EPA-AA-CTAB/TA/80-03
TECHNICAL REPORT
Technical Feasibility of the Proposed 1982-1983
High Altitude Standards for Light Duty
Vehicles and Light Duty Trucks
by
Robert I. Bruetsch
John J. McFadden
William M. Pidgeon
August, 1980
NOTICE
Technical reports do not necessarily represent final EPA decisions or
positions. They are intended to present technical analyses of issues
using data which are currently available. The purpose in the release of
such reports is to facilitate the exchange of technical information and
to inform the public of technical developments which may form the basis
for a final EPA decision, position or regulatory action.
Control Technology Assessment and Characterization Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
Office of Air, Noise and Radiation
U.S. Environmental Protection Agency
2565 Plymouth Road
Ann Arbor, Michigan 48105
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CONTENTS
I. Introduction 1
II. Conclusions ...... 4
III. Methodology 7
IV. High Altitude to Low Altitude Emissions Factors 11
V. Individual Manufacturers' Discussions
A. Gasoline-Fueled Vehicles .... 19
American Motors 19
Chrysler 25
Ford 33
General Motors 46
Honda 58
International Harvester . ......... 61
Jaguar-Rover-Triumph 65
Nissan 70
Peugot . 76
Toyota 77
Volkswagen 84
B. Diesel-Fueled Vehicles . 88.
VI. References . 96
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Technical Feasibility of the 1982-1983 High Altitude Standards
I. INTRODUCTION
Proposed high altitude standards for the 1982 and 1983 model years (MY)
*
were published on January 24, 1980 [20 at 5988-6009] . These standards
are for light duty vehicles (LDVs) and light duty trucks (LDTs). This
document presents an evaluation of the technical feasibility of the
proposed high altitude standards (herein referred to as the "standards"),
which are listed in Table 1-1.
TABLE 1-1
Proposed High Altitude Standards for
Year
1982
1983
1982
1983
*
Light Duty Vehicles and I
Vehicle Type
Light Duty Vehicles
Light Duty Vehicles
Light Duty Trucks
Light Duty Trucks
,ight Duty Ti
HC
0.57
0.57
2.0
1.0
*
rucks
CO
**
7.8
7.8
26
14
NOx
***
1.0
1.0
2.3
2.3****
A high altitude particulate standard has not been established for
the 1982-1983 model years [35 at 14501].
The high altitude CO standard for engines which have been granted a
CO waiver for the 1982 Model Year (MY) is 11 g/rai. [26]
The 1982 MY NOx standard for American Motors is 2.0 g/mi
[24 at 5990].
****
The 1983 low altitude NOx standard has not yet been determined.
This analysis was done for 2.3 g/mi NOx. [26] [24 at 5990]
* The reference notation [A at B] is used throughout this document.
This notation means that the referenced information is found in reference
A (from the references section of this document) at page(s) B.
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Several vehicle manufacturers have received CO waivers for some of their
light duty vehicles in the 1982 model year. A complete list of those
manufacturers and engines is presented in Table 1-2. Vehicles with
these engines must meet a 7.0 CO standard at low altitude [34 at 40030].
Table 1-2
Engines with CO Waivers for the 1982 Model Year
American Motors 258 CID.
Chrysler 1.7L
3.7L
5.2L-4V
General Motors 2.8L/173 CID -2V
3.8L/231 CID -2V
Jaguar-Rover-Triumph 215 CID
326 CID
Toyota 88.6 CID
The technical feasibility of the standards was evaluated for the manu-
facturers and vehicle types listed in Table 1-3.
TABLE 1-3
Manufacturers and Vehicle Types Assessed
Manufacturer Light Duty Vehicle Light Duty Truck
American Motors Yes Yes
Chrysler Yes Yes
Ford Yes Yes
General Motors Yes Yes
Honda Yes No
International Harvester No Yes
Jaguar-Rover-Triumph Yes No
Nissan Yes Yes
Peugeot Yes No
Toyota Yes Yes
Volkswagen Yes Diesel only
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The manufacturers listed in Table-1-3 include all of those who commented on
the proposed regulations.
Many of the manufacturers submitted little or no high altitude test data
for the emission control systems they plan to-use in the 1982 and 1983
model years. Due to the scarcity of high altitude test data, this
evaluation is not based on as broad a data base as EPA would prefer to
use in its technical assessments.
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II. CONCLUSIONS
It is the judgement of the EPA technical staff that the proposed high
altitude standards for the 1982-1983 model years are technically feasible.
This judgement is based on the analyses made for the manufacturers
listed in Table 1-2 and the assumption that the technical ability of
these manufacturers is representative of the automotive industry.
The primary reason for emissions problems at high altitude is the fact
that as altitude increases, the air density decreases. This causes the
air/fuel ratio of non-altitude compensated fuel metering systems to
enrich as altitude increases. Attendant with richer mixtures are increases
in HC and CO emissions. Therefore, in order to prevent or limit increases
in HC and CO emissions with increases in altitude, the air/fuel ratio
enrichment has to be limited, and/or the emission control aftertreatment
system has to be modified to increase its effectiveness in converting
the increased engine-out emissions. The methods of achieving those
objectives vary with the type of emission control system.
For open-loop systems, the following options are available:
1. Recalibrated carburetors for vehicles sold at high altitudes.
2. Carburetors equipped with an aneroid which allows the
carburetor to automatically recalibrate at high altitude to
limit air/fuel ratio enrichment.
Closed-loop systems are inherently self compensating when they are
operating in the closed-loop mode, as long as the fuel metering system
is operating within its range of authority. Sometimes, some of these
systems are in the open-loop mode. For example, open-loop operation is
not uncommon during cold start and wide open throttle (WOT) for some
systems. Other open-loop modes are possible. In these open-loop modes,
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the air/fuel ratio will enrichen with altitude unless there are control
systems incorporated to limit the enrichment. Two strategies exist
here. One is to recalibrate the open-loop modes for vehicles to be sold
at high altitude. The second is to have the open-loop calibrations
automatically compensated for altitude with a control system that senses
ambient and/or manifold air pressure. Adaptive memory such as GM's
"keep-alive" memory is another technique to correct the open-loop calibrations
for the altitude at which the vehicle is being operated.
Another strategy to reduce HC and CO emissions at all altitudes would be
to maintain a stoichiometric air/fuel ratio at WOT. In most cases, the
air/fuel ratio is purposely enrichened to increase power. A review of
combustion engines textbooks [37 at 343; 38 at 69; 39 at 492; 40 at 402-
403] showed that the typical shape of the brake mean effective pressure
(BMEP) versus air/fuel ratio curve is relatively flat between stoichio-
metric and the air/fuel ratio that yields maximum BMEP. BMEP is directly
proportional to power. According to these texts, the increase in power
(BMEP) caused by enrichening the air/fuel ratio from stoichiometric to a
best power air/fuel ratio ranges from 0% to approximately 5%.
The data in Table II-l, which were developed by the Southwest Research B
Institute for an EPA contract [41 at 46], fall within the range mentioned
above.
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Table II-l
EFFECT OF FUEL TO AIR RATIO AT WOT
Concentration as Measured
Power ,
kW
72.7
71.2a
70.6
70.1
68.4
65.8,
K
62.8°
57.6
50.1
% BL
WOT
102
100
99
99
96
93
88
81
71
HC,
PPM
2224
1776
1552
1184
96
1
1
1
1
CO,
pet
6.96
4.75
3.36
1.87
0.31
0.03
0.02
0.02
0.02
CNOx,
ppm
239
647
1041
1624
2147
2305
2114
1373
658
SFC,
kg/kW-hr
0.35
0.33
0.32
0.30
0.30
0.30
0.31
0.32
0.35
Calc.
Air/Fuel
12.0
12.8
13.2
13.8
14.6
15.0
15.8
16.8
17.8
o
Baseline maximum power is approximately 71 kW.
90 percent of baseline maximum power is approximately 64 kW.
NOTE: 14° BTDC at 2000 rpm, with thermal reactor, no air injection;
CNOx is NOx corrected for humidity.
These data show that the power loss was only 4% from the baseline WOT
air/fuel ratio of 12.8:1, to the stoichiometric ratio of 14.6:1, but the
HC concentration dropped from 1776 ppm to 96 ppm, CO dropped from 4.75%
to 0.31%, and fuel consumption also decreased.
For the analysis that follows, the EPA staff has concentrated on control
approaches that control engine air/fuel ratio. The other control option,
that of increasing the effectiveness of the aftertreatment system, is
not discussed in any great detail. It is an option, however. For
example, increased catalyst size and/or increased air pump delivery rate
(larger pump or higher pump speed) could reduce any altitude-caused
increase in HC and CO emissions to acceptable levels.
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III. METHODOLOGY
The EPA technical staff made pass/fail judgements on the manufacturers'
technical ability to comply with the standards. The following four
methods were used in making the pass/fail judgements.
1. The first method used high altitude data for emission control
systems which the EPA technical staff predicted would be used by the
manufacturers for the 1982-1983 model years. These data were averaged
for each engine group. The averages were then multiplied by deterioration
factors taken from 1981 certification data for that manufacturer. The
calculated results were then compared to the standards.
2. The second method utilized 1981 certification test data from emission
data vehicles and deterioration factors (dfs) from 1981 certification
durability vehicles. Factors were developed to reflect the change in
emissions based on tests at high and low altitudes. These three data
sets were multiplied to calculate the predicted high altitude emissions
at 50,000 miles. These predicted levels were then compared to the
standards.
3. The third method is the same as method 2, but instead of emission
data vehicle results, 4,000 mile extrapolated emission results from the
1981 certification durability vehicles were substituted. Therefore, the
dfs and 4000 mile emissions were from the same vehicles.
4. Technical knowledge of the emission control system's ability to
compensate for altitude was used for situations where data were un-
available or to specifically address issues raised by the particular
manufacturer being evaluated.
Before using any of the four methods it was necessary for EPA to predict
the engine displacements and emission control technology to be used by
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each manufacturer. In most cases these judgements were based on in-
formation from four sources; a) 1981 certification data, b) CO waiver
applications, c) testimony from the 1982-1983 high altitude hearings,
comments on the 1982-1983 high altitude NPRM, and d) written responses to
questions from the hearing panel. Of these four sources, only the 1981
certification data were not yet publicly available. While certification
data were considered in this analysis, data which were unavailable from
the other sources have been removed from this text. In such cases, the
engine displacement was replaced by a letter designation and the emission
control system description was replaced by a number.
Where the manufacturer has historically grouped more than one engine
displacement in an engine family, or where the EPA technical staff
judged that several engine displacements were equipped with similar
emission control systems, these engines were evaluated as a group in
order to expedite the analysis. Several engine displacements were
available with more than one emission control system. The prime concern
was to evaluate whether the manufacturer had the technology for each
engine group to comply with the standards. It was not an objective of
this analysis to determine whether every combination of engine displacement
and emission control system, which the manufacturer had available, could
comply with the standards. Therefore, in most cases, only one such
combination was evaluated.
In methods 1 thru 3, four different data sets were used. The 1981
certification dfs comprised one of the data sets. The dfs were taken
from the EPA Certification Status Report of July 11, 1980 and averaged
for each engine group. Deterioration factors were only calculated for
vehicles with at least three valid tests and a 15,000 mile test. Vehicles
*
which were line crossing were not included in the average.
* A durability vehicle is considered to be line crossing when the results
from one or more valid tests are above the 1982-1983 model year low
altitude standards, and either the extrapolated 4K or extrapolated 50K
results are also above the same standards.
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Because manufacturers have historically generated dfs for more engine
families than they actually market, a second set of dfs was also used.
In many cases, a manufacturer will actually market only those engine
families whose durability vehicles achieved the lowest deterioration
factors. In order to reflect these practices, EPA selected the durability
data within the engine group which had the best combination of results
when considered with the altitude factors and the 4,000 mile data. The
best combination results would give the engine group the highest probability
of passing the standards. These deterioration factors are referred to
as the "lowest dfs". It should be noted that the dfs from the single
durability vehicle with the best combination results was chosen, and not
the lowest dfs from among all the individual vehicles within the engine
group. The selected vehicle's dfs were then used in the calculations.
The second data set used in methods 1, 2 and 3 were low mileage test
results. In method 1, low mileage high altitude test results were used
along with certification dfs in order to predict 50,000 mile emissions
at high altitude. Due to the scarcity of high altitude test data, method
1 was infrequently used.
In method 2, the low mileage test results were the 4,000 mile certifi-
cation results from 1981 emission data vehicles which had been assigned
a certification disposition of passing. The cutoff date for this data
was July 15, 19.80 for light duty vehicles, and July 23, 1980 for light
duty trucks. These data were then averaged for each engine group.
Because the 1981 Federal CO standard for light duty vehicles is more
stringent than the California standard, where possible, only emission
data vehicles calibrated for sale in 49-states or 50-states were included
in 4,000 test averages. For light duty trucks, the opposite is true.
The California standards are more stringent. In this case California
trucks and 50-state trucks were used in the 4,000 mile test averages.
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10
Durability vehicles were selected by emission control system only.
Sales location was not a critereon in their selection. All durability
vehicles with at least three valid tests, a 15,000 mile test, and which
were not considered to be line crossing, were used for the df averages
and the extrapolated 4,000 mile results.
The third data set was used when 4,000 mile emission data vehicle test
results with a certification disposition of passing were not available.
Instead, extrapolated 4,000 mile results from the durability vehicles
within the EPA designated engine group were averaged and used. Only
those vehicles which met the criteria to be included in the df average
were included in the 4,000 mile average. These data were gathered on
July 17, 1980, and used in method 3.
The fourth set of data used in methods 2 and 3 were factors reflecting
the change in emissions for a vehicle tested at high and low altitudes.
Development of these factors will be discussed in a later section.
As mentioned, method 4 was used when the data required for methods 1
thru 3 were unavailable, or in order to address specific issues raised
by a particular manufacturer.
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11
IV. HIGH ALTITUDE TO LOW ALTITUDE EMISSIONS FACTORS
Multiplicative factors have been developed to reflect the difference in
emissions for vehicles tested at high and low altitude. These factors
were used in methods 2 and 3 to estimate or predict the emissions of
1981 certification emission data vehicles at high altitude, based on
their low altitude test results.
Factors were developed for the following generic emission control systems:
1. Pulse or aspirator type air injection systems (PAIR),
oxidation catalysts (OC), and exhaust gas recirculation (EGR)
with aneroid carburetors.
2. Air injection systems using air pumps (AIR),OC, and EGR.
3. Feedback carburetion (FBC), 3-way catalysts (3W), AIR, OC,
and EGR.
A. Closed-loop electronic fuel injection (CLEFI), 3W and EGR.
All the factors in this section were developed from light duty vehicles,
but were used to calculate the predicted altitude emissions of light
duty trucks in addition to light duty vehicles. Concern was expressed
by the manufacturers that the power-to-weight ratios for LDTs were lower
than for LDVs and inferred that high altitude emission standards would
be especially burdensome for LOT manufacturers for this reason [4 at 95-
96 and 6 at 7].
The manufacturers also stated that higher axle ratios would be required
on low power-to-weight ratio light duty vehicles in order to comply with
the proposed high altitude standards [42 at 1&2 and 6 at 3 & Attachment
II]. However, the manufacturers did not provide data or analyses to
support these statements. In fact, the data listed in Table Ford-2 (see
section 5) indicate that the higher the axle ratios, the higher the
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12
percent increase in emissions. However, it should be noted that there
are only a limited amount of data and the comparison involves different
vehicles with different axle ratios, rather than the same vehicles with
different axle ratios.
Because of manufacturers' statements inferring that low power-to-weight
ratios could be compensated for with higher axle ratios, the technical
staff calculated power-to-weight ratios for the LDVs from which the
factors were derived and for the LDTs to which the factors were applied.
Rear axle ratios were also compared. Although the technical staff kept
track of the power-to-weight ratios and axle ratios, the altitude factors
were not adjusted or modified as a result of the comparisons.
In most cases, the power-to-weight ratios for LDTs were lower than for
the LDVs from which the factors were derived (reference vehicles), but
the axle ratios were always higher for the LDTs which had lower power-
to-weight ratios than the reference vehicles. The power-to-weight
ratios were calculated by dividing the rated horsepower by the equivalent
test weight.
The power-to-weight ratios and rear axle ratios for the LDTs and reference
vehicles were compared on a percent difference basis
/•• */ *.rr t LDT parameter , x ,. ,__ . _.
(i.e. % Difference =( rr-7 ' „ , . ,—^ - 1) X 100. A negative
v Reference Vehicle Parameter
value means that value of the parameter for the LDT vas lower than the
reference vehicles' and a positive value means that the value of the
parameter for the LDT was higher. Where there was a larger percent
difference in power-to-weight ratios than in axle ratios (e.g. -20%
power-to-weight and 4-10% axle ratio), the predicted emission results
were checked for their proximity to the emission standards. No cases
were found where a pass/fail determination xjas made for an engine/vehicle
combination which had a higher percent difference in power-to-weight
ratio than in axle ratio and also had predicted emission levels which
were close to the proposed standards. If the power-to-weight ratio was
higher for the LDT than for the reference vehicle, the factors were
considered appropriate.
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13
Although the power-to-weight ratios for the light duty trucks were often
times lower than for the reference vehicles, this may not be true of the
vehicle fleet.for 1982 and 1983. .Projected 1980 sales data indicate
that the average engine displacement in cubic inches (CID) will be 210.5
for LDVs and 284.9 for LDTs. The average inertia weight will be 3283
pounds for LDVs and 4194 pounds for LDTs [36 at 5 and 57]. The engine
displacemnt to inertia weight ratio for LDTs is projected to be 0.0679
3 3
in /lb, whereas for LDVs it is projected to be only 0.0641 in /lb. In
other words, the displacement-to-weight ratio is projected to be 6
percent higher for LDTs than for LDVs.
PAIR/OC/EGR Altitude Factors
The altitude factors for the PAIR/OC/EGR emission control system with an
altitude compensated carburetor were developed from data submitted by
Nissan [8 at 3] and listed in Table IV-1.
VIN
Table IV-1
PAIR/OC/EGR Altitude Factors
Altitude
(f t-}
\ ^- ^ /
0
5249
Factors*
0
5249
Factors*
Avg. Factors as
calculated
Avg. Factors*
HC
0.34
0.34
1.00
0.30
0.36
1.20
1.10
1.10
CO
/ •
£/ IUJ.
4.1
5.7
1.39
2.4
5.1
2.13
1.76
1.76
NOx
0.51
1.3
2.55
0.98
1.59
1.62
2.09
Not used**
as used for Nissan
Factors* as used
for manufacturers
other than Nissan
1.70
1.80
Not used**
* Factors are dimensionless.
** See test.
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14
The average NOx factor of 2.09 is extraordinarily high in view of the
fact that there is widespread agreement that NOx usually decreases as
altitude increases. In reference to the data included in Table IV-1,
Nissan stated,
In the case of our "Oxidation Catalyst -f Heavy EGR system... the
frequency of WOT operation where EGR does not work is increased
because of insufficient engine power [8 at 3].
Nissan further explained that the EGR control system would be revised
"to control EGR near WOT acceleration [8 at 3]."
These factors were developed from engines which utilize "heavy EGR" for
NOx control, which Nissan admits, needs to be better controlled under
high altitude operating conditions.
Because it is technically feasible to control EGR near WOT, and because
the other manufacturers assessed in this analysis did not express a
concern about NOx control at high altitude, the NOx factor derived from
the Nissan data was not used in assessing the technical capability of
other manufacturers. Since the technical staff was not aware of addi-
tional datavfor a PAIR/OC/EGR control system with an altitude compensated
carburetor, a factor was not used for NOx. Instead, a maximum tolerable
factor was calculated by dividing the NOx standard by the product of the
low mileage emissions times the df. If the maximum calculated factor
was greater than 1.0, then NOx emissions were considered to pass the
standard.
The factors for vehicles with an air pump and an oxidation catalyst were
1.65 for HC and 1.73 for CO. The EPA technical staff was skeptical of
using altitude factors showing significantly better altitude compensation
for a PAIR system than for an air pump system. For this reason, the HC
factor for the PAIR/OC/EGR system was changed from the calculated value
of 1.10 to 1.70 to make it more conservative than the AIR/OC/EGR system's
HC factor of 1.65. The CO factor was rounded up from 1.76 to 1.80. The
1.70 HC and 1.80 CO factors were used for manufacturers other than
Nissan. Since these factors were developed from Nissan data, the calculated
values, 1.10 for HC and 1.76 for CO, were used as calculated for Nissan.
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15
These factors were considered appropriate even for engines without
"heavy EGR". The rate of EGR flow should not influence the carburetor's
ability (to meter fuel), to compensate for altitude nor the PAIR system's
ability to supply sufficient oxygen to the exhaust stream to maintain
catalyst efficiency.
AIR/OC/EGR Altitude Factors
The factors for the AIR/OC/EGR emission control system with an altitude
compensated carburetor were developed from light duty vehicle data
submitted by Ford [6 at Attachment 3] and listed in Table IV-2.
TABLE IV-2
AIR/OC/EGR Altitude Factors
VIN Location HC C0_ NOx //Tests
g/mi
//4 Dearborn 0.23 1.1 0.87 1
Denver 0.38 1.9 0.90 2
Factors* as 1.65 1.73 1.03
calculated and
used
* Factors are dimensionless.
The factors were used as calculated for both light duty vehicles (LDVs)
and light duty trucks (LDTs). The power-to-weight ratio for vehicle //A
was 0.0375 hp/lb and the axle ratio was 2.26.
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16
FBC/AIR/3W/OC/EGR Altitude Factors
The factors for the FBC/AIR/3W/OC/EGR emission control system were
developed from data submitted from Chrysler [7 at Appendix C] and Ford
[6 at Attachment III]. These data are listed in Table IV-3. The Chrysler
vehicles tested in Denver had minor adjustments for high altitude operation.
The Ford vehicle did not have adjustments.
Table IV-3
FBC/AIR/3W/OC/EGR Altitude Factors
Mfr VIP
Ford #5
Factors* as calculated 1.12 2.56 0.97
and used for Ford vehicles
Location
Dearborn
Denver
HC
0.17
0.19
CO
. .
0.9
2.3
NOx
1.64
1.59
//Tests
1
2
Chrysler
315
078
307
343
Detroit
Denver
Detroit
Denver
Detroit
Denver
Detroit
Denver
Chrysler factors*
as calculated by EPA
Factors*
Chrysler
Averaged
as used for
vehicles
factors* used
for
0.13
0.16
0.10
0.19
0.22
0.40
0.30
0.38
1.55
1.55
1.47
1.35
2.21
0.65
3.13
1.62
2.28
1.85
5.06
2.65
2.65
2.63
0.80
1.14
1.25
1.28
0.77
0.89
0.82
0.90
1.18
1.00
1.00
•
—
—
1
2
manufacturers other than Ford
and Chrysler
* Factors are dimensionless.
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17
Because of differences in the capability of each manufacturer's feedback
control system to compensate for altitude, the altitude factor developed
from Ford data was used for assessing Ford's engines and likewise for
Chrysler. The Ford and Chrysler data were averaged for Assessing the
technical capability of manufacturers other than Chrysler and Ford.
These factors are listed in Table IV-3.
The technical staff did not use the NOx factor of 1.18, but instead used
a factor of 1.0. Chrysler stated the following in relation to NOx:
NOx is not specifically addressed in this NPRM because
NOx emissions decrease with altitude as the engine mixture
richens. Therefore, NOx standards set at low altitude
provide a certain fortuitous degree of extra NOx control
at high altitude. If, as the EPA proposes, present air-fuel
systems are re-calibrated or controlled to more stoichiometric
air-fuel ratios (i.e. leaner), NOx emissions may actually
increase [7 at p.7].
Although the technical staff agrees that leaner mixtures sometimes can
lead to increased engine-out NOx emissions, the object with a closed-
loop three-way catalyst system is to maintain stoichiometry. The problem
is in keeping the system from going too rich rather than too lean. The
CO factor of 2.65 indicates that this system is enrichening with increases
in altitude. EPA feels that the increase in NOx emissions is probably
due to EGR calibration and control. Like Nissan, Chrysler may have to
revise their EGR control system for high altitude. Neither Chrysler nor
Nissan indicated it would be a problem, and other manufacturers have not
made an issue of NOx control at high altitude. EPA therefore used an
NOx factor of 1.0 for control systems with FBC/AIR/3W/OC/EGR, except for
Ford vehicles which used the 0.97 NOx factor. The 0.97 NOx factor was
calculated from Ford data.
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18
CLEFI/3W/EGR Altitude Factors
The ratios for this emission control system were developed from data
submitted by Nissan [8 at p.3] and listed in Table IV-4. The EFI system
included an altitude compensation device.
Table IV-4
CLEFI/3W/EGR Altitude Factors
VIN Altitude
(ft)
HC
0.31
0.52
CO
. .
2.1
5.4
NOx
0.47
0.35
0
5249
Factors* as 1.68 2.57 0.74
calculated
*Factors are dimensionless.
The Nissan electronic fuel injection system is similar to the Bosch
L-jetronic system. Bosch stated that "the controlled range is designed
such that no error exists for altitudes up to 2,500 meters [8,200 ft] [2
at Annex 5, p.5]." This factor was used as calculated.
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19
V. INDIVIDUAL MANUFACTURER'S DISCUSSIONS
A. Gasoline-Fueled Vehicles
American Motors Corporation (AMC)
Light Duty Vehicles
EPA assumed that the following engines will be marketed in 1982 and 1983
based on information provided in AMC's CO waiver request and 1981 certifi-
cation information.
1. 151 CID FBC/AIR/3W/OC/EGR
2. 258 CID - (1982) Control System 1*
- (1983) FBC/AIR/3W/OC/EGR
Pass/Fail Analysis of the 151 CID Engine
Representatives of AMC testified at the high altitude hearings of March
5, 1980 that:
Our four cylinder technology we receive from General Motors. We
buy as a total package, and we have a California package and a
nationwide package [4 at 243].
AMC also stated that the control system used on this engine includes a
feedback carburetor, air pump, three-way catalyst, oxidation catalyst
and EGR [4 at 244 and 21 at 7130]. GM submitted data from development
vehicles tested at high altitude (see 1.6L engine data in Table GM-1 in
the GM section of this report). Two 151 CID engine vehicles were among
those tested at low mileage. A method 1 analysis was performed on these
vehicles using dfs from two 1981 GM certification durability vehicles.
The lowest dfs case exhibits predicted results of 0.57/6.6/0.8 (see
Table GM-1), which are below the 1982 and 1983 high altitude standards.
Using the average dfs from three 1981 GM certification durability vehicles
and the average low mileage results from two 151 CID GM vehicles tested
at high altitude, the predicted results indicate the 151 CID engine will
fail.
* Not yet publicly released.
-------
20
Although AMC did not submit high altitude data for this engine, the data
submitted by GM are judged to be indicative of the emission control
system's ability to compensate for altitude. As explained in the factors
section, the closed-loop three-way catalyst system is designed to maintain
stoichiometry and thereby compensate for increases in altitude. The CO
factor from the Chrysler and Ford data is 2.65, and it is judged that
the GM system is at least as efficient for altitude compensation if not
more so. Based on the predicted results using the lowest dfs, EPA
concludes that AMC has the technical capability to meet the standards
with the 151 CID engine.
Pass/Fail Analysis of the AMC 258 CID Engine
Based on 1981 certification information, AMC is expected to use emission
*
control system 1 for the 1981 and 1982 model years. This engine has
been granted waivers to 7.0 gpm CO and to 2.0 gpm NOx for 1981 and 1982
MYs [23 at 53377] and [24 at 5990]. This converts to high altitude
standards as follows:
1982 1983
HC 0.57 gpm 0.57 gpm
CO 11 gpm 7.8 gpm
NOx 2.0 gpm 1.0 gpm
Information from AMC's CO waiver request indicates that they will be
using a FBC/AIR/3W/OC/EGR control system in order to comply with the
1983 MY low altitude CO standard (3.4 g/mi).
Emission control system 1 was not evaluated because altitude factors
were not available. The FBC/AIR/3W/OC/EGR emission control system also
could not be evaluated because AMC dfs and 4K data were not available.
* Not yet publicly released.
-------
21
The following statement is excerpted from the AMC submission [25 at 8]:
Beginning with the 1980 MY, the manufacturer is required
to submit data to ARB [California Air Resources Board]
which show the tailpipe air/fuel ratio is leaner than
stoichiometric to altitudes up to 6000 feet. AM is
presently using the analytical method described in this
advisory circular [Advisory Correspondence #78-2].
The technical staff's knowledge of AMC's emission control systems
leads us to believe that the 258 CID engine will be able to comply
with 1982 and 1983 high altitude standards listed at the beginning
of this pass/fail analysis. The prior quote from AMC and their
statement that "AM does not dispute the basic feasibility of the
proposed standards [25 at 4]" lends support to this belief. But in
the final analysis, the technical staff concludes that it does not
have enough information to support a judgement on the 258 CID engine's
ability to comply with the applicable standards.
-------
22
American Motors
Light Duty Trucks
EPA assumes that the following engines will be marketed in 1982 and 1983
based on 1981 certification information.
Emission
Engine Displacement Control System
1. A cu. in. 1
2. B cu. in. 2
3. C cu. in. 2
A. D cu. in. 2
Pass/Fail Analysis of the AMC A LPT Engine
AMC did not submit high altitude data for this light duty truck engine.
No emission data vehicle or durability vehicle data were available for
this analysis either. Therefore, a method 4 analysis was used for this
engine.
The A engine is equipped with emission control system 1. Although the
emission control system is not exactly the same as for the light duty
vehicle version of this engine, the technical staff feels that the LDT's
ability to compensate for altitude should be almost as effective as the
LDVs. Data from the LDV version of this engine at high altitude show
that one vehicle with the A engine is projected to pass the LDV standards
at 50,000 miles. The light duty truck standards are considerably less
stringent than the light duty vehicle standards met by this vehicle with
a similar control system. Because the data indicate that this system
can compensate for altitude, EPA concludes that AMC has the technical
capability to meet the LDT standards with the A engine.
-------
Table AMC-1
American Motors LPT
Eaission
Control
DIS?.* Systc-r-.*
HP/ETWRATIPS
Cert.
Rcf. Vch. 4K Veh's.
AXLE RATIOS
LOT to 4K
Kef. Vch.
.. e ...
Re£> Vh '
: vch's.
;x io"2)
*
*
Ref. Veh. Cert.
(%) 4K Tests
HC CO NOx
g/ol—
+12 * * *
+21 t t t
High to Low
Altitude Factors
HC CO
* *
* *
NOx
*
*
Cert.
dfs Predicted
HC
1.14
1.26
1.65
CO
f
24.7
24.9
in, 7
Results
NOx
1.68
1.68
1.75
Pass-Fall
1982 1983
HC CO NOx HC CO NOx
P P P F F P
Comnents
Lovest dfs
Average dfs
1980 Cert.
(2)
Data
III
-6
+19 * * * * * *
0.99 17.1 1.63 P P P P F P One vehicle
* N'ot Yet Publicly Released.
f 19
-------
24
Pass/Fail Analysis of the AMC B, C, & D LPT Engines
High/low altitude factors were developed for system 2 on a LDV in
Section IV. The hp/ETW ratios and the axle ratios were greater for
engines B and C than for the reference LDV, as shown in Table AMC-1.
For engine D, the hp/ETW ratio was lower than for the reference LDV.
A pass/fail analysis of the B and D CID engines was conducted by use of
method 2 since some 1981 certification data were available. The analysis
of the C engine also made use of the 1980 certification data. Results
are shown in Table AMC-1.
The technical staff concludes that all three engines can comply with the
1982 LOT high altitude standards of 2.0 HC, 26 CO, and 2.3 NOx. The
data also show that these engines are not capable of satisfying the more
stringent high-altitude standards established for the 1983 model year
(1.0 HC, 14 CO, and 2.3 NOx) without recalibration or other advanced
emission control system design strategies.
The technical staff concludes that AMC has the technology to comply with
the 1982 high altitude LOT standards, but will need to complete additional
work to comply with the 1983 standards.
-------
25
Chrysler
Light-Duty Vehicles
EPA assumed that the following engines would be marketed in 1982 and
1983 based on information provided in Chrysler's CO waiver request.
1. 1.7L FBC/AIR/3W/OC/EGR.
2. 2.2L FBC/AIR/3W/OC/EGR.
3. 2.6L PAIR/OC/EGR.
4. 3.7L AIR/OC/EGR.
5. 5.2L FBC/AIR/3W/OC/EGR.
Pass/Fail Analysis of the Chrysler 1.7L Engine
The emission control system for the 1.7L engine is expected to include
FBC/AIR/3W/OC/EGR. Listed in Table Cfirysler-1 are the altitude factors
for Chrysler's feedback carburetion system and the lowest and average
dfs from 1981 certification data for this engine. These data were -used
in a method 2 analysis. The dfs were taken from three durability vehicles
and the 4K data were averaged from four emission data vehicles.
The predicted high altitude emission levels are 0.35, 4.96 and 0.86,
using the lowest dfs, for HC, CO, and NOx respectively, and are 0.40,
6.86, and 0.86 using the average dfs. The 1.7L engine should easily
pass the 1982-1983 high altitude standards. Since this engine has a CO
waiver for the 1982 model year, it only has to meet a CO standard of 11
g/mi rather than 7.8.
Pass/Fail Analysis of the Chrysler 2.2L Engine
This engine was represented by five emission data vehicles and five
durability vehicles. Table Chrysler-1 has three different sets of
deterioration factors. The first of these represents the deterioration
-------
TABLE CHRYSLER-1
Chrysler 1.DV
IUCH TO LOW
CKHT. /.K TKSTS* AI.T1TUUK FACTORS CERT dfs* PRED1CTRD RESULTS PASS-FAX!. ^__
DISP EMISSION CONTROL SYSTEM HC CO NOx HC CO NOx HC . CO NOx HC CO NOx HC con" C07.8 l<0x CO>?t::.;T5
I.7L ytC/AIR/VJ/fjC/w:* . 1.55 2.f.5 1.00
2.2- ?3T./A.':i/:u/oc/cr,K 1.55 2.65 1.00
i.ti. PAIR/C^/KCX 1.70 1.80 1.40***
3.7L #1 * * *
5.2L-2V KaC/A!R/3'.70C/ECl( 1.55 2.65 1.00
0.35
0.40
0.41
0.58
0.38
0.44
0.37
0.49
0.22
0.29
5.0
6.7
5.0
10.0
6.2
5.6
6. '8
4.7
3.8
4.3
0.7 P P P P
0.7 P P P P
0.6 P ' - P P
0.9 r — F P
0.6 P -- P P
1.0 P _ P P
1.0 P -- P P
0.3 P P P P
0.9 P -- p P
1.0 P .- p P
Loveflt dfs
Avg dfs (3)
Lovcot i1. :'?
Avss ifs (5)
AVR dfs (4;
I.OVC5C Ufs
Avg dfs (4)
One vehicle
Lover. I dfs
Avs dfs (5)
** Engines wish .1-CO walwr hiivc a "P" or "F" In thin column. Engine*) without a CO waiver have a "—" In this column.
*** y.-ixisutt wit ttuiltf factor which nllows vehicle to pnna.
N3
-------
27
factors generated by the best case vehicle for this engine group. The
second set of deterioration factors represents an average of five deter-
ioration factors and the third group is an average of four deterioration
factors. One of the durability vehicles had dfs of greater than 5.0 for
both HC and CO. In the opinion of the technical staff, it is highly
improbable that any manufacturer would market an engine family whose
deterioration factors are greater than five. Therefore, an analysis was
done for average deterioration factors both including and excluding this
vehicle.
The results in Table Chrysler-1 indicate that the 2.2L engine is capable
of meeting the high altitude standards using the best dfs and the average
of 4 dfs, but failed both HC and CO when the average of 5 dfs were used.
In the judgement of the EPA technical staff, the 2.2L engine is capable
of meeting the high altitude standards.
Pass/Fail Analysis of the Chrysler 2.6L Engine
The Chrysler 2.6L engine's emission control system is expected to include
PAIR/OC/EGR. The data base for this engine included five emission data
vehicles and seven durability vehicles. Of these seven durability
vehicles, only four were used in the average because two line crossed
and one had less than 15,000 miles.
According to Chrysler, vehicles not using three-way catalysts will use
altitude compensating carburetors [7 at 23]. As discussed in the factors
section, the only high and low altitude data for this type of emission
control system were submitted by Nissan [8 at 3]. This engine was
evaluated using factors of 1.70 and 1.80 for HC and CO respectively.
The Nissan data, as explained in the PAIR/OC/EGR factors section, yielded
a factor of 2.09 for NOx. The 2.09 NOx factor is not an appropriate
factor for use in analyzing the Chrysler engine's ability to meet the
1.0 NOx standard at high altitude. Nissan indicated they were using
"heavy EGR" but said
The frequency of WOT operation where EGR does not work is increased
because of insufficient engine power [8 at 2] .
-------
28
Since NOx control is not an issue and additional data were not available,
a NOx factor was not used. Instead, calculations were made to evaluate
the highest factor which would still allow the engine to comply with the
1.0 NOx standard. As Table Chrysler-1 shows, even with a NOx factor of
1.40, or a 40% increase in NQx at a high altitude, the 2.6L engine is
able to comply with the high altitude standards. Therefore, with ratios
of 1.70, 1.80, and 1.40 for HC, CO and NOx respectively, the 2.6L engine
is capable of complying with the high altitude standards using the
lowest dfs or the average dfs.
Pass/Fail Analysis of the Chrysler 3.7L Engine
Based on 1981 certification information, the 3.7L engine is expected to
*
be equipped with an emission control system 1 . This engine was represented
by four emission data vehicles and one durability vehicle. Although this
engine has a CO waiver for 1982, the results in Table Chrysler-1 indicate
that it will easily comply with the 1982-1983 high altitude standards,
even for engines without a CO waiver.
Pass/Fail Analysis of the Chrysler 5.2L Engine
The emission control system for the 5.2L engine is expected to include
FBC/AIR/3W/OC/EGR. Table Chrysler-1 lists the emission data vehicle
results, the altitude factors for this emission control system and the
predicted high altitude emissions results of 0.22 HC, 3.8 CO, 0.9 NOx
with the lowest dfs and 0.29 HC, 4.3 CO, 1.0 NOx using the average dfs.
These data were developed in a method 2 analysis.
* Not yet publicly released.
-------
29
To save time only the two barrel carbureted version was assessed for two
reasons. First, it does not have a CO waiver for 1982, and therefore
has to meet the more stringent CO standard of 7.8 g/mi. Second, we
expect it to be produced in higher production volumes than the other two
versions.
The predicted results for this engine indicate that it will be able to
comply with the 1982-1983 high altitude standards using either the
lowest dfs or the average dfs.
-------
30
Chrysler
Light Duty Truck
Chrysler is expected to market the following engines in 1982-1983 for
their light duty trucks. This information is based on 1981 certification
data.
Emission
Displacement Control System
1. A 1
2. B 1
3. C 1
Pass/Fail Analysis of the Chrysler A IDT Engine
This engine was represented by three emission data vehicles and three
durability vehicles. The durability data vehicles included B033R, D103
and D104.
The altitude factors used in this method 2 analysis were developed from
light duty vehicle data. The rear axle ratio for the LDTs was more than
55% higher than the average rear axle ratio for the reference vehicles.
Although the horsepower-to-equivalent test weight ratio is approximately
40% higher for the LDVs than the average hp-to-ETW ratio for the LDTs,
it is still considered appropriate to use in light of the higher LOT
rear axle ratios.
Using a method 2 analysis, as shown in Table Chrysler-2, the predicted
emission levels were 0.8 HC, 6 CO, and 1.1 NOx using the lowest dfs and
0.8 HC, 7 CO and 1.1 NOx using the average dfs. These data indicate
that this engine will easily meet the standards when emission control
system 1 is used.
-------
TABLE CHRYSLER-2
Chrysler LPT
Emission
Control
DISP.* SVOCCT*
HP/ETC RATIOS
Cert.
Ref. Veh.* 4K Veh's.*
AXLE RATIOS
LDT to 4K
Ref. Veh.
Cert.
Ref. Veh.* AK Veh's.*
LDT to 4K
Ref. Veh.
Cert.
4K Data"
High to Low
Altitude Factors*
Cert.
DF's*
HC CO NOx
g/ml—
HC CO NOx
Predicted Results
11C CO NOx
Pass-Fall
1982 1983
HC CO NOx HC CO NOx
Comments'
3/C 1
+57
+23Z
0.8
0.8
0.7
0.8
6
7
10
10
1.
1.
1.
1.
1
1
5.
5
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
Lowest
Avg dfs
Lowest
Avg dfs
dfs
(3)
dfs
(3)
Not Yet Publicly Released.
**
Inertia weight class was used to calculate the power-to-wclght ratio.
-------
32
Pass/Fail Analysis of the Chrysler B & C LPT Engines
The B and C engines with emission control system 1, were represented by
durability vehicles C040, AGIO and C026. The dfs were averaged from all
three vehicles, as were the extrapolated 4000 mile emission levels.
Because emission data vehicle results were not available, a method 3
analysis was used. Since these engines have historically been certified
in the same engine family the data have been averaged for an analysis of
both engines.
As Table Chrysler-2 shows, in this case, the power-to-weight ratios of
the LDTs were the same as for the LDVs from which the altitude factors
for emission control system 1 were developed. Because equivalent test
weights were not available for the durability vehicles being evaluated,
inertia weight class was used to calculate the power-to-weight ratios
for both the reference vehicles and the LDTs. The axle ratios were 23%
higher for the LDTs.
The predicted results in Table Chrysler-2 indicate that the B/C engines
with emission control system 1 will be able to comply with the standards
using both the lowest and average dfs.
-------
33
Ford
Light-Duty Vehicles
Ford summarized their plans for high altitude compliance as shown in
Table Ford-1 [6 at Attachment II].
TABLE Ford-1
HIGH ALTITUDE COMPLIANCE PLAN1 - PASSENGER CAR
1982 1983
Small 1-4 Non FB/Aneroid2 Non FB/Aneroid2
3 3
Large 1-4 Non FB/Aneroid Non FB/Aneroid
1-6 Non FB/Aneroid Non FB/Aneroid
V-8 Non FB/Aneroid Non FB/Aneroid
FB/Electronic FB/Electronic
1 Compliance at high altitude achieved by use of higher
axle ratios where required.
2 Except for EFI equipped engines which will have FB and
EEC. FBC under consideration.
3 Except for turbocharged 1-4 which may be equipped with
FBC and MCU.
The following statement and data from Ford indicate that in their
opinion it is technically feasible for Ford to meet the high altitude
standards.
The data in Table 2 [Ford-2] indicates that Ford's current "altitude
compensated electronic calibrations" are capable of achieving the
standards EPA has proposed at altitude. The test results on vehicle
//4 indicate that less costly "aneroid compensated non-electronic
calibrations" also comply [6 at Attachment III].
-------
TABLE Ford-2
Vehicle Vehicle Axle Test # CVS Emissions g/mi
// Description Ratio Location Tests HC CO NOx
4 4.2L A/T 3250 I.W. 2.26 Dearborn 1 0.23 1.1 0.87
49-S Calibration Denver 2 0.38 1.9 0.90
Compensated (Aneroid)
5 5.8L FIOD 4500 I.W. 2.73 Dearborn 1 0.17 0.9 1.64
49-S Calibration Denver 2 0.19 2.3 1.59
Compensated (EEC II)
6 5.0L FIOD 4250 I.W. 3.08 Dearborn 1 0.12 1.2 0.63
Calif. Calibration Denver 2 0.22 3.6 0.46
Compensated (CFI)
In reference to their compliance plans for high altitude, Ford said,
To carry out this plan, the only additional change that need be
made to the proposed rules is to make it clear that unique axles
are a permissible element of an altitude "modification" [6 at
Attachment II].
Although Ford tested six vehicles at high altitude, the three vehicles
included in Table Ford-2 are the only ones that are representative of
Ford's plans as listed in Table Ford-1. The axle ratio for these vehicles
are 2.26, 2.73, and 3.08. The data in Table Ford-2 indicate that these
vehicles are well below the high altitude standards for HC and CO, even
with the axle ratios of 2.26 and 2.73. It should be noted that the
lower the axle ratio, the lower the increase in CO emissions. Car //4,
with a 2.26 axle ratio, had a 73% increase in CO. Car //5, with a 2.73
ratio, increased by 156% and car #6, with a 3.08 ratio and central fuel
injection, increased by 200%. Although the EPA technical staff does not
take the limited amount of data to be indicative of the general case,
it has concluded that Ford failed to show that unique axle ratios are
essential for compliance with the high altitude standards.
-------
35
Pass/Fail Analysis of the Ford 1.3/1.6L Engines
Based on information in their CO waiver request, Ford is expected to use
an open-loop AIR/3W/OC/EGR emission control system with the 1.3 and 1.6L
engines. No altitude factors have been developed for this emission
control system and Ford has not submitted high altitude data for these
engines. Since these engines use the same emission control systems and
are of the same configuration (1-4), they were analyzed as a group.
Ford has submitted high and low altitude test data for an engine with an
aneroid compensated carburetor (see vehicle #4 in Table Ford-2). Ford
said that "the test results on vehicle #4 indicate that less costly
'aneroid compensated non-electronic calibrations' also comply [6 at
Attachment III]." Ford did not indicate the type of catalysts vehicle
#4 was equipped with. Table Ford-1 shows the information Ford supplied
on the small 1-4, which include the 1.3L and 1.6L engines. These engines
have the same devices for altitude compliance as vehicle #4, but according
to 1980 certification information, vehicle //4 is equipped with AIR/OC/EGR,
rather than with the AIR/3W/OC/EGR system, which is expected to be used
with the small 1-4.
This type of emission control system usually runs leaner than stoichio-
metric whereas Ford indicated that the AIR/3W/OC/EGR system is calibrated
to operate at stoichiometry [3 at 40011]. If this is still true of the
Ford AIR/3W/OC/EGR system, the altitude factors developed from vehicle
#4 would not be appropriate to use with these engines. On the other
hand, if Ford is calibrating their 3WK)C system "lean" to operate primarily
as an oxidation catalyst system, it may be an appropriate factor to use.
Since Ford inferred that the results from vehicle #4 are representative
of their open-loop capabilities, they may now be using a lean calibration
strategy.
If Ford calibrates the 1.3L and 1.6L engines to operate at stoichiometry,
the technical staff concludes that it does not have enough information
-------
36
to predict the ability of this emission control system to compensate for
altitude.
A method 3 analysis was done using the AIR/OC/EGR altitude factors
developed from vehicle #4 in case the 1.3L and 1.6L engines are calibrated
lean. The altitude factors may not even be valid for this situation.
In any case, the predicted results in Table Ford-3 indicate that these
engines will pass using the lowest dfs or the average dfs.
Pass/Fail Analysis of the Ford 2.3L Engine
Based on Ford testimony at the high altitude hearings, the 2.3L engine
is expected to use either a FBC/AIR/3W/OC/EGR or an AIR/3W/OC/EGR emission
control system. Because of the questionable validity of using the
AIR/OC/EGR altitude factor with the open-loop 3W-OC control system, the
open-loop system was not evaluated.
Since there were no emission data vehicle test results available for the
FBC/AIR/3W/OC/EGR control system, a method 3 analysis was used. The dfs
and the extrapolated 4K test results were taken from one durability
vehicle. The altitude factor represents an average of the factors
calculated from Chrysler and Ford data. The Ford altitude factors were
derived from a vehicle with Ford's EEC II emission control system. The
2.3L engine is equipped with the less sophisticated MCU system. The
average altitude factors from the Chrysler and Ford vehicles were more
conservative than from the Ford EEC II data only, and was felt to be
more appropriate for use with the 2.3L engine.
The predicted results in Table Ford-3 indicate that this engine will
pass using the results from one durability vehicle.
Pass/Fail Analysis of the Ford 2.3L Turbocharged Engine
Based on their CO waiver request, it is possible that Ford may use
either FBC/AIR/3W/OC/EGR or AIR/3W/OC/EGR for the 1982 model year and
-------
TABLE FORD-3
Analyses by Methods 2 nnd 3 ef_
Ford LDVs
iircii TO LOW
CK,a. 4K Data* ALTITUDE FACTORS
3IS? EMISSHJN CONTROL SYSTF.M HC CO NOx HC CO NOx
1.5 AIX/3W/OC/F.CT 1.65 1.73 1.03
2.-J FiC/Am/jU/OC/K™ 1.47 2.63 1.00
3--> 1 . *
CERT DFs* PREDICTED RESULTS
HC CO NOx HC
0.39
0.39
0.53
0.40
0.53
CO NOx
4.6 0.9
4.6 1.0
5.7 0.8
2.7 0.6
4.8 0.6
PASS-FAIL
A*
HC COU C07.8
P — P
P — P
P — P
P — p
P — P
NOx
P
P
P
P
P
COMMENTS
Lowest dfs
AVR dts (2)
One Veh
I.o vest dfr.
Avg ;•.;•• n'.;.1"^--.:
'V-.4V
ffifls%B£$ffis^^
-------
38
electronic fuel injection (EFI) for the 1983 MY. No data were available
for the EFI system. Data were available for the AIR/3W/OC/EGR system,
but as explained in the pass/fail analysis for 1.3 and 1.6L engines, the
technical staff has little confidence that the AIR/OC/EGR altitude
factors would be valid to use with the open-loop AIR/3W/OC/EGR system.
Also, since the AIR/OC/EGR altitude factor was developed from data on
naturally aspirated engines, it could not be used with this engine even
if it were calibrated to operate lean. The FBC/AIR/3W/OC/EGR altitude
factors were also developed from data for naturally aspirated engines
and may not be appropriate for use with a turbocharged engine.
The technical staff concludes that it does not have enough information
to predict the ability of this engine to comply with the proposed standards.
Pass/Fail Analysis of the Ford 3.3L Engine
Based on testimony at the high altitude hearings, and on 1981 cert-
ification information, this engine is expected to have three different
emission control systems. These include FBC/AIR/3W/OC/EGR, AIR/3W/OC/EGR
*
and emission control system 1 . The feedback carburetor system was not
evaluated because dfs were not available. The open-loop 3W+OC system
was also not evaluated due to the questionable validity of using the
AIR/OC/EGR factors with it.
Although it is considered to be the least likely control system to be
used, emission control system 1 was evaluated. Dfs from three durability
vehicles and AK test results from 3 emission data vehicles were used in
a method 2 analysis.
Based on the predicted results listed in Table Ford-3, the technical
staff concludes that the 3.3L engine with emission control system 1 will
have the ability to comply with the proposed standards.
* Not yet publicly released.
-------
39
Pass/Fail Analysis of the Ford 4.2L, 5.PL and 5.8L Engines
Based on Ford's high altitude hearing testimony, these engines are
expected to be equipped with three different emission control systems.
These include AIR/3W/OC/EGR, FBC/AIR/3W/OC/EGR, and CLTBI*/AIR/3W/OC/
EGR.
All three engines use the same model feedback carburetors for their
closed-loop carburetor systems and the same model open-loop carburetors
for their open-loop emission control systems. Also, the 4.2L and 5.0L
engines were certified in the same engine families in 1980. Since it is
preferable to use actual high altitude data in a method 1 analysis
rather than the method 2 and method 3 alternatives, and because such
data were not available for each engine-control system combination,
these three engines were evaluated as a group.
Tables Ford-2 and Ford-4 indicate that vehicle #4 is equipped with an
aneroid compensated carburetor and an A1R/OC/EGR emission control system.
The emission control system description is from 1980 certification
information. Using a method 1 analysis, the predicted results listed in
Table Ford-4 indicate that, using 1981 certification dfs, this engine
group has the ability to comply with the standards with an aneroid
compensated carburetor, and an AIR/OC/EGR emssion control system.
Ford did not provide high altitude test data for their open-loop AIR/
3W/OC/EGR system. Because of the questionable validity of using the
AIR/OC/EGR altitude factor for the open-loop 3W+OC system, this system
was not evaluated.
Ford did provide high altitude test data on their closed-loop throttle
body fuel infection (CLTBI) which Ford refers to as central fuel in-
jection (CFI). These data were evaluated using a method 1 analysis. The
*CLTBI is an abbreviation for closed-loop throttle body injection.
-------
TABLE FORD-4
Method 1 Analysis of
Ford LDVs
Vehicle EMISSION HIGH ALTITUDE DETERIORATION
// DISP. CONTROL SYSTEM TEST RESULTS FACTORS*
PREDICTED
RESULTS
HC CO NOx HC CO NOx HC CO . NOx
g/mi . g/mi
4 4.2 AIR/ OC/EGR 0.38 1.9 0.90 0.38
0.60
5 5.8 FBC/AIR/3W/OC/EGR 0.19. 2.3 1.59 0.30
0.24
6 5.0 CLTBI/AIR/3W/OC/EGR 0.22 3.6 0.46 0.35
0.37
2.2
3.1
2.3
2.4
3.6
4.4
0.9
0.9
1.6
1.6
0.5
0.5
PASS-FAIL
HC CO**
P
F
P
P
P
P
C07.8
P
P
P
P
P
P
NOx
P
P
F
F
P
P
COMMENTS
Lowest dfs
Average dfs
Lowest dfs
Average dfs
Lowest dfs
Average dfs
(4)
(2)
(2)
* N'PC Yot Publicly Released,
** Engines with a CO waiver have a "P" or "F" in this column. Engines without a CO waiver have a "—" in this column.
-------
predicted results listed in Table Ford-4 indicate that this engine group
also has the ability to comply with the standards using the CLTBI/AIR/
3W/OC/EGR emission control system.
The FBC/AIR/3W/OC/EGR emission control system for this engine group was
evaluated using the high altitude test results from vehicle //5 which was
equipped with the 5.8L engine. The predicted results in Table Ford-4
indicate that vehicle #5 would fail the 1981 low and high altitude NOx
standard of 1.0. This was a 1980 vehicle which was probably calibrated
for the 1980 NOx standard of 2.0 and the data in Table Ford-2 shows that
NOx decreased slightly in Denver. It is the technical staff's judgement
that a vehicle with this control system calibrated for the 1981 low
altitude standards will be able to comply with the 1982-1983 high altitude
standards and should have the same ability to compensate for altitude on
the 4.2L and 5.0L engines as it does on the 5.8L engine.
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42
Ford
Light Duty Trucks . ,
Based on 1981 certification information, Ford is expected to market the
four engines and two emission control systems listed below:
Emission
Displacement Control System
A 1
A 2
B 1
B 2
C 1
C 2
D 1
D 2
Pass/fail analyses for 49-state emission control systems were also
included.
Pass/Fail Analysis for the Ford A-l LPT Engine
The A engine equipped with emission control system 1 was represented by
seven emission data vehicles and seven durability vehicles. The altitude
factors for this engine were developed from light duty vehicle data.
The LDTs had a hp/ETW ratio 29% lower than the reference vehicle, and
the axle ratio for the trucks was 34% higher. A method 2 analysis was
used for this engine.
The predicted results listed in Table Ford-5 indicate that the A-l
engine will pass the 1982 standards using either the lowest or average
dfs, but will fail the 1983 HC standard in both cases. Based on these
-------
HP/ETW RATIOS
Emission
AXLE RATIOS
Ccr c
LOT to 4K Ref> Vch>*4K Vch,a>,
A~2\ t\f 1 r\"*'\
_, , ...
Rtf. Vch.
(7.)
-29
-20
-11
Table Ford-5
Ford LOT
1
LOT to 4K
Ref. Veh. Cert. High to Low Cert.
(2) 4K Tests* Altitude Factors* dfs
HC CO NOx HC CO NOx
g/mi—
+34
+11
+48
+28
Predicted Results Pass-Fail
HC C° NOX 1982 1983
g/mi . HC CO NOx HC CO NOx
11.16 10 1.6 P P P P ? P
1.52 11 1.8 P P P F P P
P P P P P P
0.3 6 0.8 '
O T> P IT F P
1.6 15 1.8 P P P F F P
1.9 15 2.0 P P P F F P
0.2 1 0.8 P P P P P P
0.3 1 0.8 P P P P P P
Consents
Lowest dfs
Average Jfs (7)
One Vehicle
r^
Cj
Lowest QLS
Aver.iKC Ufs (2)
Lovest dfs
Average dfs C3y
"Not Yet Publicity Released.
-------
44
results, the technical staff concludes that the A engine with emission
control system 1 now has the ability to pass the 1982 standards, but
further development will be required to comply with the 1983 standards.
Emission control system 1 is a 49-state control system. Since the
Federal or 49-state HC standard of 1.7 g/mi is 0.7 g/mi higher than the
1983 proposed high altitude standard of 1.0 g/mi, it is not surprising
that it fails the 1983 proposed standards. Considering the development
time remaining for the 1983 MY, it is possible that this engine can also
be made to comply with the 1983 proposed standards. Also, engine A-2
with emission control system 2 now has the ability to meet both the 1982
and 1983 proposed standards.
Pass/Fail Analysis for the Ford A-2 LPT Engine
The A engine, equipped with emission control system 2, was represented
by five emission data vehicles and one durability vehicle. A method 2
analysis was used for this engine.
The hp/ETW ratio was 20% higher for the reference vehicle than for the
average hp/ETW ratio for the five emission data vehicles. The rear axle
ratio was 11% higher for the LDTs. The predicted results are 0.3 g/mi
HC, 6 g/mi CO and 0.8 g/mi UOx (see Table Ford-4). The technical staff
concludes that this engine has the ability to comply with the standard.
Pass/Fail Analysis of the Ford B, C & D-l LPT Engines
The B, C, and D engines with emission control system 1 are represented
by nine emission data vehicles equipped the D engine. Since the emission
control system and engine configuration for B, C, and D engines are
similar, the same model carburetor is used for all three, and the B and
C engines were certified in the same engine family in 1980, the technical
staff felt it would be appropriate to analyze these engines as a group
-------
45
using data from the D engines. No low mileage data meeting the criteria
discussed in section III were available for the B and C engines.
Dfs were available from three durability vehicles, but only two of the
vehicles were used in the analysis because the third had a NOx df greater
than 4.0. The altitude factors were developed from a LDV having a
hp/ETW ratio 11% greater than the trucks, but its axle ratio was 48%
lower. These data were used in a method 2 analysis.
The predicted results in Table Ford-2 indicate that these engines will
pass the 1982 standards using both the lowest dfs and the average dfs,
but will fail the 1983 standards using either dfs. This is a 49-state
emission control system. As explained in the analysis of the A-l engine,
the 1981 49-state low altitude HC and CO standards are significantly
higher than the 1983 high altitude standards. Considering the standards
these engines were calibrated to, and the development time remaining for
the 1983 MY, it is possible that these engines can also be made to
comply with the 1983 standards. Also, these engines were predicted to
be able to comply with both the 1982 and 1983 standards when used with
emission control system 2.
Pass/Fail Analysis of the B, C, D-2 Engines
The B, C and D engines with emission control system 2 were represented
by one emission data vehicle and three durability vehicles equipped with
the the D-2 engine. These data were used in a method 2 analysis. For
the reasons explained in the previous pass/fail analysis (B, C, & D-l),
these engines were evaluated as a group. As for engine A-2, the altitude
factors were developed from light duty vehicle data. In this case, the
hp/ETW ratio was one percent higher for the trucks, and the axle ratio
was 28% higher for the trucks.
The predicted results in Table Ford-2 indicate that these engines are
well below the standards. Based on these results, the technical staff
concludes that the B, C, and D engines with emission control system 2
have the ability to comply with the proposed standards.
-------
General Motors
Light-Duty Vehicles
GM has not made technical feasibility an issue in their comments on the
1982-1983 proposed high altitude regulations. GM described their high
altitude development program as follows:
Resulting test data from vehicles representing the broad
spectrum of General Motors passenger cars are displayed
in Figure 1. These data show average emissions at Denver's
altitude of 0.49 g/mi exhaust hydrocarbons, 6.7 g/mi carbon
monoxide, and 0.70 g/mi NOx. Those average emission levels
compare very favorably with the proposed 1982-1983 standards
of 0.57, 7.8, and 1.0 g/mi HC, CO, and NOx, respectively.
Clearly, insofar as General Motors passenger cars are concerned,
the purpose of the proposed regulations will be accomplished,
not in 1982, but in 1983 without any regulations [4 at 88].
EPA used a method 1 analysis to evaluate the capability of GM's
C-4 emission control system for altitude compensation. The technical
staff did not make an effort to predict the engine displacements and
emission control systems which GM would be using in the 1982-1983 model
years. Because GM characterized the data they presented as "representing
the broad spectrum of General Motors passenger cars," the technical
staff did pass/fail analyses only for those engine displacements for
which GM supplied high altitude test results and considered these data
as representative of GM's capabilities in complying with the proposed
high altitude standards.
Since GM indicated that dual bed catalysts would be required with their
C-4 system to comply with the 3.4 g/mi CO standard at low altitude in
1981 and 1982 [30 at 68-72], only 1981 durability vehicles with both
three-way and oxidation catalysts were used in this analysis.
-------
47
Pass/Fail Analysis of the GM 1.6L Engine
GM submitted high altitude test data from two 1.6L development vehicles.
As the predicted results in Table GM-1 show, this engine is projected to
fail the standards using either the lowest or average dfs.
It should be noted that the 1.6L engine has a CO waiver for the 1981 MY
and that the high altitude tests were conducted in September of 1979.
Because the 1.6L engine does not have a CO waiver for the 1982 MY, its
high altitude emission results were evaluated against the 7.8 CO standard.
Since these vehicles were tested in September of 1979, it is possible
that their low altitude CO emissions were above the 3.4 CO standard.
If this were the case, these vehicles would naturally have difficulties
meeting the 7.8 CO standard at high altitude. The predicted results in
Table GM-1 indicate that the 1.6L engine can comply with the 11 g/mi CO
standard using the lowest dfs. Using the average dfs from three durability
vehicles, the predicted results indicate the engine will fail CO. One
of the three vehicles has a CO df above 8.0 and several other vehicles
were line crossing the 3.4 CO standard. It is not surprising that
vehicles complying with the 7.0 CO standard at low altitudes would have
difficulty complying with a 7.8 CO standard at high altitude.
Considering the possiblity that the test vehicles had low altitude CO
levels above the 3.4 g/mi standard, the EPA technical staff concludes
that with the data available, it cannot predict the 1.6L engine's ability
to compensate for altitude.
Pass/Fail Analysis of the GM 2.5L Engine
GM submitted high altitude test data from two 2.5L vehicles which were
tested in July, 1979. These data were used in a method 1 analysis. The
predicted results in Table GM-1 indicate that these vehicles will pass
using the lowest dfs. Using the average dfs from three 1981 certification
durability vehicles, the predicted results indicate the 2.5L engine will
fail.
-------
Table CM-1
General Motors LDV
DISP.
*
Emission High Altitude Deterioration
Control System Test Results Factors
Predicted
Results
HC CO NCx HC CO NOx HC
1.6
2.5
3.8
4.3
4.4
4.9
-g/tni
F3C/AIR/3W/OC/EGR 0.28 6.64 0.42
FBC/AIR/3W/OC/EGR 0.46 4.95 0.7S
FBC/AIR/3W/OC/ECR 0.34 4.10 0.68
FBC/AIR/3W/OC/EGR- 0.36 3.46 0.71
FBC/AIR/3W/OC/EGR 0.52 7.90 0.56
F3C/AIR/3W/OC/EGR 0.35 3.27 0.64
Standard
4.9
High
FBC/AIR/3U/OC/EGR 0.36 2.8 0.60
Performance
CO
NOx
Pass-Fail
HC CO,,**
C07.8
NOx
Comments
g/mi
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
40
46
57
60
41
46
52
53
52
55
35
46
36
47
10
26
6
7
4
4
4
4
9
8
3
4
3
3
.7
.6
.6
.5
.4
.6
.7
.5
.4
.8
.5
.2
.0
.6
0.5
0.6
0.8
0.9
0.8
0.8
0.7
0.8
0.6
0.6
0.8
0.7
0.7
0.7
P
P —
? -
F
p ***
p ***
P — —
P
P
P
P
P
P
P
F
F
P
P
P
'P
P
P
F
F
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
p
P
Lowest dfs
Average dfs
Lowest dfs
Average dfs
Lowest dfs
Average dfs
Lowest dfs
Average dfs
Lowest dfs
Average dfs
Lowest dfs
Average dfs
Lowest dfs
Average dfs
(3)
(3)
(4)
(6)
(2)
(3)
(3)
-------
Table CM-1
(Cont.)
Emission High Altitude Deterioration
DISP. Control System Test Results Factors
HC CO NOx HC CO NOx
g/ml
4.9 . FBC/AIR/3W/OC/ECR 0.7214.8 0.63
Turbocharged
5.0 FBC/AIR/3W/OC/ECR 0.26 2.66 0.68
5.7 FBC/AIR/3W/OC/EGR 0.22 1.94 0.52
6.0 FBC/AIR/3W/OC/ECR 0.49 5.7 0.57
Predicted
Results
HC ' CO NOx
g/mi
0.87 17.3 0.7
0.90 17.0 0.7
0.29 2.7 0.7
0.40 3.8 0.8
0.24 1.9 0.5
0.34 2.8 0.6
0.66 5.8 0.7
0.91 12.8 0.7
HC
F
F
P
P
P
P
F
F
Pass-Fail
C011** C07.8
F
P
P
P
P
P
P
F
NOx
P
P
P
P
P
P
P
P
Comments
Lowest dfs
Average dfs
Lowest dfs
Average dfs
Lowest dfs
Average dfs
Lowest dfs
Average dfs
<2)
(9)
(9)
(3)
VO
* Not Yet Publicly Released.
** Engines with a CO waiver have a "P" or "F" in this column. Engines without a CO waiver have a "--" in this column.
*** 3.8L Chevrolet engine does not have a CO waiver.
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50
Considering the development time available since the July test date,
and the predicted results using the lowest dfs, the technical staff
concludes that the 2.5L engine will have the technical capability to
meet the proposed standards.
Pass/Fail Analysis of the 3.8L Engine
GM submitted high altitude test data from two 3.8L development vehicles
which were tested in July, 1979. Dfs were applied only from durability
vehicles with dual bed catalysts. These were all naturally aspirated
Chevrolet engines. The predicted results listed in Table GM-1 indicate
that this engine passes using either the lowest dfs or the average dfs
from four 1981 certification durability vehicles.
The technical staff concludes, that the, 3—&L pnginp haa rh^ ability to
compfy with the proposed" nigfi artftud*e standard's.
Pass/Fail Analysis of the GM 4. 3L Engine(s)
GM submitted test data from six vehicles equipped with 4.3L engines. GM
has two 4.3L engines, but did not identify which of these engines were
in the development vehicles. Deterioration factors from six 1981
certification durability vehicles were used in this analysis. Dfs from
both 4.3L engines were included in the average. The predicted results
show that this engine complies with the standards using either the
average dfs or the lowest dfs.
Based on the results from the method 1 analysis, the technical staff
concludes that the 4.3L engine(s) has the ability to comply with the
proposed standards.
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51
Pass/Fail Analysis of the GM 4. 4L Engine
GM submitted high altitude test data from two cars with 4.4L engines.
The predicted results in Table GM-1 indicate that this engine will not
comply with the proposed standards, regardless of whether the lowest dfs
or the average dfs of the two certification durability vehicles are
used. It should be noted that three durability vehicles met the criteria
for inclusion discussed in section 3, but one of these was not used r
because its projected CO df was a negative value according to the EPA
Certification Status Report of July 11, 1980.
At the high altitude hearing, GM stated that the 4.4L engines were
having a problem at high altitude because the range of authority was not
sufficient and went on to say that "it has been necessary to extend the
range and we expect that if we go back to altitude, that the car should
function satisfactory [4 at 107]."
Since additioaai- data, laawe? aet bee*t submitted for vehicles' which have
been modified by having their range of authority extended, the technical
staff does not have sufficient data to predict the pass/fail results of
this engine.
Pass/Fail Analysis of the GM Standard 4.9 Engine
GM submitted high altitude test data for three different 4.9L engines.
These included the turbocharged engine, the high performance engine, and
the standard 4.9L engine. This section is for the standard engine.
The technical staff did not have sufficient information to determine
whether the standard 4.9L and the high performance 4.9L are certified
within the same engine family or are certified separately. In this
analysis, dfs from three naturally aspirated durability vehicles with
4.9L engines were used in evaluating both the standard and the high
performance engine. The low mileage, high altitude test data from each
of these engines were evaluated separately, although with the same dfs.
-------
52
For the standard engine, the predicted results in Table GM-1 indicate
that this engine passes the standards using either the lowest or the
average dfs.
Pass/Fail Analysis of .the GM High Performance 4.9L Engine '?.'
GM submitted high altitude test data from two cars with the high performance
4.9L engine. Using the average or the lowest dfs from three 1981 certification
durability vehicles, which represented all 4.9L engines, except for
those with turbochargers, the predicted high altitude results for these
vehicles indicate they can comply with the standards.
Based on the predicted results listed in Table GM-1, the technical staff
concludes that the 4.9L high performance engine has the ability to
comply tf±tlnr fehfr- propose*- standards.
Pass/Fail Analysis of the GM 4.9L Turbocharged Engine
GM submitted high altitude test data from two vehicles with the turbo-
charged 4.9L engine. A method 1 analysis using the lowest or the average
dfs from two certification durability vehicles indicate that this engine
will not pass the standards.
In a written response to questions from the EPA panel at the high
altitude hearing regarding this engine, GM offers the following explanation
for the high emissions levels:
These vehicles were in a relatively early stage of develop-
ment when the tests were run, and we are confident that
emissions from current configurations of those turbocharged
engines would be appreciably lower. However, we have not yet
obtained high altitude emissions data on the refined systems
[11 at 3].
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53
The situation for this engine is similar to that for the 1.6L engine. •
GM has made two CO waiver requests for each of these engines. In its
waiver application for the 4.9L engine, GM indicated it was having
difficulty complying with the 3.4 CO standard at low altitudes. It's
possible that the vehicles tested at high altitude in July, 1979 were
not able to comply with the low altitude standards and in turn, would ^
also have difficulty complying with the high altitude standards for HC
and CO.
Because the technical staff has not reviewed high altitude data for any
other GM turbocharged engine with the C-4 emission control system, and
has not evaluated more recent development data for this engine, the
technical staff concludes that there is insufficient data on which to
base a judgement for this engine.
Pass/Fail Analysis of the 5.0/5.7L Engine
GM submitted high altitude test data from two cars with 5.0L engines and
two cars with 5.7L engines. GM has two different 5.0L engines and also
two different 5.7L engines, but it did not identify which engines were
in the development vehicles. Historically, the Chevrolet has certified
its 5.0 and 5.7L engines in the same engine family. For this analysis,
all GM durability vehicles with 5.0 or 5.7L engines which met the criteria
explained in Section 3 were included in the average df. Nine vehicles,
including Chevrolets and Oldsmobiles, were included in this average.
The same dfs were then used to evaluate both the 5.0 and the 5.7L engines,
although they were evaluated separately. The predicted results in Table
GM-1 indicate that the 5.0L engine will pass using either the lowest dfs
or the average dfs. Using the same dfs and the 5.7L engine high altitude
test data, the predicted results also indicate that this engine will
comply using either combination of dfs.
Based on the predicted results listed in Table GM-1, the technical staff
concludes that these engines have the ability to comply with the high
altitude standards.
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54
Pass/Fail Analysis of the GM 6.PL Engine
\ f
GM submitted high altitude test data from one development vehicle equipped
with the 6.0L engine. This car was tested in August, 1979. Using the
lowest dfs and the average dfs from three durability vehicles, the
predicted results in Table GM-1 indicate that this engine will.fail
using either the lowest dfs or the average dfs. .-•
GM has several options to improve the high altitude performance of their
C—4 emission control system. These include keep-alive memory, altitude
compensated spark timing, a manifold absolute pressure sensor, and
throttle position corrected by barometer. EPA is not aware of which
options, if any, were included on the 6.0L development vehicle.
Considering the development time remaining since the test date and
questions regarding the emission control system, the technical staff
concludes that it doesn't have enough information to predict the present
aFfiity erf" tfris~ engine to comply with the proposed standards.
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55
General Motors
Light Duty Trucks
Based on 1981 certification information, General Motors is expected to
market the following LDT engines in the 1982-1983 model years: ^
Displacement Emission Control
System
1. A 1
2. B 3
3. C/D 3
Pass/Fail Analysis of the GM A LDT Engine
The A engine is expected to be equipped with emission control system 1.
Since-ntv altitude; i actors were- available- fewr vehicles- rising- this LDT
engine, a method 4 analysis was used. Although this emission control
system is not exactly the same as GM's LDV control system, the technical
staff feels that its ability to compensate for altitude should be almost
as effective as the LDVs. Also, the light duty truck standards are
»
considerably less stringent than the light duty vehicle"standards. There-
fore, based on GM's high altitude data for their LDVs equipped with the A
engine, the EPA technical staff's judgement is that this engine will be
able to meet the proposed LDT standards.
Pass/Fail Analysis of.the GM B LDT Engine
This engine is expected to be equipped with emission control system 3.
Dfs from four durability vehicles and 4K test results from two emission
data vehicles were used in a method 2 analysis.
The altitude factors used in this analysis were calculated from LDV data.
As Table GM-2 shows, horsepower-to-equivalent test weight ratios for
the LDV was 19% higher than for the LDT emission data vehicles, but
-------
TABL.E •' Ctt-2
Generaljtotors LPT
HP/ETW RATIOS
AXLE RATIOS
Eaisslon
C/D
rol * e °* Ref- Veh< 2 * 2* Ref' Veh* Cert,! High to Low Cert.
em* (X 10 ) (X 10" ) (%) (X 10 ) (X 10 ) <%) 4K Tests* Altitude Factors* DF's* Predicted Rcsulta
HC CO JJOx HC CO NOx HC CO KOx
g/m^. — . g/mi
0.5 10 1.0
e . _, n c 1 10
08 4 15
Pass-Fall
1982 1983
KC CO NOx HC CO NOx
P P P P P P
Coinnents
No Altitude
Factors
Lowest dfs
Avg dfs (4)
Lowest dfs
Avg dfs (7)
Ul
Not Yet Publicly Released.
-------
57
the axle ratios were 21% higher for the LDTs. ' The predicted results in
Table GM-2 indicate that this engine will easily pass the standards. '
Pass/Fail Analysis of the GM C/D LPT Engines
v •
(
Engines C and D were grouped together because they have previously been
certified in the.same engine families. These engines are expected to be
equipped with emission control system 3. The dfs from seven durability
vehicles and the 4000 mile test results from one emission data vehicle
were used in a method 2 analysis.
The hp/ETW ratio for the reference vehicle was 5% higher than for the
certification LDTs, but the axle ratio for the LDTs was 21% higher.
The predicted results listed in Table GM-2 indicate that these engines,
with emission, control system 3.^, wiJLL. b.e_ ahlp> re\ ci^mp.ly uttrK thfe standards.
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58
Honda Mo tor Co . Ltd .
The technical staff assumes that the following engines and emission
control systems will be used by Honda in the 1982 and 1983 model years
Displacement System
A 1
B 2
C 3
The following statement was excerpted from the Honda submittal :
Honda Motor Co. Ltd. currently offers high-altitude
versions of most of their current vehicles. These
vehicles are manufactured on the production line and
offered economically to high altitude customers [14
at 1].
Honda baa useifaa "Mx Jet Controller" [1& &t 21} modification (air
aneroid) to the carburetor assembly in order to accomplish A/F ratio
control on their production vehicles for high altitude since 1977. The
potential effectiveness of this control, as demonstrated on the 1-.8L,
49-state vehicle adjusted for df, is shown in Table Honda-1. HC emissions
in the range of 0.18 to 0.28 gpm and CO emissions in the range of 5 to
6 gpm (with a new catalyst and EGR) are significantly below the interim
high altitude standards for the 1983 model year (0.57 HC, 7.8 CO). NOx
levels are also acceptable and below the 1*0 gpm standard established
for the 1983 MY.
This technology is considered by the technical staff to be transferable
to the other engines assumed to be marketed by Honda in the 1982 and
1983 model years.
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59
Table Honda-1
Honda Motor Co. Ltd.
High Altitude Emission Characteristics
With New Catalyst and EGR
[16 at 21]
1.8L 49rrstates-
5MT
1.8L 49^-states
3AT
lesc
Location
Low
Altitude
High*
Altitude.
Low
Altitude
High*
Altitude
CO
2.51
5.8
3.40
5.10
HC
g/mi
0.170
0.278
0.129
0.176
NOx
0.683
0.450
0.559
0.599
*With Air Jet Controller
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60
This technical assessment by method 1, of Honda's technical capability-
to comply with the 1982 and 1983 model year high altitude standards,
gives the technical staff confidence that Honda does indeed have the
required technological capability to comply with the interim high, altitude
standards in 1982 and 1983.
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61
International Harvester (.IH)
The technical staff assessed the technological capability of this
manufacturer for meeting the more stringent light-duty truck (LOT)
standards of 1.0 HC, 14 CO, and 2.3 NOx, considered for the 1983.MY, on
the basis of high altitude emissions data supplied by the manufacturer. .
LDT standards for the 1982 MY are more lenient at 2.0 HC, 26 CO, and 2.3
NOx. Since the technology considered here could be applied to meet the
less stringent 1982 standards, compliance with the 1982 standards is
considered assured if IH can comply with the 1983 standards.
The technical staff assumes that that the following gasoline engine
families and emission control systems will be marketed by IH in the 1982
and 1983 model years:
Displacement System
1." A 1
2. B 1
3. C 1
At the public hearing held in Denver, Colorado on March 5 and 6, IH was
requested to submit LDT high altitude data. These data were provided
and are shown in Table IH-1. These data apply to the 345 cubic inch
engine in the 5000 pound IW Scout Traveler. The emission control system
included AIR-OC-EGR, and is representative of 1977 technology [13 at
Attachment]. The high altitude emission data in Table IH-1 were developed
in 1977. The vehicles were tested at high (5000 pound) inertia weights.
Since the altitude data provided by IH were not of recent origin, the
technical staff used method 4 in determining IH's technical capability
to comply with the more stringent 1983 high altitude standards of 1.0
HC, 14 CO, and 2.3 NOx. IH has demonstrated that HC, CO, and NOx can
indeed be controlled at high altitude to the interim standard levels by
use of different carburetor modifications or adjustment strategies
(Table IH-1). As this capability was demonstrated in 1977 on the large
-------
62
Table IH-1
International Harvester
HIGH ALTITUDE TEST DATA OBTAINED AT
AUTOMOTIVE TESTING LABORATORIES (DENVER) ON
SCOUT LPT VEHICLES DURING JUNE. 1977
[13 at Attachment]
Vehicle #237 - Scout Traveler with: V-345 CID gas engine, 3-speed automatic
'• transmission. 3.54:1 final drive ratio. RLHP = 14.1
IW = 5000// Emission Control System: Air Injection,
Catalyst, EGR
HC
.51
.50
•54
.44^
.45
.47 .
.42
.42
.49
.49
Vehicle
HC-
.67
.71
.64
.60
.57
-'75 FTP
(g/mi)
CO NOx
7.16 1.35
6.43 1.24
4.40 1.43
4.^_ ... T.6T~
5.61 1.43
4.26 2.02
3.90 1.82
3.50 1.80
4.94 1.93
5.02 1.67
#203 - Scout Traveler with:
transmission, 3.73:1
IW = 5000# Emission
Catalyst, EGR
_ * 7 5 Tfrp ___
(g/mi) .
GO NOx
15.9 .92
15.9 1.01
12.6 1.22
8.49 1.66
6.38 1.55
Remarks
Fixed high altitude metering
Fixed high altitude metering
Switch in high altitude position
Switch in high altitude position
Switch in high altitude position
Remetered EGR
Recalibrated Accelerator Pump
Recalibrated Accelerator Pump
Metering Same as EM 93
Metering Same as EM 93
V-345 CID engine, 3-speed manual
final drive ratio. RLHP = 14.1
Control System: Air Injection,
Remarks
Fixed high altitude metering
Fixed high altitude metering
Switch in high altitude position
Carburetor Remetered
20, 30 mph shift points used
-------
63
Table
International Harvester
HC
.54
.48
.59
.60
.48
1 7 c "FTP -
(g/mi)
CO
5.4
5.58
6.35
7.75
6.32
NOx
1.81
2.04
1.54
1.52
1.80
(continued)
Remarks .,
Run without air injection divert ;on
Run without air injection divert on
Metering same as EM 92
Metering same as EM 92
Metering same as EM 92
decels
decels
* No df included.
-------
64
displacement C345 cubic inch) engine, tested at high (5000 pounds IW),
the technical staff concludes that this technology is also transferrable
to smaller displacement engines and lighter vehicles. In fact, the
modifications used for the 345 cubic inch engine at high altitude back
in 1977, demonstrate levels of emissions for HC and CO at high altitude
that are lower than some 1980 MY equivalent models at low altitude
conditions. -
-------
65
Jaguar-Rover-Triumph (JRT)
Light Duty Vehicles
Based on the CO waiver application from Jaquar-Rover-Triumph (British
Leyland), the assumed engine usage for the 1982 and 1983 model years is:
1.: 122 CID CLEFI/3W
2. 215 CID CLEFI/3W/EGR
3. 258 CID CLEFI/3W/AIR
4. 326 CID CLEFI/3W/3W
JRT submitted no high altitude data for any of these engines. They
have CO waivers for the 1982 model year for the vehicles using the 215
and 326 cubic inch engines.
Pass/Fail Ana-lys-is- e>f fehe- 12£ ei& Engtrreg
Method 3 was used to analyze the available data for this engine. Data
for this engine size were taken from durability vehicles for two engine
families, both of which were equipped with the same emission control
system and the same engine displacement. The system includes a closed-
loop electronic fuel injection system with a three-way catalyst. The
extrapolated 4000 mile certification test results were averaged as were
the deterioration factors. The deterioration factors representing the
lowest dfs were also examined. High-to-low altitude ratios were chosen
for an emission control system consisting of closed-loop electronic fuel
injection with automatic altitude compensation, and EGR.
No CO waiver was granted for the 122 CID engine, but the predicted
50,000 mile results shown in Table JRT-1 illustrate that in all cases it
passes the 0.57 HC, 7.8 CO, 1.0 NOx standards for light duty vehicles.
-------
Table JaguarrRpver»-Triumph-l
CID
122
215 CLEFI/3W/EGR
Emission Cert. High to Low ,i
Control System . 4K Data* Altitude Factors Cert dfs* ' Predicted Results
HC CO NOx HC CO NOx HC CO JlOx HC
;LEFI/3W 1.68 2.57 0.74 0.40
0.55
CO
7.34
7.34
NOx
0.45
0.45
Pass-Fail
**
HC C01
P ' »
P
C07.8
P
P
NOx
P
P
Comments
Average
Lowest d
1.68 2.57 0.74
0.57 12.32 0.42
CO Vaiver granted
Fails low altitude
CO standards
One vehicle
258 AIR/CLEFI/3W
No data-method 4
analysis
258 CLEFI/3W
1.68 2.57 0.74
1,02 10.83 0.84
One vehicle
fails low altitude CO'
standards
326 CLEFI/3W/3W
* Not Yet Publicly Released.
** Engines vith a CO vaiver have a "P" or "?"'. In this column. Engines without a CO waiver nave a "—" In this column.
CO waiver granted
No data-method A
analysis
-------
67
Pass/Fail Analysis of the 215 CID Engines
As with all the JRT engines, no emission data vehicle test results are
available in certification. Durability vehicle data were examined by
method 3 for extrapolated 4K. certification results and deterioration
factors. The control system includes closed-loop electronic fuel' injection,
a three-way catalyst, and EGR. High-to-low altitude ratios were developed
for this system which includes an automatic altitude compensation device.
The 4000 mile extrapolated certification durability emissions fail to
meet the 3.4 CO standard. Also, the predicted 50,000 mile results,
using the altitude ratios developed from the Nissan data for this par-
ticular control system, indicate that this engine fails to meet both the
1982 and 1983 high altitide CO standards. The predicted 50K results for
hydrocarbons and NOx meet the standards.
The fuel injection system employed on the 215 CID engine is the Lucas
Electronically Controlled" Ftrel Injection- System. Like the Bosch and
Lucas/Bosch systems, it is an air flow sensitive, pulsed, port injection
system with one injector per engine cylinder. The air/fuel ratio is
controlled near stoichiometry by the use of oxygen sensors in the exhaust
down pipes [28 at 6.1].
Statements made by Bosch [2 at Annex 5, p. 5] indicated that their
existing electronic fuel injection systems are capable of altitude
correction up to 8200 feet with the Lambda control system. In light of
this information, as explained in the factors section, the 2.57 CO factor
for this system, developed from the Nissan data, seems quite conservative.
Because the technical staff is not confident that one test point, which
indicates that CO emissions will increase by over 250 percent, is indicative
of the actual or typical compensating ability of this fuel injection system,
the technical staff concludes that a judgement on the 215 CID engine's
ability to comply with the proposed high altitude standards can not be
made.
-------
68
Pass/Fail Analysis of the 258 CID Engine
Two engine families are included in this displacement class. Both are
equipped with closed-loop electronic fuel injection and three-way catalysts
and one engine is equipped with an air pump. Neither engine has received
a CO waiver for the 1982 model year.
Very limited data are available for these engines, but JRT stated in a
letter [19 at 1] regarding the final rule making on the high altitude
standards that,
We are now at the point where we are confident of meeting a 7.8
gram CO standard at altitude on all but the 215 CID V-8 and the 326
CID V-12 engines. The 215 CID and 326 CID engine families were
granted waivers from the statuatory (sic) CO standards for 1981 and
1982.
No data were available for the AIR/CLEFI/3W engine and the one vehicle
that had- AuraK-ilit-y data~ £ar_ t-t»» CLEE1/3W ettgjjaa. failed, to meet the low
altitude CO standard. Therefore, a method 4 analysis was performed on
the 258 CID engine.
The fuel injection system employed on the 258 CID engine is the Lucas/
Bosch electronically controlled, pulsed, port injection system with one-
injector per cylinder. The primary control parameters sensed are air
flow and engine speed [28 at 08.01-1]. Bosch has claimed that their
Lambda control systems are self-compensating up to altitudes of 2500
meters (8200 ft.) [2 at Annex 5, p. 5].
Because of the conflicting information on the ability of this fuel injection
system to compensate for altitude, the technical staff can not make a
judgement on the 258 CID engine's ability to complywith the:standard.
Pass/Fail Analysis of the 326 CID Engine
The emission control system for this engine family includes closed-loop
electronic fuel injection and two three-way catalysts [5 at 53397].
-------
69
No data is.available to assess the capability of this engine to meet the
standards by methods one, two or three. A method 4 analysis was done,
but because of conflicting information on the fuel injection system, and
the absence of low; altitude certification data, EPA concludes that it
cannot make a judgement on the ability of the 258 CID engine to meet the
standards.
-------
70
Nissan
Light Duty Vehicles
EPA assumed that Nissan would market the following engines in 1982 and
1983 based on their CO waiver application:
1. 1.2L PAIR/OC/EGR
2. 1.4L PAIR/OC/EGR
3. 1.5L PAIR/OC/EGR
4. 2.0L FB*/CLEFI/EGR
5. 2.8L CLEFI/3W/EGR
Nissan did not have any 4000 mile data with a certification disposition
of pass certification for its 1981 emission data vehicles, but did
supply high altitude data on three vehicles. The technical staff assumed
this; was low mileage JaCa for method" I analyses. In addition» 1981
certification durability vehicle data were used for method 3 analyses.
Pass/Fail Analysis of the Nissan 1.2L, 1.4L, 1.5L Engines
Nissan's CO waiver request designated the 1.2L, 1.4L, and 1.5L engines
as their A-series engines. The EPA technical staff grouped these engines
together for this analysis because they are close in engine displacement
and are all equipped with a PAIR/OC/EGR control system and an altitude
compensated carburetor.
Two different pass/fail analyses were done on the 1.5L engine using
methods one and three. Nissan submitted high altitude data, for the
1.5L engine with the above control system, which EPA assumed to be low
mileage emission results. Using a method 1 analysis, average and best
case 1981 certification durability deterioration factors were applied to
this data and the system passed the 1982/83 HC and CO standards but
FB means "fast burn."
-------
71
failed NOx (see Table Nissan-1) . The NOx value did not meet the low .
altitude standard either, so it appears that at this stage of the develop-
ment process the system was not calibrated to the 1.0 NOx standard.
Extrapolated average 4K results from two 1.5L vehicles and average and
lowest case df's were applied to Nissan's- high altitude factors for the
PAIR/OC/EGR control system and were used in a method 3 analysis. This
data showed predicted results that passed the 1982/83 standards in all
cases. A maximum tolerable NOx altitude factor of 1.20 was calculated
(see PAIR/OC/EGR altitude factors section for explanation) . This
represents a sizable cushion for an increase in NOx emissions. EPA
concludes that Nissan has the technical capability to meet the 1982/83
standards with the 1.2L, 1.4L, and 1.5L engines.
Pass/Fail Analysis of the Nissan 2 . 0 L Engine
Tlae, -emission. ^•"Uro'i- system, for. t*"3 2~QI» engine- is™ expected to include
FB/CLEFI/3W/EGR. According to Nissan, an altitude compensator, for the
fuel injection system, will also be used [8 at 2] .
The method 3 analysis for this engine used Nissan data for the altitude
factor, although the EPA technical staff is not confident that CO
emissions will increase by over 250% as the data indicates. Statements
by Jaguar-Rover-Triumph on the Bosch L-Jetronic fuel injection system,
Volvo on the K-Jetronic, and Bosch statements on the two systems are not
in agreement with the results of the Nissan data. Nevertheless, even
using the altitude factors developed from the Nissan data, the predicted
results listed in Table Nissan-1 indicate that the 2.0L engine can
comply with the high altitude standards.
•: -. : ./.'... .:• ..-. .. ...r '..'. ..•••••
Pass/Fail Analysis of the 2.8L Engine
This engine is expected to be equipped with a CLEFI/3W/EGR emission
control system.
-------
. Table Nissan-1
Kissar. L1JV
CID
Emission High to Low v
Control Svstem 4K Data Altitude Factors Cert dfe* Predicted Results
HC CO NOx HC CO KOx HC CQ ' NOx ' HC CO NOx
1.2L,
1.4L,
1.2L,
1.4L,
2.0L
2.8L
**
PAIR/OC/EGR * * * 1.10 1.76 1.20
1.5L
PAIR/OC/EGR 0.36 5.1 1.59 Method 1
1.5L
FB/CLEFI/3W/EGR * * * 1.68 2.6 0.7
CLEFI/3W/EGR 0.52 5.4 0.35 Method 1
0
0
0
0
0
0
.33
.35
.43
.45
.42
.52
4
5
5
6
4
6
.7
.2
.5
.1
.3
.1
1.0
1.0
1.6
1.6
0.5
0.4
Pass-Fail
***
HC COU
P --
P ' —
P *»•»
P
P
P --
C07.8
. P
P
P
P
P
P
NOx
P
P
F
F
P
P
Comments
Lowest dfs
Average dfs
Lowest dfs
Average dfs
One vehicle
One vehicle
(2)
(2)
.* Not Yet Publicly Released.
** Maximum altitude factor which allows engine to pass.
*** Engines with a CO waiver have a "P" or "F" in this column. Engines pithout a CO waiver have a "—" in this column.
N>
-------
73
A method 1 pass/fail analysis was done on this engine* Nissan submitted
high altitude data for the 2.8L engine with the above control system. EPA
assumed these data to be low mileage emission results. 1981 certification
durability deterioration factors from one vehicle were applied to these
data and the system passed the 1982/83 standards for all three regulated
pollutants (see Table Nissan-1). The predicted results as listed in the
table indicate that this engine displays the technical capability to meet
these standards.
-------
74
Nissan
Light Duty Trucks
Based on 1981 certification data, Nissan is expected to market only one
light duty gasoline engine for their light duty trucks. The Nissan A
engine is expected to be available with emission control system 1. Data
from five California emission data vehicles and two durability vehicles
were used in a method 2 analysis. The predicted results listed in Table
Nissan-2 indicate that engine A easily complies with the proposed standards
for HC and CO using either the lowest or average dfs.
NOx altitude factors of 2.79 and 2.73 were used with the lowest dfs and
average dfs respectively. Power-to-weight ratios were not available
CN/A) for the vehicles from which the factors were developed and, therefore,
were not compared to the 1981 certifications LDTs.
Based on the predicted results listed in the table, the technical staff
concludes that engine A with emission control system 1 has the ability
to meet the proposed standards.
-------
TABU! 'tttssan-2
NIS3AH-LDT
HP/ETW RATIOS
AXLE RATIOS
N/A
. Veh. Cerf. High to Low Cert.
(%) 4K Toets.* Altitude Factors* DF's* Predicted Results
'0618*
HC CO MQjt
HC CO NOx
H/A
HC CO NOx
g/ml -------
Pass-Fail
1982 1983
HC CO NOx HC CO NOx
0.61
0.68
6.1 2.3
5.5 2.3
Comments
Lowest dfs
Avg dfs (5)
Not Yet Publicly Released.
Maximum altitude factor which allows vehicle to pass.
-------
76
Peugeot
The technical staff assumes that Peugeot will market the following
gasoline-fueled vehicle in the USA for the 1982 and 1983 MYs:
Displacemment System
A 5
Another engine could possibly be used in 1982 and 1983. The technical
staff is not certain of Peugeot1s marketing plans for engine B. Regardless
of Peugeot1s plans, the staff could not make a pass/fail determination
for engine B due to a lack of data.
For gasoline-fueled engine A with system 5, the technical staff is not
cognizant of high-altitude data required to develop factors for use in
methods 1, 2, or 3. Method 4 was, therefore, employed to assess the
technological capability for this emissian, control, system, ta comply with
the 1982 and 1983 interim high altitude standards.
Using method 4 (which in this case is method 3 except that some engineering
judgement was included in the selection of factors), the following
predicted results were determined for this engine:
0.38 gpm HC
7.0 gpm CO
0.58 gpm NOx
Since there was no better data available to assess this Peugeot case,
the technical staff has determined that Peugeot has the technological
capability to comply with the proposed 1982 and 1983 high altitude
emission standards.
-------
77
Toyota
Light-Duty Vehicles
EPA assumed that the following engines would be marketed in 1982 and
1983 based on information provided in Toyota's CO waiver request.
l.: 78.7 CID PAIR/OC/EGR
2. 88.6 CID PAIR/OC/EGR
3. 108.0 CID CLAIR*/3W/EGR
A. 134/144.4 CID CLAIR/3W/EGR
5. 168.4/156.4 CID CLEFI/3W/EGR
Pass/Fail Analysis of the 78.7 CID Engine
Analysis of this engine was accomplished by the third method for assessing
the tecnnrTcar al>ftfty Co meet tfie proposed" high altitude standards.
1981 certification durability vehicle 4000 mile extrapolated emission
results and deterioration factors were utilized. High-to-low altitude
factors were incorporated into the analysis for a system equipped with
pulse air injection, an oxidation catalyst, exhaust gas recirculation,
and an automatic altitude compensating carburetor. As explained in the
PAIR/OC/EGR factors section, a NOx factor was not used. The maximum
possible NOx ratio for the. predicted results to still meet the standard
is 1.16 times the low altitude 50K NOx emissions (see Table Toyota-1)•
This factor represents a sizeable cushion for a NOx increase.
The predicted results for HC and CO are well below the standards for
non-waivered engines. Therefore, the EPA technical staff concludes that
the 78.7 CID Toyota engine is capable of meeting the 1982 and 1983 high
altitude emission standards.
&
CLAIR means "closed loop air injection system".
-------
TABLE TOYOTA - 1
Toyota LDV
CTD EMISSION CCWreOI. SYSTEM
CERT. «K Data*
)IC CO NOx
HIGH TO LOW
ALTITUDE FACTORS
!1C CO
NOx
CERT OF'8
CO
NOx
PREDICTED RESULTS
1IC CO NOx
PASS-FAIL
HC CO ** CO
COMMENTS
73.7 PAIWOC/ECR
1.70 1.80 1.16***
0.51 4.73 1.00
P P 1 durability vehicle
88.6 PAIX/OC/ECH
1.70 1.80 1.22*** . |
0.42 5.57 1.00 p p p p l durability vehicle
108.0 CLAIX/3V/KCX
2.23*** 2.50*** 1.70*** |
2.23*** 2.79*** 1.58*** f
CO
Q.57 7.8 .1.00
0.57 7.8 1.00 '
P ~ P P Avcrago DFs {2>
Lowest DFs
U4.4 CUIR/W/KCR
2.68*** 3.63*** 1.41***
0.57 7.8 1.00 P
P P 1 durability vehicle
168.4
1.64 2.57 0.74
0.47 6.94 0.31 P — P P 1 durability vehicle
Sot Yet Publicly Released.
" EnilR*. wlch . «0 waiver have a "f" or "f" in this column. Engines without a CO waiver have » ",-•' In thia column
Kaxinun altitude {actor which allows vehicle to pass.
• • ^i'i»c'>-.-.v" •**'-'. ' .
-------
79
Pass/Fail Analysis of the 88.6 CID Engine
In the absence of 19.81 certification test data from emission data
vehicles, method 3, using extrapolated durability data, was employed to
predict the technical ability of these engines: to meet the. proposed high
altitude standards. HC and CO high-to-low altitude factors were used
for the control system which includes pulse air injection, an oxidation
catalyst, EGR, and an altitude compensating carburetor.
Like the 78.7 CID engine, a NOx factor was not used in the evaluation.
The maximum possible NOx factor in this case that would still meet the
NOx standard is 1.22 times the low altitude 50K result (see Table
Toyota-1).
The 50K predicted results for HC and CO are well below the standards
especially since this engine has received a CO waiver. The EPA technical
staff concludes, that the. S&.d GIB Toyota, gng-in^ is. capable of aeeting
the 1982 and 1983 high altitude emission standards.
Pass/Fail Analysis of the 108 CID Engine
As for all the Toyota light duty vehicle engines, 1981 durability data
for the 108 CID was evaluated in the absence of emission data vehicle
test results. The emission control system includes a closed-loop air
injection system (CLAIR) three-way catalyst and EGR with an altitude
compensating carburetor. No high-to-low altitude factors were developed
for this control system because no data were submitted by Toyota or the
other manufacturers. In the absence of these factors the average 4K
emissions were multiplied by the average and best case deterioration
factors. The high altitude standards for non-waivered engines were then
divided by these numbers to determine the maximum possible HC/CO/NOx
factors that would still meet these standards. In.the case of the
average deterioration factors, the altitude factors are 2.23/2.50/1.70
and in the case of the lowest dfs, the numbers are 2.23/2.79/1.58 (see
Table Toyota-1). These numbers represent relatively high ratios for all
-------
80
three pollutants. In the judgement of the technical staff, the only
ratio that may be troublesome is. the average CO value. A factor this
high for a control system such as this seems quite unlikely though,
especially with a closed-loop air system which should, according to
Toyota, effectively compensate for A/F fluctuation and produce a higher
conversion efficiency [29 at 8]. The EPA staff concludes that it is r
technically feasible for Toyota to pass the 1982 and 1983 standards with
the 108 cu. in. engine.
Pass/Fail Analysis of the 134/144.4 CID Engines
The 134 and 144.4 CID engines were considered.together as they have
previously been certified in the same engine family. As with the 108
CID engine, extrapolated 4K emissions and deterioration factors were
examined from 1981 certification durability data by method 4 for a
closed-loop^ air i»jeetio»~9ys-teiBr three—way catalyst;, and E€R- system
with an altitude compensating carburetor. Again, since no high-to-low
altitude factors were developed for this control system, 4K emissions
and deterioration factors were used to determine the maximum possible
altitude factors that would still meet the high altitude standards. For
HC, CO, and NOx the altitude factors are 2.68/3.63/1.41, respectively
(see Table Toyota-1). These ratios are higher than those projected for
the 108 CID engine with the same emission control system, especially the
CO factor. The predicted CO results for this engine is 32.4% lower than
the average predicted CO result for the 108 CID engine. This engine is
also equipped with the closed-loop secondary air control system which
should compensate for altitude [29 at 8].
EPA therefore, concludes that it is technically feasible for Toyota to
meet the 1982 and 1983 high altitude standards with the 134/144.4 CID
engine.
-------
81
Pass/Fail Analysis of the 168.4/156.4 CID Engine
These engines have also been analyzed together as they have previously
been certified in the same engine family. The system includes closed-
loop electronic fuel injection, three-way catalyst and EGR. The EFI
system also includes an altitude compensation device. The factors for
this emission control system were developed from data submitted by
Nissan [8 at 3] and are listed in Table IV-4. Analysis of the 1981
certification extrapolated 4k durability data and deterioration factors
indicates predicted 50K results that pass the 1982 and 1983 high altitude
standards (see Table Toyota-1). The design of the EFI system with high
altitude compensation, as with manufacturers with similar systems,
indicates that Toyota has the technical capability to meet these standards
with the 168.4/156.4 CID engine.
-------
82
Toyota
Light Duty Trucks
EPA assumed that the following engines would be marketed in 1982 and
1983 based on 1981 certification information.
1. A CID system 1
2. B CID system 2
Pass/Fail.Analysis of the A LPT Engine
A method four analysis was used to assess this engine's ability to meet
the standards. The emission control system judged capable of meeting
the standards for this engine is system one. No high-to-low altitude
factors were developed for this control system.
Extrapolated 4K emissions and deterioration factors were used to determine
the maximum possible high-to-low altitude factors that would still meet
the standards. These factors came out to be 11.05 HC, 12.30 CO, 3.50
NOx for 1982, and 5.52 HC, 6.62 CO, 3.50 NOx for 1983. These factors
are extremely high and indicate a large margin of safety for meeting the
standards in both model years. Based on these results, the technical
staff concludes that Toyota has demonstrated the technical capability to
meet the standards with the A engine.
Pass/Fail Analysis of the B LPT Engines
Method three was used to assess engine B and emission control system
two.
Predicted 50K emission results are well below the standards for both
1982 and 1983. These data indicate that Toyota has the technical
capability to meet these standards with the B engine.
-------
Table Toyota-2
Toyota LPT
HP/ETV RATIOS AXLE RATIOS !
Emission _ - „ . * ..,„.! * LDT to 4K. _ _ ,,,*,„,. , I * LOT to 4K
Control Re£- Vf ' *K Vch !•* - Kef. Veh. Rcf' V^h*4K Veh f" Ref. Veh. Cert. ' Jligh to Low
DIS?.* Systsx* (X 10) (X 10 )' (Z) (X 10 ) (X 10 ) (2) 4K Tests* Altitude Factors
HC CO NOx HC CO NOx
A 1 U.SS 12.30 3.50
5,SS 6.6*5 3.*$
a •> '17 4-fi/, * * . *
Cert.
dfs Predicted Results Pass-Fall
HC CO NOx HC CO,, CO^ NOx
g/mt 2.0 1.0 " U.
2.0 26 2.3 • P - P P
1.0 14 2.3 P - P P
Comments
One Vehicle. No
Factors Developed
for this System
One Vehicle
* Sot Yet Publicly Released.
** Kaximua Altitude Factors which Allow Vehicle to Pass.
00
to
-------
84,
Volkswagen
According to VW's CO waiver application.of July 1979, the 97 CID engine
was to be fuel injected for 1981 and 1982 if the waiver for their feedback
carburetor system were denied. Since the waiver was denied, a method 4
analysis was used to address the issues VW raised in their comments
concerning their feedback (Lambda-sond) fuel injection system.
VW currently has a CO waiver application in for their 1.46 L engine. VW
stated they would not market this engine if their waiver request was
denied [33 at 0.2J. The ability of the 1.46L engine to comply with the
standards was not assessed in this analysis because VW has not decided
if they will use the 1.46 liter engine.
VW made the following statements regarding their emission control systems
and their ability to comply with the proposed high altitude standards
for 1982-19&&
In model year 1982, Volkswagen and Audi will use lambda-
control technology on the gasoline fuel injection concepts
as well as carburetor concepts. Although the lambda-control
system is, in fact, able to compensate for changes in air
density, the EPA assumption that 'these emission control
systems are designed and calibrated for the full range of
altitudes where emission reductions are required* is not
absolutely valid for Volkswagen/Audi systems.
The entire control range for lambda-control systems is
required to compensate for the lambda-variations in part-
load to accurately operate the engine, compensate for
variations in production tolerances for fuel metering
systems and engine components, as well as the deterioration
during the useful life. If the system is forced to compen
sate for high altitude enrichment the system is required to
operate at its limit and cannot further compensate for the
variation stated above. Therefore, additional high altitude
corrections become necessary for vehicles to safely comply
with the appropriate standards.
Modification of those vehicles which utilize the lambda-control
system would require a complete replacement of the electronic
control unit and addition of an aneroid device sensing changes
in barometric pressure which would trip a micro-switch activating
alternate functions in the control unit for high altitude
-------
35
operation. This modification is expected to be expensive
and cannot be developed in time to apply to -the model year
vehicle affected by the proposed regulations. My simpler
modification, such as the application of devices external
to the control unit which would modify its function would
merely shift the entire fuel flow curve characteristics for .
the system and not expand the range of authority II at 6 &,7].
VW's lambda-controlled fuel injection system is the Bosch K-Jetronic
fuel injection system. Bosch has made the following statements about
their fuel injection systems:
For both existing systems K- and L-Jetronic altitude
compensations have been developed and were partially
introduced by some of our customers.
Fig. 7 shows an aneroid acting on the warm-up regulator
of the K-Jetronic by modifying the control pressure.
Fig. 8 shows an altitude compensation for the L-Jetronic
where an aneroid actuates a potentiometer which i&
-connected. ~ta the eLectxanics..-
No altitude correction is required with Lambda control.
The controlled range is designed such that no error exists
for altitudes up to 2,500 meters [8,200 ft.][2 at Annex 5,
p. 5]. .
Bosch's statement that the controlled range on their Lambda-controlled
fuel injection systems are "designed such that no error exists for
altitudes up to 2,500 meters [8,200 ft.]" contradicts VW's statements
that:
The entire control range for lambda-control systems is
required to compensate for the lambda-variations in part-
load to accurately operate the engine, compensate for vari-
ations in production tolerances for fuel metering systems
and engine components, as well as the deterioration during
the useful life. If the system is required to operate at
its limit and cannot further compensate for the variation
stated above. Therefore, additional high altitude correc-
tions become necessary for vehicles to safely comply with
the appropriate standards [1 at 6].
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86
VW's statements are placed further into question by Volvo's SAE Paper
entitled "Development of the Volvo Lambda-Sond System" from which the
following was taken:
HIGH ALTITUDE PEHFOBMANCE was evaluated in the Denver
region of the USA. Tailpipe CO measurements indicated
full compensation from 0 to 12,000 ft altitude.
'Results from representative CVS testing:
HC CO NOx
0 m (Volvo/Gothenburgl 0.16 2.15 0.39
ATL, Denver 0.31 2.86 0.32
The increase in HC, CO was caused by rich A/F during cold
start condition and poor performance of the manifold de-
pression limiting bypass valve 13 at 13]."
The Volvo Lambda-Sond system is a Bosch K-Jetronic fuel injection system
as is VW's. The Volvo data show that the system met the 1981 low
altitude emission standards when tested at high altitude in Denver. It
should be noted that these data were published early in 1977.
At the high altitude hearings it was brought up to VW that the Volvo
fuel injection system seemed to be similar to the VW system, yet had
compensation limits of sufficient range for meeting the low altitude
standards of 0.41 HC, 3.4 CO, 1.0 NOx. They were asked to address why
it wouldn't be possible to extend the limits of compensation for the VW
system, and what would be involved in doing so {4 at • 29.8-309.] . In their
final written submittal, W did not provide EPA with any insight as to
why their K-Jetronic fuel injection system would not perform as well as
the Volvo K-Jetronic fuel injection system at high altitude. Also, VW
was asked to provide data on their 1981 and 1982 systems [4 at 297 & 298]
Their response was as follows:
At this time only a limited amount of data is available
which is very preliminary in nature. The limitations
result from a restricted high altitude test capacity.
As a result of these conditions, 'Volkswagen has little
confidence in the data and feels that the data are
statistically insignificant.
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87
A program of vehicle measurement at altitude is beginning
and Volkswagen will attempt to provide data based upon
availability [emphasis added]J4 at 9],
The preliminary nature of the VW' data would not provide sufficient
grounds for the EPA technical staff to judge that V¥ is not technically
capable of meeting the standards even if the data had been provided. ~
Based on the statements and data from Volvo and Bosch (Bosch designed
the K-Jetronic fuel injection system) and the absence of data to support
VW's assertions, the EPA technical staff's judgement is that VW will be
able to comply with the proposed high altitude standards of 0.57 g/mi
HC, 7.8 g/mi CO, and 1.0 g/mi NOx with their Lambda-controlled fuel
injection system.
VW is not currently using a Lambda-controlled carburetor. In their CO
waiver application, dated. July-19>79^ YU indicated,they were, unable to
meet the applicable standards at low altitude with the Lambda-controlled
carburetor, therefore, this system's capabilities at high altitude were
not assessed. Also, .W indicated that the fuel injection system will be
available [5 at 53399].
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88
B. Diesel-Fueled Vehicles
Pass/Fail Analysis of Diesel-Fueled Vehicles
Light Duty Vehicles
General Motors, Peugeot, Volkswagen, Merecedes Benz, Volvo, Audi, and
International Harvester offer Diesel fueled vehicles in their product
mix for light duty vehicle and/or light duty truck applications. The
Diesel combustion process tends to produce low HC and CO emissions, and
the technical staff's judgement is that the interim high altitude
standards should not pose a problem for this category of engines. There
were not many comments from the manufacturers concerning this issue.
General Motors did comment that:
For Diesel engines, adjustments have a much smaller effect
on HC, CO and NOx compared to gasoline enginesk but can,
..reduce exhaust smoke [18 at 1],
In order to assess the ability of Diesel engines to comply with the
standards, the technical staff developed high/low altitude emission
factors from two distinct sources 19 at Appendix A and Appendix I] and
[10 at Task 1]. The data shown in Table Diesel-1 show that HC, CO and
NOx emissions are lower for the Mercedes Benz 300D at the high altitude
test site. This is explainable since this engine was apparently equipped
with an intake-air density compensator. The other high altitude test
engine shown in Table Diesel-1 was a prototype GM Oldsmobile Diesel.
Comparing the altitude factors for the Oldsmobile in Table Diesel-1 to
factors for the high-to-low altitude standards (high -s- low altitude
standard) of 1.89 HC, 2.3 CO, and 1.0 NOx, indicate that Diesel LDVs can
comply with the proposed standards without the need for adjustments.
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89
Table Diesel-1
Average Emission
Data from EPA Low Altitude
Test Site Compared to
High Altitude Test Site
[9 at Appendices A and I]
Mercedes Benz VIN-W 123 - 30QOD - C791
Lo Alt
Hi Alt
HC
CO
NOx
Comments
0.315
0.310
1.25
1.17
1.67
1.54
EPA-AA
ATL
Hi/Lo Alt. Factor C(T. 987 CO.
GM-Olds Diesel VIN 3W69N8M105364
HC
CO
NOx
Comments
Lo Alt
Hi Alt
0.510
0.669
1.45
1.76
1.78
1.42
EPA-AA
GM-Denver
Hi/Lo Alt. Factor (1.31) (1.21)
(0.79)
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90
Other FTP data, more recently developed, for five Diesel LDVs tested at
both EPA (for low altitude environment) and at the Automotive Testing
Laboratory (ATL) at Aurora, Colorado (5480 feet), are shown in Table
Diesel-2. These tests provide the following average high/low altitude
emission factors:
HC - 2.27
CO - 1.85
NOx - 1.02
These factors show some upward pressure on HC emissions and negligible
effect on NOx emissions. There is also an effect on CO. However, the
CO factor of 1.85 is off-set by the higher standard of 7.8 g/mi at high
altitude, which is calculated to be 2.3 times the low altitude standard
of 3.4 g/mi. Those LDV Diesels certifying (low altitude) at 0.25 g/mi
HC or below should comply with the interim high altitude standards.
Otherwise, aneroids, other fuel limiting devices, fuel rack .adjustments,
or injection tlmi tig mnAvf iga± ^rvn. np.t -t f>iy«^ are available to- the manufacturers.
In order to test this assumption that Diesel LDVs can comply with the
interim high altitude standards for 1982 and 1983, with only minor
adjustments, the technical staff applied the more conservative high/low
altitude factors of 2.27 HC, 1.85 CO, and 1.02 NOx to low altitude 1980
4K certification, average test results [32 at LDVs] on the CMC, Mercedes,
Peugeot, VW, Audi, and Volvo. The predicted results including dfs, are
listed below:
CMC Mercedes (49 States) Peugeot VW Audi Volvo
HC
CO
NOx
(NA)
0.71
3.86
1.68
(NA)
0.72
1.98
1.50
(TC)
0.54
1.98
1.49
(NA)
0.72
2.4
1.46
*
(TC)
0.49
2.5
1.0
(NA)
0.82
2.22
1.27
(NA)
0.91
2.40
1.73
(NA)_
0.66
2.53
1.70
*4K certification value interpolated from 1981 durability car data as
in method 3.
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91
Other FTP data, more recently developed, for five Diesel LDVs tested at
\ ' • •
both EPA (for low altitude environment) and at the Automotive Testing
Laboratory (ATL) at Aurora, Colorado (5480 f eet) t are shown in Table
Diesel-2. These tests provide the following average high/low- altitude
emission factors;
'<
. EC - 2.27 *'
CO - 1.85
NOx - 1.02
These factors show some upward pressure on HC emissions and negligible
effect on NOx emissions. There is also an effect on CO. However, the
CO factor of 1.85 is off-set by the higher standard of 7.8 g/mi at high
altitude, which is calculated to be 2.3 times the low altitude standard
of 3.4 g/mi. Those LDV Diesels certifying (low altitude) at 0.25 g/mi
HC or below should comply with the interim high altitude standards.
Otherwis-er, aneroids', ottrer frcel limiting devices, fuel rack adjustments,
or injection timing modification options are available to the manufacturers.
In order to test this assumption that Diesel LDVs can comply with the
interim high altitude standards for 1982 and 1983, with only minor
adjustments, the technical staff applied the more conservative high/low
altitude factors of 2.27 HC, 1.85 CO, and 1.02 NOx to low altitude 1980
4K certification, average test results 132 at LDVs] on the CMC, Mercedes,
Peugeot, VW, Audi, and Volvo. The'predicted results, including dfs, are
listed below:
GMC
(NA)
HC 0.71
CO 3.86
NOx 1.68
Mercedes
(NA)
0.72
1.98
1.50
(49 States)
(TC)
0.54
1.98
1.49
Peugeot
(NA) (TC)*
0.72 0.49
2.4 2.5
1.46 1.0
VW
(NA)
0.82
2.22
. 1.27
Audi
(NA) .
0.91
2.40
1.73
Volvo
INA).
0.66
2.53
1.70
*4K certification value interpolated from 1981 durability car data as
in method 3.
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92
Table Diesel-2
High to Low Altitude Emission
Factors Developed From 5 Diesel .
LDVs Tested at EPA (Ann Arbor, MI)
and Again at ATL (Aurora, CO) -
grams per mile [10 at Task 1]
Comments
Vehicle
VIN
HC
CO
NOx
Particulate
//Tests
EPA
ATL
(Lo)
(Hi)
Hi/Lo Alt.
EPA
ATL
(Lo)
(Hi)
Hi/Lo Alt.
EPA
ATL
(Lo)
(Hi)
Hi/Lo Alt.
EPA
ATL
(Lo)
(Hi)
Hi/Lo Alt.
EPA
ATL
Hi/L
(Lo)
(Hi)
o Alt.
Oldsmobile
n it
Factor:
Oldsmobile
n it
Factor :
V-W -Rabbit
ii it
Factor:
Peugeot
tt it
Factor:
Mercedes
ii it
Factor:
3R47P7M 0.
0.
(2.
3R47P9M 0.
1.
(2.
17A08154G& &.
386
966
50)
678
387
04)
217
0.588
(2.
504D90 3.
6.
(1.
123123120 0.
0.
(2.
71)
86
74
75)
250
588
35)
Average High/Low Altitude
1.
2.
(1.
1.
2.
(1.
49
57
72)
50
206
47)
1.
1.
(0.
1.
1.
(0.
e>. ?s i.
i.
(2.
3.
8.
(2.
0.
1.
(.1.
78
28)
84
88
31)
67
04
55)
Emission
1.
(1.
0.
0.
(1.
1.
1.
(1.
67
57
94)
44
29
90) ..
05
087
04)
94
98
04)
30
531
18)
1.
1.
(1.
0.
1.
(1.
0.
0.
(1.
0.
2.
2.
0.
0.
(1.
1
8
6)
6
0
3)
26
37
4)
90
43
7
4
5
2)
2 FTP
2 FTP
2 FTP
3 FTP
2 FTP
5 FTP
2 FTP
2 FTP
3 FTP
1 FTP
Factor
HC - 2.27
CO - 1.87
NOx - 1.02
Part. - 1.64
* 34 tests
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93
These results confirm that there could be some upward pressure on HC •
from Diesel LDVs at high altitude, and that some minor injection timing
or maximum fuel adjustments may be required to meet the high altitude
standard of 0.57 g/mi. The conservative high/low altitude factor of 1.02
NOx indicates that the manufacturers that certify at low altitude should
also conform to high altitude standards. The higher NOx values shown^.
here are to be expected since the NOx standard for 1980 MY vehicles was
2.0 g/mi. For the interim period of 1981 to 1984, Section 202(b)(6)(B)
of the Act provides that the Administrator may waive the 1.0 g/mi NOx
standard to a level not to exceed 1.5 g/mi upon petition of a manufacturer.
Light Duty Trucks
With respect to the LDT standards for 1982 and 1983, Nissan, who has
supplied Diesel engines to International Harvester, provided the following
statement [8 at 2]:
—t :. "" " *•
Because the amount of inlet air is reduced at high altitude
and excessive air cannot be obtained, an altitude compensator
(aneroid type compensator) will be required for the fuel in-
jection system at WOR operation. Furthermore, our simulation
test data indicates that HC and CO emissions are likely to
increase with altitude even at partial load operation. (The
HC and CO emissions during FTP increases 2.2 and 1.4 times
repectively.) Therefore, in order to control HC and CO emissions
at high altitude, it is considered that using only a compensator
is not enough, and recalibration of injection timing and EGR
will be necessary.
International Harvester has used a turbocharged engine for LDT applications.
This engine does have the capability to provide excess air, and the
statement by Nissan that "excess air cannot be obtained", does not
apply. Furthermore, it is currently accepted practice to install aneroid
controls on turbocharged engines for the sole purpose of preventing excess
smoke, during acceleration modes. This aneroid could also automatically
correct the maximum fuel setting for high altitude conditions.
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94
Nissan, in their submission, considered emission factors of 2.2 and 1.4
for HC and CO, respectively, for high altitude. The EPA technical staff
used the more conserative LDV factors of 2.27 and 1.85 for HC and CO in
establishing whether this engine would comply with the high altitude
standards. Application of these factors to 1980 MY certification test
results provided the following predicted results:
: 0.95 g/mi HC ('83 high altitude standard is 1.0 g/mi HC)
3.51 g/mi CO ('83 high altitude standard is 14.0 g/mi CO)
1.53 g/mi NOx ('83 high altitude standard is 2.3 g/mi NOx)
The technical staff assumes that the same basic Diesel emission control
systems used in the 1980 MY will also apply to the 1982 and 1983 MY CMC
and VW LDTs. The conservative high/low altitude factors developed for
the LDVs were applied to both the CMC and VW LDTs with the following
predicted results:
CMC VW
2.0 g/mi HC 0.73 g/mi HC
4.01 g/mi CO 1.85 g/mi CO
2.14 g/mi NOx 2.18 g/mi NOx
Both the VW Diesel and the Nissan 198TC Diesel, as used by International
Harvester, are considered by the technical staff to be capable of meeting
the high altitude standards for the 1982 and 1983 model years. Because
of upward pressure on HC, the CMC trucks will probably require modifications
which may include adjustments of injection timing or the maximum fuel
setting in order to comply with 1983 MY standards.
It is the determination of the technical staff, that both light duty
vehicles and light duty trucks powered by Diesel engines can comply with
the high altitude standards with minor adjustments or, effectively, by
addition of aneroid type controls. Particulate emissions were not
considered in this determination, but preliminary data on the five LDVs
-------
95
reported in Table Diesel-2 indicate that total particulate emissions may
*
be adversly affected by high altitude operation . About a 64% increase-
over low altitude values was noted. For those manufacturers that may have
a problem meeting a 0.6 g/mi particulate standard for the 1982 and 1983
model years at low altitude, use of an aneroid control or other advanced
technology may be the preferred strategy. This would allow the manu-
facturers to gain field testing experience in limited volume with advanced
controls in anticipation of the tighter particulate standard, 0.2 g/mi»
in the 1985 model year.
*
A high altitude particulate standard has not been established for the
1982-1983 model years [35 at 1450].
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96
VI. REFERENCES
1. Letter and enclosure to the Central Docket Section (A130). of EPA
from Wolfgang Groth (Administrator Emissions Regulations & Testing,
Volkswagen of America, Inc.). dated April 7, 1980.*
2. Letter and enclosure to the Director, Emission Control Technology
Division of EPA from Dr. -Ing Hanjorg, Manager, Robert Bosch GMBH,
dated December 30, 1977.
3. Grunde T. Engh and Stephen Wallman, AB Volvo, SAE Paper 770295,
February - March, 1977.
4. Transcript of Proceedings - United States Environmental Protection
Agency - In The Matter Of: Proposed High Altitude Emission Standards
for 1982 and 1983 Passenger Cars and Light Duty Trucks. auA Proposed
'ftigh Altritade PerftMiiKtmre MjagtHteirC Regulations, and ITigfr Altitude
Emission Standards for 1984 and Beyond Passenger Cars and Light
Duty Trucks, dated March 5, 1980.
5. Federal Register, Volume 44, No. 179, September 13, 1979.
6. Letter and enclosures to Mr. Michael P. Walsh (Mobile Source Air
Pollution Control of EPA) from D. A. Jensen (Automotive Emissions
and Fuel Economy Office of Ford), dated April 30, 1980.
7. Letter and enclosure to Mr. Douglas Costle (Administrator of EPA)
from C. M. Kennedy (Federal Government Affairs of Chrysler) dated
April 7, 1980.
8. Letter and enclosures to the Public Docket (.Central Docket Section
of EPA) from Teruo Maeda (Engineering Office of North America of
Nissan) dated April 8, 1980.
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97
9. 1977 EPA - Industry Light Duty Diesel Correlation Program, EPA
Report CORP 7801-RL, April 1978.
10. EPA Contract 68:03-2891, Basic Testing Support to ECTD, Task 1,
Effect of Altitude of Emissions of Diesel Powered Light Duty
Vehicles. (Preliminary data, July 1980.)
11. Letter and enclosure to Mr. Michael P. Walsh (Mobile Source Air
Pollution Control of EPA) from T. M. Fisher (Automotive Emission
Control of GM) dated April 7, 1980.
12. Diesel and Gas Turbine Progress, July, 1980.
13. International Harvester letter to USEPA, Central Docket Section
(A-79-14), April 3, 1980, "Comments on EPA's Proposed High-Altitude
Emission Standards for 1982 and 1983 Model Year LDVs and LDTs
when Sold for Principal Use at Altitudes above 4000 Feet."
14. Honda Motor Company, Ltd. submission to USEPA Central Docket
Section (A-79-14), "on the proposed high altitude regulation
on high altitude performance adjustment regulation," April 4, 1980.
15. Letter to Mr. J. McFadden (Emission Control Technology Division of
EPA) from Mr. M. Yamaki (Honda Motor Co., Ltd.), dated.December 18,
1979.
16. "Research and Development of the Caruburetor for the CVCC Engine,"
Tasuku Date and Toshio Nomura, Honda, SAE Paper 800507, February
25-29, 1980.
17. Federal Register, Vol. 45, No. 107, June 2, 1980, Notices.
18. "General Motors Comments on EPA NPRM for Submission of Altitude
Performance Adjustments for Motor Vehicles," March 3, 1980.
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93
19. Letter to Mr. M. Walsh (Mobile Source Air Pollution Control of
EPA) from Dianne Black (Emissions Certification of Jaguar-Rover-
Triumph, Inc.), dated April 2, 1980.
20. Federal Register, Vol. 45, No. 17, January 24, 1980, Proposed
Rules.
21. Federal Register, Vol. 45, No. 22, January 31, 1980, Notices.
22. EPA Test Report, 1980 Fuel Economy Program, 49 State Test Car
List - Trucks, March 28, 1980.
23. Federal Register, Vol. 44, No. 179, September 13, 1979, Notices.
24. Federal Register, Vol. 45, No. 17, January 24, 1980, Proposed
Rules.
25. "Supplementary Comments of AMC on the Notice of Proposed Rule-
making on High Altitude Emissions Standards for the 1982 and 1983
Model Year Light Duty Vehicles," Letter to the EPA Central Docket
Section (A-94-14) from K. W. Schang, AMC, dated April 7, 1980.
26. Personal communication with R. Wilcox (EPA), July 28, 1980.
27. Letter and enclosures to the EPA Central Docket Section A-130
from J. Kawano, Toyota Motor Company, Ltd., April 7, 1980.
28. Application For A Waiver of 1981 And 1982 Carbon Monoxide Emission
Standards, British Leyland Cars, Ltd., June 1979.
29. "Development of Closed Loop Secondary Air Control Three-way
Catalyst System," T. Toyoda, Y. Yamakawa, T. Inove, K. Oishi, and
K. Hattori, Toyota Motor Co., Ltd., SAE Paper 800399, February, 1980.
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99
30. Transcript of Proceeding - Environmental Protection Agency - In
the Matter of: 1981 and 1982 Emission of Carbon Monoxide Waiver
Hearings, dated July 9, 19.79, by Acme Reporting Company.
31. Letter to Michael P. Walsh (EPA) from T. M. Fisher (GM), dated
April 7, 1980.
32. Federal Register, 1980 Certification Test Results, Light Duty
Vehicles. (to be published)
33. Application for Waiver of the 1981 CO Emission Standard for Light
Duty Vehicles, Volkswagenwerk AG, May 1980.
34. Federal Register, Vol. 45, No. 115, June 12, 1980.
35. Federal Register, Vol. 45, No. 45, March 5, 1980.
\
36. U"Passenger Car and Light Truck Fuel Economy Trends Through 1980,"
by J. D. Murrell, J. A. Foster, and D. M. Bristor, SAE Paper 800853,
June 9-13, 1980.
37. Internal Combustion Engines, third edition by Edward F. Obert,
International Textbook Company, Scranton, PA, 1968.
38. Emissions from Combustion Engines and Their. Control, by D. J. Patterson
and N. A. Henein, Ann Arbor Science Publishers, Inc., 1972.
39. Combustion Engine Processes, by Lester C. Lichty, McGraw-Hill Book
Company, 1967.
40. The Internal Combustion Engine, Second Edition, by C. Fayette Taylor
and Edward S. Taylor, International Textbook Company, Scranton, PA, 1948.
41. Heavy Duty Fuel Economy Program Phase II-Evaluation of Emission
Control Technology Approaches, EPA Report No. EPA-460/3-77-010, July 1977.
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