United States
           Environmental Protection
           Agency
Mav 1995
wEPA    Highway Vehicle  Emission
           Estimates  --  II

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                      DISCLAIMER
        This  paper  has  not been peer  reviewed.
    It  is  intended to  present  the current thinking of
 the Office of  Mobile Sources  with  respect  to  a number
of  issues  pertaining  to  the accurate  modeling  of  in-use
emission  factors  for highway  vehicles,  and to facilitate
  discussion  of these issues  among  interested  parties.

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June  9,  1995

The  paper "Highway Vehicle  Emission Estimates  -  II" (May 1995) is  an
update to an earlier paper of the same  title released  in July 1992.  The
earlier paper, as well as this  update, were prepared  in  response  to
concerns  regarding  potential  underestimation  of in-use  highway  vehicle
emissions by highway vehicle  emission  factor models.  A  number of
studies  had  provided  indications that then-current estimates of  total
highway  vehicle  emissions may  be  too  low.   Among  these were  tunnel
studies (such  as the 1987 Van  Nuys tunnel study),  roadside emission
measurements (including  the  use of  remote  sensing  devices),  and
ambient  concentration comparisons.   Each provided  suggestive but  not
definitive evidence  that the total  emissions  contribution  of highway
vehicles  is  understated  by  current  emission  inventory  development
procedures,  which include the  use of emission factor  models (such as
MOBILESa)  to  estimate average in-use  per vehicle emission rates in
grams per mile.

EPA  was aware  of  a  number  of areas  in  which then-current practice,
including  the collection  of in-use vehicle emission  data,  could be
improved.   Some of these improvements are reflected in MOBILESa,
released  in  1993,  while  others will  take  longer to implement.  The EPA
approach  to  estimating highway vehicle emission factors prior to 1990,
the known  limitations of that approach, issues  that  have been identified
as possibly  contributing  to the  underestimation  of in-use  emission
levels by the model, and the  approaches EPA has undertaken and is
planning  for the future  to address  these issues,  are  discussed in  these
papers.   This second  paper provides updated information  on  a  number
of issues relevant to estimating highway vehicle emission factors and
emission  inventory  contributions.

This  paper  is intended to provide an overview  and to facilitate
discussion; it is  not  a  statement of official  EPA policy. Comments on the
paper and the  issues discussed  therein  are welcome,  and should  be
directed  to:

                  Mr. Terry Newell (AQAB)
                  U. S.  Environmental Protection Agency
                  National Vehicle  and  Fuels  Emission Laboratory
                  2565 Plymouth  Road
                  Ann Arbor, MI  48105

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 Summary

       In July  1992,  EPA's Office of Mobile  Sources released  "Highway  Vehicle
 Emission Estimates."  a  document  that  was prepared  in  response to  heightened
 attention  to and concern  about  the  accuracy of  emission inventory  estimates
 for  highway mobile sources (sometimes  referred  to as the  "QMS White Paper"
 on  vehicle  emissions).1   Highway  mobile sources (cars,  light and  heavy  trucks,
 buses,  and  motorcycles)  account for a  significant portion of overall emission
 inventories  for volatile  organic  compounds (VOC), carbon  monoxide  (CO), and
 oxides  of  nitrogen  (NOx).  With a  substantial part of the  nation's  population
 living in areas that fail to attain  the  National  Ambient  Air Quality  Standards
 (NAAQS)  for  ozone and/or CO,  the  need  for  additional reductions in  emissions of
 these pollutants  is  clear.   In  order  for  officials to  make the best choices in
 achieving  the   needed  reductions,  accurate  emission  inventory  estimates   are
 crucial.

       In the  late  1980s,  the  results  from a  number  of  different studies along
 with  other  evidence  suggested  that  the  inventory  contribution  of  highway
 vehicles was being  underestimated  by  the methods in use  for  calculating such
 estimates  at  that  time.   The July 1992  paper  provided  an overview  of some the
 more important  studies  that  suggested  this,  including studies of  ambient
 emission ratios  and  the  1987  Van Nuys tunnel study.   The July  1992  paper also
 summarized  many of the  known  weaknesses  in the  methods  used  to  develop
 these estimates,  from  the  process of collecting  data on  in-use  vehicle  emissions
 performance, to   the  calculation  of  average  fleetwide  emission  factors  under  a
 range of  conditions  and driving,  to  the estimation of the total  vehicle  miles
 traveled  (VMT).   Finally, it  outlined  some of the significant improvements that
 EPA  was  implementing  and  planning  to  implement to improve  the  accuracy  of
 the  process.

       Since the  release of the  July  1992  paper  on  highway  vehicle  emission
estimates,  considerable  activity  has  occurred  on  a  wide  range  of  issues
discussed therein.   EPA  has  revised the  highway  vehicle emission  factor  model
(the  latest  version,  MOBILESa, was  released in May  1993) with the  net effect of
a  number  of  changes being  an  increase  in  the  estimated average  in-use
emission  rates   for  light-duty  gas vehicles  under   most  conditions.    Additional
tunnel  studies   have  been  performed,  using  tunnels with different
characteristics  and  in  other parts of the  country.    An  evaluation  of various
ambient  emission studies conducted  in  recent years has been  performed.   EPA
has  implemented  a number of new regulations  under the provisions of the
Clean Air  Act  Amendments of 1990  that  are  designed  to  further reduce in-use
emissions from new cars,  trucks, and  buses.   Studies  intended to  address  other
concerns, such  as  the  representativeness  of the driving cycle  long  used  to
certify  new  vehicles  and  as  a baseline  for other  emission estimates  from  those
 vehicles,  have  made  considerable   progress  in  determining   improvements  and
changes  that  are necessary in order to  increase  the  accuracy  of  highway
 vehicle   emission  inventory  estimates.

       This second  OMS  "White  Paper" on highway vehicle  emission estimates
provides an  update on  these   topics.    Some  background  information  provided in
the July 1992  paper  is  repeated below.   Following  that,  the  revisions that have
been  made  to  EPA's  highway vehicle  emission  factor  model and the effects of
these changes  on emission  factor estimates are  summarized in Section 1.   A

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summary of  the  findings  of  an  evaluation of  various  ambient  emission  studies
is given  in  Section  2,  and  in  Section  3  more  recent  tunnel  studies are discussed.
A comparison of emission  factors estimated by  MOBILE5a to those calculated  by
the  1987 Van Nuys  tunnel  study, as well as the  1992  Fort McHenry and
Tuscarora  tunnel  studies,  is  presented  in  Section 4.    Section 5  provides  a recap
of  many of  the  issues concerning  the accuracy  of  highway  vehicle  emission
factor and  inventory  estimates, in  the  format  used  in the first  July  1992 paper.
Finally,  Section  6 outlines  some  of  EPA's  plans  for the  next major revision  to
the  model  (which will  be  MOBILE6),  and  other  ongoing  research  is  briefly
discussed.

       The  next  section (Background)  is largely repeated  from  the July  1992
paper, and  is included here  as refresher  and for the benefit of readers  that
may  not be  familiar with  that  document.   Readers unfamiliar  with the  first
White Paper  are  encouraged to obtain  a  copy by contacting  QMS.2

Background

       The  three primary  pollutants  from  motor vehicles and  engines  for
which EPA  has  established  emission  standards  are   hydrocarbons  (HC),  carbon
monoxide (CO),  and oxides of nitrogen  (NOx).   All  of these  pollutants  are  emitted
from vehicle  tailpipes  when  the  engine   is  running   (exhaust  emissions).
Vehicles  also  emit  HC through evaporation of  fuel from  the engine  and fuel
system   when  they   are  not  running:    Diurnal  ("breathing") emissions,  trip-end
("hot soak")  emissions, continuous  resting  loss  emissions (as can  occur  due  to
porous  tubing  in the  evaporative  emission  control   system), and  refueling
emissions  (vapor  in the partially  filled fuel tank  being  displaced  by  the
addition  of new  fuel),  and  from sources  other  than  the  tailpipe  when in
operation (running  loss  emissions).   Some vehicles   with  disabled  or
disconnected  hoses  also exhibit crankcase  emissions   of  HC  ("blowby"  losses).

       One  key  to  the  accurate  assessment of air quality problems  and to
estimating reductions in  air  pollution  is  the development of   reliable  emissions
inventories, which  quantify  the total  amount  of  a given pollutant  under a
specified  set  of conditions.   Emission  inventories, usually expressed  in  tons  of
pollutant  per  year,  are  the product of  two  factors:    emission factors and
activity  levels.    An emission factor  expresses  the amount of  pollution emitted
per  unit  of  activity (i.e.,  grams  of carbon  monoxide  emitted per  vehicle  mile
traveled).   An activity level  represents the amount  of  the  given  activity that
occurs over  a specified period of  time (i.e.,  vehicle  miles traveled by highway
vehicles  in  a  metropolitan area on  a typical summer  ozone  season  day).   The
sum of  the products  of the  emission factors  and  activity levels for all sources  of
a  given  pollutant  constitute the emission  inventory  for  that   pollutant.

       For  highway  vehicles  (light-duty   vehicles,  light-duty   trucks,  heavy-
duty  trucks,  and motorcycles,  both gasoline and diesel),  emission factors  are
most often  expressed  in  grams  of pollutant  emitted  per mile   driven  (grams per
mile, or  g/mi).   The  activity  level  for  highway vehicles is generally vehicle
miles traveled (VMT).   Emission  factors and VMT can  be estimated for each
individual  vehicle type, or  for  all highway vehicles  as a  group.   The  scope  of a
highway  vehicle  emission  inventory  can be as  small  as a single  link of  a  given
roadway  for  a specific hour,  or  as large  as  an entire  Consolidated Metropolitan
Statistical Area (CMSA),  State, or  the  whole country  for an  entire  year.   In any
                                                                               May 1995

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event,  development  of  an  accurate  emission  inventory  for  highway  mobile
sources  requires the  best  possible  estimates of  the emission  factors.

       Since  the  late  1960s  EPA has  issued and periodically  tightened emission
standards applicable  to  highway  motor  vehicles.   However,  the emission
standards applicable  to  new  vehicles  do  not  represent  the  emission  factors
applicable  to those vehicles  once they  are  actually  in use.   Emissions from
vehicles vary  over  the  entire  range of  conditions  that  vehicles  operate  under:
ambient temperature,  traffic  conditions  (represented  by   average  speed  in  the
MOBILE emission factor  model),  operating  mode (the mix of cold or  hot starting
and  warmed-up  vehicle  operation),  fuel  volatility  and. composition,  types  and
condition of emission  control  equipment  and other  vehicle  or  engine
components  that  affect  emission  levels  (maintenance),   expected  deterioration
in  emission  control  performance  with  increasing  age/mileage  of the  vehicle,
and  other  variables  all  affect the  emissions  actually produced  by  vehicles  in
everyday  use.   In addition, the  in-use  vehicle  fleet  is composed of several
generations   of  vehicles  and  emission  control technology,  each  of which
behaves  differently in terms  of in-use  emission levels and  how these  levels
change  over  time  (as the vehicle ages  and accumulates  higher mileage).   Thus
average  in-use  highway  vehicle  emission  factors  are  estimated  using
computer models,  which  allow emission  factors for  different vehicle  types  to
be  estimated  under conditions specified  by the  user of  the  model  and combined
into  an  overall estimate of emission factors for the  in-use  vehicle  fleet.

       Direct measurement  of emission  levels from  all  in-use  vehicles under
all  possible  conditions is clearly  impossible.   To  estimate in-use emission  levels,
EPA  conducts surveys  in  the form  of vehicle  test  programs, collecting emission
data from as many vehicles as is  practical  over  as wide  a range of conditions
affecting emissions as possible.   Time  and funding  are  the  constraints that
determine what is  practical in terms of adding  to  the  emission factor data
bases.   Over  the last  25 years, EPA has collected emissions data from Federal Test
Procedure (FTP) tests on tens of thousands of  in-use vehicles  under  the
emission factors  program (EFP).   The EFP  has also  accumulated data on
thousands of vehicles tested  over non-FTP  cycles  (e.g.,  speed  correction  cycles.
Highway  Fuel Economy  Test  cycle)  and conditions  (e.g., different
temperatures,   fuels).

       Direct measurements  of  emissions   from  highway  vehicles  operating   on
the road  have  become available  through  the  results of  several on-road
emission  measurement projects  and  tunnel  emission studies.   One well
publicized example  of such  a study  is the Van Nuys, CA tunnel study, sponsored
by  the  Coordinating  Research  Council (CRC) and conducted  in  1987.   The  results
of  this  study  were  widely interpreted  as  indicating  that the highway  vehicle
mobile  source emission  factor models developed by  the  California Air
Resources Board  (ARB)  and  by EPA  may underestimate  hydrocarbon  (HC) and
carbon  monoxide (CO) emissions  from  highway vehicles.   (California has had
more  stringent  motor vehicle emission  controls than  the rest  of  the country
since  the 1970s.   Emission  factor models have been developed by  both EPA and
ARB.   The   current versions of these  models are  known  as MOBILESa  and
EMFAC7F,  respectively.)   That  study initiated  increased  scrutiny  of  in-use
emission  factor  and  inventory estimates; work  inspired  by  that  study and its
reported  results   continues.
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       Since  then,  two other  major tunnel studies  have  been conducted  in the
U.  S.,  one in the  Fort McHenry tunnel  under  Chesapeake  Bay (Baltimore)  and
another  in  the Tuscarora  Mountain  tunnel in  Pennsylvania.   The  results  of  the
tunnel  studies  and  their  implications  for highway  vehicle  emission factor
estimation are also discussed in a  later section  of  this paper.


L	Revisions   to the   MOBILE   mnHpl

       Since  the  release of  "Highway  Vehicle  Emission Estimates" in July  1992,
EPA  has extensively  revised the model used to  estimate  average  in-use  emission
factors  for  highway  vehicles.  At  the  time that  the  1987  Van Nuys tunnel  study
was performed, the  current EPA  model  was MOBILE3  (1984).  The July  1992
paper  presented  a comparison  of emission  factors calculated  by  MOBILE4.1
(1991) to those measured  in the Van  Nuys tunnel study, with the  MOBILE4.1
emission  factors  corrected  to  account  for  the  differences  in  microscale  and
area-wide  weightings  of  the contribution  of  vehicles of  each  specific model
year to the total  fleetwide  average  emissions.    In March  1993,  EPA released
MOBILE5a, a  corrected  version  of MOBILES (December 1992).  MOBILESa  is  the
current  model  at  the  time of this  writing, and  is used for the  comparisons  to
tunnel study-measured  emission factors  later in this  paper.

       EPA has  continued  to collect  emission factor  data from in-use  vehicles,
and  has  expanded its  data collection  efforts  to  include  IM240  program  lanes
(see "Recruitment  Bias  in Emission Factor Testing"  in the section  on
implemented and  planned  improvements to the  model).    This  section  presents  a
brief  summary  of the   most significant changes  that  have been  made to  the
MOBILE  model since  1992.   For a more thorough discussion  of  these  changes,
see Chapter 1  of the "User's Guide to MOBILES."

       Updated Basic  Emission  Rates

       The  basic  emission  rate  equations  describe emissions  as a function  of
increasing  odometer  mileage,   for properly   maintained  non-tampered   vehicles.
The  rates consist of zero-mile  levels  (ZMLs)  and deterioration  rates  (DRs),
which  indicate how much  emissions  are predicted  to  increase  with increasing
age/mileage.    For  light-duty gas  vehicles  and  light-duty  gas trucks,  there are
two distinct DRs,  with  one being applied  to the first 50,000  miles  of  accumulated
mileage and the second (higher) DR  being applied  to mileage in  excess  of
50,000.

       The data used  to  develop the  basic emission rates  for  use  in  the model are
collected  under the Emission Factors  Program (EFP).   Historically,  such  data
have  been  collected  primarily   through  mail  solicitation  of  owners  selected
from  vehicle   registration   lists.   Under  this  method  of  recruitment,  privately
owned vehicles are recruited  by  mail  (invitation postcards)  to  loan  their
vehicles  to  EPA  (or an EPA  contractor) for  testing,  and  incentives for
participation  (e.g., use  of late  model  leaner  vehicle)  are  provided  to the
vehicle  owner.    Typical  response rates  (the  fraction of  those owners contacted
about  participation  in   the  program that  agree   to  participate) have been  low,
raising  concerns  about  biases  in the  samples  of in-use vehicles  used to  develop
the BERs.  For  example,  one  might  expect that  an  owner who has knowingly
tampered  with his  vehicle,  or  one  who is  aware that the vehicle has  not  been
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 maintained  properly,  would  be  reluctant  to provide  that  vehicle  to  EPA  for
 emissions   tests.

       In the  last several  years,  EPA has  expanded the EFP to  include  collecting
 data  from  centralized  inspection  and maintenance  (I/M)  program lanes.   In  a
 centralized  I/M  program,   all  vehicles  subject  to  the  program  requirements
 must visit  one  of a  relatively  few  state-operated  inspection locations for  the
 test.   EPA  took  over  operation of one  lane at the  centralized I/M test site  in
 Hammond.  IN  for two two-year  periods,  separated  by a one-year  interruption.
 Recently, data  collection  at the Hammond  I/M  lane  ceased,  and  was replaced  by
 data obtained from  a  lane  at  a test site in  Chicago  Heights, IL.    A similar
 program of  data collection is currently  operating  at  one  lane  of an  I/M site  in
 Mesa,  AZ.   The  required  nature of  these tests means  that there is a far  lower
 degree  of  self-selection bias  evidenced  in  the  vehicles  that  pass  through such
 stations.   (There is  still some residual bias, in  that  most programs exempt
 vehicles  above a  specified age,  and sometimes also  those  under  another
 specified age,  from  the  program  requirements,  and  no  programs  achieve 100%
 compliance  in  practice.)

       The  I/M  programs  in  Hammond and Phoenix  utilize the  IM240 test, a
 short dynamometer-based  transient driving  cycle  test.   This  test cycle,  which
 was derived  from the  Federal Test  Procedure  (FTP)  driving cycle,  measures
 emissions over a  range of vehicle  speed and load.   Such  measurements provide
 a  much  more  realistic set of emission  measurements  than  do simpler  idle-based
 tests.   In  addition to  the   substantial  reduction  in  potential   sample bias
 described above,  EPA has   used  the data collected  from operating one  of the
 lanes in these  programs to  improve  the  basic  emission  rates  used  in the
 MOBILE model in two other  significant  ways.

       First, EPA  obtained  IM240-based  emissions  measurements of HC,  CO,  and
 NOx  from  all  of  the  vehicles  that  passed  through the  lane  being operated by
 EPA.   This provided  emission results  for  thousands of vehicles  annually  at each
 lane,  a  considerable   increase over the  hundreds  of vehicles   tested annually
 under  the  more  traditional  EFP.   Second,  EPA  has randomly  recruited a
 subsample  of  the vehicles that pass  through the  lane  for  additional  testing
 (including  full  FTP tests)  in  a  laboratory  setting.   Using the  IM240  lane  results
 and  the  lab-based  FTP results for those vehicles  has enabled EPA to  develop a
 statistical correlation  between  the  IM240 and FTP emission  results.   This
correlation was then  used  to  "predict" the  FTP  emission  results  for all of the
 vehicles  that  passed  through  the  EPA-operated  lane.   Thus,  this approach  both
 vastly  increased  the  sample  sizes  available  for  development of  basic  emission
 rates  and  greatly reduced the  bias, particularly  with  respect  to self-selection,
 of  the  samples.

       Another important  benefit  of  data  collection  at  the  I/M lanes follows
 from  the far  higher volume of  vehicles that are tested.   With  so many more
 vehicles, and (over time)  access  to a cross-section  of almost  all vehicles  in  the
 I/M  area, EPA  was able  to  obtain  significantly  more  data  from  vehicles  that
 have  "aged."   This refers  to  the  ability  of testing  at  such sites to include
 vehicles  that  are both  "old"  (measured  by  age)  aM have  very  high  mileages
(75.000  to  100,000 and greater).   Much  of the data  on  high-mileage vehicles
that  has been collected in recent years  came from  tests  of vehicles  that  had
accumulated  mileage  at  far above  average  rates  (e.g.,  a  vehicle is only 4 years
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 old but has  80,000 miles).   These  data  provided an  opportunity to examine
 whether  the  degree  of in-use  deterioration  in  emission levels  is  the same  for
 all  vehicles  that  have  high mileage (those  that  have  high  mileage  because
 they  are  used  more  frequently  and/or  for  longer  trips,  and  those  that  have
 high  mileage because  they  have  been in  use for  a  longer number of years.

        The  most  significant difference,  found  when  new  basic  emission  rates
 were  calculated from the IM240  lane  data,  relative to the previous basic
 emission  rates based  only on  data  collected  in  the mail-solicitation part  of  the
 EFP,  was an increase  in  estimated  deterioration  rates.   This may  be due  in part
 to  the inclusion of  substantially  more ail,  high  mileage  vehicles  in  the  test
 samples,  as  noted  above.   Relatively little difference  was  found  in the  zero-mile
 level  (ZML)  estimates.   Table  1  summarizes the basic emission rates  for  all
 three  pollutants  used in MOBILE4.1  and  those used in  MOBILES  for light-duty
 gas vehicles.   The differences  in the estimates for  future vehicles (model years
 1994  and later), particularly in the  ZMLs, are  primarily the  result  of the
 Federal  Tier  I  tailpipe emission  standards  mandated by  the Clean  Air Act
 Amendments  of  1990, which  were not yet  legislated at the time of  MOBILE4.1.

       These   changes  in  the  basic   emission rates, when  translated to changes
 in  average fleetwide in-use  emissions  as estimated by  the model,  resulted  in
 increases  on  the order  of  20 to 30  percent.  EPA  is continuing  to  collect  IM240
 data  for  further expansion of  the in-use data base  and refinement  of the  basic
 emission   rate  equations.

       Revisions  to Speed Correction  Factors

       The bulk  of emission  data available  for light-duty  vehicles  and  light-
 duty  trucks  is measured  during  Federal  Test Procedure  (FTP)  tests,  which
 include a  driving cycle  with an  average  speed of  19.6  mph.   This cycle,  which
 is  used  for  certification  of new  vehicles  for  sale  and  in  measuring  compliance
 with  standards  in  use  as  part  of EPA's  recall program, is  intended to represent
 urban  commuting driving.   Exhaust  emission factors  calculated by the MOBILE
 model are trip based,  with the  speed provided by  the  user  of  the  model
 representing  average  trip  speeds.   In  other  words, MOBILE exhaust  emission
 factors represent transient operation, and  include  the  effects  of  speed
 variability  (acceleration  and  deceleration),  time  at  idle  (such  as  at  red  traffic
 lights), and  some   cruising  at  relatively  stable   speeds.

       In  order  to   more  accurately  account for vehicle  emissions  in emission
 inventory  calculations,  emission  factors  representing  a broader  range  of
 driving behaviors  than are  included in  the  FTP are  necessary  for many  areas.
 While the emissions  impacts  of some of  these  behaviors are  not yet
 characterized  in  the  model  (very  high rates  of  acceleration,  for  example  -  see
 the discussion of the Non-FTP  Study in  section  6), the model  does include  the
 ability to  model emission  factors  at  other average  speeds in the range of 2.5  to
 65  mph.   This is done in MOBILE5a through the  use  of speed correction factors,
 which are applied  to  the  basic emission  factor  estimates  and  are  specific  for
 each  pollutant  and  vehicle  type.

       The  speed correction factors   in the  model  are developed  for  three  bands
of  average speeds:   "low" speeds, defined  as average trip  speeds  under 19.6  mph
down  to 2.5  mph;   "mid-range"  speeds,  from  19.6 to 48  mph; and "high" speeds,
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 from 48 to 65  mph.   In  MOBILES, all available  data  on vehicle  emissions  over
 driving cycle tests  w,th average  speeds  over  19.6  mph were  analyzed,  and as  a
 result  the  speed correction  factors  for  mid-range  and  high average  speeds
 applicable  to  light-duty  vehicles  and  light-duty  trucks  were revised.

        For  VOC and  CO  emissions,  the effect  of  this change  is that emissions
 modeled at  average speeds  over  19.6  mph are generally greater  relative  to
 emissions modeled at  19.6 mph,  than was true when MOBILE4.1  was used  to
 estimate  emissions.    Average  emission  factors  estimated  by  MOBILESa  in grams
 per  mile  (g/mi). decrease  with   increasing  average  speed in  the  range  19 6-48
 mph, are constant  from  48-55  mph,  and  increase  with  further  average  speed
 increases  to  65   mph.   This  is similar to  the behavior of  emissions  as  a function
 of average  speed in  MOBILE4.1, although  the decline in emission factors
 between  19.6  and 48  mph  is  less than, was  modeled previously.  For NOx
 emissions,  the new speed  correction  factors show  slight increases  in  NOx  as
 average speed increases  from 19.6  to  48  mph,  and more pronounced  increases
 as average  speed  further  increases  to 65  mph.

        The  new  speed  correction  factors  more  accurately  describe the behavior
 of emissions as  a  function of average trip  speed seen  in the available  test data.
 For  areas  that  develop  highway  vehicle emission   estimates  using emission
 factors  for  different  roadway facility  classifications  with  their  associated
 variation in  average  speed,  the   new speed correction  factors  will result  in
 higher  emission  factor  estimates  than  would  be  obtained using  the   previous
 model.

        Fleet  Characterization  Data

        MOBILES  models  average  fleetwide  emission  factors  for  each   vehicle
 type  by first  estimating  the  average  emission  for vehicles of age  X  in calendar
 year  Y, then  considering  the relative population  of vehicles  of each age  X  and
 how  many  miles they  are typically  driven  in terms  of annual averages.   The
 relative  population  of  vehicles  of  each  age  is  described by  registration
 distribution fractions by age,  a set  of values  that sum  to 1.0  for each vehicle
 type  and give the  fraction of all  vehicles of that type  that  are  in  their first,
 second, third (and so  on)  year of operation.   MOBILE  accounts for the  most
 recent  25  years'  vehicles,  with all  vehicles  over  age  25  being  considered  in  the
 "25+" age  category.   The  average  annual  mileage  accumulation  rate   varies  with
 the age of  the  vehicle,  with  newer  vehicles driven  more and older  vehicles
 less.   By  combining data on the relative  population of  vehicles of  each age and
 how  frequently  they are  driven,   MOBILESa  calculates a travel  fraction for
 vehicles of  each  age,  representing  the fraction of  all  vehicle  miles   traveled
 (VMT)  by a given vehicle type accounted for  by  vehicles of that age.   These
 travel fractions  are  then  used to  weight the  average emission  rates  for
 vehicles of each  age X in  a given  calendar year, with  the  result  being the
 average  in-use  emission   factor.

       The   registration  distribution  and  annual  mileage  accumulation  rates  by
age are together  described  as fleet  characterization  data.   Although the user  of
the model  has the ability to  alter either or  both of  these  in  MOBILES  to account
for local  variations,  adequate  data is not  always  available,  particularly for
annual  mileage accumulation  rates.   Thus the  values  for these  data that  are
included in  the   MOBILE  model,  which  represent  nationwide averages, are
                                                                               May 1995

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                                          -8-


important.    For MOBILES,  EPA updated  both the registration distributions  by
age  and the annual  mileage accumulation rates  by  age.   The registration
distribution  data in  MOBILES  (and  MOBILE5a)  are  national  values  for calendar
year  1990.  The annual  mileage accumulation  rates  used  in  MOBILE5/5a  have
been  adjusted  upward by  about 10%; this adjustment was based  on the increase
in total  vehicle miles traveled  (VMT) since  the  previous  rates were developed,
accounting for the  increase  in total  registrations  (total  vehicles  on the  road)
that  also  occurred  over  that time.

       Relative to  the values used in MOBILE4.1, these  data  show that the fleet
of in-use  vehicles  is older on  average, and that  vehicles  of  all types and  ages
are driven  more miles, than  before.    The net effect  of  both  of these changes  is
to further  increase  the  average in-use  emission  factors  calculated  for any
given  set  of  conditions.

       As  always, EPA  encourages  States  and others estimating  vehicle
emissions  to  use  locality-specific  registration data  to  calculate  registration
distributions by  age   when  it is available, as  variation  in  the average  age of  the
in-use  fleet  modeled will  affect the  emission factors.   However,  for areas
without  such data (and  with respect  to  mileage  accumulation  rates  by  age, for
most  areas), these  revisions  will  better describe  the emissions of  the  in-use
fleet  by better  characterizing  its  age  and  use  patterns.

       Evaporative  Emission Estimates

       Beyond  exhaust emissions of  VOC,  CO, and NOx,  gasoline-fueled vehicles
are responsible  for   considerable  evaporative  emissions.    These  "non-tailpipe"
emissions  consist  primarily  of  gasoline  vapor, and  are emitted  from  cars  and
trucks  in a  number  of ways:   At  the end  of a trip,  when the vehicle,  engine,
and emission control and  fuel  systems are  hot  and  the vehicles is  turned off,
there  are  emissions  of evaporating gasoline.   These  are known as  hot soak  (or
trip-end) emissions.   When  a  vehicle sits  idle during  a  period of  rising  ambient
temperatures, such as  in  a parking  lot all day,  the  heating of the  day results in
heating of  the  fuel  tank  and  fuel,  and the  resulting evaporation of gasoline  is
termed  diurnal emissions.   When  vehicles  are  being  driven, the  heat
generated  and   transferred  to the  fuel  will  result  in vapor  generation; if the
vapor  generated is  not  captured  by  the  evaporative control  carbon canister,  or
if the  canister becomes  saturated with  vapor which is not  properly  purged  and
routed  to  the  engine to be burned,  the resulting  running  loss emissions are
another  evaporative   emission  source.    When  gasoline-fueled  vehicles  are
refueled,   evaporative hydrocarbon  emissions  termed   refueling  emissions are
released; these  occur as  liquid  fuel  displaces the vapor in  the  "empty  part" of
the. vehicle  fuel tank  (displacement  losses) and  as a result of small  amounts  of
fuel  being spilled  via dripping  fuel  dispenser nozzles  or splashbacks  (spillage
losses).   All  gasoline-fueled vehicles also leak  small  amounts  of  vapor  through
the fuel tank,   canister and hoses,  and other parts  of the fuel handling  system;
these  are  termed resting   loss  emissions.

       The non-tailpipe emissions  of VOC from  the  sources  outlined above  can
equal  or exceed the tailpipe (exhaust) emissions  of  VOCs,  particularly  in  very
warm  weather  or when  higher than recommended  volatility  gasoline  is used.
To improve the accuracy  of the  estimated  non-tailpipe emissions  from  cars  and
light  trucks, EPA  has  collected substantial  data on  emission  rates   from  in-use
                                                                               May 1995

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                                          -9-
vehicles that pass  both,  fail  one  or the other,  or fail  both of the  functional
evaporative  emission  system  tests  recommended  for  use  in  enhanced
inspection and  maintenance (I/M)  programs.   These tests  are referred to  as  the
pressure  test and  the  purge  test.

        In  the pressure  test,  the  integrity  of  the  vehicle  evaporative  emission
control system  is  tested.   If the  system fails  to  maintain a specified  pressure
when  ostensibly sealed, then  it  is  concluded  that  one  or more leaks exist  in the
system.   Under such  conditions, at least  some  of the  gasoline vapor  that  should
be  trapped  and routed  to  the   carbon  canister  for storage  and  later combustion
is being  released  as emissions.    In the purge  test,  the  evaporative control
system is  tested  to determine  if  vapors once  captured in  the  canister are  being
properly purged and  routed to   the  engine  to  be burned.   If a vehicle fails  the
purge  test,  then  vapor  may be  routed  to  the  canister, but  once  the canister
capacity has been  reached, additional vapor  will  be  released as emissions.   As
might  be  expecied,  given the  above,  vehicles  that fail  one  or both of these
functional tests  are  found to  have  considerably higher  evaporative  emissions
(except  for  resting losses).

       MOBILE5a  evaporative  emission  factor  estimates  have  been improved  by
accounting for  the  rates  of failure  on one or both of  these tests as a  function  of
vehicle age  (the  older  the  vehicle,  the higher the  probability that it  fails  one
or both  of  the tests),  and  by accounting for the  emissions  impacts of such
failures on  the various types  of evaporative  emissions.   The  estimated effect  on
evaporative  emissions   due  to  failure of  the  pressure  and/or  purge tests   has
been  improved  as  a result of  having  significantly  more test data  from  vehicles
that  failed one or  both tests.    (EPA performed  the  pressure and purge tests
before  selecting  vehicles  for  further testing  in the  laboratory.   This allowed
data to  be  obtained  from  more "failing"  vehicles than   would otherwise  have
been  feasible, and  with  more data the  emissions  impacts of  failing these  tests
could  be  estimated with greater   confidence.)   Fleetwide  average  evaporative
emission  factors  that  account for  the  rates  of  pass/fail  on  the  functional
pressure and purge tests,  and   for  the  emissions  increases  associated  with
failure  on one  or  both  tests, are  more representative  of actual  in-use
conditions,  and  are generally  higher than  previous  estimates  that  did not  take
these  factors  into  account.

       Another  improvement  in the  MOBILE5/5a evaporative emission  factors
results  from  accounting  for  "real-time"  effects  on  diurnal  emissions.   Data
describing emissions  that  occur over  8-hour periods  of  rising  ambient
temperature  have been  collected,  and  were  used  to  modify  the  emission  factor
estimates  based  on  1-hour  simulated  diurnal  events.    Data  have  also  been
analyzed  from  hot  soak and  diurnal emissions  generated  using  fuels  of  lower
volatility  (down to 7  psi RVP), which  has  improved  the accuracy  of  these
emission  factors  when  fuel  volatility  under 9.0  psi  RVP is specified.

       Fuel  Effects

       Historically, EPA certification of  new  vehicles and most  other vehicle
test  programs (including the  EFP)  have used  a  specifically  formulated   .
gasoline.   This fuel  (formerly  known  as  Indolene)  is  blended to  regulatory
specifications, and  has  certain  specific  properties (e.g.,  9.0 psi  RVP volatility).
While  much  attention  has  been focused on  the effects  of fuel volatility   (as
                                                                                May 1995

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                                          -10-


 measured by  RVP) on  emissions,  it  is  known  that  other  fuel  properties  also
 have  an  impact  on  emission levels  and  that commercially available  fuels  do  not
 necessarily  correspond to  EPA's test fuel with  respect  to  these  additional
 properties.

        In MOBILESa, EPA has included adjustments  to emission levels  to  account
 for differences  between  EPA test  fuel  and industry-average  commercial   fuel
 These  adjustments are  independent  of  RVP effects,  which are controlled   by  the
 modeler  as  part  of the  model input,  and of other fuel programs  (such  as
 oxygenated  fuel   or  reformulated gasoline  requirements).   When the  modeler
 specifies  the  inclusion  of  fuel  programs, such  as  reformulated  gasoline   the
 necessary adjustments to  the emission  factors  are  made  from the starting point
 of  industry-average   commercial  fuel  emissions.

        The  net  effect of  the industry-average   fuel  properties being  accounted
 for  in  the emission  factors  produced by MOBILESa,  for  current  technology
 (model  year  1990,  three-way catalyst,  fuel-injected) vehicles  at  standard  FTP
 conditions, are increases of  about  13.6% for VOC,  8%  for CO, and 13.8%  for  NOx.
 (The NOx effect  is  applied  for all  three-way  catalyst  vehicles only.  The VOC  and
 CO  effects are also  applicable to oxidation  catalyst  vehicles.)   These  increases
 are  independent of, and  in  addition  to, increases  in the  emission  factors
 resulting from  the  revised  basic  emission  rate  equations  and  other  revisions  to
 the  model.   This  adjustment  to the  modeled emission  factors  is another
 significant  step  toward  making  the  modeled  emissions more  representative  of
 actual  in-use conditions.


 The revisions to the MOBILE model discussed  above all had the effect, to  greater
 or  lesser  extents,  of  increasing  the  estimated  average  in-use  emission factors
 calculated by the  MOBILE model  for any calendar year after  1980.   There  were
 also other revisions  made  to the  MOBILE model that had  only  limited effects on
 current or past  (e.g.,  1990)  emission factor estimates,  in  terms of changing the
 overall  level  of emissions, but are  included  in  order to improve  the accuracy  of
 estimated  future year  emission factors.    These  are  briefly described below:

       July I  Evaluation  Option

       MOBILE4.1  and earlier versions of the model  allowed the  user  to  specify
 the  calendar  year  of  evaluation  (the year  for  which   average in-use emission
 factors  are to  be  calculated), but allowed  no choice  as  to  the  date  within  the
 specified  year:   All emission  factors  were estimated  as  of  January  1 of the
 specified calendar  year.    When  emission  factors  for  summer  conditions  were
 required,  the  guidance was  to evaluate  two  consecutive calendar year  sets  of
 emission  factors  and  interpolate  (i.e.,  if  July  1,  1995  emission factors  were
 desired,  the  modeler  would  obtain  MOBILE  emission factor  estimates for
 January  1,  1995  and  January 1,  1996,  and  interpolate  between them).

       In MOBILESa,  the  provision  to have  the  model  directly calculate
emission  factors  as of either January  1  or July  1 of the specified year has been
added.   This  allows  the  model to account for the  benefits of an additional  six
months  of fleet  turnover  (sales of  new vehicles meeting  the   latest  standards
and  retirement from service  of  older,  more  polluting  vehicles).   In  addition  to
allowing  summer.  season  emissions   to  be estimated  from  a  single  run, rather
                                                                               May 1995

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                                        -11-
than from interpolation  of two  runs,  this feature  is  used  in the modeling  of
reformulated gasoline effects  (see  below).    If January  is  specified,  then
"winter"  RFG rules are  assumed, while  if July is  specified,  "summer"  RFG rules
are  assumed.

       If  emission  factors as of a specific date other than  January 1 or July  1
are  needed, then  interpolation  between the  appropriate  January and July
evaluation dates is  still  required.

       Oxygenated  Fuel  Effects

       The  effects  of oxygen content  in the fuel  on emissions  has  been revised
and  expanded in MOBILESa.  This feature  is important  for regulatory analyses
(many  areas  have  mandatory  oxygenated  fuel requirements  in the  winter
season,  during  which most  ambient CO  violations occur),  and  for more  accurate
assessment  of  base  year  (1990)  emission levels,  as  many  areas have  significant
market  penetration  of oxygenated  fuels  even  in  the absence  of regulatory
requirements, particularly  in  the  Midwest.

       The  largest  impact  of  oxygenated  fuels is on CO  emissions.  Due to the
tighter  time constraints  for inventory  and   State  Implementation  Plan   (SIP)
development imposed on  CO nonattainment  areas  (relative  to  ozone
nonattainment areas)  in  the  Clean Air Act  Amendments of  1990, EPA included
the effects of oxygenated  fuels  on CO emissions in MOBILE4.1  (1991).4  In
MOBILE5a,  the effects  of oxygenated fuels  on emissions  have  been updated
using the  revised Tech5  model,  and the  effects of oxygenated  fuels on VOC
emissions  have  been  incorporated in  the  model.    These effects are  smaller  than
the impacts  on  CO  emissions.  On the  basis of all available data,  MOBILES
continues  to model no impact of oxygenated fuels  on NOx  emissions.

       Reformulated   Gasoline

       One  of  the  requirements  of  the 1990  Clean Air  Act  Amendments  for
highway  mobile sources is the use of reformulated gasoline  (RFG).  The  use of
such fuel  is mandated  for  the  nine  worst  ozone  nonattainment  areas  of the
country (Los Angeles, Chicago, Houston,  Milwaukee, New  York City, Baltimore,
Philadelphia, San   Diego,  and "Greater Connecticut").   Other  areas not  included
in this  list  are  permitted  to  "opt in"  to the  RFG  requirements, and some areas
have done  so.

       Section  211(k) of the amended  Clean  Air Act specifies  two levels, or
phases,  of RFG requirements.  In Phase  I, RFG that results  in  at  least  a  15%
reduction  in VOC  emissions  from "baseline  vehicles" is  required.  Phase  I  RFG
requirements begin in 1995.   For Phase II,  this  requirement  is strengthened to
at least a 25%  reduction  in  VOC emissions, under the  same provisions (on the
basis of  emissions from  "baseline  vehicles," which has  been  interpreted  to
mean model year  1990,  current technology  light-duty  gas  vehicles).   Other
requirements of the  RFG  sections of the CAAA include that there  be  no
negative  impact on (increase in) NOx  emissions  from RFG  and  that the
maximum  benzene  content of  the  fuel  be  no greater  than  1.0  percent.

       The  details  of RFG effects  on  emissions depend  on the  season (summer or
winter).   In  summer, when temperatures are  higher and  emissions  of  ozone
                                                                              vlay

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                                         -12-
precursors are the  primary  concern, the focus of  the  RFG  rules is on
reductions in fuel volatility.   In  winter, when the  weather  is  colder  and CO
emissions  are  generally  more  of  a concern,  the  focus  of RFG  requirements  is
on  oxygen content of the  fuel.

       Both  summer and winter  Phase  I  RFG requirements  can  be  modeled
using MOBILE5a.   The  effects are  based  on  the month specified by the  user  (if
January  emission  factors are requested,  winter  RFG  rules are applied,  and  if
July emission  factors are requested, then  summer  RFG rules are applied).   Only
the VOC  and CO effects  of  Phase  II RFG are included  in MOBILESa, and  are based
on  the  "simple  model" used in the  development  of the  RFG regulations.   In  the
next update  to the model, Phase II RFG effects on NOx emissions will  be
included,  and the  estimates  of the  emission  impacts of both  Phase  I and  II  RFG
will be updated  on the  basis of the "complex model"  used  in the  regulatory
development process.   The  additional  requirement  that NOx emissions  be
reduced  (by 6.8%  for  "current  technology"  1990  model year,  three-way
catalyst,  fuel-injected  vehicles),  rather than  simply  not  being  allowed   to
increase,  will also  be  reflected in  the  next model  update.

       Federal  (Tier 1 and   other)  Exhaust  Emission  Standards

       The Clean  Air Act Amendments of  1990  included  the first  new
tightening of tailpipe  (exhaust)  emission   standards  to  be  implemented since
model  year  1981.   These standards  are known as the Federal Tier  1 emission
standards,  and the compliance  phase-in period  began with  the  1994  model
year.   The Act  specified the levels of  both the  Tier  1  standards (section 202(g))
and  intermediate  standards  (section  207(c)),  with  the complete  phase in  of the
final Tier 1  standards  not  complete  until model  year  1998.

       MOBILESa includes  the estimated  in-use  impact of  these emission
standards.   EPA  has  assumed that  these  standards  will  reduce  emissions from
"normal  emitter"  vehicles,  but  will not have a significant  impact  the  in-use
emissions  of "high" and "super"  emitters,  nor  the rates at which  vehicles
migrate from the  "normal"   to the  "high"   to  the  "super"  emitter  categories.
Thus,  the reduction in  average  in-use emission  levels projected to  result  from
implementation of these   standards  is  less   than  the  reduction  in the levels  of
the  standards.  For example, the  HC standard is  being reduced from 0.41  to 0.25
g/mi,  a decrease of about  40 percent,  but  the  reduction  in .the fleet  average
emission  factor  will be  less than  that, even after  the  phase-in  is  completed
(after  1998)  and  essentially all vehicles on the  road are certified  to  the new
standards  (25 years  later, or after  2023).

       While not defined as  part of the Federal Tier  1  emission standards  under
the  1990  Clean  Air Act Amendments, the  4.0  gram  per brake horsepower-hour
(g/bhp-hr) standard for  NOx  emissions from heavy-duty  diesel trucks  that  is
set  to  take effect for the 1998 model year is also included  in MOBILESa.

       California LEV  Program

       Under the  Clean  Air Act  and  its  amendments, California has long been
granted  the  right  to  establish  its  own  regulations  regarding  highway vehicle
emissions, so long as the  regulations   promulgated by  California are  no less
stringent  than  those promulgated  by  EPA  for the  other  49 states  (Federal
                                                                              May 1995

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                                         -13-


standards).   .With  the  severe  and  persistent air quality  problems  experienced
in  most of the  populated  portions of  the  state,  California cars  and light  trucks
have  been  required to  meet  more  stringent standards- than  Federal  standards
for many years.  The Act also  provides  other  States the  option of remaining
subject  to the  requirements  of the  Federal  Motor Vehicle  Control  Program, or
of  implementing the  California  motor  vehicle  emission  control  program.

       The  most significant  difference  between  the programs  being
implemented  by  California and  those  being implemented by  EPA  in  the  1990s is
that California's low  emission vehicle (LEV) program,  which  includes  a  zero-
emission  vehicle  (ZEV)  sales  mandate beginning  in  the. 1998  model year.
Section  177  of the  Act  allows other states  to adopt  California vehicle  emission
control  programs  and  standards,  which  several northeastern  states  have
already  done.   In  response to a  petition  from the Ozone  Transport Commission
(OTC),  EPA  published a final  rule in  December  1994 mandating adoption  of the
California LEV program, without  a ZEV  sales mandate,  in the Northeast  Ozone
Transport  Region (OTR).   In addition, the  states  and the  auto  industry  have
been  negotiating a  possible "49-state LEV"  program  without a  ZEV sales
mandate,  which  might ultimately  replace  proposed LEV  programs  in  the  OTR
and the Federal  Tier  1  program in the rest of the country.  EPA has  included
the ability to  model the effects of all of  these options in MOBILES a.  Model  users
can specify the  initial model  year,  the phase-in  schedule, and  the  type  of  in-
use  inspection  and  maintenance  (I/M)  program  applicable  (which  has   a
strong effect  on the  level of  benefits  achieved  by  implementation of an  LEV
program)  for  whichever  LEV  program option is  applicable.   The  reader  is
referred to the  User's  Guide  to MOBILE5 for additional  details on  modeling of
LEV  program  options.5
                                                        /
The  discussion above  summarizes the most  important  revisions  that  have been
made  to EPA's MOBILE  model since  1992.   In the next section, an overview  is
provided  of  a  report  prepared for  EPA  that evaluates  various  ambient  emission
studies  and their conclusions.   Section  5  includes  comparisons  of emission
factors modeled by  MOBILESa to those measured  in  the 1987  Van Nuys  tunnel
study, as  well  as to the 1992  Fort  Me Henry and  Tuscarora  tunnel  studies.
2.     Ambient   Studies

       As  discussed  in  the  first "Highway  Vehicle  Emissions Estimates"
document,  tunnel  studies  (which  are  discussed  in the next  section) were  not
the only  evidence that highway  mobile  source  emissions may  have been
underpredicted  by the models and  methodologies  in  use in the late  1980s.   Other
types  of studies,  collectively  referred  to  as "ambient  studies," also  provided
indications  that  the  mobile  source contribution  to  overall emissions  was  being
underestimated.

       There are  four  main  types of  studies that are considered "ambient
studies"  in this  context:   receptor modeling studies,  source fingerprint studies,
ambient ratio  studies, and  mass balance  studies.   Ambient studies as a
descriptive  term  means  that  the  studies are  in some  way  based  on
measurements  of ambient  pollution  concentrations.    That is,  rather  than
working  from  estimated emission  rates  and  activity  levels  for  various sources
in an  effort  to  estimate  overall  pollutant  inventories and/or  ambient
                                                                              May 1995

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                                         -14-


concentrations,  the  studies  discussed  in  this   section  start from  measurable
ambient aspects  of the  air  pollution  problem  (such  as  pollutant  concentrations
or  the  ratios of  concentrations  of various pollutants)  and  work back  to
examine  whether  the  ambient  (measured)  data are  compatible with  estimated
(modeled)  emissions.

        In  1994,  a critical  review of a  number  of such ambient  studies was
performed by  Systems Applications  International (SAI), under  contract  to  EPA.
The final  report  of that  work,  "Evaluation  of  Ambient Species Profiles.
Ambient Versus  Modeled  NMHCNOx and  CO:NOx  Ratios,  and Source-Receptor
Analyses,"6  provides  an  extensive  review of  25 ambient  studies  performed
between the  early 1980s  and 1994.  The  studies  were  each  reviewed from two
viewpoints  independently:    once from  an  "objective"  stance  and  again  from  a
"skeptical"  stance.   These  reviews  were  performed  by  different  reviewers,  who
did not see  the  other  review  until their own review  had been completed.   The
objective review  briefly  summarizes the  study  in question  and  more  resembles
a  typical peer  review,  while  the  skeptical review  is  developed from the
viewpoint  of  being eager  to  find  things about  the  study,  its  logic and
conclusions,  and  its underlying  premises  that  can  be  challenged.    As stated  in
the final report,  "the  extent  to  which  the two  reviews are similar,  both
unfavorable,  divided,  or both  favorable  ... is  an  indication of  the  perceived
strength of  the   study."

       The  discussion  in  this  section  only deals with  the  overall  conclusions  of
the report and  the  implications of  those  conclusions  for  the  accuracy of
highway vehicle  emission estimates.   The reader  interested  in  more details  of
this  review,  particularly  with  respect  to  the  review   of  specific  studies among
the 25  evaluated, is encouraged  to  obtain  a  copy of  the SAI  report.

       The  ambient  studies  examined  in  this work can be  categorized into four
basic  types,  as  noted above.   In each  type  of  study, there  are  assumptions  that
must  be  met (inherently   or  explicitly), although in   practice  it is  rarely
possible to  precisely meet all  assumptions.  The extent to  which  the validity  of
the study  results  is affected  by deviations in  the  assumptions is  discussed, and
the degree  to  which the  applicable assumptions are  met  by  the   individual
studies  examined  is stated.   The  relative  strengths and weaknesses of each type
of study are also  discussed.

       Receptor-  modeling, techniques >includc:.- chemical< mass:? balance -(CMB),
tracer  analysis;  and factor analysis  methods.   The SAI  report  concludes that-
one  of  the'strengths  of  receptor  modeling techniques  is  that  small deviations
from  the assumptions   may  be  tolerated,  although large deviations  will
invalidate  the. results of  the  study.   Thus,  although  strict  adherence  to  all
necessary assumptions  is   rarely  achieved  in  actual practice (as is  true  of  all
ambient studies),  useful results  can still  be obtained from  such studies  if  the
assumptions  are  reasonably  well  met.

        Discussion  of the  limitations specific to  each   type  of  ambient  study,  and
the degree  to  which  various specific  studies that were evaluated  by  SAI met the
necessary assumptions,  is  beyond  the  scope of this  paper.   Again,  the
interested reader  is  referred  to  the  SAI final  report  for more details.   In
general, however,  a few   points can  be made  that are relevant to  the current
discussion:
                                                                               May 1995

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                                         -15-
       There  is  considerable  disagreement  in  the  conclusions  of the  various
studies.   For example,  of the  13  receptor modeling studies examined,  only one
reported  a  motor vehicle  exhaust emission  contribution  that  was  significantly
higher  than  inventory-based values.    Nine of  the  13  studies  reported  evidence
of  underestimation of  emissions  from  one or more  source categories.   SAI  notes
that "although  there  is  no consistent  [emphasis  added]  conclusion  of  motor
vehicle exhaust  underprediction  in the  studies  reviewed,  there  is  a  consistent
result  of  low  gasoline  vapor  contribution."   The  question  of the  accuracy of
speciation profiles  assumed for  gasoline vapor  (evaporative)  emissions,  and
the degree  to  which the  speciation  profile  of  gasoline  vapor  corresponds to
that of  whole  gasoline,  requires  additional  investigation  before  firm
conclusions  can be  drawn.  SAI also  states  in  the report  that,  based on their
reviews,  emissions   from  petroleum  refineries  may be  underestimated  in
emission   inventories.

       Of the  five  ambient ratio  studies  that were examined, only one  provided
evidence  for a  discrepancy between  (measured)  ambient  and   (modeled)
inventory  ratios  of NMHCNOx and CO:NOx.  As noted,  although  the evidence in
that study for  a  discrepancy in  these  ratios was substantial,  the  fact that a
discrepancy  exists  does  not necessarily imply  that a bias  in the  emission
inventory  is  the  cause  of the  discrepancy.   In  general,  it  is  not  prudent  to
conclusively  state, on  the  basis  of an ambient  emission study, that emissions
from  any one  particular  source  category  (including  highway  vehicles)  are
underestimated.    However,  the evidence  of the  studies reviewed when taken
together  is   sufficient  to  conclude that  further  improvements  in emission
inventory  estimates  for  all major contributors  is  warranted.

       The  25  studies  examined  in this  report  range from  very recent  (1994) to,
by  the  standards of  this  field,  quite  old (1980-81).  Other ambient studies
became available,  either  published or  in pre-publication  form, after  the  list  of
25  for  inclusion  in  this  work  assignment was  finalized,  and others were
recommended for  inclusion  after it  was too  late  to do so.  More  work in these
areas  is certain to  continue, and  EPA will consider the results  of newer  studies
as  they  become  available.

       At this  time,  it does seem  clear that  some  (but by  no means  all) ambient
studies  provide  indications that   emission  inventory estimates  for  highway
vehicles  require   additional improvement.   The  varying conclusions  of the
studies  examined  also  make clear that disagreement between two methods  of
estimating the  same thing (for example,  measuring  ambient  emission ratios
and calculating them  from modeled  emission  factors and estimated activity
levels)  is insufficient  to  draw a  firm conclusion  that one or  the other methods
must  be  right  and  the other  wrong.    Measurement errors,  which are  a  factor
in  any experimental work (including  laboratory  emission tests  of in-use
vehicles), can  lead  to  inappropriate  conclusions  being  drawn.    EPA believes
that caution  must  be  used in interpreting  the  results of  ambient studies;  in
particular, citing  of  only one  or  two  statements  from  such a  study, taken
without the  context  and  caveats provided in  other  portions  of  the  report, is  not
appropriate   for   drawing  generalized  conclusions.
                                                                               Vlay

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                                         -16-
3.     Tunnel  Studie^

       The  July  1992  paper  discussed  the  tunnel  study  that was  conducted in
Van Nuys,  CA  in  1987.  This study became  the  focus  of considerable  attention,
in  part due  to  the  fact  that among  its conclusions  was the statement  that
existing  highway  vehicle  emission  factors  and  inventories  were  being
underestimated (at least  for HC and  CO emissions).   As  outlined  in  Section 1,  the
EPA  model  for estimating  average  in-use emission  factors for  highway
vehicles  has  undergone  two  major  revisions  since then; for  a  variety of
reasons,  the emission  factors estimated by MOBILESa  are generally
significantly  higher  than those  estimated  by MOBILE4  and MOBILE4.1 for the
same  conditions.   Also  since  then,  more  tunnel  studies have  been performed.
In  particular, the  Coordinating Research  Council (CRC), under  whose
sponsorship  the  1987 Van Nuys  tunnel  study  was performed,  sponsored  two
tunnel studies  that  were performed  in  1992,  one  at  Fort  McHenry (Interstate  95
tunnel under Chesapeake Bay,  near Baltimore) and  the other  at Tuscarora
Mountain  in  south-central   Pennsylvania.

       The  next  section  on the  Van  Nuys  study is partly taken from  the  July
1992  paper.   Following  are  similar  overviews  of  the Fort McHenry and
Tuscarora tunnel studies and  their  results.   Section  4  presents updated
comparisons  of  measured vs.  modeled  emission factors,  with  the  latest EPA
emission factor  model  MOBILESa used to  develop the  modeled emission factors
for comparison  with the 1987  Van  Nuys  measurements  and  the 1992  Fort
McHenry  and  Tuscarora  measurements.

       Van  Nuvs  Tunnel (1987)

       In  1987, the  Coordinating  Research  Council (CRC) sponsored what is
usually  referred to  as  the  "Van Nuys  tunnel  study,"  in which  a highway tunnel
in Van  Nuys, CA was  used  to  measure the total emissions produced by all  of  the
traffic passing  through  the  tunnel  during  a  total of  22 one-hour sampling
periods.   By measuring  all  of the emissions  exiting  the mouth  of  the tunnel
(accounting   for  winds  and total  air flow) and counting the  number  and  types
of  vehicles   that passed  through  the  tunnel  during  each  sample  period,
estimates of  gram  per mile  (per vehicle) emissions  of  HC, CO,  and NOx were
derived.

       The details of the design  and execution  of the Van Nuys  tunnel study  are
beyond  the   scope of the current  discussion.    For additional information on  the
study,  the  reader  is referred to  the final  report  "Measurement of  On-Road
Vehicle Emissions in the California  South  Coast  Air  Basin, Volume I: Regulated
Emissions."3

       While  not the  original design purpose of  the  tunnel  study,  one use of
the emission  factor estimates  measured in  the  study is  validation  of  emission
factor  estimates  produced by the  EPA  and California Air Resources Board
(CARB)  emission  factor  models.   After  fleet  average gram  per mile  (g/mi)
emissions for each  tunnel  study  sample period  were  calculated,  they were
compared to  emission  factors  modeled by the then-current version  of  the
California model,  EMFAC7C.   These comparisons reflected good agreement for
NOx  emissions,  but  suggested  that HC  and  CO  emissions were  being
underpredicted by EMFAC7C.   Over the range of conditions (average trip speeds
                                                                             May

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                                        -17-


and  ambient temperatures)  occurring  during  the   tunnel  study,  the  apparent
underproductions  were by  ratios  of between  1.4  and 6.9 (average  3.8) for  HC,
and  between 1.1  and 3.6  (average 2.7)  for CO.  The results of these  comparisons
led to much questioning  of  the  accuracy of the EMFAC7C model  and its
successors.   Since EMFAC7C was, in many ways, similar to the EPA  emission
factor  model (MOBILE3  at  the  time),  and  relied upon  some of  the same in-use
vehicle test  data, the accuracy  of the  emission  factors  calculated  by  MOBILE3
(and  succeeding  versions  of the model) were  called into  question as well.

       In the  1991   technical memorandum7 and the July  1992 paper, EPA
provided  a  comparison of the emission  factors calculated by  MOBILE4 for the
tunnel study sample  periods  to  those  measured in the study.   While  the
evidence  clearly  indicated that  HC  and CO emissions  from  highway  vehicles
were  likely  being underestimated, the  degree to which the  measured emissions
exceeded  the modeled  emissions was much  less than was  cited in  the  tunnel
study final  report.   The  ratios  of the  tunnel  study  emission  factors  to  those
calculated by MOBILE4 ranged  from 0.6 to 3.2 with an average of 1.9 (the  same
comparisons  using EMFAC7C showed  rations ranging from  1.4  to 6.9 with  an
average of  3.8).   Thus,  the  discrepancy between measured  and modeled HC
emission  factors  was  only  about  one-half  that  reported in  the final report on
the  tunnel  study.

       Similar results were found in  the case of CO emissions:  the ratio of
tunnel  study  to MOBILE4 CO emission  factors  ranged from 0.5 to  2.4  and
averaged  1.7 (the  EMFAC7C  comparisons gave  ratios of 1.1  to 3.6 with  an
average value of 2.7).   The  NOx emissions comparison  changed in  the same
direction; however,  since the  tunnel  study report  showed  reasonably  good
agreement between  measured  and modeled NOx emissions,  the lowered ratios
resulting  from  comparing MOBILE4  to the  tunnel   study results  indicated   less
agreement.   The  tunnel study  to EMFAC7C  ratios  for  NOx emissions  ranged from
0.6 to 1.4 and averaged  1.0  (on average, the modeled  and measured  NOx  emission
factors were  the  same),  but  the  tunnel  study to  NOx ratios for NOx  ranged from
0.4 to  0.9, with 0.7  as  the average of the ratios.

       The  problems inherent in using  emission factor  models (such  as  EPA's
MOBILE  model) to estimate emission  factors  for  microscale  situations  (such as
tunnel  studies),  when  the model  was  developed to estimate  average  area-wide
emission  factors  over the course of an entire day,  were discussed  in the
technical  memo  and  the  July  1992 paper.    The conclusions drawn  at that  time
included  (i) that the  discrepancy between  tunnel  study   measurements and
MOBILE  modeling of  in-use emission  factors  was  reduced,  but not  eliminated,
when the comparisons  were carefully  constructed to  account for some of  the
differences  in  microscale  and  area-wide  modeling (such  as  the  inapplicability
of "travel fractions,"  as defined in the MOBILE model, to microscale modeling
situations), (ii) that this  fact  did not  negate  the evidence  that the  models  were
underestimating   average   in-use  vehicle  emissions,  (iii)  that  there  were
aspects  of the  tunnel study  that could  have  contributed  to errors in the
measured  emission factors,  and thus in the  comparisons  of  measured  to
modeled   emission factors,  and  (iv)  that additional  work  underway  would  likely
improve  the  model  estimates  of in-use  emissions, which would be  expected to
increase   their  accuracy  and  the  degree of  agreement  between  measured  and
modeled  emissions.
                                                                             May 1995

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                                         -18-
       Two major  tunnel  studies were  conducted  in  1992, as discussed  below
The 1992  tunnel  studies  in  1992 were performed at Fort McHenry  (Baltimore)
and Tuscarora  Mountain  (Pennsylvania)  and are  very  briefly  described below.
The combination  of data  obtained from more  recent  tunnel  studies,  and  the
considerable  revisions that have  been  made  to  the MOBILE  model since  that
time, provide  an  opportunity to  examine the extent to  which  discrepancies  still
exist between  measured  and  modeled  emissions.

       Comparisons  of the results of the  Van Nuys  tunnel  study to  emission
factor  estimates calculated using  MOBILESa  are  summarized  in  Section  5.   Note
that the  revisions  and corrections  made  to MOBILES (04  Dec 92) that  are
reflected in MOBILESa (26 Mar 93) are to aspects of the  model  that would not
affect  emission estimates  developed  for comparison  to the  tunnel  study
measurements.   Most  of the  changes  between MOBILES and  MOBILESa  affect
future  calendar years only  (i.e.,  would not  affect the  emission  factor estimates
for  calendar years  1987  or  1992),  and several  others  affect only evaporative
emission  factors (not applicable  to tunnel  studies)  or emission factors  under
certain  specific sets  of  assumptions  about   operating  inspection and
maintenance  (I/M)  programs.    For more details  on the  differences  between
MOBILES  and  MOBILESa, the  reader is referred to the  Federal Register notice
announcing  the  release and availability  of  MOBILESa (58 FR 29409,  May  20,
1993).

       Fort McHenry and Tuscarora Mountain Tunnels (1992)

       The  two tunnel studies  conducted in   1992  were performed by  Desert
Research  Institute (DRI).   The  work  was sponsored by  the  Coordinating
Research Council  (CRC),  which  sponsored the Van Nuys  study,  as well  as the
Auto/Oil  Air  Quality Improvement  Program,  the  Department of Energy's
National Renewable  Energy Laboratory, the   Southern  Oxidant Study,  and the  U.
S. EPA.   At the time of this writing, the  final report of these two studies was  not
available.   Information  provided  here  is  taken  from   the draft  final  report
"Real-World Automotive Emissions -  Results  of  Studies in the  Fort McHenry and
Tuscarora  Mountain Tunnels"  (March   1994). 8

       The  Fort  McHenry tunnel carries  eight lanes of  Interstate 95  traffic
under the  Baltimore (MD)  Harbor,  with  four  separate  bores  each carrying two
lanes of traffic.  The tunnel  is  7200 ft long.  Eastbound  traffic  was  sampled in
the tunnel  emissions study.   As an  interstate freeway  segment,  it is
characterized by higher average speeds  (generally  50  mph   or  more)  and less
speed variability than an  urban tunnel,  such as  Van Nuys.   One major
difference  between  Fort McHenry and  most  other tunnel  studies of this type  is
that, the Fort  McHenry  tunnels  contain  significant grades,   with both  uphill
and  downhill portions of  the tunnel having  ±. 3.76% maximum  grades.   The
average  grade  in  the eastbound bores  used  in  the study  is  -1.8% downhill
(entrance  at west  portal to  bottom of  tunnel) and +3.3%  uphill  (bottom of
tunnel  to exit  at  east portal).   As none of  the  existing  highway vehicle
emission factor  models (MOBILES, EMFAC7F,  and earlier versions of each)
account  for the effects  of grade, the  results  from  this study were of particular
interest  in  assessing  the  importance of roadway  grade  on  emission  levels.

       The  Tuscarora Mountain  Tunnel  is a  two-bore  tunnel, 5325  ft  long,
carrying Interstate  76  traffic  through  Tuscarora  Mountain  at  elevations  of
                                                                             May i

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                                         -19-
approximately  1000 feet (303  to  306 m)  above sea level.  Emissions
measurements  were  conducted  using  the  two-lane  eastbound  bore  of  the
tunnel.   The tunnel  segment  of the roadway  is  essentially flat, which  made  it  a
better  test of  the  emission  factor model, since MOBILES  and other  such models
do  not  account for the  impacts  of roadway  grade  on emissions.   As in :he case
of  Fort McHenry,  traffic   through  this  tunnel  was  characterized  by   relatively
high  average  speeds  and  relatively little  variation  in  speed.

       In  each of these studies,  emissions measurements  were  made  over
eleven  one-hour  sampling periods.  The  sample  periods were selected  so  as  to
span  a  range  of  vehicle  fleet compositions  (light-  and  heavy-duty  vehicles,
gasoline-fueled  and diesel   powered).   Overall,  the average  traffic  volume  for
the 11  samples at Fort McHenry  was 2424 vehicles  per hour at  an average speed
of 49  mph;  at Tuscarora, the average volume was 539  vehicles per hour at an
average  speed  of 59  mph.

       Due to  the locations of  these two tunnels,  it could safely  be assumed  that
virtually all  vehicles  were  operating in  stabilized mode.  That  is, the
contributions  of  cold-start  (or  hot-start)  engine  operation  should be  near  zero,
as each tunnel is a  link of  interstate freeway  with the  nearest accesses
(entrance  ramps)  being  from  other arterial roadways   and  more  than  one mile
away  (Fort McHenry)  or at  least 6  mi (10  km) away (Tuscarora).  Based  on
observations  and  some  interviewing of  drivers,  the average  ages of  the  light-
duty  vehicle  fleets during  the  tunnel  study  samples  was somewhat  newer  than
the national  average,  and average mileage  accumulations  (odometer readings)
were  somewhat higher  than  would  be  expected  for  a  fleet of those  average
ages.   DRI  notes  that the  average  vehicle  age was  lower  and  the condition of
vehicles  in  the tunnel  study  sample periods  was  better (i.e.,  better
maintenance,  fewer  gross   problems with   engines  or   emission  controls)  than
would  be  seen in  urban areas taken as  a  whole.

       Beyond comparing  the  measured emission results  and derived  emission
factors  to  those produced  by  the  MOBILES model, each of  these  studies  examined
a number  of other related  issues.   Remote sensing data,  speciation of
hydrocarbon  (HC) emissions,  apportionment  of  tailpipe  (exhaust)  and  non-
tailpipe  (running  loss and  evaporative)  HC  emissions, separation of  light-
fro m  heavy-duty   vehicle  emissions,  and   characterization  of compositional
differences  in  hydrocarbon emissions  from  light-  and  heavy-duty  vehicles
were  also  examined.   For  additional details on these two  studies,  see  the  report
prepared by  DRI.8

       DRI included  in their report on  the Fort McHenry  and  Tuscarora  tunnel
studies  the  results  of  comparisons between  measured  emission  factors  and
those  modeled using  MOBILES.   Although the  comparisons  presented  in  the
draft  final report  were  based  on  MOBILES, rather than the corrected  MOBILESa,
this should not have  a significant  impact  on the  results  of the comparison, as
the  changes  between  MOBILES and 5a  did not  affect  emission estimates  for
calendar year  1992 in  nearly all cases.   (For details  on  the differences  between
MOBILES  and  5a,  see the Federal Register  notice of May  20,  1993,  58 FR 29410).
The  use  of observed vehicle  registration   distributions by  age,  rather than
travel  fractions by age, as weighting  factors for  the  model  year-specific
emission factors  in order  to  obtain fleet  average  estimates,  has  also  been
correctly  accounted for in  the  comparisons presented  by  DRI.   Thus,  detailed
                                                                              May 1995

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                                        -20-


comparisons  (for  each  individual  sample  period  and  for  each study) were  not
re-performed  for  inclusion  in  this  paper.   The  results of  the  comparisons
presented by  DRI are summarized  in  the  next  section.


4,	Comparison   Of  MOBIT.ESa   and  Tunnel  Study  Emission  Fartnrc

       After  the  release  of the Van Nuys tunnel  study reports,  a widespread
perception that the  MOBILE  model was  grossly  underestimating  in-use
emissions of  HC,  CO, and NOx took hold.   This perception  was based  on the  fact
that the  final  report on  the  tunnel study results  indicated  that California's
then-current  emission  factor  model, EMFAC7C,  was  underestimating  in-use
emission  levels  by as much as a  factor of 7 (the  worst case comparison of
measured to  modeled emission  factors,  for  HC in  one of the 21 sampling periods,
showed  a measured-to-modeled emission  factor ratio  of 6.7).   Since California's
EMFAC  model borrowed considerably  from  both  the  data  sources  underlying
and  the  modeling algorithms  developed for EPA's emission  factor  model,  then
MOBILES, the conclusions drawn  with  respect to  EMFAC  were also  assumed
applicable to the  MOBILE model.

       In the July  1992 paper on vehicle  emissions  and  in  the technical  memo
analyzing the  comparison  of  tunnel study  measurements  of  emissions  to
emission  factors estimated by  the  MOBILE model,  EPA drew  the  conclusion that
while the evidence  pointed  to  the  possibility that  MOBILE3  was
underestimating  emissions, the  problem was  not  nearly so  severe as  would  be
assumed by extension of the worst-case performance of EMFAC  to the MOBILE
model.   The reader  is referred to  the  July  1992  paper and  the  technical  memo
for additional details  in  this area.   Essentially, when a  later update  of the  model
(MOBILE4,  1989) was used and  the contribution  of vehicles  of  each model year
was  accurately reflected,  the  apparent  discrepancies  between  the  measured
and  modeled  emissions  estimates  were reduced by roughly  SO percent.
However, all  indications  were  still  in  the  direction  of concluding that MOBILE
was  in  fact  underestimating   emissions.

       In the  intervening time, EPA  has  extensively  updated and revised  the
emission factor model (MOBILE4.1, 1991; MOBILES, 1992; MOBILESa, 1993).  In
each of  these  updates, the  estimated emission factors  for  a  given  set  of
conditions was  increased (in   almost  all  cases) over the corresponding  estimate
of the preceding  version of the model.  This is  most  particularly true of
MOBILE4.1 and MOBILES, where the  basic emission  rate equations  were
increased dramatically over  previous  estimates  on  the  basis of  extensive
testing  of vehicles in conjunction  with IM240 tests  in  Hammond,  IN.   The  first
section  of this  paper discussed model  revisions  since 1989  in more  detail.

       Additional  tunnel studies  have  been conducted  since  1989, as described
above.   Before examining  the  performance of MOBILES  and  5a  relative  to the
tunnel  studies  conducted  in  1992, one  item  of  interest is the re-examination  of
the  performance  of  the  latest model  against  the measurements  taken  during
the  1987 Van  Nuys  tunnel  study.   This comparison  is  summarized in Table 3
(there are three  tables, as  in the cases of Tables 1  and  2:   Table  3a for HC,  3b for
CO, and  3c  for NOx).   This  comparison is discussed  in the  following paragraphs.
                                                                             May 1995

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                                         -21-
       The  July  1992  paper and  the  accompanying  technical  memorandum
described the  use of the MOBILE  model to estimate  emission  factors for the
tunnel study  sample periods  and the  adjustments  that must  be made to  the
MOBILE emission  factors in  order  to better  represent  fixed-length,  microscale
modeling domains.   That information  is not repeated  in  detail here, but is
briefly   summarized  in  the  next  paragraph:

       The  MOBILE model is  designed with area-wide (e.g.,  metropolitan area,
state, region,  nation),  daily emission  factor estimates  in  mind.   For this reason,
the  model  accounts  for both  the  registration-distributions  by age  (fraction  of
all  vehicles of  a given type that are  of a  given  age)  and the average  annual
mileage  accumulation  rates  by  age  (newer  vehicles  on  average  are driven
more than  older vehicles)  in  developing  travel  fractions (the  fraction  of all
vehicle   miles traveled  (VMT)  by  vehicles  of a  given  type  represented  by
vehicles  of each  age).    In  a microscale situation,  such  as the tunnel studies,  the
use  of   such  travel  fractions  is  inappropriate:    Each  vehicle  contributes
mileage  (i.e.,  the length of  the  tunnel)  in  direct proportion to its
representation  in the  fleet  of  vehicles  that drove through  the tunnel.

       Table 3  shows,  in  summary, that predictions of average  HC and CO
emissions from  MOBILESa are  in generally good agreement  with   the  measured
emissions from  the  Van Nuys  tunnel  study,  while NOx  emissions  would appear
to be over-predicted by  the  model.   In general,  this  result is not  surprising,  for
the  following  reasons:   The previous  comparisons  between  the  measured
emissions and  emission  factors  from  MOBILE4  indicated  some under-prediction
of HC and  CO  but  generally good  agreement for NOx;  and,  emission factors
produced by  MOBILESa are  generally  greater  than  corresponding  estimates
from MOBILE4,  as discussed above and  illustrated  by  Tables  1  and 2.  Thus the
increased basic  emission  rate  estimates and other  model  revisions  since
MOBILE4  have  had the net effect of  improving the agreement between
measured and modeled  HC and  CO while degrading the extent to  which
measured and  modeled  NOx emissions  are  in  agreement.

       Specifically,  when  the ratio of  measured  (tunnel  study) to   modeled
(MOBILE) emission  factor estimates  is  examined  for each of  the  sample periods
of the Van Nuys study, measured  HC  emissions  averaged  86% higher than
modeled  emissions when MOBILE4 was used,  but average only 22% higher
when MOBILESa  is  used.   Over the 20  sample periods for which valid HC
emission measurements  were  reported,  the  range  of this  ratio  was  0.64  to  3.24
when the comparison is based on MOBILE4, and  0.54  to  2.36  when  based on
MOBILESa.   Most of the ratios were actually much closer to 1.0, which  would  be
indicative of  exact  agreement;  of the  20 samples,  the ratio  of measured  to
MOBILESa-modeled  emissions was  between  0.7  and 1.5 in 15  cases.

       For CO  emissions, the degree  to which measured and  modeled emissions
are in reasonably good agreement  was  even better:  The average of  19 valid
samples'  ratios of measured to  modeled  emissions  was 1.67  using MOBILE4, and
0.94 using MOBILESa;  the  range  of these ratios  was 0.52  to 2.43 using MOBILE4,
and 0.48 to 1.25 using  MOBILESa.  Most of the  emission  factors  from MOBILESa
were  within ±  25%  of the measured  values (true  for  17 of  19 cases).

       The  situation  in  the case  of oxides  of nitrogen (NOx) emissions  is not  as
clear.   Since  the original comparisons of MOBILE4  emission  factors to  those
                                                                              May 1995

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                                         -22-


 from the  tunnel  study  showed excellent  agreement, the  increase  in  NOx
 emissions  modeled by MOBILESa  relative  to  MOBILE4  had the effect of
 increasing the  discrepancies  between  measured  and  modeled  emissions.    This
 can  be seen  by comparing  the results presented  in Table  3c.   Reasons for this
 cannot  be  stated  with  certainty.

       The results of the  newer  tunnel studies at Fort McHenry and  Tuscarora,
 in terms  of comparison  with emission factors  estimated by MOBILESa  for  the
 same conditions,  generally  show  that  the models  are  performing  well  to the
 extent that the inherent  assumptions of the  model are met.   DRI reports  that
 predictions were  generally  within  ±.50%,  although MOBILES  had  a  tendency to
 over-predict  emissions,  especially  at  Tuscarora.   This can be  partly  explained
 by  the  fact  that  speed  variability  in  these two tunnels  was quite  low,  while  one
 of the inherent assumptions  of  the  MOBILE  model is  that "average speed"  is
 descriptive of  entire trips   rather  than  of  essentially  free-flowing  links;
 variability of speed  implies accelerations,  which  result   in  higher emissions,
 and  decelerations, which  in some  cases  also  can result  in  higher emissions.

       Also  worth noting with  respect to  the  1992 tunnel  studies  is that  the
 emission, ratios (CO to NOx,  and NMHC to NOx)  measured  in the tunnel studies is
 within the range  of ratios  predicted by the  model.  The  separation of exhaust
 from  non-tailpipe  NMHC  emissions showed  a  split similar to  that  predicted by
 MOBILE5a,  with  less than  20%  of NMHC from  light-duty vehicles  being
 evaporative running  loss  emissions.   At  Fort  McHenry,  non-tailpipe  NMHC
 emissions  (in  the  form of  running losses and resting  losses)  were estimated to
 be 15 + 2% of total NMHC based on use of MOBILESa;  at Tuscarora, the
 corresponding  estimate was   13  ±  2%.  These model estimates  agree  reasonably
 well  with  the estimates  of  the fraction of NMHC  emissions  from  non-tailpipe
 sources  derived from the tunnel study work (15 ±.3% and  16 ±. 4% at Fort
 McHenry  and  Tuscarora,  respectively).

       DRI concludes that with respect to the emission factor models,  the  Fort
 McHenry   and Tuscarora tunnel  studies indicate  that the   models  are
performing reasonably  well,  particularly   to  the   extent  that  the assumptions
concerning average  speed and other conditions are  met.   While this  is
undoubtedly   not  the  final  word  regarding  real-world  verifications  of modeled
emission  factors,  EPA is encouraged by  the  indication that  the revisions  that
have  been  made to  the MOBILE model  over  the  last few  years appear to be
improving  the  model's   accuracy  at  predicting  in-use  average  emissions.

       The Fort  McHenry tunnel,  as noted, is characterized  by significant
grade (up  to  3.76% both uphill and downhill).   Since the  MOBILE  models
 include  an "inherent  assumption"  of level  roadway, this  was  of  particular
 interest in assessing the  importance of grade  on  emissions.   The  results
 indicated  that  grade  has  a substantial effect  (up  to a factor  of 2) on  emissions
 expressed  in  grams  per mile,  but  a negligible  effect on fuel-specific emissions
 (e.g., grams  per  gallon  gas  consumed).   This indicates both  the  importance  of
 efforts to  include some  means of  correcting  emissions for  grade in  g/mi
 models, such  as MOBILES,  and the potential that  models  based  on fuel
 consumption  rather  than  distance traveled  could  have   significant  advantages.
 The  latter is a longer-range  issue; in the nearer  term, EPA  will be  considering
 methods  by  which  model users  could  account  for  grade effects when  running
 the  MOBILE  model.
                                                                              May 1995

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                                         -23-
L	Update  on   Specific   Issues  (since  .Tulv   199jj

       This  section  of  the  paper presents an  update  on  specific  issues
concerning   recognized  shortcomings  in  EPA's  historical  (1990  and  before)
approaches   to  in-use  vehicle  emission data  collection,  highway  vehicle
emission  factor modeling (MOBILE),  and  highway  vehicle  emission  inventory
development  (e.g., traffic models,  VMT estimation).   The  statements  of the
issues are the  same  as those presented in the July 1992  paper,  while the
"action"   sections  have  been  updated  to  reflect  changes   implemented  and
progress  made  since  then.   Many of  the  activities that have  occurred  or  are
now  occurring  have been  discussed in  the preceding sections,  while  longer-
range  projects  are  mostly covered  in   the last section.


ISSUE:      Recruitment   bias  in   emission   factor  testing.

       Traditional  recruitment  programs  are  based   on initial contacts  by  mail
and  generally  have   not  had  high  positive  response  (participation)  rates.    Are
the  vehicle  samples  developed  by   EPA's  emission factor  testing  programs
really  representative  of  the  in-use fleet?

Action   toward   resolution:

       When  the  July 1992  paper was written,  EPA  was  performing emission
testing of vehicles  at  a centralized  I/M program test stations  in  Hammond, IN
and  was  preparing to start  a similar program  near  Phoenix,  AZ.   Testing  at the
Hammond site  ran  from  September  1989.  through February  1992, and  after a
temporary interruption  testing   recommenced  in September  1993  and
continued through  March  1995.   EPA   has since  started operation of  a new lane
testing program at Chicago  Heights,  IL.   Testing at Mesa, AZ was  performed
from  November 1991  through  September  1994,  when  it  was temporarily
stopped.   Testing at the Mesa  site  may recommence  in fiscal  1996  (after October
1, 199S), depending  on  the  availability  of  contract  funding.

       Since  all vehicles  are  required  to obtain  these  tests,  and  the  lane
operated   by  EPA would  be expected to obtain  a cross-section  of  all  vehicles
reporting  for testing  at  the  site, the  resulting emission data  has much less
selection  bias,  relative  to  mail-solicitation  vehicle  recruitment.   (To the  extent
that   vehicle  owners make  "temporary"   repairs or  other  vehicle/engine
adjustments   in  anticipation  of  this  required  testing,  it is possible that  vehicle
selection  itself  could be  relatively  unbiased,  while  emission  levels  from  tested
vehicles  could  still be biased toward lower  emissions.  The  extent  to which such
behaviors may  have  influenced emissions data  obtained  at  the  I/M  lane
programs  is unclear.)

       A  subsample  of vehicles  participating  in  the  lane testing is  then
recruited  for additional  laboratory  testing.   The recruitment  of vehicles  for
laboratory testing has  been  much  more  successful   (higher participation rates)
at these  lanes  --  potential participants  recruited at  the  lanes  have  the
immediate opportunity to see  their  vehicles  tested  on  a  dynamometer  and  to  see
the loaner vehicles  provided  for their  use  while EPA has  their vehicle for
testing, decreasing  reluctance  to participate  that may  be  based  in part  on
uncertainty  about  what .will  be  done  with  their vehicle during emission  factor
                                                                              May 1995

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                                         -24-
testing.   The personal  face-to-face contact between  the  vehicle  owner  and  the
recruiter  also appears  to  have  a  positive  impact  on  participation  rates.

       The  I/M  lane  testing  programs allow far  more  vehicles to be  tested and
added to the data base  within  time  and  resource  constraints,  greatly  increasing
the  number  of  vehicles  represented  in  the data  base  and thus  increasing
confidence  in the  resulting  estimates.    In recent  years,  the  "traditional"
emission  factor  program  has  tested  between  500 and  1000  vehicles  annually,
depending  on the  number  and  complexity  of  the  tests  performed on  each
vehicle.   To  date,  IM240 data  has  been  obtained from about  12,000 vehicles  in
the Hammond program, at a  rate of about  70  vehicles per  week.   The Mesa
program  is  testing  about  70 vehicles  per  week, with  a total of about 6500
vehicles  as  of November  1994 .   Of the 12,000 Hammond vehicle  tests,
corresponding laboratory  FTP results  were  obtained  for about  640 vehicles;  of
6500  Mesa vehicle tests, corresponding  FTP  tests  have  been  performed  on about
480   vehicles.

       I/M  lane  testing also* provides the  opportunity  for  EPA to focus  on
recruitment  and  laboratory  testing of  higher-emitting  vehicles.    The
emissions   behavior of  properly  maintained,   non-tampered  vehicles  is
supported  by  more data than  that  of  various  higher-emitting  vehicles
(whether  due to  tampering,  malmaintenance,   or  other  causes),  thus  this
ability to  focus  on recruitment  and testing  of  high emitting vehicles  provides
useful data  for inclusion  in the  model.   The  large  proportion of all  vehicles
registered in  the  I/M  area  that  pass  through   a  centralized test location  over
the course  of an  inspection  cycle  (i.e., annual,  biennial)  mean that EPA  has
also  been able  to  obtain  more  data  from  old  vehicles  at  high mileages,  an area
that  has  lacked  data  in  the past.   Generally,  high  mileage vehicles tested in the
EFP  have  been relatively  new  vehicles  that  accumulated mileage  at  greater
than  average  rates,  while relatively  few  high age  and  high  mileage  vehicles
have  been  tested.   The data from  vehicles that  reached high  mileages  at  more
average  rates  of  mileage  accumulation  have  been  used in revising the  basic
emission  rate  equations in  MOBILE5, as discussed  earlier  in  this  paper.

       In the  discussion of  revisions to the MOBILE  model in Section 1, the
development  of  new  basic  emission  rate equations  using  data from IM240
programs  (Hammond)  and  correlations  between  IM240 and  FTP emission
results was  outlined.  For MOBILE5a,  IM240 and FTP emissions from 590 vehicles
were  used to  develop  the  correlations for HC and  CO emissions.  For NOx
emissions,  an additional  55  vehicles specifically selected  for use  in
characterizing  NOx emissions  were  also used, for  a total  of 645  vehicles.  All of
the data  used in  MOBILESa  for  this purpose  was  collected at the Hammond lane.
In the next revision of  the  BERs,  additional  Hammond and Chicago Heights  data
plus  data obtained  at Mesa,  AZ will  be also  be used.

       The  basic emission rates  used in MOBILE4.1  and  in  MOBILESa, for 1981
and  later model  year  light-duty  gas vehicles  and  for all  three  pollutants,  are
presented in  Table 1.   The biggest difference  observed in these rates  is  in  the
in-use deterioration rates  (rates of increase   in  emissions  with  increasing
age/mileage of the vehicle).   Relatively  little change  in  the zero-mile level
emission  estimates  was supported by these  data.   For the reasons cited  above,
EPA  believes  that  the  sample  of vehicles  from  the  Hammond  program is
comparatively free of  selection  bias, particularly  relative  to the  mail-
                                                                               May 1995

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                                         -25-
 solicitation  EFP.   As data continue to be collected  in  the  Mesa  area, those results
 will be  added to the emission factor  data base, and  the  complete data  will  be
 used  for future  updates to the basic emission  rates.

       Table  2 presents another  way  of  viewing the impact  of  the  use of  the
 IM240  data in the modeling  of basic non-tampered  emission rates  in  MOBILESa.
 These  tables  (one  for  each  pollutant) show  the  predicted  emissions in grams
 per mile, by  model  year, at 50,000 (50K) and 100,000 (IOOK)  miles accumulated
 mileage.  There are also columns  indicating  the  ratio of the MOBILE5a to
 corresponding  MOBILE4.1  emissions estimates.   Table  I  showed  that the zero-
 mile  levels  for various model year/pollutant  combinations  were,  for   the  most
 part,  not significantly  different  when revised to  account for the  IM240  testing
 data.    The bigger  differences were in  the  deterioration  rates,  most notably  in
 the estimated  values  of "DR2" (the  deterioration  rate applied to  accumulated
 mileage  above  50,000  miles).

       In the  case  of HC emissions. Table 2  shows that MOBILESa estimates of
 non-tampered  vehicle emissions at  50,000  miles tend  to  be around 5-10%
 higher  than the corresponding  MOBILE4.1  estimates  for  early  1990s  vehicles.
 In some model  years  (1981-2,  1984,  1987-88,  and  1997+), the MOBILESa estimates
 are slightly  lower  than  the  MOBILE4.1  estimates,  although generally  by  only I
 or 2%.   This  is  not the  case  at 100,000 miles,  where MOBILESa  emissions are
 much higher  than  MOBILE4.1 emissions for  all  model  years 1980  and later,
 often  double  the earlier estimates.   This  notably includes  all  future  vehicles,
 where  even with  the  implementation of  Tier 1  tailpipe standards, the available
 data on current late-model  vehicles  indicates that  average  in-use  HC  emissions
 exceed  applicable  standards  at  100,000 miles.

       Basically  similar  conclusions can be  drawn  from  Table 2  for CO
 emissions.   At  50,000  miles,  the MOBILESa  estimates (relative  to the
 corresponding MOBILE4.1  estimates)  range  from a  decrease  of  4%  (for MY
 1981) to an increase of  63%  (MY  1980),  and are generally  in the range  of  10  to
 35% increases.   At  100,000  miles,  the impact  of  the new  basic  emission rate
 equations based  on  the  IM240 data is to  roughly double  the average CO emission
 factor for most model  years  after   1980.   Note that  the Federal Tier  1  exhaust
emission standards,  which  are phased in from MY   1994  through 1998, do  not
 include   any change in   the current 3.4 g/mi CO  exhaust  emission  standard.

       Finally, in the case  of NOx emissions, similar  statements can be made.
The  major  difference for the  new  basic emission  rate  equations for NOx,
 relative  to the changes  made  in the HC and  CO equations,  is that  the  best
 estimates for  both  deterioration rates (DR1,  applicable  to the first  50,000  miles,
 and  OR2,  applicable  to mileage accumulation  over  50,000  miles)  are
 significantly higher than previous  estimates.   For HC  and CO,  as  noted, the
 largest  contributor  to   the  increase  in  emission  factors  was the  substantial
 increase  in  the estimates for  DR2.   For NOx, on the other hand,  deterioration
 throughout  the  life  of   the vehicle  is now  estimated as  substantially  higher
 than in  the past.   As  can  be seen in Table 2c,  the pre-50,000-mile deterioration
 rates are 2  to 3 times  earlier estimates for model years  1984 and later.   The
deterioration  rates  for  50,000+  miles are  also  considerably higher than
previous  estimates.

       There  is  some  indication from tunnel  study  results  that the model's
 estimates of in-use  NOx emissions  may be  too high.  The  reasons behind  this
                                                                               May 1995

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                                         -26-


are not yet  understood.  The same  sources  of data were used  to  revise the basic
emission  rate  equations  for  all  three  pollutants.   One possible explanation  is
that the  vehicles in  the  1992  tunnel  studies  (Fort  McHenry  and Tuscarora)
tended  to be  newer  and better maintained  than  the  overall population of
vehicles,  particularly  those  in urban  areas.   EPA  will continue  to  collect  in-use
emission  data  under  both  the mail-solicitation  and  IM240  lane portions  of the
emission  factor  test  program,  and  will  make  changes  as  warranted  by  that  data.

       In  the  future,  the utility of collecting data  from  operating I/M
programs  for  the  derivation of  basic  non-tampered  emission rate  equations
will have  to be  reconsidered.   As  vehicles  built  to compliance with  the newest
levels  of  exhaust emission  standards  (Federal  Tier  1  standards, LEV  standards)
are introduced over the  next decade,  EPA  anticipates  that all  areas  of the
country required to operate  I/M  programs will in  fact be doing so.   This will
prevent EPA from  collecting the wide range  of  in-use test data  from vehicles
in their first I/M cycle, as  has  been  obtained in  Hammond and  is being
obtained in  Mesa.   Since  vehicles  in  areas  that  have had  an  I/M program  in
effect  for  longer than one  full cycle  (e.g.,  a year  for annual  programs or  two
years  for  biennial  programs)  will,  as  a fleet, exhibit the  benefits of  that  I/M
program  in the results of their  emissions tests, EPA  will  no longer be able to
use data   collected  under  these  conditions   to  represent  "basic,  non-tampered"
emission  rates,  which by definition do  not  include  any I/M benefits.    Other
approaches  to  using  data collected from I/M  programs, and other means of
collecting  in-use  data from  the  widest  and  most bias-free  samples  available,
will be considered  by EPA  for future  updates to  the  basic  emission rate
equations.

ISSUE:    Are   "super"   emitting   vehicles   correctly   represented   in    the
model?

       Within each  model year,  MOBILE4.1  [and  MOBILESa] assume a
distribution  of  vehicles  among  four  emitter categories:   normal,  high,  very
high,  and  super  emitters.    Normal emitters have  hydrocarbon (HC)  emissions
of  no  more  than twice  the  then-current 0.41  g/mi standard, or 0.82  g/mi, and
carbon monoxide  (CO) emissions  of no more  than  three  times the standard, or
10.2 g/mi.   Super emitters are vehicles emitting at  least 10  g/mi  HC at at least
150 g/mi  CO.   The relative proportion of vehicles in each  of  these  emitter
categories, the  growth  in  the fractions of  "high,  "very  high," and  "super"
emitters  over time,  and  the emission  rates  of the  "super"  emitters  are estimated
on  the  basis of emission factor  program data.   The fraction of vehicles modeled
as  super  emitters  and  their modeled  in-use  emission  rates  may  not  accurately
reflect the  occurrence and  behavior  of these vehicles in  the  real  world.

Action    toward   resolution:

       In  the  real  world vehicle  emission  levels  fall along a continuum,  from
low (normal)  levels,  through  "high"   and  "very  high" emitters,  to  the extreme
values characterized in the   model  as  "super"  emitters.   The  grouping of
vehicles  into four  emitter categories   in  the model,  with  vehicles slowly
migrating  from  the  lower  to  the  higher  emitter categories   with  increasing
mileage,   may  underestimate  emissions  in  two  ways:   By   underestimating  the
number of vehicles that are in  the  higher  emitter  categories at any given
                                                                              May 1995

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                                         -27-
point  in  time  or  accumulated  mileage,  and/or  by  underestimating  the average
in-use  emission  levels  associated  with  those  categories.

       However, the same data collected in the Hammond  lane  program
(discussed  in  Section  1  and  in  the  first  "Issue"  above) was  used  to derive
estimates  of  the relative  in-use populations  of  vehicles in  each  of the four
emitter categories  (normal,  high,  very high, super) used  in  the  MOBILE  model.
What  was  found  was  that  there  were considerably more  vehicles  in  the   "verv
high"  emitter category  than  was assumed in MOBILE4.1.   The  increase in this'
category  was approximately  100%  (there were  about  twice  as  many  very  high
emitters as  was assumed in MOBILE4.1).   The estimate of the  fraction of  vehicles
in  the  high emitter  category derived  from  the  Hammond data  was  slightly
lower  than  that in MOBILE4.1, and the estimated  fraction of super emitters  was
slightly higher  than  in  MOBILE4.1, but the biggest difference by  far was  in
the  very  high  emitter category.

       EPA has  included  these  updated estimates  of the  fractions  of  vehicles in
each  emitter category in  MOBILESa.   The  large  increase in the very  high
emitter category,  and  the smaller  increase  in  the super emitter  category, more
than  outweigh  the  slight  decrease  in  the  high  emitter category,  such  that  the
net effect  of including this  revised emitter category  distribution  in MOBILESa
was to further  increase  the  average  in-use emission  factors  over the  range  of
conditions  included  in  the   model.

       What was not found  in  the  Hammond data  was  evidence  that the
emission  rates  associated  with  vehicles  in  each  of the  above-normal  emitter
categories needed  to be significantly changed.   This is partly  due to the
definition of  the  emitter  categories by  their emission levels  (the average
emissions  of  all vehicles  that are defined as  having emissions  between  X  and  Y
g/mi  is  not likely  to  change  significantly,  regardless  of the  number  of
vehicles  considered  or  the source of  the  data).   The  super emitter category  is
also defined by emission  levels, but  is  open-ended (anything  over 10  g/mi HC
or over 150 g/mi  CO).   The Hammond data did  not demonstrate  that the average
emission rate  of super emitters  used in MOBILE4.1 needed  to  be  increased.

       EPA will continue  to  examine  the  distribution  of  vehicles  among  the
defined emitter  categories  as additional lane data  are  collected.   To  the extent
that remote  sensing  data  meeting  the caveats listed  above become  available for
analysis, such data  will also be included in future updates  to  the emitter
distribution.   There is  also  a need  for remote sensing data  from non-l/M  areas.
Thus,  this  is  an issue that will continue to draw  attention  over the  longer term.

       A  number  of investigators (EPA, State and local  agencies, motor  vehicle
manufacturers  and  oil  companies,   and  other  researchers)  have  conducted
studies  using  remote  sensing  devices (RSD)  for HC and CO emission
measurements,  and to a  much   lesser  extent NOx  emission  measurements.   Only
some  of  these  studies  have also obtained  an independent  measurement of
emissions  (such as from  an  IM240  or  an FTP test) to relate instantaneous  RSD
emission  measurements  to overall  emissions over  a driving cycle.  The
California  Bureau  of Automotive  Repair has  conducted the most  extensive RSD
study,  which  included  RSD  readings  on  about I  million  vehicles;  IM240
measurements were  obtained on about 3000 of those  vehicles  (0.3%).  Analysis
is underway to determine how  to  incorporate the  use  of  RSD readings into an
                                                                              May 1995

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                                         -28-
 I/M program so  as to  focus  on  the  identification  of high-emitting  vehicles  for
 more  complete  testing  and  repairs.


 ISSUE:      Representativeness  of  the   FTP  and  other  driving  cycles.

       The Federal Test  Procedure (FTP), used  to represent  urban traffic,  and
 the  other  driving  cycles  used  in  emission testing  (i.e.,  cycles  of differing
 average  speeds  used  to  develop  speed correction factors)  used to represent
 other  modes  of driving behavior,  may  not be  representative  of all  of the  types
 of  actual  vehicle  operation  important  to determining overall  highway vehicle
 emission   levels.

       The FTP was  developed during  the early  1970s  in  southern  California.
 Traffic patterns  and  typical  driving  patterns  may  have  changed   significantly
 since  then,  calling into  question  the  utility  of  the FTP  in  characterizing
 typical urban driving behavior.   Even  if  the  FTP is  still  representative  of
 average  urban  driving  in terms  of such  variables  as operating  mode,  average
 speed,  and average  trip  length, EPA  is  aware  that  accelerations  in   real-world
 driving conditions  at  time exceed the maximum  acceleration  rates  included  in
 the  FTP,   and that emission  rates  at higher  accelerations can  be  much  greater
 than those at lower rates  of  acceleration.  Due to  the  sensitivity  of  emissions  to
 the  amount  and severity  of acceleration,   the various  speed cycles used  in  the
 development  of  speed  correction  factors (SCFs),  and thus  the  SCFs  themselves,
 may  not  be  adequately representative of  the emissions  behavior  of  vehicles  at
 those  speeds in  real-world  conditions.

 Action    toward   resolution:

       The issues  of representativeness of the  FTP to  characterize   typical
 urban  driving,  the  effects  of "off-cycle"  driving  patterns  (defined  as types  of
 driving,  such as  higher  speeds  and  acceleration  rates, not reflected in  the
 existing FTP),  and the  representativeness  of  the   various speed  cycles used  in
emission  factor  testing  to actual   traffic at various  average speeds  are  closely
 related.  Since  the  July 1992  paper, EPA  and the California Air Resources  Board
(CARB) have  conducted  programs  involving both  instrumented  vehicles  and
chase  cars to evaluate  the  degree to which  the  FTP  is  representative of today's
driving, and  the  prevalence  of driving behaviors  not  included  in the FTP,  are
as required by  the 1990  Clean Air Act Amendments.    Additional information  on
the  study  design,  including  survey  methods, data collection,  and results based
 on  preliminary  analyses,  can  be   found  in the  report  "Federal  Test  Procedure
 Review  Project:  Preliminary  Technical  Report."8

       Although  the results of  these  studies  are  not  yet available for use
 directly in the  MOBILE  emission factor  model, they  are providing  the
 information necessary for  EPA to  develop new  driving  cycles  for use  in
 emission  factor  testing  that  will  better  capture  the  range of  driving  patterns
 actually  encountered in  use.   The information  obtained  from  such  studies on
 the  frequency  of  occurrence  of,  and  the  emissions  impacts  of,  various
 conditions  not  currently  included  in  the   FTP will  culminate  in  revisions  in  the
 FTP itself.   [EPA  published a  Notice  of  Proposed Rulemaking (NPRM) initiating
 the formal process of revising the FTP on  February 7,  1995  (60 FR 7404).   A
 public hearing on  the  NPRM was held in Ann Arbor on  April  19,1995.]
                                                                              May 1995

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                                        -29-


       A  report  has  been  published  by EPA's Certification  Division  that
summarizes the  findings  of  research  into  the  frequency  of occurrence  and
emissions  impacts of  various  "off-cycle"  driving behaviors.9  This report
identified a number  of  significant  ways in  which the existing FTP  fails to
capture  situations  that  occur under  actual  in-use  conditions  and  may
significantly  affect  in-use  emission  levels.    Among  those  identified:

   •     Commanded  enrichment   -  Vehicles  accelerations  greater  than the
         maximum  rate  included in  the  current  FTP,  particularly  when
         demanded  at moderate  to  high travel speeds,  result  in the  vehicle's
         computer  controls   "commanding"   enrichment  of  the  air/fuel  mixture
         reaching  the  engine  in order  to  supply  the  power demanded  by  the
         driver.   Such events can  result in  emission rates  much  greater than
         are seen  in  testing  over the existing  FTP.

   •     Transient  enrichment -  In addition to  enrichment  events  that are
         "commanded"  by  the  vehicle/engine  computer  controls,  the   in-use
         driving  survey  revealed that  brief  periods  of  fuel/air  mixture
         enrichment  occur  during  driving  that is  otherwise similar  to  FTP
         driving.   It  appears that  this  may  be the result  of minor  but  frequent
         variations  in  throttle position  (how  far  the  gas pedal  is depressed)
         during  otherwise  ordinary  driving.    This type  of enrichment  also
         results  in  "spikes"  of  higher  emissions  that are  generally  not
         encountered  in  EPA vehicle tests,  during  which  vehicles  are  operated
         by  technicians  that  are trained  to  follow  speed/time traces.

   •    Air  conditioning  use - Although the  FTP  includes provisions  for
         increasing  the  dynamometer load  during vehicle  testing,  in order  to
         simulate the added power  demand  of air conditioning (A/C), FTP  and
         other  emissions  tests  historically are not  performed with  the  vehicle
         air conditioner  turned on.    Measurements obtained as  part  of  the  in-
         use  driving  surveys  and   subsequent  emission  testing  in  the   laboratory
         indicate  that  use  of air  conditioners  can result  in  substantial  increases
         in NOx  emissions.

         After  some  initial  testing  conducted  by  EPA demonstrated  an
         unexpectedly  large  increase  in NOx  emissions  with  the  air conditioner
         on, the  vehicle  manufacturers  tested  seven   (7) model  year  1994
         vehicles in  a sophisticated  environmental  test  chamber.    Under  fairly
         extreme temperature conditions  (95°F  ambient  temperature,  40%
         relative  humidity,  simulation  of  sunny mid-afternoon radiant  heating,
         and  135°F road  surface  temperature, and  using  HCF-134a refrigerant
         in the A/C), average emission increases of 25%  for  NMHC  (0.09  to 0.11
         g/mi),  51% for CO (1.0  to  1.5 g/mi), and 92% for NOx (0.21  to 0.41 g/mi)
         were  observed over  the full  FTP.   A survey  of  in-use  A/C operation
         conducted  by EPA in Phoenix, AZ demonstrated  that A/C  compressor
         operation  decreases  rapidly  at lower ambient  temperatures and  with
         lowered solar (radiant) heat loading, although  data  to quantify  the
         associated  emissions  impact  do not  yet  exist.   Another complicating
         factor  is  that the NOx  increase due to A/C  operation  appears to be
         dependent  on vehicle speed.   The  same  vehicles,  when operated over  a
         high-speed  driving  cycle,  had average  increases  in  NOx  emissions of
         only 44%  (0.22  to  0.32 g/mi).   Thus, not only  is  the emission  increase
         associated with  A/C usage  highly  dependent  on  ambient  temperatures
                                                                             May 1995

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                                 -30-
and  solar  heat loading,  but  adjustments  in the algorithms  used to
generate speed correction  factors  may  be  required  as  well  in  order  to
more accurately quantify  the  effects of  A/C  on  in-use  emission  levels.

Trip  patterns - Beyond the speed vs. time trace  that is used to define all
driving cycles  for  laboratory  testing, including the  FTP,  there  is  an
issue regarding the pattern of trips  taken.   The FTP and its  associated
operating  mode  fractions  assume that 43%  of all  vehicle  starts are
 'cold  starts,"  where the engine  and  the  catalyst have  cooled off
completely,   and that  the  remaining  57%  of starts  are  "hot starts,"  in
which the  engine   and  catalyst  have only  cooled  slightly  from
operating  temperatures  and   therefore  will  regain  operating
efficiency  temperatures  very  quickly.   The  data obtained by  EPA  in
Baltimore  indicated  that  almost 40% of starts  occur  after engine-off
times of  between  10 minutes  and two  hours  (see  next paragraph).   The
trip  length  of the  FTP is  7.5 miles; the average trip  length in Baltimore
was  only  4.9  miles, and the  median length (half of all  trips longer and
half  shorter)  was only  2.5 miles.    This  implies  that a greater  fraction
of total  VMT is  accumulated  in "start"  modes,  when engine and  catalyst
temperatures  have  yet  to  reach the high   levels   required  for  efficient
operation,  than  is  reflected  in  the  operating  mode fractions  associated
with  the  FTP.   Other differences  in trip  patterns,  such  as  the average
distance  traveled between  stops,  were also  observed.

EPA  recently  received  the final report  from  a contractor  on  the
analysis  of  trip pattern  data.10   This analysis focused  on  trips per day,
miles per day, and  other  aspects  of in-use travel  descriptors,  and  was
initiated  by  QMS  for  the  purpose  of improving the handling  of these
parameters  in  the  model.   The  results of  the analysis indicated that
there are  in  fact   differences between  current  EPA  modeling
assumptions  and  real-world  experience.

The  results   of these  analyses will  be considered in  the  next  major
revision to the MOBILE  model, MOBILE6, in which OMS will also make
an effort  to  include  some form of  "trip-based  emission  factors"  option.
It  is  also possible  that MOBILE6 will include  the option  to  model hot
soak  evaporative  emissions as  a function of  soak  time  (see  following
paragraph).

Intermediate  soak  times  • "Soak  time"  refers to the amount of time  that
the  vehicle   is  not  running before a trip begins.   The  FTP as currently
structured  includes  the  emission  impacts  of  a 10-minute engine-off
period,  representing "hot  start"  emissions (the hot  start bag  3 of  the
FTP  is preceded by a  10-minute soak after the completion  of the
stabilized  bag 2).   The  emissions impacts  of  a cold-start are  measured
during the bag 1 portion  of  the test, following  a soak time of  12  hours.
Data on  in-use trip  patterns  and follow-up emissions  testing  show  that
the  extent  to  which additional  emissions  are associated with  start-ups
is  a  continuous function  of  the soak  (engine off)  time  immediately
preceding the  trip.   Additional testing  is  required  to adequately
characterize  incremental  start-up  emissions over  a  wide  range  of soak
times.
                                                                       May 1995

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                                         -31-
         Simulation  of actual road  load -  The road load setting is  used  in
         emission testing  to set the dynamometer power absorption  at  a  level
         intended to  equal  the  power  required for on-road  driving  over  a  range
         of vehicle  speeds.   To the extent that  current procedures for
         determining  road   load  (e.g.,   coastdowns)  are  inadequate  in  measuring
         actual  road load,  the  dynamometer  settings  will be  in  error and  the
         resulting emissions test  will   not  accurately  reflect the  conditions
         being  simulated.   The advent  of new   electric  dynamometers   (replacing
         the  water  brake dynamometers that  have - been  used since   the early
         1970s) should enable EPA  to  better match  actual  road  load,  over  the
         entire  range  of  speeds included in  the  test cycles,  to  actual on-road
         road loads, and  hence should  improve  the  accuracy of  the  emissions
         data obtained in these tests.

    •     Road   grade  • The  FTP, and  all other laboratory  driving tests,  assume
         level  roadways.   That  is,  the  additional   power required  of a vehicle to
         climb a grade is not  accounted for in any emissions testing.   That
         many  roads are  not in fact level  is  well known.   Quantifying  the
         impact  of  grade on emissions, however,  has  not  been  investigated
         until  recent  years  (see  the discussion of the  Fort  McHenry tunnel
         study  above).   Preliminary  indications are that  road  grade   has a
         substantial  impact  on  emissions,  but questions on how  best  to model
         such  effects  require   additional  investigation.  •

       The  task of  determining the impacts  of each of these aspects of in-use
driving behavior  on  emissions,  the quantities and variety  of  data   collection
required  to attempt  to incorporate  the  effects of  each  item into  the  MOBILE
model,  and  the potential interactions  among  items  that  are listed  distinctly
above,  make it clear that  all  concerns about the representativeness of  driving
cycles cannot  be resolved  to the  satisfaction  of  all  interested  parties  in  the
short  term.   EPA continues  to  collect and  analyze  data,  and recognizes  that a
great  deal of effort will  need  to be  expended in  these areas for  the foreseeable
future,  which  the   Agency  intends  to  pursue.

       It  should be pointed  out  again  here that  the current  MOBILES  model and
its  predecessor  versions do  not  and did not  rely  only  on FTP emissions test
results  in  estimating  in-use emission   factors  for highway  vehicles.    Much
testing has  been performed   outside of  the  FTP  and its specified  conditions  (e.g.,
with  different  fuels,  at  different  temperatures,  and  over  different driving
cycles),  and  that information  has  long been  used  in estimating average  in-use
emissions  over a wider  range  of  conditions  than  are represented in  the
current FTP.   Also, no  matter  how  the revised FTP  rulemaking  is finalized,  no
single driving  cycle  will be capable  of capturing all of the driving  behaviors
and  other variables  that affect  in-use  emissions.


ISSUE:     Actual   freeway   (limited  access  highway)   speeds  exceed   55
mph   in  many   areas.

       MOBILE4 and  earlier versions of the  EPA emission  factor model estimated
emission factors  only  up  to  a maximum speed  of  55  mph.  EPA  guidance was  to
use the  55  mph emission  factors  for  situations  where vehicle  miles  traveled
(VMT) were accumulated at higher speeds.  The increase in the speed  limit to
65  mph  on  many   limited access highways and  the  frequent violation  of  the  55
                                                                               May 1995

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                                         -32-
mph  limit in areas where it  applies  has  led  to  requests  for  emission  factors at
higher  speeds  to  be  calculated by  the  model.

Action   toward   resolution:

       MOBILE4.1  used  data  collected by  the  California Air Resources Board
from  driving  cycles  with average speeds  as  high as 65 mph  to revise  the  speed
correction  factors  used in  MOBILE4  and  previous  versions  of the  model  and to
extend  them  to  a  maximum average speed  of 65  mph.   Since  that time,  EPA has
re-examined  the  available  data  on emissions as  a  function  of speed,  as  discussed
previously.   In MOBILES,  this  led to  further revision  of the speed correction
factors, for all  three  pollutants, for all  average  speeds over  19.6  mph (the
average speed of the existing FTP driving cycle).   These  differences, as
described in  section  1,  included changing the  modeled  emissions  behavior of
vehicles in the "high speed  range",  which for  the  purposes  of speed
correction  factors  is considered to be average  speeds of  48-65  mph.   Where in
MOBILE4.1  emissions were  modeled as  increasing  with  increases  in  average
speed  from  48 to 65  mph,  MOBILES models  g/mi emissions as being constant
over  the  range  of  48-55  mph  average  speed, then  increasing as  speed
increases  from 55  to  65  mph.   Both EPA  and  CARB are  continuing to obtain
emission  data from  vehicle  tests over  driving  cycles having  high  average
speeds, and additional data will be considered in the  next  revision to the  model.

       This does  not address the problems  inherent in  using  average  trip
speeds, and  emission correction  factors  based  on  testing  over  transient  driving
cycles of differing  average speeds, to  model  emissions  for  applications  not  well
characterized  by   such driving cycles  (i.e., link-based  estimates).   This  is  the
next "Issue"  discussed.   Nor  does  it address the fact that a non-zero  fraction of
travel, particularly in  certain  areas,  occurs at  speeds of 70, 75,  or  80 mph  (or
more).   The  "high-speed"  cycles  currently being  used for emission  factor
testing  have  average  speeds  up  to  60-65  mph; these cycles  include some
operation  at speeds  in excess  of 70 mph.  As more  data  from testing of  vehicles
over  high-speed cycles  becomes available, it   will be  taken  into account in the
development  of revised  speed  correction  factors for use  in  later  versions  of   the
MOBILE  model.   In the  interim, EPA recommends that  VMT at  speeds over  65
mph  continue  to  be  assigned the  maximum-speed  65   mph emission factors
from MOBILES.
ISSUE:    The  use  of  average  trip   speed  to  estimate  emissions  as  a
function   of  speed  in  the   model.

       The  speed correction  factors (SCFs)  used in the  models to correct
emissions to average  speeds  other than the FTP average  speed of 19.6 mph  are
derived from testing  over a series  of driving cycles,  having  average speeds
ranging from 2.5 to 65  mph.   Each  of  these  driving cycles  represents a trip, in
that  each cycle  begins  and ends  at  idle  and  includes  a mix  of accelerations,
decelerations, and  driving at different  speeds,  such that the  total distance  of
the cycle divided by  elapsed  time gives  the average speed  of the  cycle.  Many
users of the MOBILE model  apply the emission factors  to  individual or
aggregated  highway  links (for  example,  a  given   length of  an  arterial  roadway,
or all arterial roads  taken  together),  where  emission  factors based  on
"cruising"  at the given  speed  (steady-state, or  modal,  emission  factors)  would
                                                                              May 1995

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                                         -33-


be  more  appropriate  than  the  trip-based average  speed  emission  factors
produced  by  the  model.

Action   toward   resolution:

       The  emission factors  as a  function of  average speed  produced by
MOBILE5a  are the  best that can  be  developed  at present,  given the driving
cycles used  to develop  the  speed correction  factors  and  the available  data.
Although  the  application  of emission  factors  estimated on  the  basis of data
collected  from transient speed cycles to  highway  links  has been  criticized,
there  is  no  immediate solution that  would resolve all concerns.    It should be
noted  that  most  highway  "links," or  segments, are  der'ined  as  including  either
the beginning  or ending  intersection  of  the  link.   Thus, the speed estimates
for links  (as  might  be generated  from the output of a  traffic  demand model)
would reflect  the inclusion  of at  least one stop, idle,  and acceleration,  and so a
link  modeled in this  way  is  actually  closer to  being  a "trip" (in the sense that
much of  the  MOBILE  modeling  is based  )  than generally  has  been considered.

       As  data  obtained  from  recent  driving  characterization  studies  continue
to be  analyzed and  made  available,  EPA will be considering ways  in which
emission  factors  can  be  refined  to  represent trips  and  highway  links  more
accurately.   One  possibility would be  to generate  driving cycles  of  different
average  speeds  for  different  roadway  types,  reflecting  differences in  traffic
congestion  and  other  conditions  (reflected  by  differences  in  frequency  of
stops   and  intensity  of  acceleration/deceleration  rates),   then  to  develop
corrections  to  the emission  factors  that  would  account   for  both  average  speed
and roadway  type.   The California Air Resources Board  (CARB) has developed
some  "facility-specific" driving cycles using  the  newest  data, and CARB  and
EPA  are  collecting  emissions data from  tests  over these  cycles.   The  speed
correction  cycles  currently used  include cycles  that  begin  and  end  at
relatively  high  speeds;  some  of these might  be used to  develop  emission  factors
more  representative  of  highway  links  as well.

       EPA and CARB continue to test  vehicles at  different  speeds,  and  to
evaluate  the  suitability of  the  SCFs  used in  the emission factor  models.   Since
speed  is  one  of  the  most critical determinants of  emission levels,  improvements
in the  characterization of in-use  speeds and  speed  variability,  and in  the
methodology  used to  convert  speed-dependent  emission  data into  speed
correction  factors  used in  the  model, will lead  to   further  improvements  in  the
accuracy of  the emission  factors.   EPA  is also  working  to develop  more and
different  driving  cycles,  accounting  for information obtained  from
instrumented  vehicles  and  other  work in  support  of  the  Revised  FTP
rulemaking  discussed  earlier.   This  continuing  work will be  taken into
consideration by EPA  in future revisions to the  SCFs used in MOBILE.


ISSUE:      Accuracy   of  the   characterization  of   in-use  emission
deterioration   rates   in   the  model.

       If  vehicles  overall  exhibit  significantly greater  emission  deterioration
with  increasing  age  and/or  accumulated mileage than is modeled  on the basis
of currently available data  (based on  FTP  testing  at different mileages),  then
the basic  emission  rate  equations understate emissions  for all but  relatively
new  vehicles.   There  are  two  aspects to  the issue  of modeling in-use emission
                                                                               May 1995

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                                          -34-
 deterioration  rates:   extrapolating  emissions as  a function of  mileage to  verv
 high  mileages  (very  few  vehicles  with  extreme  odometer  mileages  have  been
 tested  in  mail-solicitation  emission  factor testing programs),  and  separation  of
 the  emission effects  of vehicle age  and  vehicle mileage.

 Action   toward    resolution:

        EPA  believes  that the  premise of  the  first sentence above  is  true:
 Vehicles  overall   do   exhibit  greater  emission  deterioration  rates  with
 increasing age  and/or  accumulated  mileage  than  has  been  modeled in  the  past.
 The  updating  of  the  basic emission  rate  equations  for light-duty  vehicles  for
 all  three  pollutants on the  basis  of thousands of  IM240 tests and  the
 correlations  developed  between  IM240 and FTP emission  rates, as  already
 discussed  and illustrated  in Tables  la,  Ib, Ic,  showed that in-use deterioration
 rates  are considerably  greater than had been  estimated in  the  past.    This is
 particularly  true  for   vehicles after they  have  accumulated  50,000  miles;  the
 post-50K deterioration  rates used in  MOBILE5a  are  double and triple the
 previous estimates for HC  and CO,  and have  increased  by  more than a factor  of
 10  (from  previously  very  low estimates) in the case of NOx emissions from late
 model  vehicles.    As  noted previously,  these  increases  in  the  in-use
 deterioration  rates  account  for  much of  the overall  increase  in  emission  factor
 estimates  in  MOBILES  relative to MOBILE4.1.

       The increased  deterioration  rates  developed  from the  data collected at
 the  IM240 program lane and used in MOBILES  were  estimated  on the basis of
 the  emission  test results from the  highest mileage  vehicles  tested  in  the
 program thus far.  Most of  the  very high mileage vehicles tested were  also
 relatively  old  vehicles (early  1980s  model years, mostly  carbureted),  and  the
 data  from those  vehicles was used  to  estimate  the emissions at  very high
 mileages  from  later  vehicles  (for  which   direct data  are  not  generally
 available,  since  most  such  vehicles  have   yet to  attain those  very  high
 mileages,  and  which  are   primarily  fuel-injected).

       This  approach  to estimating  in-use deterioration rates  at  high  mileages
(over 50,000  miles)  has  been  criticized  as inappropriate.    However, in  the
absence  of late  model  year  vehicles having  high  odometer  mileages  for testing
(a problem that  always exists for the  newest,  latest  technology  vehicles in the
first  years  of production  and  sale),  there  is no readily   apparent  alternative  to
 reasonable extrapolations.   With  respect to the  specific case noted  in the
preceding  paragraph,  EPA  notes  that  while data  from  tests of mostly
carbureted  vehicles  was  used  in estimating  high-mileage deterioration rates
 from  newer,  mostly  fuel-injected  vehicles, there  is  no evidence that
carburetor problems  or failures  were  the underlying  cause of  the  increases
 observed  in  emissions.   Thus  use  of such data  for estimating deterioration  rates
 for  fuel-injected  vehicles  is  not  inappropriate.    As  emission  factor testing
 continues,  an  increasing  fraction  of vehicles of  mid-  and  late-1980s  model
 years will reach  very  high mileages  and  will  become available  for testing,  and
 the  estimated  deterioration  rates  applicable to  mileages over 50,000  miles  for
 those  later  vehicles   may  require  further revision.

       The  revisions  made  so far to the  basic  emission rate  equations and  in
 particular to  the  deterioration rates  only  address  one  of the  two  aspects of the
 issue  identified  above.  While the extensive IM240 data has allowed  EPA to
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                                         -35-
estimate  emissions  deterioration  at high  mileages with  more  confidence,  it  so
far has  not  been used  to attempt to distinguish  between the effects  of high
mileage  and the effects  of age.    While a  strong correlation exists  between  age
and  mileage, it remains  unclear  whether  the  increase  in  emissions  due  to
mileage  is  the  same  for  very high  and very  low rates  of mileage accumulation.
Consider, for example, two  MY 1991  vehicles  that are  each tested at  100,000
miles,  one  as  a  high-average  mileage  three-year-old  vehicle in  1994   and
another  as a low-average  mileage  10-year-old vehicle  in  2001:   Not only  is  it
not possible  at  this  time  to predict on  the basis  of  data whether the  emissions
increases experienced by  these two vehicles  are comparable,  it  is  unclear  how
such  information  would  be  reflected  in the  model.

       EPA  suspects  that  a real  distinction exists  between  in-use  deterioration
in emissions performance  as a result  of  high accumulated  mileage,  and that
resulting  from  advancing  age  of the  vehicle (whatever  the  accumulated
mileage  on  the older vehicle).   These  are  not  independent  effects,  and
resolution  of this  issue  can  only be  reached by collecting substantial in-use
emission  data  from  vehicles  spanning  a range of both  ages  and  mileages  over
a  long period.


ISSUE:      Evaporative   emissions,  particularly   diurnal   emissions,   may
not  be  the   same  under   test  conditions  as  in  real-world  experience.

       The  diurnal  portion  of the evaporative emission  test includes a
temperature  increase,  in the  vehicle  fuel tank  only,  of 60° to  84°F over one
hour.    This  temperature  increase  would typically occur over  eight or more
hours  outdoors  and would  affect  the  entire  vehicle,  not just  the fuel tank;
hence  the  resulting  emissions may  not  be  the  same.   EPA in the past  has only
measured hot soak  emissions for one  hour  after the end  of operation, while
such emissions  do not just cease  after  an   hour,  and are in  part  dependent on
the nature of the trip immediately preceding the  hot soak  (i.e., a  long  or a
short  trip, at high or low  speeds).

Action   toward    resolution:

       As  required by the  1990 Amendments to the Clean Air Act,  EPA has
revised the  evaporative  emissions test  procedure  used  for. new  vehicle
certification  to  more  accurately  reflect  real-world conditions.    This  new test
procedure, compliance with  which will be phased in  over the  next  few years
beginning  with  model year  1996, will  result  in better  control  of  evaporative
emissions  under a  wider  range of in-use  conditions not  reflected  in the
current evaporative  test  procedure.   The  benefits  of the  new  evaporative
emission  test procedures  on in-use emissions from vehicles  certified under
those   procedures is  included  in MOBILESa.

       To  more accurately  measure  evaporative  emissions  from  in-use  vehicles
certified  under  the  current procedures, EPA  implemented  changes  in the
evaporative  test procedures  used  for emission factor  testing to cover  more
realistic  conditions,   including  "real-time"   diurnal  tests  (e.g.,  measure
emissions  over  an   8-hour  period  during  which  temperatures   increase  from
60° to 84°F, rather  than  forcing  the 24F° rise  in temperature  to  occur during  a
I-hour  test),  measurements  of hot  soak emissions in  the  second  and  third
hours  following engine  operation (rather   than  for  only  one  hour)  and after


                                                                              May 1995

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                                         -36-


trips  of varying  lengths,  speeds,  and duration (rather  than  only  after the  FTP).
and  functional  purge  and  pressure   testing  of  evaporative  emission  control
systems  (see  next item).

       As  was noted in  the discussion in section  1, EPA  has  already taken one
step  toward  improving  the  diurnal  evaporative  emission  estimates  by
accounting  for observed  differences in  emissions over  8-hour  diurnal
temperature  rises  (rather  than  relying   solely  on 1-hour  simulations  of  such
events).   EPA has  also  been testing vehicles  using different  fuels and at
different  temperatures,  over  longer  diurnal  periods  (e.g.,  33 hours,  72   hours).
These  longer real-time   measurements will be  used  in  updating  the  estimated
emissions  from "multiple diurnal"  events,  in which  the vehicle  is  not   driven
for 2,  3,  or more consecutive days (and  so does  not  have an opportunity  to
purge  the  evaporative  control  canister of  accumulated  vapor).   Hot  soak
emissions  are  being  measured  after actual  on-road  trips,  rather  than only
after   dynamometer  simulations.

       All   of  the information  gathered  through  these  testing programs will be
considered   in the  development  of  MOBILE6.   Indications are that higher
emissions  will be observed in  most  cases,  which  would lead  to  revisions  in  the
emission estimates produced by  the  model.   Results  from such  testing to  date
have  been   used,   and  further results  will continue  to  be used, to revise  the
evaporative emission  factors  to  better  represent  actual  in-use   conditions.


ISSUE:     Many  vehicles,   particularly  those   more   than  five  years   old,
have    functional   problems    with    evaporative   emission   control
systems.

       Recent  data  have shown  that  many  vehicles, particularly those  greater
than five  years  of  age, demonstrate functional  problems with   their
evaporative  emission control  systems.    Such  problems  fall  into  two  categories,
"purge" and "pressure"  failures.    Vehicles with either  or both  of  these
functional  problems  will  exhibit  much  higher  levels  of evaporative  emissions.

Action   toward   resolution:

       As  part of the Hammond  IN,  Chicago  Heights  IL, and  Mesa AZ programs
already discussed, EPA  has  been  conducting   functional  pressure and purge
tests of  vehicle evaporative control  systems.    This provides  data on  both  the
rate  of failure of these  tests  observed in  a  large random sample of vehicles,
and  on the emissions  impact  of  vehicles exhibiting  these  problems.

       QMS has   revised  the evaporative  emissions algorithms in  the MOBILE
model  to  account  for  the  in-use  rates of  pressure  and  purge  test failures, based
on  the  data available  for use  in MOBILES,  and the  associated emissions impact.
As  additional  data on  both failure rates  over the two tests and  the  emissions
impact  of  such  failures  is  collected, we  will continue to  analyze those data  and
the results  of  such  analyses will be  reflected  in  future model revisions.   As
noted  earlier, examination  of ambient and modeled   emission  ratios  seems to
suggest that  evaporative emissions  are  not  adequately accounted for; this  work
assists  in  better  quantifying  both  the   relative  and  absolute  contribution of
evaporative emissions  to  overall  hydrocarbon emissions  from   motor vehicles.
                                                                              May 1995

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                                        -37-
       EPA  is  also  investigating  ways  in  which  the functional  pressure  and
purge  tests of  evaporative emission  control  systems  can  be  made more
practical.   While  the  tests  currently being  performed  are  useful in obtaining
data on  the  rates and  emissions impacts  of  failure  on one or  both of these  tests,
the  tests themselves are  somewhat  complex  and are difficult  to  perform  on
some  vehicles.


ISSUE:     Commercial  and  test  fuels   differ   in   properties  (e.g.,
volatility,   sulfur   level,    distillation   curves,   composition)   that   have
an  impact  on   vehicle   emission  levels.

       The  fuel  used  in  new  vehicle. certification  and  standard  emission  factor
testing  programs  (excluding  tests designed  to characterize the  impact .of  fuel
parameters,  such as  volatility)  is  blended to  a  specified formula.  Commercial
fuels differ,  both from this  test  fuel  and in  different areas of  the  country  and
at different  times,  and  fuel  parameters  other than  volatility  affect  emissions.
Such parameters include,  but may  not be limited to, the sulfur  content of  the
fuel,  the distillation curve (i.e.,  what  fraction of the fuel evaporates at various
temperatures), and  the  composition. of the  fuel  in  terms  of fractions of
paraffins,  olefins,   and  aromatics.

Action   toward    resolution:

       MOBILE4 incorporated  fuel volatility  as  measured by  Reid vapor
pressure  (RVP)  as  a user  input,  and  adjusted emission  factors to account for
volatility  effects.   These  correction  factors  will  be updated as  more  data  are
available  for analysis.  In MOBILES,  EPA also has adjusted  upward the  "base
fuel"  (9.0 psi RVP) emission factors  to  reflect  the effects of  average
commercially  available fuel  (defined using  other  fuel   parameters,  such  as
average  sulfur content) based  on  a  large body  of  recent  testing performed  as
part  of  the  Auto/Oil  Air  Quality  Improvement  Research Program.

       The  other significant  fuels  issue  affecting estimated  average in-use
emission  levels  concerns  the reformulated  gasoline (RFG)  requirements.
Under  the 1990  Clean  Air Act Amendments, the nine worst ozone areas of  the
country  are required to  have  RFG  during  the summer  ozone  season, and  many
other areas  of the  country have "opted  in"  to this program.   The  estimates  of
the impact of RFG  on  emissions  included in  MOBILE were first  based on the
"simple  model"  developed as  part of  the RFG rule making, and  later  updated in
MOBILES to  reflect  the  results of analyses  based on  use of the  "complex model,"
which  accounts  for more fuel  parameters.   EPA plans  to include  the complex
model  or its results, in some  form, in  a  future update  to  the MOBILE  model.   This
would  increase  the accuracy  of  the estimates and make the  emission factors
produced by  MOBILE  better reflect the conclusions  drawn  from the "complex
model,"  particularly  for  the  second  phase  of the  RFG  requirements.


ISSUE:     Accuracy  of vehicle   miles   traveled  (VMT)   estimates  and
traffic   modeling;   potential   use  of   operating   hours   rather   than
VMT  as  the  activity  level  for  highway  mobile  sources.

       While  not related  to  emission  factor  modeling per se,  this  issue  is
important  to  the development of  accurate   highway  mobile  source  emission


                                                                             May 19

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                                         -38-


inventories.   The  accuracy of  VMT  estimates  has a  directly  proportional  effect
on  the accuracy  of mobile  source  emission  inventories  (i.e.,  a  20  percent
underestimate  of  VMT results  in  emissions  being  underestimated  by  20
percent).    Interest  has been  expressed  in  the  idea of  using  vehicle  operating
hours, rather than  VMT,   as  the  activity level  for  highway  mobile  sources  on
the  grounds  that  operating  hours  might be  more  readily  and  objectively
measured.

Action    toward   resolution:

       The development of accurate  VMT  estimates  is a local/State
responsibility.   EPA  is working with  the  U.  S.  Department of  Transportation
(DOT) and other parties  to  develop and demonstrate better  methods  for
estimating  VMT and  modeling traffic  flow.    EPA  is requiring  that  States tie
their  estimates  of  VMT to actual observations of traffic  volumes in a more
comprehensive  way  than  has been  required  in  the  past,  which is  intended  to
improve  the accuracy  of  these estimates.   The  use  of traffic counts,  such as in
the  Highway  Performance Monitoring  System (HPMS),  as  part  of this  process
is an  important component of efforts  to improve  the  accuracy of  this aspect  of
the   inventory  process.

       Researchers  at  Georgia  Technological  University (Ga  Tech),  working
with  EPA's Office  of  Research  and  Development (ORD), have examined  estimates
for  total VMT  in  the metropolitan  Atlanta  region using  a  variety  of
approaches.   The methods included  estimates  from  the Georgia DOT  and from
HPMS, estimates  derived  from  estimated fuel  efficiency  data and  from  fuel tax
revenues,   and estimates developed from odometer data collected as  part  of the
Atlanta area's  inspection   and  maintenance  (I/M)  program.    When  minor
adjustments to  account for known  or  suspected biases  are  included  in  these
estimates  (e.g.,  the  DOT  estimate may  be higher than other methods since it
includes  "external"   or through  trips,  fuel consumption-based  estimates  may  be
high  since  some fuel  allocated  to Atlanta  is  shipped  to  rural  areas; fuel  tax
revenue-based  estimates may  be  low due to  some  use  of agricultural  and
construction  fuels   for  personal  transportation),  the  results  show  that  all
estimates  were  in  reasonable  agreement.   This implies  that  VMT  estimates may
be  more  accurate,  and more  consistent  across  methodologies,  than  is  generally
considered   to be  the case..   However,  additional work is  required  to  confirm
these   conclusions  and  their  applicability  to  other  areas.

       EPA's  ORD  is  also investigating the  potential  for  using  vehicle  operating
hours  as the  activity level for  highway  mobile sources,  as a  substitute for VMT.
This  is considered  a long-range  research effort, as EPA does not  believe  that
States or  others  are in  any  better  position  to  accurately  measure  operating
hours  than  to  estimate VMT  at this  time.   The  suggestion has been made that
emission factors based on seconds  of  operation  would be  less  sensitive  to
average speed  and  driving cycle;  if  proven  true, this  would  reduce the
importance  of uncertainties in these  areas.   The  Office  of Mobile  Sources is
skeptical that this  will prove to be  the  case,  but  will continue  to  examine new
information  as  it  becomes  available.

       EPA is  also  involved  in  other  efforts  to improve emission  factors  and
VMT  estimates that do not  fit neatly  into the problem/action format  of the
preceding  paragraphs.   QMS is participating  in  the  HPMS  Steering Committee,
which is   working  to  better  coordinate and  integrate the  work,  including
                                                                              May 1995

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                                         -39-
development of  models  and  guidance,  of the emissions/air  quality  and
transportation communities.    Part  of  this  effort  is aimed  at improving  the
accuracy  and consistency  of VMT estimates developed  for  different  purposes.
EPA  is  also working  to improve  and  enhance our  cooperation  and coordination
with  efforts being  undertaken by  the  California  Air  Resources  Board  to
improve  emission  factor  and activity  level  estimates  for'use  in developing
accurate  emission  inventories.

       The  list  above,  while  not exhaustive,  indicates  some  of the most
important efforts  underway  and planned  to  improve  the  estimates  produced  by
the emission factor model.
6.    Plans   for   MOBILE6  and   Other   Ongoing  Studies

       Many  of  the  issues  that have been  discussed in  this paper  will require
considerable   resources  (time,  money,  testing  capability)  to  be  thoroughly
addressed.   It  is the nature of this type  of  work that some  issues will  never be
resolved in  a final  manner,  no  matter  how much  information  becomes
available, and no  matter  how many resources are  devoted to addressing  the
issue  by EPA or others, the  situation will change  over time,  and so an answer
deemed  "final"  one  day will be  rendered incomplete,  or  even  incorrect,  by
future  developments.   With  this  in  mind,  this final section  of  the  paper
addresses some of  the  studies, outreach  initiatives,  and other activities  that  are
aimed  at helping  better  estimate  real-world in-use emissions  from  highway
vehicles.

       As noted  in the  last  "Issue/Actions"  segment above, the MOBILE model
and  the  best estimate  of in-use  emission factors  is only one  aspect  (although
arguably the  most  important  single  aspect)  of  the overall  process  of
quantifying   total  in-use emissions  from  highway   vehicles.   Beyond
continuing  to collect  emissions  test  data  and revise the  model  to  reflect  the
latest and  most  complete  information available,  EPA wants to make the model
more  responsive  to the needs  of  its users,  particularly  those  at  the  State  and
local/regional  government   levels  with  responsibilities  for  air  quality  under
the Clean Air Act.   This is discussed  in the following  paragraphs.   This section
concludes with a  brief  overview  of some of the  other  (outside of OMS) efforts
underway to  improve  the   accuracy  of  highway  vehicle  emission  factors   and
inventories.

       Increasing  Participation  in  the  Model  Development Process

       One  of the criticisms that  EPA has  received  concerning the  MOBILE model
concerns the processes  by  which  in-use emissions  data  are  collected  and analyzed
and  decisions made  as  to  the best  means  of modeling  in-use emission  factors on
the basis of  such  data,   Although EPA  has always held public  workshops  during
the development stage  of  each major  new  revision  to  the  model (for example,
during the development of MOBILES  public  workshops  were conducted on March  5
and  July  8.   1992), these  workshops have  in fact  been  attended primarily   by
representatives  of the  automotive  and,  in  recent  years,  petroleum  industries.
Relatively few representatives of EPA  Regional  Offices or of State  or local air
quality  agency  officials have  attended  these workshops.    Further,  though  EPA has
held  these  workshops  in  order  to  present  preliminary findings,  proposed  model
                                                                              May 1995

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                                         -40-


 revisions,  and  related  information,  the  Agency  has  been  criticized  for not  taking
 sufficient  time to  educate  audiences, and  for not  adequately  considering  the input
 of  parties outside the  Agency  in  making  its  final  decisions  about revisions  to  the
 MOBILE  model.

       In  response  to these criticisms and  to  the perception  that  the process of
 developing  and  revising the  model  is  "closed,"  two  changes  are  being
 implemented  in  the  model  development  process.   The  first  of these  actually  has
 been  started  already, while  the  second  will be applicable  to  the  development and
 release  of the next  major  revision  to  the  model  (MOBILE6,  which is specifically
 discussed  below).   These  changes  are  (1)  to  conduct  "user workshops" during the
 development of  new  models and  (2) to  submit the model and  its underlying
 analyses  to  a more  focused outside review  process.

       (1) Emissions modeling  workshops.

       On June 28-29,  1994, the Office of Mobile Sources  hosted the  first Mobile
 Source  Emissions Modeling  Workshop.   This  workshop was  specifically aimed at
 the users  of the MOBILE model at the regional. State,  and  local level.   The technical
 workshops mentioned above,  which  tended  to   be aimed  more  at  the regulated
 industries  as  the  audience,  mostly  focused  on  OMS  presentations  of  new
 information,  data,  and  preliminary  analyses  and  results to the  audience.   This
 workshop, by  contrast,  was intended  for those  parties that are required to  develop
 analyses,  such as State  Implementation Plans  (SIPs),  that  use MOBILE emission
 factors.    Rather  than  having OMS  present  information, the  invitees  were  asked  to
 make  presentations  on  topics such  as their  experiences  in  the  use of  the  model,
 the guidance  for mobile source  emission  inventory  development  provided by EPA
 and  its  utility, and  their perceptions  of  EPA's  strengths and weaknesses  in
developing the model  and  related guidance  and  providing  of support to States  and
 local  or  regional  air  quality  planners.

      The  workshop spanned two days.   On  the first  day, there  were  four panel
discussions:


      •       Problems  Modeling  SIP  Strategies  for  Mobile Sources

      •       Experiences with  Transportation  Plans  and  TIPs
      •       Emission  Effects  Not  Included  in  the Current  MOBILE  Model

              States'  Needs  and Requirements:  Planning  a New  MOBILE Model

      Each  panel  discussion  included  three  or four  presentations  from  workshop
attendees,  and provided some  opportunity  for  questions and  discussion.  On  the
 second  day,   "break-out" sessions  corresponding  to each  of  the  panel  discussions
 were  conducted.   In these  break-out  sessions, participants were  asked to
 brainstorm and develop lists of  the most  significant  items  requiring  EPA  attention
 under each topic.    The workshop  then  concluded with a general session  at  which
 the results from each break-out session,  in  the form  of a  list of the  items most
 urgently  requiring   attention,  was  presented.

      The  workshop provided  OMS with insights  into the processes  required of
 and the  problems faced by   those  officials at  the State and  local  levels attempting to
accurately quantify  mobile  source  emissions  and  their  relative  contribution to  air
quality  problems,  particularly  nonattainment  status  for  the  National   Ambient  Air


                                                                               May 1995

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                                         -41-


Quality  Standards  (NAAQS) for criteria  pollutants.   While  many of the  problems
identified and discussed  were  known to  QMS,  others  were not,  and  this workshop
was extremely helpful  to QMS in its efforts  to  identify the areas  of greatest need
from  the perspective of  the users of the  model.   This  will  assist QMS in focusing
attention and  resources  in  the  right  areas.

       The  feedback  received  from workshop  attendees  was  generally   very
positive,  and  the desire  to maintain the  ability  to  present  issues  and  problems  to
QMS for consideration  in  its  future work was  strong.   Thus,  although  many
problems identified in the  June  1994  workshop  sessions  have  yet to  be addressed,
or  at  least will  require significant  resources  (both  time and  financial)   to  address
thoroughly, QMS  is  committed  to  periodically   conducting such  user-oriented
workshops in  the future.   At  least one  more workshop of  this nature  will  be held
before the next major revision to the model (MOBILE6, see below).  State and local
air quality agencies  and  metropolitan   planning  organizations  that  are   on the
MOBILES Mailing  List  will be  notified  directly  of the next user workshop.

       (2) Outside  review  of  model revisions.

       In the  past,  QMS has  conducted  two  kinds of  workshops  relating  to the
MOBILE model,  excluding the  workshop  discussed  immediately  above.
Developmental,  or  pre-release, workshops were   held  in  order  to  present
preliminary results  of analyses  and to  provide  information on  the  types  of
revisions  planned for  the  model.   As  noted  above,  the audiences  at  these
workshops tended  to  be composed  more  of  automotive and  petroleum  company
technical  staff dealing  with  emissions  modeling  and  air  quality  issues, with
relatively little   representation  of  many  model  users  (States,  local  and  regional
governments,  EPA  Regional  Office  staff)-   Although these  workshops   generally
led to  the  submission of  comments, additional data,  and  other  suggestions  from
those attending,  OMS  has   been  criticized in  the past  for  not thoroughly
considering  all  of  the  information  submitted  in  making the  final decisions on
how to  revise the MOBILE model.

       What OMS  has  termed  "user workshops"  have  been conducted after the
release  of most  of  the  major  revisions to  the  model.   These  workshops  are  aimed
almost  entirely  at  the air   quality staff  of State,  regional,  and  local  governments
and  EPA Regional  Office  staff,  and are  focused  on explaining the changes  to the
model since the  last  revision and the  presentation  and discussion of guidance  on
how best to  use  the  model for various  applications.   While  these  workshops  have
proved  useful  to  the  modeling community, they   do  not provide  a  forum for
reviewing how  the model was  revised  or for suggestion of alternatives.   Thus,
neither   the developmental  or  user  workshops have  been perceived  as providing
sufficient opportunity  for  parties  outside  of  OMS to  influence the choices  made  in
revising  the  model.

       Due  to  the  size,  complexity,  and  long  history of the MOBILE model,  a full
formal  peer review  of the  entire  model  does  not  appear to be the best  or  most
efficient  means  of  obtaining  the outside  review  and  input needed.    However,  the
need  for some review and input  is  apparent  to  parties both inside and  outside  EPA.
Thus, beginning  now,  in the earliest stages of work  on MOBILE6, OMS  has decided
on  an  approach  to providing  significantly  more opportunities  for  more  parties  to
have  the chance  to comment  on  components  of  the  model and  to  provide relevant
information at a much  earlier stage of  the  model  development process.
                                                                              May 1995

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                                         -42-


       While further changes  and  additions to  this  approach  are  still  possible, the
basic outline can  be stated.   In  addition  to  basic  emission rate equations  developed
for  each  pollutant  and each  vehicle  type, for different  model  years  or model  year
groupings  and  for  different  technologies (e.g.,  non-catalyst,  oxidation  catalyst,
three-way   catalyst,  three-way+oxidation  catalysts;  carburetor,  throttle-body  fuel
injection,  multi-point  fuel  injection),  MOBILES  contains  algorithms  for  modeling
the  effects  of many parameters on  emissions.   Thus,  the model is  some  ways can  be
viewed  as a  large  set of interrelated components.   QMS will  be actively seeking
review  and  comment on  analyses  that may be  used  in considering  revisions to
these  many  components.

       This  may  be best  illustrated by  an  example.   One  of  the many variables
affecting  exhaust  emissions  is  the  ambient   temperature  in   which  vehicles  are
operating.   Carbon  monoxide  (CO) emissions,  for example,  are much greater on a
grams  per  mile  (g/mi)  basis  at cold  winter temperatures  (e.g., 25°F)  than  at
warmer summer temperatures  (e.g.,  80°F).  MOBILE calculates  exhaust emission
factors  initially  assuming  the  nominal FTP test temperature  of 75°F,  then corrects
these estimates  to  the temperature  specified by  the modeler  on  the  basis  of
temperature  correction factors (TCFs).   Like  the  basic  emission  rates,  there are
distinct  TCFs for  each  vehicle type,  pollutant, model  year or  model year group, and
for  different  technologies.    The  form  of the  current  correction  factor equations
includes  the effects of fuel volatility (as-  measured  by  RVP)  and  the  interaction  of
temperature  and RVP, for  temperatures of 75°F and  higher.   The equations
generally  are  in the form of  exponential functions (e.g., TCP  = exp[a  * (temp-75)  +
b  *  (RVP-9)  + c * (temp-75)  * (RVP-9)],  where a, b, c  are coefficients  specific  to a
combination  of  vehicle   type/pollutant/model  years/technology),   and  the
resulting TCP is  applied  as  multiplicative correction  to  the  estimated emissions at
75°F and  9.0  psi RVP fuel.

       Recently, an EPA contractor  completed  an analysis of the correction  factors
for  the  effects  of  temperature  and  fuel volatility  (RVP)  on  emissions  from light-
duty gas  vehicles and  trucks.   Using all of the  available test  data  on emissions at
different  temperatures and/or fuel volatilities,  including  new  data  that were  not
yet  available the  last time these  temperature  correction  factors (TCFs) were
revised  (MOBILE4.1, 1991), the contractor was  asked to examine the suitability  of
the  current  algorithm as  well  as  alternatives  (e.g..  different  equational  forms,
additive  vs.  multiplicative  corrections)  and to  present  statistical  summaries of the
ability of  each  alternative  analyzed  to best  predict  the effects  of temperature  and
RVP on exhaust  emissions.

       Since the  results of  this  report  might  well  find their way into MOBILE6 in
some form  as part  of updating the  model,  this could be termed the temperature
correction  "component"  of the model  as described above.   QMS will  shortly  be
sending copies  of this contractor  report to a  group of 10 to  20 individuals  or
organizations  thought to  be in a  position to  critically  review and comment on the
report, its  methodology, and its  results.  QMS will  establish  a  central file,
analogous  to the  dockets  established in  support  of  rulemaking  activities,   to
maintain all of  the review comments  received.   These  comments  then  will be
available  for consideration  and  further  analysis  when  attention  is  turned to
modeling  the effects of temperatures  on  emissions in MOBILE6.

       Over time,  this  informal docket-style file should grow  to the  point  that it
can  serve  as  a central  repository of  model  documentation   and related information.
OMS will  include  in this file  other  documents  and data relating  to  estimating  of  in-
                                                                               May 1995

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                                         -43-
use  emission  levels, developed  by parties  outside the Agency.   This  would  include
the  reports  developed  by  Sierra  Research  and  Systems  Applications  International
for  the  American  Petroleum  Institute,  reports and  data generated  by the  Auto/Oil
Air  Quality  Improvement  Research  Program  on  real-world  emissions  behavior,
reports  and  data generated  by  the  North  American  Research  Strategy  for
Tropospheric Ozone (NARSTO)  group and  by the Southern Oxidants Study  (SOS),
and  other  similar  information.

       Such  a central  repository of information and  data  would be  a big step
toward  addressing  concerns  that  have  been expressed  by both  those who  argue
that  the revision  development  process  in  the past  has ..been  too "closed,"  and those
who feel  that  the  lack of overall  documentation  for  the  model  serves as  a
hindrance  to  thorough understanding  and  correct use  and  application  of  the
model's results.   As  noted,  this process  is  not  finalized, and could  be expanded to
include more  and  wider  reviews  than would be indicated by  this  outline.

       As  now  envisioned,  this  process  would not provide the  opportunity  for
every  component of the  model to be  subject to outside  review before the next
release  of  a major model  update.   This  is due, in part, to  the  fact that none of the
revisions to the model,  going  back to the  replacement of MOBILE 1  by MOBILE2 in
1980,  have included revisions  to every component of  the  model.   Sufficient new
data is not generally  available to support  revisiting  every  aspect  of the model
every  time  that  it is  being  updated,  and  there are often cases in  which enough
new  data exists  to  virtually demand that  some component of the model be  revisited
even though little  or  no  additional data  exists to  support revisions to  many other
parts  of the model.    However, with  targeted reviews of  each component (or, each
study or  analysis  affecting a  component) being done as  such components  or
analyses are  prepared, and with  the  significantly  greater involvement  of outside
reviewers  at early  stages  of the model revisions process,  OMS should be  provided
with much  more  useful information from outside  the Agency  in  time  for  such
information to  be  carefully considered  before decisions  on  final  approaches to
specific issues must be made.

       Another  source  of outside-EPA input to the  model development  process is
the information  gathered  at the "Emissions  Modeling Workshop" held  in  June  1994
(preceding  section)  and other  similar workshops  planned in  the  future.   While
OMS has  yet  to  thoroughly absorb all  of the information provided by  attendees at
the June  1994 workshop,  the information  is  still in  hand and  will  be used  in pan
to determine  where our  resources (for  in-house  and  contracted  emission  factor
testing  programs  and  for data  analyses)  should  be  directed  for  the  maximum
benefits.

       On  a broader scale,  OMS  is in  the  process of developing  a standing  technical
review  panel  of  some  type,  the  focus  of  which  will  be  to  provide  outside  review
and  input on  OMS  technical projects.   This  would  include the MOBILE  model  and
revisions and updates  to  the  model.   A  plan for involving this  technical  review
panel in the development  of MOBILE6  is  being  prepared.   OMS  also continues with
efforts   to  more  closely coordinate with  the  California Air  Resources Board (CARB)
on  emission  factor testing  and  modeling  issues.
                                                                              Uay

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                                         -44-
       MOBILE6  Plans

       Exactly what changes  will  be incorporated  into  MOBILE6, the next  major
revision  to EPA's  highway  vehicle  emission  factor 'model, will  be  determined  in
part by  when  the model  is  released, and  by other events that cannot now  be
foreseen.   However, some things can be  said  about MOBILE6 with reasonable
certainty.   In  addition  to the items  that have  been discussed  in  the  preceding
section,  QMS  believes  that these revisions  and updates are likely to be included in
MOBILE6.

•      General update  of some  underlying data:  In  every  major iteration  of  the
development  of the  model (MOBILE1, MOBILE2, and so on),  EPA updates the basic
emission rate  equations  on  the  basis  of additional emission  factor  testing  that has
been  performed  since  the previous  update.   In particular, as  has  always been the
case,  the modeled behavior of emissions  of vehicles of a specific  model year  and
technology  type   as the  vehicle  reaches  advanced age/  accumulated  mileage  levels
will need  to  be  updated  as  data from those specific vehicles, at  advanced
ages/mileages,  become  available.   Thus, while  emission  rate  equations  for pre-
1980  vehicles  are  unlikely  to  change  significantly  in  the future,  those for later
model  vehicles will likely require  revision as  directly applicable data  become
available and  are  used  in place  of extrapolations  based on  results  from older
vehicles.    Furthermore,  potential  problems with continuing  to   base  development
of  basic  emission  rate  equations  on  IM240  data  in the  future, as  was  done  for
MOBILE5a,  will   need  to  be addressed.   These  potential complications, as described
in  the discussion  of "Recruitment Bias  in  Emission  Factor Testing" (page 27),  may
require  EPA  to   find other  means  of  enhancing  the  representativeness of  the
vehicles  tested in  the  emission  factor  testing  program.

•      Effects  of  temperature  and  fuel  volatility  on  exhaust  emissions:
Substantially more  data  on  the  effects  of  "high"  temperatures (over 75°F)  and  of
fuel volatility  (as  measured  by   RVP)  have become  available  since  the correction
factors currently   used  were  developed.   These  data are the  subject of  an  analysis
performed  under  contract  to  EPA  in 1994,  which  was  discussed  in  the  section  on
"outside  review of  model development"  above.   On the basis  of the results  of  that
analysis  and  the  input  EPA  obtains from  outside  review  of  the  contractor's  final
report,  revisions  to the  "high  temperature and  fuel  volatility"  exhaust  emission
factor  corrections   will  be included in MOBILE6.

•      Evaporative  emissions  under  "real  world" conditions:   The evaporative
emission  factors  for  diurnal (daily temperature  rise  while  vehicles  are  not  being
driven)  and  hot soak (trip end)  emissions  will  be updated on the basis  of new test
data  obtained  from conditions  more closely   approximating  real-world  conditions.
In  the case  of diurnal  emissions estimates, EPA  has  collected  data  from "real  time"
diurnal  testing (i.e.,  measurement  of evaporative emissions  over  the  6-12  hour
periods  of  increasing  ambient   temperatures  during  which   such emissions
actually  occur, rather  than  from  a  1-hour test  in  which the temperature  rise
characteristic  of  an  entire day  is forced to occur within  one  hour).   Diurnal
emissions  under  real-time  temperature  rises  have been  measured over  a  range  of
diurnal  temperature  rises and using  fuels  of  different volatilities.   As  has been
described,  MOBILES  includes an  adjustment  to diurnal emission  estimates  to
account  for  the  differences  in  8-hour real-time temperature rises  and  I-hour
forced-heating  simulations of such events,  on  the basis  of the  data  available  at
                                                                               May 1995

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                                                                                                1
                                         -45-


that time.   The results of  additional  tests will be  used to further  improve the
diurnal emission  estimates  produced  by MOBILE6.

       In  the  case  of hot  soak emissions, data have been  collected reflecting
variation  in two  other parameters  affecting  the  levels  of  such  emissions in  the
real  world:    characteristics  (including   length/duration)  of  the  trip(s)  preceding
the  hot  soak,   and  the duration over  which  emissions  are  measured.   Historically,
the  test  procedure  for measuring hot  soak emissions  involved an  FTP  test
preceding  the   hot  soak  and  emissions being  measured  for one  hour after the
engine is  turned  off.   Obviously, not  all  trips  resemble the FTP in terms  of  length,
speeds, duration,  and  so  on; perhaps  less obviously, such  emissions do  not  simply
cease  after one hour.   By  collecting  hot  soak data after  different  types  of
"immediately  preceding"  trips  (e.g.,  longer  durations,  significantly higher   or
lower  speeds), and  collecting  emissions   for  analysis  until they  emission
generation  has  effectively  stopped,  EPA is obtaining data that will be used  to
revise  the  hot  soak  emission estimates produced  by MOBILE6.

•      Inspection  and maintenance  (I/M) program modeling:   EPA has  been
working  for some time  at  improving  the  ability  of  the  model  to  calculate emission
reduction  credits  associated  with   I/M program  options  other than the   "standard"
set of options  (test only  vs.  test-and-repair,  annual vs.  biennial,  and  test type).
The recent release  of the  MOB5a_H  "hybrid  I/M  program  credits" version of
MOBILESa is  a first  step  toward providing the States the ability to assess the  likely
impacts  of various  "hybrid"  program  options.   Work  in  this area 
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                                         -46-


 vehicle age  implicitly defines  average miles per  trip as  well.   The  need  for  better
 temporal  and  spatial resolution  of motor  vehicle  emissions,  as required for in  the
 Urban  Airshed Model  for  example, has  increased  the  demand  for  emission  factors
 to  be expressed in  terms  that  can be  associated with  specific activity levels  beyond
 VMT:  diurnals in grams  per vehicle  per event,  hot soaks in grams per trip end,
 refueling  emissions  in  grams  per  gallon  of fuel dispensed, and  so  forth.

       The  recent  activity  in  the  areas of  non-FTP driving  behavior studies,
 instrumented  vehicle  data  collection  efforts,  and  other  related areas  are
 providing  substantial  new  data  on the characteristics  of  the  "average  trip."    These
 are  the  first  recent   major  efforts  to  obtain  data  on  travel/trip characteristics.    It
 is too  soon to determine  exactly  how  this  information  will  be incorporated  into  the
 model or  what effect such  updated trip characteristics  data are likely  to  have  on
 the  emission  factors   produced  by  the  model.   However,  enough is  known at this
 point  to  indicate  that  changes  in  the  modeling  of average  trip  characteristics  may
 be  warranted,  and  EPA  plans  to develop  ways to  reflect  this  new  information   in
 the  model.

 •      Fuels:   The  impact of fuels on vehicle emissions is dependent on many  fuel
 parameters,  and the  model  does not yet reflect the  full complexity  of  the  issue.
 The  earliest versions of MOBILE  assumed  that in-use fuels,  everywhere,  were  the
 same as "Indolene" (the specially  formulated, 9.0 psi RVP  test fuel  used in
 laboratory  tests).   In MOBILES,  this assumption  was  updated to reflect the increase
 in  average  in-use  fuel  volatility,  for  evaporative  emissions  only  (exhaust
emission factors were based on  9  psi RVP  and evaporative emission  factors on
 11.5 psi RVP).  In MOBILE4,  RVP was  added to the list of user-defined parameters
for  estimating  emissions,  and  both exhaust  and  evaporative  emissions were
modeled as a  function  of  user-specified  RVP  in the range 9.0-11.5  psi.

       MOBILE4.1  included  extension  of  the  range of RVP for which exhaust
emissions  could be modeled, down to  7.0  psi  RVP, for scenarios  where the  ambient
temperature exceeded  75°F.  The  ability to  model  the  impacts of  oxygenated fuels
(ether blends  and  alcohol  blends)  was introduced  in  1988  as a  post-processing
algorithm;  this was later included in the  MOBILE model,  and revised in  MOBILES to
extend  the  effects  from carbon monoxide emissions (which  are  most  impacted  by
oxygenate  content) to hydrocarbon  and oxides  of  nitrogen emissions.   In MOBILES,
a  correction  to  account for  differences  in  laboratory  test  fuel and  commercially
available  fuels, in terms of fuel  composition  parameters  other  than RVP (such as
sulfur content)  was  added.   Each of these changes represents an  incremental  step
toward  better  handling  of  the  impacts of fuel  composition on in-use emissions.

       The  increasing regulation  of in-use fuels  (Phase  I and  Phase II volatility
 limits  during  the  summer  ozone season,  Phase  I  and  Phase  II reformulated
 gasoline  requirements,   and mandated  oxygenated  fuel   programs), and  increasing
 understanding  of  the effects  of fuel parameters  on in-use  emissions, point  to  the
 need for  additional model  revisions  in  this  area.   EPA is considering  the  addition
 of  more fuel  parameters  to the list  of  parameters  affecting  emissions that  can  be
 specified by the model  user.   EPA is  also considering  development  of a means  of
 incorporating  the  so-called  "complex  model"  used in  the  reformulated gasoline
 rulemaking  analyses,   or  at  least the results  from that  model,  into  the MOBILE
 model.  Collection  and  analysis  of data on the impacts of  fuels on  emissions will
continue,  and  MOBILE6 will include updates  and revisions  based  on that work.
                                                                              May 1995

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                                         -47-


       An issue somewhat  related to the  impacts  of fuels  is  the  increasing  need for
speciation data for  HC  emissions.    While  incorporation of speciation profiles  into
the MOBILE  model  is not  likely, QMS is  aware of the  need to  further refine the
speciation profiles   for  exhaust  and evaporative  emissions,   for  highway  vehicles
and  for  non-road  mobile  sources.    The  introduction  of  reformulated gasoline
(RFG)  in  many areas also  highlights the  need  for  more  and  better  emission
speciation  data.   QMS  plans for  work  in  this  area over the next  few years include:
Updating  of  the  exhaust,  evaporative,  and  running  loss  emission  profiles for
light-duty  vehicles   operated on  industry  average  gasoline and  on  oxygenated
gasoline  blends;  development  of speciation  profiles  for  non-road  mobile  sources
(such  as  agricultural and  construction  equipment);  development  of speciation
profiles  for  alternative  fuels;  updating  of  the  profiles for light-duty diesel
vehicles;  and  development  of  profiles  for  heavy-duty diesel  vehicles.

•      Non-FTP  driving:   In  the  "Issues/Actions"  section  of  this paper, the fact
that  the  FTP clearly does not  represent all  driving and in  fact  fails to account  at
all  for certain driving  behaviors (e.g., high  acceleration  rates)  that  have a  major
impact  on emission  levels,  was  discussed.    That work,  and a final  rulemaking  to
revise  the FTP, may  not be complete before the next  revision  of the MOBILE  model
is  developed.   However, that does  not imply  that  the information  already available
will  not be included  in  the  next  model update.   The  effects on  emissions of some of
the "off-cycle"  driving  behaviors  is  too great  to be  ignored, or to  wait  for  the final
estimates;  EPA plans  to include  some  means  of  accounting  for non-FTP  driving
behaviors in  MOBILE6.   This will  be one of  the  areas in  which more outside  input
during the  model  development  process  will be crucial to  providing  the  best
feasible   interim  approach   for  modeling.

•      Trip-Based  Emission  Estimates:    This  would involve  providing, as  an option
for users of the  MOBILE  model, the separation of trip-start  emissions  (for both
cold-   and hot-starts)  from  running  emissions.   Trip-start emission  factors  would
be  estimated  in  units  of grams per vehicle  per  starting  event  (g/veh-start)  for
cold-  and  hot-starts  separately.    Such  emissions would then  be excluded  from  the
exhaust  emission  factors in  g/mi produced  by  MOBILE,  which would represent
only stabilized  operation.   This  would enable  modelers using  tools  such  as Urban
Airshed,  which  require  that emissions  be  finely resolved  both  spatially  and
temporally, to  assign all  start-related  emission  increments to  the  locations  and
times  of  vehicle  starts  (as  if  all of the  start-related  increase in emissions  occurred
instantaneously  at  the location  and  moment  of vehicle start), and  to exclude  such
emission  effects  from  the   emissions  modeled   for traffic  links  and  intersections.

       The data required  to estimate trip-start  emissions  in  this  way are implicitly
included  in  the basic emission rate equations,  but  an algorithm to  perform the
required  calculations  has not been  programmed  for use in  the model.   EPA is
considering the inclusion of such an option  in  MOBILE6.   If such  an  option  were
exercised,  the  operating mode  fraction inputs  to  the  model  would  not  be relevant
to  the resulting  emission factors, in  that all starts could be  accounted for by  use of
the cold-  and  hot-start  g/veh-start  emission  factors,  and  all  "running"  emissions
would  be  assumed  to be in  stabilized  operating mode.

       In-use  emissions from  heavy-duty  vehicles:    Emissions from heavy-duty
engines  (HDEs)  are regulated on  the basis  of  mass  pollutant  per unit work
performed,  rather  than  per  mile traveled,  due  to  the  wide   variety of  applications
in  which  such  engines  are  used.   In order to  estimate emissions  in grams  per mile
from  heavy-duty  vehicles  (HDVs, defined  as  vehicles  over 8500  Ib Gross  Vehicle


                                                         """""""""              May

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                                         -48-
 Weight. and  equipped with HDEs),  MOBILES and  earlier  versions of the model  use
  conversion  factors   to  convert  gram  per  brake  horsepower-hour  (g/bho-hr)
 emissions  to grams per  mile.   These  conversion  factors  take into  account average
 fuel  economy,  m-use  loads,  and other variables  affecting how  much  work is
 necessary  to move the  vehicles  per  mile.   This  necessarily  involves making  a
 number of assumptions  about  the use patterns of  such  vehicles  as  well as the
 weighting  together of  information  applicable  to  different  subcategories of  HDVs
 on the  basis of  their relative  populations and  use profiles.    Furthermore  the
 expense and complexity  of. testing  heavy-duty  vehicles  on  chassis  dynamometers
 relative to  testing heavy-duty  engines on  engine dynamometers,  and  the  inabilitv
 tor  various  reasons to  conduct  an  in-use  emission  factor  testing program  for  HDVs
 analogous  to that  used  for  light-duty vehicles  and trucks,  mean that  the  emission
 estimates in  the model for HDVs are not  based on  actual  in-use  data in the way  that
 light-duty  vehicle and truck  emission factors  are  estimated.   Rather,  they are
 based  primarily  on HDE certification  data,  engineering  judgment,   and
 extrapolations.

        The two  most important  improvements that  could be  made to  emission
 factors  for HDVs  in the  MOBILE model would be (1)  collection of data from chassis
 dynamometer tests  of HDVs,  and/or from instrumented HDVs in  actual  use, and  (2)
 subdivision of  the HDV vehicle categories  (particularly diesel)  into  more  distinct
 groups.   For  example,  the  current  heavy-duty  diesel  vehicle emission  factors
 account for   transit buses, inter-city  buses,  and  freight-haulers; while
 characteristics  of  each  of these  are  reflected in  the  various conversion  factors
 and  weighting  factors  used to develop  one  set of emission  factors for  all HDDVs,
 these  emission  factors are clearly not the best estimates  of  in-use  emissions  for
 any  one of  those subcategories.  EPA anticipates  having  some chassis
 dynamometer  test  data from  in-use  HDDVs available for  analysis  before MOBILE6 is
 released (see NARSTO discussion  below).  EPA  is also considering division  of at
 least  the HDDV  vehicle  category into subcategories (e.g., urban  buses, Class VIII
 freight  haulers).   The  extent  to which  useful data  can  be obtained  on  the  various
 subclasses  of HDDVs will determine  exactly what  refinements can be  made for
 MOBILE6,  and  what may have  to wait  until  a  later revision.


 While  other  changes and improvements may  also  be included  in MOBILE6, those
 outlined above  and suggested  by  the  "Issue/Actions"  in  the preceding section  are
the most  important of  those  currently planned.


       Other  Ongoing  Studies

       NARSTO

       A  major  research  initiative  now underway,  the North American  Research
 Strategy for  Tropospheric Ozone  (NARSTO),  is  expected to  provide  significant new
 information for use in   the  improvement  of  emission  factor and  inventory
estimation  for  highway  vehicles.    Much  of the  highway  mobile source  research
 being  sponsored by NARSTO is  being  performed by  researchers  at Georgia
Tecnological  University  (Ga  Tech)  in  Atlanta under  a cooperative  agreement  with
EPA's  Office  of Research  and Development.
                                                                             May 1995

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                                         -49-


       One of the first areas that is  likely to provide data for near-term
consideration  in  the  process  of  revising the MOBILE  model is  the  plan  for  NARSTO
to  sponsor chassis testing of heavy-duty  diesel vehicles.   This will  provide data
that can  be  used in  evaluating  the  validity  of  the  conversion  factors  (g/bhp-hr  to
g/mi)  used in MOBILE  as  well as the assumptions  that have  been made regarding
the  relationship  of  certification test  emission levels to in-use emission  levels,
presumably  increasing  the  accuracy  of these emission  estimates  and  the
confidence  that  can  be  placed  in them  by policy  makers  and  air quality  analysts.
NARSTO  is also planning to sponsor work in which  HDDVs'will  be  instrumented
while  in  actual  real-world use;  as noted above, this  will be  most useful in
evaluating  and  improving the  estimates  of  in-use  emissions  from  such vehicles.

       A   number  of other  efforts are  planned or  under consideration  by  the
emissions  modeling  subgroup within  NARSTO that  could  provide  valuable  data for
improvements  in and  verification of the  highway  vehicle  emission factors  and
inventories.    These  include:

         •     Evaluation of  the population of "super  emitting"  vehicles  by region

         •     Studying  the  effects of I/M  programs  through  use  of  remote sensing
              data

         •     Evaluation of  the effects of alternative  fuels  on in-use  vehicle
              emissions through use  of  remote  sensing  data

         •     Evaluation  of  the  "real-world"   impacts  of  transportation control
              measures  on  reducing  in-use  emissions  from  highway  vehicles

         •     Investigation of  the variability   of  emission rates for  in-use  highway
              vehicles

         •     Work  on reconciliation  of  mobile  source emission  inventory
              methodologies  and results  on the  State  and  national  levels

         •     Development of  a modal emission  factor  model for highway vehicles

         •     Development of  temporally  and spatially  resolved activity  data  for
              highway  vehicles,  for  use  in conjunction  with  modal  emission   factor
              models

       While  many of these  efforts may not  be  completed  in time  for  use  in
MOBILE6,  EPA  will consider whatever  data is available  at that time,  and will
continue to  work with  NARSTO  to  ensure that  the  information  collected is useful
and  relevant  to  the  most important  uncertainties  to be addressed.

       As  has been  pointed  out elsewhere, EPA  (and  the  rest of the community)  are
far from   being  able to  say that all uncertainties  regarding in-use   emissions  from
highway vehicles have  been resolved, and  MOBILE6  will  not reflect the  "last
word"  on  these  issues.   Longer-range  work,  such  as  that  being sponsored and
evaluated   by  NARSTO,  will be critical  to continued improvement  in the estimates
of  actual  in-use  emission levels  and quantification  of  the  uncertainties in those
estimates.
                                                                              Uay

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                                         •50-
       Vnlpe  Center

       EPA  has also  been working  with  personnel at  the  Volpe  Transportation
Center in  their  efforts to develop a  modal emission  model.   Unlike the MOBILE
model,  which  could  be  termed  a  "transient"  or  "trip-based" emission  factor  model,
a  modal  model  provides  a series of emission  factors  for each  vehicle  type  and
modeling scenario.   For  example, a  modal  model  would include  distinct  emission
factors  for  vehicles  at  stabilized  operating  temperatures for  acceleration  mode  (at
various  rates of acceleration),  deceleration  model(at  various  rates of
deceleration), cruising  (steady-state  operation  at  a  range   of  speeds),  trip-start
emissions  in  grams  per  vehicle  start for both  cold-  and  hot-starts,  trip-end
emissions  in  grams per  vehicle  per  trip-end,  and  so  on.   Such  emission factors
would be  particularly useful  for cases,  such  as  Urban  Airshed  Modeling,  where
emissions  must  be  allocated  on  an  hour-by-hour  basis  and  for  each of  numerous,
relatively small  "grid  cells."   Emission  factors could  be calculated for each link  of
roadway,  with  other  non-driving emissions  allocated  spatially  on the basis  of
where they occur  (i.e.,  hot soaks  at employer  parking lots  in the morning,
refueling  emissions at  service  stations,  and  so  forth).

       Considerable resources  would  need to  be  expended  on  data collection and
vehicle  testing  in order  for such a  model to  be  developed  correctly  for  use  in the
development  of emission   inventories for State  Implementation  Plans  and  other
regulatory  applications.   This is a  longer-range  effort  that, while  not  likely  to
provide  sufficient  information  to influence  the  development  of  MOBILE6,may
provide  useful   information  for  future   modeling  improvement  efforts.
       Los Alamos

       Researchers  at  the Los Alamos  National  Laboratory are  investigating  the
potential  for  development  of a model that would encompass all major  aspects of
estimating highway  vehicle  emissions  and  their environmental impact.   Such   a
model would  incorporate, in  a  single  integrated package,  a  transportation  model
(to  provide activity  levels on  the basis  of mode of operation),  a  modal  emission
factor model  (to provide  emission factors  for each activity level), and  air  quality
models  (to  model  the  impacts  of emissions  on  ambient air quality).  The inclusion
of exposure  models  might also be considered  at  a later stage.   This is  a long-range
research  effort.   Los  Alamos  researchers are not  planning, to actually  test  vehicles
or otherwise  collect data  that  are necessary  for  such a  project;   rather,  this  effort
is  aimed at  integrating  the  various  modeling tools needed for emission  inventory
development  and air quality  analyses.   The  type of model being  planned,  and  the
enormous data  requirements  of such a  model,  would  require  the  use  of super-
computer type systems to  operate.   As  such,  these  efforts  must be considered  to be
research   efforts  at  present,   with practical  use  and application being  more   distant
                                                                               May 1995

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                                         -51-
7.   Co nc I usion

       The  preceding  discussion  is  not exhaustive, in  that  many researchers  in
other EPA  offices, other  government  agencies at  various  levels  (Federal, State,
local/regional),  the  automotive  and  petroleum  industries,  and  academia
(primarily  state  universities)  are  at  work  on  studies  and  projects that  address one
or  more  aspects  of  the  issue  of accurately  quantifying  highway  vehicle emission
estimates.   This subject  is  expected  to  continue  to be the  focus  of  considerable
work by  all of the  aforementioned parties.   As  results  from  various  studies  and
other research  become available,  EPA  will  continue  to  reexamine  the   approaches
used  in  modeling  highway  vehicle emission  estimates,  and  will  continue  to  make
revisions  supported by the  data  to improve  those estimates.   This paper  was
intended  to provide an update on  the issues raised in  the July 1992  paper, and to
facilitate  discussions   and  productive  interactions  among  the various  parties
involved  in such  work.
                                                                                May 1995

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                                      -52-
                                    Table  la
    MQBILE4.1  and MQBILESa  Basic Emission Rate  Equations for  Light-Dut
                                    Vehicles
                             Hydrocarbons   (HO
Pre-1968
1968-1969
1970-1971
1972-1974
1975-1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998+
MOBILE4
ZML
7.250
4.430
3.000
3.380
1.060
0.360
0.287
0.287
0.257
0.240
0.249
0.247
0.248
0.253
0.256
0.262
0.263
0.264
0.264
0.264
0.264
0.264
0.264
0.264
DET1
0.180
0.250
0.370
0.160
0.280
0.100
0.118
0.110
0.068
0.076
0.070
0.071
0.073
0.071
0.067
0.062
0.061
0.060
0.060
0.060
0.060
0.060
0.060
0.060
j
DET2
0.180
0.250
0.370
0.160
0.280
0.100
0.111
0.106
0.078
0.090
0.085
0.089
0.092
0.092
0.087
0.084
0.084
0.083
0.083
0.083
0.083
0.083
0.083
0.083

ZML
7.250
4.430
3.000
3.380
1.060
0.360
0.287
0.286
0.241
0.247
0.249
0.253
0.253
0.257
0.258
0.260
0.261
0.261
0.261
0.247
0.233
0.210
0.193
0.185
MOBILESa
DET1
0.180
0.250
0.370
0.160
0.280
0.205
0.101
0.105
0.089
0.073
. 0.077
0.071
0.070
0.070
0.073
0.075
0.075
0.076
0.076
0.074
0.073
0.072
0.072
0.072

DET2
0.180
0.250
0.370
0.160
0.280
0.205
0.285
0.271
0.274
0.282
0.284
0.282
0.271
0.265
0.277
0.280
0.281
0.283
0.283
0.279
0.275
0.273
0.273
0.273
Where:
      ZML = Zero-mile level, in  grams per mile (g/mi)
      DET1  = Deterioration  rate, in  (g/mi)/10,000  miles  accumulated  mileage,
      applicable  to  mileage  accumulation up  to  50,000 miles
      DET2  = Deterioration  rate, (g/mi)/10K mi, applicable to  mileage  accumulated
      in excess  of 50,000  miles
                                                                         May 1995

-------
                                      -53-
                                Table  Ib

MQBILE4.1 and MQBILE5a Basic  Emission Rate
                                                           for Light-Dutv  Gas
                                    Vehicles
                            Carbon  Monoxide   (CO)
Pre-1968
1968-1969
1970-1971
1972-1974
1975-1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992+
                    ZML
                          MOBILE4.1
                         DET1
78.270
56.340
42.170
40.940
17.720
6.090
3.071
3.107
2.842
2.574
2.629
2.576
2.644
2.704
2.652
2.669
2.669
2.665
2.250
2.550
3.130
2.350
2.460
0.730
1.757
1.634
1.039
1.200
1.065
1.081
1.097
1.043
0.971
0.875
0.857
0.844
2.250
2.550
3.130
2.350
2.460
0.730
1.683
1.584
1.153
1.352
1.211
.248
.277
.236
.148
.049
1.030
1.015
ZML
                                                       MOBILESa
DET1
                                                                        DET2
78.270
56.340
42.170
40.940
17.720'
6.090
3.069
3.105
3.255
3.184
2.920
2.740
2.704
2.490
2.424
2.203
2.166
2.147
2.250
2.550
3.130
2.350
2.460
1.958
1.663
1.727
1.549
1.193
1.331
1.240
1.242
1.289
1.343
1.423
1.439
1.448
2.250
2.550
3.130
2.350
2.460
1.958
3.609
3.318
3.345
3.604
3.547
3.554
3.403
3.286
3.423
3.407
3.419
3.434
Where:
      ZML = Zero-mile level,  in  grams per mile  (g/mi)
      DET1  =  Deterioration rate, in (g/mi)/10,000  miles  accumulated mileage,
      applicable  to  mileage  accumulation up  to  50,000  miles
      DET2  =  Deterioration rate, (g/mi)/10K mi, applicable to  mileage accumulated
      in excess  of 50,000  miles
                                                                          May 1995

-------
                                       -54-
                                    Table Ic

     MOBILE4.1  and MOBILESa  Basic Fmission Rate  Equation. far Light-Dutv  Gas
                                    Vehicles
                          Oxides  of  Nitrogen  (NOx)
Pre-1968
1968-1972
1973-1974
1975-1976
1977-1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996+
Where:
                    ZML
                          MOBILE4.1
DET1
                              MQBILESa
DFT2
ZML
3.440
4.350
2.860
2.440
1.790
1.500
0.648
0.635
0.632
0.652
0.656
0.459
0.442
0.442
0.470
0.489
0.494
0.498
0.498
0.498
0.498
0.498
0.000
0.000
0.050
0.040
0.110
0.070
0.068
0.072
0.051
0.049
0.042
0.038
0.039
0.034
0.031
0.025
0.024
0.024
0.024
0.024
0.024
0.024
0.000
0.000
0.050
0.040
0.110
0.070
0.068
0.072
0.051
0.049
0.042
0.038
0.039
0.034
0.031
0.025
0.024
0.024
0.024
0.024
0.024
0.024
3.440
4.350
2.860
2.440
1.790
1.500
0.648
0.635
0.578
0.465
0.469
0.425
0.442
0.483
0.478
0.464
0.465
0.467
0.467
0.365
0.240
0.178
0.000
0.000
0.050
0.040
0.110
0.102
0.063
0.066
0.067
0.079
0.078
0.082
0.078
0.077
0.080
0.082
0.082
0.083
0.083
0.083
0.083
0.083
0.000
0.000
0.050
0.040
0.110
0.102
0.190
0.190
0.199
0.224
0.210
0.214
0.213
0.204
0.198
0.189
0.188
0.186
0.186
0.189
0.193
0.195
      ZML = Zero-mile level,  in  grams per mile  (g/mi)
      DET1  = Deterioration rate, in (g/mi)/10,000  miles accumulated mileage,
      applicable  to  mileage  accumulation up  to  50,000  miles
      DET2  = Deterioration rate, (g/mi)/10K mi, applicable to mileage accumulated
      in excess  of  50,000 miles
                                                                         May 1995

-------
                                       -55-
                                     Table  2a

         MOBILE4.1  and MQBILESa Basic (Non-Tampered^ Emission Levels

 (Note  that  the basic emission estimates  for pre-1980 model  year vehicles were not changed:
           hence these  values are the same in both MOBILE 4.1 and MOBILESa.)


                             Hydrocarbons   (HO
                      al  SOK  miles  (s/ml)
                                    at   1QOK   miles  (a/mi}
Model  Year(s)

1980
1981
1982
1983
1984

1985
1986
1987
1988
1989

1990
1991
1992
1993
1994

1995
1996
1997
1998*
 M4.1

0.860
0.877
0.837
0.597
0.620
 MSa

1.385
0.792
0.811
0.686
0.612
 Ratio*

1.610
0.903
0.969
1.149
0.987
0.599
0.602
0.613
0.608
0.591
0.634
0.608
0.603
0.607
0.623
1.058
1.010
0.984
0.998
1.054
0.572
0.568
0.564
0.564
0.564
0.564
0.564
0.564
0.564
0.635
0.636
0.641
0.641
0.617
0.598
0.570
0.553
0.545
1.110
1.120
1.137
1.137
1.094
1.060
1.011
0.980
0.966
M4.1
                                  0.992
                                  0.988
                                  0.979
                                  0.979
                                  0.979

                                  0.979
                                  0.979
                                  0.979
                                  0.979
M5a
                                  2.035
                                  2.041
                                  2.056
                                  2.056
                                  2.012

                                  1.973
                                  1.935
                                  1.918
                                  1.910
Ratip*
1.360
1.432
1.367
0.987
1.070
2.410
2.217
2.166
2.056
2.022
1.772
1.548
1.584
2.083
1.890
1.024
1.047
1.073
1.068
1.026
2.054
2.018
1.958
1.932
2.008
2.006
1.927
1.825
1.809
1.957
                                  2.051
                                  2.066
                                  2.100
                                  2.100
                                  2.055

                                  2.015
                                  1.977
                                  1.959
                                  1.951
*   'Ratio" is the MOBILESa emission factor estimate divided by the MOBILE4.1
emission  factor  estimate.   For example,  MOBILE5a estimated  average, non-
tampered  HC emissions for MY 1980 LDGVs at  50,000  miles are  61%  greater  than the
corresponding MOBILE4.1 estimate;  at  100,000 miles,  the  MOBILESa estimate  is
77.2%  higher than  the  corresponding  MOBILE4.1  estimate.
                                                                           May 1995

-------
                                       -56-
                                     Table  2b

         MQBILE4.1  and MQBILE5a  Basic (Non-Tampered)  Emission  Levels

 (Note  that  the basic emission estimates  for pre-1980 model year vehicles  were not changed:
           hence these  values are the same in both MOBILE 4.1 and MOBILESa.)


                            Carbon   Monoxide   (CO)
                      at  50K  miles  (g/mi)
                                     at  100K  miles  (g/mil
Model  Year(s)

1980
1981
1982
1983
1984

1985
1986
1987
1988
1989

1990
1991
1992+
  M4.1

 9.740
11.856
11.277
 8.037
 8.574

 7.954
 7.981
 8.129
 7.919
 7.507

 7.044
 6.954
 6.885
  M5a

15.880
11.384
11.740
11.000
 9.149

 9.575
 8.940
 8.914
 8.935
 9.139

 9.318
 9.361
 9.387
Ratio*

1.630
0.960
1.041
1.369
1.067

1.204
1.120
1.097
1.128
1.217

1.323
1.346
1.363
  M4.1

13.390
20.271
19.197
13.802
15.334
12.289
12.104
11.960
  M5ja

25.670
29.429
28.330
27.725
27.169
14.009
14.221
14.514
14.099
13.247
27.310
26.710
25.929
25.365
26.254
26.353
26.456
26.557
Ratio*

1.917
1.452
1.476
2.009
1.772

1.949
1.878
1.786
1.799
1.982

2.144
2.186
2.220
*   "Ratio" is the MOBILESa emission  factor estimate divided by the MOBILE4.1
emission  factor  estimate.   For  example,  MOBILESa estimated  average, non-
tampered  CO emissions  for MY  1980 LDGVs at 50,000 miles are  63%  greater than the
corresponding MOBILE4.1 estimate;  at  100,000 miles, the  MOBILESa  estimate  is
91.7%  higher than  the  corresponding  MOBILE4.1   estimate.

-------
                                       -57-
                                     Table 2c

         MQBILE4.1 and  MQBILE5a  Basic  (Non-Tampered Emission Levels

 (Note that  the  basic  emission  estimates for pre-1980 model year vehicles were  not changed;
            hence these values  are the same in both MOBILE 4.1  and MOBILESa.)
                           Oxides   of   Nitroen
                      at  50K  miles  (a/mi)
                                    at   100K   miles
Model Year(s^

1980
1981
1982
1983
1984

1985
1986
1987
1988
1989

1990
1991
1993
1994
1995
1996+
 M4.1

1.850
0.988
0.995
0.887
0.897

0.866
0.649
0.637
0.612
0.625

0.614
0.614
0.618
0.618
0.618
0.618
 M5a

2.010
0.963
0.965
0.913
0.860

0.859
0.835
0.832
0.868
0.878

0.874
0.875
0.882
0.780
0.655
0.593
RatiQ*

1.086
0.975
0.970
1.029
0.959

0.992
1.287
1.306
1.418
1.405

1.423
1.425
1.427
1.262
1.060
0.960
M4.1
2.200
1.328
1.355
1.142
1.142
1.076
0.839
0.832
0.782
0.780
0.739
0.734
0.738
0.738
0.738
0.738
MSa
2.520
1.913
1.915
1.908
1.980
1.909
1.905
1.897
1.888
1.868
1.819
1.815
1.812
1.725
1.620
1.568
Ratio'
1.145
1.441
1.413
1.671
1.772
1.774
2.271
2.280
2.414
2.395
2.461
2.473
2.455
2.337
2.195
2.125
*  "Ratio"  is the MOBILESa emission factor estimate divided by  the MOBILE4.1
emission factor  estimate.   For example,  MOBILESa estimated  average, non-
tampered NOx emissions for  MY  1980 LDGVs at  50,000  miles are 8.6% greater than
the  corresponding MOBILE4.1 estimate; at  100,000 miles,  the MOBILESa  estimate  is
14.5%  higher than  the  corresponding  MOBILE4.1 estimate.

-------
                                      -58-
                                   Table 3a
Comparison of Emission Factors  as  Estimated in the  Van Nuys  Tunnel Study  (1987)
      to Emission Factors Estimated  by MQBILE4 (1989)  and  MOBILE5a (1993)
                            Hydrocarbons   (HC)
        Ambient  Average
Sample
Period
B-l
B-2
B-3
B-4
B-5
B-6
B-7
B-8
B-9
B-10
B-ll
B-12
B-13
B-14
B-15
B-16
B-17
B-18
B-19
B-20
B-22
Temp
(°F)
78
81
65
72
66
65
64
66
71
65
58
64
66
58
72
73
68
72
65
62
54
Speed
(mph)
42
42
44
43
43
45
40
43
40
44
11
40
39
15
40
36
41
39
40
41
41
Van Nuys
EF
3.79
*
1.35
2.61
2.81
2.30
3.01
2.32
2.78
2.59
3.88
3.24 .
2.39
6.12
4.68
1.28
2.59
2.29
1.58
2.21
1.62
M4
EF
1.17
1.28
1.06
1.10
1.08
1.04
1.85
1.51
1.46
1.32
6.10
1.45
1.54
4.60
1.39
1.57
1.28
1.32
1.22
1.12
1.14
Ratio
TVN/M4}
3.24

1.27
2.37
2.60
2.21
1.63
1.54
1.90
1.96
0.64
2.23
1.55
1.33
3.37
0.82
2.02
1.73
1.30
1.97
1.42
M5a
EF
1.91
1.97
1.92
1.86
1.94
1.89
2.10
1.94
2.00
1.92
7.12
2.10
2.12
5.39
1.98
2.18
1.99
2.03
2.08
2.09
2.24
Ratio
(VN/MSal
1.98

0.70
1.40
1.45
1.22
1.43
1.20
1.39
1.35
0.54
1.54
1.13
1.14
2.36
0.59
1.30
1.13
0.76
1.06
0.72
                               Mean  ratios:
1.86
1.22
   Value  deemed outlier by SwRI and  not reported.
                                                                         May 1995

-------
                                       -59-
                                     Table  3b
 Comparison of Emission  Factors as Estimated  in  the  Van Nuys  Tunnel Study (1987)
Carbon Monoxidf

Sample
Period
B-l
B-2
B-3
B-4
B-5
B-6
B-7
B-8
B-9
B-10
B-ll
B-12
B-13
B-14
B-15
B-16
B-17
B-18
B-19
B-20
B-22
Ambient
Temp
(°f)
78
81
65
72
66
65
64
66
71
65
58
64
66
58
72
73
68
72
65
62
54
Average
Speed
fmph}
42
42
44
43
43
45
40
43
40
44
11
40
39
15
40
36
41
39
40
41
41
(CO)
Van Nuys M4
EF
(a/mi)
20.38
*
23.04
18.43
21.64
19.91
21.15
21.53
18.44
17.80
37.56
28.08
19.30
44.11
24.75
*
21.17
18.27
26.20
15.95
19.15
EF
(g/mil
9.86
10.97
9.47
9.19
9.52
9.21
19.76
14.77
13.39
12.35
72.05
13.90
15.06
53.76
12.23
14.35
11.67
11.68
11.36
10.40
11.52
Ratio
(VN/M4>
2.07

2.43
2.01
2.27
2.16
1.07
1.46
1.38
1.44
0.52
2.02
1.28
0.82
2.02

1.81
1.56
2.31
1.53
1.66

M5a
EF
fg/mi )
19.64
20.65
20.83
19.24
20.85
20.57
22.53
20.85
20.53
20.83
78.12
22.53
22.38
58.33
20.25
21.85
20.97
20.66
22.23
22.72
25.23


Ratio
(VN/M^a^
1.04

1.11
0.96
1.04
0.97
0.94
1.03
0.90
0.85
0.48
1.25
0.86
0.76
1.22

1.01
0.88
1.18
0.70
0.76
                                 Mean  ratios:
1.67
0.94
*   Value  deemed  outlier  by  SwRI and not reported.
                                                                           May 199!

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                                      -60-
                                    Table 3c
 Comparison of Emission Factors  as  Estimated in the  Van Nuys  Tunnel Study (1987)
Oxides of Nitroeen

Sample
Period
B-l
B-2
B-3
B-4
B-5
B-6
B-7
B-8
B-9
B-10
B-ll
B-12
B-13
B-14
B-15
B-16
B-17
B-18
B-19
B-20
B-22
Ambient
Temp
(°F)
78
81
65
72
66
65
64
66
71
65
58
64
66
58
72
73
68
72
65
62
54
Average
Speed
(mph)
42
42
44
43
43
45
40
43
40
44
11
40
39
15
40
36
41
39
40
41
41

Van Nuys
EF
1.20
41
1.79
1.73
1.57
1.34
1.47
2.00
1.39
1.65
1.15
1.85
1.22
1.36
1.65
1.08
1.82
1.38
1.28
1.57
41

M4
EF
1.99
1.96
2.10
2.07
2.09
2.12
2.53
2.51
2.38
2.39
2.75
2.44
2.42
2.64
2.37
2.33
2.25
2.19
2.14
2.12
2.23
(NOx)

Ratio
( VN/M41
0.60

0.85
0.84
0.75
0.63
0.58
0.80
0.58
069
0.42
0.76
0.50
0.52
0.70
0.46
0.81
0.63
0.60
0.74

,woii^->q i i

M5a
EF
2.57
2.50
2.79
2.68
2.76
2.81
2.75
2.76
2.66
2.79
2.54
2.75
2.71
2.51
2.65
2.58
2.71
2.63
2.74
2.79
2.90
77-M

Ratio
( VN/M5a1
0.47

0.64
0.65
0.57
0.48
0.53
0.72
0.52
0.59
0.45
0.67
0.45
0.54
0.62
0.42
0.67
0.52
0.47
0.56

                          Means:
0.66 '
0.55
*  Value  deemed outlier by SwRI and  not reported.
                                                                          May 1995

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                                       -61-
                                    References


 1.  "Highway Vehicle  Emission  Estimates,"  U.  S.  EPA  Office of Mobile  Sources  June
    1992.

 2.  The  July  1992 paper "Highway  Vehicle Emissions  Estimates"  (Ref.  I) is available
    through  EPA's Technology  Transfer Network computer  Bulletin  Board System
    (BBS)  in  the "QMS  - Mobile  Sources"  section.  To obtain a single paper copy, send
    your request to:  White  Paper  (AQAB),  U. S. EPA Office  of Mobile Sources,
    National  Vehicle  and Fuel  Emission Laboratory, 2565 Plymouth  Road,  Ann Arbor
    MI 48105.

 3.  Ingalls, Melvin N.,  et al., "Measurement of On-Road Vehicle  Emission
    Factors in  the California  South  Coast Air  Basin, Volume I: Regulated
    Emissions,"  Final  Report, June  1989.

4.  "User's Guide to MOBILE4.1,"  U.  S. EPA Office of Mobile  Sources,  July 1991,  EPA-
    AA-TEB-91-01; 56  FR 42053, August 26,  1991.

5.  "User's Guide to MOBILES,"  U. S. EPA Office  of Mobile Sources, May  1994, EPA-AA-
    AQAB-94-01; 58 FR  7780 (February 9, 1993) and 58 FR 29409 (May 20, 1993).

6.  "Evaluation  of Ambient  Species  Profiles, Ambient  Versus Modeled NMHCNOx  and
    CO:NOx  Ratios, and Source-Receptor Analyses,"  Systems  Applications
    International, September  1994, SYSAPP94-94/081; prepared  for U. S. EPA  Office
    of Mobile  Sources (under Contract No.  68-C1-0059,  Work  Assignment No.  2-03).

7.  "On-Road Emission  Measurements  in South  Coast  Air Basin  (Tunnel Study'),"
    EPA Memorandum from  Terry Newell to Charles L. Gray, Jr.,  August 22, 1991.

8.  Pierson, William,  et  al., "Real-World Automotive Emissions -  Results of Studies  in
    the Fort  McHenry and  Tuscarora  Mountain  Tunnels,"  Draft Final Report,   DRI
    Document No. 6480.1D1,  March  1994.

9.  Enns,  Phil,  et al., "EPA's Survey  of In-Use  Driving  Patterns:   Implications  for
    Mobile Source Emission  Inventories," U. S. EPA Office of Mobile Sources,
    Certification  Division;  from  "The  Emission  Inventory:  Perception  and Reality,"
    Air & Waste  Management  Association   Special  Publication  VIP-38,  1994.

 10. Carlson,  Thomas  R., et  al.,  "Travel Trip  Characteristics  Analysis,"  Sierra
    Research,  Inc.,  September 1994;  prepared for  U.  S. EPA  Office of Mobile  Sources
    (under Contract No.  68-C1-0079, Work  Assignment No.  2-05).
                                                                           May 1995

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