Calculations using official CAFE data, and the newly proposed credit trading flexibility contained in the September 28, 2009 Notice of Proposed Rulemaking show that ninety-eight percent of the benefit derived from just the cross fleet credit trading provision flows to Toyota. According to these calculations 75% of the benefit from the two new CAFE credit trading provisions, cross fleet trading and 5-year carry-forward, falls to foreign manufacturers. Toyota can use the provision to avoid or reduce compliance on average by 0.69 mpg per year through 2020,