Timing and Process of EPA s Proposed Determination

Transcription

1 Motor & Equipment Manufacturers Association Comments on Proposed Determination on the Appropriateness of the Model Year Light Duty Vehicle Greenhouse Gas Emissions Standards under the Midterm Evaluation Docket No. EPA HQ OAR December 30, 2016 Introduction The Motor & Equipment Manufacturers Association (MEMA) 1 submits these comments to the U.S. Environmental Protection Agency s (EPA) Proposed Determination on the Appropriateness of the Model Years (MYs) Light duty Vehicle Greenhouse Gas (GHG) Emissions Standards under the Midterm Evaluation (MTE) (Proposed Determination). MEMA and the motor vehicle supplier industry are committed to policies that enable the introduction of new technologies that support sustainable mobility and reduce emissions. MEMA represents more than 1,000 companies that supply systems and components for use in the light and heavy duty vehicle original equipment and aftermarket industries. The motor vehicle components manufacturing industry is the nation s largest direct employer of manufacturing jobs employing over 871,000 workers in all 50 states and contributes nearly $435 billion in GDP. 2 Our members innovate and develop a multitude of technologies and manufacture a wide range of products, components and systems. Motor vehicle suppliers play a significant role in developing and engineering innovative technologies that improve vehicle performance, fuel efficiency and emissions. Suppliers strongly support the National Program as originally articulated by President Obama in 2010, 3 and have invested heavily in developing a wide variety of technologies and solutions to offer their original equipment manufacturer (OEM) customers to help them meet the standards. These technologies reduce vehicle emissions and improve vehicle efficiencies. MEMA continues to urge EPA to 1 MEMA represents its members through four divisions: Automotive Aftermarket Suppliers Association (AASA); Heavy Duty Manufacturers Association (HDMA); Motor & Equipment Remanufacturers Association (MERA); and, Original Equipment Suppliers Association (OESA). 2 MEMA updated its economic impact figures since its September 26, 2016 comments to the Joint EPA, National Highway Traffic Safety Administration (NHTSA) and California Air Resources Board (CARB) Draft Technical Assessment Report (TAR). 3 Presidential Memorandum Regarding Fuel Efficiency Standards (May 21, 2010), available at press office/presidential memorandum regarding fuel efficiency standards.

2 recognize the need for flexibility to meet these standards and the supplier industry stands ready to fully participate in that process. Our comments to EPA s Proposed Determination will address the following: Timing and Process of EPA s Proposed Determination o By releasing the Proposed Determination ahead of schedule, EPA missed an opportunity to base the determination on the best available data and important data trends. Importance of Harmonization and a National Program o MEMA is disappointed that the Proposed Determination fails to address the harmonization between EPA, the National Highway Traffic Safety Administration (NHTSA), and the California Air Resources Board (CARB). Because harmonization and coordination are critical to the industry, MEMA hoped they would be cornerstones to the National Program during the MTE. Opportunities to Enhance the Off Cycle Technology Credit Program o Further development and improvement to the off cycle program is needed to provide flexibilities to industry. o Improvement to the program s pathways for obtaining off cycle credits is needed to spur technology adoption in the latter half of the program (MYs ). Observations on the Technical Support Document (TSD) o EPA should revisit light duty diesel data and update the final TSD. 4 o EPA should add engine idle stop start with a 48 Volt system to the off cycle predefined menu with credits available on a sliding scale. o Air Conditioning (A/C) off cycle credit applications should be analyzed before deciding whether the awarded credit should count toward the A/C efficiency credit cap. Timing and Process of EPA s Proposed Determination MEMA is deeply concerned about EPA s unilateral decision to issue its Proposed Determination ahead of schedule, with an abridged comment period, and separately from NHTSA s proposed Corporate Average Fuel Economy (CAFE) standards for MYs Because EPA and NHTSA recognized the importance of maintaining a single National Program, the 2012 final rule stated that the agencies would finalize their actions related to MYs standards concurrently and in coordination with the California Air Resources Board. 5 4 EPA Proposed Determination on the Appropriateness of the Model Year Light Duty Vehicle Greenhouse Gas Emissions Standards Under the Midterm Evaluation: Technical Support Document, November 30, Fed. Reg (Oct. 12, 2012). 2

3 On November 30, EPA released its Proposed Determination and the accompanying TSD, consisting of nearly 1,000 pages, several months ahead of the agency s own timetable 6 and separately from NHTSA s fuel economy proposed rule. These documents including a significant amount of new assumptions and analyses are EPA s justification of its MTE determination that the GHG emissions standards established under the 2012 final rule 7 for those model years are achievable without change. Thirty days for stakeholders to review, digest and respond to the significant amount of data in these documents has been challenging. It is unfortunate that EPA chose to release its Proposed Determination significantly ahead of the expected MTE timeline and combine it with an abbreviated public comment period. 8 Moreover, MEMA is disappointed that this timeline does not allow EPA to base its decision on the most up to date data, such as 2016 compliance data and information considered by CARB in conducting its forthcoming comprehensive midterm review of California GHG standards under the Advanced Clean Car (ACC) Program. In 2012, EPA and NHTSA recognized the need for a MTE to ensure industry received an objective, data driven and transparent evaluation of the standards set for 10 years in the future. 9 The MTE process was designed to allow EPA and NHTSA, in consultation with the CARB, to evaluate in unison the appropriateness of the standards for MYs This decision intended to be coordinated between NHTSA and EPA was to be based on the most up to date data and scientific analysis. By releasing the Proposed Determination at least six months ahead of the agencies intended schedule, and months before CARB s anticipated release of its determination, EPA has greatly hampered its ability to base the determination on the best available data. As an example, EPA has negated the possibility of reviewing vehicle manufacturers 2016 and 2017 compliance data to see if they show the same patterns of compliance as MYs 2012 through In the agency s 2015 GHG Emission Standards Manufacturer Performance Report (EPA 2015 Manufacturer Performance Report), EPA has correctly stated that OEMs have exceeded requirements for the 2015 fleet of cars and trucks by 7 grams per mile (g/mi) of CO 2 and for the 2015 fleet of light trucks by 1 g/mi of CO EPA fails to mention, however, that the 2015 light truck fleet complies only because of a flex fuel vehicle credit (10.3 g/mi) as shown in Table 3 34 (see Appendix). Without this flex fuel credit, the 2015 light truck fleet would be out of compliance. Further, the 2015 combined cars and trucks fleet would be within only 1 g/mi of the standard without the flex fuel credit (6.4 g/mi) as shown in Table 3 32 (see Appendix). Importantly, passenger car compliance margins have decreased each year from 2013 to 2015 as shown in Table 6 EPA had previously indicated that its Proposed Determination would be released in mid See, e.g., 10/documents/grundler sae naipc presentation.pdf, at C.F.R (h) 8 MEMA requested an extension to the comment period of at least 120 days in a letter to the EPA on December 9, On December 22, 2016, the EPA rejected that extension request C.F.R (h) Model Year Greenhouse Gas (GHG) Emission Standards for Light Duty Vehicles: Manufacturer Performance Report, Environmental Protection Agency, pgs. 62 and 63, available at 11/documents/420r16014.pdf. 3

4 3 33 (see Appendix). Since the vehicle flex fuel credits have been eliminated for MY 2016, EPA s analysis would benefit from evaluating OEMs 2016 compliance data to fully evaluate the impact. The credit elimination will significantly scale back manufactures ability to meet the more stringent requirements in MYs These factors need to be included in EPA s analysis. Again, the agency s action to pull forward the Proposed Determination has greatly impacted its ability to base the determination on important data trends. In fact, there are program elements EPA should consider improving if the MYs standards are to remain appropriate. Harmonization between the two programs and improvements in the off cycle technology credit program will be critical components of OEMs meeting the MYs targets. We discuss these issues in more detail below. Importance of Harmonization and a National Program Regulatory requirements and standards must provide a consistent, aligned framework, which, in turn, provides certainty and clarity to all stakeholders. MEMA supports the harmonization of GHG emissions and CAFE standards to a true National Program, as directed by President Obama. 11 The industry has invested heavily in technology to meet those standards. True harmonization would alleviate friction from overlapping regulations from the EPA, NHTSA and CARB. Harmonization of regulatory programs is critical to provide long term certainty and spur innovation in the automotive industry, and MEMA hoped it would be a cornerstone to improving the National Program during the MTE analysis. As such, MEMA is disappointed that the Proposed Determination dismisses the harmonization problems with the National Program. The EPA states that the current program delivers on the original intent of the harmonization as envisioned by the National Program and that the program allows manufacturers to build a single fleet that would comply with both the GHG and CAFE standards. 12 Unfortunately, there are instances where a fleet can comply with the EPA program and still be subject to fines under the NHTSA program. Since motor vehicle suppliers are responsible for a significant proportion of research and development of the technologies needed for OEMs to meet and exceed the standards, any initiative to further align regulatory requirements is equally important to suppliers. EPA s unilateral action to release its Proposed Determination ahead of the expected MTE timeline, combined with a truncated public comment period, conflicts with the agencies commitment to a true National Program. Under the direction of the President, 13 the agencies committed to a harmonized National Program in which EPA and NHTSA, along with CARB, would coordinate and issue their draft TARs and subsequent MTE determinations at the same time. The misalignment of the NHTSA and EPA rulemaking processes raises the risk (and uncertainty) that each agency will make different determinations, subjecting industry to conflicting GHG and fuel efficiency standards. In addition, CARB may disagree with EPA s final determination and, instead, 11 Presidential Memo Regarding Fuel Efficiency Standards, May 21, EPA Proposed Determination, pgs Presidential Memo Regarding Fuel Efficiency Standards, May 21,

5 seek more stringent GHG standards for MYs EPA s decision to proceed without input from NHTSA or CARB, leaves open the possibility of inconsistent GHG or fuel efficiency standards at the state and federal levels. This would be a significant diversion from the spirit of collaboration on a true National Program. Further, harmonization between the two programs is pertinent to the MTE because of the inconsistencies in the way the agencies recognize, transfer and account for technology credits. As such, harmonization of the two programs to a true National Program, is crucial to enhance the vehicle industry s ability to make technology investment decisions and plan for compliance. For these reasons, MEMA supports a uniform, footprint based National Program. A harmonized program provides regulatory clarity and the certainty needed for OEMs and suppliers to make the necessary technology investment decisions. Long term certainty is an essential factor in the industry s investment equation. Program harmonization creates economies of scale, leads to reduced compliance cost for the OEMs, and improves market availability for the needed technologies. This, in turn, enables suppliers to continually innovate, to advance development and to turn research technologies into commercially viable products. MEMA expects EPA, NHTSA and CARB to work together to provide industry with optimal harmonization as contemplated by the National Program. This is essential for providing the coordination necessary to meet the more stringent standards for MYs Opportunity to Enhance Off Cycle Technology Credit Program In the Proposed Determination, EPA states that the standards for MYs remain appropriate without any changes to the credit and incentive provisions currently in place. 14 MEMA disagrees with that statement. EPA s inaction is a missed opportunity to enhance the offcycle credit program for near term and future technologies. Further development of and improvement to the off cycle credit program is necessary to provide much needed flexibilities and allow industry to stay on track for MYs targets. It is critical that the off cycle credit program has opportunities to evolve and develop with the technologies it is meant to encourage. If deployed thoughtfully, these technologies can benefit a wide variety of vehicle types and provide more choice in the marketplace. It is critical that EPA consider data from 2015, 2016 and 2017 on the utilization of off cycle technology credits before it makes the determination that no changes are needed to the program to meet the MYs targets. Motor vehicle suppliers play a significant role in the development and engineering of innovative off cycle credit technologies. For these reasons, MEMA is a proponent of an improved off cycle technology credit process. An improved program would encourage more efficient, broader deployment and earlier adoption. Suppliers should be able to fully participate in advocating improvements in the off cycle credits program. Accordingly, MEMA is willing to work with the agencies to further develop the off cycle technology credit program. 14 EPA Proposed Determination, pg

6 We urge the agency to consider how off cycle credits can be optimized, even if it is outside EPA s MTE process. MEMA recommends expanding the predefined menu of off cycle credits, lifting the cap placed on these credits, and streamlining the petition process for the second and third pathways. We also encourage the agencies to consider allowing suppliers to directly petition for approval of new off cycle technologies they develop and produce. We expand on these issues below. Importance of Credits and Flexibilities Unfortunately, there was an absence of analysis in the draft TAR and now the Proposed Determination regarding how the off cycle credit program could be amended. Improvements to the program are necessary to offer more opportunities for OEMs to utilize off cycle technologies and offer more flexibility in meeting the standards, particularly as the target curve grows steeper for MYs Elimination of Credit Cap The 2012 final rule acknowledged that the cap on credits earned through the pre defined off cycle technology credit menu would be a topic for further consideration and one of the issues the agencies examine during the mid term review. 15 MEMA is disappointed that there was very little analysis and discussion in the Proposed Determination around the conclusion that the credit cap of 10 g/mi remains appropriate. 16 The draft TAR and the EPA 2015 Manufacturer Performance Report show that off cycle credit use from the pre defined menu is steadily increasing. The data in these reports point to the growing resources dedicated toward lowering emissions using off cycle technologies. 17 The agencies must eliminate the arbitrary cap on off cycle technology credits obtained from the pre defined menu. The pre defined menu is a heavily used credit pathway and, per 2015 data, for most OEMs it is the sole pathway for obtaining credits. 18 Having a cap on obtaining credits this way will soon stymie OEM adoption of off cycle technologies. This credit cap on off cycle technologies is counterproductive as it is essentially capping real world CO 2 reductions. These technologies offer real world benefits that help spur innovation and incentivize OEMs to incorporate these technologies. One gram of CO 2 per mile on the 2 cycle test does not equate to one gram of CO 2 in the real world or on the 5 cycle test. Historical data clearly demonstrates real world fuel economy is lower than the published drive cycle test fuel economy, with the gap steadily increasing over the years. (Gains achieved in miles per gallon over time as observed on the 2 cycle test do not translate to equivalent gains over the 5 cycle test or the real world.) These off cycle technology credits need to be recognized as incentivizing the development and adoption of innovative fuel saving and emission reducing technologies not to be treated like loop holes Fed. Reg. at EPA Proposed Determination, pg. A Draft TAR pgs and EPA 2015 Manufacturer Performance Report, pg EPA 2015 Manufacturer Performance Report, pg

7 Current Structure Needs Change The off cycle credit program has room for improvement if it is to continue to encourage the use of these technologies in MYs Technology, if properly incentivized, will continue to develop and evolve. For these reasons, MEMA urges the agency to provide more opportunities for off cycle technologies to be recognized and applied. The off cycle credit program provides three pathways an OEM can accrue off cycle technology credits. The first pathway, as discussed earlier, is the pre defined menu of technologies. The second pathway is a 5 cycle testing methodology that captures emission benefits not captured in the regular 2 cycle test. The third pathway allows OEMs to seek EPA approval through a public application process for an alternative methodology. According to data in the TSD and the EPA 2015 Manufacturer Performance Report, only a handful of credits were obtained via the second and third pathways in 2012 through 2015 (see Appendix Tables 3 17 and 3 18). 19 Opportunities to Improve the Second and Third Pathways Information on off cycle credit utilization outlined in the draft TAR, the TSD and the EPA 2015 Manufacturer Performance Report points to opportunities to further develop and improve the off cycle technologies credit program. These reports discuss that the second and third pathways are rarely used to obtain off cycle credits. In fact, in 2015 less than 5 percent of off cycle technology credits obtained by the OEMs were from the second and third pathways the remaining were from the pre defined menu. 20 Table 3 17 (see Appendix) show that OEM utilization of off cycle credits grew significantly from 2012 to However, OEMs obtaining credits from the second and third pathways stayed level from 2012 to 2015, the increase came from the pre defined menu (see Appendix Tables 3 17 and 3 18). This pattern indicates that the second and third pathways of accruing off cycle credits need to be improved and streamlined. Otherwise, these pathways will continue to be underutilized because of the arduous amount of information, data and testing requirements. MEMA urges the agency to examine how the information from the second and third pathways can be streamlined and standardized. Currently, these pathway processes have a significant amount of risk for both OEMs and suppliers, which ultimately serves as a barrier to deploying these GHG reducing technologies. Having a better application process for the second and third pathways will allow OEMs to use off cycle credits more effectively and creatively to meet the goals of the program. The industry and the agencies would benefit if the process for petitioning for off cycle credit technologies is revised and improved. Suppliers must invest heavily to offer multiple technology solutions intended to support a variety of vehicle manufacturers strategies to meet the programs targets. For these reasons, motor vehicle suppliers have a vested interest in making sure these technologies are easily deployed and utilized by OEMs. In MEMA s comments on the draft TAR, MEMA outlined two 19 TSD, pg and EPA 2015 Manufacturer Performance Report, pg EPA 2015 Manufacturer Performance Report, pg

8 proposals that could streamline the off cycle credit process and decrease the workload of the agencies and vehicle manufacturers. First, the agencies should evaluate each off the menu, offcycle credit petition from OEMs. If an application is for a technology that can be applied across the industry, then the off cycle technology should be added to the menu. Second, if an OEM applies for a not on the menu off cycle technology, then that same data and test validation should be available to all OEMs that want to implement the same off cycle technology. 21 Moreover, allowing suppliers to directly petition the agency to allow for an off cycle technology they produce to be eligible for a credit would greatly enable these technologies to enter the market at a higher rate. If a supplier s technology is approved to be eligible, then an OEM would petition EPA for approval of the off cycle technology for a specific platform. If approved, EPA would then determine what level of credit to assign given the platform. Suppliers could work with EPA to provide the test validation and data to determine minimum credit values for technologies. If certain off cycle technologies are assigned minimum credit values, this would provide a significant incentive to OEMs to adopt the technology. Suppliers, which are the developers and implementers of these innovative technologies, are in the best position to provide these data. A supplier petition process would be much more efficient than if each OEM had to provide the individual research data separately for a credit for the same technology. Expand Pre Defined List of Credits As discussed in the EPA 2015 Manufacturer Performance Report and the TSD, the vast majority of off cycle credits utilized in 2014 and 2015 are from the pre defined off cycle credit menu. 22 In 2015, more than 95 percent of the off cycle credits were generated from the predefined menu. Further, it was the sole pathway for generating off cycle credits for all OEMs except for GM. 23 In 2014, EPA initiated offering off cycle credits from the pre defined menu. As a result, off cycle credits obtained by OEMs jump significantly in 2014 (see Appendix Table 3 17) and many OEMs started obtaining credits for the first time. These data show that OEMs are much more likely to deploy off cycle technologies from the pre defined menu than the second and third pathways. One significant factor for the significant increase in OEMs obtaining off cycle credits from the pre defined menu when they were not utilizing them before is the relatively streamlined process for obtaining credits through the menu. For these reasons, we urge the agencies to expand the current pre defined off cycle credit menu. Expanding the pre defined menu would help these GHG decreasing technologies to enter the market at a faster rate and gain penetration. The menu could be supplemented with more technology categories and corresponding credit values. Expanding the pre defined menu would provide certainty for long term tooling investments, product development planning and system integration strategies for both OEMs and their suppliers. Further, expanding the pre defined menu would decrease the agency s workload on the agency s already limited resources; this, in turn, 21 For additional context, MEMA refers the agency to its comments to the draft TAR, which MEMA expressly incorporates by reference herein. See MEMA Comment Docket No. EPA HQ OAR , pgs EPA Technical Support Document, pg EPA 2015 Manufacturer Performance Report, pg

9 would allow more timely approval of these off cycle credits. MEMA provided suggestions on an expanded off cycle technology pre defined menu in our draft TAR comments. 24 Observations on the Technical Support Document Light Duty Diesel In MEMA s draft TAR comments regarding light duty diesel, we highlighted that the data on diesel from the National Research Council (NRC) were unclear, pessimistic and not sourced with specific technology cost breakdowns. 25 We requested that the agencies closely review the MARTEC report and revisit the NRC diesel analysis. 26 The Proposed Determination, however, did not include a response to our comments. Modern diesel engines can provide equal or better performance than equivalent gasoline engines while improving fuel economy due to their inherent lean burn operating regime. As such, light duty diesel vehicles will remain an important strategy for compliance. Thus, MEMA urges EPA to revisit the light duty diesel data and analysis in the finalized determination and finalized TSD. 48 Volt Systems The industry needs more flexibility for off cycle credits to be applied to hybrid powertrains, such as the rapidly developing 48 Volt (48V) technology, to further incentivize the technology. Off cycle benefits have been demonstrated for 48V systems ranging from the 48V P0 mild hybrid system, to 48V P2 hybrid systems and to the 48V P4 hybrid systems and the plug in hybrid vehicles (PHEV) that are being developed. The 48V system architectures each offer different levels of improvements; therefore, off cycle benefits for the stop start technology depends on the system configuration (including positioning, calibration and battery size). The OEM typically determines these architectures. OEMs will have little incentive to adjust these variations to increase efficiency unless credits are available on a sliding scale that correlates to vehicle performance. The supplier industry projects the adoption rate of the 48V to be lower than EPA and NHTSA s projections in the draft TAR. 27 A more flexible regulation and incentive program is needed to increase the penetration of such technologies. (For more detail please see our draft TAR comments. 28 ) The industry needs more clarification and certainty on incentives for these technologies. Therefore, we urge EPA to add engine idle stop start with a 48V system to the offcycle credit pre defined menu with a range of credit values available based on the system configuration and vehicle performance. Even if these technologies are not expected to be on the market for another two to five years, incentives for this technology need to be provided now. 24 MEMA Comment Docket No. EPA HQ OAR , Appendix A. 25 MEMA Comment Docket No. EPA HQ OAR , pg engine technology an analysis of compliance costs and benefits white paper/ 27 Draft TAR Table ES MEMA Comment Docket No. EPA HQ OAR , pgs. 8 and 12. 9

10 Further, the current credits for adoption of mild hybrid technology in full size pickup trucks should not end in MY2021. Rather, the credits need to be extended for the full length of the program MYs 2017 through 2025 (see Appendix Table A). A/C Credits and Credit Caps The draft TAR explains that A/C efficiency credits, even if obtained through the off cycle credit program, will continue to be subject to the A/C efficiency credit cap. 29 In the Proposed Determination, EPA restates that it intends to cap the A/C credits regardless of the pathway in which they are obtained. 30 MEMA strongly recommends that the agencies consider discontinuing counting A/C efficiency credits earned through the off cycle petition process toward the A/C efficiency credit cap. 31 However, we appreciate EPA s willingness to look at the overall data provided in the application before deciding whether the A/C off cycle credit will be counted toward the A/C efficiency credit cap. We encourage the agency to provide deference to an application when applying credits to the overall A/C efficiency credit cap as the industry develops and deploys these important technologies. Further, MEMA supports the continuation of A/C refrigerant credits through MY 2025 for low global warming potential refrigerants in new motor vehicles. We agree with EPA that this credit program has been very successful and that it will continue to play an important role in GHG reductions. 32 Conclusion Suppliers play an important role in the innovation and development of many of the technologies used to improve vehicle fuel economy and reduce GHG emissions. These technologies are critical to helping OEMs meet the MYs standards. As such, MEMA urges the agency to assess opportunities for further coordination among EPA, NHTSA, and CARB to achieve harmonization among fuel efficiency and GHG standards under the National Program. MEMA encourages EPA to consider how the off cycle technology credits program can be optimized and further developed, even if it is outside the MTE process. Thank you for consideration of these comments. For more information, please do not hesitate to contact Laurie Holmes, senior director of environmental policy or Leigh Merino, senior director of regulatory affairs. 29 Draft TAR, Section at pg EPA Technical Support Document, pg For further detail, MEMA refers the agency to its comments on the draft TAR. MEMA Comment Docket No. EPA HQ OAR , pgs. 14 and EPA Technical Support Document, pgs

11 Appendix Table Off Cycle Technology Credits by Manufacturer and Fleet, Model Years (g/mi) Model Year 2013 Model Year 2014 Model Year 2015 Model Year Manufacturer Cars Trucks All Cars Trucks All Cars Trucks All Cars Trucks All BMW FCA Ford GM Honda Hyundai Jaguar Land Rover Kia Mercedes Nissan Subaru Toyota Fleet Total Note that 0.0 indicates that the manufacturer did report off cycle credits, but that the overall volume was not high enough to round to 0.1 g/mi, whereas a dashes no off cycle credits reported. Table Reported Off Cycle Technology Credits from the Menu, by Manufacturer and Fleet, 2015 Model Year (Mg) 34 Manufacturer Car Truck Total Grams/Mile Equivalent of Total Credits BMW 233, , , FCA 490,904 2,385,988 2,876, Ford 670,668 1,523,766 2,194, GM 469, ,921 1,404, Honda 283, , , Hyundai 166,386 30, , Jaguar Land Rover 7,573 67,230 74, Kia 134,413 23, , Nissan 385, , , Subaru 5,270 15,844 21, Toyota 694, ,447 1,378, Fleet Total 3,541,476 6,326,548 9,868, EPA 2015 Manufacturer Performance Report, pg Ibid., pg. 41.

12 Table Compliance & Credit Summary, Model Years Combined Cars and Trucks (g/mi)* 35 Credits Model 2 Cycle CH 4 & N 2 O Compliance Standard Standard Year Tailpipe FFV A/C Off Cycle Deficit Value Compliance * Values stated in this table and in the text are correct, although rounding of values may result in some parent differences. Table Compliance & Credit Summary, Model Years Passenger Cars (g/mi)* 36 Model Credits Year 2 Cycle CH 4 & N 2 O Compliance Standard Standard Tailpipe FFV A/C Off Cycle Deficit Value Compliance *Values stated in this table and in the text are correct, although rounding of values may result in some parent differences. Table Compliance & Credit Summary, Model Years Light Trucks (g/mi)* 37 Model 2 Cycle Credits Year Tailpipe CH 4 & N 2 O Compliance Standard Standard FFV A/C Off Cycle Deficit Value Compliance *Values stated in this table and in the text are correct, although rounding of values may result in some parent differences. Table A 38 Model Year Required Minimum Percent Electrification of Full Size Pickup Trucks for Credit (percentage) Ibid., pg Ibid., pg Ibid., pg Fed. Reg. at