Tesla: skipped regulatory credit reporting for survival, there is no ZEV/BEV transfer reported for September 2018-August 2019, $594 million revenue in doubt

Since 2009, Tesla has been reporting about their regulatory credit revenue from sale of (zero emission vehicle) ZEV in their quarterly earning report.

According to CARB data, Tesla transferred 223,788.12 ZEV credit to Chrysler, Honda, Subaru, Fuji, Ford, Toyota and Fiat with remaining balance of 210,851.13 as of August 2019. Tesla reported 0.00 of ZEV credit transfer between September 2018 - August 2019 and between September 2019 - August 2020 will be reported next month.  

According to New York data, Tesla transferred 21,306.76 BEV credit to Ford, Mazda, Subaru, and Toyota in 4 year with remaining balance of 19,994.07. There was 0.00 BEV credit transfer between September 2018 - August 2019  which is mandatory to report and between September 2019- August 2020 credit balance will be reported next month. 

So if we add credit sale of New York, and California till August 2018

 21,306.76 +223,788.12 = 245,094.88 

Total regulatory credit revenue reported since 2009 till August 2018:  $1.7152 Billion 

This means Tesla is making: $1.7152 Billion / 245,094.88 = $6,998.11 on each ZEV credit transfer. 

Each Tesla car gets approximately 3.5 ZEV credit = 3.5 times $6,998.11 which mean they made $24,493.7 on each car sale. (May be some customer would sue Tesla and get their share because its their car)

Here is a link to CARB site, click on each link you can see the credit transfer and balance. 

https://ww2.arb.ca.gov/our-work/programs/advanced-clean-cars-program/zev-program/zero-emission-vehicle-credit-balances

But based on CARB, here are the ZEV credit balance and transfer. since 2010:

Year	Balance	Transfer	Transferee	Total Credit Generated
2009
2010
2011	0	22.995	Chrysler	22.995
2012	0	31.605	Honda	31.605
2013	276.08	1311.52	Honda+Subaru	1,587.6
2014	221.56	650.195	Fuji +ford	595.675
2015	4988	1,554.805	Toyota+Ford	6,321.245
2016	3530	80,227	Ford + Fiat + Honda	78,769
2017	29556	51,776	Toyota Subaru Fiat	77,802
2018	74712.17	88,214	Toyota	133,370.17
2019	210,851.13	0.00		136,138.96
2020
	Total	223788.12		434639.25

New York ZEV credit balance is reported since 2014: https://www.dec.ny.gov/chemical/8575.html

Year	Balance	Transfer	Transferee	Total Credit Generated
2011	0	0		0
2012	0	0		0
2013	0	0		0
2014	0	0		0
2015	3.714	1,316	Ford	1,319.714
2016	4,807.71	850	Mazda	5,653.996
2017	68.71	10,287	Toyota+Subaru	5,548
2018	2,303.95	8,853.76	Toyota	11,089
2019	19,994.07	0.00		17,690.12
2020
		21306.76		41300.83

Tesla claimed in their quarterly report they made $8.2 million in 2009, $2.7 million in 2010, and $2.8 million through ZEV credit transfer. They didnt even sell car in 2009. thats another red flag.

Regulatory credit revenue reported by Tesla :

Year	Regulatory Credit in (million)
2009	$8.2
2010	$2.8
2011	$2.7
2012	$40.5
2013	$194.4
2014	$216.3
2015	$168.7
2016	$302.3
2017	$360.3
2018	$419
2019	$594
2020	$772
Total	$3,079.2

Tesla reported regulatory credit revenue of $354 million in Q1 2020, and $428 million in Q2, thats total of $772 million. There was 0.00 ZEV/BEV transfer between August 2018-August 2019 yet Tesla reported $594 million in regulatory credit revenue, so question how did they come up with this number ? Whom did they transfer ZEV credit and what is the balance left ?  Will they skip reporting again for $772 million ?