to offset, and similarly, for a single truck that is 

one gram non-compliant the cost is 0.226 metric tons. For rough calculations, however, it makes 

sense to assume that for cars and trucks, one gram per mile costs about 0.2 metric tons to offset 

(or 5 grams per mile non-compliance costs about 1 metric ton). For example, a manufacturer 

with a fleet average that is 5 grams/mile above its fleet average standard and that produced 1 
6 

million vehicles in that model year will need about one million metric tons of credit to offset the 

deficit created by the noncompliant fleet. 

II. Credits Based on Early Fleet Average CO2 Reductions

Fleet average GHG credits are based on the difference between the applicable emission standard 

and the actual fleet performance (in grams per mile), the expected lifetime miles (vehicle miles 

traveled, or VMT) of a vehicle, and the total vehicle production volume. The VMT used in this 

calculation for passenger cars is 195,264 miles, and for trucks is 225,865 miles. The equation 

that generates the metric tons (or Megagrams, Mg) of credits for a given fleet is as follows:

Credits (metric tons) = (Standard − Fleet Average) × VMT × Production Volume

1,000,000

As described earlier, there are four distinct pathways that manufacturers may select from to earn 

early fleet average credits, two of which base credits on the effective California standards, and 

the remaining two which include credits based on compliance with the CAFE standards in states 

that have not adopted the California standards. Table 3 summarizes the credits reported by 

manufacturers under each of the four available pathways. Because these pathways imply slightly 

different data and information reporting, we are summarizing the fleet average credits separately 

according to the selected pathway. Readers should refer to the Appendix and to the 

downloadable data for the complete detailed values underlying the fleet average credits, such as 

the applicable emission credit threshold levels and the manufacturer’s reported fleet average 

performance. Manufacturers reported a total of 180,179,993 metric tons of CO2, or 86% of all 

the early reported credits, based on fleet average CO2 emission reductions (see Table 1). Because 

these manufacturers were known to be outperforming either the California or CAFE standards in 

the 2009-2011 model years, EPA anticipated that these manufacturers would generate early 

credits, and, in some cases, substantial numbers of credits. Although the fleet targets under each 

pathway differ slightly, note that they increase in stringency rapidly. See, for example, Table 4, 

which shows a reduction in the fleet targets of 56 grams/mile for cars and 49 grams/mile for 

trucks from 2009 to 2011. Most manufacturers exhibit a substantial drop in credit accumulation 

from 2009 to 2011 (in some cases transitioning to generating a deficit rather than credits), 

indicating that the technological progress of these manufacturers, over these model years, was 

being outpaced by the stringency of the emission targets. We expect that this trend will continue 

for several model years, and that these companies will use the early credits as they bring new 

technologies on line to meet the tight emission standards of future model years. For those 

companies with the greatest number of credits, the concerns regarding the potential for 

“windfall” credits from the 2009 model year are mitigated by the fact that those credits will 

likely expire before those companies can make use of them (and no other company may benefit, 

because those credits may not be traded). 
7 

TABLE 3. REPORTED EARLY FLEET AVERAGE CREDITS, BY EARLY 

CREDIT PATHWAY

Pathway Credits (Mg) Percent of Total (%)

1 134,258,207 74.51

2 0 0.00

3 45,547,983 25.28

4 373,803 0.21

Total 180,179,993 100.00

A. Credits Reported By Manufacturers Using Pathway 1

Pathway 1 requires that credits be measured over the manufacturer’s nationwide fleet, with 

credits based on fleet performance relative to the California standards in effect at the time. The 

California standards effective in the 2009-2011 model years are not based on footprint, but are 

“flat” universal standards that all manufacturers were required to meet. Also note that under this 

pathway the vehicle categories subject to the thresholds in Table 4 are those defined in the 

California regulations. These categories are subtly different from those used in the EPA GHG 

program in the 2012 and later model years; readers should refer to the California and EPA GHG 

program regulations for the precise definitions.13

The ten manufacturers selecting Pathway 1 reported generating credits against the Californiaequivalent emission standards shown in Table 4. 

 

13 For EPA definitions, see the Code of Federal Regulations, 40 CFR 86.1803-01. For California definitions, see the 

California Code of Regulations, 13 CCR 1900. 
8 

TABLE 4. CALIFORNIA EQUIVALENT EMISSION STANDARDS BY MODEL YEAR AND 

VEHICLE CATEGORY (GRAMS/MILE) 

Model year Passenger cars and light trucks 

with LVW1 of 0–3,750 lbs

Light trucks with LVW1

>3,750 lbs and a GVWR2 up 

to 8,500 lbs, and MDPVs3

2009 323 439

2010 301 420

2011 267 390

1 LVW is “loaded vehicle weight,” defined by regulation as the measured curb weight of the vehicle 

plus 300 lbs. 

2

GVWR is “gross vehicle weight rating,” which is the maximum load capacity specified by the 

manufacturer. 

3

MDPV is “medium-duty passenger vehicle,” a category that covers passenger vehicles from 8,500-

10,000 lbs GVWR (i.e., sport utility vehicles and vans). 

Table 5 shows the early fleet average credits reported by manufacturers using Pathway 1. As can 

be seen, all of these manufacturers reported net credits over the three model years (this is by 

definition; if they could not earn net credits under this pathway they would either select a 

different pathway or not participate in the early credits program), despite some reporting a deficit 

in some model years and vehicle categories. Note that because of concerns expressed by some 

stakeholders during the regulatory process that there may be a potential for a large number of 

credits under Pathway 1 in the 2009 model year, the regulations included two restrictions. First, 

2009 model year credits earned under this pathway may not be sold to another manufacturer, and 

second, these credits may be carried forward only five years, to the 2014 model year, after which 

they expire. As noted earlier, credits from 2010 and 2011 may be carried forward to the 2021 

model year. 
9 

TABLE 5. EARLY FLEET AVERAGE CREDITS REPORTED BY MANUFACTURERS USING PATHWAY 1

Model Year

2009 2010 2011

Manufacturer Fleet Production

Volume

Credits

(Mg)

Productio

n Volume

Credits

(Mg)

Productio

n Volume Credits (Mg)

Chrysler

Car 287,364 224,447 430,110 (1,259,775) 335,790 (2,753,843)

Truck 528,286 4,414,889 729,662 4,284,933 739,487 (1,002,145)

Ford

Car 508,727 2,384,066 856,065 2,005,904 792,654 (2,476,429)

Truck 504,921 4,789,847 965,968 3,054,497 873,635 591,971 

GM

Car 1,048,593 5,733,069 857,825 502,507 1,006,900 (5,701,728)

Truck 844,892 4,961,620 932,358 8,002,308 1,419,043 2,564,097 

Nissan

Car 605,439 6,502,124 617,548 4,220,471 666,660 781,048 

Truck 234,883 3,554,474 236,588 1,122,176 299,074 540,403 

Subaru

Car 156,871 459,469 183,763 71,765 176,923 (967,307) 

Truck 43,945 1,161,300 74,489 2,153,531 129,950 2,876,413

Suzuki

Car 24,859 232,995 20,212 165,760 19,390 18,931

Truck 10,146 215,413 8,728 163,622 7,864 79,929

Tesla Car 599 35,206 269 14,024 

Toyota

Car 1,273,815 19,400,957 1,412,172 20,129,484 1,140,255 5,343,618 

Truck 482,202 10,237,780 793,226 12,003,853 834,019 12,997,923 

Volvo

Car 31,618 37,043 23,529 (73,510) 24,846 (160,100)

Truck 11,420 82,540 34,413 310,908 27,761 225,729 

Total 6,597,981 64,392,033 8,177,255 56,893,640 8,494,520 12,972,534

B. Credits Reported By Manufacturers Using Pathway 2

Pathway 2 is identical to Pathway 1 with the exception that the credits are calculated not for a 

nationwide fleet, but for the manufacturer’s fleet only in California and the states that have 

adopted the California standards under Section 177 of the Clean Air Act (these states are referred 

to as the “Section 177 states”).14 Pathway 2 was not used by any manufacturer, presumably 

because manufacturers that were able to meet the California standards in California and the 

Section 177 states found that they could also earn credits in the remainder of the states. In other 

words, no manufacturer found an advantage to excluding the states outside California and the 

Section 177 states from their credit calculations. 

 

14 As of the date the regulation was finalized, there were thirteen states that had adopted the California greenhouse 

gas emission standards: Arizona, Connecticut, Maine, Maryland, Massachusetts, New Jersey, New Mexico, New 

York, Oregon, Pennsylvania, Rhode Island, Vermont, Washington, and Washington, DC.
10

C. Credits Reported By Manufacturers Using Pathway 3

Pathway 3 allows manufacturers to earn credits as under Pathway 2 (the California standards 

applied to the fleet of vehicles in California and the Section 177 states), plus additional credits 

that may be earned in the remaining states against threshold levels that are based on a translation 

of the CAFE MPG standards to GHG grams per mile threshold levels. The emission threshold 

levels used for generating credits in the states outside California and the Section 177 states under 

Pathway 3 are shown in Table 6 below. 

TABLE 6. CAFE-EQUIVALENT EMISSION STANDARDS BY MODEL YEAR AND 

VEHICLE CATEGORY (GRAMS/MILE) 

Model year Passenger Automobiles Light Trucks

2009 323 381*

2010 323 376*

2011 Footprint-based standard Footprint-based standard

*Manufacturers that optionally used a footprint-based standard must use that standard.

These threshold levels are based on the CAFE standards that were in effect in the 2009-2011 

model years. In the 2009 and 2010 model years manufacturers could optionally calculate a 

manufacturer-specific CAFE standard for their light truck fleet, and starting in the 2011 model 

year, footprint-based CAFE standards became mandatory both for cars and trucks. Thus, for the 

purposes of generating early light truck credits, manufacturers using the footprint-based option in 

the 2009 and 2010 model years must determine a manufacturer-specific, footprint-based CO2

threshold level to use in lieu of the numerical values shown in the table above. In the 2011 

model year the early credits must be generated using a footprint-based CO2 threshold level. The 

specific emission levels actually used and reported by each manufacturer are included in the 

detailed table in the Appendix and in the downloadable data. Credits are generated under this 

pathway using the car and truck definitions that apply to the CAFE program that are in place for 

the model year in which credits are being generated. This adds an additional layer of complexity 

for two reasons: (1) these definitions were revised by NHTSA such that they change starting in 

the 2011 model year, and (2) medium-duty passenger vehicles (MDPVs) are not part of the 

CAFE program until the 2011 model year, and therefore are not part of the early credits 

calculations for 2009 and 2010 under Pathway 3. 

Table 7 shows the credits reported by the five manufacturers that used Pathway 3. The credits are 

shown for each vehicle category within each of the separate regions required under this pathway. 

The credits reported in the 2009 model year are subject to the same restrictions as under Pathway 

1, i.e., they may not be sold and they have a limited life relative to the 2010 and 2011 credits. 
11

TABLE 7. EARLY FLEET AVERAGE CREDITS REPORTED BY MANUFACTURERS USING PATHWAY 3

Model Year

2009 2010 2011

Manufacturer Region Fleet

Production

Volume

Credits

(Mg)

Production

Volume

Credits

(Mg)

Production

Volume

Credits

(Mg)

Honda

NC Car 433,183 5,582,613 414,562 5,828,330 317,065 2,290,721

Truck 232,149 2,202,242 290,216 3,080,833 280,042 569,265

CA/177 Car 388,318 4,321,998 429,692 3,272,232 247,437 821,364

Truck 89,079 1,327,909 95,106 1,159,980 244,121 3,032,611

Mazda

NC Car 61,283 514,554 133,292 1,561,628 112,883 506,966

Truck 35,084 412,061 64,558 685,325 18,435 (49,966)

CA/177 Car 40,884 335,293 86,948 611,201 59,856 128,565

Truck 10,612 143,813 25,351 343,554 25,145 289,648

Mitsubishi

NC Car 60,347 341,724 30,144 270,758 49,447 212,415

Truck 8,573 114,244 14,832 177,552 15,159 34,239

CA/177 Car 23,293 150,093 15,733 39,937 25,408 0 

Truck 872 19,105 2,699 33,529 7,712 55,740

Volkswagen

NC Car 139,498 898,885 143,295 1,371,037 151,373 650,269

Truck 21,078 85,694 23,488 106,102 35,176 79,450

CA/177 Car 118,411 693,642 134,231 629,052 121,114 (141,895)

Truck 13,295 171,164 19,350 257,859 25,667 324,648

Grand Total 1,675,959 17,315,034 1,923,497 19,428,909 1,736,040 8,804,040

Notes: CA/177 = The region comprised of California and the Section 177 states. NC = The region comprised of the states 

outside California and the Section 177 states. 

D. Credits Reported By Manufacturers Using Pathway 4

Pathway 4, which was used by only one manufacturer, is for manufacturers choosing to forego 

California-based credits entirely and earn only CAFE-based credits outside California and the 

Section 177 states. Credits are earned under this pathway against the thresholds described in 

Table 6 and the previous section. Table 8 shows the early credits reported by BMW, the sole 

manufacturer that chose to use Pathway 4. 
12

TABLE 8. EARLY FLEET AVERAGE CREDITS REPORTED BY MANUFACTURERS USING PATHWAY 4

Model Year

2009 2010 2011

Manufacturer Fleet Production 

Volume

Credits 

(Mg)

Production 

Volume

Credits 

(Mg)

Production 

Volume Credits (Mg)

BMW

Car 95,270 316,248 72,225 197,441 153,966 (30,064)

Truck 16,978 (49,852) 13,612 (24,596) 31,323 (35,374)

Total 112,248 266,396 85,837 172,845 185,289 (65,438)

III. Credits Based on Improvements to Air Conditioning Systems

Over 95% of the new cars and light trucks in the United States are equipped with air 

conditioning (A/C) systems. There are two mechanisms by which A/C systems contribute to the 

emissions of greenhouse gases: through leakage of hydrofluorocarbon refrigerants into the 

atmosphere (sometimes called “direct emissions”) and through the consumption of fuel to 

provide mechanical power to the A/C system (sometimes called “indirect emissions”). The high 

global warming potential of the current automotive refrigerant means that leakage of a small 

amount of refrigerant will have a far greater global warming impact than emissions of a similar 

amount of CO2. Refrigerant leakage can be reduced significantly by systems that incorporate 

leak-tight components, or, ultimately, by using a refrigerant with a lower global warming 

potential. The A/C system also contributes to increased tailpipe CO2 emissions through the 

additional work required to operate the compressor, fans, and blowers. This additional power 

demand is ultimately met by using additional fuel, which is converted into CO2 by the engine 

during combustion and exhausted through the tailpipe. These emissions can be reduced by 

increasing the overall efficiency of an A/C system, thus reducing the additional load on the 

engine from A/C operation, which in turn means a reduction in fuel consumption and a 

commensurate reduction in GHG emissions. 

Manufacturers may generate and use credits for improved A/C systems in complying with the 

CO2 fleet average standards taking effect in the 2012 model year (or otherwise to be able to bank 

or trade the credits). These provisions may be used in the 2009-2011 model years to generate 

early credits, prior to the 2012 model year. We expect that most manufacturers will choose to use 

the A/C credit provisions as part of their compliance demonstration. Ten manufacturers were 

able to claim credits for A/C systems that either reduce refrigerant leakage or reduce GHG 

exhaust emissions. Although the quantity of A/C credits is small relative to the fleet average 

credits reported by manufacturers, EPA is encouraged by the use of these credit provisions and 

takes it as an indication that manufacturers are exploring a full range of options for reducing 

GHG emissions. The A/C provisions are structured as credits, unlike the CO2 standards for 

which manufacturers will demonstrate compliance using the EPA test procedures. Those tests do 

not measure either A/C refrigerant leakage or the increase in tailpipe CO2 emissions attributable 

to the additional engine load of A/C systems. Because it is optional to include A/C-related GHG 

emission reductions as an input to a manufacturer’s compliance demonstration, the A/C 

provisions are viewed as an additional program that credits manufacturers for implementing A/C 
13

technologies that result in real-world reductions in GHG emissions. A summary of the air 

conditioning credits reported by the industry is shown in Table 9. 

TABLE 9. REPORTED EARLY AIR CONDITIONING CREDITS, BY TYPE AND 

MODEL YEAR (MG) 

Type 2009 2010 2011 Grand Total

A/C Efficiency 2,036,470 2,695,786 3,403,929 8,136,185 

A/C Leakage 5,696,751 7,389,503 7,747,824 20,834,078 

Total 7,733,221 10,085,289 11,151,753 28,970,263 

A. Reported Credits From Reduced A/C Refrigerant Leakage

A manufacturer choosing to generate A/C leakage credits with a specific A/C system is required 

to calculate a leakage “score” for the A/C system. This score is based on the number, quality, and 

technology of the components, fittings, seals, and hoses of the A/C system. This score, which is 

determined in grams per year, is calculated using the procedures specified by the Society of 

Automotive Engineers Surface Vehicle Standard J2727. It is subsequently converted to a 

grams/mile credit value for consistency with the units of GHG exhaust emissions. The 

grams/mile value is used to calculate the total tons of credits attributable to an A/C system by 

accounting for the global warming potential (GWP) of the refrigerant, the VMT of the vehicle 

class (car or truck), and the production volume of the A/C system. Note that while A/C leakage 

credits can also be based on transitioning to systems that use refrigerants with a lower GWP, the 

use of the conventional hydrofluorocarbon refrigerant (HFC-R134a) was universal in the model 

years covered by these early credits. Thus, these credits are based entirely on improvements to 

the physical systems that contain and move the refrigerant through the A/C system. 

Nine manufacturers participated in the early A/C credits program based on reducing refrigerant 

leakage, as shown in Table 10. These manufacturers reported a total of 20,834,078 metric tons of 

CO2 credits over the three model years, or about 10% of the total early credits reported by the 

industry (see Tables 1 and 9). 
14

TABLE 10. EARLY CREDITS REPORTED EARNED FROM LOW-LEAK AIR CONDITIONING 

SYSTEMS

Model Year

2009 2010 2011

Manufacturer Fleet

Production 

Volume

Credits 

(Mg)

Production 

Volume

Credits 

(Mg)

Production 

Volume

Credits 

(Mg)

BMW

Car 95,270 47,490 72,225 34,939 153,966 80,174

Truck 16,978 17,334 13,612 13,670 31,323 35,952

Chrysler

Car 287,364 237,143 430,110 352,786 335,790 340,299

Truck 528,286 551,632 729,662 740,466 739,487 843,506

Daimler

Car 57,812 31,408 59,736 30,856 71,711 41,110

Truck 20,035 18,297 33,642 32,334 33,670 16,851

Ford

Car 421,306 247,818 713,574 387,819 832,559 476,473

Truck 553,174 830,382 1,085,059 1,623,677 833,730 1,279,698

GM

Car 954,239 792,488 786,528 716,959 658,994 1,340,422

Truck 729,189 1,393,043 644,464 1,487,242 1,089,891 1,648,173

Honda

Car 802,442 246,771 836,304 277,048 563,002 142,831

Truck 321,228 176,484 385,322 226,311 524,163 283,673

Nissan

Car 143,263 20,466 167,243 16,755 248,209 44,656

Truck 220,896 100,005 214,294 109,905 251,623 135,259

Toyota

Car 1,264,617 507,913 1,402,166 583,900 1,090,293 532,137

Truck 363,547 343,961 648,233 598,764 814,743 343,787

Volkswagen

Car 266,152 110,126 284,037 120,055 268,550 109,887

Truck 26,130 23,990 36,327 36,017 64,780 52,936

Grand Total 7,071,928 5,696,751 8,542,538 7,389,503 8,606,484 7,747,824

B. Reported Credits From Improved A/C System Efficiency

Manufacturers that make improvements in their air conditioning systems to increase efficiency, 

and thus reduce CO2 emissions due to air conditioning system operation, may be eligible for air 

conditioning efficiency credits. Most of the additional load on the engine from air conditioning 

systems comes from the compressor, which pumps the refrigerant around the system loop. A 

significant additional load on the engine may also come from electric or hydraulic fans, which 

are used to move air across the condenser, and from the electric blower, which is used to move 

air across the evaporator and into the cabin. Manufacturers have several currently-existing 

technology options for improving efficiency, including more efficient compressors, fans, and 

motors, and system controls that avoid over-chilling the air (and subsequently re-heating it to 

provide the desired air temperature with an associated loss of efficiency). For vehicles equipped 

with automatic climate-control systems, real-time adjustment of several aspects of the overall 

system (such as engaging the full capacity of the cooling system only when it is needed, and 
15

maximizing the use of recirculated air) can result in improved efficiency. The regulations 

provide manufacturers with a “menu” of technologies and associated credit values (in grams/mile 

of CO2). The total tons of credits are then based on the total volume of vehicles in a model year 

using these technologies. 

Ten manufacturers used the provisions that allow early credits based on improvements to the 

overall efficiency of the A/C system, as shown in Table 11. These manufacturers reported a total 

of 8,136,185 metric tons of CO2 credits over the three model years, or almost 4% of the total 

early credits reported by the industry (see Tables 1 and 9). 

TABLE 11. EARLY CREDITS REPORTED EARNED BY IMPROVING THE EFFICIENCY OF AIR 

CONDITIONING SYSTEMS

Model Year

2009 2010 2011

Manufacturer Fleet

Production 

Volume

Credits 

(Mg)

Production 

Volume

Credits 

(Mg)

Production 

Volume

Credits 

(Mg)

BMW

Car 95,270 62,528 72,225 46,231 153,966 113,483

Truck 16,978 16,106 13,612 12,765 31,323 30,428

Chrysler

Car 171,522 68,074 258,478 107,553 335,790 118,345

Truck 435,791 86,828 579,480 111,650 739,487 324,184

Daimler

Car 53,062 30,018 62,638 35,122 69,772 71,586

Truck 20,035 16,744 33,642 25,808 33,670 28,138

Ford

Car 0 0 34,076 15,304 57,499 14,415

Truck 0 0 12,516 6,501 464,707 64,493

GM

Car 838,289 113,142 597,220 99,629 542,683 310,606

Truck 87,771 12,683 620,030 263,524 1,043,792 330,160

Honda

Car 466,518 161,988 481,676 177,222 331,756 119,152

Truck 140,335 53,885 125,879 48,334 342,934 111,311

Nissan

Car 605,439 225,310 617,548 231,360 666,660 248,584

Truck 234,883 94,333 236,588 81,072 299,074 102,799

Tesla Car 0 0 599 374 269 168

Toyota

Car 1,273,815 639,927 1,412,172 768,652 1,140,255 621,412

Truck 482,160 195,200 793,187 373,144 834,019 483,423

Volkswagen

Car 266,152 231,296 284,037 249,431 268,550 239,277

Truck 26,130 28,408 36,327 42,110 64,780 71,965

Grand Total 5,214,150 2,036,470 6,271,930 2,695,786 7,420,986 3,403,929
16

IV. Credits Based on Off-Cycle Emission Reductions

General Motors requested, and was subsequently granted, off-cycle credits for a technology used 

on certain gasoline-electric hybrid vehicles. The off-cycle credits reported by General Motors are 

shown in Table 12. The technology is an auxiliary electric pump which keeps engine coolant 

circulating in cold weather while the vehicle is stopped and the engine is off. These hybrid 

vehicles feature engine stop/start capability for improved fuel economy, and as a result the 

engine can frequently be turned off when the vehicle is stopped, such as at a traffic light. 

However, during cold weather, a hybrid vehicle without the auxiliary heater pump would need to 

keep the engine idling during the stop periods solely to maintain coolant flow to the heater to 

maintain a comfortable temperature inside the vehicle. This would reduce the fuel economy 

benefits of the stop/start feature during cold weather, which is an “off-cycle” temperature 

condition not captured by the greenhouse gas test methods. Note that starting with the 2014 

model year, the regulations provide a “menu” of off-cycle technologies and associated credits for 

each technology. Manufacturers implementing engine idle stop/start technologies may receive 

off-cycle credits for those technologies, and the addition of an auxiliary heat pump (or system 

that achieves the same result) to these vehicles will gain additional off-cycle credits.

Manufacturers may also seek additional off-cycle credits for technologies not listed on the menu 

based on data and analyses submitted to EPA for approval. 

TABLE 12. EARLY CREDITS REPORTED EARNED BY OFF-CYCLE EMISSION REDUCTIONS

2009 2010 2011

Manufacturer Fleet

Production 

Volume

Credits 

(Mg)

Production 

Volume

Credits 

(Mg)

Production 

Volume

Credits 

(Mg)

GM Truck 8,671 3,329 2,512 965 3,484 1,338 

Grand Total 8,671 3,329 2,512 965 3,484 1,338 

V. Early Advanced Technology Vehicle Incentives

The GHG regulations include provisions that provide a temporary regulatory incentive for the 

commercialization of certain advanced vehicle power trains — electric vehicles (EVs), plug-in 

hybrid electric vehicles (PHEVs), and fuel cell vehicles (FCVs). The purpose of these provisions 

is to provide a temporary incentive to promote technologies which have the potential to produce 

very large GHG reductions in the future, but which face major challenges, such as vehicle cost,

consumer acceptance, and the development of low-GHG fuel production infrastructure. These 

incentives may also be used by manufacturers that introduce these advanced technologies in the 

2009-2011 model years. 

There are two ways manufacturers can treat advanced technology vehicles that are introduced in 

the 2009-2011 model years. First, until specific production volume thresholds are reached, the 

GHG emissions of EVs and FCVs will be considered for compliance purposes to be zero, as will 

the GHG emissions of PHEVs for the portion of operation that uses electricity from the grid. 

After those production thresholds are met, these vehicles will be required to account for their net 
17

“upstream” emissions relative to a conventional gasoline vehicle.15 We acknowledge, based on 

current electricity and hydrogen production processes, that EVs, PHEVs, and FCVs yield higher 

upstream GHG emissions than comparable gasoline vehicles. But we support temporarily 

rewarding advanced emissions control technologies by foregoing modest emissions reductions in 

the short term in order to lay the foundation for the potential for much larger emission reductions 

in the longer term. EVs, PHEVs, and FCVs are potential GHG “game changers” if major cost 

and consumer barriers can be overcome and if there is a nationwide transformation to low- GHG 

electricity (or hydrogen, in the case of FCVs). Second, manufacturers have the option of not 

including these vehicles in their calculation of fleet average credits in the 2009-2011 model 

years, but instead “deferring” the use of these vehicles and their associated compliance values to 

the 2012 or later model years. Manufacturers using this option must maintain records of the 

volume of these vehicles and their GHG emission levels and ensure that these vehicles are not 

included in their fleet average credit calculations using one of the four fleet average credit 

pathways. 

Two manufacturers chose the “deferral” option, electing to not include some 2011 model year 

advanced technology vehicles in their 2009-2011 fleet average credits. Other manufacturers with 

advanced technology vehicles chose to include those vehicles in their fleet average credits. 

Because there is no emission standard that applies to these vehicles until these manufacturers 

elect to “use” these vehicles in compliance calculations for a future model year, there are no 

associated tons of credits to report at this time. Thus we are only able to report the volume of 

these vehicles and the emission values (as reported to us by these two manufacturers) that 

manufacturers have elected to defer to a future model year in the calculation of a future model 

year fleet average. 

TABLE 13. MODEL YEAR 2011 ADVANCED TECHNOLOGY VEHICLES 

REPORTED AS DEFERRED TO A FUTURE MODEL YEAR

Manufacturer Fleet

Production 

Volume GHG (g/mi)

Daimler Car 623 0

GM Car 4,370 54

Grand Total 4,993

VI. Conclusion

EPA’s GHG program includes a number of flexibilities designed to provide sufficient lead time 

for manufacturers and to reduce the overall cost of the program, without compromising overall 

 

15 In this case, “upstream” refers to the emissions associated with the production and distribution of electricity and 

hydrogen. 
18

environmental objectives. One of these flexibilities is an optional program that allows 

manufacturers with superior greenhouse gas emission reduction performance to generate early 

credits in the 2009-2011 model years. The early credits program provided a valuable incentive 

for manufacturers that have implemented GHG reducing technologies in excess of either the 

CAFE or California GHG standards prior to MY 2012. These early credits represent surplus 

reductions that were not otherwise required by law, and will allow manufacturers to transition to 

the increasingly stringent GHG standards. EPA’s early credits program is also an important 

example of how the GHG and CAFE programs were aligned to achieve a coordinated National 

Program.16

EPA is providing this report as part of our commitment to provide the public with timely, 

transparent information about the implementation of the light-duty GHG standards program. This 

report summarizes the credits reported by each manufacturer in the 2009-2011 model years and 

explains the options for earning and using early credits. Manufacturers that chose to participate 

in the early credits program submitted documentation in early 2012, as required under the 

regulations. Seventeen manufacturers chose to take advantage of one or more elements of the 

early credits program, reporting some 209 million metric tons of CO2 credits over the three 

model years covered by the program.

This report is also intended to be used as a reference for users of the early credits data, which we 

are making available in formats appropriate for importing into spreadsheets or database 

applications. EPA is neither making any assumptions regarding the potential disposition of these 

early GHG credits nor attempting to speculate at this time on how manufacturers will choose to 

use these accumulated early credits over the applicable credit lifetimes. However, we believe 

that most manufacturers will be taking a long-term view by using their accumulated credits 

judiciously to plan a smooth pathway to the increasingly stringent GHG emission standards in 

the future.

 

16 Under the CAFE program, manufacturers that have been outperforming the CAFE standards in the same time 

period will be approaching the increasingly stringent CAFE standards with a bank of credits accumulated in the 

same model years as the early GHG credits program. 
i 

APPENDIX I – REPORTED CREDITS BASED ON EARLY FLEET AVERAGE CO2 REDUCTIONS

Manufacturer Pathway Model 

Year Region Fleet

Fleet 

Threshold 

(g/mi)

Fleet 

Average 

(g/mi)

Vehicle 

Production 

(# units)

Fleet Average 

Credits (Mg)

BMW 4 2009 NC Car 323 306 95,270 316,248

Truck 381 394 16,978 (49,852)

2010 NC Car 323 309 72,225 197,441

Truck 376 384 13,612 (24,596)

2011 NC Car 302 303 153,966 (30,064)

Truck 351 356 31,323 (35,374)

BMW Total 383,374 373,803

Chrysler 1 2009 US Car 323 319 287,364 224,447

Truck 439 402 528,286 4,414,889

2010 US Car 301 316 430,110 (1,259,775)

Truck 420 394 729,662 4,284,933

2011 US Car 267 309 335,790 (2,753,843)

Truck 390 396 739,487 (1,002,145)

Chrysler Total 3,050,699 3,908,506

Ford 1 2009 US Car 323 299 508,727 2,384,066

Truck 439 397 504,921 4,789,847

2010 US Car 301 289 856,065 2,005,904

Truck 420 406 965,968 3,054,497

2011 US Car 267 283 792,654 (2,476,429)

Truck 390 387 873,635 591,971

Ford Total 4,501,970 10,349,856

GM 1 2009 US Car 323 295 1,048,593 5,733,069

Truck 439 413 844,892 4,961,620

2010 US Car 301 298 857,825 502,507

Truck 420 382 932,358 8,002,308

2011 US Car 267 296 1,006,900 (5,701,728)

Truck 390 382 1,419,043 2,564,097

GM Total 6,109,611 16,061,873

Honda 3 2009 NC Car 323 257 433,183 5,582,613

Truck 381 339 232,149 2,202,242

CA Car 323 266 388,318 4,321,998

Truck 439 373 89,079 1,327,909

2010 NC Car 323 251 414,562 5,828,330

Truck 376 329 290,216 3,080,833

CA Car 301 262 429,692 3,272,232

Truck 420 366 95,106 1,159,980
ii

Manufacturer Pathway Model 

Year Region Fleet

Fleet 

Threshold 

(g/mi)

Fleet 

Average 

(g/mi)

Vehicle 

Production 

(# units)

Fleet Average 

Credits (Mg)

2011 NC Car 290 253 317,065 2,290,721

Truck 347 338 280,042 569,265

CA Car 267 250 247,437 821,364

Truck 390 335 244,121 3,032,611

Honda Total 3,460,970 33,490,098

Mazda 3 2009 NC Car 323 280 61,283 514,554

Truck 381 329 35,084 412,061

CA Car 323 281 40,884 335,293

Truck 439 379 10,612 143,813

2010 NC Car 323 263 133,292 1,561,628

Truck 376 329 64,558 685,325

CA Car 301 265 86,948 611,201

Truck 420 360 25,351 343,554

2011 NC Car 289 266 112,883 506,966

Truck 347 359 18,435 (49,966)

CA Car 267 256 59,856 128,565

Truck 390 339 25,145 289,648

Mazda Total 674,331 5,482,642

Mitsubishi 3 2009 NC Car 323 294 60,347 341,724

Truck 381 322 8,573 114,244

CA Car 323 290 23,293 150,093

Truck 439 342 872 19,105

2010 NC Car 323 277 30,144 270,758

Truck 376 323 14,832 177,552

CA Car 301 288 15,733 39,937

Truck 420 365 2,699 33,529

2011 NC Car 288 266 49,447 212,415

Truck 335 325 15,159 34,239

CA Car 267 267 25,408 0 

Truck 390 358 7,712 55,740

Mitsubishi Total 254,219 1,449,336

Nissan 1 2009 US Car 323 268 605,439 6,502,124

Truck 439 372 234,883 3,554,474

2010 US Car 301 266 617,548 4,220,471

Truck 420 399 236,588 1,122,176

2011 US Car 267 261 666,660 781,048

Truck 390 382 299,074 540,403
iii

Manufacturer Pathway Model 

Year Region Fleet

Fleet 

Threshold 

(g/mi)

Fleet 

Average 

(g/mi)

Vehicle 

Production 

(# units)

Fleet Average 

Credits (Mg)

Nissan Total 2,660,192 16,720,696

Subaru 1 2009 US Car 323 308 156,871 459,469

Truck 439 322 43,945 1,161,300

2010 US Car 301 299 183,763 71,765

Truck 420 292 74,489 2,153,531

2011 US Car 267 295 176,923 (967,307)

Truck 390 292 129,950 2,876,413

Subaru Total 765,941 5,755,171

Suzuki 1 2009 US Car 323 275 24,859 232,995

Truck 439 345 10,146 215,413

2010 US Car 301 259 20,212 165,760

Truck 420 337 8,728 163,622

2011 US Car 267 262 19,390 18,931

Truck 390 345 7,864 79,929

Suzuki Total 91,199 876,650

Tesla 1 2010 US Car 301 0 599 35,206

2011 US Car 267 0 269 14,024

Tesla Total 868 49,230

Toyota 1 2009 US Car 323 245 1,273,815 19,400,957

Truck 439 345 482,202 10,237,780

2010 US Car 301 228 1,412,172 20,129,484

Truck 420 353 793,226 12,003,853

2011 US Car 267 243 1,140,255 5,343,618

Truck 390 321 834,019 12,997,923

Toyota Total 5,935,689 80,113,615

Volkswagen 3 2009 NC Car 323 290 139,498 898,885

Truck 381 363 21,078 85,694

CA Car 323 293 118,411 693,642

Truck 439 382 13,295 171,164

2010 NC Car 323 274 143,295 1,371,037

Truck 376 356 23,488 106,102

CA Car 301 277 134,231 629,052

Truck 420 361 19,350 257,859

2011 NC Car 289 267 151,373 650,269

Truck 342 332 35,176 79,450

CA Car 267 273 121,114 (141,895)

Truck 390 334 25,667 324,648
iv

Manufacturer Pathway Model 

Year Region Fleet

Fleet 

Threshold 

(g/mi)

Fleet 

Average 

(g/mi)

Vehicle 

Production 

(# units)

Fleet Average 

Credits (Mg)

Volkswagen Total 945,976 5,125,907

Volvo 1 2009 US Car 323 317 31,618 37,043

Truck 439 407 11,420 82,540

2010 US Car 301 317 23,529 (73,510)

Truck 420 380 34,413 310,908

2011 US Car 267 300 24,846 (160,100)

Truck 390 354 27,761 225,729

Volvo Total 153,587 422,610
i 

APPENDIX II – SUMMARY OF REPORTED CREDITS BY TYPE AND MODEL YEAR, BY 

MANUFACTURER

Manufacturer MY Fleet A/C Efficiency A/C Leakage Off-Cycle Fleet Average Grand Total

BMW

2009 Car 62,528 47,490 316,248 426,266

Truck 16,106 17,334 -49,852 -16,412

2010 Car 46,231 34,939 197,441 278,611

Truck 12,765 13,670 -24,596 1,839

2011 Car 113,483 80,174 -30,064 163,593

Truck 30,428 35,952 -35,374 31,006

Total 281,541 229,559 373,803 884,903

Chrysler

2009 Car 68,074 237,143 224,447 529,664

Truck 86,828 551,632 4,414,889 5,053,349

2010 Car 107,553 352,786 -1,259,775 -799,436

Truck 111,650 740,466 4,284,933 5,137,049

2011 Car 118,345 340,299 -2,753,843 -2,295,199

Truck 324,184 843,506 -1,002,145 165,545

Total 816,634 3,065,832 3,908,506 7,790,972

Daimler

2009 Car 30,018 31,408 61,426

Truck 16,744 18,297 35,041

2010 Car 35,122 30,856 65,978

Truck 25,808 32,334 58,142

2011 Car 71,586 41,110 112,696

Truck 28,138 16,851 44,989

Total 207,416 170,856 378,272

Ford

2009 Car 247,818 2,384,066 2,631,884

Truck 830,382 4,789,847 5,620,229

2010 Car 15,304 387,819 2,005,904 2,409,027

Truck 6,501 1,623,677 3,054,497 4,684,675

2011 Car 14,415 476,473 -2,476,429 -1,985,541

Truck 64,493 1,279,698 591,971 1,936,162

Total 100,713 4,845,867 10,349,856 15,296,436

GM

2009 Car 113,142 792,488 5,733,069 6,638,699

Truck 12,683 1,393,043 3,329 4,961,620 6,370,675

2010 Car 99,629 716,959 502,507 1,319,095

Truck 263,524 1,487,242 965 8,002,308 9,754,039

2011 Car 310,606 1,340,422 -5,701,728 -4,050,700

Truck 330,160 1,648,173 1,338 2,564,097 4,543,768

Total 1,129,744 7,378,327 5,632 16,061,873 24,575,576

Honda

2009 Car 161,988 246,771 9,904,611 10,313,370

Truck 53,885 176,484 3,530,151 3,760,520

2010 Car 177,222 277,048 9,100,562 9,554,832

Truck 48,334 226,311 4,240,813 4,515,458

2011 Car 119,152 142,831 3,112,085 3,374,068

Truck 111,311 283,673 3,601,876 3,996,860

Total 671,892 1,353,118 33,490,098 35,515,108

Mazda

2009 Car 849,847 849,847

Truck 555,874 555,874

2010 Car 2,172,829 2,172,829

Truck 1,028,879 1,028,879
ii

Manufacturer MY Fleet A/C Efficiency A/C Leakage Off-Cycle Fleet Average Grand Total

2011 Car 635,531 635,531

Truck 239,682 239,682

Total 5,482,642 5,482,642

Mitsubishi

2009 Car 491,817 491,817

Truck 133,349 133,349

2010 Car 310,695 310,695

Truck 211,081 211,081

2011 Car 212,415 212,415

Truck 89,979 89,979

Total 1,449,336 1,449,336

Nissan

2009 Car 225,310 20,466 6,502,124 6,747,900

Truck 94,333 100,005 3,554,474 3,748,812

2010 Car 231,360 16,755 4,220,471 4,468,586

Truck 81,072 109,905 1,122,176 1,313,153

2011 Car 248,584 44,656 781,048 1,074,288

Truck 102,799 135,259 540,403 778,461

Total 983,458 427,046 16,720,696 18,131,200

Subaru

2009 Car 459,469 459,469

Truck 1,161,300 1,161,300

2010 Car 71,765 71,765

Truck 2,153,531 2,153,531

2011 Car -967,307 -967,307

Truck 2,876,413 2,876,413

Total 5,755,171 5,755,171

Suzuki

2009 Car 232,995 232,995

Truck 215,413 215,413

2010 Car 165,760 165,760

Truck 163,622 163,622

2011 Car 18,931 18,931

Truck 79,929 79,929

Total 876,650 876,650

Tesla

2010 Car 374 35,206 35,580

2011 Car 168 14,024 14,192

Total 542 49,230 49,772

Toyota

2009 Car 639,927 507,913 19,400,957 20,548,797

Truck 195,200 343,961 10,237,780 10,776,941

2010 Car 768,652 583,900 20,129,484 21,482,036

Truck 373,144 598,764 12,003,853 12,975,761

2011 Car 621,412 532,137 5,343,618 6,497,167

Truck 483,423 343,787 12,997,923 13,825,133

Total 3,081,758 2,910,462 80,113,615 86,105,835

Volkswagen

2009 Car 231,296 110,126 1,592,527 1,933,949

Truck 28,408 23,990 256,858 309,256

2010 Car 249,431 120,055 2,000,089 2,369,575

Truck 42,110 36,017 363,961 442,088

2011 Car 239,277 109,887 508,374 857,538

Truck 71,965 52,936 404,098 528,999

Total 862,487 453,011 5,125,907 6,441,405

Volvo 2009 Car 37,043 37,043

Truck 82,540 82,540
iii

Manufacturer MY Fleet A/C Efficiency A/C Leakage Off-Cycle Fleet Average Grand Total

2010 Car -73,510 -73,510

Truck 310,908 310,908

2011 Car -160,100 -160,100

Total 196,881 196,881