Motorvehicleregs.COM is maintained by Dale Kardos & Associates, Inc., a Washington, DC-based consulting firm providing assistance to motor vehicle manufacturers, suppliers and trade associations on regulatory and legislative matters concerning motor vehicle safety, fuel economy, emissions and other issues. If you would like to know more about us and how we can help you, please click on the link below to access our website or call us at (202) 567-2926.
NHTSA has posted on its fuel economy website CAFE credits earned by light duty vehicle manufacturers in the model years 2008, 2009, 2010 and 2011. The report is available here. NHTSA last reported on the status of CAFE credits in April of 2012. That report is available here.
On August 21, 2013,
EPA published CD-13-11 (LDV/LDT/ICI/LIMO) which supplements the information
provided in EPA guidance letter CD-12-18, November 16, 2012. The letter is
intended to guide manufacturers in their 2014 model year fuel economy labeling
program. It includes the following
Enclosure 1 - "Fuel Economy
Supplementary Information for 2014 Model Year" contains information about
the printed Fuel Economy Guide and about posting 2014 fuel economy data on the
EPA/DOE website (www.fueleconomy.gov).
Enclosure 2 - Enclosure 2
provides instructions for submitting information to EPA for the Fuel Economy Guide for
alternative-fueled vehicles, CNG vehicles, electric vehicles, plug-in hybrid vehicles, and sport
Enclosure 3 - Enclosure 3
contains the timetable for inclusion of fuel economy label values in the 2014 model year printed Fuel Economy Guide.
Since 1995, Dale Kardos & Associates, Inc. (DKA Inc.) has
been supplying automakers, automotive suppliers and their trade associations with
comprehensive detailed regulatory and legislative tracking reports. Each month, DKA Inc. publishes the following three related, but uniquely-focused, tracking reports:
The Reg Update
The Reg Update isa monthly report that tracks the status of all North American
regulatory activity concerning emissions, fuel economy (CO2) and safety (we
track all regulatory actions of NHTSA, EPA, California Air Resources Board,
Transport Canada, Environment Canada, and Section 177 States (i.e., states that
have adopted CA’s Low Emission Vehicle program rules). For each rulemaking, the
Reg Update provides electronic links to the latest official publications
and includes information concerning comment period deadlines, anticipated
future actions, projected implementation dates, and more. In print since 1998, the Reg Update also
serves as a tremendous archive of past actions.
U.S. Motor Vehicle Safety and
The U.S. Motor Vehicle Safety & Legislative Update is a monthly report summarizing the past month’s legislative and
regulatory activity concerning motor vehicle safety, emissions, and fuel
economy/GHG issues. The report provides
brief summaries of and electronic links to key Federal Register notices,
Congressional bills, public laws, NHTSA interpretation letters, recall
listings, defect reports, NCAP test results, etc. The report also covers financial incentive
program announcements coming out of the Department of Energy, California and
Status of Motor Vehicle Related
Legislation in the 113th Congress
This report is devoted to keeping automakers and supplier up-to-date
on the status of all legislation pending in the U.S. Congress that may
potentially affect the auto industry. We cover the introduction of all new bills and track their status over
the course of the next two years. We’ll
provide updates on any official new activity related to the bill, increases in
sponsorship, etc. The report typically
groups bills into the following categories: Appropriations, Climate
Change/GHG/Environment, Financial Incentive Programs, Biofuels and Flex Fuel
Vehicles, Funding for Vehicle Development, Safety, Toxic Chemicals, misc.
Pricing: The above reports can be purchased individually or at a discount (as a
package). A one year subscription is
required (12 monthly updates). For
pricing and/or questions, please send an email to Dale Kardos (firstname.lastname@example.org).
TO ASSIST AUTOMAKERS COMPLY WITH NEW FUEL ECONOMY AND CO2 STANDARDS
DC-based startup offers online compliance credit trading for automakers, engine
manufacturers, fuels producers, and alternative fuel vehicle fleet operators
Washington, DC, Oct.
– In today’s Federal Register (77 FR 62624),
EPA and NHTSA published their final fuel economy and GHG emissions standards
for 2017-2025 model year light duty vehicles.
On average, by 2025, light duty vehicles will be required to achieve
roughly 54.5 mpg. For some companies
like BMW, Mercedes, Jaguar Land Rover, VW and Volvo, this will be a tough nut
to crack because 54.5 mpg is a big leap from where most of them are today
(roughly 30 mpg). On the other hand,
there are manufacturers like Toyota, Hyundai, Nissan, Honda (and let’s not
forget electric vehicle manufacturers like Tesla, Fisker, Coda and Wheego) who
are already meeting tomorrow’s standards.
Some of these companies, in fact, have generated and banked hundreds of
millions of CAFE credits. In fact, there
1.6 billion CAFE credits currently in the bank at NHTSA waiting to be sold
to other manufacturers at a serious profit.
As the CAFE standards increase and the IRS CAFE penalties become
prohibitively expensive, these credits are likely to become increasingly more
valuable to those who hold them.
the need to provide automakers with a platform for trading CAFE and other types
of regulatory compliance credits, Mobilis Trading LLC (www.mobilistrading.com) recently
introduced the first of its kind online platform providing automakers the
opportunity to trade compliance credits by running forward and reverse
auctions. Using the Mobilis trading
platform, companies needing credits to comply can run reverse auctions allowing
companies with excess banked credits to profit by selling their credits to the
company with the shortage. The reverse
auction option makes it easy for companies short on credits to get exactly what
they need and nothing more.
addition to helping automakers comply with CAFE, Mobilis is also set up to
assist automakers trade motor vehicle CO2 credits and California zero emission
vehicle credits. Mobilis has also
established trading exchanges for engine manufacturers, fuels producers, and
alternative fuel vehicle fleet operators.
Mobilis is particularly excited about a new Department of Energy final
rule that is due out soon that should put a stop to the Department’s historic
practice of granting fleets waivers from the EPAct requirement that requires a
specified percentage of new vehicle acquisitions to be alternative fuel
vehicles. As discussed in the notice of
proposed rulemaking issued October 5, 2011, DOE has proposed to modify the
exemption process so that, in the future, noncompliant fleets will need to make
a good faith effort to purchase credits in the market place prior to applying
for an exemption from the requirements. Mobilis is also very excited
about California’s Low Carbon Fuel Standard regulation and the opportunities
for credit trading that exist within that program.
is now in the process of signing up customers and the company anticipates that
the first trades via the platform will take place later this summer. To
open an account with Mobilis, a company must be regulated under at least
one of the credit trading programs for which the platform has been designed.
Companies that establish an account with Mobilis in 2012 pay no fee to
access the platform. Mobilis will generate revenue by charging credit
buyers a fee for each credit transfer that results from an auction run using
the Mobilis platform.
more information on the new Mobilis compliance credit trading platform, please
go to www.mobilistrading.com.
Trading’s mission is to make credit trading a practicable compliance option for
vehicle manufacturers, engine manufacturers, fuels suppliers, and
alternative fuel vehicle fleet operators. Mobilis has developed an online
trading platform which makes it possible for regulated parties to trade
emissions compliance credits by running forward and reverse auctions.
Mobilis Trading, LLC
325 7th St., NW Suite 400
Washington, DC 20004
Tel: (202) 567-2926
Washington, DC - July 17, 2012 -- Today, Washington, DC-based Mobilis Trading, LLC ("Mobilis") launched a new trading platform (at www.mobilistrading.com) with four credit exchanges to help motor vehicle manufacturers, engine manufacturers, fuels producers, and alternative fuel vehicle fleet owners achieve compliance with increasingly more stringent environmental standards. Using the Mobilis trading platform, companies subject to the regulatory programs listed below will now have the opportunity to trade compliance credits online by running forward and reverse auctions:
NHTSA's Light Duty Vehicle Fuel Economy Program
EPA's Light Duty Vehicle GHG Emissions Program
NHTSA's Medium- and Heavy-Duty Vehicle Fuel Consumption Program
EPA's Medium- and Heavy-Duty Vehicle GHG Emissions Program
California and S.177 State Low Emission Vehicle Programs
EPA Emissions Standards for Heavy Duty Highway Diesel Engines
EPA Emissions Standards for Heavy Duty Gasoline Engines and Vehicles
EPA Emissions Standards for Non-Road CI Engines
EPA Emissions Standards for Snowmobile SI Engines
EPA Emissions Standards for Small Non-Road SI Engines
EPA Emissions Standards for Marine SI Engines
EPA Emissions Standards for Locomotive Engines
CARB's Low Carbon Fuel Standard Program
EPA's ABT Program for Benzene
Alternative Fuel Vehicle Fleet Operators
DOE's Alternative Fuel Vehicle Transportation Program (AFTP)
The Mobilis trading platform was developed by veteran auto industry regulatory affairs consultant, Dale Kardos. According to Kardos, the Mobilis trading platform will eliminate the uncertainty associated with negotiating a credit trade in a vacuum with a single trading partner. He said, "Our goal at Mobilis is to take the guesswork out of credit trading by offering regulated parties the opportunity to buy and sell compliance credits via a competitive online bidding process."
Mobilis developed the new compliance credit trading platform anticipating that some regulated parties may experience difficulties complying with future fuel economy and emissions standards. With motor vehicle fuel economy standards poised to top 50 mpg in the near future, Kardos believes that automakers will welcome the new service. He is equally confident that Mobilis will be a hit with companies that must comply with programs such as California's Low Carbon Fuel Standard and the Department of Energy's Alternative Fuel Vehicle Transportation Program. He said that with all of these programs, the regulators have built credit trading into the regulations because they know that, without such provisions, some companies simply will not be able to comply. According to Kardos, however, the regulators have not created the trading exchanges necessary to make credit trading practical and so Mobilis has stepped in to fill that void. Using the Mobilis trading platform, companies that need credits can run forward or reverse auctions to buy credits from companies that have generated excess credits through over-compliance with the standards. Kardos calls it a "win-win-win" situation because companies facing compliance difficulties will be able to get the credits they need to comply, companies that exceed the standards will benefit from their over-compliance, and the regulatory agencies will achieve their goals without putting anybody out of business in the process.
Mobilis will now begin the process of signing up customers and they anticipate that the first trades via the platform will take place later this summer. To open an account with Mobilis, a company must be regulated under at least one of the credit trading programs for which the platform has been designed. Companies that establish an account with Mobilis in 2012 pay no fee to access the platform. Mobilis will generate revenue by charging credit buyers a fee for each credit transfer that results from an auction run using the Mobilis platform.
For more information on the new Mobilis compliance credit trading platform, go to www.mobilistrading.com. For an electronic brochure about Mobilis, click here.
About Mobilis Trading:
Mobilis Trading's mission is to make credit trading a practicable compliance option for vehicle manufacturers, engine manufacturers, fuels suppliers, and alternative fuel vehicle fleet operators. Mobilis has developed an online trading platform which makes it possible for regulated parties to trade emissions compliance credits by running forward and reverse auctions.
According to a May 2, 2012 study released by the Congressional Budget Office (CBO), the proposed light duty vehicle fuel economy standards would reduce revenues going into the Highway Trust Fund by 21 percent. Specifically, the CBO estimates a $57 billion drop in revenues credited to the trust fund for the period 2012 – 2022.
To address the possible shortfall, the CBO provides several possible solutions. One solution is to transfer more money from the general fund to the Highway Trust Fund which is the action Congress took to address the shortfall each year from 2008 to 2010. An alternative would be increasing the gasoline tax by 5 cents per gallon. CBO further notes that a combination of fuel taxes and VMT taxes might be an even better idea.
EPA has published a document containing a record of the answers the agency has completed to date to the questions submitted by industry before, during and after the November 3, 2011 workshop. Regulated parties may use this document to aid in achieving compliance with the regulations for heavy-duty vehicles (40 CFR Part 86, 1037; and, 49 CFR Part 523,534 and 535) and heavy-duty engines (40 CFR Part 1036; and, 49 CFR Part 523, 534 and 535). For a copy, click here.
On January 13, 2012, NHTSA and EPA published a notice in the Federal Register at 77 FR 2028 announcing that they are extending the comment period for the joint 2017-2025 CAFE/GHG NPRM to February 13, 2012. The extension does not apply to NHTSA’s Draft Environmental Impact Statement which is available online at www.nhtsa.gov/fuel-economy. The comment period for NHTSA’s Draft EIS closes on January 31, 2012.
On March 15, 2011, the House Energy and Commerce Committee voted 34 to 9 to approve H.R. 910, the Energy Tax Prevention Act of 2011. While the bill is clear that EPA and CARB would be unable to issue motor vehicle GHG standards for the 2017 and later timeframe, it is also the opinion of the EPA that the legislation would also prevent them from enforcing 2012-2016 motor vehicle GHG standards that were passed in 2010. Although the bill is expected to be approved by the full House, it is not expected to garner enough votes in the Senate to pass there.