5619 905R80107
A REVIEW AND ANALYSIS OF THE
GOOD FAITH OF THE
AUTOMOBILE INDUSTRY
IN ATTEMPTING TO COMPLY WITH THE
STATUTORY 0.4 NOx STANDARD
a report to
the
Senate Public Works Committee,
U.S. Congress
U. S. Environmental Protection Agency
Eaviron^cnitsi Pi-scect.lon Agency
Ration V. ".-, - -
*5O 1 C -. 0 -''-1 - * * "' '3r » VN-if
J:ou fi'jl .,.i >,^t,.,.' .; ii Dui«2TJ,
Chicago, ZJJl",'/r, 6"60'f
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TABLE OF CONTENTS
Introduction i
Section 1 - Summary and Conclusions 1-1
Section 2 - Background 2-1
Section 3 - Resource Commitments 3-1
Section 4 - NOx Control Technology 4-1
Section 5 - Program Review 5-1
Section 6 - Project Review 6-1
Appendix A - Letter requesting NOx Good Faith Analysis
Appendix B - Request for Information from Auto Manufacturers
Appendix C - Financial Data
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INTRODUCTION
This report has been prepared by the U.S. Environmental
Protection Agency (EPA) in response to a request (Appendix A)
from the Honorable Edmund S. Muskie, Chairman, Subcommittee on
Environmental Pollution, U.S. Senate Public Works Committee,
on November 18, 1974, to investigate and report on the good
faith of the auto industry efforts in meeting the 0.4 gram per
mile (gpm) Nitrogen Oxide (NOx) standard established by the
Clean Air Act of 1970.*
A letter was sent to the manufacturers on January 6, 1975,
(Appendix B), requesting that they submit information on their
low-NOx efforts by March 1, 1975. The material received, in
addition to other submissions and suspension documents, formed
the major body of information used in preparing this report.
The report is divided into six sections. Section 1 summarizes
the body of the report. Section 2 provides the history of the
"good faith test" under Title II of the Clean Air Act. The remaining
four sections analyze the actual level of efforts of the industry as
a whole and the major manufacturers - General Motors (GM), Ford, Chrysler,
and American Motors (AMC) - with only some brief references to foreign
manufacturers. In the opinion of the report team, what the domestic
manufacturers have or have not done is of the greatest relevance to
*The 0.4 gpm NOx standard is to be met in conjunction with standards
for Hydrocarbons of 0.41 gpm and 3.4 gpm of CO. The designation for
emissions used in this report will be such that the above mentioned
standards are denoted by 0.41 HC, 3.4 CO, 0.4 NOx.
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the issue of good faith efforts; In any case, review of the foreign
manufacturers' submittals indicated little difference in basic approach
between the foreign manufacturers and the domestic manufacturers.
The submittals of all manufacturers were generally somewhat
less than fully adequate. Some foreign manufacturers did not respond
at all. However, the short time in which the manufacturers had to
reply possibly influenced their submittals, making most of the results
just copies of earlier submissions.
In addition to the submittals, the report team has reviewed
other documentation, primarily manufacturers' Status Reports and
suspension applications.
One obvious characteristic of almost all of the domestic
manufacturers' development programs is a fairly recent upsurge of
effort.
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Section 1 - SUMMARY AND CONCLUSIONS
The state-of-the-art of NOx emission control technology is
such that most manufacturers will be unable to certify vehicles
at 0.41 gpm HC, 3.4 gpm CO, and 0.4 gpm NOx for the 1978 model
year. Most manufacturers have not developed the advanced prototype
systems required for certification at the fall statutory standards,
and inadequate lead time remains for development and testing of a
full line of prototypes to meet market demand in 1978.
A comparison of emission expenditures with sales and profits
in 1973 and 1974, shows that emissions research in 1974 was not
significantly reduced even when profits were substantially lower
than those in 1973. Chrysler, x^hich stated that it spent 33-40%
of its emission budget on NOx control, only reduced its emission
expenditures by 10% at the same time it reported a loss of $52
million and its unit sales dropped 25%. Similarly, both Ford
and General Motors reported a substantial drop in earnings while
emissions expenditures rose 19% and 46% respectively. The issue
of whether the expenditure levels for 1973 and earlier years
constitute a good faith effort was essentially dealt with in the
1973 NOx Suspension decision, in which EPA found that the sums
spent by the manufacturers were adequate to satisfy a "good faith
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effort." As a proportion of their total research and development
budgets for 1974 the fractions allocated by those companies to
emission control development were 16% for GM, 22% for Chrysler, and
24% for Ford. Therefore, based solely on resource commitments, it
is difficult to find fault with tae auto companies priorities when
related to the financial condition of the industry in 1974.
A review of the record of manufacturers' and vendors' research,
development, and testing and evaluation programs, however, shows
that:
The automotive industry has not in most cases
combined all of their best systems on test vehicles.
The automotive industry has not vigorously pursued
and fully exploited the developments of independent
vendors.
The efforts of some auto manufacturers directed
toward the 1978 statutory emission standards have
dramatically decreased during the past year.
Some manufacturers have redirected their alternate
engine problems toward a 2.0 NOX level rather than 0.4
NOX.
Some manufacturers have redirected their efforts
from dual catalyst systems to 3-way catalysts which appear
at the present time to require more research to establish
their durability and, hence, longer leadtimes before
implementation than dual catalyst systems.
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Taken in their entire context, the above conclusions suggest that
a maximum effort was not made by the automobile industry to meet
the 1978 emission standards of 0.41 gpm HC, 3.4 gpm CO, and 0.4 gpm
NOx. The question of whether all good faith efforts were made, however,
must also take into account the following considerations:
As early as 1972, EPA disclosed that an error was
made in the Federal Reference Method measurements of
ambient N0_, which formed the basis for the 0.4 gpm NOx
emission level, resulting in an overstatement of the number
of cities and amount by which cities would violate the 100 ppm
NO,, ambient air quality standard.
In reconsideration of the need for 0.4 NOx, EPA
suggested to Congress in a letter to Senator Randolph dated
November 11, 1973, that the timetable for reaching statutory
NOx be stretched out with 2.0 NOx required from 1977-1981,
1.0 NOx from 1982-1989, and 0.4 NOx not required until the
1990 model year.
Congress has not resolved the uncertainty raised by
the EPA disclosure and recommendations. Congress has delayed
the implementation of the 0.4 NOx standard by one year, but
has not dealt with the greater issue of x^hether or not
0.4 NOx is still required to protect public health.
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As explained in Section 2 - Background - this report provides
objective information on the magnitude of efforts but refrains from
making a conclusive "determination" on good faith. In particular,
this report does not conclude whether the complicating considerations
just listed provide any justification for lack of adequate efforts,
although in a strictly legal sense only an actual change in the
statute - not mere recommendations and discussions - v/ould absolve
a company of its obligation to make all good faith efforts.
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Section 2 - BACKGROUND
The 1970 Clean Air Act Amendments
The 1970 Amendments represented a major change in the legislative
approach toward controlling automobile emissions. The Amendments were
technology forcing, i.e., when they were passed the technology to
meet the requirements was not available and the purpose of the
Amendments was to force the needed development.
Under the 1970 Amendments, the EPA Administrator could consider
requests from automobile manufactueres for a one-year suspension
of the legislated standards. In acting on suspension requests, the
Administrator was required to rule on each of four criteria: (1)
public welfare or public health, (2) technological development, (3)
a report from the National Academy of Sciences and (4) the exertion
of all good faith efforts on the part of the manufacturers to meet the
standards. Section 202(b)(5)(c).
Before this report was written, there was no published EPA
"methodology" that could be used to determine good faith. This is
in contrast to the methodology used by EPA to determine the technical
capability to comply with the standards. The technical methodology
has been the subject of discussion during the various EPA suspension
hearings, and also was an area in which EPA received some guidance
and direction from the Court of Appeals in International Harvester
versus Ruckelshaus. It is more difficult to produce a quantitative
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"methodology" for a good faith determination. Attempts have been
made in the various decisions of the Administrator on manufacturers'
requests for suspension of the statutory standards. This chapter
will expand somewhat on those previous discussions. This is, of
course, an issue on which interested parties are likely to comment,
and we invite them to do so.
Ideally, an analysis of the good faith efforts toward meeting
any emission standard should start with a universally agreed-to
definition of good faith. Unfortunately, such a definition is not
available. Therefore a review has been made of what has been
previously published on the good faith issue.
EPA has acted four times on applications for suspension. These
four decisions in chronological order are for convenient reference
referred to on the Original Decision (1972), the Remand Decision
(April 1973), the NOx Decision (July 1973) , and the Sulfate Decision
(1975) in this report.
Listed below are the key good faith aspects of the four decisions:
Decision Good Faith Implications
Original (HC, CO) No good faith determination specifically
(May 1972) made. The Administrator considered that
his denial, based on technological
feasibility, did not require a specific
decision on the other three issues.
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Decision (cont.) Good Faith Implications (cont.)
Remand (IIC, CO) The ''nuclear deterrent" aspect of a non-good
(April 1973) faith finding was discussed, and the
implication was that a finding of less
than all good faith efforts would require
a sanction too severe to employ.
NOx The severe consequences of the "nuclear
(July 1973) deterrent" were again mentioned.
Sulfate (HC, CO) Good faith was considered to be essentially
(March 1975) met since the standards could be attained
and meeting the standards was considered
to be good faith.
What is "Good Faith"?
The Original Decision made the first time the automobile
manufacturers applied for suspension of the HC and CO standards. It
was a denial, and the resulting judicial review (International Harvester
vs. Ruckelshaus) led to the Hearings on Remand and the Remand Decision.
In the Original Decision the Administrator did not make a definitive
determination on good faith. His reading of the law was that since
the technology was available, in his opinion, he was not under the
law required to make a specific good faith determination.
He did, however, provide a discussion of the good faith issue.
After a discussion of the monetary expenditures of the applicants,
he said:
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"that the level of expenditure of the automobile industry
as a whole would appear to meet the test of good faith and
to be consistent with the intent of the Act."
However, he went on to say:
"It is clear that a substantial financial commitment
to emission control research and development is not a
sufficient basis by itself for me to find that all good
faith efforts have been made by an applicant. In my view,
I am empowered to make the required determination on good
faith only if a. manufacturer's overall program for
compliance with 1975 emission standards has been clearly
structured with a view to achieving timely compliance
with the Act's requirements if possible and has been
expeditiously executed. The manufacturer must have or
create adequate in-house capability to develop and test
necessary components, or he must provide necessary
assistance to independent developers and vendors of such
components or show why such assistance is not necessary.
Equally important, the manufacturer must establish and
implement a system which adequately integrates his own
development program with those of suppliers on whom he is
likely to be dependent. The manufacturer's development
program must include adequate provision for promptly
testing promising technology as it is developed, and he
must react promptly and reasonably to the test results
which are forthcoming."
In other words, good faith involves not only the commitments
of resources, but also the use of those resources. Conversely,
however, the failure to commit substantial resources may constitute,
in effect, a prima facie indication of a lack of good faith, and
will impose a much heavier burden on the company seeking to show
that all good faith efforts have in fact been exerted.
In the court decision to remand the Original Decision to EPA
on certain technical grounds, the Court of Appeals for the District
of Columbia Circuit also suggested that explicit determinations be
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made on all four issues before the Administrator (public interest
or public health, good faith, availability of technology, NAS report)
In the Remand Decision, the Administrator dwelt at length on
the good faith of Chrysler, analyzing both resource commitment and
research and development decisions. In the end he found all the
applicants in good faith. The difficulty faced by the Administrator
on the good faith issue was mentioned in his press conference
revealing his Decision where he said:
"The issue of good faith as it relates to Chrysler
Corporation has been particularly troublesome for me
in these proceedings. I have covered this issue in
some detail in my decision and will not dwell on it
here. If Congress had provided me with some sanctions
short of the nuclear deterrent of in effect closing
down that major corporation, my findings on good faith
may have been otherwise."
In a sense, he considered the "punishment", denial of the
suspension request and shut down of production) too severe to fit
the nature of the ''crime'' (lack of good faith) .
The "nuclear deterrent1' issue also influenced the next EPA
decision, the NOx Decision. In it, the Administrator said:
"The good faith question is little changed from prior
hearings. As in May 1972, I am disturbed by the apparent
lack of adequate coordination between automobile companies
and catalyst supplier.
As before, however, the evidence, when weighed with an
eye to the drastic consequences of a denial of suspension
on this ground, supports the conclusion that the
requirements of the statute have been met."
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In the most recent decision, the Sulfate Decision, after some
discussion of the manufacturers' expenditures, the Administrator
said:
"By the standards of past suspension decisions, these
expenditures would be taken as sufficient to satisfy
the "good faith" test in its financial aspect. What
is more disturbing is the significant decline since
1Q73 in emission testing of vehicles (except for testing
by Ford) aimed at meeting the statutory HC and CO emission
standards. This drop-off is clear from the face of the
Technical Appendix."
In other words, the Administrator was again looking beyond the
mere commitment of resources to the decisions made as to the use
of those resources. The Administrator went on to say:
"There might be some difficulty in making a finding
of good faith in the face of such a testing effort
but for one factor. The industry, both the NAS and
my technical staff agree, has developed the technology
to attain the statutory HC and CO standards in the 1977
model year. Since there is no requirement that a
company spend more than is needed to meet the standards,
the success of the auto industry here warrants a finding
of 'good faith' by definition."
This final addition to the approach to evaluating good faith is
based on the fact that the primary goal of the statute is attainment
of a fixed standard, and efforts are only required insofar as the
standard is still unmet. A similar view of the technology forcing
aspect of the Act was recently expressed by the U.S. Supreme Court
in Train versus N.R.D.C., U.S. , 7 ERC 1735, 1745, 43
L.W. 4467, 447^ (April If., 1^75).
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Finally, it should be mentioned for the sake of completeness
that the Administrator has recently made the first "good faith"
determination under section 110(f) of the Act - a provision
essentially identical to section 202 (b) (5)(c), but applicable
to stationary sources. In re: Application of the Governor of
West Virginia Pursuant to Section 110(f) of the Clean Air Act
for One-year postponement of applicability of standards, pocket
no, CAA-1 (April 29, 1975). In that decision, the Administrator
found some compliance in good faith and others not in good faith
as to their efforts to achieve compliance with the regulations
with regard to certain electric plants for the latter be denied
extenious of the applicable emission standards.
"Good Faith" and Maximum Effort''
A good faith determination involves both an objective investigation
and a subjective conclusion. The remainder of this report will deal
with the report team's investigation of the objective facts and to
the level of efforts made by the automobile industry. It is believed
that this is the information requested by Senator Muskie's letter of
November 18, 1974. Since the Clean Air Act does not currently
provide for the Administrator making an actual "determination" on
good faith with regard to the 1978 NOx standard, the drawing of
conclusions amounting to such a determination is in the hands of the
Congress.
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Section 3-RESOURCI<; COMMITMENTS
The following analysis deals with resource commitments and does not
focus on technological questions. The data presented here is primarily
from the February 1975 submissions of the manufacturers in response to
EPA's request for data of January 6 and 27, 1975.
Adequacy of the Data
The data on resource commitments submitted by the manufacturers was,
with few exceptions, disappointing. Only three manufacturers (Ford,
Chrysler and Renault) submitted a detailed breakout of expenditures
directed towards NOx control. All others submitted only the expenditures
and manpower of their total emission control development program, claiming
that their accounting procedures were inadequate to give more detailed
information. In addition, differences in both accounting practices and
methods of differentiating between NOx control expenditures and all other
expenditures make it difficult to compare one company with any other or to
analyze expenditure patterns in a meaningful way.
Domestic Manufacturers' NOx Control Efforts
Table 3-1 presents the expenditures and manpower committed by the
large domestic manufacturers to efforts for meeting the 1978 statutory
NOx standards of 0.4 gm/mi. As shown in the table, there is a wide
variation in the estimated percent of total emission expenditures directed
towards NOx control, from 7% for Ford in 1973 to 40% for Chrysler in the
same year. However, this difference may be misleading. Following EPA's
follow-up request on March 28, Chrysler developed its data hurriedly,
whereas Ford included the data in its March 3 submission and had time
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to obtain more exact results. In either case, this data should not be
viewed in isolation, but should be considered in conjunction with the
technical evaluation to understand its significance.
Ford was the only domestic manufacturer to submit detailed
project expenditures for NOx control. In Section II of the March 3, 1975,
submission (attached), Ford estimated that 47% of its total 1973 financial
commitment to NOx control and 75% of its variable expenditures occurred in
only four projects: (1) R&D for systems designed for meeting 1978 Federal
Standards, (2) closedloop emission research, (3) catalyst component
research, and (4) EGR systems research. Over the four projects, the average
proportion devoted to NOx control was 57%. Although no such detailed
comparison can be made for Chrysler and General Motors, it is quite likely
that projects such as those listed above are also the principal research
efforts for NOx control at these companies as well.
The data shown in Table 3-1 and Appendix C show that a substantially
higher proportion of Chrysler's emissions expenditures has been for NOx
control than has been the case for Ford or General Motors. This is
curious, for Chrysler is an aggressive advocate of the non-catalytic
approach to emissions control, a system which cannot meet the statutory
NOx standard. Thus, the expenditures data submitted by Chrysler seems
at odds with its public stance, which has been in opposition to the need to
control NOx to statutory levels. Since no detailed project expenditure
schedule was submitted which shows NOx vs. HC/CO expenditures, this question
cannot be investigated further.
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General Motors, while submitting financial data on its expenditures
for NOx control, submitted no data on the proportion of its emissions
expenditures committed to NOx versus EC/CO control. As justification for
this, in its March 31, 1975 submission, Section VIII, GM stated:
"Segregating expenditures or manpower data to the extent that they
are specific to a federally mandated standard (such as the 1978 oxides
of nitrogen standard) is exteremely difficult. This is attributed to
the fact that the technology itself cannot be isolated. As stated
numerous times, standards set for hydrocarbons and carbon monoxide
emissions affect the development of the oxides of nitrogen control
systems because the control technologies interact. Since the control
technologies cannot be isolated technically, they cannot be segregated
by cost. Emission devices currently installed in many of our vehicles
will continue to be used in both the 1977 and 1978 systems, with
improvements being made to these devices where necessary. Consequently,
the financial and manpower data filed with our request for suspension
of the 1977 emission standards is relevant to the 1978 standard and
should be considered as part of our response toward meeting the oxides
of nitrogen standard for 1978."
As a consequence, in contrast to Chrysler and Ford, GM did not submit a
detailed analysis of its NOx expenditures. The estimates for GM given in
Table 1 were based on data submitted by GM in its January 1975 Application
for Suspension of the 1977 Emission Standards. Project expenditures for
NOx control were estimated for those projects most closely associated with
NOx control technology. Those projects and their weighting factors
included: catalyst research (50%), Questor system (100%), single catalytic
system (100%), air injector reactor system (50%) exhaust gas recirculation
(100%), controlled combustion system (50%), and fuel injection (100%). The
use of different weighting factors or choices of projects could markedly
change the estimates.
Table 3-2 shows the relationship between emission expenditures, total
research and development expenditures, and market sales for the three
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TABLE 3-1
EMISSIONS RESOURCES FOR NOx CONTROL
Chrysler
Ford
General
Motors 3/
Total
Nox Emission Control Expenditures (Million$) I/
*1973
Expense
$13.7
- 1471
21.9
$49.7
Percent of
Co. Total
(40%) ~~"
-r- ~
(18%)
(12%)
'l974
Expense
$10.9
- 17. 8
18.4
$47. 1
Percent of
Co. Total
(33%)
( 9%)
(16%)
(11%)
TVTDv T?niTiT-a1»v>* TTV^. rxV.-rv.-,.-,"-.-,-; 9 /
"J ~-- --- -^.. -
Chrysler
Ford
General
Motors 3/
1973
Employ.
475
987
^ ercent of
.- Co. Total
(44%)
Not Submitted
(20%)
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TABLE 3-3
U.S. AUTOMOBILE INDUSTRY FINANCIAL DATA. 1974 vs 1973
Unit Sales (OOO)i/
American Motors
Chrysler
Ford
General Motors
Total
Sales (Million $p/
3/
American Motors^
Chrysler
Ford
General Motors
Total
Profits After Taxes (Million *)
American 'iotors*^'
Chrysler
Ford
General Motors
Total
Jmission Control Expenditures (Million
3/
American Motors7
Chrysler
Ford
General Motors
1974
354
1,221
2,619
3.651
7,845
$2,000
10,971
23,621
31,550 "
$68,142
$28
(52)
361
950
$1,287
$)
$4-8
42.8
357-3
450.7
1973
390
1,629
2,940
5,261
10,220
$1,739
11,774
23,015
35,798
$72,326
$66
255
907
2^398
$3,646
$4.6
47-5
299.2
309.5
1974 over/
jUnder) 1973
(Percent)
(25/0)
(ll/o)
3/0
2fo
(6/0)
(I20/o)
(60/o)
Total $660.8 $855.6 29$
ote: 1. Factory sales in the U.S., including those from Canadian plants.
2. Worldwide sales, both automotive and non-automotive.
3« Results given for the AMC Fiscal Year ending September 30.
3URCE: Annual Reports, Motor Vehicle Manufacturers Association Statistics,
and Manufacturers' Submissions to EPA.
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largest domestic manufacturers. Table 3-3 lists the major U.S. automobile
manufacturers' financial statistics and emissions expenditures for 1974
compared to 1973.
Table 3-3 shows that although unit sales decreased 23% and profits
fell by 65%, emission expenditures increased 29%. Chrysler, which reported
a loss of $52 million in 1974, only reduced its emissions budget by 10%.
To show this change in perspective, Chrysler had almost one-half of its
work force laid off during the last quarter of 1974 as its production
declined precipitously to bring its inventories in line with sales. During
one point in late 1974, Chrysler had approximately one-fourth of its
engineering staff on leave. As a result, Chrysler's emission expenditures
reflect its difficult financial condition more than do the expenditures of
Ford or General Motors. The emission expenditures for Ford and General
Motors increased 19% and 46%, respectively, from 1973 to 1974, even while
profits for the two companies were declining 60%.
Foreign Manufacturers
Except for Renault, foreign manufacturers submitting data in response
to the EPA request could not segregate out expenditures for NOx control.
In fact, due to deficiencies in their accounting systems, most of the
manufacturers state that they cannot separate out emissions expenditures
by project. In addition, only thirteen foreign manufacturers responded at
all to EPA's request for information relating to their efforts toward meeting
the 1978 NOx emission standard.
Table 3-4 lists the total emissions expenditures for manufacturers
submitting data. Several manufacturers submitted data on technical achievements
but this did not include expenditures data.
3-4
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Section 4 - NOx CONTROL TECHNOLOGY
The significance of the NOx emission control technology available
currently is most meaningful when put in the context of the historically
available technology. To establish the background of NOx control work
that preceded the 1970 Amendments to the Clean Air Act, a review has
been made of the technical literature available prior to the passage of
the amendments. The bulk of the work done in the area of automobile
emission control technology development during that time frame was
reported through the Society of Automotive Engineers, Inc. (SAE), the
professional society which has received the greatest support from the
engineers and scientists involved in research and development projects
on automobile emissions. Besides the SAE literature, several of the
reports of the Inter-Industry Emission Control (IIEC) program were
available to the report team. IIEC is a group consisting of representatives
of:
Ford Motor Co.
Mobil Oil
American Oil
SOHIO
Mitsubishi
Nissan
Toyo Kogyo
Other organizations have also been represented. The members of IIEC
independently work on projects but meet periodically to share the results
with, and receive comments from, other members. Beyond 1970, the avail-
4-1
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ability of literature was expanded significantly by the provision of the Act
which required manufacturers to periodically report their progress in the
emission control technology area to EPA. Annually the EPA's Emission
Control Technology Division (ECTD) has requested and received status
reports from nearly all automobile manufacturers. These reports, which
often are several hundred pages in length, have covered work which is
not generally reported through publication. In addition, coverage is
given to work which is reported in other technical papers and reports.
These status reports formed the basis for the following ECTD reports
which summarized the status of automobile emission control technology:
1. Automobile Emission Control - A Technology Assessment
as of December 1971.
2. Automobile Emission Control - The State of the Art as
of December 1972.
3. Automobile Emission Control - The Development Status
as of April 1974.
4. Automobile Emission Control - The Technical Status
and Outlook as of December 1974.
NOx Control Technology Prior to December 1970
SAE publications in the area of automobile emissions first appeared
in 1955. In a paper 1 entitled "Automobile Exhaust and Ozone Formation,
A. J. Haagen-Smit of the California Institute of Technology and Margaret
IHaagen-Smit & Fox, "Automobile Exhaust and Ozone
Formation", SAE 421, Jan. 1955.
4-2
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M. Fox of the Los Angeles Air Pollution Control District surfaced
the need for automobile emission control concluding:
"Ozone has been found to be a substantial part of the
oxidant characteristic of Los Angeles smog. Since
automobile exhaust gases are capable of forming ozone
in the air, they are considered a definite cause of
smog."
Initial activity in the auto emission control areas concentrated
on the control of FC emission. As early as 1957, work on catalytic
2
converters v,Tith 80% hot efficiency for HC had been reported. Most
of the early literature does not include any information of the effect
of various HC control measures or other parameters on NOx emissions.
The lack of activity in the area of NOx emissions was the result of the
singular concern for working on the "smog" problem. NOx by itself
was not considered a pollutant but only one of the ingredients in the
chain of reactions which result in the formation of photochemical
smog. The relationship between NOx and photochemical smog was shown
to be such that, for the level of HC and NOx occurring in Los Angeles
air, reductions in NOx tended to increase smog formation. As recently
-5
as 1966 in a paper " by Caplan of GM the following statement was made:
"The results of studies of atmospheric chemistry of smog
formation serve as guidelines for determining a rational
basis for control of vehicle emissions. These guidelines
indicate the desirability of reactive hydrocarbon reduction
and the futility of nitric oxide reductions from vehicles."
(Emphasis added)
2. G. J. Nebel, "Automobile Exhaust Gas Treatment - An
Industry Report," SAE 173, Aug. 1957.
3. J. D. Caplan, "Smog Chemistry Points the Way to Rational
Vehicle Emission Control" SAE Transactions Vol. 74, 1966.
4-3
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By 1966 however, more consideration of NOx control began
appearing in the literature. The increase in NOx control work was
due in part to the adoption by the California State Board of Health
of NOx emission standards in October 1965.
Separately NOx control work had appeared in the literature
previously:
R. W. Bishop & G. J. Nebel, "Control of Oxides of
Nitrogen in Automobile Exhaust Gases" Industrial
Hygiene Foundation, 1957.
R. I). Kopa & H. Kimura, "Exhaust Gas Recirculation
as a Method of Nitrogen Oxides Control in Internal
Combustion Engines", APCA, 1960.
G. J. Nebel & N. W. Jackson, "Some Factors Affecting
the Concentrations of Oxides of Nitrogen in Exhaust
Gases from Spark Ignition Engines", APCA 1958.
4-4
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The Nebel & Jackson Paper covered the effect of air fuel ratio and spark
retard on NOx emissions. Kopa , who reported some of the earliest EGR work,
reported in 1966 paper that 60% NOx reductions were possible without
economy degradation if EGR was used in conjunction with advanced spark
timing, indicating that the shifting of MET timing that occurs with EGR
usage was known and reported in 1966 despite the fact that most manufacturers
still fail to take advantage of this effect.
The 1965 Decision by California to go forward with Nox standards generated
the most significant industry opposition that had been experienced up to that
time. As stated by representatives of the California State Department of
Health , "Standards for oxides of nitrogen continue to be the most
controversial of all possible standards. The Automobile Manufacturer's
Association has strongly opposed such standards and has stated that the
control of these compounds will negate some of the benefits from hydro-
carbon control alone." It was also noted, however, the NOx control was
required for more reasons than just the role played in the formation of
photochemical smog, "These compounds have a multiple role in air
pollution. Aside from being a necessary ingredient in the photochemical
reaction, nitrogen dioxide is a toxic gas and it is highly colored.
Benefits of reducing possible health hazards and coloration of the
atmosphere are expected with the control of oxides of nitrogen."
5. R. D. Kopa, "Control of Automobile Exhaust Emission by
Modifications of the Carburetion System" SAE Paper
660114, Jan. 1966.
6. J. A. Maga & J. R. Kinosian, "Motor Vehicle Emission
Standards - Present and Future, SAE Paper 660104, Jan. 1966.
4-5
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In 1967 the IIEC group also investigated water injection for NOx control.
Significant reductions were determined to be possible with high rates
of water usage.
Combustion Chamber modifications for NOx minimization were reported by
New Hall and EL Messiri in 1970.7
Although early emission control work concentrated on HC emissions, prior
to the passage of the 1970 Amendments essentially all basic approaches to
NOx control had been investigated and reported. The groundwork necessary
for a rapid expansion of NOx control research and development had, therefore,
aready been completed.
The State of the Art as of April 1975
NOx Catalysts - Since the passage of the 1970 Amendments, the most significant
progress in NOx control technology has been made in the area of catalyst
refinement. Early NOx catalyst work showed problems with rapid deter-
ioration, attrition and ammonia formation. Some of the so-called catalyst
problems were the result of less than desirable control of the basic
engine operating parameters (especially air/fuel ratio control). Significant
differences have been observed between the performance and durability of
various catalysts in laboratory tests and in vehicle tests. Catalyst
formulation improvements have, however, resulted in catalysts with
greater tolerance for non-ideal operating environments.
7. H. K. Newhall & U. A. ElMessiri, "A Combustion Chamber
designed for minimum Engine Exhaust Emissions," SAE
Paper 700491, 1970.
4-6
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A unique approach to the operating environment problem has been developed
by the Emission Controls Division of Gould, Inc. With the addition of an
oxygen removal catalyst or "getter" to their metallic dual catalyst system,
the lean excursions which cause deterioration of the NOx catalyst itself
have been eliminated. The Gould system has demonstrated NOx levels close to
the 0.4 limit during durability tests of over 25,000 miles. When used in
conjunction with advanced engine modifications and EGR systems it is
estimated that certification to the 0.41 HC, 3.4 CO, and 0.4 NOx levels
may be possible, provided catalyst changes are made at 25,000 miles. An
unresolved issue with the Gould system is that of particulate emissions.
Preliminary data suggests some attrition of the nickel based catalyst
is still occurring. Further data is necessary to assess the degree of
this potential problem.
Matching - Catalyst/engine matching has also been significantly improved
since the passage of the 1970 amendments with the development of feedback
control systems to tightly control air/fuel ratios. "Lambda" sensors,
which respond to the level of excess oxygen in the exhaust gases, can
provide a signal to a carburetor of fuel injection system for mixture
control. The most successful systems to date have relied on fuel injection
for more rapid and accurate response. When the excess oxygen content of
the exhaust is closely controlled by a feedback system, it is possible
to either:
1. Extend the life and efficiency of a NOx catalyst by
continually providing an optimum environment for the catalyst, or
2. Accomplish the simultaneous conversion of HC, CO, and NOx
in one catalyst bed.
4-7
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In now appears that exhaust sensors with 20,000 mile life and
modest ($5) replacement costs are available, as are the feedback and
fuel injection systems with which they are used. Two problems remain
with the feedback approach:
1. No 3-way catalyst has as yet demonstrated the capability
to maintain 0.4 NOx levels at high mileage in a domestic
vehicle.
2. The costs of fuel injection systems are much greater than
carburetors and U.S. manufacturers are hesitant to take on this
burden.
Oxidation Catalysts - Although not directly associated with NOx control,
major improvements in oxidation catalysts have improved the chances of
meeting low NOx levels in conjunction with the 0.41 HC and 3.4 CO
levels. The state-of-the-art oxidation catalyst technology appears capable
of providing 70% HC and CO conversion efficiencies at high mileage over
the LA-4 cycle.
EGR - EGR system refinements have been made in the laboratory with
Q
the most significant recent work being that of Gumbleton, et. al which
reported an EGR/engine calibration optimization technique which resulted
in 1.0 gpm NOx levels from full size cars without fuel economy penalties.
High HC emissions experienced with this approach reflect the relationship
between NOx control and HC control. Low-NOx adjustments can increase HC
emissions to the point that the 0.41 HC standard becomes tougher to meet
than the 0.4 NOx standard.
8. J. J. Gumbleton, R. A. Bolton, H. W. Lang, "Optimizing Engine
Parameters with Exhaust Recirculation," SAE Paper 740104
Feb. 1974.
4-8
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It is clear that optimum EGR scheduling will require more sophisti-
cated EGR systems than are currently available on production cars.
Work on electronically modulated EGR and spark timing systems has been
reported as successful and encouraging in the laboragory, but there have
been no commitments on production systems.
Reactor-Catalyst-Reactor - The "Questor" type concept of combining thermal
oxidation of HC and CO with catalytic reduction of NOx has shown consider-
able potential for achieving 0.41 HC, 3.4 CO, 0.4 NOx standards. Tests
of the Questor system by several manufacturers have been below the '78
levels even on full size cars. The problems that are yet to be solved
are associated with the degree of mixture enrichment and high temperatures
necessary to achieve adequate control of HC, CO and NOx. The rich mixtures
used with the system cause some fuel economy degradation and result
in high exhaust temperatures which have caused some system degradation
during mileage accumulation. Over a three year time frame, however,
the fuel economy penalty associated with the Questor system has been
reduced from a 20% loss to essentially no loss relative to 1974 models
(13% lower than 1975 models).
Fuel Metering - Improvements in fuel metering systems have been made since
1970, the most notable example being the Dresser carburetor. The dresser
system uses a single fuel circuit and variable area throat to maintain
sonic flow conditions over most of the engine's operating range. The
ability to accurately control air flow and achieve fine atomization with
this concept will benefit any carbureted system, but thus far only lean-
burn systems have been considered.
4-9
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Alternative Engines - A summary of the current state of the art in NOx
control would not be complete without mention of several alternative engine
approaches.
Honda's CVCC stratified charge engine has been demonstrated to be capable
of bringing even full size cars into compliance with 0.41 HC, 3.4 CO, 2.0
NOx levels with essentially no fuel economy penalty. With spark retard
and EGR usage NOx levels can be lowered to the .25 gpm level on small cars,
providing adequate cushion to meet a 0.4 standard. A problem at this
calibration level is fuel economy, which is degraded by about 20%.
Toyo Kogyo has made major improvements in rotary engine control
technology in the last 5 years. Current stratified charge rotary proto-
types show potential for meeting 0.41 HC, 3.4 CO, 0.4 NOx. Prototypes have
achieved .33 HC, .17 CO, .38 NOx with fuel economy superior to current
1974 and 1975 production versions of the engine. (This economy level
approaches that of conventional engines.)
Ford has shown that its PROCO stratified charge engine is capable of
achieving 0.4 NOx in 4500 pound cars without catalytic NOx control. The
combination of stratified charge combustion and high EGR tolerance of the
PROCO combustion system makes this possible. Hydrocarbon emissions,
rather than NOx, have presented the greatest problem. While the PROCO
vehicle can simultaneously achieve 0.41 HC, 3.4 CO, 0.4 NOx with oxidation
catalysts, HC levels have exceeded .41 prior to 25,000 miles of durability
at the 0.4 NOx calibration. In an uncontrolled state the PROCO engine
can deliver substantially better fuel economy than conventional engines,
4-10
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but it has high HC emissions. Achievement of low HC levels has so far
required the use of throttling which makes the engine's economy comparable
to conventional engines. Once the throttling has been used for control
of HC emissions, further control measures such as EGR for lower NOx have
little effect on fuel economy.
GM has reported that its latest prototype turbine vehicle has met the 0.4
NOx level in preliminary tests. Such performance potential has been fore-
casted in the past but the GM tests are the first actual demonstration of
the tubine's potential to meet the '78 standards. Problems with the turbine
as an alternative engine remain in the areas of cost, fuel economy and
possibly particulate emissions.
Limited data available from Daimler-Benz has indicated that the Diesel
engine has also met the 0.41, 3.4 0.4 levels in prototype tests with the
use of EGR for NOx control. Potential problems with smoke levels with
0.4 NOx calibrations have been suggested by Daimler-Benz but no hard data
quantifying absolute smoke levels is available to EPA. The potential of
the light duty Diesel is still largely unknown due to the lack of effort
in the Diesel area by industry and government alike.
Summary Current NOx Control Technology
In summary, the current status of NOx control technology is such that
prototype certification at the 0.41 HC, 3.4 CO. 0.4 NOx levels may be
possible in the near future with any of the following systems:
4-11
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1. Honda CVCC with EGR in subcompact vehicles
2. Gould Getter metallic NOx catalyst-oxidation catalyst system,
all vehicle sizes, catalyst changes possible required.
3. Questor system, small vehicles (large cars may not meet CO
levels).
4. Prechamber Diesel with EGR in small vehicles
5. PROCO stratified charge with oxidation catalysts.
6. Turbine
Potential problems with unregulated pollutants need to be further
investigated with options 2 through 6. Some of the systems had demonstrated
a tendency toward high or possibly harmful particulate emissions.
Potential for Future Development
Assuming funding is available, many areas of development could lead
to improvements in NOx control technology. Three areas, however, seem to
have the greatest potential: (1) catalyst refinement, (2) improved engine
programming and (3) advanced HC control techniques development.
Catalyst Refinement
The progress in the area of catalyst improvements has been such that the
successful development of a durable 3-way catalyst is not out of the
question. The 3-way catalyst system has so far received a clean bill
of health in the unregulated pollutant area. No attrition products
have been identified and sulfate formation across the catalyst appears
to be extremely low, based on limited testing to date.
4-12
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Work recently reported to EPA by Exxon indicates that some progress
has also been made in the area of noble meta] NOx catalysts. Prototype
catalysts have shown good low mileage NOx control and substantial HC and CO
elimination. Further work is needed to solve persistent durability
problems.
Improved Engine Programming
The engine programming area seems to hold considerable promise for
future work. Evidence suggests that the optimization of engine calibrations
for low emissions is not possible from exclusively steady state engine
mapping. Optimum spark timing, EGR rate and air/fuel ratio all appear to
be functions of the rate of change of speed and load in addition to the
absolute value of speed and load. Very little information is available in
the literature concerning transient optimization work. In addition to the
basic research needed, spark air/fuel ratio and EGR systems that are fully
programmable need to be developed. Many manufacturers who have suffered
fuel penalties in meeting emission standards have done so because of crude
programming techniques for EGR and spark timing. With electronically
controlled fuel, EGR and spark systems, significant emission reductions
without fuel penalties may be possible. Chrysler and GM are both known
to have worked in the programming area but more is required.
HC Control
Improved HC control techniques offer potential for lower NOx emissions
because of the relationship between HC and NOx emissions that exists with
some NOx control approaches. High EGR rates and high-turbulence combustion
chambers can produce significant NOv reductions without fuel economy
penalties, but such techniques cause higher HC emissions which must be
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controlled. i'ne use ot HC control techniques that degrade economy
(e.g., spark retard) may therefore cause the achievement of low NOx to
be erroneously identified as an inherent cause of poor fuel economy.
Some further improvement in oxidation catalyst efficiency is
anticipated but more significant improvements may be possible with
other approaches such as:
1. Heat conversion
2. Start catalysts
3. Cold storage
Heat conversion techniques such as port liners, ceramic pistons,
etc., would reduce catalyst light off temperatures and increase thermal
oxidation in the exhaust system. Both of these effects would lower HC
and CO emissions with insignificant effects on NOx. Little work has been
reported in this area.
Start catalysts are currently under investigation at GM and Chrysler.
Several foreign manufacturers have reported work also. The most effective
approach considered to date has been GM's system which directs exhaust
through a small volume catalyst located close to the exhaust ports during
start up. This catalyst achieves rapid light off and holds emissions down
until the larger, main catalyst can take over. When the main catalyst
reaches operating temperature, the start catalyst can be switched off
stream to prevent the deterioration that might occur if left in this
position continuously during all vehicle operating modes.
Cold storage of hydrocarbons is another approach that may warrant
further development. Temporary adsorbtion of the cold start HC emissions
in a bed of activated charcoal is a complex but effective approach which
may be desirable on some engines that would be suitable except for a
serious cold start emission problem.
4-14
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In summary, it is the judgment of the report team that considerable
potential for NOx control technology improvement exists. The rate of
progress that can be anticipated depends on the motivation of the auto
industry to pursue a low-NOx emission goal.
4-15
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Section 5 - PROGRAM REVIEW
One aspect of considering the magnitude of efforts that have been
made by each manufacturer to achieve the statutory standard is a review
of manufacturers' research and development programs. The magnitude of
efforts has been measured by whether a manufacturer has investigated,
evaluated and developed, fairly and with good engineering practice,
each and every technique, approach, or combinations of techniques and
approaches that have a possibility of meeting the standards in question
in essence, whether each has left no stone unturned.
If a manufacturer is successful in meeting the standards, the
question of the magnitude of his efforts is not relevent since there is
no requirement that he do more than necessary to meet the standards.
Though this may seem to be a small point, it does cover the special
case of Honda which can meet 0.41 HC, 3.4 CO, 0.4 NOx with the CVCC
approach on Civic-sized vehicles.
The applicable time frame for investigation is December 1970
(passage of the 1970 amendments) to the present. This means that the
systems and approaches under consideration include those known in
December 1970, and those developed, introduced or discovered since
that time.
By its nature, the analysis of the level of efforts lends itself
to a qualitative, instead of a quantitative approach. Much effort was
expended on investigations of a quantitative rating methodology, but an
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acceptable scheme could not be designed during the preparation of
this report.
Efforts are considered in terms of "programs" and "projects".
This breakdown has been used to show the general scope of the efforts
(programs) and the details of how the programs were conducted (projects).
Projects are discussed in Section 6 of this report.
A program is a general technique, approach or system for achieving
low emissions. One or more projects make up a program. A project
can be as detailed as a specific vehicle. For example, there is a
Metallic NOx Catalyst Development Program, and in it a durability
vehicle with a Gould GEM-68 NOx catalyst system would be considered
a project.
The following list of programs is considered by the report team
to represent an effort of the type that, if conducted diligently and
with good engineering practice, would represent maximum efforts.
Programs
1. Cooperative Catalyst Development
When the 1970 Amendments were passed, catalysts of several types
for HC and CO control and for NOx control were promising concepts.
Some catalysts were known, having been developed by catalyst manufacturers
to meet California's early standards. Most, if not all, of the catalyst
expertise in 1970 resided with the catalyst manufacturers. A logical
approach toward the integration of catalyst control technology with
the conventional engine would have been to enter into a cooperative
catalyst development program with OTT* or more catalyst manufacturers.
5-2
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This would involve automobile manufacturers providing financial
support, manpower, and development facilities to the catalyst
manufacturers and the catalyst manufacturers providing catalyst
knowledge and personnel to the joint effort.
2. Combustion Studies
Effort in this area involves the study of the basic pollutant
formation and destruction in the engine and in aftertreatment devices.
There was much to be learned in this area in 1970.
3. Noble Metal NOx Catalyst
One of the promising NOx catalyst types uses noble metal
as the active material.
4. Base Metal NOx Catalyst
Base metals have promise for use as NOx catalyst. This property
has been known for years. Efforts in this area could have been
intensified in 1971.
5. 3-Way Catalyst
This is an attractive approach for controlling EC, CO, and NOx.
This subject could be the subject of a concerted effort, but starting
later than NOx catalysts.
6. Fuel and/or Fuel/Air Mixture Additives
One way to reduce emissions could be to modify the fuel and
fuel/air mixture.
7. Improved Fuel Metering
This is one of the keys to improvements in emission control.
Much room for improvement in this ar^a was apparent in 1970, and
5-3
-------
-------
an extensive effort would have seemed warranted. Especially important
is the sophisticated fuel metering required with NOx catalysts and dual
catalyst systems.
8. Advanced Exhaust Gas Recirculation Development
EGR was known as a control technique in 1970. Work could have
started then to optimize the systems and to search for effective ways
to control EGR rates.
9. Improved HC Control
Control of NOx to low engine-out levels can tend to increase HC
emissions. This has been known for a long time. Ways to improve HC
control are intimately tied to successful low NOx level control.
10. Ignition System Improvements
The ignition system is another key to emission control. Misfire
can be disastrous for catalyst systems, and flexible spark control
is desirable for an optimized system.
11. Combustion Chamber and Compression Ratio Studies
Changes in these parameters through cylinder head and piston
design can influence emissions greatly and are relatively easy to
make.
12. Improved Intake Manifolding
Good mixture distribution and minimum choking are requirements
for any low emission vehicle.
13. Rich Thermal Reactor
Rich thermal reactors were known to have good HC, CO, and NOx
potential in 1970.
5-4
-------
-------
14. Lean Thermal Reactor
A super-lean thermal reactor with EGR or a lean thermal reactor
coupled with other NOx control devices could have been a possibility
in 1970.
15. Air Injection Studies
Providing the optimum amount of air for catalytic or non-catalytic
systems was recognized early as an important area for investigation.
16. Oxidation Catalyst Improvement
This area is important for optimized 0.4 NOx systems, due to the
additional KG control necessary to meet 0.41 HC. This also would yield
benefits in fuel economy.
17. Alternative Engines
When the 1970 Amendments were passed, there was general agreement
that in the 1975-1976 timeframe a complete conversion to an alternate
engine was not possible for the domestic manufacturers. Therefore in
this report the general area of alternate engines is considered only
insofar as the conduct of the programs shed light on the attitude of
the manufacturers toward 0.4 NOx.
18. Reactor-Catalyst-Reactor System
This is the Questor or a Questor-like system. This system has
demonstrated impressive emission control. The optimization of such
a system by the manufacturers in a joint development program with
Questor or by themselves would seem logical.
5-5
-------
-------
19. Getter-Dual Catalyst System
This is a system like the one developed by Gould. The getter
helps control the 0 transients caused by inadequate fuel control.
2
This system is one of the most promising to date.
20. Chassis and Body Optimization
When the 1970 Amendments were passed there were no guarantees
to the industry that the types of vehicles in the future had to be
the same as the then current types. It was known that the lighter
vehicles theoretically have an easier time meeting NOx mass emission
standards, all other things being equal. Improvements that would
lower vehicle weight and improve NOx capability (and fuel economy)
were therefore an obvious area for investigation.
21. Vehicle System Synthesis Studies
All of the techniques, components and subsystems must eventually
be integrated into a complete vehicle package. A maximum effort
would investigate ways to predict the likely results from composite
systems to aid in vehicle system selection for development and
durability testing.
The above general discussions indicate the scope and the
breadth of a maximum effort.
The following summary chart gives the report team's estimates
of the level of effort exerted by the manufacturers in the 21 program
areas considered to be part of a maximum effort.
5-6
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-------
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Section 6 - PROJECT REVIEW
The previous section discussed whether certain programs were
undertaken. This section tries to answer the question "How well was
the effort expended?" The projects considered by the report team
are ones that have actually been worked on by the industry. This
analysis focuses on what actually was reported and how fair and complete
an investigation it was.
Project Evaluation Criteria
The projects were evaluated by considering the following
questions listed below which address how the project was run.
1. Were full effort systems tested? Did they contain the components
and subsystems known to be effective to reduce emissions or were some
components inadequate or missing? An example of a less than full-
effort system would be a NOx catalyst vehicle without EGR.
2. What efforts were made to find the cause of failures and
solutions? Failures and/or problems are bound to happen in development
programs. What was done about failures and/or problems? Was reasonable
judgment used to determine whether or not to continue the test? If
a problem occured, how many times was it fixed? If an outside developer's
system was involved, was an engineering effort made to fix the problem
by the manufacturer alone or in conjunction with the vendor? Could the
vendor fix it? Considering the vendor's expertise, should he have
been expected to have been able to fix it?
6-1
-------
-------
3. If a project was terminated or abandoned, why was this done?
Were any technical reasons given?
4. How does the apparent level of effort on any given project
compare to the apparent level of effort on other projects? In this
regard the relative emission control performance of the vehicles
in the projects is especially important.
fi-2
-------
-------
6.1 General Motors (GM)
General Motors is concentrating on the catalytic approach in
meeting the 1978 Standard. GM reported durability testing of four
categories of vehicles.
1. Dual catalyst vehicles on AMA durability.
2. Dual catalyst vehicles in customer service fleet operation.
3. Three-way catalyst vehicles on AMA durability.
4. Questor system cars on AMA durability.
Tables GM-1 and GM-2 depict the vehicles in three of the four
categories. The category not shown is the customer service fleet.
These vehicles were omitted because the reported information was
incomplete with regard to dates and system descriptions. The emission
performance of the fleet vehicles was poor. Twelve of the eighteen
fleet vehicles exceeded the '78 Standards at zero miles.
6-3
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i t
-------
-------
GENERAL MOTORS 1978 SYSTEMS
ZERO MILE EMISSIONS
System Type
CAR NO. Dual Cm.
61315B
61322
6132 2A
62356
62356A
62356C
62369
63303
63307
63339
63340
63341
63341A
63343
63344
64346
C-3321 3-way
77108
1750-37
1750-37C
1800-39
1800-41
1800-39A
1800-41A
1800-61
4213
2447 Questor
2483 Questor
HC_
.22
.42
.36
.30
.17
.36
.24
.28
.31
.26
.30
.22
.19
.37
.31
.25
.28
.38
.20
.48
1.4
.19
.36
.21
.23
.26
.10
.12
CO
(Grams/Mile)
1.1
3.1
1.7
2.2
1.3
3.1
1.8
2.2
2.8
1.6
2.2
1.3
1.7
2.4
1.3
.8
4.0
2.0
2.7
4.7
2.3
0.9
2.0
3.1
2.5
3.0
3.8
2.3
NOx
.22
.21
.27
.35
.35
- .34
.31
.19
.23
.32
.19
.27
.22
.28
.34
. .27
.37
.28
.13
.26
.10
.16
.20
.09
.29
2.66
.29
.36
Inertia Weight
4500
4500
4500
4500
5000
5000
4500
5000
5000
4500
5000
5000
4500
5000
5000
5000
5500
3000
2500
2500
2500
2500
2500
2500
2500
5500
5000
5000
-------
-------
All of the dual catalyst vehicles were full-sized Chevrolets
equipped with 350 cu. in. engines. GM reported that some of these
vehicles were equipped with their Triple Mode Emission Control
System (T-MECS) but its unclear from the vehicle descriptions as
to which are which. The T-MECS wa,. intended to improve catalyst
warm up and achieve thermal reactor action at high output by housing
the oxidation and reduction catalysts in the exhaust manifolds. The
majority of the dual catalyst vehi "Les were the more conventional
configuration with a reduction catalyst mounted close to each exhaust
manifold outlet and an underfloor oxidation catalyst. Vehicle No.
63446 was equipped with a closed loop control system for more
precise air-fuel ratio control. This vehicle achieved good low
mileage emissions, .27 HC, .78 CO, .27 NOx at zero miles, but
deteriorated rapidly. The best overall performance was given by
car no. ES63341A, which stayed within the 1978 Standards for
approximately 15,000 miles. The best NOx control was shown by
car no. ES-63307 which remained below 0.4 NOx for approximately
25,000 miles. Unfortunately, the reduction catalyst run on this
most successful car (Nippon Denso) was not evaluated on any other
vehicle.
Three of the ten 3-way catalyst vehicles were domestic cars:
two Cadillacs and one Vega. GM's system descriptions do not specify
the type of fuel metering system on these cars but GM does state that
6-4
-------
-------
most full sized 3-way cars are utilizing servo controlled carburetors
whereas the compact sized 3-way development cars are using
electronic fuel injection. The closed loop fuel metering control
system employs oxygen sensors mounted upstream and downstream of
the oxydation catalyst. The use of a downstream sensor is a GM
innovation. They report that it is used to guide a logic unit
which provides a variable reference to account for vehicle to vehicle
variations. All three domestic vehicles exhibited poor emission
control durability. The two Cadillacs exceeded the 1978 standard
at zero miles, indicating that they may not have even been targeted
for 0.4 NOx.
The remainder of the 3-way vehicles were Opels equipped with
electronic fuel injection, closed loop fuel metering and proportional
EGR. The best performing Opel stayed within the standard only
12480 miles at which time the catalyst monolith became loose and
was replaced. All seven Opels were equipped with the same catalyst,
the Degussa OM 721.
The remaining two AMA durability test cars reported by GM were
Pontiacs equipped with Ouestor Reactor-Converter-Reactor Systems.
Car No. 2447 exhibited excellent HC and NOx control with 20,000 mile
measurements of .061 HC and .289 NOx. The CO control was insufficient,
however, with levels holding relatively steady at about 4.0 gpm. The
6-5
-------
-------
thermal reactor on this car failed at about 22,000 miles which ended
testing. The second Ouestor equipped Pontiac, Car No. P2.483 did
not display the stable, effective, HC and NOx control exhibited by
the first. The emission control deteriorated rapidly and the thermal
reactors failed at about 15,000 miles.
The following is an evaluation of General Motors efforts to comply
with the 1978 standards.
The dual catalyst system development program represents General
Motors most significant effort toward meeting the 1978 standards. This
can be shown in several ways. In the first place, it represented GM's
most viable approach to meeting the standards given the time frame for
development and the inertia weight classes GM was forecasing for the
1978 period. Secondly, the dual catalyst program involved a far
greater number of durability test cars than the other programs. Out
of a total of 46 durability test vehicles reported by GM, 34 were
equipped with dual catalysts. Using the premise that the dual
catalyst was considered by GM to be the most promising approach, it
would stand to reason that a tireless effort would be made in this area,
leaving no stone unturned. The reported data, however, show that
6-6
-------
-------
the level of effort appeared to decline significantly during mid
to late 1973, (after CM received a suspension of the then 1976
0.4 NOx standard). Evidence of this is GM's reported AMA durability
testing. The reported data shows that in 1972 eight dual catalyst cars
initiated testing, in the following year, 1973, seven dual catalyst
cars initiated testing, but in 1974 only one vehicle was started.
Hypothetical arguments that would justify GM's decrease of testing
effort here is that either all of the known techniques for improving
dual catalyst systems had been throughly tried and shown unsatisfactory
(no stone had been left unturned) or that another area held sufficiently
better promise that CM diverted their resources to that area. Dealing
with the second argument first, the only alternative area of promise
was the 3-way catalyst approach. GM reported testing of ten 3-way
systems on AMA durability but only three of these were domestic cars,
and only two of these three were the full size variety that GM's
marketing plans are commited to in the 1978 time frame. This leaves
the first argument as GM's justification for reducing vehicle testing
effort on the dual catalyst approach. GM states:
"Because of the gross lack of durability of catalyst systems
using catalytic reduction of NOx, major emphasis has shifted
from vehicle durability to basic catalyst research and
laboratory and dynomometer evaluation of reducing catalysts."
1. General Motors progress toward achieving the 1978 Automotive
Emission Standard for Oxides of Nitrogen, Vol. 1, Sec. 5, p. 20.
6-7
-------
-------
In the opinion of the report team, however, GM ignored several
of their own emission control systems which if used in conjunction
with their dual catalyst system could have passed or come close to
passing the 1978 Standards. The important point here is that GM
did not even test them on the dual catalyst cars and, thus, these
cars did not represent full effort systems. The systems in mind are
the Super Early Fuel Evaporation System (Super EFE), closed loop fuel
metering control, cold storage HC control and reduction catalyst
replacement.
Super EFE was developed by GM and Table GM-3 shows test
results of this system on systems using no catalysts.
TABLE GM-3
Super EFE-No Catalyst (g/mi)
HC C0_ NOx
4000 ft test weight .37 3.09 1.51
4500 /' test weight .43 3.86 1.86
5000 ft test weight .49 4.27 2.24
Closed loop fuel metering control was used on car No. ES64346
which exhibited outstanding CO control at low mileage. In the opinion
of the report team, this control could maintain at high mileage if
this system were refined to hold its Air-Fuel ratio control more
constant. Along with better CO cont-rol this system would give
6-8
-------
-------
improved reduction catalyst durability because of its control of
oxygen spikes during transient operation.
The cold storage concept is effective on HC emissions. As
early as 1971 GM reported 30% reductions in HC emissions with the
system. GM stopped work on the system because of its complexity
but the system was revived for use on their rotary engine when it
appeared that HC emissions would keep it from certifying in 1975.
It is hard to reconcile GM's abandonment of dual catalyst
development car durability just when Gould was making their advances.
GM is, however, building a Gould getter car now.
By using some combination of these advanced systems (but not
necessarily all three) in conjunction with their dual catalyst systems,
GM could recalibrate spark timing and EGR to improve NOx control and
fuel economy.
Reduction catalyst replacement at 25,000 or 30,000 miles is a
straight-forward way of circumventing insufficient durability.
6-9
-------
-------
b-2 i'orcl
vi::
10T714
10T718
10T719
10T743
11A55D
201CD
2101SD
22C53D
22P37
31A74D
3055D
36A57D
42P25D
46P35D
43206
4A15D
14A53D
14A55D
XPU233
4W57D
!-- rol -Mr
;:--. ,.-_-- ::-:. drc .-; ;-\.oi ::-_.^ri.-5 Cat-i/st:
---'- , - -* Lj--i:> " or-"=roo CIJ rrf'o '>"! C-rj I V3". 0": '.ol
i
351'..' Dual Cat
1
429
3 5 Is'
351W
351W
250
250
2.6L
400
351C
" 351W
2.3L
2.3L
2.3L
351%'
351!'
35H.'
2.3L
400 .
Xal Cat
B-'^y-HOX
Dual Cat
Dual Cat
Dual Cat
Dual Cat
3aal Cat
The real
Reactor
Dual Cat
Dual Cat
Dual Cat
3-UayfOX
3-Way
3ual Cat
Questor
3-1, :ay
i^C
rior
Nor
X
;ioi
X
t
X
na
X
i
19
19
a(?) X(?)
2 (?)
X
X
X
e
32/19
19
19
19
X
.92
.92
1.4
1.4
1.2
Fdbk
Fdbk
Fdbk
Fdbk
Kdb'c
Fdbk
'
4V
2V
2V
IV
IV
2V
2V
2V
X
2V
X
X
0 T '-. -.,
3 ltd
X
X
X
X
X
X
X
X
3-Wa
3-Wa
3-Way
X
X
3-Way
f
_\.
X
X
X
X
" X
X
X
X
65
3
5
5C
72
48
52
'^->-
Ford
Sagelhard
Engelhard
Gulf
Aaoco
Engelhard
ICI
ICI
Sagcl'aard
Ford
Grace
Engelhard
Gould
ICI
-
Gould
5-10
-------
-------
Vehicle 110T714
Vehicle 110T714 was terminated in 1973 due to deterioration of
the noble metal NOx catalyst. Emissions were higher than the 1978
levels at zero miles. Insufficient vehicle and catalyst information
was provided to complete a full-efi >rt vehicle analysis.
Vehicle 110T718
Vehicle 110T718 was terminated in 1973 due to deterioration
in the base metal/noble metal NOx catalyst. Emissions exceeded the
1978 levels at zero miles. Exhaust gas input to the catalyst
system exceeded 50 CO. This indicated very poor system selection
or calibration. Sufficient catalyst and vehicle information was
not provided for a full-effort analysis.
Vehicle 11A55D
Vehicle 11A55D was equipped with different NOx catalysts in
each bank. Feedgas levels were very high for all three pollutants,
and 1978 emission levels were not achieved at low mileage. Poor
system selection or calibration was obvious. A full-effort analysis
again could not be made. The vehicle was terminated after significant
NOx conversion losses.
Vehicle 2010D
Vehicle 2010D was also terminated due to reduced NOx conversion
efficiency. Feedgas levels again were high despite the use of several
improved EC/CO control techniques. Had this vehicle been equipped
with EGR, it would have been given consideraiton as a full-effort
vehicle.
6-10
-------
-------
Vehicle 21018D
Vehicle 21018D was reported in the 1973 Ford status report to
EPA. It was assembled to evaluate an ICI NOx catalyst. Vehicle
21018D was added and catalyst volumes were reduced. This car probably
was a full-effort system in 1973. Initial test results (one test
reported .5 HC, 3.8 CO, .45 NOx) indicated that NOx conversion
efficiency was not as high as expected. Additional tests were
scheduled to find the NOx conversion problem. Vehicle 21018D has
never been mentioned again. The p, jblem analysis has never been
concluded.
Vehicle 22C58D
Vehicle 22C58D was terminated in 1973 due to the losses in
conversion efficiency of the two Ford noble metal NOx catalysts used.
EGR was not used and thus 22C58D was not a full-effort system. Zero
mile emission levels exceeded 1978 levels.
Vehicle 22P37
Vehicle 22P37 was a thermal reactor car which was reported to
EPA in 1973. Ford did not report the use of EGR on this vehicle.
Low mileage emissions were quite impressive for an apparently unoptimized
vehicle.
TABLE FO-2
Vehicle 22P27 Results
HC CO NOx MPG Miles Date Comments
.26 4.7 .59 0 32 CID air pump
.14 4.39 .63 5,000 19 CID air pump
.18 6.68 .60 10,000 19 CID air pump
No further optimization has been reported on vehicle 22P37.
b-11
-------
-------
Vehicle 31A74D
Vehicle 31A74D was used to test three ;;ypes of NOx catalysts.
Two different catalysts from Grace were tested at low mileage, and
an Amoco NOx catalyst was durability tested. The Amoco catalyst test
was terminated due to the loss of reduction efficiency. The 1973
Ford status report indicated that . .^e best Grace catalyst was to be
durability tested. This has not been done in the following year and
a half. Vehicle 31A74D may have been a full-effort vehicle; however,
a complete description of the vehi 1e and catalysts was not available
for complete analysis. Feedgas emissions for HC and CO were very
high.
Vehicle 3055D
Vehicle 3055D was equipped with a Gould GEM 67 NOx catalyst.
The testing of vehicle 3055D is a good example of improper treatment of
a vendor product. The vehicle had immediate problems with low catalyst
temperatures. Ford either installed or modified the air injection
system and promptly terminated the testing of the vehicle apparently
due to "disappointing" results. The maximum NOx conversion
efficiency achieved was 43%. A complete description of the vehicle
was not provided to determine if the manufacturer made his best
technology available on this car. NOx values of some test results
indicate that this car was not optimized for NOx input to the
Gould catalyst.
6-12
-------
-------
Vehicle 36A57D
Vehicle 36A57D is another example of improper treatment of a
vendor product. Ford reported very brief low mileage testing of
the catalyst and then terminated testing "until converter designs
which allow higher catalyst operating temperatures are completed".
A full effort would mandate that Fu^l work with ICI to develop
such a design or provide an existing one for them. The exact
nature of the ICI catalyst problem, if any, was not reported.
Vehicle 110T719
Vehicle 110T719 begins the vehicles whose testing occurred in
1974. A detailed description of the vehicle and catalysts was not
provided. Extremely high PC and CO feedgas levels indicated that
1974 technology was not employed on the 1972 Ford test vehicle.
The 1978 emission levels were not met in brief, low mileage testing.
Vehicle 110T743
Vehicle 110T743 and its emission control system were very
poorly described. CO feedgas levels were very high indicating
less than current technology. Vehicle termination was said to
be due to catalyst deterioration even though one had deteriorated
very little over the 9,000 durability miles.
Vehicle 42P25D
Vehicle 42P25D has feedgas levels which are much improved
over all previous catalyst vehicles due to the addition of current
technology emission control device (feedback controlled electronic
fuel injection, improved EGR control). Low mileage emission
6-13
-------
-------
values were very impressive; however, similar technology could
be applied to dual catalyst vehicles as well as 3-way + ox. cat.
vehicles such as vehicle 42P25D. The durability of dual catalyst
systems is currently greater than that of 3-way catalysts.
TABLE FO-3
Vehicle 42P25D Results
HC CO NOx MPG Miles Date Comments
.14 .70 .15 low IW=3500 Ib.
.07 .25 .18 low IW=3000 Ib.
Vehicle 46P35D
Vehicle 46P35D was prepared by Bosch GMBH of Germany to illustrate
the potential of feedback controlled mechanical fuel injection systems.
Proportional EGR apparently was not supplied to Borch by Ford. The
feedgas NOx levels are higher than those of vehicle 42P25D; however,
the more effective 3-way catalyst used by Bosch was reducing about 90%
of the NOx. Low mileage emissions were .12 HC, 1.26 CO, .13 NOx.
Vehicle 43206
This vehicle program is just beginning. The vehicle was not
described completely by Ford so a full effort determination could
not be made. Vehicle 43206 is similar to vehicle 46P35D and 42P25D
in that they have appeared only recently in the Ford fleet.
6-14
-------
-------
Vehicle 4A15D
This vehicle is also very new. Apparently the 3-way
catalyst has not even been installed yet. The technology presented
on this car is equivalent to that which could have appeared on
Ford vehicles in early 1974.
Vehicle 14A53D
Gould prepared this vehicle for Ford's evaluation after the
testing of vehicle 3055D disappointed Ford engineers. The
engineers at Gould succeeded (which Ford engineers failed on 3055D)
in calibrating the vehicle to achieve emission within the 1978 levels.
Ford received the vehicle in January of 1974. "During attempts to
repeat the Gould (emission) results, the vehicle stalled on a cold
start and the NOx catalyst temperatures exceeded 2000° F causing
a partial catalyst melt," according to Ford. No reason for the
stall was provided, and no vehicle tests have been reported since.
New Gould GEM 68 catalysts were provided by Gould in September.
Ford indicated that a feedback controlled Gould car will be
assembled in the fall of 1975. The proven durability of the Gould
catalyst should be ever better with a good fuel metering system.
A full effort system should include Ford's advanced EGR and AIR.
Vehicle 14A55D
The Questor-equipped vehicle was run for 20,000 miles before
HC and CO control was lost. Several fixes were attempted by Ford
before the vehicle was terminated. Ford noted that air pump
deterioration and air system leaks may have been responsible for the
6-15
-------
-------
failure. There was no indication that any technical advice or
improved hardware was provided to Ouestor to prevent similar
problems in the future.
Another vehicle was prepared by Questor for Ford. This one
was a 2.3 litre Pinto. After only 360 miles it exceeded the 1978
levels and showed deterioration in both HC and CO. Ford analyzed
the problem as being an insufficient air supply. No fixes were
attempted. Instead of installing a larger air pump and recalibrating,
the vehicle was promptly returned to Questor for repair. Approximately
an eight month delay resulted from Ford's fairlure to repair the
vehicle.
Vehicle XP4233
Vehicle XP4233 was built for Ford in Europe by Bosch. The
absence of EGR indicates that current technology hardware was not
provided to Bosch. Shortly after the vehicle arrived in Dearborn,
Michigan, it was taken on a "short trip" to Denver, Colorado!
Valuable development cars (especially those that are not altituded
compensated) seldom are driven between test sights. After the return
drive to Dearborn, emission levels exceeded the 1978 levels.
Vehicle 4W57D
This vehicle is another of Ford's recently built vehicles.
Very few details of the vehicle and control system were available.
6-16
-------
-------
The Alternate Engine Program
Ford told EPA that their alternate engine program had been
retargeted from 0.4 to 2.0 NOx in 1973. This would seem to be a
problem for the alternate Ford engine as they are not scheduled
for introduction until after the im^ ^mentation of the 1978 0.4 NOx
standard. The 0.4 NOx potential of this engine is well known. Its
failure has been in HC emissions. Ford also has chosen not to work
on their CVCC engines at low NOx lev 'Is. The report team believes
that Ford technology could provide improvements to the CVCC system
should they be convinced that the 0.4 NOx law will be enforced.
Ford Summary
Most test vehicles were poorly calibrated or used less than
optimum emission control hardware. Full effort vehicles did not
appear until late 1974 or about the same time as this evaluation
of industry good faith was announced. Some vehicles were terminated
without adequate technical justification. Promising technologies
such as base metal NOx catalysts and feedback dual catalyst systems
were not pursued. The shift in emphasis from dual catalyst systems
to 3-way plus ox. cat. systems may provide long term advantages;
however, it will reduce capability to certify at .41 HC,
3.4 CO, .4 NOx in 1978. The Ford alternate engine programs were
redirected to 2.0 NOx in 1973. The Ford treatment of vendor's vehicles
and products has been questionable. Current technology and technical
advice have not been provided to vendors.
6-17
-------
-------
6.3 Chrysler
The vehicles in Table CH-1 arc discussed as they are the
Eost recent: and representative Chrysler 0.4 NOx vehicles.
TABLE CH-1
433
166
173
219
263
352
476
178
136
T
rani] v
360
360
360
360
360
360
360
360
' 360
"onLrol
System.
1 vne
Dual Cat
Dual Cat
Dual Cat
Dual Cat
Dual Cat
Dual Cat
Dual Cat
Dual Cat
Questor
.
EGR
Jroo Xor-?rop
Nc
Nc
Nc
Nc
ne
ne
X
X
X
X
ne
ne
Air j
drive I
CTD ratio
19
19
19
19
26
26 "
26
19
by Q
1.67
2.08
1.87"
1.67
1.67
1.5
1.67
estor
6-18
-uel Metering
ETI Carb
4V '
2V
2V
2V
2V
Ford
2V
Catalyst
X0.\- Ox Vol
X
X
X
X
X
X
-'
X
X
X
X
X
X
X
X
X
X
X
.20
.20
.50
L20
L52
.20
L20
L50
ffr
Chrysler
Chrysler
Chrysler
J-M
Chrysler
Chrysler
ICI
Chrysler
Chrysler
Chrysler
Gulf
Chrysler
Chrysler
Chrysler
Engelhard "
Gould
Chrysler
Questor
'
-------
-------
Vehicle 433
The emission control system of vehicle 433 included exhaust
port lines and 87 CID, air-gap exhaust manifolds. The absence of
EGR was not consistent with either 1973 engineering practice or
prolonged NOx catalyst life, due to the increased NOx input to
the catalyst system. Under these adverse conditions, Chrysler
stated that the NOx catalyst was performing well at 20,000 miles.
At the 20,000 mile point the engine failed (the engine in this test
car had been used for 30,000 miles of testing prior to the beginning of
this NOx catalyst test) and testing was terminated. This noble metal
NOx catalyst has not been installed on a vehicle with EGR for reduced
NOx input to the catalyst, and was less than a full effort.
TABLE CH-2
Vehicle 433 Results
HC CO NOx MPG Miles Date Comments
.40 4.1 .56 low July '73
.31 1.7 .99 low Carb. problems
.47 3.8 ,67 low Oct. '73
Vehicle 173
Vehicle 173 most accurately represented the Chrysler first
choice control system in the 1973 Status Report to EPA. No advanced
HC/CO control was used, but vehicle 1973 more closely approached a
1973 full effort test vehicle. High HC and CO results apparently
were the result of either poor vehicle calibration or poor oxidation
catalyst efficiency. Insufficient details were provided to make a
more precise determination.
6-19
-------
-------
TABLE CH-4
Vehicle 173 Results
HC CO NOx MPG Miles Date Comments
.57 6.08 .27 low Aug. '73
.53 5.40 .29 low
.63 3.71 .50 low Sept. '73
Vehicle 219
Vehicle 219 was equipped with port liners and enlarged, air-gap
exhaust manifolds. Also it included an ICI base metal NOx catalyst.
Vehicle 219 was possibly a full effort project in 1973. Complete
catalyst details were not presented to permit a full evaluation.
Early emission results indicated excellent potential; however
substrate breakage problems occurred. Chrysler then prepared a new
catalyst with a stronger substrate, and installed it on the vehicle.
Emissions again were good; however, catalyst overtemperature problems
occurred. Chrysler then removed some exhaust system insulation and
modified the intake manifold and spark advance to alleviate the
overheating problem. Another catalyst was found to be broken and
replaced. All three emissions later deteriorated during durability
testing.
6-20
-------
-------
TABLE CH-5
Vehicle 219 Results
HC
.35
.25
.30
.31
.45
.50
.87
.67
Vehicle
CO
2.3
3.0
3.6
3.7
6.5
6.8
8.5
5.4
263
NOx
.24
.17
.32
.32
.29
.26
.49
.49
MPG Miles
low
low
8.58 low
8.92 low
8.60 low
8.49 low
620
2623
Date
Comments
New catalyst
with improved
substrate
replaced one
catalyst biscuit
Vehicle 263 included enlarged, insulated exhaust manifolds in
conjunction with base metal NOx catalysts. Vehicle 263 may have been
a full effort system; however, catalyst detail again were not presented
for a full evaluation.
Catalysts efficiencies dropped very rapidly and the catalyst
was replaced with "an improved NOx catalyst". No further results were
reported with the new catalysts.
TABLE CH-6
Vehicle 263 Results
HC
.32
.51
.47
1.1
CO
2.9
8.4
8.6
11.2
NOx
.25
.84
.35
.56
MPG
10.34
9.19
10. 4^
9.23
Miles
low
low
1500
2000
Date
Comments
6-21
-------
-------
Vehicle 352
Vehicle 352 was built in 1973. It was not a full effort system
as no advanced HC controls were used. It was initially used to
evaluate a Gulf NOx catalyst and later to evaluate a Chrysler noble
metal NOx catalyst. The Gulf catalv, ,c evaluation appears to have
been very brief and superficial.
A new oxidation catalyst is to he installed and durability
continued as the NOx catalyst appeas to be performing well at
12,000 miles. Mileage accumulations has been slow with the Chrsyler
catalyst.
TABLE CH-7
Vehicle 352 Results
Date Comments
Gulf catalyst, no EGR
Gulf catalyst, no EGR
Chrysler Catalyst
installed
HC
.36
.39
.49
.46
.57
.58
.84
.99
.65
1.1
CO
4.68
4.33
6.07
5.25
4.78
6.31
9.92
11.4
13.0
31.2
NOx
.65
.80
.37
.47
.46
1.31
.55
.61
.47
.46
MPG
11.7
11.5
12.46
11.07
10.8
11.4
10.7
11.0
Miles
low
low
low
low
low
6000
6000
6000
6000
12000
6-22
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Vehicle 476
Vehicle 476 was run with port lines and insulated, enlarged
exhaust manifolds, but apparently was without EGR. It used a Chrysler
metallic NOx catalyst.
Chrysler noted that very painstaking carburetor calibrations
were necessary to obtain these excellent low mileage emissions.
Chrysler also noted that this difficult calibration would not be
possible on production vehicles. The report team is in agreement
with that statement, and we hope that Chrysler will soon begin to
test vehicles with more sophisticated A/F metering systems similar
to those fuel injection or feedback carburetion systems which have
been run by many other manufacturers for some time now. If the
Chrysler fuel injection system (which has been under development
for at least two years) is not ready for vehicle use, then
Chrysler could purchase fuel injection systems which are in
production from others.
TABLE CH-8
Vehicle 476 Results
Date Comments
HC
.37
.30
.33
.25
.40
.35
.26
.25
CO
3.9
3.8
3.0
3.1
2.85
2.55
1.68
2.56
NOx
.34
.29
.34
.27
.21
.28
.38
.38
MPG
11.8
11.3
11.8
11.2
Miles
low
low
low
low
low
low
low
low
6-23
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Vehicle 178
Vehicle 178 is the Gould GEM-b8 equipped vehicle. This car was
run without EGR and the larger displacement air pump used on more
recent Chrysler 0.4 NOx vehicles.
The catalysts were damaged by Ignition failure. In addition,
there has been some controversy Governing the exact number of times
this vehicle ran out of fuel while being tested. New catalysts were
obtained from Gould and durability r.esting is to be resumed.
TABL7 CH-9
Vehicle 173 Results
Date Comments
7/12/74 At Gould
7/13/74 At Gould
7/15/74 At Gould
At Chrysler, add PCV
HC
.6
.3
.3
.43
.35
.37
.50
CO
2.6
.97
.72
2.5
1.7
2.7
3.2
NOx
.72
.52
.62
.71
.60
.69
1.31
MPG
12.3
12.7
12.7
11.4
11.6
11.5
11.56
^iles :
low
low
low
low
low
low
496
Prior to ignition
failure
Vehicle 136
Vehicle 136 was prepared by Questor for Chrysler. It was
equipped with the Questor Reverter system. No EGR was used, and the
engine compression ratio was increased thus providing higher engine-out
emissions.
The preparation and particularly the testing of this vehicle
has been very slow. The vehicle was received by Chrysler on October 9,
1974. Only three sets of low mileage test results have been reported
from that time to the present.
o-24
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TABLE CH-10
Vehicle 136 Results
HC
.39
.20
.31
.15
.24
.13
.22
CO
3.14
2.18
2.84
1.94
2.43
2.00
2.77
NOx
.34
.38
.32
.33
.39
.38
.32
MPG
10.1
11.0
9.4
9.7
10.0
10.2
10.3
Miles
low
low
low
low
low
low
low
Date
9/74
9/74
9/74
9/74
Comments
At Quest or
At Questor
At Questor
At Questor
At Questor
Chrysler Summary
Chrysler has reported to be developing many effective emission
control devices. These include:
advanced oxidation catalysts
electric hot spot intake manifolds
hot well intake manifold
aluminum intake manifolds
electric fuel vaporizer
electronic fuel injection
sonic induction
electronic EGR
electronic spark
modulated AIR
6-25
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Virtually none of these device, have been applied to 0.4 NOx
test vehicles. Some are scheduled for 1976 production so it must
be assumed that they were available for testing. The addition of
these items to Chrysler 0.4 NOx veh'cles could have had a strong
influence on Chrysler's ability to - ^rtify vehicles at .41 HC,
3.4 CO, .4 NOx in 1978, in the opinion of the report team. This
is a typical example of the less than full effort systems run by
many manufacturers.
Other useful approaches have net received much attention at
Chrysler. These include:
high energy ignition
delayed canister purge
3-way catalysts
feedback A/F metering
Major problems with the Chrysler 0.4 NOx program include:
Insufficient number of vehicles were tested in 1974
Very slow, delayed testing of the few vehicles which
were tested (very few actual test dates were provided
by Chrysler)
No vehicles which would be considered full effort
vehicles in 1974 were tested
Development programs are moving very slowly - especially
advanced fuel metering programs.
26
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Test vehicles are all very old, the newest being 1973
models. These are poor choices for 50,000 mile
emissions durability demonstrations.
Poor follow-up of potentially good components (i.e.,
NOx catalyst of vehicle 433)
Poor or inadequate reasor.s for apparent project
terminations (i.e. vehicle 433, vehicle 166, vehicle 173)
Questionable treatment of some vendor vehicles. The
vehicle 178 was discussed extensively at the sulfate
hearings.
6-27
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6.4 American Motors (AMC)
AMC is the smallest of the domestic manufacturers and, perhaps
not surprisingly, has mounted the least comprehensive effort directed
toward 0.4 NOx. AMC, however, has an advantage that Ford and Chrysler
do not have, through their consulting agreement with GM. AMC, in
general, tends to follow the GM approach in many areas, their choice
of production oxidation catalysts and some EGR systems are examples.
AMC has reported work targeted toward 0.4 NOx as early as 1971.
At that time AMC was considering several approaches, and had indicated
that the dual catalyst approach was considered to be one of the more
promising systems to meet 0.4 NOx. However, in 1971, none were built
and tested. AMC was also aware of che 3-way approach in 1971. The
most promising test results for AMC in the 1971 status report came
from a Questor system. This is one of the first Questor system
tests known to the report team. Lox. mileage results of 0.01 HC,
2.44 CO, 0.37 NOx were achieved.
In spite of these results, AMC in 1971 indicated that they had
no plans to use this system for the 0.4 NOx levels. Although the
system certainly was a first generation prototype and had the problems
associated with this approach (high temperatures, poor fuel economy,
marginal CO control). These problems were ones that could have
been attacked in 1971 by AMC. No further testing was planned in 1971,
6-28
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no cooperative development was men_ioned, and AMC missed the
opportunity to be one of the early leaders in the NOx control
technology. This is another example of a corporate decision that used
the technical drawbacks of a syste \ to reject it, in spite of its
having the best emission control / .onstrated to that date at AMC,
with essentially no AMC work done to improve the system.
In 1972 AMC had essentially chosen systems to pursue toward
0.4 NOx that were like GM's. Of t^n tests reported not one met the
0.41 HC, 3.4 CO, 0.4 NOx levels. F > in 1972 AMC's project choice
was based on what GM was doing.
In 1973 AMC was still planning to use a dual catalyst system.
No durability testing was reported, putting AMC in the same position
as they were in 1971 and 1972, essentially nothing in the durability
area the most serious problem at the 0.4 NOx level. AMC's fall 1973
status report x^as identical to their suspension request earlier in
the year in the area of 0.4 NOx development, an indication that no
work was done in the interim. Even though AMC may have not known
about the need for precise fuel metering before the NOx suspension
hearings they knew about it afterwards, but no plans were reported
to put an advanced fuel metering system on a dual catalyst vehicle
in their status report.
In 1974, AMC reported only one test of a system that they
claimed was a 0.4 NOx possibility. This was the vortex reactor
vehicle which achieved 0.48 HC, 10.2 CO, 2.62 NOx. AMC indicated
-------
-------
that the purpose of the project was twofold, to obtain data with
an eye to eventual integration into a catalyst system, and to
examine the possibility for adapting the concept to their rotary
engine. The success or failure of this approach is not important.
What is curious is that AMC would devote their time and resources
to testing a system type whose poor chances for meeting 0.4 NOx
were known from the literature several years earlier, when AMC had
never been able to find the time and resources to do much at all in
the area of their first choice system toward meeting 0.4 NOx.
In contrast to the actual testing and modifications to the
thermal reactor vehicle, AMC reported that they were only beginning to
construct a Gould catalyst vehicle in their 1974 Status Report.
In their latest submission, AMC reported work in four program
areas:
1. Thermal Reactor
2. Gould's Reducing Converter
3. Potary Engine
4. Pre-Chatnber Stratified Charge Engine
No work in other program areas, for example noble metal NOx
catalysts, 3-way catalysts, reactor-catalyst-reactor systems, or
improved HC control were reported.
6-30
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AMC indicated that once a generalized siet of programs are
generated to meet legislative mandates, the proposals are sent to
the Engineering Vice President for program approval. This plan
includes R&D projects, budget, facilities, timing, potential
production tooling impact, and so ^. The plans are also submitted
to Purchasing and Manufacturing. The three parties determine that
the program approved is compatible within all corporate limitations.
AMC stated that this plan subr'ssion and or approval has not
been done for the 1978 model year. Therefore it could be said
that AMC does not even have a plan approved for meeting the 0.4 NOx
standard at this time. The lack of decisions on a well defined
program for meeting 0.4 NOx is hampering AMC efforts, in the opinion
of the report team. It may be that AMC is waiting to see what the
Congress will do. AMC also did not indicate what "all corporate
limitations" were.
Thermal Reactor
AMC's curious thermal reactor program was discussed above.
Gould Catalyst
The most significant 0.4 NOx work reported by AMC was with
the Gould catalyst system. This system which was reported as in the
build stage earlier in 1974, was installed in a vehicle in December,
1974. This date is about a month after the letter from Senator Muskie
to Administrator Train which specifically mentioned the Gould catalyst.
In the opinion of the report team, the impetus provided by that letter
probably accelerated the completion of the vehicle. Vendor-based
vehicles have a habit of taking a long time to build in the industry.
6-31
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The vehicle is a 232 cubic inch six-cylinder 3500 pound inertia
weight vehicle. The vehicle build list indicates that it includes
several components that would tend to make it a full effort vehicle.
Possible exceptions are noted below.
The carburetor is a 1975 production unit. While this is better
than some manufacturers who have useJ older 1973-type units, it could
be improved. Dual catalysts systems have suffered from poor fuel
metering control for several years, and Gould's getter is an attempt
to cope with this. AMC did not indicate if the carburetor configuration
provided the correct CO/0,, ratio during transient operation. They
also tried some calibrations outside the rich region (15.5 to 1 A/F)
which as far as the report team is aware is outside of the region for
proper operation of the Gould system.
The ignition and EGR calibrations were not specified. AMC must
know of the approach taken by GM and others to optimize EGR and spark
timing. If GM can get a full size 5000 Ib. vehicle down to about 1.0
NOx v;ith EGR and advanced spark then AMC ought to be able to do as
well with a 3500 Ib. vehicle. Therefore, the NOx baseline on this
vehicle (approximately 1.8 gpm) could be considered too high.
The oxidation catalyst is apparently a 160 cubic inch 1975
production catalyst. Better development catalysts may be available
and should have been investigated, especially since AMC indicated
that they had an HC and CO problem.
6-32
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The air injection system included provisions for switching the
air injection point from the manifolds to the oxidation catalyst after
light-off. AMC indicated that after the 3500 miles of durability, air
injection switching using manifold air injection during periods of
choke operation would be tried. AMC indicated as early as 1971 that
they knew that air injection switch'ng should be used with a dual
catalyst vehicle, therefore it is curious that the initial tests
did not report using this approach. The high HC and CO reported
by AMC may be due to this lack of a known technical approach. AMC
indicated that the oxidation catalyst light off was delayed, but
Gould has been able to get the Getter to light off (and act as a
start catalyst) in 15 seconds, faster than AMC's own oxidation
catalyst-only system.
AMC indicated that an EFE-type jianifold was part of their
first choice 1978 system. This veh .le was not so equipped.
AMC also reported that the exhaust back pressure with the Getter
system was almost double that of a .Astern with an oxidation catalyst.
This may cause excessive use of the ^ower valve during the test and
lead to high HC and CO emissions. However, AMC did not report any
discussion or work with Gould to attempt to resolve this problem.
Possibly because of the above-described less than optimum system
configuration, the HC and CO performance has exceeded the 0.41 HC,
3.4 CO levels on this Gould catalyst vehicle. NOx has been below
0.4 on several tests, but not as low as AMC's 0.20 low mileage
target, 0.37 NOx being the lowest reported. Test results of the vehicle
in baseline and modified configuration are shown below:
6-33
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TABLE AMC-1
System System Miles HC CO NOx MPG
Baseline Low 0.14 3.5 1.87 14.1
Gould 3550 0.51 3.89 0.45 15.1
Gould 3550 0.74 5.91 0.40 14.3
The Gould vehicle fuel economy results are essentially the same
as the baseline vehicle.
All in all, the results are promising and if AMC spends a little
more time optimizing the EGR and spark calibration and uses switched
air injection, they may have their first reported dual catalyst
durability car.
Rotary Engine
AMC reported little on their rotary engine program. The only
results were a Curtis-Wright RC 2-6< engine with an AC 260
converter and air injection. Low mileage results were 0.80 HC,
2.72 CO, 1.78 NOx, 15.3 mpg at 3000 Bounds interia weight.
What is important about this effort is that no EGR was used.
In fact the emission control system appears to be targeted toward
standards different than 0.41 HC, 3.4 CO, 0.4 NOx. AMC reported
no plans to build a system for their rotary that would be targeted
toward 0.4 NOx, indicating that their program may be targeted away
from 0.4 NOx currently. This is considered odd, since the rotary
could only come into production for AMC just about when 0.4 NOx
would be a requirement (1978 and later).
6- 34
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Prechamber Stratified Charge Engine
No vehicle tests with a prechamber stratified charge engine
were reported. Some engine dynamometer tests have been run showing
an 8.2 percent loss in power, a 5 percent gain in ISFC at full power
and a 2.7 percent loss in HC control, a 36 percent gain in CO control,
a 42 percent gain in NOx control ar,J a 13.5 percent gain in ISFC at
part throttle, compared to the conventional engine.
Again no specific plans for making this concept meet 0.4 NOx
were presented. Work with main chamber and prechamber EGR should
have started concurrently. The best NOx results from this engine
type (Honda's) were obtained with EGR and have been reported in the
literature.
American Motors Summary
AMC's programs are fairly typieal-a low rate of effort, less
than full effort systems, and an apparent lack of cooperative development
and problem solving with vendors. 1'nique to AMC is an almost total
lack of durability testing of any 0.4 NOx system in the more than
4 years since the 1970 amendments.
6-35
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APPENDIX ..
-------
-------
-CA, N. MEX. JAMES U. BUCXLEY, N.Y.
^JLSKA ftontirr T. STAFTOWO. vr.
^H, TEX. WIl-UAM I SCOTT, VA,
oU^ofCX, N. DAK* JAMS3 A. MCCUJHC. IDAHO
, 1QWA PETE V. OOMO4IO, N.
M. EARFTT METER, CHlEy COUNSEL AND CHIE* O-E»K
BAJUEY CUA«D, MIMCATTV CUERK
COMMITTEE ON PUSUC WORKS
WASHINGTON, D.C, 20510
November 18, 1974
Honorable Russell E. Train
Adminis trator
Envirornnental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dear Mr. Administrator:
On March 22, 1974, you transmitted proposed legislation to modify
the statutory automobile standard for emissions of oxides of nitrogen.
This legislation was purportedly based on data which indicated the ap-
plicable statutory standard was not justified by current air quality-
data. More recently in a speech to the New York City Chamber of Commerce
and Industry you indicated that the basis for1relaxation of the statutory
standard for control of automobile emissions of oxides of nitrogen was
"that the required technology would not be available in time."
This statement appears to recognize the recent findings of the
National Academy of Sciences that strict control of NOX may be needed
to assure achievement of health related ambient air quality standards
for photochemical oxidants, in that it does not argue for a modified NOX
standard on the basis of air quality.
More recently the joint Environmental Protection Agency-Department
of Transportation Fuel Economy Report indicated that the required tech-
nology to achieve a .4 NOX standard can in fact be available within the
time required by current law.
In light of the NAS findings and the conclusion of the Fuel Economy
Report it is imperative that there be a determination of the extent to
which the auto companies are actively pursuing this requirement of the
Clean Air Act. Such a review should include analysis of the level of auto
company investment to achieve ihe statutory NOX standard as well as the
extent to which the companies are taking advantage of recent developments
by non-industry suppliers. This latter point is particularly important in
light of recent information released by Gould, Inc. which indicates that
a feasible, fuel-efficient NOX catalyst is now available.
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Honorable Russell E. Train
Page Two
Novenfcer 18,1974
Undoubtedly Congress will be asked to review the 1978 statutory
standard for NOX next year. Your review and analysis of the good faith
of the industry in attempting to comply with that requirement will be
essential to that review.
Sincere
, U.S.S.
Subcommittee on
nental Pollution
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APPENDIX B
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON DC. 20-60
January 6, 1975
Dear
We have been requested by tr- Senate Public Works Committee
to review and analyze the efforts of your and other automobile
manufacturing companies to meet the statutory emission standard
for oxides of nitrogen that becomes effective with the 1978 model
year, and to report promptly to the Senate Public Works Committee
on the results of this review. Trie information on this issue
is required to be reported by the Environmental Protection Agency
to the Congress by Section (202)(b)(4) of the Clean Air Act. In
the past information for the Section (202)(b)(4) report was obtained
from auto company suspension applications and related submissions;
this year it is necessary to obtain this information separately
since no suspension of the NOx standard is authorized by the Act.
There is enclosed with this letter as a supplement to my request
for information of September 20, 1974, an outline of information
requested to be. submitted by your company which will enable us to
r.ake the review and analysis that has been specifically requested
by the Conrr.lttea. To permit tlrz^ly preparation, and submission to
tns Conrnictee of the requested r^ort, you ara requested to provide
:h-j information id^ntit .. ^ 1 ir. t"1-. --'Vci^' -I ^utlLr-1 by 7-bruar;* 1,
_?75. Please address y.-ur ^.-, -.:>:.--:- tj r.-._. J -j: v .> c :.^ '. ":c Deputy
Assistant Administrator for Ac^li- Scurc-^ Air ~'o Llucian Control,
AW-455, 401 M Street, S.W., Washington, O.C. 2G460, roum: 741,
WSMWT, whose office has responsibility for EPA in making this
Any questions abouc the information desirad should also be
addressed to that office.
Sincerely yours,
Roger Strelow
Assistant Administrator
for Air and Waste Management (AW-443)
Enclosure
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IDENTICAL LETTERS SENT TO:
Foreign Manufacturers
Mr. Guenter Storbeck
Product Planning Manager
Volkswagen of America, Inc.
818 Sylvan Avenue
Englewood Cliffs, New Jersey
07632
Mr. Bernard Steinhoff
Emission Control Department
Mercedes-Benz of North America, Inc.
One Mercedes Drive
Montvale, New Jersey 07645
Dott. Ing. Andrea Catanzano
Automobili Ferruccio Lamborghini, S.p.A.
40019 S. Agata
Bologna, Italy
Mr. Guy Malleret
Managing Director
Officine Alfiera Maserati, S.p.A.
Viale Giro Menotti, 322
41100 Modena, Italy
Mr. Guido A. Foggini
Designated Agent (Ferrari)
Fiat Motor Company
560 Sylvan Avenue
Englewood Cliffs, New Jersey 07632
Toyo Kogyo
Suite 423, 2733 Greenfield Road
Southfield, Michigan 48075
Attn: Mr. G. Utsunomiya
Technical Liaison
Mr. Olaf E. Strand
Assistant Engineer
U.S. Suzuki Motor Corporation
13769 Freeway Drive
Santa Fe Springs, California 90070
Mr. Toshitake Mishimura
Manager, USA Office
Lsuzu Motors Ltd.
c/o C. Itoh and Company (America), Inc.
245 Park Avenue
New York, New York 10017
Domestic Manufacturers
Mr. Ernest R. Starkman
Vice President
Environmental Activities Staff
General Motors Corporation
Warren, Michigan 48090
Mr. Herbert L. Misch
Vice President
Ford Motor Company
The American Road
Dearborn, Michigan 48121
S.L. Terry, Vice President
Chrysler Corporation
Post Office Box 1919
Detroit, Michigan 48231
Mr. W.J. Martin
Staff Engineer, Vehicle Emissions
International Havester Company
Motor Truck Engineering Department
Post Office Box 1109
Fort Wayne, Indiana 46801
Mr. Daniel Hittler
Manager, Development Department
American Motors Corporation
14250 Plymouth Road
Detroit, Michigan 48232
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Outline of Supplementary Information
for Emission Control Status Report
The information requested ;i.n the following paragraphs should
be specifically addressed to your company's efforts to meet the
1978 emission standard for oxides of nitrogen (0.4 gm/m). To
the extent that relevant information has already been submitted
to EPA, copies of the previous submission will serve as a
response to this request. If a complete response on the issue of
your company's effort toward meeting the 0.4 gm/m NOjj standard
requires a description of efforts to meet the statutory HC and
CO standards, such information should be included in the response.
Please submit an original and four copies of your response, by
no later than February 1, 1975, to the Deputy Assistant Administrator
for Mobile Source Air Pollution Control, AW-455, 401 M Street, S.W.,
Washington, D.C. 20460.
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Section 1 should contain the company's statement of Its total
effort to achieve compliance with the established emission standards. The
statement should present a discussion of the company's research,
development, testing and engineering program(s) in the area of emission
control. The statement should include:
a. The overall organization chart for the emission control
activity with an indication of the decision-making process in
major areas; for example, se_ ~tion of first choice 1978 system.
The names and titles of all responsible personnel in the organization
description should include all personnel involved in the light duty
vehicle emission control area down to and including the first supervisory
level.
b. Engineering goals fc: the emission levels to be achieved by
low mileage engineering prototypes in order to achieve compliance with
the emission standards, including assumptions made to arrive at those
goals; factors assumed to allow for production variations, prototype-
to-production slippages, and deterioration; and change in production
variations assumed to occur by 1978 model year production.
c. The composition of the program(s), presented in sufficient
detail to include the number and qualifications of professional
personnel assigned to emission control activity, and the academic or
functional disciplines involved, the type(s) and quantity of major
items of laboratory equipment used (e.g., visible, ultra-violet and
infra-red spectrophotometers), and the laboratory and testing
facilities used. When equipment, projects, and personnel are only
partially dedicated to the emission control activities, the company
should indicate the percentage portion of such equipment, projects,
and personnel so dedicated.
d. The purpose of each program, including the specific technical
problem or area toward which the program is directed, the reasons for
the program, the date the program was started and its projected or actual
end date.
e. Detailed lead time schedule for model year 1978 production,
including crucial milestones, commitment and signoff dates, lead time
requirements of vendors, and specific lead time schedules for those
e.ission control system components which are most critical. Discuss
how much less lead time would be required to produce a reduced number
of models or nameplates that will comply.
f. The progress of each program toward achieving the goals set
out for it, including information as to: (i) whether the program is
ahead or behind schedule, (ii) important milestones that have been
met/not met., (iii) the number of times the program's progress has been
reviewed (date and specifics) and the personnel responsible for the
review, (iv) the outcome of the program reviews, and (v) any changes
there have been in the rate of progress for the program as a result
of review and redirection.
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g. A narrative discussion of the results. Quantitative data
should be included here to the extent it is not presented in other
sections of the submission.
h. Major problems associated with the most promising system
investigated, including fuel consumption, emissions of currently
unregulated pollutants, reduc> , driveability, other performance
penalties, and any safety, maintenace servcing, warranty, development
(emission performance, durability and producibility), production
tooling, and vendor problems.
i. Plans for resolving the problems identified in h including
use of technology developed o> .side the company or outside the
automobile industry, timetable for developing solutions, critical
milestones for meeting this timetable, confidence placed in the schedule,
areas of greatest uncertainty, probable or possible breakthrough(s)
that would result in a significant reduction in lead time, and consequences
of any shortcuts both to the company and to the potential vehicle user.
j. Where an individual project within a program is of significant
importance or has not been fully discussed in the program discription,
a narrative description providing at the least the following: time of
project start/end, level or effort (man hours), reason for starting and
stopping the project, results obtained, and how the results of the
project were used in the overall approach to emission control program
being investigated.
k. The efforts that have been made to identify useful technology
developed by other companies.
1. That portion of the program(s) carried out under contracts
or agreements with other firms or ad hoc organizations.
m. The efforts, results, and conclusions relative to all alternative
power systems considered.
n. The accomplishments of the research, development, testing
and engineering program(s) in terms of determination of feasible and
non-feasible approaches to emission control, patents obtained or pending,
and publications in technological journals, including knowledge and
account of any pertinent independent research conducted by facilities
not associated with the company.
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-3-
Section 2 should contain the company's detailed expression of
its financial commitment to emission control research, development,
testing and engineering activities.
a. A project narrative should be completed for each project or
particular phase of a project in research, development, testing and
engineering for the years 1969 through 1978. The project narrative
should include the following:
1. Project title, number of designation and date started or
planned to start.
2. Project description, including objectives, scope, approach,
phase and status. Phase refers to research, development,
engineering, testing or other areas of the emission control
program. Project status should indicate the percentage
completion of the project and which phases of the program
have been completed for the project and which phases are
pending.
3. Description of the project's relationship to the total effort
to meet the emission standards for the 1978 model year and
relationship to or dependency upon other projects. The
description should include whether the project was originated
because of the 1970 Amendment to the Clean Air Act, the
original objective of the project if they have changed since
inception, the percent of direct cost attributed to the
present project objectives, and the basis of the percentage
attribution.
b. Direct research, development, testing and engineering cost
should be summarized in this sub-section. These costs should be presented
as shown below - by type of expense and by year of expenditure, including
projections for 1975 to 1978, if possible for each project or project
phase described in. 2(a). Financial data presented in this sub-section
nust be consistent with the project narratives of 2(a), and should
conform to the normal accounting year of the company, with
designation of the fiscal year end. Expense classification applied
and specifically indicated when a classification change has been made.
-------
-------
The financial commitment for services supplied by outside organizations,
i.e., those services financed by the company that can be directly related
to its emission control program, should be reported. The following
outline should be used to report direct costs for each project identified
in 2(a) :
Actual Projected
Projection Title Costs Costs
69, 70, 71, 72, 73, 74 75, 76, 77, 78
Direct project costs
1. Salaries and wages
(A) Professionals
(B) Laboratory technicians
(C) Other technical & clerical
2. Chemicals and gases
3. Laboratory supplies
4. Outside services (identify)
5. Rental expenses
6. Equipment purchases expense
7. Depreceiation expense*
8. Other direct costs (identify)
9. Total direct project costs
Other information
10. Number of personnel directly
assigned to project at end of
each year.
(A) Professionals:
Full Time
Part Time
(B) Laboratory technicians '
(C) Other technical & clerical
^Submit separate schedule indicating costs of buildings and/or
equipment purchased and the respective asset life used to
calculate depreciation.
-------
-------
-5-
c. Company should indicate in this sub-section all other costs
that may be allocated to the emission control projects reported in
2 (a). Such costs are to be listed by year of expenditure, including
projections for 1975 and 1978, if possible, along with a detailed
description of the expenditure and the basis for allocation. The
nature of these costs, (e.g., research and development administrative
costs, employee benefits, util^.ies, depreciation of certain research
and development facilities) makes it normally not practical to allocate
the costs of each project.
d. This sub-section should contain a summary of emission control
program costs of each year (69-78). Direct project costs of projects
reported in 2(b) should be totiled and added to the total other allocated
from 2(c). This total should be the total cost (past and projected) of
research, development, testing and engineering by year as applied to
emission control systems for light duty vehicles. Total company
Research and Development cost by year and total domestic (U.S.)
light-duty vehicle sales by year (69-78) should also be presented in this
sub-section.
Additional Information
Part V A, First Cost Information, of the "Outline for Emission
Control Status Report" has been extended to include the specific costs
by major engine family. If this information was not contained in your
response to our September 20 request for information, please submit
it with the response to this request.
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-------
APPENDIX C
-------
-------
Attachment 1
CHRYSLER CORF.
-------
-------
CORPORA
K A ?. -.; s :
April 11, 1975
Mr. Eric O. Stork
Deputy Assistant Administrai,.,r
Mobile Source Air Pollution Control (A.W-455J
Environmental Protection Agency
401 M Street, S.W.
Washington, D. C. 20460
Dear Mr. Stork:
In response to your letter of March 2B, 1975 to Mr. S. L. Terry,
I am forwarding to you the requested information, regarding Chrysler's
commitment of dollar resources and manpower to NOx and HC/CO
emissions control for the 1970 through 1975 calendar years.
It is hoped that this information will prove sufficient to satisfy
the needs of your Agency and the Senate Public Works Committee in.
determining the degree of effort that Chrysler has expended in these
two areas of emission control. We appreciate the opportunity to clarify
the information that we supplied to you in our February, 1975 Progress
Report on Chrysler's Efforts to Meet the 1978 Federal NOx Emission
Standards.
Sincerely yours,
CMH:mn
Attachment
cc: Mr. S. L. Terry
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-------
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SECTION II
- FINANCIAL SUMMARY
Chrysler's commitment of its resources to vehicle emission
control for the years 1967 through 1975 is shown on Table
One on Page I-B-3.
Table Two provides a breakdown of our financial commitment
for the years 1970 through u/*74 by emission control tech-
nology programs. The following list, indicates which of- the
1974 cost categories the 1975 cost categories are being
placed into for the comparisons to 1974 arid before cost
categories in Table Two.
Table Three provides a brea, down of emissions control
resources expressed as a percentage of the total ER&D
resources. Table Four details Chrysler's capital costs
for labs, equipment, and facilities added for the 1973
and 1974 calendar years for engineering activities engaged
in emissions control. Table Five if- a detailed breakdown
of the emission control dollar resources estimated to be
spent in the 3,975 calendar year.
1 - Engine Modifications
CN Evaporative Emission Control
UB A-4G6 Long-Life Spark I Mog
COG Improved Carburetion
COH Advance Carburetion
CoJ Altitude Ccrnpeii.-ation
UI Electronic Lean Burn (A--4L6)
COK Improved Emission Components
COP Temperature Control
CP/2 Emissions Certification (1/2 of this in
Catalytic Reactors)
2 - Electronic Engine Control
COC Lean Burn Concept Plus Oxidation Catalyst
SX Electronic Fuel Metering (A--330)
3 - Thermal Reacbgrr.
COB Air Purnp Development
-------
-------
4 ~ Catalytic Reactors
COA Oxidation Catalyst Development
COE Exhaust Heat Conservation (Reactor)
COI NOx Reduction Catalysts
COM Production Support - Emissions
CON Emissions Support Testing
COR Emissions Cost Reduction
COQ Engine Dynamometer Durability
CP/2 Emissions Certification (1/2 of this in
Engine Modification)
5 - Alternate Power Sources
ST A-907 Gas Turbine
It can be rioted that, unlike its major competitors,
Chrysler does not manufacture many of the vehicle
components that are important to the control of
emissions. Carburetors, spark plugs, air pumps,
electronic sensors, thermostatically controlled
carburetor air cleaners, catalysts, exhaust systems,
and crankcase ventilation valves are all purchased
from outside vendors. The cost of the basic research
and development of these components is borne by our
vendor companies and is not therefore reflected in
the Chrysler costs r,hown in Tables One, Two, and
Three. However/ Chrysler's share of these component
development costs is reflected in the purchase price
of such components from our vendors.
Reference should aluo be made to Section I-B of this
report which provides the details of Chrysler's pre-
sent level of personnel, equipment, and facilities
devoted to emissions control activities.
-------
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TABLE TWO
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TABLE THREE
EMISSIONS CONTROL RESOURCES PRESENTED AS
A PERCENTAGE OF TOTAL. ER&D RESOURCES
% Dollar
:alendar Resources
Year (Emissions)
1967
1968
1969
1970
1971
1972
1973
1974 Eat.
1975 Est.
4%
5%
7%
11%
16%
16%
32%
ft
28%
29%
% Dollar
Resources
(Safety)
-
-
13%
16%
11%
14%
11%
13%
% Dollar
Resources
(Other)
-
-
-
76%
68%
73%
54%
61%
58%
% Total
Dollar
Resources
(All ER&D)
-
-
100%
100%
100%
100%
100%
100%
n the months of -January and February, 1975, the following percent-
ge of those persons workiny in the Engineering Office, Product
lanning, Research and the Emissions Office were working on the
missions or safety areas:
Emissions
Safety
32.4%
12.3%
44.7%
t should be noted that the percentage of personnel devoted to
missions control projects for these months is at an all-time
igh.
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TABLE FOUR
CAPITAL CGSTG OF KMISSKJN CONTROL LABH, EQUIPMENT
AND FACILITIES FOR THE 1973 AND 1974 CALENDAR YEARS
Chassis Engineering
rehicle Engineering
Emissions
tesearch
u3min. Services
TOTAL
($ in Millions)
J97_3
$ . 7M
2.4
7.2
.7
2.3
$
$13. 3M
1^74.
$1.8M
.4
4.8
.2
2.1
$9.3M
Total
$ 2.5M
2.8
12.0
.9
4.4
$22. 6M
Reference Section I-B of this report for a detailed explanation
jf the lab equipment or facilities added for emissions control
,t Chrysler during the 1973 and 1974 calendar years.
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TARLK JFIVE
EMISSIONS CONTROL
DOLLAR RESOURCES (DETAIL)
CALENDAR YEAR 1975 (ESTIMATED)
($ in Millions)
Cost
ate gory Project^ Title* ER&D
COA Oxidation Catalyst Development $ 3, 5M
COB Air Pump Development .5
UI Electronic Lean Burn (A-416) 2.3
COG Lean Burn Conceit: Plus Oxidation
Catalyst ,5
COB Exhaust Heat Conservation (Reactor) .7
COG Improved Carburetion 2.0
COH Advance Carburetion 1.2
SX Electronic Fuel Metering (A-330) 1.4
COI NOx Reduction Catalysts 2.3
COJ Altitude Compensation ~ 1977 .2
ST A-9Q7 Gas Turbine 1.9
CN Evaporative Emissions Control .9
*
COK - Improved Emissions System Components .8
UB A-406 Long Life Spark Plug .2
COM Production Support -- Emissions 1.1
CON Emissions Support Testing .9
COP Temperature Control * .8
CCQ Engine Dynamometer Durability .7
COR Emissions Cos!; Reduction .4
CP Emissions Certification 6.5
Total Calendar Year 1975 ER&D $28.8M
Capital and Administration 6.0
$34. 8P.
^Reference Pages £I»A-J through A-21 of Volume II of
this report for a detailed project description.
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Attachment 2
FORD MOTOR CO.
-------
-------
MCTJO\ VIII - Schedule B
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/V /6~
- 157 - r-- .
Section IIr Financial Cgromltoent
Section VIIIA of Ford's Application for Suspension of 1977
r Vehicle Exhaust Emission Standards summarizes the alloca-
tion of Ford's emission control activities among 22 general pro-
ject categories. The following Table presents financial data for
>ach of these same 22 project categories relating to Ford's
:fforts for 1978 low NOX development.
Total research and engineer-ing expenditures were 17.8
illion dollars for calendar year 1974, up 3.8 million from 1973
xpemlitures of 14 million dollars. .
Note:
EPA discussions with Ford staff members revealed that Ford's
NOx expenditure data was compiled for efforts directed towards meeting
the 1978 standard only and did not include NOx research in meeting
earlier standards which could be applied to the 1978 standard.
-------
-------
AC.VAI,
- 158 -
^ijfi'^'UYiry-'L i.\r; ']Hyin;vs
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earch ft. Engineering
Ca 1 enda r Yea r h':-penditii r« ;,
Project Description
f:S:I) of systems designed for rif;eting 1075 Federal
s tanclards
R2-:l) of systems designed J or r.eeting 1978 Federal
standards
ll";D of sydtc.ii'.: designed for iiu-eting 1974
California Standards
Catalyst Cor,ijx>nt)
551 ( $3%}
290 ' ( 50%)
85 ( 2£$)
418 ( 12$)
57 ( 16$)
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241
499
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318
1,060
407
305
40
5,245
15
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446
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6,769
S3 7. 738
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-------
Attachment 3
GENERAL MOTORS CORP.
-------
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-------
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SECTION VI1!
PROGRAM EXPENDITURES, CONSUMER COST AND MANPOWER
Section Vlli relates to the financial and manpower commitments made by
General Motors toward meeting the 1978 emission standards for oxides of
nitrogen. Genera! Motor-., is devoting financial resources and manpower to
attempt to comply fi;l!y n,> n 'imely basis with federal mandated emission
standards, i-'urfher, implied in al! our research and development programs is
GM's continuing commitment to improve vehicle fuel economy, with current
emphasis being directed towards meeting the President's goal of a 40% improve-
ment in fuel economy for ihe industry by 1980, This will mean a 53% safes
weighted improvement for CM,
Segregating expenditures or manpower data to the extent thai they are specific
to a federal mandated standard (such as the 1978 oxides of nitrogen standard)
is extremely difficult. This is attributed to the fact that the technology itself
cannot be isolated. As sfutad numerous times, standards set for hydrocarbons
and carbon monoxide emissions affect the development of the oxides of nitrogen
control systems because the control technologies interact. Since the control
technologies cannot be iso!<;'ad technical!y,, they cannot be segregated b/ cost.
Emission devices currently installed in many of our vehicles will continue to be
used in both the 1977 and 1978 systems, with improvements being made to these
devices where necc-ssary. Consequently, the financial and manpower data filed
with our request for suspension of the ]977 emission standards is relevant to the
?978 standard and should be considered as part of our response toward meeting
the oxides of nitrogen standard for 1978.
As mentioned in previous correspondence and testimony, General Motors does
not have the technology to comply with the 1978 statutory requirements of
.41 HC, 3.4 CO ard .A ,\'OX for 50,000 miles. To rre.~i these re
-------
-------
-2-
jn omission control sysf<-v> must ir.vet a preproducfion certification test for v
50,000 miles- In addition, tha system must be warranted In customer's use
or 50,000 miles or !i years. We have not yet been able to develop a system
hat has adequate durability performance to meet either of these requirements.
F General Motors were required to choose a system at this time, it would most
ikely include the following components in addition to those on 1975 federal
chicle;;
1. Air Injector Reactor Systems
2. Improved Exhaust Gas Recirculatfon
3. Catalyst Change Reminder System
4, Electric Choke
'j. Closed Loop Feedback Control System
6, Reducing Converter
!e$e components wool'I odd approximately $340 to the consumer cost of the
?75 vehicles. It should be noted that fhe two catalysts (oxidizing and re-
icing) would require a change every 5,000 to 10,000 miles based on current s
chnology. The undor floor converter oxidizing catalyst change would cost the
>nsumer from $60-$70, The consumer cost in effecting the cafafysr change In
} reducirKj converters has jiot been estimated at this time, buf If is expected
exceed significantly the cost of a change for the oxidizing cataFysto
3 facilities required to produce the above hardware will depend on the sysfern
?sen fo moet the 19/7 jixuidards. jf a warm-up converter is Included on 1977
licles, it would \>Q dropped hi J97H, However, some of those facilities could
bably bo diverted to produce the reducing converter. The additional expend?-
is required to meet the !978 emission standards are presented on fwo alternate
es: i.e., (1) if the i97/ system included the warm-up converter, expenditures
$140 million would be required, or (2) If the 1977 system excluded the warm-up
verter, expenditures of $270 million would be required.
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-3
Including Worm-up Excluding Warm-up
Converter In 1977 Con verier in 1977
1977
1978 Combined
1977
1978
Com bin
C !*-* Jk A * f I * *-,
-*.-.-._,*-....-. ..^ | pj |Y^| j 1 1 ons~" * ~ -* " *"
125
60
20
205
75
55
10
140
200
115
30
3?5
25
25
10
60
.
175
75
20
270
200
100
30
530
Foci 15 ties
Tools
Rearrangement- and Start-up
Expenditures
Total
As mentioned it) previous sections of fhis report, the 3-way cafalysf is also being
considered os a method of meeting the 1978 standards although, based on currenr
Technology, fhis system does not approach durability requirements. The following
components, in addition to the 1975 hardware, are considered Integra! to this
system:
I. 3-Way Catalyst
2. Closed Loop Feedback System
3. Electric Choke
4. Improved Exhaust Gas Recirculafion
5, Catalyst Change Reminder System
If is expected rfiaf this system would odd $150 to the customer cost of the 1975
system. If would cost Genera! Motors in the area of $70 million for facilities,
tools, and skirt-up, etc. If this system were used in 1978. This would be in
addition to facilities, tools and start-up expenditures ranging from $60 million
to $205 million which would be required to meet 1977 standards, if technology
can be developed to perm?;- me e ling these standards (see prior tabulation).
It should be recognized that if this system were adopted there would be no need
for the addition'!! A!R purnp capacity and warm-up converter capacity acquired
to meet the 1977 standarrk. This illustrates the compounding of ihe problems that
occur v/hen stondnrds arc frequently revised. If it is assumed that no other use
could be made of these facilities, GM v/ould have !o idle or dispose of approxi-
mately $200 nillii'jn worth of facilities and tools af'er one year's uro.
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;f mus." bo pointed out rhui due to fhe early stage of development "best guess"
, , , ___ __ S ^
iypa estimates are all that are possible clearly, (he estimates we are able
io make now are not the result of "forma!" or "detailed" studies. If the des-
cribed .systems are ever developed and manufactured, the actual costs and
expenditures could vary significantly. (All estimates are based on 1975 economic
fevels.)
It should be noted that at the time iofai capital expenditures were being com-
./iled far our initial submission for suspension of the 1977 standards, warm-up
:tnd reducing converter facilities were not considered due to the preliminary nature
jf their development. Subsequently, ihey have been included in our supple-
nentol filing dated February 14, 197'; on a "best guess" basis. These expendi-
ures would be substantially additive to the amounts reported In our January 10,
975 fillncj for suspension of the 1977 emission standards. These expenditures
/III be rmide principally in the 1976 arid 1977 calendar years.
should be further noted that General Motors recommends a conrlnuance of the
975 exhat.^ emission requirements through the 1980 mode! year in the Interests
f conserving the fuel economy gainnH by our current models and to avoid
/>
mecessary "economic hardships" on our customers,
Ifh re sped to the 1974 data, (nformui'ion furnished In connection with the 1977
spensioti request was developed on an estimated basis. Attached are two
ledules complied for fiio purpose of replacing 1974 estimates with actual data
w available. Actual detailed information, pertaining to fhe 27 project
tegories listed on Schedule B of our !977 suspension request Is sfiH not avafl-
le for 1974. However, we expect ihat spending in those categories will
low the same pattern as uur projection of 1974 (submitted with the 1977
pension request) since forai spending under major headings research and
jineering; reliability, inspection and testing; facilities and tools Is about
same as projected. ,
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-5-
!n connection wifh our 1978 calendar year projection, if a technological break"
through is achieved then our research and engineering programs relating to
1978 standards should be completed. However, our reliability, inspection and
testing programs will confuuj;; as will our research and engineering efforts on
alternate power sources and other methods of achieving emission sfandards on a
more economical basis. Because of the uncertainties that exist, we are unable
to forecast these expenditures at this time.
With respect to our 1978 manpower projection, the uncertainty associated with
the 1978 requirements preclurles a workload forecast at this time.
Total actual U.S. Research, Development and Engineering expenditures for 1978
calendar year are expects'! to be about the same level as 1974 which is also
about the same level as 1977, as shown on Schedule F of our request for sus-
pension of the 1977 emission standards.
At this time, no reliable projection of unit sales can be made for the 1978
calendar year, This result from uncertainties due to many variables such as
economic conditions broughr ubout by inflation and the energy problems,
possible Increased penetration by overseas manufacturers, federally mandated
safety and emission standards and other possible items like gasoline rationing,
increased toxe-> on gasoline rind car weight taxes,,
The above information and trie information submitted In connection with our
previous request for suspension of the 1977 emission standards shows clearly that
General Motors has made an
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KOTOS:1. CORPORATION
FACTORY SALES OF
U.S. DOMESTIC PRODUCTION AND IMPORTCD
1974 Actual
ssenr.er Cars
Chevrolet
Domestic
Imports
Total
Pontiac
Domestic
Imports
Total
OldsEobile
Domes tic
Imports
Total
Buick
Domestic
Imports*
Total
:adillac
Domestic
Total Domestic
Total Imports
Total
jcks (6000 RVW or Less)
Chevrolet
Dottiest
Imports**
Total
2-1C
Domestic
laports
Totp.l
.'otal D'Maestic
Total Inports
Total
Ir.cludea Opel
Jnclu-les LUV
1974
Fvojfcct-d
l,97/,'i44
236^093
2,,214,V42'
5?/i ,686
10J56
536,842
561,546
9,353
570,999
410,509
60,562
471,071
232^639
3,708,824
317jjD69
4^0?5A/393_
54«,742
77,604
626,346
101,261
7,245
1Q3 ,506
650,003
84,849
7 j''t ,852
1974
Actual
1,905,457
236,039
2^141,537
503,100
9,849
512,949
550,529
9,747
560,276
402,032
62,014
464,046
230,, 857
3,591,975
_ 317?j90
3Jj_Q9J665
541,801
81t805
623,606
96,253
6.316
102^569
638,054
88,121
726, 175
Over/ (Under)
1°74 pro-jftcted
( 71,837)
( J.18)
( 72,805)
( 23,586)
(. 307)
( 23,893)
( 11.U7)
394
- ( 10,723)
( 8,477)
1.452
( 7,025)
( 1,782)
(116,849)
621
(116,228')
( 6,941)
__^2JOl
( 2.740)
( 5,008)
( 929)
( 5,937)
( 11,949)
3,272
( 8,677)
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\t<
Regi-m V:
230 OCUail
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GENERAL MOTORS CORPORATION
U.S. EXPENDITURES AND MANPOWER
(Calendar Ynar Basis)
a Control Expenditures
($ Millions)
Research and Engineering
Reliability, Inspection
and Testlog
Facilities and Toola
CM Contribution to MVMA*
Total
Estimated -- final data not available.
1974
Projected
$
140
33
277
1
45f
1974
Actual
$
136
33
284
1
454
1974 Actual
Over/(Under)
1974 Projected
$
(4)
($ Millions)
Total U.S.
Resaarch, Pev_e 1 opmentand Engineering Expend jtares
1974
Projected
$
1,090
1974 Actual
Over/(Under)
1974 Projected
$
94
Bnission Control Equivalent Rnployment
Full Time
Part Time*
Laboratory Technicians
Other Technical and Clerical.
Total
1974
Projected
751.0
622,8
950.2
24652.0
4,976.0
1974
Actual
731,0
535.1
967.2
2j556.8
4-^TjlOa
1974 Actual
Over/ (Under)
1974 Projected
( 20.0)
( 87.7)
17.0
( 95.2)
(i§UU
* Full tine equivalent
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