SUffTARY AND ANALYSIS OF CONTENTS
ON THE
NOTICE OF PROPOSED RULFAKIMG
FOR
HIGH-ALTITUDE EMISSION STANDARDS FOR 1982 Ml B83
MODEL YEAR LIGKT-DUIY MOTOR VEHICLES
ENVTOffNTAL PROTECTION AGENCY
OFICE OF AIR, NOISE, AND RADIATION
OFFICE OF F13BILE SOURCE AIR POUUTICri
OQOBE
-------
SUftlARY AND ANALYSIS OF OTENTS
ON THE
NOTICE OF PROPOSED RULB1AKING
FOR
HIGH-ALTITUDE EMISSION STANDARDS FOR 1982 AND 1983
MODEL YEAR LIGHT-DUTY MOTOR VEHICLES
ENVIRONMENTAL PROTECTION AGENCY
OFICE OF AIR, NOISE, AND RADIATION
OFICE OF MOBILE SOURCE AIR POLLUTION CONTROL
OCTOBER 1980
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IMPORTANT NOTICE
EPA has recently decided to delay the implementation of more
stringent low-altitude standards for light-duty trucks (LDTs) from
1983 to 1984. Since the high-altitude LOT standards are based on
the levels of the applicable low-altitude standards, this decision
also affects the stringency of the 1983 high-altitude standards.
This Summary and Analysis of Comments was completed prior to the
postponement; therefore, the analyses presented here were done
under the assumption that LDTs would comply with more stringent
standards in 1983. Although the LOT high-altitude standards which
were originally proposed for 1982 will now also be applicable in
1983, the conclusions contained in this document remain valid and
EPA has chosen not to revise the analyses in order to prevent an
unnecessary delay in promulgating the interim high-altitude stan-
dards.
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Commenters and Speakers on the
Proposed High-Altitude Motor Vehicle Standards
Congressman Alan Simpson
Congressman Gary Hart
Recreation Vehicle Industry Association
Ford Motor Company
General Motors Corporation
Motor Vehicle Manufacturers Association
Chrysler Corporation
Renault, USA
Colorado Department of Highways
Subaru of America, Inc.
Colorado Open Space Council
National Automobile Dealers Association
Welling Ford Sales, Inc.
Nissan Motor Company
Jaguar Rover Triumph, Inc.
U.S. Technical Research Company
Colorado Department of Health
Toyota Motor Company
Mr. B. Jay Welling
South Dakota Department of Health
Congressman Timothy Wirth
Congresswoman Patricia Schroeder
Volkswagen of America, Inc.
American Motors Corporation
International Harvester
Mr. Steve Schweitzberger
Mr. Richard Becker
Utah Department of Health
Honda Motor Company
Ray Shellabarger, Chevrolet, Inc.
Zeiger Enterprises
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Table of Contents
Issues Page
Important Notice.
Commenters and Speakers on the
Proposed High-Altitude Motor Vehicle Standards ii
Table of Contents iii
A. Standards 1
B. Technical Feasibility 13
C. Adequacy of Existing High-Altitude Test facilities ... 35
D. Selective Enforcement Auditing 47
E. High-Altitude Certification 57
F. Number of Certification Vehicles 73
G. Economic Impact 78
H. Environmental Impact 91
I. Leadtime 101
J. Exemptions 110
K. Model Availability 120
L. EPA's Legal Authority 123
M. Parameter Adjustment 133
N. Fuel Economy 137
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A. Issue: Standards
Summary of Issue
1. Light-Duty Vehicle. EPA derived the light-duty vehicle
standard (which called for a maximum 90 percent reduction from
a 1970 high altitude baseline fleet) from a limited sample of
high mileage vehicles tested by the MVMA. Because this limited
and older sample could not be construed to have equal results
with a true 1970 high-altitude baseline, certain" controversial
mathematical procedures were used on this data to obtain an
estimate of the true baseline figure. Also, EPA did not propose
any high-altitude counterpart to the 1982 CO and NOx waivers for
low altitude.
2. Light-Duty Truck. EPA derived the light-duty truck
standard beginning with 1969 low-altitude fleet data and used the
MVMA light-duty vehicle test data to estimate the altitude effect.
While this approach was recognized to be far from ideal, it seemed
the only rational method given the dearth of data available at the
time.
Summary of Comments
The industry collectively disputed the procedures used in the
derivation of the LDV and LDT standards. The criticism of the LDV
derivation involved the question of the proper manipulation of the
data; the criticism of the LDT derivation also included a challenge
of the propriety of the assorted data which were used.
Major Subissues
1. Light-Duty Vehicle. Most of the manufacturers who
commented on the subject supported the position of the MVMA who
criticized EPA's "misapplication" of their data. Specifically,
MVMA argued that their fleet was statistically representative
(something about which EPA had earlier doubts), but that EPA should
have multiplied the ratio of the high-to-low altitude emissions
found from the test data by the low-altitude baseline which hope-
fully would provide an estimate of the true high-altitude base-
line. A 90 percent reduction then yields the high-altitude stan-
dard. Rather, EPA "erroneously" added the absolute difference of
the high- and low-altitude data to the true .low-altitude baseline.
MVMA, as well as several manufacturers (AMC, Toyota, Peugeot,
and Jaguar), also pointed out that EPA had not proposed any CO or
NOx waiver standards to parallel those permitted by the CAA. Not
to do so would contravene the act. Peugeot also complained that
the evaporative emission standard was too tough and that the MVMA
fleet itself was unrepresentative because it contained no diesel
vehicles.
2. Light-Duty Truck. Again the industry as a whole echoed
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the MVMA criticisms. MVMA had four major complaints with the EPA
methodology. First, as with the LDV, they felt that EPA should
have used a ratio approach rather than an absolute difference in
extrapolating the low-altitude baseline to high altitude. Second,
they objected to EPA's use of a 1969 instead of 1970 baseline fleet
which was not even representative of the LDT sizes. Third, they
objected to the use of the LDV data from their study to extrapolate
the baseline from low altitude to high altitude. Fourth, they
capped off their criticism by claiming that EPA's formula gave
nonsensical results.
Ford and Chrysler went on to recommend that EPA abandon the
LDT standard until such time as it had a representative 1970 fleet
from which to obtain high- and low-altitude comparison data.
Chrysler also questioned if EPA's use of LDV data to derive the
LDT standard was legal in view of the U.S. Court of Appeals ruling
in International Harvester vs. Ruckelshaus in which the court
forbad EPA from treating LDT the same as LDV and thus giving them
the same standards.
Analysis of Comments
1. Light-Duty Vehicle. Certain criticisms can be dismissed
at once; others require greater analysis. First, Peugeot claimed
that the evaporative emission standard was "too tough." Perhaps it
is for Peugeot, but it is nonetheless correct. The MVMA study
verified the EPA theoretical prediction for the evaporative emis-
sion baseline at high altitudel/ and subsequently supported the 2.6
g/test SHED requirement. With EPA's prediction thus substantiated
by an experimental program conducted by industry, little attention
need be paid to Peugeot unsupported claim.
Peugeot also claimed that the 1970 baseline fleet that was
used was not representative because it did not contain a diesel
vehicle. This is wrong. In 1970, less than one-tenth of one
percent of the LDVs sold were diesel. Hence, they represent a
negligible influence on the baseline and even one vehicle in the
MVMA fleet of 25 would grossly over-represent diesels.
Several manufacturers and MVMA pointed out EPA's failure to
provide CO and NOx waiver standards for 1982 to parallel those for
the statutory low-altitude standards. This is an excellent point.
This final rule will include waiver standards. The exact levels of
the standards will be discussed along with EPA's rebuttal to the
industry objections to EPA's approach to the derivation of the
standards.
For the LDV standard, the single remaining complaint is that
the EPA applied an additive correction for altitude to the recog-
nized 1970 fleet baseline rather than applying a multiplicative
factor to get an estimate of the 1970 high-altitude baseline which
is not available from data. The Clean Air Act (202(f)) requires
that the high-altitude emissions reduction from the 1970 high-
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altitude emission level be no greater than that required at low
altitude. Inasmuch as the corresponding low-altitude regulations
for LDV (202(b)) require a 90 percent reduction from the 1970
baseline, this same reduction (or less) is also required for high
altitude LDV standards. The basic information which is required
is a high-altitude emissions baseline from a certification fleet
of 1970 vehicles using the 1975 FTP. Such information is not
available.
However, data do exist which allow the high-altitude base-
line to be estimated and thus the standards to be found. These
estimates can be obtained in two ways: 1) by obtaining a well-
tuned 1970 vehicle high-altitude baseline and applying a 90 percent
reduction to these emissions to establish the 1982-83 standards,
and 2) by generating a high-to-low altitude correlation and using
this to adjust the generally recognized low-altitude baseline to a
high-altitude equivalent. The former approach is most similar to
the ideal method if confidence can be gained that the test fleet
(1) is representative, (2) is in compliance with the corresponding
1970 low-altitude standards, (3) properly accounts for deteriora-
tion, and (4) is tested with the relevant (1975) FTP. If these
conditions cannot be met, then the latter procedure may offer
greater confidence.
These alternatives were first discussed by Miriam Torres in a
memorandum to R. Maxwell on July 24, 1978.* On the basis of the
data available to her at the time, she recommended the latter
approach which, as she saw it, involved the use of a ratio of
high-to-low altitude emission performance which would be applied
to the low-altitude baseline to establish a high altitude base-
line. There are other possibilities, of course, including the
procedure used by EPA in determining the proposed standards. Ms.
Torres' preference for the high-to-low altitude correlation rests
largely in the lack of confidence that the high-altitude data
available then was adequate and appropriate (being based upon the
obsolete 1970 FTP and untuned, less than new condition vehicles):
The most important reason for preferring the ratio method
(i.e., a high-to-low altitude correlation) is that it is not
necessary to determine what high-altitude emission levels
would correspond to the low-altitude emissions that were
determined for the 1970 model year baseline under the CVS-CH
procedure. This correspondence would be necessary in order to
meet the Clean Air Act requirement that the high-altitude
emissions reduction be no greater than that required at low
altitude. No study has been conducted where the same set of
* This document was referred to several times in the comments as
evidence that EPA officially supported a ratio approach. However,
a memorandum from a branch member to the branch chief does not
constitute agency policy.
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vehicles was tested in both high- and low-altitude cities and,
therefore, there is no assurance that a proportional emissions
reduction would be achieved (emphasis added).
With the advent of the recent MVMA data, this concern is
largely overcome if that data can be accepted (1) as representa-
tive, (2) in compliance with the corresponding low-altitude stan-
dards, (3) with deterioration properly accounted for, and (4)
with the relevant (1975) FTP used. Indeed MVMA presents strong
arguments that their data are indeed valid and representative. If
so, then a 90 percent reduction would lead to high-altitude stan-
dards of 0.3 gm/mile HC and 2.1 gm/mile CO, which are far below the
proposed values. Hence, the proposed standards apparently repre-
sent a less severe criterion than the corresponding low-altitude
standard. The uncertainties in the baseline nonetheless weigh
against the imposition of these values. For instance, MVMA
attempted to validate the test data by comparing the low-altitude
portion with the original low-altitude certification data. This
led to only marginal agreement with HC, the two numbers being about
one standard deviation apart. Thus, the MVMA HC result appears
genuinely low at least at low altitude for which the comparison was
made. But if the high-altitude data is considered to be a roughly
correct baseline (but because of small sample size, partially
deteriorated or worn condition of the vehicles, etc., an element of
uncertainty exists), how then to adjust the above result in a
reasonable manner, recognizing that excessive conservation will
result in a standard too lax?
The MVMA data can be utilized to adjust the baseline using a
correlation method (method 2). The idea here is to find a correc-
tion for altitude (i.e., the correlation) and apply it to the
generally accepted low-altitude values which are higher than the
MVMA values. This would result in a new baseline for high altitude
that is above the raw MVMA value.
One correlation method, and the one that was used by EPA in
deriving the proposed standards, applies an additive constant to
the generally recognized low-altitude baseline values (the 1970
standards corrected to account for the effects of the current, 1975
FTP) to arrive at the high-altitude baseline. This additive
constant is obtained from the difference in the high- and low-
altitude data.
The other correlation method is the use of ratios (high-
altitude data/low-altitude data) as advocated by Miriam Torres and
MVMA. MVMA supported their position by heavy reference to Ms.
Torres' work. Ms. Torres, in turn, supported her position with two
observations: (1) ratios vary less than the emissions themselves
and (2) deterioration and maladjustment have less effect on ratios
than on emissions. The second of these is irrelevant to the MVMA
data as that fleet was carefully tuned and, indeed, partially
renovated. The first proves incorrect for the MVMA data as the
following summary of that data shows.
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f rejected
EPA 77.9p
High-Altitude
MVMA 64.4
High-Altitude
•H
0
CO
C
o
•H
CO
w
•H
EPA 34
Low-Altitude
MVMA
Low-Altitude
Projected*
EPA
Emissions
Consequence
Characteristic Curve
43.9
MVMA
Emissions = 43.9
Consequence
EPA
Altitude
Effect
(16%)
MVMA
Altitude
Effect
(16%)
i
Ul
(Rich) 14.7 (Ideal)
Air/Fuel Ratio
(Lean)
* Necessarily equal to the MVMA emissions consequence (= 64.4 - 20.5 or 43.9 gm/mile) if the
EPA altitude effect is taken to be equal to the MVMA altitude effect (very nearly true for the
16 percent change due to altitude over the plausible range of air/fuel ratios).
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/Std. Deviationx
Method Mean Mean
HC CO HC CO
1. Ratio 1.60 3.47 0.19 0.45
2. High-altitude 4.47 64.45 0.21 0.37
absolute level
3. Low-altitude 2.851 20.45 0.24 0.40
absolute level
The differences in the normalized standard deviations do not
appear significant. The ratio method operates with a marginally
better variation in HC, but worse variation in CO than does the
absolute difference method which utilizes the data in rows 2 and 3
in the table. Thus, while these two methods for correlation
obviously result in different high-altitude baselines and, hence,
standards, they cannot so easily be criticized on the basis of
variability.
Finally, MVMA submitted to EPA some late data (having asked
for an extension of the comment period) which by the ratio method
again, they attempt to demonstrate how actual, more or less cur-
rently controlled vehicles (1976, 1978) change with altitude
differently than the EPA high-altitude standards require them to
do. EPA finds these data unpersuasive. The issue is to determine
a 1970 baseline and, therefore, it is necessary to see how 1970
vehicles vary with altitude, since vehicles produced in different
model years have different emission characteristics. In fact,
these MVMA data are also irrelevant with regard to the issue of
technical ability to achieve the standards because the vehicles
tested were under no requirement to reduce high-altitude emissions.
The 1977 model year was specifically avoided.
EPA's decision to use the absolute difference method is based
upon a recognition that a multiplicative approach, such as the
ratio method, tends to exaggerate an otherwise modest error in the
high-to-low altitude correlation which might appear as a result of
the use of a fairly small sample (25 vehicles). The additive
approach ought to avoid this concern.
A further argument, based upon a consideration of the chem-
istry involved, independently supports the additive approach. The
argument will be presented for CO, the pollutant of greatest
concern to the manufacturers; it is equally valid for HC. The
slope of CO vs. air/fuel ratio is very linear on the rich side of
stoichiometry, the typical running regime of weakly controlled
vehicles (i.e., 1970). This is shown in Figure 1. The generally
recognized CO emissions factor for the 1970 low-altitude fleet is
34 gm/mile. The MVMA fleet obtained 20.5 gm/mile at low altitude
and 64.4 gm/mile at high altitude. These are also shown in Figure
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1. The air/fuel ratios between the MVMA data points must differ by
16 percent due to the altitude effect on air density. The actual
low altitude air/fuel ratios for the general fleet and the MVMA
fleet are not known; however, the MVMA fleet as seen in Figure 1 is
necessarily more lean than the general fleet at each altitude.
From the figure, it is apparent that a change in stoichiometry
due to altitude leads to a nearly constant change in the emissions
regardless of the initial value. That is, for a given altitude
effect (i.e., change in air/fuel ratio), there is a constant change
in the emissions consequence, regardless of the starting point.
Thus, the emissions effect is clearly additive.
Criticism that EPA failed to account for the CO and NOx waiver
portions of the standards is well founded. Again, the question
arises how best to account for this. At low altitude the waiver
granted under 202(b)(5) permits the governing CO standard to go
from 3.4 gm/mile to 7.0 gm/mile during MY 1981-82. Once again, the
derivation of a high-altitude analogue requires a decision on the
choice of methodology. Similar reasoning to the preceeding dic-
tates the utilization of the absolute difference approach. Hence,
the CO waiver standard should be 7.8 + (7.0 - 3.4) = 11.4 gm/mile,
or, rounding to two significant figures, 11 gm/mile. The NOx
waiver from 1.0 gm/mile to 1.5 gm/mile for MY 1981-1984 diesel
vehicles which may be granted under 202(b)(6) of the Clean Air Act
as amended (1977) will also be available for high-altitude vehi-
cles. Even though NOx emissions for a particular vehicle are
generally lower at high altitudes, the Clean Air Act prohibits EPA
from establishing high-altitude standards which are numerically
lower than corresponding low-altitude standards. The diesel NOx
waivers have been determined on an engine family basis, and thus
any engine family which is granted the NOx waiver at low altitude
will also have the waiver at high altitude.
2. Light-Duty Truck. MVMA's complaints about the proposed
LDT standard fall into two general categories: first, they chal-
lenge the equation, claiming by example that it gives "nonsensical"
results. Thus, no matter how excellent the data may be, the
standard would be incorrect, they insist. Second, they point out
several alleged deficiencies in the data base that results from
EPA's use of certain assumptions and approximations they claim are
inappropriate or outright wrong.
Taking these points one at a time, EPA rejects MVMA's con-
tention that the equation used to derive the standards is non-
sensical. The behavior of the equation demonstrated by MVMA in its
examples is consistent and rational. One example:*
EPA proposed the following equation for calculation of the
LDT standard at altitude.
* From submittal at the time of the Public Hearing, March 30,
1980.
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Standard _ (LDT baseline at + Change in LDVv x LPT low-altitude std.
at Altitude • low altitude Emissions LDT low altitude
baseline
When this equation is used to calculate the 1982 HC high-
altitude standard, the following result, which was also shown
in the NPRM, is obtained:
High-Altitude HC Standard = (8 + 1.6) -~j— = 2.0 g/mi
Now, consider what happens if the value of the low-altitude
baseline, (i.e., 8 g/mi HC) is, in fact, high since it was
obtained with vehicles which were both uncontrolled and
heavier than average for vehicles in the present LDT weight
class. EPA recognized that this was, in fact, likely to be
the case. Suppose the high-altitude baseline value were 5
g/mi HC instead of 8 g/mi HC. Then, substituting this
value in the equation in the EPA methodology gives the follow-
ing result:
High-Altitude HC Standard = (5 + 1.6) ^- = 2.24 g/mi
This is indeed surprising. Contrary to the EPA reasoning and
expectations, a high value for the low-altitude baseline gives
a more stringent rather than a less stringent high altitude
emission standard. Obviously, the methodology contains a
flaw.
Deeper consideration of this example will corroborate the
result and serve to support the equation. The significant point
to observe is that the stringency of the standard (i.e., the
fractional reduction from the baseline) changes as the baseline
changes. Thus, if the low-altitude baseline is 5 (as in the second
scenario), then the standard (1.7) represents something less
stringent than in the first scenario. Because the standard is a
proportional standard (i.e., it requires the same percentage
reduction from the appropriate baseline at both high and low
altitude), this less stringent low-altitude standard yields also a
proportionally less strict high-altitude standard, too.
This does, however, disprove the logic behind EPA's assump-
tion, namely that while the two pieces of available data were
not directly applicable, their errors would be in the opposite
direction and, therefore, would tend to cancel, hopefully to
large degree. It is evident that the use of this equation shows
that as the baseline is reduced, the standard increases slowly to
reflect the fact that the stringency of the standard (low-altitude
standard/low-altitude base) is lessening at a slightly faster rate
than the high-altitude baseline is dropping. This is due to the
additive nature of the altitude correction. A multiplicative
altitude correction would not display this behavior, as pointed out
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by MVMA, but that cannot be construed as an endorsement of that
approach. EPA remains convinced that the additive nature of
altitude effects is correct and amply defended its position in the
LDV discussion.
However, because the errors in the data base compound each
other rather than cancel, EPA must take care to see that these
errors are minimized, if not removed altogether. A careful recon-
sideration of the overall derivation of the standards provides some
useful insight' into the problem at hand. The basic equation upon
which the standards are based is:
u- u Ai^-t j o.. j j _ /high-altitude.. /1-fractional reduction N
High-Altitude Standard = ( ? , . ) x (c ., , ., . , , .)
baseline from the baseline demanded
Guidelines for the numbers to be used in the terms within the
parentheses are found in section 202(f)(2) of the CAA(1977):
"Any such future regulation applicable to high-altitude
vehicles or engines shall not require a percentage of reduc-
tion in the emissions of such vehicles which is greater than
the required percentage of reduction in emissions from motor
vehicles as set forth in section 202(b)- This percentage
reduction shall be determined by comparing any proposed
high-altitude emission standards to high-altitude emissions
from vehicles manufactured during model year 1970."
Section 202(b) refers to the LDV standards for 1982 and 1983
among other years. The LDV standards for these years reflect a 90
percent reduction from the baseline year 1970 which was also the
basis for the high-altitude LDV standards. Thus, the fractional
reduction permitted by the CAA to be used for the derivation of
these LOT standards is also 90 percent, not the various lesser
reductions used in the derivation of the proposed standards.
Section 202(f)(2) also requires this 90 percent reduction to be
taken from a 1970 baseline.
The 1970 model year saw the present LOT class divided into two
groups: those up to 6,000 Ibs. GVW which were classified as LDVs
and subject to those standards and those of 6,000-8,500 Ibs. GVW
which were classified as HDTs and subject to those standards. The
lighter weight group constituted 84 percent of sal'es, the heavier,
16 percent of sales. Thus, a composite baseline of these groups
can be expressed by:
Low-Altitude Baseline = 0.16(LDV baseline) + 0.84(HDV baseline)
However, this is not useful because the 1970 HDV baseline cannot be
approximated by its standard and converted to an equivalent number
for the current test procedure based upon the generally recognized
conversion factors.2/ Unfortunately, the HDV standard was not
based upon the LDV cycle and, in fact, is not even expressed in
terms of gm/mi. Thus, there is no recognized conversion.
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Barring the use of a 1970 low-altitude baseline, the available
1969 low-altitude baseline must be considered. This will be highly
favorable to the industry as the HDVs (i.e., those 6,000-8,500 Ibs.
GVW) are totally uncontrolled and the LDVs (i.e., trucks less than
6,000 Ibs. GVW) are less controlled than in 1970. Furthermore,
because 1969 LDV data (or appropriate standards) are not available,
it becomes necessary to put this 1969 baseline completely in terms
of the 6,000-8,500 Ibs. GVW vehicles, thus raising the baseline
further. The values for this baseline used in the NPRM were found
to be erroneous and were later corrected by retesting. The correct
values are:3_/
HC 6.46 gm/mi
CO 76.02 gm/mi
These values are higher by an unknown, but nonetheless, substantial
amount than the proper 1970 baseline fleet of sales-weighted
0-8,500 Ib. GVW LDTs.
The correct low-altitude baseline, as referenced above, must
be corrected to a high-altitude baseline, so to it must be added
the high-altitude increment (following the LDV procedure which was
amply justified in the earlier discussion). For the LDT increment,
EPA used the LDV increment because no proper LDT high-altitude data
existed then, nor exists now. While EPA recognized that this
value was probably low, it concluded that the value cannot be too
erroneous because the increase in emissions with altitude is
largely due to the enriching of the fuel-air mixture of the car-
buretor and is not significantly affected by the differences in
weight or road load between the two categories of vehicles. What
little error there may be (a value too low and therefore unfavor-
able to industry) will have a smaller effect than the advantage
given to industry by the use of the uncontrolled 1969 low-altitude
baseline. Also, in its final submittal, MVMA presented additional
data which followed, to a degree, the format of its earlier LDV
study. It presented the results of 5 LDTs (all GM) tested at both
low and high altitude with which it concluded that EPA grossly
underestimated the degradation of emissions with altitude by using
the LDV data additively. It did this by comparing those high-to-
low altitude ratios to that implicit in the proposed standards.
EPA rejects the data and, hence, the argument. The data are
irrelevant because they come from vehicles designed to meet the
1978 California standards. The behavior with altitude of these
strongly controlled, vehicles is irrelevant to the estimation of
altitude effects in a very weakly controlled 1970 baseline fleet:
variation with altitude could be vastly different due to vastly
different control technologies. Furthermore, EPA has already
rejected the use of the ratio method and, hence, finds an argument
based upon the comparison of two computed ratios to be pointless.
Thus, the high-altitude baseline is taken to be:
HC 6.5+1.6=8.1 gm/mi
CO 76 + 44 = 120 gm/mi
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Taking then 10 percent of this baseline, as permitted by Sections
202(f)(2) and 202(b) of the CAA(1977), yields potential'standards
for 1982-83 of 0.8 gm/mi for HC and 12 gm/mi for CO. These
values still are higher than that allowed because of the generous
baseline used (the only supportable one, however, at this time).
They are, however, less than the 1982 and 1983 standards proposed
by EPA on January 24, 1980 and debated here. Unfortunately, while
the CAA permits these lower standards, to use them at this point
would suggest a reproposal which would delay the truck standards,
at least to 1983. EPA judges that it would be preferable from an
air- quality perspective to promulgate the proposed rules, thereby
obtaining some control, although not the maximum, in 1982.
Recommendat ion
The standards are acceptable as proposed except for the need
to include waiver standards for CO and NOx. The waiver standards
should be, for qualifying vehicles, CO = 11 gms/mile and NOx =1.5
gms/ mile.
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References
I/ Michael W. Leifertnan, "Effect of Altitude on Non-Controlled
~~ Evaporative Emissions from Gasoline-Fueled Vehicles," U.S.
Environmental Protection Agency, Emission Control Technology
Division, Ann Arbor, Michigan, January, 1979.
2/ Thomas A. Huls, "Evolution of Federal Light-Duty Mass Emis-
~~ sions Regulations," Society of Automotive Engineers paper
730554, 1973.
3/ Larry Ragsdale, "Final 1969 LOT Baseline Emission Results,"
~~ U.S. EPA, Memorandum to the Record, March 21, 1980.
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B. Issue: Technical Feasibility
Summary of Issue
In the NPRM, EPA predicted that it would be technically
feasible for all light-duty vehicles and light-duty trucks to
comply with the proposed high-altitude standards.
Summary of Comments
Most of the manufacturers commended that the proposed stan-
dards were not feasible for the 1982 model year, for either light-
duty vehicles or light-duty trucks.
Major Subissues
1. Technical Feasibility for Gasoline-Fueled Light-Duty
Vehicles.
2. Technical Feasibility for Gasoline-Fueled Light-Duty
Trucks.
3. Technical Feasibility for Diesel-Fueled Light-Duty
Vehicles and Trucks Analysis of Comments.
Analysis of Comments
1 . Technical Feasibility for Light-Duty Vehicles. The
light-duty vehicle high-altitude standards which EPA proposed, and
which EPA is promulgating in the final rule, are 0.57 g/mi HC, 7.8
g/mi CO, and 1.0 g/mi NOx. There are several exceptions to these
standards, however. Several engine families have received CO
waivers for the 1982 model year at low altitude. Accordingly,
these engine families will only have to meet a high-altitude CO
standard of 11 g/mi in 1982 rather than 7.8 g/mi. These engine
families are listed in Table 1.
In addition, American Motors must only comply to a 2.0 g/mi
low-altitude NOx standard in 1982; accordingly, American Motors
will have a 2.0 g/mi high-altitude NOx standard in 1982 as well.
Finally, several light-duty diesel engine families have received
low-altitude NOx waivers for 1982; these engine families will have
high-altitude NOx standards equivalent to the low-altitude NOx
standard levels for 1982. These engine families and their 1982
waiver levels are listed in Table 2.
The analysis of the feasibility of the 1982-83 high-altitude
interim standards has not been an easy task. Many of the manu-
facturers submitted little or no high-altitude test data for the
emission control systems they plan to use in the 1982 and 1983
model years. Many manufacturers did not even submit relevant
low-altitude data or data which would be helpful in determining
appropriate high-altitude/low-altitude emission factors. Due to
-------
-14-
Table 1
Engines with CO Waivers for the 1982 Model Year
Manufacturer Engine
American Motors 258 CID
Chrysler 1.7 L
3.7 L
5.2 L-4V
General Motors 2.8 L/173 CID-2V
3.8 L/231 CID-2V
Jaguar-Rover-Triumph 215 CID
326 CID
Toyota 88.6 CID
-------
-15-
Table 2
Diesel Engines with NOx Waivers
Manufacturer
Daimler-Benz
General Motors
Peugeot
Volkswagen
Volvo
for the 1982 Model Year
Engine Family
2.4 L
3.0 L-NA
3.0 L-TC
5.7 L
2.3 L-TC-XD2S
1.6 L-NA-2375IW
2.0 L-NA-3250IW
1.6 L-TC-2375IW
1.6 L-TC-2625IW
2.0 L-TC-3250IW
2.4 L-NA
1982 NOx Standard
1.25
1.5
1.5
1.5
1.5 •
1.3
1.5
1.3
1.4
1.5
1.5
-------
-16-
the scarcity of relevant data, our technical evaluation has not
been based on as broad a data base as EPA would prefer to use in
its technical assessments.
Nevertheless, despite the limitations imposed by the lack of a
broad data base, EPA's technical staff has performed a compre-
hensive feasibility analysis for all the manufacturers which
commented on the technical feasibility of the proposed standards.
It is entitled "Technical Feasibility of the Proposed 1982-1983
High Altitude Standards for Light-Duty Vehicles and Light-Duty
Trucks" by Robert J. Bruetsch, John J. McFadden, and William M.
Pidgeon, dated August, 1980. This Technical Report has been placed
in the docket and is publicly available as CTAB/TA/80-3. This
chapter will only summarize the methodology and results of this
analysis, anyone wishing further detail should consult the above
report.
The basic methodology used by EPA's technical staff to deter-
mine the feasibility of the high-altitude standards was to make
pass/fail judgments on the manufacturers' technical ability to
comply with the standards. The following four methods were used in
making the pass/fail judgments.
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 (dfs) taken from 1981 cer-
tification 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 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 emis-
sion results from the 1981 certification durability vehicles
were substituted. Therefore, the dfs and 4,000-mile emissions
were from the same vehicles.
4. The fourth method utilized technical knowledge of the
emission control system's ability to compensate for altitude.
This was used for situations where data were unavailable 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
-------
-17-
to be used by each manufacturer. In most cases these judgments
were based on information from four sources; a) 1981 certification
data, b) CO waiver applications, c) testimony from the 1982-1983
high-altitude hearings, and comments on the 1982-1983 high-altitude
NPRM, and d) written responses to questions from the high-altitude
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 cannot be divulged in our analysis. In such
cases, the engine displacement was replaced by a letter designation
and the emission control system description was replaced by a
numbe r.
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 dis-
placements 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 stan-
dards. It was not possible for 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.
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,
* 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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-18-
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
certification results from 1981 emission data vehicles which had
been assigned a certification disposition of passing. The cutoff
date for this data was July 15, 1980 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.
Durability vehicles were selected by emission control system
only. Sales location was not a criterion 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. 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 com-
pensated fuel metering systems to enrich as altitude increases.
Attendant with richer mixtures are increases in HC and CO emis-
sions. Therefore, in order to prevent or limit increases in HC and
CO emissions with increases in altitude, the air/fuel ratio en-
richment has to be limited, and/or the emission control after-
treatment 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
-------
-19-
system. Multiplicative high-altitude to low-altitude emission
factors were developed for four generic emission control systems:
1. Pulse or aspirator type air injection systems (PAIR),
oxidation catalysts (OC), and exhaust gas recirculation (EGR)
with altitude compensating carburetors.
2. Air injection systems using air pumps (AIR), OC, and EGR
with altitude compensating carburetors.
3. Feedback carburation (FBC), three-way catalysts (3W),
AIR, OC, and EGR.
4. Closed-loop electronic fuel injection (CLEFl), 3W, and
EGR.
These factors were developed from light-duty vehicle data submitted
by various manufacturers. They are summarized in Table 3.
For further detail on the calculation of these factors, see
the aforementioned EPA Technical Report CTAB/TA/80-3.
With this basic methodology, we will now briefly summarize the
analyses for each light-duty vehicle manufacturer.
American Motors - In their final written comments, American
Motors(AMC) did not "dispute the basic feasibility of the proposed
standards." They considered the issue more one of leadtime and
resource prioritization. Table 4 summarizes EPA's technical
analysis of AMC's position. Based on the above quote from AMC, the
advanced nature of the GM emission control system that AMC uses,
and the dearth of any data to the contrary, EPA concludes that AMC
will be able to comply with the high-altitude standards.
Chrysler - Table 5 summarizes EPA's technical feasibility
analysis for Chrysler. Based on the conclusions reached in Table 5
and EPA's latest discussions with Chrysler representatives, it is
clear that Chrysler will have no problems meeting the high-altitude
standards in 1982-1983.
Ford - Table 6 summarizes EPA's technical feasibility analysis
for Ford. As can be seen from Table 6, EPA cannot show that Ford
can comply with the high-altitude standards. This is primarily due
to a lack of relevant data. However, the following statement from
a letter from D.A. Jensen of Ford to EPA (dated April 30, 1980)
clarifies Ford's current position:
"The data in Table 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
nonelectronic calibrations also comply'."
-------
-20-
Table 3
High-Altitude to Low-Altitude Emission
Factors for Genenic Emission Control Systems
Emission
Control System
PAIR/OC/EGR +
aneroid carburetor
PAIR/OC/EGR +
aneroid carburetor
AIR/OC/EGR +
aneroid carburetor
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
CLEFI/3W/EGR
Data Base
Nissan
Nissan
Ford
Chrysler
Ford
Chrysler, Ford
Nissan
Applicable
Manufacturers
Nissan
All Others
All
Chrysler
Ford
All Others
All
HC
1.10
1.70
1.65
1.55
1.12
1.47
1.68
CO
1.76
1.80
1.73
2.65
2.56
2.63
2.57
NOx
1.03
1.00
0.97
1.00
0.74
-------
-21-
Table 4
Technical Feasibility for American Motors
Engine Year
Emission Control
System
151 CID 1982-83 FBC/AIR/3W/OC/EGR
258 CID 1982
258 CID
1983
FBC/AIR/3W/OC/EGR
Conclusion
Pass
Not Enough
Data
Not Enough
Data
Basis
Method 1 Analysis
Using GM Data and
Lowest DFs.
Table 5
Technical Feasibility for Chrysler
Engine
1.7 L
2.2 L
2.6 L
3.7 L
Year
1982-83
1982-83
1982-83
1982-83
Emission Control
System
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
PAIR/OC/EGR
FBC/AIR/3W/OC/EGR
Conclusion
Pass
Pass
Pass
Pass
Basis
Method 2 Analysis
Method 2 Analysis
Method 2 Analysis
Method 2 Analysis
-------
-22-
Table 6
Technical Feasibility for Ford
Engine Year Emission Control System Conclusion Basis
1.3/1.6 L 1982-83 Open-loop/AIR/3W/OC/EGR Not enough data
2.3 L 1982-83 FBC/AIR/3W/OC/EGR or Pass Method 3 analysis
Open-loop/AIR/3W/OC/EGR Not enough data
2.3 L/TC 1982 FBC/AIR/3W/OC/EGR or Not enough data
Open-loop/AIR/3W/OC/EGR Not enough data
1983 EFI Not enough data
3.3 L 1982-83 FBC/AIR/3W/OC/EGR or Not enough data
Open-loop/AIR/3W/OC/EGR Not enough data
Pass Method 2 analysis
4.2/5.0/ 1982-83 Open-loop/AIR/3W/OC/EGR Not enough data
5.8L FBC/AIR/3W/OC/EGR Fail (NOx) Method 1 analysis
CFI/AIR/3W/OC/EGR Pass Method 1 analysis
-------
-23-
Thus , there seems to be little question that Ford can meet the
high-altitude standards.
General Motors - Table 7 summarizes EPA's analysis of General
Motors' technical position.
GM did not make technical feasibility an issue in their
comments on the NPRM. They provided more extensive high-altitude
test data than any other manufacturer. This allowed EPA to use
method 1 analyses, which give conclusions with higher confidence
than methods 2, 3, or 4. As Table 7 shows, we have concluded that
most of the engine groups for which GM Provided high-altitude test
data will comply with the high-altitude standards. Two factors
must be noted with respect to Table 7. First, there are four
engine groups for which we could not show compliance. GM did
provide high-altitude data on these vehicles, and EPA's technical
analsyis showed these vehicles to fail the high-altitude standards.
But in each of these four instances, there have been extenuating
circumstances that lead us to the conclusion that we do not have
sufficient information to make a conclusion (for example, in the
case of the 4.4-liter engine GM has expanded the feedback car-
buret ion range of authority and they expect the engine to meet
high-altitude requirements). Secondly, the technical staff did not
attempt to analyze every engine displacement and emission control
system which GM might use for the 1982-83 model years. GM char-
acterized the data they presented as "representing the broad
spectrum of General Motors passenger cars," and EPA concluded that
analyses covering these data would be representative of GM's
capabilities in complying with the high-altitude standards, based
on Table 7, then, we conclude that GM will be able to comply with
the high—altitude standards.
Honda - We have assumed that Honda will market engines A, B,
and C with emission control systems 1, 2, and 3 for model years
1982 and 1983. Honda has used an "air jet controller" (aneroid)
modification to the carburetor assembly for air/fuel ratio control
on high-altitude vehicles since 1977. The potential effectiveness
of this control, as demonstrated on the 1.8-liter, 49-state vehicle
adjusted for deterioration, is shown in Table 8.
It can be seen that the high-altitude emissions in Table 8 are
well under the standards. The air jet control technology is
considered to be transferable to other Honda engines allowing
compliance with the 1982-83 high-altitude standards.
Jaguar-Rover-Triumph - Table 9 summarizes Jaguar-Rover-Triumph
(JTR) technical position.
JRT submitted no high-altitude data for any of their engines.
This has made our technical analysis very difficult. JRT uses a
Lucas/Bosch electronically-controlled fuel njection system on its
vehicles. It is an air flow sensitive, pulsed, port injection
system with one injector per engine cylinder. The air/fuel ratio
-------
-24-
Engine Year
1.6 L 1982-83
2.5 L 1982-83
3.8 L 1982-83
4.3 L 1982-83
4.4 L 1982-83
4.9 L 1982-83
(standard)
4.9 L 1982-83
(high
performance)
4.9 L/TC 1982-83
5.0/5.7L 1982-83
6.0 L 1982-83
Table 7
Technical Feasibility for General Motors
Emission Control System Conclusion
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
FBC/AIR/3W/OC/EGR
Not enough data
Pass
Pass
Pass
Not enough data
Pass
Pass
Basis
Method 1 analysis
using lowest dfs.
Method 1 analysis
Method 1 analysis
Method 1 analysis
Method 1 analysis
Not enough data —
Pass Method 1 analysis
Not enough data —
-------
-25-
Table 8
Honda High-Altitude Emission Characteristics
Using Air Jet Controller
Vehicle
1.8 L 49-states
5MT
1.8 L 49-states
3AT
Test Location
Low altitude
High altitude*
Low altitude
High altiude*
HC
0.17
0.28
0.13
0.18
CO
2.51
5.8
3.40
5.10
With Air Jet Controller
Table 9
Technical Feasibility for Jaguar-Rover-Triumph
NOx
0.68
0.45
0.56
0.60
Engine
122 CID
215 CID
258 CID
Year
1982-83
1982-83
1982-83
Emission Control
System
CLEFI/3W
CLEFI/3W/EGR
AIR/CLEFI/3W
Conclusion
Pass
Not enough data
Not enough data
Basis
Method 3
Analysis
—
—
or CLEFI/3W
326 CID 1982-83 CLEFI/3W/3W Not enough data
-------
-26-
is controlled near stoichiometry by the use of oxygen sensors in
the exhaust down pipes. Bosch has claimed that this control system
is self-compensating up to 8,200 feet. Thus, despite the lack of
relevant data, we have concluded that JRT will be able to comply
with the high-altitude standards.
Nissan - Table 10 summarizes our technical analysis for
Nissan.
Based on the technical analysis, EPA concludes that Nissan
will be able to comply with the high-altitude standards.
Peugeot - EPA assumes that Peugeot will market engine A with
emission control system 5 in model years 1982 and 1983. Data
were not available to fully utilize methods 1, 2, and 3. We
did have some limited data analysis of this along with engineering
judgment led us to predict the following results for the Peugeot
engine at high altitude: 0.38 g/mi HC, 7.0 g/mi CO, and 0.58 g/mi
NOx. These results are less than the high-altitude standards.
Toyota - Table 11 summarizes Toyota's position.
As shown in Table 11, EPA concludes that Toyota will achieve
compliance with the high-altitude standards.
Volkswagen - Volkswagen intends to use the Bosch K-Jetronic
fuel injection system. Although this system is able to compensate
for changes in air density, VW expressed some doubt that it would
compensate sufficiently to meet the high-altitude standards. Bosch
has stated that the system compensates for altitude up to 8,200
feet. In addition, Volvo test data has shown that the same K-
Jetronic fuel injection system produced emissions results well
under the high-altitude standards. In view of these facts, and
lacking any VW data to prove otherwise, the EPA technical staff's
judgment is that VW will be able to comply with the high-altitude
standards. For a more complete discussion of VW, see EPA Technical
Report CTAB-TA/80-3.
2. Technical Feasibility for Gasoline-Fueled Light-Duty
Trucks. Light-duty trucks have higher numerical standards at low
altitude than do light-duty vehicles. Similarly, light-duty trucks
will have numerically less stringent standards at high-altitudes as
well. In 1982, light-duty trucks will have high-altitude standards
of 2.0 gpm HC, 2b gpm CO, and 2.3 gpm NOx. In 1983, the high-alti-
tude standards will be 1.0 gpm HC, 14 gpm CO, and 2.3 gpm NOx.
Basically, the methodology used by the EPA technical staff to
determine the technical feasibility for light-duty truck manufac-
turers was the same as that used in the previous subissue for
light-duty vehicles. One issue in this regard was the validity of
using the high altitude to low altitude emission factors in Table 3
(calculated from light-duty vehicle data) in assessing the techni-
-------
-27-
Engine
Year
Table 10
Technical Feasibility for Nissan
Emission Control System Conclusion
Basis
1.2/1.4/
1/5L
2.0 L
2.8 L
1982-83
1982-83
1982-83
PAIR/OC/EGR
"Fast Burn"/CLEFI/
3W/EGR
CLEFI/3W/EGR
Pass
Pass
Pass
Method 3
Analysis
Method 3
Analysis
Method 1
Analysis
Table 11
Technical Feasibility for Toyota
Engine Year Emission Control System Conclusion
78.7 CID 1982-83 PAIR/OC/EGR Pass
88.6 CID 1982-83 PAIR/OC/EGR Pass
108 CID 1982-83 Closed Loop AIR/3W/EGR Pass
134/ 1982-83 Closed Loop AIR/3W/EGR Pass
144.4 CID
156.4/ 1982-83 CLEFI/3W/EGR Pass
168.4 CID
Basis
Method 3
Analysis
Method 3
Analysis
Method 4
Analysis
Method 3
Analysis
Method 3
Analysis
-------
-28-
cal feasibility for light-duty trucks. This issue is discussed in
some depth in the EPA Technical Report CTAB/TA/80-3 discussed
above. EPA did use the emission factors in Table 3 for light-duty
trucks, but did so with the understanding that there were questions
about doing so.
We will now summarize the technical feasibility of each
light-duty truck manufacturer that commented on the issue.
American Motors - The summary of AMC's technical position is
listed in Table 12.
Table 12 indicates that AMC can comply with the 1982 high-
altitude light-duty truck standards but can not now show compliance
with the 1983 standards. There will be an extra full year of
leadtime for 1983 and EPA believes this to be sufficient for the
development of a light-duty truck package to meet the 1983 stan-
dards .
Chrysler - Table 13 summarizes our analysis of Chryslers
light-duty trucks.
EPA anticipates that Chrysler will have no problems meeting
the high-altitude light-duty truck standards.
Ford - Our analysis of Ford's light-duty situation is high-
lighted in Table 14.
As shown in Table 14, the only engine groupings which failed
were engines A-l and B/C/D-1, both for the 1983 model year. Two
factors must be noted. One, both of these engines involved emis-
sion control systems which were calibrated to meet the 49-state HC
standard of 1.7 gpm, thus it is not surprising that these vehicles
would fail to meet the 1983 high-altitude HC standard of 1.0 gpm.
Given a year of development time and the lower standard it is quite
likely that compliance can be achieved. Second, both the A and
B/C/D engines were able to show compliance with the 1983 high-
altitude standards with emission control system 2. Thus we con-
clude that Ford will be able to meet the high-altitude standards.
General Motors - Our summary of GM's light-duty truck situa-
tion is given in Table 15.
As Table 15 shows, GM should be able to meet the high-altitude
light-duty truck standards.
International Harvester - The only high-altitude data which IE
provided to EPA were two series of tests of 1977 Scout Travelers
with 345 CID engines. Both vehicles showed high-altitude emissions
consistently below the 1983 high-altitude standards. Since IE
demonstrated ability to meet the 1983 standards at high-altitude
with a relatively large vehicle (5000 pounds inertia weight) and
large engine (345 CID), EPA is confident that the technology can be
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-29-
Table 12
LPT Technical Feasibility for American Motors
Engine Year
Emission Control
System
A
B
B
C
C
D
D
1982-83
1982
1983
1982
1989
1982
1983
1
2
2
2
2
2
2
Conclusion
Pass
Pass
Fail
Pass
Fail
Pass
Fail
Basis
Method 4 Analysis
Method 2 Analysis
Method 2 Analysis
Method 2 Analysis
Method 2 Analysis
Method 2 Analysis
Method 2 Analysis
Table 13
LPT Technical Feasibility for Chrysler
Engine Year
Emission Control
System
Conclusion
Basis
A
B/C
1982-83
1982-83
Pass
Pass
Method 2 Analysis
Method 3 Analysis
Table 14
LOT Technical Feasibility for Ford
Engine Year
Emission Control
System
A
A
A
B/C/D
B/C/D
B/C/D
1982
1983
1982-83
1982
1983
1982-83
1
1
2
1
1
2
Conclusion
Pass
Fail
Pass
Pass
Fail
Pass
Basis
Method 2 Analysis
Method 2 Analysis
Method 2 Analysis
Method 2 Analysis
Method 2 Analysis
Method 2 Analysis
-------
-30-
Table 15
LPT Technical Feasibility for General Motors
Emission Control
Engine Year
A 1982-83
B 1982-83
C/D 1982-83
System
1
3
3
Conclusion
Pass
Pass
Pass
Basis
Method 4 Analysis
Method 2 Analysis
Method 2 Analysis
Table 16
LPT Technical Feasibility for General Motors
Engine Year
A 1982-83
B 1982-83
Emission Control
System
1
2
Conclusion
Pass
Pass
Basis
Method 4 Analysis
Method 4 Analysis
-------
-31-
transferred to smaller displacement engines and lighter vehicles.
In addition, three years time has elapsed yielding IE much time to
resolve any possible problems in transferring the technology.
Nissan - Nissan is expected to market only one light-duty
gasoline engine for light-duty trucks in 1982-83. The Nissan
A engine is expected to be available with emission control system
1. A method 2 analysis was performed which indicated that this
engine easily complies with the 1982 and 1983 high-altitude stan-
dards .
Toyota - Table 16 summarizes our analysis of Toyota's feasi-
bility in meeting the light-duty truck standards.
Based on Table 16, Toyota should be able to comply with the
high-altitude light-duty truck standards.
3. Technical Feasibility for Diesel-Fueled Light-Duty
Vehicles and Trucks
Light-Duty Vehicles
General Motors, Peugeot, Volkswagen, Mercedes 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 problen 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 engines, but can reduce
exhaust smoke."
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 sources. Data from an EPA report entit-
led "1977 EPA-Industry Light-Duty Diesel Correlation Program,"
April 1978, showed that HC, CO and NOx emissions were lower for a
Mercedes Benz 300D at high altitude than at low altitude. This is
explainable since this engine was apparently equipped with an
intake-air density compensator. The high-altitude/low-alt itude
emission factors were 0.98, 0.94, and 0.92 for HC, CO, and NOx,
respectively. The same report determined altitude factors for a GM
Oldsmobile diesel as well. Its high-altitude/low-altitude factors
were 1.31, 1.21, and 0.79 for HC, CO, and NOx, respectively.
Comparing these altitude factors to factors for the high-to-low
altitude standards (high/low altitude standard) of 1.89 HC, 2.3 CO,
and 1.0 NOx, would indicate that diesel LDVs can comply with the
proposed standards without the need for adjustments.
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Other FTP data more recently developed, for five diesel LDVs
(two Oldsmobiles, VW, Peugeot, Mercedes) tested at both EPA (for
low-altitude environment) and at the Automotive Testing Laboratory
(ATL) at Auroram Colorado (5480 feet), averaged high/low-altitude
emission factors of 2.27, 1.87, and 1.02 for HC, CO, and N0xs
respectively.
These factors show some upward pressure on HC and CO emissions
and negligible effect on NOx emissions. However, the CO factor of
1.85 is offset 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 HC high-altitude stan-
dard. Otherwise, aneroids, other fuel 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 on the CMC, Mercedes, Peugeot, VW, Audi, and Volvo vehi-
cles. The predicted results are listed in Table 17.
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 manufac-
turers 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.
Although the 1981 statutory NOx standard is 1.0 g/mi, wiavers to
1.5 g/mi NOx are available for manufacturers whom fulfull the
statutory criteria under Section 202(b)(b)(B) of the Clean Air Act
for model years 1981 through 1984.
Light-Duty Trucks
With respect to the LOT standards for 1982 and 1983, Nissan,
who has supplied diesel engines to International Harvester, provi-
ded the following statement:
"Because the amount of inlet air is reduced at high altitude
and excessive air cannor be obtained, an altitude compensator
(aneroid type compensator) will be required for the fuel
injection system at WOR operation. Furthermore, our simula-
tion 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 respectively.) Therefore, in order to control HC and Co
emissions at high altitude, it is considered that using only a
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Table 17
Predicted High-Altitude Diesel LDV Emissions Using
Conservative Altitude Factors and 1980
Certification Results
Mercedes
CMC (49 states)
HC
CO
NOx
(NA) (NA)
0.71 0.72
3.86 1.98
1.68 1.50
(TC)
0.54
1.98
1.49
Peugeot
(NA)
0.72
2.4
1.46
(TC)
0.49
2.5
1.0
VW
(NA)
0..82
2.22
1.27
Audi
(NA)
0.91
2.40
1.73
Volvo
(NA)
0.66
2.53
1.70
Table 18
Predicted High-Altitude Diesel LDT Emissions Using
Conservative Altitude Factors and 1980
Certification Results
HC
CO
NOx
Nissan/IH
0.95
3.51
1.53
CMC
2.0
4.01
2.14
VW
0.73
1.85
2.18
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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.
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 conservative 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 results
in Table 18.
Since the 1983 high-altitude LDT standards are 1.0 g/mi HC,
14.0 g/mi CO, and 2.3 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.
Particulate emissions were not considered in this determina-
tion, but there is no high-altitude particulate standard for the
1982 and 1983 model years. Thus, 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 stan-
dards with minor adjustments or, effectively, by addition of
aneroid type controls.
Recommendation
The interim high-altitude standards appear to be technically
feasible after a careful analysis of the available information.
Therefore, the levels of the standards should not be changed in the
final rule.
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c- Issue; Adequacy of Existing High-Altitude Test Facilities
Summary of the Issue
The proposed regulations would necessitate the use of testing
facilities located at high altitude (HA) or testing facilities with
the capability of simulating HA conditions. These HA test facili-
ties would be needed for research and development (R & D) work,
certification testing, and Selective Enforcement Audits as well as
continued EPA in-use surveillance testing. The proposal assumed
that existing HA test facilities would be sufficient to develop and
certify the low-altitude light-duty fleet to the proposed 1982 and
1983 HA standard.
Summary of the Comments
The major comment by the manufacturers was that existing
commercial HA test facilities might not have adequate test capacity
to meet the needs of the manufacturers. MVMA stated that they
questioned if HA test facilities would be adequate but they didn't
give any analysis of this suspicion. Ford stated that they prob-
ably would require expansion of their HA facility. However,
further details were not given. AMC claimed that HA test facilities
were already scheduled to capacity and Fuji/Subaru was concerned
that the Denver commercial labs could not guarantee test time due
to limited testing capacity. VW claimed that since HA facilities
would be fully utilized for development work, Selective Enforcement
Audits could not be done.
f
Analysis of Comments
The following discussion and analysis of high-altitude test
facilities is divided into two parts. First, a review of existing
facilities both commercial and private is presented. This infor-
mation was obtained from the various manufacturers at the request
of EPA. EPA1s letter and the manufacturer's responses can be found
in the public docket for this rulemaking. The two commercial
testing facilities also submitted information in response to an
EPA request and their letters can be found in the public docket as
well.
After discussing existing facilities, the need for high-
altitude test facilities will be presented. Estimates of each
manufacturer's research and development (R&D), certification, and
Selective Enforcement Audit (SEA) burdens are made. Then the
previously developed information on existing facilities is combined
with the need for facilities to resolve the issue of whether or
not there are adequate high-altitude test facilities to implement
the proposed rule.
la Existing Facilities. Currently, there are two commercial
high-altitude test facilities in the Denver area. EPA is not aware
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of any other commercial facilities capable of performing HA test-
ing. The two facilities are Automotive Testing Laboratories (ATL)
and Environmental Testing Corporation (ETC). Both facilities have
the capability of performing the full Federal Test Procedure (FTP)
for light-duty vehicles (LDVs) and light-duty trucks (LDTs) in-
cluding evaporative emission testing. Both facilities have con-
siderable amounts of testing capacity" still available at the time
of this writing and both facilities doubt that the proposed rule
will necessitate full utilization of their respective testing
capacities.
ETC is located in Aurora, Colorado, a suburb of Denver. This
commercial testing facility has two chassis dynanometers and one
LDV evaporative emission enclosure or SHED. ETC states that by
running at full capacity they could conduct 252 tests per week if
evaporative testing is not included (i.e., 2 test sites x 3 shifts
per day x 6 tests per test site per shift x 7 days per week). If
each test included evaporative emission testing, ETC could then
conduct 63 tests per week (i.e., 3 tests per test site per shift x
1 test site x 3 shifts per day x 7 days per week). However, ETC
states that they could have another LDV SHED operational within six
months should they perceive a need. This would effectively double
their evaporative emission testing capability to 126 tests per
week.
The above test rates are for non-certification testing. These
rates would be appropriate for R & D testing but not for actual
certification testing. Tests conducted for R&D purposes do not
have to meet any EPA specifications. For example, R&D tests could
be conducted with an ambient temperature of 50°F. This would still
be a useful test for R&D purposes but would not be acceptable
from a certification point of view. Because there are a number of
specifications which must be met in order to have a valid certifi-
cation test, a void rate should be applied to the above testing
rates if the testing has to be of certification quality. ETC
estimated their void rate as 20 percent at maximum. This would
reduce the above test rates to 202 tests per week not including
evaporative testing and 101 tests per week including evaporative
testing (2 SHEDs).
The other commercial high-altitude testing -laboratory, Auto-
motive Testing Laboratories, Inc. (ATL), is also located in Aurora,
Colorado. This facility currently has one test cell in operation
and floor space for another. A second test cell will be opera-
tional by November 1, 1980, which is the date that this analysis
will use as the starting point of the manufacturers' development
effort. November 1, 1980 will be used as the starting date even
though we know that significant development effort has already
occurred. In fact, conversations with ATL indicate that a number
of manufacturers have been testing since the spring of this year
and testing is continuing to be scheduled from now through the
November 1 starting point of this analysis. ATL does not expect to
fully utilize their testing capacity at any time in the next 12
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month s. Furthermore, conversations with Chrysler (see the public
docket for this rulemaking) indicate that they have been running
4-5 tests/day since February 1, 1980. It is, however, difficult to
quantify the amount of development work that will have been done by
November 1, because ATL cannot provide the necessary details due to
the proprietary nature of such information. Thus, this analysis is
based on the very conservative assumption that no HA development
testing will be done until November 1, 1980.
The test cell currently operating at ATL's high-altitude
facility is staffed to operate 20 hours per day. The other four
hours are used for calibration and maintenance. ATL submitted
standard dynamometer test times which show that 112 FTPs without
SHED could be conducted per 7-day week. With the addition of the
second test cell 224 non-SHED FTPs could be conducted per 7-day
week.
ATL's one operating test cell includes a SHED for evaporative
emissions testing. ATL has another SHED and the necessary auxil-
iary equipment for evaporative emissions testing at the Aurora lab,
however, it is not set up at the present time. This second evap-
orative emission test site could be assembled very quickly if the
need presented itself. Therefore this analysis will assume that
the second SHED is operational. It has not been assembled yet
because ATL has no indication that it will be needed. With two
operating SHEDs and two chassis dynos, ATL could conduct about 93
FTPs per week including SHED testing.
ATL did not include a void rate for certification quality
testing so ETC' s void rate of 20 percent will be used. ATL's
capacity for certification quality testing is 179 FTPs per week
excluding SHED testing and 74 FTPs per week including SHED test-
ing.
To summarize the available commercial facilities, with current
equipment ETC can run 252 non-SHED FTPs per week and ATL can run
224 non-SHED FTPs per week for a total of 476 tests per week.
If evaporative emissions testing capabilities are included then ETC
can run 63 FTP (with SHED) tests per week and ATL can run 93 FTP
(with SHED) tests per week for a total of 156 tests per week.
Additionally, if necessary ETC could double its capacity within six
months to 126 FTP (with SHED) tests per week bringing the total for
both facilities to 219 tests per week. Test rates for certifi-
cation quality testing would be the above testing rates reduced by
20 percent.
The total number of non-SHED tests that could be made avail-
able between November 1, 1980 and June 30, 1981 is somewhat more
than 16,000 of R&D quality. EPA expects that SHED testing will not
be a limiting factor because it will be relatively easy to meet the
HA evaporative emission standards. Therefore, the large majority
of testing will be R&D quality, non-SHED test.
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Besides commercial test facilities there are many manufact-
urers that have facilities for high-altitude testing. General
Motors, Ford, Honda, Mercedes Benz, and Fiat have testing facili-
ties located at high altitude. Furthermore, General Motors,
VW/Audi, Honda, Nissan, Mercedes Benz, Toyota, BMW, Mitsubishi,
Mazda, Subaru, and Peugeot all either have a pressure chamber
capable of simulating high-altitude conditions or have contracted
to rent such a facility overseas. In this section a brief discus-
sion of each manufacturer's high-altitude test facilities will be
presented.
General Motors has an emissions laboratory in Denver, Colo-
rado. It has three chassis dynamometers, two SHEDs, and covers
51,750 ft2- General Motors also has a high-altitude test chamber
at Mil ford, Michigan. The chamber has one chassis dynamometer only
and was designed to achieve a pressure reduction of 4 inches of
mercury below ambient atmospheric pressure.
Ford also has an emissions laboratory at Denver, Colorado.
Ford's facility has four chassis dynamometers, one SHED and covers
approximately 25,000 ft2 which includes a soak area for 45 vehi-
cles. Although Ford does not have an altitude test chamber at this
time, the company is considering converting an engine dynamometer
cell to accomodate simulated high-altitude conditions.
Chyrsler has no facilities of its own at high altitude nor any
capable of simulating high-altitude conditions. However, Chrysler
has contracted with ETC to rent two of their six testing shifts as
of August, 1980.
Volkswagenwerk/Audi has a chamber capable of simulating
high-altitude conditions which is located in Germany. The chamber
is very close to being finished and some testing has been done.
The chamber has one chassis dynamometer and one SHED plus area for
soaking vehicles. Another chamber is planned.
Nissan has a high-altitude simulation chamber located in
Japan. The chamber has two chassis dynamometers and one SHED.
Nissan is currently studying whether or not to build a test facil-
ity at a high altitude location in the USA.
Toyota has a pressure controlled test room in Japan which has
one chassis dynamometer and one SHED.
Mercedes Benz has both an emissions testing facility at a
high-altitude location (Aurora, Colorado) and a chamber capable of
simulating high-altitude conditions (in Germany). The facility at
high-altitude has one chassis dynamometer, one SHED, and covers
10,300 ft2. The high-altitude simulation chamber has two chassis
dynamometers but they can't be used simultaneously. It has a SHED
and particulate measuring equipment that will be installed by
October.
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Mitsubishi has neither a facility located at high-altitude nor
a chamber capable of simulating high-altitude conditions. However,
they do rent time from a laboratory in Japan which has high-
altitude simulation capability. This facility has an engine
dynamometer but no chassis dynamometer or SHED.
Toyo Kogyo/Mazda has a high-altitude simulation chamber in
Japan. The chamber has one chassis dynamometer, one SHED and area
for soaking vehicles.
Honda has a high-altitude emissions test facility in Denver,
Colorado. The facility has one chassis dynamometer, one SHED, and
covers approximately 19,000 ft2. Honda also has a high-altitude
simulation chamber located in Japan. This chamber has one engine
dynamometer and covers approximately 2200 ft2.
Subaru/Fuji has a facility capable of simulating high-altitude
conditions and is located in Japan. This facility has one chassis
dyno but no SHED. However, the company is planning to construct
another facility capable of performing the full FTP including SHED
in one of their plants.
Fiat has a laboratory located in Sestrier, Italy which is at
an altitude of 6,691 ft. this facility has one chassis dynamo-
meter, no SHED, and covers approximately 2100 ft2.
Peugeot has built a pressure chamber in France. The chamber
has one chassis dynamometer but SHED testing cannot be performed in
accordance with Federal regulations.
BMW will be using an environmental chamber that is owned and
operated by Industrieanlagen-Betriebsgesellschaft of West Germany.
This facility has one chassis dynamometer and one SHED.
Renault is currently building a chamber for the simulation of
high-altitude conditions in Lardy, France. It will include one
dynamometer and one SHED and is scheduled to be ready for the 1982
model year.
AMC, IHC, Isuzu, Volvo and Alfa Romeo indicated they have no
facilities at a high-altitude location nor do they have a chamber
capable of simulating high-altitude conditions.
EPA did not obtain information from other companies such as
Ferrari, Maserati, Lotus, Panther, Porsche, Jaguar/Rover/Triumph,
Hyundai, Rolls Royce, or Aston Martin. These smaller companies
represent less than 10 percent of the engine families that were
certified in 1980. For the purposes of this analysis it will be
assumed that these manufacturers have no high-altitude test capa-
bility.
2. Need for Facilities. High-altitude emissions test
facilities are needed for four primary reasons. First, high-
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altitude test facilities are needed for research and development
(R&D) work. Some engine families will need some recalibration of
either the carburetor or the feedback control system. Once the
recalibration is made it must be tested to see if it meets the new
high-altitude standards. As discussed later in this section, R&D
is the only area of facility usage that even comes close to fully
utilizing existing commercial high-altitude test facility capa-
city.
High-altitude test facilities will also be needed for certifi-
cation testing. In order to produce a model the manufacturer must
show to EPA that the model meets the emission" standards. He does
this by performing certification tests in the late spring and early
summer before production is scheduled to begin (usually in August).
If the vehicle representing the model passes the test (and it
usually does) the manufacturer is issued a certificate which allows
him to produce the model. The utilization of high-altitude test
facilities for certification testing will be minor as discussed
later in this section.
The third and fourth reasons that high-altitude test facili-
ties will be needed relate to Selective Enforcement Audits (SEA)
and potential in-use surveillance programs. SEA is EPA's method of
checking to make sure that production vehicles from the assembly
line actually meet the emission standards. In-use surveillance
testing is used by EPA to help determine the level of emissions
of vehicles that have been owned and operated by the public for
various lengths of time. Both SEA and in-use surveillance are
expected to utilize relatively minor amounts of high-altitude
testing facilities as discussed later in this section.
a. Research and Development Needs. Of the four different
reasons why HA commercial test facilities are needed for this
proposed regulation (i.e., R&D, certification testing, SEA, and
in-use surveillance), R&D is the only one that could approach full
utilization of existing commercial test capacity. In order to meet
the proposed HA standards some manufacturers will have to recali-
brate their low altitude engine/ emission control systems. Some
manufacturers may add new components for HA vehicles that will have
to be optimized for emissions, fuel economy and driveability.
Estimations of R&D efforts for the industry are, of course, dif-
ficult because each manufacturer's needs are different. Addi-
tionally, utilization of test facilities to meet a given R&D
need can vary considerably depending on factors such as the engi-
neering experience and skill, the priority that the manufacturer
places on the project and the extent that theoretical evaluations
can be substituted for trial and error FTP testing. The following
discussion present EPA's estimation of HA commercial test facility
utilization for R&D in which a "worst case" scenario is evaluated.
The "worst case" is based on the assumption that manufacturers will
not begin development work until November 1, 1980, the projected
date for the final rule (this conservative assumption, which
ignores the development work done prior to November 1, will be
discussed later.
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It is convenient to divide LDVs and LDTs into two groups
according to'expected engine/emission control strategies. Feedback
control strategies are those where an oxygen sensor electronically
communicates with the air/fuel metering system through a computer
to provide a constant stoichiometric A:F ratio during most driving
modes. This allows optimization among emissions, fuel economy, and
driveability. The feedback control system was relatively rare
prior to 1981 but with the stricter low-altitude NOx, HC and CO
standards for 1981 this type of system is now in the majority and
is expected to be the predominant type of system for 1982 and
1983. The other group of engine control systems are known as
non-feedback. This group has air/fuel metering systems of the
conventional type such as carburetion or fuel injection but has no
oxygen sensor or associated micro-processor unit.
The feedback systems are the easier of the two groups to
modify for compliance with the proposed HA standards. When a
feedback system that has been developed for low-altitude use is
operated at high altitudes, there will be some automatic compensa-
tion for the less dense air. The oxygen sensor will signal the
air/fuel metering system that the A:F ratio is too rich. The
mixture will be enleaned to either the correct mixture called for
by the micro-processor unit (usually close to stoichiometric) or
the leanest mixture that the system can deliver. If the leanest
mixture is still to rich, the system's range of authority can be
shifted so that proper A:F mixture is obtained. Shifting the
range of authority is probably the simplest of the modifications
that will be needed to meet the HA standards.
The optimization effort for non-feedback systems will include
recalibration for cold start, power enrichment, and other driving
modes. Proper engine and emission control system performance must
be obtained at different cruising speeds, during accelerations and
decelerations, and during transient operation. The development
effort for non-feedback systems is expected to be more than the
development effort for feedback systems.
In order to determine if the capacity of HA commercial test
facilities is sufficient, the number of R&D tests which will be
needed must be estimated. In the chapter entitled Economic Impact
of the 1982-1983 High-Altitude Emission Standards (Chapter V) of
the "Regulatory Analysis" of this rulemaking the number of R&D
tests required to meet these HA standards is estimated. To sum-
marize that discussion, all diesel engine families, whether car or
truck, are expected to need 20 R&D tests each. Also, all gasoline-
fueled LOT families are expected to need 150 tests per famliy.
Gasoline-fueled LDV engine families are divided into two groups:
those which need so few R&D tests as to be considered already
meeting the standards (GM's C-4 system and Bosch's Jetronic system)
and those others which EPA estimates will each need 150 R&D tests.
The number of LDV and LOT engine families to be certified for
1982 is, of course, unknown at this time. We have assumed that
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approximately the same number of engine families will be .certified
in 1982 as was certified in 1980. In 1980 there were 156 non-
California LDV and LDT engine families certified. These include
families for sale in either the 49 states, excluding California, or
the 50 states, including California. Engine families which are
certified for sale in California only have been excluded because
these proposed regulations do not apply to those vehicles.
Since some manufacturers have their own facilities capable of
performing HA tests, a number of the 156 non-California engine
families will have R&D work done at these facilities instead of the
HA commerical facilities. We estimate that GM will have 32 LDV and
LDT engine families in 1982. As discussed earlier, GM has a test
facility in the Denver area which has 3 chassis dynos. At a
testing rate of 6 FTPs per shift per dyno site x 3 dynos x 3 shifts
per day x 7 days per week, GM could perform 378 FTPs per week.
Testing at this rate for 8 months (i.e., from the promulgation of
the final rule, November 1, 1980 to June 30, 1981) gives a poten-
tial of about 12,000 HA FTPs. Since all of GM's LDV engine fami-
lies will have the C-4 system, they will need minimal R&D testing
to comply with the HA standards. EPA estimates that GM's remaining
engine families (diesels and LDTs) will require less than 1000
tests total. Therefore, GM should easily be able to handle all
necessary R&D work at their own HA facility.
Ford's situation is similar to GM's. Ford has a HA test
facility with 4 chassis dynos while GM had only 3. Thus, Ford's
testing capacity is about 16,000 R&D tests. EPA estimates that
Ford will need about 3000 R&D tests. Therefore, Ford should easily
be able to handle all of their R&D testing in-house.
Mercedes Benz has both a facility at HA (Denver) and a HA
chamber in Germany. Each facility has one chassis dyno. There-
fore, Mercedes can run about 8000 FTPs in 8 months. However,
EPA estimates Mercedes will have to run less than 100 tests for
R&D purposes and, therefore, Mercedes will not have to use any of
the commercial HA test facilities.
Similar analyses for Honda (2 engine families), BMW (3 engine
families), Nissan (6 engine families), Fiat (2 engine families),
Subaru/Fuji (3 engine families), Peugeot (2 engine families), Toyo
Kogyo/Mazda (5 engine families), Toyota (8 engine families),
VW/Audi (3 engine families), Porsche (3 engine families), and Saab
(2 engine families) indicate that these manufacturers have the
capacity to do all of their R&D work in-house either at HA or in
chambers capable of simulating HA conditions. None of these
manufacturers should need to use the existing commercial HA test
facilities in Denver for R&D work.
The above discussion shows that the total number of LDV and
LDT engine families for which the necessary R&D work can be done at
manufacturers' facilities is 106. This leaves 50 LDV and LDT
engine families that may have to use the commercial testing labs in
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Denver. If all of these 50 engine families were gasoline-fueled
LDVs and LDTs, which did not employ either the C-4 system or the
Bosch^Jetronic, then the required R&D tests at HA commercial
facilities would be about 7500. However, since some of these
engine families are diesels and some use the C-4 or Bosch Jetronic
systems, EPA estimates that the number of R&D tests to be conducted
at HA commercial facilities will be about 6400. As discussed
earlier, EPA estimates that the commercial HA test facilities are
capable of performing about 476 FTPs (excluding SHED) per week.
This means the test capacity for 8 months is approximately 16,000
tests. Subtracting the tests needed for R&D work (6400) leaves
a reserve capacity of 9,600 tests. Therefore, EPA has determined
that adequate HA comercial testing facilities exist to handle the
R&D work required for this rulemaking.
As mentioned earlier, the above analysis is based on a very
conservative assumption — that manufacturers will not begin
high-altitude development testing until November 1, 1980, the
projected date for promulgation of the final rule. Even assuming
this to be true, we showed that existing commercial facilities
would be able to provide the high-altitude R&D test capacities
necessary for those manufacturers which do not have their own
high-altitude test facilities.
EPA is aware, however, that many manufacturers have already
begun their high-altitude R&D test programs. Chrysler has been
running tests at ETC since February of this year (telephone
conversation of June 30, 1980). JRT has also notified EPA that it
has performed testing at high altitude as well (June 2, 1980 letter
to EPA). Finally-, conversations with ATL and ETC indicate that a
substantial amount of high-altitude development work has been done
by several manufacturers. The exact amount of testing that has
been done by each manufacturer is unknown since manufacturers did
not volunteer such information in their written comments and
because the commercial labs will not divulge proprietary informa-
tion. The point is that much development work has been and will be
performed prior to November 1, 1980. Our above analysis ignores
this work, and to that extent overestimates the test capacities
needed after November 1. Thus, there will actually be an even
greater safety margin than the near-60 percent hypothesized above.
In conclusion, when it is remembered that: • 1) the number of
R&D tests required per engine family was estimated on the high
side, 2) most if not all manufacturers have already done some R&D
testing at the time of this writing (July, 1980) and will certainly
do more between now and November, 1980, 3) the estimate of existing
commercial test facility capacity includes liberal estimates for
maintenance and downtime, and 4) even with this worst case scenario
there is 60 percent reserve capacity, EPA's determination that
sufficient test capacity exists for high-altitude R&D work is both
reasonable and conservative.
b. Certification Needs. High-altitude test facilities
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needed for certification testing appear to be more than adequate.
Since each manufacturer will be required to test only one emission
data vehicle per non-California engine family (see the issue
entitled "Number of Certification Vehicles" in this document), the
total number of certification tests at high-altitude should ap-
proximate the number of non-California engine families certified.
However, the actual number of high-altitude certification tests may
be somewhat more or less than the number of non-California engine
families. Tending to decrease the number of certification tests
which may be needed is the fact that some low-altitude, non-
California engine families will not need to be tested under high-
altitude conditions because of the exemption criteria discussed in
the issue "Exemptions" in this document. Tending to increase the
number of certification tests is the fact that some tests will be
voided due to mechanical problems or human error. But, as discus-
sed earlier, the void rate is included in the testing rates of the
commercial facilities and, therefore, no further consideration of
the void rate is required in this discussion of adequate commercial
testing capacity. Another factor tending to increase the number of
certification tests is emission test failures. Some emission-data
vehicles may not pass the emissions test the first time. Those
vehicles will have to be retested if the problems can be resolved
or, possibly, instead of retesting, new engine families (almost
identical to the ones which failed) could be created, tested at low
altitude and then tested at high altitude. Emission test failure
is relatively rare and it may well be that the exemptions will
cancel out the retests leaving the number of high-altitude certi-
fication tests about equal to the number of engine families to be
certified. However, since the exact number of non-California
engine families in 1982 and 1983 is unknown and the exact number of
exemptions and retests are unknown, a safety factor of 50 percent
will be used.
The number of non-California engine families to be certified
in model years 1982 and 1983 will be estimated by using the number
of non-California engine families that were certified in 1980.
Analysis of certification data for model year 1980 indicates that
156 certificates of conformity were issued for engine families that
could be sold only in the 49 states excluding California or could
be sold in all 50 states. Certification for California-only engine
families were not included. Applying the safety factor of 50
percent gives the estimated number of 234 high-altitude certifica-
tion tests per model year. As discussed earlier under "Existing
Facilities", the two commercial testing laboratories (ATL and ETC)
in Denver can perform 175 full FTPs (including SHED tests) per
week. This number assumes a void rate of 20 percent. The above
numbers show that the entire industry's high-altitude certification
testing could easily be done in less than two weeks if only the two
commercial laboratories were used. However, EPA expects that most
manufacturers who have high-altitude test facilities will do their
own certification testing. These manufacturers include GM, Ford,
Mercedes Benz, Honda, VW/Audi, Nissan, Toyota, Toyo Kogyo, Fiat and
Renault. The number of 1980 non-California engine families repre-
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sented by these ten manufacturers is 94, thereby leaving only (156
- 94) x 1.5 or 93 certification tests to be performed by the two
commercial laboratories in Denver. Thus, of the total amount of
commercial facility test time available between now and the 1982
model year, EPA estimates that less than 5 days would have to be
devoted to the actual certification of the emission-data vehicles.
c- Selective Enforcement Audit (SEA) Needs. One commenter
expressed concern that there would be no test facilities available
for SEA testing. EPA expects that HA commercial test facility
availability for SEA testing will be more than adequate. SEA
testing would not begin until after the start of the 1982 model
year. Therefore, development work needed for the first year of
implementation will be finished long before SEAs are required.
While it is likely that some development work will need to be done
for the 1983 model year, that effort should be less than that
required for the first year of implementation (i.e., 1982 model
year). Thus, there should be ample reserve testing capacity
at the time that SEAs would be done.
Furthermore, the number of SEAs that might be required at HA
is expected to be quite small. As discussed in the issue entitled
"Selective Enforcement Auditing (High Altitude)" in this document,
the number of SEAs at HA should approximate the percent of HA
sales. Since HA sales are about 4 percent of all sales, HA SEAs
would be about 4 percent of all SEAs. This is a very small number;
maybe 3 at most. Three SEAs might require 30 tests which is a
liberal estimate. Since EPA believes that excess HA commercial
testing capacity will be many times the 30 tests required for the
maximum number of SEAs, the Agency concludes that existing capacity
for commercial HA testing will be more than adequate for HA SEAs.
d. In-Use Surveillance Needs. The fourth area of demand to
be placed on existing commerical high-altitude test facilites is
the use of those facilities for EPA's In-Use Surveillance (IUS)
program. EPA contracts with test facilities each year to test
limited numbers of vehicles in different regions of the country.
The data from this testing are used to develop EPA's Emission
Factors which are subsequently used in air quality projections and
analyses. ATL's Denver lab will be testing vehicles for EPA's IUS
program from December, 1980 through July, 1981. At most, this
testing effort will require about 350 tests at ATL. Even if
utilization of the existing commercial HA test facilities ap-
proaches the 40 percent rate discussed earlier (an very unlikely
possibility); the 60 percent reserve capacity represents more than
enough full FTPs with SHED (3300) of certification quality to
handle the 350 tests needed for the IUS program. Therefore, EPA
expects that IUS testing will be absorbed by existing HA commerical
test facilities with little or no impact on their capability to
supply the auto industry with adequate capacity for R&D and certi-
fication testing.
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Reconnnendat ion
EPA has determined that available high-altitude testing
facilities are adequate to meet the testing requirements imposed by
the proposed regulation. Therefore, it is recommended that no
change to the proposal be made concerning this issue.
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D- Issue; Selective Enforcement Auditing
Summary of Issue
In the preamble to the NPRM, EPA stated that, "The Agency may
also require manufacturers to perform assembly-line testing (Selec-
tive Enforcement Audits) at high-altitude locations." No regulatory
changes to the current SEA program were proposed in the NPRM.
Summary of Comments
EPA received many comments with respect to the high-altitude
NPRM and Selective Enforcement Audits (SEA). Some commenters
stated that since EPA failed to explicitly propose a regulatory
system for implementation of SEA at high altitude, EPA would have
to repropose the SEA portion of the rulemaking. Many commenters
simply believed that high-altitude SEA testing would be impossible
due to an inadequate number of high-altitude test facilities (in
view of developmental and certification testing requirements and
too little time to construct new facilities) and/or the difficul-
ties involved in obtaining a sufficient number of high-altitude SEA
vehicles in a specified time period. A few commenters desired
clarification of EPA's position, with respect to whether foreign
manufacturers would be required to construct high-altitude test
facilities in the U.S., and whether a suspension or revocation of a
certificate would apply only to vehicles operated at the altitude
at which the SEA failure occurred, or at all altitudes. Finally,
several commenters recommended alternate test procedures for
high-altitude SEA and one manufacturer expressed concern about the
criteria EPA would use to determine when a SEA was required.
Major Subissues
1 . Adequacy of Proposal. Ford commented that EPA had failed
to propose a responsible regulatory system for the implementation
of SEA at high altitude and, therefore, reproposal of this portion
of the NPRM is required. Ford also believed that the actual
mechanics of the high-altitude SEA program were impermissibly
vague. The Motor Vehicle Manufacturers Association (MVMA) stated
that EPA should withdraw its high-altitude SEA testing require-
ments. After certain problems (discussed under other SEA sub-
issues) have been resolved and a specific need for a high-altitude
SEA program has been identified, MVMA recommended that the program
then be reproposed for public comment.
2. Facilities. EPA regulations require that manufacturers
provide a testfacility that would be capable of performing high-
altitude (HA) emission testing for SEA. Some commenters expressed
concern that not enough HA facilities are available to conduct SEA
testing, or to perform the testing within the time constraints
imposed by the SEA regulations. The Motor Vehicle Manufacturers
Association (MVMA) stated that leasing or renting facilities would
present considerable problems to manufacturers and EPA because of
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the following reasons: (1) facilities may not be available quickly
enough to conduct SEA in an expeditious manner due to the require-
ments of HA development and certification testing; and 2) schedu-
ling problems might occur due to the unknown number of required
audit tests or the possibility of an audit failure. In addition,
MVMA noted that §86.079-30(d)(2) requires all manufacturers to
provide HA SEA test facilities and manpower, but stated that with a
large number of manufacturers competing for available facilities
and because of the difficulty of predicting how many tests would be
required, scheduling problems would be encountered. Chrysler
stated that it does not have a HA facility, and would have to
purchase cell time from a private firm. Therefore, they would be
competing with other manufacturers and with EPA itself for time,
and this would result in extremely complicated scheduling difficul-
ties. Chrysler believed that a SEA at a contractor facility would
take up to one month, depending on cell availability. In addition,
Chrysler felt that there was no guarantee that the minimum require-
ment of four tests per day could be achieved utilizing a contractor
facility. Further, Chrysler commented that the development of
rolls validation data prior to conducting SEAs would require
several weeks of contractor time. Volkswagen (VW) stated that they
can not contract for HA testing in the short time frame imposed by
the SEA regulations. VW also suggested that test capability at the
HA location, or the development and availability of HA chambers at
manufacturing facilities, are extremely limited, and that the
capacity of these facilities would be fully utilized for develop-
ment testing. Subaru of America stated that there are problems
with testing in Denver because of scheduling problems and lack of
available facilities. They indicated that they are considering
building a HA facility in Japan, and that approximately 22 months
of lead time is necessary to develop operating procedures and do
some engine design work. Therefore, they suggested that the
effective date for these HA regulations be extended to the 1983
model year. Ford stated that they needed to acquire an environmen-
tal chamber. They claimed that it would take a "couple of years"
to construct an operational facility.
3. Impact on Foreign Manufacturers. Several foreign manu-
facturers were concerned that their HA test facilities might have
to be located in the U.S., thereby increasing the cost of SEA
testing due to shipping costs. Nissan stated that a high-altitude
test facility for SEA testing, e.g., a pressure 'chamber, would be
required at each assembly plant, or SEA test vehicles would have to
be sent to Denver, Colorado; in either case, Nissan believes it is
too expensive and unreasonable. Renault stated that high-altitude
SEA testing would have to be conducted in the U.S. and would,
therefore, be very expensive for an importer. Jaguar/Rover/Triumph
(JRT) believes that HA SEA is financially burdensome due to the
company's lack of HA testing facilities and the distance to suit-
able commercially available facilities. (JRT did not indicate
where they anticipated these facilities would be located.)
4. Available Vehicles. Some manufacturers were concerned
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that a sufficient number of HA vehicles would not be available in a
specified time period for SEA testing. American Motors stated that
there would be a lack of sufficient HA vehicles for SEA testing.
International Harvester stated that, based on their 1979 audit,
SEAs can not be easily completed in a short period of time because
a sufficient number of HA vehicles may be difficult, if not impos-
sible, to find. The Motor Vehicle Manufacturers Association (MVMA)
stated that there may be a lack of HA-equipped vehicles to complete
the audit within a reasonable time period, especially for low-
volume manufacturers. MVMA pointed to a possible lack of necessary
engine, transmission, and axle ratio categories at the assembly
plant or on dealer lots, and stated that pre-sold vehicles would
further reduce the number of vehicles available. Chrysler stated
that SEA test vehicles required under the batch sampling plans may
exceed the entire sales population of a high-altitude configura-
tion.
5. Sanctions. Ford asked for a clarification of the Selec-
tive Enforcement Audit (SEA) implications of the new regulations.
Ford inquired whether a suspension or revocation of a certificate
of conformity would apply only to vehicles operated at the altitude
at which the audit failure occurred, or at all altitudes. Ford
contended that EPA lacks,authority to suspend or revoke certifi-
cates based upon testing at any altitude other than the altitude at
which the vehicles in question are principally operated. Ford
provided no basis for this statement.
6. Alternative Test Procedures. Currently the Federal Test
Procedure (FTP)isusedtotestvehicles during SEAs. Several
manufacturers suggested that EPA use an alternate test procedure
for HA SEAs to ease the scheduling and cost problems that the
manufacturers believe will occur as a result of the HA SEA program.
American Motors and Ford suggested that EPA adopt a test procedure
patterned after the California Air Resources Board (GARB) test
procedure for vehicles that will be operated at high altitude.
Ford further recommended that a more representative driving cycle
be developed for high-altitude testing. Chrysler believes that HA
vehicles should be tested at low altitude and a mathematical
adjustment should be used to determine anticipated high-altitude
performance. Chrysler also recommended the development of a more
representative driving cycle. Nissan recommended, for economic
reasons, that altitude compensator functional tests be used for HA
SEAs instead of chassis dynamometer tests.
7. Test Order Criteria. Section 206(b) of the Clean Air Act
authorizes the Administrator to test new motor vehicles to deter-
mine whether they do in fact conform with the regulations with
respect to which the certificate of conformity was issued. Inter-
national Harvester (IH) stated that EPA should limit SEA test
orders only to situations where there is a specific indication that
a vehicle configuration is failing to conform to the regulations
at HA.
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Analysis of Comments
1. Adequacy of Proposal. Section 206(b) of the Act autho-
rizes EPA to test new production vehicles to determine compliance
with emission requirements contained in regulations issued under
Section 202 of the Clean Air Act. The Agency established the
LDV/LDT SEA program to accomplish that objective. As additional
standards become applicable to these, vehicles, EPA may exercise
its discretionary authority to test for compliance with those
standards.
The SEA regulations in Subpart G of Part 86 are structured to
accommodate new LDV and/or LDT emission standards within the
existing SEA program. For example, when particulate standards
become effective in the 1982 model year, diesel LDVs and LDTs will
also be tested under SEA for compliance with those standards. The
only changes that EPA made to the SEA regulations because of the
new particulate standards were: additional information required
with regard to particulate testing results (a new test procedure
was promulgated) and wording changes to indicate that compliance
must be determined for all "regulated" pollutants instead of just
the "three" pollutants presently tested for (i.e., HC, CO, and
NOx) . See 45 FR 14524-14525, March 5, 1980. The only mention of
SEA in the preamble to the particulate rule was the discussion of
the deletion of separate SEA test procedures and the adoption of
the test procedures used during certification in Subpart B of 40
CFR 86, including the new particulate test procedure, for SEA
purposes.
For the proposed high-altitude emission standards, EPA had
determined that no regulatory changes to the existing SEA program
were required due to the new standards and, therefore, no proposed
changes were included in the NPRM. EPA believes that any unique
situations which may develop when testing vehicles under high-alti-
tude conditions can be dealt with adequately under the purview of
the existing SEA regulations. Manufacturers viewed their high-alti-
tude SEA testing responsibilities within the context of the SEA
program as it presently exists and indentified or alluded to these
unique situations. As discussed in other SEA subissues, the Agency
believes that all of the manufacturers' concerns can be accommodat-
ed under the present SEA program and has therefore made no amend-
ments to Subpart G of Part 86 in this final rule.
In summary, EPA does not believe that a reproposal describing
a program of high-altitude vehicle Selective Enforcement Auditing
is necessary because this program is already covered by the present
SEA regulations. The SEA regulations apply to both high-altitude
and low-altitude vehicles and are not "impermissibly vague," as
Ford suggested, because the special high-altitude testing situa-
tions and problems anticipated by both EPA and the manufacturers,
and discussed under other SEA subissues, can be handled by the
flexibility contained in the existing SEA regulations, e.g.,
very low-volume high-altitude vehicle configurations can be tested
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using sampling plans A, B, or C of Appendix VIII of 40 CFR 86, if
necessary (see Subissue 4); additional time for shipment to
high altitude facilities may be granted under §86.608(e) (see
Subissue 3); and the 4-test-per-day requirement may be relaxed
under §86.608(g) if a manufacturer experiences scheduling diffi-
culties at contractor facilities (see Subissue 2).
MVMA suggested that a high-altitude SEA program be established
only after a specific need for this program has been identified.
Experience with the current SEA program indicates that compliance
by a prototype certification vehicle does not necessarily indicate
that the manufacturer's production vehicles will also meet the
standards. Since the initiation of the program in 1977, eight
vehicle configurations have been terminated as a result of SEA test
orders, with failure rates varying from 72 to 91 percent. MVMA did
not identify any characteristic of high-altitude vehicles which
indicate that they will comply with high-altitude emission stan-
dards to a greater degree than that of low-altitude vehicles to
low-altitude standards.
SEA provides a logical means of ensuring that production
vehicles comply with standards at the time of manufacture by
testing vehicles at the completion of assembly. In this manner,
SEA provides a deterrent to the production of noncomplying vehi-
cles, as experience with the program has illustrated, and thus
serves to prevent introduction into commerce of vehicles polluting
above the established standards. Considering the substantial
contribution of mobile source emissions to ambient HC and CO in
high-altitude regions and the air quality benefits to be obtained
from adherence to the proposed standards, EPA sees a very definite
need for monitoring compliance of motor vehicles destined for
high-altitude use.
2. Facilities. Presently, two of the five domestic manu-
facturers (GM and Ford) have test facilities in Denver, Colorado, a
high-altitude location, which are capable of performing the Federal
Test Procedure (FTP). GM has three chassis dynamometers; Ford has
four.I/ Chrysler, American Motors Corporation (AMC) and Inter-
national Harvester (IH) do not have their own HA test facilities.
Of the seven Japanese manufacturers, only Honda has an emission
test facility capable of performing the Federal Test Procedure at a
high-altitude location.^/ Mercedes-Benz and Fiat are the only
European manufacturers which have test facilities in high-altitude
locations.^/
At the present time, only a small proportion (approximately
4.0 percent) of total vehicle sales are expected to occur at high
altitude. Once the Agency is satisfied that HA vehicles are not
more likely to be in noncompliance with the emission standards than
low-altitude vehicles, the proportion of test orders applicable to
HA vehicles should generally approximate their sales fraction.
Thus EPA does not expect manufacturers to construct facilities
solely for HA SEA testing if other options exist.
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Presently, there are two independent HA testing facilities
(Automotive Testing Laboratory (ATL) and Environmental Test Cor-
poration (ETC)), both located in the Denver area. ETC has two test
cells, with the capacity to do a total of 12 tests per eight-hour
shift, while ATL has one cell with the capacity to do 6 tests in an
eight-hour shift.47
Since fewer than 12 tests would be required to complete a
typical HA audit, these facilities provide a substantial testing
capability for manufacturers, even considering those tests required
for preconditioning, voided tests, and normal downtime. Therefore,
with presently available contractor facilities, the Agency believes
sufficient capacity exists to accommodate HA SEAs as well as
certification and emission calibration testing. The ability of
contractors to operate on more than one shift and the possibilities
of HA SEA testing by foreign manufacturers outside of the United
States should supplement high-altitude test facility availability.
Further, if a manufacturer which has no HA facility of its own is
unable to schedule a facility for SEA testing on an "as-needed"
basis, sufficient lead time may be provided before actual testing
must begin so as to enable the manufacturer to obtain the use of a
HA test facility. EPA may also exercise its authority under
§86.604 of the regulations to perform HA SEA testing using its own
mobile emission testing facility (METFac). In this latter in-
stance, the EPA facility would be devoted exclusively to SEA
testing, so that the manufacturers should experience no facility
availability or scheduling problems.
The two manufacturers (Ford and Subaru of America) who men-
tioned problems with insufficient lead time for building a HA
facility did not provide any documentation to substantiate the
amount of time they claim is needed to build this facility-
According to ATL, a lead time of 9 months is necessary to build a
HA test facility.
In summary, the Agency believes that there will be a suffi-
cient availability of high-altitude facilities to meet SEA testing
needs.
3. Impact on Foreign Manufacturers. The SEA regulations
require manufacturers to provide the personnel and equipment
(facility) needed to conduct testing. This facility (the manu-
facturer's own or a contractor's) could be located anywhere as long
as the high-altitude conditions are satisfied when the exhaust
emission tests are conducted under Subpart B of 40 CFR 86. There-
fore, a foreign manufacturer has the option of testing at a HA
facility in the U.S. or in its own country. If a foreign manu-
facturer has access to a HA facility in its own country and wishes
to test there, EPA will conduct any HA SEAs at that facility to
minimize shipping costs and to help provide for more expeditious
auditing. However, if a foreign manufacturer elects to use a HA
test facility in the U.S., then EPA will require that manufacturer
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to ship the HA SEA test vehicles from its assembly plant (or, if
feasible, from storage at a U.S. port of entry) to the test facil-
ity in U.S. Any increases in shipping costs should be nominal
since the vehicles were presumably destined for sale in the general
area of the test facility. The Agency's possible use of its mobile
emission testing facility (discussed earlier) for SEA testing may
also lessen the impact of HA SEAs upon foreign (and domestic)
manufacturers. When a manufacturer believes it needs more than 24
hours for shipping test vehicles to the appropriate HA facility, it
can request additional time under §86.608(e) of the regulations.
4. Available Vehicles. None of the manufacturers' comments
were specific enough to demonstrate to EPA why it would not be
possible to complete an audit. The SEA regulations require that
the sampling plans in Appendix VIII of 40 CFR 86 be used in select-
ing test vehicles (§86 .607(c) ) . These SEA sampling plans are
structured to accommodate low-volume configurations, e.g., only 21
vehicles need be selected under sampling plan "A" and the audit can
be passed after testing as few as 4 vehicles. In certain situa-
tions, not all of the vehicles need to be shipped to the test site,
e.g., if the audit was passed before selection was completed. A
manufacturer may request an alternative random sampling plan under
§86.607(a), provided that the request is made in advance of receipt
of a test order and that the Administrator approves the alternative
plan. EPA usually does not elect to audit configurations with a
production volume so low as to cause unexpeditious selection.
However, if a HA configuration were chosen for auditing and there
were problems in finding enough HA-equipped vehicles to complete
the audit, the manufacturer could select low-altitude vehicles and
have them modified for HA use as a dealership would, under author-
ity of §86.603(c) and §86.607(a), since the HA regulations require
that any vehicle (including low-altitude vehicles) manufactured for
sale in the U.S. shall comply with the HA standards, or be capable
of being modified to do so. EPA is considering the proposal of a
sequential sampling plan for LDV SEA testing which would further
ameliorate problems associated with the lack of SEA test vehicles.
Using sequential sampling plans, only a small number of vehicles
(as few as 4) would have to be selected and tested to complete an
SEA, and the selection of large numbers of vehicles under the
current batch sampling plans would be eliminated.
5. Sanctions. Paragraphs (h) of §86.082-8 and (h) of
§86.082-9 require that all light-duty vehicle (LDVs) and most
light-duty trucks (LDTs) must be capable of complying with both the
low and high-altitude emission standards, "by initial design,
adjustment, or modification," with a possible waiver of the re-
quirement for certain low power, high fuel economy LDVs. Ac-
cordingly, certificates of conformity certify compliance with both
low and high altitude emission standards ( §86.082-30(a)(3)) .
Vehicles sold for principal use at high-altitude locations must
have undergone the required adjustments or modifications, if any,
necessary to be covered by the certificate.
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EPA may issue a test order requiring the testing of new
high-altitude vehicles under high-altitude conditions. Under
Section 206(b) of the Clean Air Act (Act), the purpose of this
testing is to determine whether the production vehicles conform
with the regulations with respect to which the certificate of
conformity was issued. According to Section 206(a), certificates
are issued when a manufacturer has demonstrated conformity with
regulations prescribed under Section 202. Since the high-altitude
regulations are being promulgated under the authority of Section
202, a manufacturer that does not comply with these regulations can
not be granted or retain a certificate of conformity. One of the
regulatory requirements, as stated previously, is that all LDVs and
most LDTs must be capable of meeting the applicable emission
standards for any altitude operation.
If the results of SEA testing indicate that vehicles do not
comply with the high-altitude standards, then the EPA Administrator
can, under the authority of Section 206(b)(2) of the Act, suspend
or revoke the certificate covering those vehicles. Since any
configuration is originally issued its certificate on the basis of
compliance with both low-altitude and high-altitude standards, even
if a modification or adjustment to the low-altitude vehicle was
necessary in order for it to become a high-altitude vehicle, the
low-altitude vehicles will also be affected by the suspension/
revocation order. Due to the audit failure, the latter vehicles
will have not satisfied the regulatory requirement that they be
capable, by initial design, adjustment, or modification, of com-
plying with the high-altitude emission standards.
To suspend or revoke only the certificates for the high-
altitude vehicles may result in certain vehicle models only being
available in the low-altitude configuration. This is the situation
that developed during the 1977 model year, when high-altitude
vehicles needed to demonstrate compliance only with high-altitude
standards in order to be granted a certificate of conformity
applicable only to those standards. (Note that the language of
§86.077-30(a)(3) , "One such certificate. . .will certify compliance
with no more than one set of applicable standards," was amended, in
§86.082-30(a)(3), to add "...except for low-altitude and high-
altitude standards.") The resulting limitations on model avail-
ability in high-altitude areas generated adverse public reaction
and caused Congress, in 1977, to revoke EPA's separate high-
altitude certification program. For the Agency to begin in the
1982 model year to selectively suspend or revoke certificates of
conformity, based on altitude of operation, could produce the
situation that Congress was attempting to rectify in the 1977
amendments to the Clean Air Act. EPA will therefore use its
statuatory authority to apply a particular sanction (e.g., sus-
pension of a certificate) to the entire configuration, i.e., at
all altitudes, when vehicles fail a Selective Enforcement Audit
based on testing under either low-altitude or high-altitude con-
ditions, unless the manufacturer can demonstrate, under §86.612(j),
that the decision to suspend or revoke a certificate of conformity
for a configuration is not appropriate for the configuration as a
whole.
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6. Alternative Test Procedures. The SEA regulations, at
§86.608(a), require that SEA vehicles be tested according to the
FTP. This was done to ensure that the results of SEA tests could
be compared with the applicable emission standards. These alterna-
tive test procedures were also suggested for HA certification
testing, but have been rejected by the Agency- The GARB test
procedure and the altitude compensator functional test were re-
jected for certification purposes because they do not give a result
that can be compared with the standard. EPA rejected the mathe-
matical correction that Chrysler suggested because it does not
yield accurate results. These alternative test procedures and the
specific reasons they were rejected are discussed in the certifi-
cation portion of this Summary and Analysis of Comments.
7. Test Order Criteria. In the determination of which
vehicle class should be subject to a SEA test order, EPA uses
several criteria which provide information regarding potential
nonconformance of vehicles with the standards. These include
certification emission testing results, manufacturers' assembly-
line emission data from new vehicles, and other indications of
noncompliance. In this manner, EPA focuses its audits on those new
vehicle classes most likely to be in noncompliance with the emis-
sion requirements. Therefore, the suggestion of IH is already
substantially incorporated into the SEA Program.
Recommendation
Based on the above analysis it is recommended that no changes
be made to the high-altitude Selective Enforcement Audit program.
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References
!_/ Letters from GM and Ford to T.D. Mott, U.S. EPA, Ann Arbor,
Michigan, both dated May 28, 1980.
2/ Letters from Japanese manufacturers to T.D. Mott, dated May
~ 28, 29 and 30, 1980.
3/ Letters from Mercedes-Benz and Fiat to T.D. Mott, dated May 28
and 29, 1980, respectively.
4/ Letters from ATL and ETC to T.D. Mott, U.S. EPA, dated May 15
and 16, 1980, respectively.
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E- Issue; High-Altitude Certification
Summary of Issue
EPA proposed that compliance with the proposed high-altitude
(HA) standards be shown in the same basic manner that low-altitude
compliance is shown. That is, emission-data vehicles would be
required to be tested according to the light-duty vehicle (LDV) and
light-duty truck (LOT) Federal Test Procedure (FTP). However, the
testing would be done at HA instead of low altitude.
Summary of the Comments
Major Subissues
1 • Alternative Certification Test Procedures. The manu-
facturers who commented on this issue mainly requested that EPA
drop the proposed certification program and adopt some form of
alternative certification program. Most commenters claimed that
the HA certification program used in California (see the Appendix
to this issue) would be acceptable to the manufacturers and would
reduce their costs and leadtime requirements. In addition, MVMA
claimed the California procedures have "already been found to meet
the needs of high-altitude population centers" and AMC claimed that
the California procedures are "an effective means of reducing
high-altitude emissions." However, neither commenter included any
analysis or supportive data to substantiate the claim.
S
2. Testing in Foreign Countries. Peugeot and Renault both
asked EPA to address the question of where can certification
testing be done by foreign manufacturers. Could the testing be
done in their countries and the results sent to EPA, or would the
testing have to be done in the U.S.?
3. FTP Driving Cycle Change. Ford and Chrysler commented
that the driving cycle used in the FTP is inappropriate for use at
HA. They claimed that since performance is adversely affected at
HA, the emission-data vehicle will experience decreased accelera-
tion rates and increased time at wide open throttle (WOT) when
being operated over the driving cycle at HA. They claimed that a
new driving cycle should be developed to represent HA driving
patterns since the current driving cycle is unrepresentative.
4. HA Coastdown. Honda expressed concern that the dynamo-
meter power determination as described in EPA Advisory Circular No.
55B (coastdown) should not be used at HA. The coastdown procedure
is performed at low altitude where the air density is greater than
at HA. Therefore, coastdown power settings obtained at low alti-
tude would be too high to represent HA coastdown.
Analysis of comments
1 Alternative Certification Procedures. Since most commen-
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ters requested that EPA adopt the State of California Air Resources
Board's (GARB) HA certification scheme, a brief discussion of that
program follows. CARB's Manufacturers Advisory Correspondence
#78-2 which explains the program in more detail is attached as
Appendix 1.
CARB's basic requirement is that the tailpipe air to fuel
ratio (TAFR) during selected driving modes (e.g., idle, 30 mph
cruise, 50 mph cruise, and WOT) be shown to be stoichiometric or
leaner at elevations up to 6,000 feet except in those modes where
the sea level TAFR is richer than stoichiometric. In those
instances, the TAFR up to 6,000 feet must not be richer than at sea
level.
GARB gives three acceptable methods to demonstrate compliance
with their HA test requirement. For the "Flow Bench Testing"
method the fuel and air mass flow rates, including secondary air
injection if applicable, are measured under sea level conditions
and under simulated conditions of 6,000 feet of altitude. The
results are compared and if the above TAFR criteria are met then
that vehicle is deemed to be in compliance. Another method sug-
gested by CARB is called the "Analytical Method." This method
first measures the fuel and air mass flow rates at sea level by
using the "Flow Bench Testing" method. However, instead of mea-
suring the mass flow rates under altitude conditions, they are
calculated from the sea level mass flow rates using correction
factors which were derived by comparing the air density at sea
level to that at 6,000 feet of altitude. The mass flow rates at
sea level and 6,000 feet are compared and compliance is deter-
mined. The third method suggested by CARB is called the "Dyna-
mometer Testing" method. The concentrations of oxygen (02) and
carbon monoxide (CO) are measured for each driving mode while
operating the vehicle or engine on a dynamometer. This is done
both under sea level conditions and altitude conditions. If the
concentration of 0^ is greater than or equal to one half the
concentration of CO, then the TAFR is considered to be stoichio-
metric or leaner. For the sea level driving modes that have a rich
TAFR, the ratio of 02 to CO at altitude must be greater than or
equal to the same ratio at sea level.
EPA acknowledges that there is probably a reduction in HA
hydrocarbon (HC) and CO emissions which results from CARB's compli-
ance program. Certainly the primary reason for increased HC and CO
emissions at HA as compared to low altitude is that the air-to-fuel
ratio becomes richer with increasing altitude. This is due to the
fact that the density of air decreases with altitude. Thus, the
mass of oxygen necessary for the combustion of the fuel decreases
with increasing altitude while the amount of fuel entering the
combustion chamber remains about the same. This results in an
overly rich mixture, incomplete combustion and increased HC and CO
emissions. Furthermore, fuel economy and driveability are ad-
versely affected. Since CARB's HA compliance program seeks to
ensure that enough 0 is present to fully combust the fuel, the
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potential exists to improve HA emissions. The problem is that the
GARB certification procedures do not require that the 02 be used
efficiently to reduce emissions. For example, if secondary air is
injected into the exhaust manifold or somewhere else downstream of
the combustion chamber, the TAFR at HA can be made stoichiometric
6r leaner very easily by merely being sure to inject plenty of
ai5' This would satisfy CARB's certification criteria. However,
this in no way guarantees that the tailpipe emissions have been
significantly reduced. Sufficient oxygen is not the only factor
needed to assure further combustion of the emissions from the
chambers.
For example, if the temperature is too low then there may not
be much oxidation of the unburned emissions. Proper mixing of the
injected air with the exhaust stream is necessary because the 02
and the unburned emissions must come in contact in order to react.
Residence time is also important since the more time the molecules
have to get together, the more complete the reaction will be. The
GARB procedure does not account for any of these factors.
The most that the GARB procedure can claim is that there is
sufficient 02 available for potential oxidation of the unburned
emissions during selected driving modes. As discussed above, there
are a number of other factors which must be considered to actually
achieve oxidation of those unburned emissins. Furthermore, the
GARB procedure does not even require proof of sufficient oxygen for
the most complex of driving modes - transient operation. A car-
buretion system designed and calibrated to deliver enough air to
ensure a stoichiometric or leaner TAFR at idle or cruise or WOT
will not necessarily give a stoichiometric or leaner TAFR during
transient operation. Since much of the operation of a vehicle is
transient, especially in urban areas where air pollution is the
worst, this mode is very important. The Federal Test Procedure
(FTP) has transient operation as a major part of it and, therefore,
EPA's proposed HA certification program will account for this
important driving mode.
For the above reasons, EPA is convinced that if the GARB HA
certification program were implemented, the reductions in emission
levels of HA vehicles would be substantially less than under EPA's
proposal is needed to meet the National Ambient Air Quality Stan-
dards (NAAQS) in HA areas (see the issue "Air Quality" in this
document), and EPA's proposal is cost effective (see the chapter
"Economic Impact" in the "Regulatory Analysis" of this rulemaking),
the Agency finds it unacceptable to use CARB's HA certification
program in which HC and CO emissions would be substantially more
than under EPA's proposal.
In summary, EPA believes that the proposed HA certification
program will reduce HA emissions substantially more than the GARB
program because it will require closer scrutiny of all the factors
which affect emissions generation and control. For example, EPA's
proposal will assure that proper attention is given to adequate 02,
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reaction temperature, residence time and reactant mixing instead of
just DŁ concentration. Additionally, all driving modes will have
to be considered, including complex transient operation, instead of
just the four modes required by GARB.
Another problem with the GARB HA certification program is that
the emission reductions are not known. Although there may well be
some reduction in emissions for California-certified HA vehicles as
compared to pre-certification HA vehicles, the reduction will not
be quantified. If EPA were to adopt a HA certification program
similar to California's (the significantly less reduction notwith-
standing), the Agency would have to increase its in-use surveil-
lance to determine the emission levels of the HA vehicles.
Because of the large variation in emission levels that would likely
occur among different models under alternative certification
schemes, it would take a larger in-use surveillance program to
characterize emissions since the more variation there is in a
population, the more samples it takes to define the mean and
variation of that population. Such an in-use surveillance program
could be quite costly.
The reason actual emission levels must be determined is
because of their crucial role in projections of air quality. The
national programs for reducing air pollution and attaining the
National Ambient Air Quality Standards (NAAQS) depend on the
projection of air quality in different regions to some future
date. If such projections indicate that a region will not meet the
NAAQS, then planning can begin now for additional air pollution
control programs to bring the region into compliance. On the other
hand, if the air quality projections indicate that a region will be
in compliance, then additional air pollution programs probably are
not needed. Thus, air quality projections are critical tools to
help in the decisions of when more control is needed as well as
when enough control has been achieved. These projections would not
be possible if the emission levels of different sources of air
pollution (e.g., automobiles, trucks, power plants, etc.) were not
known.
Emission levels of vehicles also need to be known in order to
analyze the effects of proposed urban projects such as parking
structures and traffic corridors. Such projects must consider
whether or not the local environment (in this case the local air
quality), can withstand the additional stress of the proposed planl
The GARB certification procedure for HA vehicles gives little or no
information as to what the emission levels of the vehicles might
actually be.
Another reason GARB's compliance program should be rejected in
favor of EPA's proposed program involves what is known as 207(b)
warranty protection. In 1977, Congress authorized EPA to develop a
warranty program to protect consumers from defective emission
control systems or components. In Section 207(b) of the Clean Air
Act, 42 U.S.C. 7541(b), Congress stated that if an in-use short
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test could be developed which had reasonable correlation with the
FTP, then that short test could be used to determine whether or not
to invoke warranty regulations.
EPA has spent a number of years developing a short test which
correlates with the FTP. If a vehicle fails the short test, it
is assumed that it would fail the FTP. Since vehicles are supposed
to pass the FTP for the first 50,000 miles of their useful life,
something must be wrong with the vehicle's emission control
system if it fails before 50,000 miles. The vehicle owner may have
maladjusted, tampered with, or abused the emission control system.
On the other hand, the emission control system could have been
improperly assembled and/or installed at the factory or defective
emission control components might have been used. If the failure
to pass the short test and, by implication the FTP, is the manufac-
turer's fault, then the manufacturer will have to pay for neces-
sary replacement or repairs.
The 207(b) warranty program will become increasingly important
as Inspection and Maintenance (I/M) programs become implemented,
and more and more vehicles are subjected to the short test.
Congress obviously intended that the manufacturer pay to fix faulty
emission control systems. EPA has no reason to believe that
Congress intended that only low-altitude consumers be afforded this
important warranty protection. Certainly HA consumers have just as
much right to emission control system warranties as do low-altitude
consumers.
However, in order to give HA consumers this warranty protec-
tion, a HA standard is needed. Since the short test is correlated
with the FTP, only the FTP can be used for HA certification if the
short test is to be used for HA warranty protection. In fact, HA
consumers will not have any warranty protection unless the HA, full
FTP, certification program is implemented. Theoretically, if
another certification program (such as California's) for HA was
promulgated, then another short test might be developed which would
correlate with that certification test and HA warranty protection
could be provided. Not only would such a certification scheme
present the problems of inadequate emissions control and unknown
emission levels as discussed earlier, but the effort needed to
develop a new short test could be huge. It could take a tremendous
amount of time and money to develop a reliable new short test which
could accurately identify vehicles with faulty emission control
systems especially when the emission levels at certification are
not even known. It could be many years before HA consumers would
have warranty protection. It may well not even be possible to
develop such a short test and, in that case, the HA consumer might
never receive HA warranty protection. EPA does not believe there
is sufficient reason to undertake for the second time such a large
effort when the Agency already has a short test and the cost of
EPA's proposed HA certification program is minimal as will be
discussed below.
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EPA has determined that HA areas need further HC and CO
reductions and that reducing LDV and LDT emissions to the levels
proposed is both feasible and cost effective. EPA is convinced
that CARB's HA certification program will not provide the reduction
required to meet the proposed standards. Therefore, EPA intends to
retain its HA certification program in a modified form to make it
even less burdensome than originally proposed. As discussed more
fully in the issue entitled "Number of Certification Vehicles" in
this document, EPA has reduced the cost of certification by about
67 percent. The Agency estimates that the cost of certification
will increase the retail price of a new'HA vehicle by only 0.01
percent (about $.76). It will be even less if the cost is spread
over all of the sales of a manufacturer rather than just HA sales.
EPA is convinced that the benefit gained from retaining the pro-
posed certification program far outweighs this minimal cost.
/ In summary, EPA's HA certification program as modified in this
document is the most cost effective method of assuring that the
required emission reductions are achieved in HA areas. CARB's
certification program for HA vehicles not only wouldn't provide the
required emission reductions but the amount of emissions actually
being produced would be unknown. This would lead to a substantial
increase in expenditures by the Agency to determine actual emission
levels so that necessary air quality projections can be made.
EPA's proposed HA certification program is also necessary to give
HA consumers the same timely emission control system warranty
protection as low-altitude consumers will have. EPA's program is
very inexpensive and the burden on the manufacturers is minor.
2. Testing in Foreign Countries.
Certification protocol will be the same for both high- and
low-altitude standards. Currently, manufacturers perform emission
certification tests at the facility of their choice and submit data
to EPA demonstrating their vehicles comply with the applicable
standards. After reviewing this data, EPA may select a particular
vehicle for conformity testing at a facility designated by the
Administrator. This facility may or may not be the manufacturer's.
These procedures are the same for both domestic and foreign manu-
facturers, and will not be changed by the promulgation of high-
altitude standards.
3. FTP Driving Cycle Change.
EPA received no data demonstrating that the driving habits of
low-altitude and high-altitude residents differ from one another.
Furthermore, it is not intuitively obvious that just because a
vehicle performs poorer at altitude, a driver will not demand just
as much acceleration at altitude as would be demanded at low-alti-
tude, i.e., the high-altitude driver may simply push harder on the
accelerator peddle. In this case, where a vehicle operator demands
similar acceleration the existing driving cycle is representative
of high-altitude driving patterns. Therefore, there appears to be
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no reason to change the existing FTP driving cycle.
4. High Altitude Coastdown.
The comments on this subissue are based on the fact that the
air density under high-altitude test conditions (5282 +_ 328 feet
or 83.3 +_ 1.0 kilopascal) is less than that under low-altitude test
conditions. EPA agrees that the lower air density at high-altitude
results in less aerodynamic drag on a vehicle. However, these
high-altitude standards have already accounted for this air density
difference.
Both the LDV and LOT high-altitude standards were derived by
adding an "altitude increment" to a low-altitude baseline to get a
high-altitude baseline. Then, the standard was determined by
taking a percentage of the high-altitude baseline (see the issue
entitled "Standards" in this document). The part of the above
standards determination relevant to this discussion is the "alti-
tude increment."
This "altitude increment" was obtained from MVMA data. MVMA
tested 25 vehicles at low altitude (St. Louis) and then tested them
at high altitude (Denver). The sales-weighted average emissions at
low altitude were subtracted from the sales-weighted average
emissions at high altitude to give the "altitude increment." In
the MVMA tests at high altitude no compensation was made for the
decreased air density when the dynamometer load factor was set.
Therefore the dynamometer load factors for the high-altitude
emissions tests were somewhat greater than they would have been had
the vehicles been subjected to the coastdown procedure at high
altitude.
It is logical to assume that since the dynamometer settings
were higher than they would have been if high-altitude coastdowns
had been used, HC and CO emissions were somewhat more too. This
increase in HC and CO emissions is presumably why the commenter
requested that EPA consider a high-altitude coastdown procedure.
Since the MVMA tests at high altitude produced levels of HC and CO
greater than if high-altitude coastdown had been used, the sales-
weighted average for high altitude was greater. Thus the "altitude
increment" was also greater as was the high-altitude baselines and
finally the high-altitude standards. In other words, the fact that
MVMA did not account for decreased air density at high altitude
when setting the dynamometer load factor carried through the entire
high-altitude standard setting technique and produce high-altitude
standards which are higher than they would have been had high-
altitude coastdowns been used by MVMA.
If EPA had unlimited time and resources, the Agency could
reestablish the standards (at a lower level) using new test program
data which had utilized high-altitude coastdowns in setting the
high-altitude dynamometer load factors. Then a high-altitude
coastdown procedure would be appropriate as a part of the high-
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altitude certification testing procedure. However, since the
Agency does not have unlimited time or resources and these high-
altitude standards already account for the decreased air density of
high-altitude conditions, EPA concludes that a high-altitude
coastdown procedure is not required or correct for this rulemaking.
Recommendat ion
It is recommended that EPA retain the HA certification program
as proposed except for the modifications discussed in the issue
"Number of Certification Vehicles" which can be found in this
document.
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Appendix 1
State of California Air Resources Board's
Manufacturers Advisory Correspondence # 78-2
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Attachment to Manufacturers Advisory
Correspondence ^73-2
CA7.3 Policy Kimia
Date Issued:
Subject t Ccr-pliance with California High-Altitude Test Rcquinsn
Applicability: 1G2Q ar.d s-jbsc-t-j^r.t rr.odel year -passenger cars, and
1S31 and subsequent irodal year light-duty trucks and medium-
duty vehicles.
v
Raferanca: Subsection S.d. of the "California Exhaust Emission
Standards and Test Procedures for 1980 and Subsequent Model
'Passenger Cars, Light-Duty Trucks, and Medium-Duty Vehicles,"
as amended Septejnber 30, 1977.
Background: Kany vehicle fuel altering systems have an Inherent
enrichment charactsHstlc with increasing altitude. This
characteristic can affect sessions of carbon conoxlc'e (CO),
. which cay be significantly increased by an excess of fuel or,
car.versaly, by a lack of oxygen. California's high-altitude
test requirement was promulgated in an effort to stabilize CO
emissions up to 6000 feet by requiring sufficient oxygen in
the exhaust to theoretically maintain sea level CO emission
Policy: A vehicle will be deemed in ccanpliance with Subsection S.d.
1f the manufacturer dssx>nstratES that the tailpipe air/fual
ratio (TAR) 1s, at elevations up to 6000 feet, stoichicsetric
or leaner In each of several driving trades. However 1f a
Vfihlcle operates in a given driving mode at sea level with a
TArR richer than stoichicssetric, then for that particular driving
Kxie the manufacturer 1s only required to show -that the TAFR is,
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Attachment to Manufacturers Advisory
Correspondence Ł73-Z
CAR3 Policy Manual
at elevations up to 5CCO feat, no richer than the TAR at
sea level. The driving rodes selectsd for tasting shall be
rcprosar.tatlYS of the full ranga of normal driving conditions,
•i
and shall include the following stsady-stata nadss: idle,
30 tsph road load cruise, 50 tnph read load cruise, W.O.T. in
the 20-30 c?h ranga. Assuming tha use of dry air and indclane
fusl (hydrogen to carbon atom ratio of 1.85), a TAR of 14.5
shall be considered a^staichiosetric ratio. The vehicle ,
jgar.ufactur*r ray correct this value for different fuels and/or " .
huoidity, subject to approvaj by the Executive Officer.
, • t
Tbrea acceptable nethcds of detannining the TAHl are attached.
Tha first, "Hew Bench Testing," is an example of a cathod
using flow bench measurements of the fuel ar.d air inass flow-
ratas ta datarains the TAFR's at ssa level and altitude. The
second, "Analytical Method," illustrates a theoretical c?i- \
-• -v. . -
culation of the TAR. at altitude frcm raaasunsnents of the \
' w -
TAR at sea level. (To usa tha "Analytical Method" to deter- / -V
crin« ccmplianca of vehicles using car-burster fee
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Attachment to .M.5nui
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Correspondence #73-2
CARS Policy Manual
Methods of Determining the TAFR
I. Flcvf Bench Testing
A. Measure the fuel and air rass flcwrates, Including secondary
air Injected 1f applicable, for each selected driving code
under saa level conditions.
B. ffeasure the fu«l and air mass flowratss, Including secondary
air injected 1f applicable, for each selected driving rode
under simulated 6000 feet altitude conditions.
C. The TAFR shall be determined frcra the above data using the
following equations:
TAFRo " alo * mso
°f
Khere n » mass flcvrrats of intake air
a. * mass flowrate of secondary air injected
Bf • mass flowrate of fuel
CFTowrates and densities used here and on the following
page ara at an altituds of 6000 feet, except that an "o"
subscript indicates values under standard conditions
at ssa level.)
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Attachment to Manufacturers Advisory
-71- Correspondence #78-2
CARB Policy Kinuil
II. Analytical Method (for ncn-altitude compensated
• systems, with or without fczdbick control)
A. Using the "Flc* Bench Testing" method, treasure the fuel and
&1r rass flowratss, Including secondary air injoctad if
applicable, for each selected driving rode undar sea level
conditions, and calculate the TAFR's fron this data. For
•
systems with feedback controls, eaJce these itsasurerants
with the control unit first connected, and then disconnected.
B. Tha TAFR at an altitude of 6000 feet may be dstarrdned using
tha above data (for systars with feedback controls, using
the Esasursnants made with tha control ur.1t disconnected)
and the fallowing assumptions and equations:
,
Khare p « density of air
T. For Idle and cruise driving inodes:
» • * *
TAFR « n, •»• m, « ra4^ * .S4 mfn
•f K09 "fo
2. For W.Q.T. driving rodes
TAFR - + m -
mf .84 (1.09) nfo 1,09
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~72~ Attachment to Manufacturers Advisory
Correspondence #78-2
CAR3 Policy Kar.ual
III. Dynirrseter Testing
A. fcisurs the concentrations of 0^ and CO in the tail pi pa
*hile operating the vehicle or engine in each selected
*
driving coda, both at ssa level and at an altituds (or
siirulated altitude) cf 6GOQ feet.
B. For a given driving mode. If the concentration of 0^ is
greater than or equal to one half the concentration of CO,
tha TAFR 1n that driving nade shall be considered to be
stoichicnetrfc or leaner.
C. For a given driving mode, 1f the .concentrate on of Og is
Isss than one half the- .concentration of CO, the TAFR 1n
' that driving tncda shall be considered to be richer than -
stoichiomatric.
0. The relative uagnitudes of the TAFR's at sea level and at
an altitude of 6000 feet shall be determined by the relative
sagnitudes of the ratios of the 0^ to CO concentrations.
For example, 1f a vehicle operates in a given driving mode
at sea level with an 0-:CO concentration ratio of 0.3, then
for the sama driving rcode at an elevation of 6GOO feet, the
vehicle must operate with an 02:CO concentration ratio
greater than or equal to 0.3.
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F. Issue; Number of Certification Vehicles
Summary of Issue
EPA proposed that any certification vehicle selected for
testing at low altitude could be selected for testing under
high-altitude conditions. Additionally, one other certification
vehicle for each engine/system combination within an engine family
could be selected for high-altitude testing if such a vehicle is
expected to have high exhaust emissions when operated at high
altitude.
Summary of Comments
Most commenters stated that the certification costs of the
proposed regulation were overly burdensome. (Certification costs
are further discussed in the chapter entitled Economic Impact in
the "Regulatory Analysis" for this rulemaking.) The number of
vehicles selected to undergo certification testing (emission-data
vehicles) is, understandably, a major factor in certification
costs. Under the proposal, EPA could select as many (and even
more) vehicles for testing under high-altitude conditions as were
tested at low altitude. The commenters observed that if the same
number of emission-data vehicles were tested under high-altitude
conditions as were tested at low altitude, the cost of certifi-
cation testing for high altitude could be more than the cost for
low-altitude certification testing. This is true because the cost
of shipping vehicles to Denver for high-altitude testing may be
substantial and, in addition, testing at commercial facilities will
be more expensive than testing at the manufacturers' facilities due
to the extra link in the profit chain.
The commenters continued that although EPA's proposed high-
altitude certification program would be certifying less than 4
percent of LDV and LDT annual sales, the cost of that certification
program could be substantially more than the cost of certifying the
other 96 percent of LDV and LDT annual sales.
Chrysler claimed the proposed regulations were inconsistent
concerning the number of emission-data vehicles which might be
selected for testing under high-altitude conditions. They stated
that §86.082-24(b)(l)(v) allowed the Administrator to select only
one vehicle for each engine/system combination within an engine
family while §86.082-26(a)(3)(i)(D) allowed the Administrator to
select for high-altitude testing, any vehicle that was selected for
testing at low altitude under §86.082-24(b)(1)(ii) through (vii).
The apparent contradiction occurs if the Administrator selects (for
low altitude testing) more than one emission-data vehicle to
represent a particular engine/system combination within an engine
family. In practice, the usual case is that more than one vehicle
per engine/system combination is selected for testing at low
altitude.
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Analysis of Comments
The proposed regulation was not as clear as it could have been
concerning the maximum number of certification vehicles which
EPA could select for testing under high-altitude conditions.
However, the proposed regulation was not inconsistent as Chrysler
claimed. Section 86.082-26 (a)(3)(i)(D) was correctly interpreted
by Chrysler. It would have allowed the Administrator to select any
vehicle that was tested at low altitude to be tested under high-
altitude conditions.
Chrysler's confusion arises from their interpretation of
§86.082-24(b)(l)(V). Their interpretation that this subparagraph
allowed the Administrator to select a maximum of only one emission-
data vehicle per engine/system combination is not correct. This
subparagraph was intended to allow the Administrator to select one
emission-data vehicle per engine/system combination for testing
under high-altitude conditions that had not been previously
selected for testing at low altitude. It would have given the
Administrator the option of picking a high-altitude, worst case
calibration if that calibration had not been selected for testing
at low altitude.
EPA agrees that, as proposed, the possibility exists that the
cost of certifying the high-altitude fleet could be greater than
the cost of certifying the low-altitude fleet. As discussed above,
the maximum number of certification vehicles which could be se-
lected is actually greater for high-altitude certification. This
fact together with the increased cost of conducting a high-altitude
certification test due to vehicle shipping expenses and commercial
facility usage certainly allows the possibility of an expensive
certification program for the high-altitude fleet.
However, it was never EPA's intent to test the maximum allow-
able number of emission-data vehicles. That maximum would have
been about six emission-data vehicles per engine family assuming
there is only one engine/system combination per engine family.
(This is presently true for the large majority of engine families.)
In the draft "Regulatory Analysis" for this rulemaking, EPA assumed
that only three emission-data vehicles per engine familyl/ would be
tested. This assumption was intended as a maximum and a maximum
certification testing cost was developed from it. This certifica-
tion testing cost was (215 engine families) x (3 tests per family)
x $1,800 per test) x (2 model years) = $2.3M. Spreading this
maximum certification testing cost over the 1.1 million high-alti-
tude vehicles expected to be sold during the 1982 and 1983 model
years, gives certification testing costs of about $2.00 per high-
altitude vehicle. This represents a 0.029 percent increase in the
new car retail price if the average retail price is assumed to have
been $7,000 2f in 1979.
In the Preamble to the NPRM, EPA again stated that the $2.3M
for certification testing was a maximum. Also, EPA stated that
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while the proposed rules provide broad selection criteria, the
number of vehicles actually chosen for testing will be small and
limited to vehicles which, in the Agency's engineering judgment,
are likely to have poor emission performance at high altitude.
Although EPA made it clear in the proposal that the actual
number of certification vehicles selected for testing under high-
altitude conditions would be small, the Agency appreciates the
concern of the industry that high altitude certification testing
could possibly be very expensive. In order to assure the industry
that the cost of high-altitude certification testing is kept
minimal, we have changed the selection criteria for certification
vehicles.
The new selection criteria require the manufacturer to choose
the one emission-data vehicle per engine family expected to have
the worst emissions when tested under high-altitude conditions.
The emission-data vehicle selected for testing under high-altitude
conditions will be one of the emission-data vehicles previously
selected for testing at low altitude. Thus, this regulation will
not cause the manufacturers to incur the additional cost of build-
ing a new emission-data vehicle and of accumulating 4,000 miles.
The total cost of certification has been modified also. In the
draft "Regulatory Analysis" EPA estimated that 215 engine families
would be affected by the proposed regulation. The Agency had
counted all LDV and LOT engine families in that estimate. It is
now recognized that vehicles certified for California sale only
will be exempt from this regulation. Thus, the estimated number of
LDV and LDT engine families to be certified per model year is 156.
A retest rate of 50 percent is used in calculating certification
costs. Retests are often required because of equipment malfunc-
tion, operator error, manufacturer and administrative errors, lack
of correlation with previous test, etc. The cost of certification
now becomes (156 engine families per model year) x (1.5 tests per
family) x ($1,800 per test) x (2 model years) = $842,400. If this
maximum certification testing cost is spread over the 1.1 million
high-altitude vehicles expected to be sold during the 1982 and 1983
model years, then the retail price increase of a high-altitude
vehicle due to certification testing is about $0.76 or 0.01 percent
of a $7,000 vehicle. The impact on sales of a $0.76 retail price
increase would be insignificant.
The new emission-data vehicle selection criteria, while not
providing the extent of assurance for high-altitude certification
that the proposed selection criteria would have, will give EPA
adequate assurance that high-altitude vehicles are meeting the
high-altitude standards. Since the Administrator can select any
of the low-altitude emission-data vehicles in an engine family, the
manufacturers assume substantial risk if they do not adequately
design all of their calibrations to meet high-altitude standards.
Also, Selective Enforcement Audits (SEAs) at high altitude lend
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incentive to the manufacturers to adequately design all of their
high-altitude calibrations.
In summary, although EPA emphasized that the number of certi-
fication vehicles selected for testing under high-altitude condi-
tions would be kept to a minimum, the Agency recognizes that the
manufacturers would prefer more definitive language. EPA has
concluded that the new selection criteria (i.e. one emission-data
vehicle per engine family) does not jeopardize the high-altitude
certification program and allows the Agency more accurately to
estimate the certification costs of this regulation.
Rec ommend at ion
It is recommended that the certification vehicle selection
criteria be changed to allow the Administrator to select one
emission-data vehicle per engine family for exhaust and evaporative
emission testing under high-altitude conditions. This emission-
data vehicle can be any engine -calibration and any evaporative
emission control system offered by the manufacturer.
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References
I/ "Draft Regulatory Analysis; Environmental and Economic Impact
~~ Statement for the Proposed 1982 and 1983 Model Year High-
Altitude Motor Vehicle Emission Standards," ECTD, OMSAPC,
OANR, EPA., pg. 43.
2/ Automotive News, 1980 Market Data Book Issue, April 30, 1980.
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G. Issue; Economic Impact
Summary of Issue
In the NPRM, EPA assessed the economic impact of the proposed
regulations. Among other things, the Agency projected that vehi-
cles using electronic feedback emission control hardware would
automatically meet the standards, or would only require an adjust-
ment to better control open-loop emissions at no cost. EPA esti-
mated that feedback systems would be utilized on 90 percent of the
LDVs in 1982 and 1983. Non-feedback vehicles which required
additional hardware were estimated to include 10 percent of the
LDVs and all of the LDTs sold at high altitude. For these vehi-
cles, EPA estimated an average of two aneroids would be required
per vehicle to meet the high-altitude standards, at an average cost
of $10 per aneroid (1979 dollars). The total cost of the package
was estimated to be $2.32 million for certification, $1.4 million
for LDV hardware, and $6.6 million for LDT hardware. No change in
fuel consumption was assumed in the NPRM. The cost effectiveness
of the proposed high-altitude standards was $170 per ton of HC
reduced and $5 per ton of CO reduced. The average cost increase
for a high-altitude vehicle which required additional hardware was
$26.
In this section, the comments concerning hardware cost and
complexity, economic impact on individual manufacturers, certifi-
cation costs, SEA costs, and cost effectiveness are analyzed. The
economic issues relating to the $40 vehicle modification limit,
fuel economy, exemptions, and available facilities are discussed in
their respective sections of this report.
Summary of Comments
Manufacturers were unanimous in attacking the proposed stan-
dards because of their economic impact. Generally, their comments
stated that EPA had significantly underestimated the cost of the
proposal.
A few private individuals and one from a high-altitude dealer-
ship commented, in a general way, that the proposed regulations
would unnecessarily increase consumer costs in high-altitude areas.
Major Subissues
1. Requisite Hardware And Its Cost. Only comments con-
taining specific information on high-altitude emission control
hardware are summarized below. Since EPA has previously decided to
delete the proposed $40 limit for modifying a vehicle to conform to
the emission standards, only those comments concerning vehicle
modification costs that are relevant to the remaining issue of the
increment in new vehicle prices are summarized below.
Ford - EPA was given two different estimates from Ford con-
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«
earning an increase in the retail price equivalent (RPE) for
newly-manufactured high-altitude vehicles. In comments at the
public hearing, a price for a non-feedback system (aneroid) was
estimated to range between $35 and $50. Generally, this is a small
increase over what Ford is currently charging for an aneroid
carburetor, i.e., $36 to $37.50. The added cost was attributed
to the need for additional carburetor work. In Ford's written
comments, a RPE of $200 to $225 for LDVs and $150 to $180' for LDTs
was presented. No elaboration was provided to justify these
costs. If a crash program .were required to comply with the
standards, the shortened development cycle woul-d increase these
costs to $800 to $900 for LDVs and $450 to $500 for LDTs.
Ford presented cost information for "minimum" and "maximum"
vehicle modifications in their written comments.
LDV Maximum Modification - $600 (1980 dollars)
Axle Ratio Change
Replace Carburetor
Re-Indexed Distributor Stator
Transmission Aneroid
Revised Air Pump Pulley
Change Speedometer Gear
LDV Minimum Modification - $280 (1980 dollars)
Axle Ratio Change
High Flow PCV
Revised Choke Pulldown
Re-Indexed Distributor Stator
Change Speedometer Gear
LPT Maximum Modification - $1,100 (1980 dollars)
Change Front and Rear Axle Ratio
Carburetor Change with Aneroid
High Flow PCV
Revised Choke Pulldown
Re-Indexed Distributor Stator
Transmission Aneroid
Change Speedometer Gear
Change Driveshaft Assembly
LPT Minimum Modification - $50 (1980 dollars)
High Flow PCV Valve
Revised Choke Pulldown
Re-Indexed Distributor Stator
Transmission Aneroid
The above costs include labor based on rates typical of Ford
dealers in Denver.
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Ford also provided cost information at the public hearing.
Modification Cost per Vehicle
Adjust Choke $ 40 - $ 50
CAN Change * $ 30 - $ 50
Axle Change $220 - $230
Carburetor Change $140 - $330
Chrysler - This manufacturer presented various comments on the
RPE for newly-manufactured vehicles and on the cost of modifying
vehicles. For feedback vehicles (LDVs), Chrysler indicated that
two types of emission control changes might be required: replace-
ment of the electronic spark advance (ESA) module for high-altitude
vehicles and the addition of a manifold absolute pressure (MAP)
sensor. Chrysler stated at the public hearing and in their written
comments that the high-altitude RPE of these changes would be about
$100 and the modification would be about $200. They indicated that
the MAP sensor accounted for the greatest portion of these costs.
The new vehicle RPE was broken down as follows:
New Car Factory Installation
Average per Vehicle Variable Design Piece Cost,
Plus, Average Proration of Program Costs $55
Fixed and Off Standard Allowance,
Margin and Contingency $20
Dealer Mark-up (includes profit, overhead, etc.) $15 to $ 25
Suggested Retail $90 to $100
Chrysler stated that non-feedback systems would have costs similar
to those for their feedback systems. Subsequent to Chrysler's
final written comments on the proposed rules, EPA received a
request to provide a decision in advance of the final rulemaking
pertaining to the proposed $40 limit for modifying a vehicle. EPA
requested a clarification and elaboration of Chrysler's request and
received additional information on costs. At that time, Chrysler
had decided that a MAP sensor would not be required but that a
change in the ESA module would still be needed to recalibrate the
opeiy-loop portion of the system for high altitude. This would be
accomplished at the factory on newly-manufactured vehicles at no
increase in price because there is essentially no difference in
cost for a high-altitude unit versus a low-altitude unit. They
also stated that the cost of replacing the ESA unit as a modifi-
cation would be about $270 and not the $200 previously reported.
For modifying non-feedback systems they suggested that the RPE of a
new carburetor was about $75 to $100 and that the RPE of an aneroid
was about $25. Labor for changing carburetors was not estimated.
Chrysler also commented that it was likely that they may institute
a program for exchanging the replaced parts for the "modification"
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parts which will reduce the overall cost of new vehicle modifica-
tions. Replacement of the ESA was cited as an example where a
small handling charge and the labor to install the part would be
the only costs of the modification.
GM - Some LDVs might require wiring harness changes to accomo-
date additional control features. Since this would not be prac-
tical on high-altitude LDVs only, a cost penalty would result for
every such car nationwide. GM also commented that high-altitude
LDVs would probably need a barometric pressure sensor and a pro-
grammable read only memory (PROM) change at an estimated cost of
$60. For LDTs, GM stated that air pumps would be needed on their
4.1 liter, 5.0 liter 4-bbl and 5.0 liter 2-bbl engines. These air
pumps were estimated to cost about $50 per unit. GM pointed out
that, if strictly interpreted, the proposed regulations would force
the addition of air pumps on both high- and low-altitude production
at an estimated cost of $25 million. They requested that GM be
allowed to place air pumps only on the 22,000 high-altitude vehi-
cles involved. For diesel engines, GM provided no cost estimates,
but stated they were optimistic that the proposed standards could
be met with a reasonable recalibration effort.
AM - The only significant comment 'concerning hardware and
its cost was that AM agreed with EPA that aneroids could be pur-
chased for under $10, but added that design and retooling would
more than double the cost due to limited application. AM also
commented in general that the adjustment of parameters covered by
the parameter adjustment regulations (PAR) would increase the cost
of modifications.
Volkswagen - Commented that in the past they have offered an
optional high-altitude package which included an aneroid at a cost
of between $60 to $80 to the consumer. Volkswagen claimed the full
cost of the option was $165 and that PAR may make it more expen-
sive. They claimed they did not have enough time to supply a
breakdown of the component costs for their 1977 high-altitude kits
but that they would provide the information when it was available.
(EPA has received no additional information from Volkswagen to this
date.)
IH - Commented that it was possible that carburetors could be
replaced as part of a vehicle modification and that the old car-
buretor could be sold as a reconditioned part. IH indicated the
modification cost in such instances could be about $100. Also, IH
commented that fixed fuel metering systems would require idle
mixture recalibration at altitude and that timing and idle speed
may also need to be reset. Thus, three of the sealed parameters
may need to be defeated in order to allow for adjustment. Since
PAR requires that sealed parameters can not be defeated for less
than $20, a minimum of $60 may be involved.
Toyota - The cost to meet the proposed standards was estimated
to vary from $30 to $50. Toyota commented that they were planning
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to use an automatic altitude compensation system on all high-
altitude models (except feedback systems) even in the absence of
high-altitude standards. It was not clear whether the estimated
$30 to $50 was the full cost of their altitude system or whether
the altitude standards would add this amount to the existing
price. Toyota stated that an axle change was needed as part of a
vehicle modification. They also commented that their feedback
systems would require an altitude compensating device and that
their evaporative controls would also require additional compen-
sation because some data indicated an evaporative emission ratio
for low-to-high altitudes to be 1.7 instead of the 1.3 calculated
by EPA. No further explanation was given. Their estimate of $30
to $50 also included whatever changes would be needed to bring
feedback systems and evaporative control into compliance.
Honda - An automatic compensation device (Air Jet Controller)
will be used instead of a fixed fuel metering calibration which,
according to Honda, tends to have some deficiencies when tempor-
arily operated at different altitudes. The price for modifying a
vehicle is itemized below:
Item Cost
Air Jet Controller $ 90
Replacement Carburetor $300
Labor Cost $ 30
Total $420
The Honda comments did not specifically address new vehicle
prices for factory installed original equipment orders. However,
the Air Jet Controller described above is presumably the same
altitude compensating system that Honda has provided since 1977 on
most of their models. Honda describes this system as being offered
"economically" to high-altitude customers.
Nissan - The following table lists the components and costs
that Nissan believed would be necessary to modify a low-altitude
vehicle into a high-altitude configuration.
Vehicle Type Component Modification Cost
Garb Vehicle Altitude Compensator Unit
Check Valve
Vacuum Tank
Solenoid Valve
Vacuum Switch
Timer Unit
Vacuum Hose & Harness $130 - $170
EFI Vehicle Altitude Compensator Unit
Harness $ 45 - $ 70
Diesel Vehicle Aneroid Compensator
Bracket $165 - $185
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No estimate of the price increase for factory installed high-
altitude components was given.
2. Certification. Several manufacturers and the Motor
Vehicle Manufacturers Association (MVMA) commented on the cost
burden that the proposed standard would inflict on the indus-
try. MVMA stated that certification testing is very expensive and
indicated that special 4,000 mile emission data vehicles and
50,000 mile durability vehicles would have to be built. Further-
more they estimated that the high-altitude certification require-
ment would involve 25 percent of the low-altitude fleet. GM
stated that most of their cars will meet the standards anyway;
therefore, certification is the real cost burden of high-altitude
emission standards. Based upon this fact they said standards are
unnecessary.
All commenters were unanimous in their advocacy of an alterna-
tive certification program that would allegedly lessen the certifi-
cation burden. Commenters urged EPA to adopt a program tailored
after the State of California's high-altitude requirement. This
program allows manufacturers to use engineering evaluations
in lieu of full FTP certification testing. Ford was the only
commenter to try and quantify the alleged saving. They estimated
the alternative certification scheme would save $750,000 per year
for their LDVs or about $20 to $25 per high-altitude vehicle.
Peugeot asked who pays for shipping vehicles to the United
States for high-altitude certification testing?
3. Selective Enforcement Audits. All of the comments
concerning high-altitude SEA stated that it would be too expensive
and burdensome. Manufacturers pointed to logistical problems
such as the probable lack of an adequate number of vehicles
already at high-altitude dealerships from which to select SEA test
vehicles. They concluded that vehicles may have to be shipped in
from low altitude at a prohibitive cost. Chrysler was the only
manufacturer that presented cost data for high-altitude SEA. This
data is summarized below:
Item
Rental of high altitude test facility $450 per test,
plus additional costs
Drop shipment per vehicle $ 30 - $120
Shipping costs per vehicle (up to 70 $500 - $600
vehicles involved)
One fulltime engineer to coordinate SEA
(surveillance) program $50,000 per year
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Chrysler also noted that if it must lease high-altitude test
facilities the cost could be $1.5 million dollars for two years.
In a related comment, Chrysler also implied that their own sur-
veillance program would be more costly because it is difficult to
conduct such a program at a rented facility, and that repair and
diagnosis are virtually impossible. No additional explantion of
these alleged problems was given. It was indicated that, a full
time engineer would be required to select vehicles, test, and
coordinate this program. . '
4. Economic Effects on Manufacturers. Several manufacturers
commented that the standards should not be promulgated because
they were so costly at a time when the U.S. automotive industry was
experiencing record losses. Ford also commented that their finan-
cial and technical resources are already being strained excessively
by the requirements to achieve fuel economy improvements and meet
the cumulative effects of other governmental regulations.
Jaguar, IH, AM, and Chrysler commented that the burden of the
regulation would be disproportiately greater for the smaller volume
manufacturers. This would raise vehicle costs more for small
manufacturers than for larger ones.
5. Cost Effectiveness. Manufacturers generally commented
that the standards would be less cost effective than EPA calculated
in the Draft Regulatory Analysis when all of the costs of the
standards are accounted for.
Analysis of Comments
1. Requisite Hardware and Its Cost. EPA is frequently
confronted with the issue of what the consumer cost will be
for systems installed on motor vehicles for the purpose of con-
trolling emissions. Ideally, it would be desirable to determine
the economic impact on the consumer for any emission standard
proposed and on any vehicle for which such a .standard would be
applicable. Such a task as this requires a very high level of
effort, whether it is performed by EPA or by the manufacturer
when commenting on a rulemaking. Therefore, it is usually more
realistic to use generic descriptions of the requisite control
hardware to represent the costs of all components or systems of a
similar nature. This is the approach that EPA used to estimate the
costs of emission control in the Draft Regulatory Analysis and is
the approach that manufacturers used in responding to the Notice of
Proposed Rulemaking.
Using generic descriptions of the requisite control hardware
can be very useful if proper attention is given to detail and
supporting evidence. In almost every case, the comments on
hardware costs were general and provided no breakdown of the
associated cost elements or other supporting detail. This lack of
substance and, hence, justification, prevents EPA from effectively
analyzing the manufacturers' technology cost comments. As an
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example, Ford and Volkswagen stated that in 1977, they offered
vehicles for sale with an optional aneroid system. Ford said they
charged up to $37.50 for this option and Volkswagen said the actual
retail cost of their system was $165. Ford provided EPA with no
further description or cost breakdown for their system, while
Volkswagen provided a description but no cost breakdown of their
system. Without further information, it is impossible to determine
not only why the costs of these two systems are so different but
what the charge should be for these types of systems in 1982 and
1983.
The Agency attempted to ensure that comments would contain
useful information by requesting at the public hearings that
manufacturers provide greater detail in their final written sub-
mittals on this rulemaking. Despite this request and a reopening
of the comment period to allow for further comments, few manufac-
turers significantly expanded on their cost comments. In fairness
to the manufacturers, it must be pointed out that many of them may
have been unable to provide substantive comments because of their
relative unfamiliarity with the high-altitude requirements of their
new 1981 emission systems which will generally also be used in 1982
and 1983.
In addition to the general and unsupported nature of the
manufacturers' comments, EPA's technology analysis found that some
estimates appeared to be very pessimistic and could not be used as
generic descriptors of a particular manufacturer's high-altitude
requirements. As an example, Volkswagen and Nissan estimated that
they would have to modify their electronic fuel injection system by
adding an altitude sensor and that this modification would be
expensive. The technology assessment (Issue B) presents evidence
that these systems should have the inherent capability of meetng
the standards without any change. Also, Chrysler continually
stated that a manifold absolute pressure (MAP) sensor was needed on
their high-altitude feedback systems, but then in response to EPA's
specific request for additional information, stated that the MAP
sensor would not be needed. EPA believes that these examples
illustrate the generally conservative trend in the cost comments.
Some of the comments from the same source were internally
inconsistent. In their final written comments, Ford estimated
the retail price equivalent (RPE) increase for a factory produced
high-altitude vehicle to be $200 to $225. At the public hearings,
a Ford representative estimated the new car RPE for an aneroid
system at up to $50. In addition, although Ford presented no
justification for their $200 to $225 estimate, they did present a
list of items which were part of a "modification kit." This list
should also represent the items that Ford would have to use in
producing a new car at the factory. Producing the high-altitude
vehicle is obviously cheaper than modifying a vehicle after it is
built: there are no existing parts to replace or modify. If we
assume that Ford's upper limit of $225 is representative of their
"maximum" modification, the cost for some items can be segregated
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and their retail price discussed. In this brief analysis assume an
optional axle ratio is $30 and the carburetor is $50 as stated at
the hearing: a total of $80. If this cost is subtracted from the
$225 estimate, then $145 is left to account for the different
distributor stator, transmission aneroid, air pump pulley, and
speedometer gear. These parts and their installation as original
equipment should be nowhere near that cost. An examination of the
lower cost estimate of $200 for a new car and Ford's "minimum"
modification is even more inconsistent. Ford lists an axle change
as part of this modification. However, the axle they are changing
to must already be used on a vehicle that also must have some other
modification to meet the standards, so a true minimum modification
can only include the changes that must be made to the vehicle
already possessing the axle that any other vehicle must change to.
Therefore, an optional axle should not be part of the "minimum"
high-altitude package. Nevertheless, we will assume $30 for an
optional axle. This leaves $170 ($200-$30) to account for a
different PCV valve, distributor stator, speedometer gear, and
choke adjustment. Again this seems very unreasonable for these
items as original equipment.
The above serves only to indicate that if EPA were to accept
industry cost estimates on face value, a representative indication
of the economic impact of these proposed regulations would probably
not result. Therefore, EPA must develop its own cost estimates of
the requisite control hardware based on the comments and the best
judgment of its technical staff.
Some conclusions regarding the cost estimates contained
in EPA's Draft Regulatory Analysis can be made based on the com-
ments, however. The Agency's estimate of the most likely control
hardware, which was based on discussions with industry representa-
tives, was essentially correct, but the complexity of the changes
which may be required for some feedback systems was in error.
The development effort was also underestimated. Therefore, the
revised analysis should pay careful attention to these two areas in
particular.
As previously stated, EPA's costing methodology should be
based on generic descriptions of the systems that the comments and
the Agency's technical experience indicate most likely to be used
by manufacturers to meet the proposed standards. Implicit in this
approach is the fact that some individual systems will cost more or
less than the generic system used in the analysis. However, in
order to ensure that the analysis does not underestimate the cost
of this regulation, the generic systems should be conservatively
chosen. This requirement is met by using the following five
generic systems in the analysis:
Unmodified feedback system - These systems have the inherent
capability to meet both the low- and high-altitude stan-
dards as they are currently designed. These systems are
characterized by the GM C-4 system and the Bosch Jetronic fuel
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injection systems used by Volkswagen, Nissan, and others.
Recalibrated feedback system - These systems cannot meet the
proposed standards as currently designed. A special calibra-
tion to reduce open-loop emissions will be necessary. There-
fore, a different electronic unit will be used for high and
low altitudes. These systems are characterized by the two
electronic spark advance modules that Chrysler estimates they
will need.
Aneroid non-feedback system - These sytems will use a pres-
sure-sensing device on the carburetor to lean the fuel-air
mixture at high altitude. These systems are characterized by
the aneroid carburetors described by Ford and Chrysler for
which EPA has the best information.
Air injection non-feedback system - Although EPA cannot
confirm that air pumps will be necessary on GM 2.2 liter, 5.0
liter 2-bbl, and 5.0 liter 4-bbl LDT engines, the analysis
should account for this possibility.
Diesel engine system - As discussed in the technology assess-
ment(IssueB),the analysis -should assume that diesel-
engined vehicles can comply with the proposed standards by
simple recalibration. No additional hardware such as aneroids
appears to be necessary.
By using these generic systems to characterize the high-
altitude motor vehicle fleet, a conservative estimate will be
ensured because (1) there are likely to be more feedback systems
that will automatically meet the standards than are identified in
the Agency's technical assessment, (2) there are likely to be
non-feedback systems, such as those used by IH, that will employ
different fixed-calibrations at high altitude instead of the more
expensive and complex aneroid carburetors, and (3) there are likely
to be non-feedback systems, as suggested in the Ford, IH, and AM
comments, that will require changes as simple as readjusting idle
mixture and choke.
The economic analysis should retain the assumption that
current evaporative emission control systems can comply with the
proposed high-altitude standard. Only one commenter specifically
commented that EPA's calculated ratio of 1.3 was incorrect. Toyota
alluded to "some" data that indicated for some of their systems
the correct ratio was 1.7. No data or further explanation of
Toyota's contention were supplied to EPA for analysis. Ford had
included the cost of an evaporative cannister change as part of
a high-altitude modification in their comments at the public
hearings. However, this was excluded in the subsequent and more
detailed final written comments. EPA assumes that Ford had found
such a change unnecessary.
2". Certification. The commenters raised three basic issues
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regarding certification costs: (1) full certification testing as
proposed is expensive and burdensome, (2) significant cost savings
can be achieved by using an alternative certification technique
patterned after California's high-altitude program, and (3) who
pays the cost of shipping certification vehicles to a high-altitude
test location?
MVMA indicated in their comments at the public hearings that
the proposed high-altitude regulations would require the building
of special 50,000-mile durability vehicles and 4,000 emission data
vehicles. EPA agrees that this would be very costly and burden-
some, but the high-altitude standards as proposed would avoid this
added expense by allowing the use of low-altitude durability and
emission data vehicles for high-altitude certification. Also as
discussed in Issue F, EPA expects to reduce the number of high-al-
titude certification vehicles and, hence, the cost of certification
from that which was possible in the proposal. Instead of the
possibility that three vehicles per engine family could be tested,
EPA will reduce this number to one vehicle per family. If 156
engine families are certified at $1,800 per high-altitude test, the
cost is reduced from $2.3 million, as estimated in the Draft
Regulatory Analysis, to about $842,400. This is about $0.76 per
high-altitude vehicle. EPA dcres not consider this to be a cost
burden on the manufacturers.
EPA accepts the manufacturers' assertions that alternative
certification could significantly reduce the costs of high-altitude
regulations. However, EPA rejects the assertion that alternative
certification is appropriate for a Federal high-altitude motor
vehicle emissions program. Alternative certification is discussed
in detail in Issue E, but because of its significance to the
cost of regulation, it will be briefly discussed here. It is
important to realize that the savings attributable to an alterna-
tive certification technique are mainly due to the potential
savings in development efforts. Also, the savings in development
are dependent on the fact that the alternative technique used in
certification must also be the technique used in Selective Enforce-
ment Audits (SEA) of production vehicles. If full FTP testing were
used in SEA, EPA believes that manufacturers would also do their
development work using full FTP testing to provide them with
confidence that they can pass an FTP SEA and, hence, will not be
subject to very expensive production line changes and later,
recalls. EPA feels that FTP SEA is needed to assure that produc-
tion vehicles do indeed meet the high-altitude standards; there-
fore, development will not be significantly different whether or
not EPA allowed alternative certification or retained full FTP
certification. As calculated above, the difference cannot be
greater than about $0.76 per high-altitude vehicle. EPA believes
the benefits of full certification outweigh this small cost. With
regard to Peugeot's comment concerning shipping costs, current
Federal emission certification procedures call for the vehicle's
manufacturer to assume the cost of transportation. This will
remain unchanged for the high-altitude standards.
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3. Selective Enforcement Audits. EPA is aware of the
manufacturer^1concerns about the cost of a high-altitude SEA and
will attempt to administer the HA SEA program so as to minimize the
financial burden on the industry. However, EPA believes that a
high altitude SEA program is necessary for EPA to fulfill the tasks
mandated by Congress in the Clean Air Act (Act). Section 206(b)
(10) of the Act authorizes testing af vehicles from the assembly
line. The enforcement mechanism EPA presently uses to perform
these assembly line tests is the SEA program, the major purpose of
which is to provide a deterrent to the production of noncomplying
vehicles. Accomplishing this purpose will help to ensure that the
air quality benefits anticipated from adopting the high-altitude
emission standards will be achieved.
Any increased cost due to high-altitude SEA testing will
depend on many factors, the most significant of which are whether
the manufacturer has its own high-altitude test facility and the
location of whatever facilities it employs to conduct high-altitude
testing. With regard to facility location, any manufacturer,
either foreign or domestic, which tests in the U.S. should not
experience any substantial increases in shipping costs. This is
because during audits of low-altitude vehicles, manufacturers ship
vehicles to test facilities which are often hundreds of miles away
from the assembly plant and then must re-ship them to the correct
(dealer) destination. When auditing high-altitude vehicles at a
location such as Denver, Colorado, the cost of shipment to Denver
represents part of the shipping costs the manufacturer would incur
in delivering the vehicle to its correct destination, i.e., at a
high-altitude dealer in the Western U.S. In the latter case,
therefore, little or no shipping cost increase will be incurred.
Foreign manufacturers which elect to test in their home
countries can be accommodated under the existing SEA regulations.
These manufacturers may incur some extra costs in shipping to their
local high-altitude facility, but, as discussed in Subissue 4 on
SEA test vehicles, not all vehicles selected may have to be shipped
to the test site. With regard to the cost of performing high-alti-
tude testing, manufacturers having their own high-altitude test
facilities should experience costs similar to those for low-alti-
tude testing. If the manufacturer must use a contractor facility,
however, some additional costs will be incurred.
EPA has received manufacturer estimates of the cost of
performing high-altitude SEA testing at a contractor facility
ranging from approximately $800 to $1050 per test. Automotive
Testing laboratory (ATL) and Environmental Testing Corporation
(ETC) have submitted information to EPA indicating that their costs
of performing all of the procedures involved in the SEA testing
requirements (drain/refuel, preconditioning, soak, heat-build, and
emission tests) average out to about $875, which is in general
agreement with the manufacturer estimates.
Manufacturers that must use contractor facilities are general-
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ly small volume manufacturers whose low testing volume does not
warrant establishing their own high-altitude test facility. The
EPA emission testing laboratory in Ann Arbor, Michigan, which is
representative of a manufacturer that only tests vehicles on an
infrequent basis, estimates its own costs at about $750-1000 per
test. This cost is comparable to the cost at a high-altitude
contractor facility. Therefore, a small manufacturer should incur
no substantial cost increases when contracting for high-altitude
SEA testing.
It should be emphasized, when considering the incremental
costs of a high-altitude SEA program, that high-altitude SEA test
orders, if passed, will count towards a manufacturer's annual quota
of audits. High-altitude audits are merely being substituted for
low-altitude audits and do not increase the quota. Therefore,
manufacturers whose audited vehicles comply with the standard will
experience no increase in the number of audits they must perform
due to the implementation of high-altitude regulations in 1982.
4. Economic Effects on Manufacturers. EPA will make every
attempt to prescribe standards that are the least costly to in-
dustry but that also adequately protect the health and welfare of
higti7altitude residents. In addition, EPA will implement and
enforce these standards so as to minimize compliance costs.
EPA agrees with the commenters that the standards have the
potential of impacting smaller manufacturers more heavily than
larger manufacturers, simply because of the lower production volume
over which fixed costs can be amortized. The Regulatory Analysis
should identify the cost of compliance for each manufacturer.
5. Cost Effectiveness. The Regulatory Analysis will include
a calculation of the cost effectiveness of the proposed standards
using EPA's revised cost methodology and updated air quality
information.
Recommendation
EPA's Regulatory Analysis should include a determination of
the proposed standard's economic impact by using generic descrip-
tions of the emission control systems that will be used to comply
with the regulations. The analysis should also reflect the reduced
certification requirement as recommended in Issue F. The economic
impact on individual manufacturers should be discussed and a
new cost-effectiveness figure should be calculated. The Regula-
tory Analysis should not include additional costs for high-altitude
SEA.
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ll. Issue; Environmental Impact
Summary of Issue
The Environmental Protection Agency (EPA) estimated that the
interim high-altitude standards would significantly reduce hydro-
carbon (HC) and carbon monoxide (CO) emissions from high-altitude
vehicles. For Denver, Colorado the reduction in 1987 would be 0.8
tons/day for HC and 19.8 tons/day for CO or a reduction of 0.6
percent and 2.0 percent for the pollutants, respectively.
Summary of Comments
All automobile manufacturers commented that the interim
standards are unjustified and will not result in any significant
improvement in air quality. Opposing this view were comments from
political representatives and the general public which stated that
the standards were necessary to improve air quality and protect the
public health.
Major Subissues
1. Justification for the Standards. Industry representa-
tives basically stated that Denver's air pollution problem was not
unique and was not serious enough to warrant special action.
The Motor Vehicle Manufacturers Association (MVMA) submitted
data from low and high altitudes of CO and ozone levels and of the
number of exceedances of the CO standards. MVMA concluded that no
general trend relating higher air quality levels or exceedances
with increasing altitude can be established. MVMA also stated that
the National Jewish Hospital monitoring site in Denver was an
apparent anomaly because it had a greater number of exceedances
than the other Denver sites. The MVMA also submitted trend data
showing an improvement in Denver area CO and ozone levels between
1973 and 1977.
Chrysler stated that eight of the twenty cities listed in the
Draft Regulatory Analysis (RA) as high altitude do not meet the EPA
definition of high altitude. Chrysler further commented that
Denver has now dropped to fifth place in number of days in viola-
tion of the air quality standards according to the 1979 Council on
Environmental Quality (CEQ) Report, instead of being second only to
Los Angeles as stated in the RA.
Many industry representatives pointed out that recent air
quality trends up to 1977 have shown an improvement in pollution
levels, and that because many new cars have the capability to
compensate somewhat for altitude changes, this air quality improve-
ment will continue without the standards. Chrysler went even
further and stated that the ambient air quality standard for CO
in Denver would be met within the next few years even without
standards.
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2. Effects of CO on Health. Chrysler stated that no medical
evidence exists which demonstrates the relationship between ambient
CO levels and health problems in the general public. Commenters
from the general public stated that the effects of CO on indivi-
duals at high altitude were-more pronounced than the effects of the
same level of CO on individuals at low altitude because of the
thinner air at higher elevations.
3. Effectiveness of Interim Standards. Commenters pointed
to EPA's own analysis of the interim standards' effect 'on air
pollution as evidence of the ineffectiveness of these standards.
The Colorado Department of Highways stated that EPA's Mobile
Source Emission Factors document (March 1978) shows low- to high-
altitude ratios for recent model year vehicles to be 2.06 for CO
and 1.62 for HC's. They pointed out that applying these ratios to
the 1981 low-altitude standards would result in high-altitude
emissions levels below the interim standards, and concluded that
high-altitude certification would be an unnecessary expense.
Ford stated that a proportional relationship exists between
low- and high-altitude emission levels, and that without stan-
dards high-altitude emissions will continue to decrease propor-
tionally, particularly with voluntary offerings of high-altitude
calibrations.
Chrysler referred to an EPA Issue Paper, February 12, 1978,
"High Altitude Emissions Standards for 1981-83 Model Year Cars,"
which concluded that there would be no air quality benefit from
1981-83 standards.
The MVMA also submitted emission trend data for CO and HC,
and concluded that high-altitude emission levels have continued to
decline even though high-altitude standards were in effect for only
one model year—1977. MVMA stated that the reductions due to the
high-altitude standards, shown in the regulatory analysis between
1980 and 1987 in Denver, are so small over what they would be
without standards as to be within the expected error of emission
inventory analysis.
The Utah Division of Environmental Health commented that the
ratio of high- to low-altitude emissions has increased as a result
of the Federal Motor Vehicle Emission Control Program (FMVECP).
They stated that the pre-controlled CO ratio was 1.61 while for
1968-74 model years it was 2.46. For 1975-1983, with the exception
of 1977, the ratio was 2.06. Utah goes on to state that high-
altitude CO emissions in 1975 were 20 percent greater than if they
had been maintained at pre-controlled levels. This statement is
obviously in error. Examination of that attached tables indicate
that they meant emissions were 20 percent greater than if the high
to low altitude ratio were maintained at the precontrolled level.
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4. The Effect of the Standards on Ambient Nitrogen Dioxide
and Ozone. Chrysler stated that some high-altitude nitrogen
dioxide (NO2) levels are currently just below the National Ambient
Air Quality Standards (NAAQS) and that if the standards result in
leaning the engines fuel-air mixture, the standards may be vio-
lated. They also pointed out that NO2 is a catalyst for photo-
chemical smog and that any increase in oxides of nitrogen (NOx)
from motor vehicles could lead to a more severe ozone problem.
5. The Effect of the Standards on the "Brown Cloud".
Industry representativesnotedthatthestandardswillhaveno
beneficial effect on the brown cloud.
6. Non-Resident Vehicles. Commenterspointed out that
out-of-state cars are a significant portion of Denver's total
vehicle population and so all cars must be able to meet the stan-
dards when sold, instead of merely being capable of modification to
meet the standards.
7. In-Use Modifications. Very few in-use vehicles will be
modified and so there is no air quality justification for requiring
high-altitude certification.
Analysis of Comments
1. Justification for the Standards. The Clean Air Act
requires attainment of the CO and oxidant standards by 1982. An
extension up to 1987 can be allowed if all reasonable control
measures will not attain the standards by 1982. Denver and
Boulder, Colorado, and Salt Lake City, Utah, require extensions to
meet both the ozone and the CO standards. Albuquerque, New Mexico,
has both an ozone and CO problem, but is expected to achieve the
ozone standard by 1982. Albuquerque, New Mexico, Colorado Springs,
Greeley, and Fort Collins, Colorado require extensions to meet the
CO standard. These areas also are required to implement an inspec-
tion and maintenance (I/M) program to reduce HC and CO emissions.
Even with I/M and other transportation control measures, attainment
of the standards in the Denver area by 1987 is not assured.
Chrysler is correct in that Denver is listed in the 1979 CEQ
Report as being the fifth worst city in the nation in number of
days in 1977 in violation of the NAAQS. Denver was second only to
New York City in violations of the CO standard; however, Denver had
127 days in 1977 over the CO standard while New York had 247.
No other cities had more than 100 days of violation of the CO
standard in 1977. Chrysler's comment concerning eight of the areas
listed as high altitude not meeting EPA's definition is relevant.
The RA has been revised to remove seven of the cities from the list
of high-altitude areas. Reno, Nevada (Washoe County), was not
included in the original proposal of high-altitude areas but has
since been included.
The MVMA statement that there is no general trend relating
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higher CO and ozone air quality levels or exceedances with in-
creasing altitude is not surprising. Ozone is a very complicated
pollutant which is not directly emitted but formed in the atmos-
phere from the photochemical reaction of NO and HC. There are
both mobile and stationary sources of these two pollutants. The
high-altitude areas with ozone problems are isolated and are not
affected by long range transport of ozone precursors as are many
sea level cities.
CO is directly emitted, almost entirely, from mobile sources—•
motor vehicles. However, CO is generally a localized problem in
areas with high traffic density. Ambient CO levels are dependent
on the density of CO emissions and atmospheric dispersion condi-
tions such as mixing depth and wind speed. CO emission densities
are in turn dependent on traffic volume, vehicle mix, vehicle
speed, ambient temperature, percentage of vehicles operating from a
cold or hot start-up, and altitude. Finally, the geometry of the
traffic pattern and distance of the receptor or monitoring location
is critical to the CO level measured.
Given all of these factors, it is far from surprising that a
plot of air quality levels or exceedances against altitude does not
produce a one to one relationship. The fact remains that emissions
of CO and HC from mobile sources are higher at high altitude,
exacerbating existing air quality problems.
The MVMA assertion that the National Jewish Hosital site in
Denver may be providing anomalous CO data is related to the factors
mentioned above, concerning the localized nature of ambient CO
levels. The fact that all but one of the sites measuring CO in the
Denver area experience violations of the standard indicates that
the CO problem in the Denver area is pervasive and more of a
regional nature than is usually the case. However, there is a wide
variation in CO levels due to variations in traffic density within
the Denver area.
The one site which did not measure CO violations in 1978 is a
new site located on the extreme southern fringe of the metropolitan
area. This site is normally outside of the "urban plume" and only
is affected by traffic on a single arterial. The other sites
ranged from four exceedances above the standards at the Overland
site to 125 exceedances at the National Jewish site in 1978. The
CAMP station experienced 50 exceedances; CARIH, 25: Arvada, 15; and
Welby, 10. Welby is located on the extreme northeastern fringe of
the metropolitan area, but is often within the urban plume and
indicative of the urban background CO concentration. Neither the
CARIS or Arvada sites are located in high traffic density areas.
The National Jewish site is at the intersection of Colfax and
Colorado Boulevard, two fairly high density arterials. The total
average daily traffic on these two streets was about 69,000 vehi-
cles in 1978. The CAMP station is at the intersection of 21st and
Broadway and Champa Streets. The total average daily traffic on
these streets was 20,000 in 1978.
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The high CO levels and exceedances recorded at the National
Jewish site is due to the higher traffic density at this site
compared to the other sites. The traffic density at this site is
not the highest in the Denver area, however. For example, Inter-
state 25 and U.S. 6, which intersect, had a combined volume of over
215,000 vehicles per day in 1978. Many other intersections have
densities similar to that at the National Jewish site. Denver does
not have a center city "street canyon" monitoring site which may
produce even higher CO levels due to the combination of poor
dispersion and high density.
The MVMA statements about decreasing trends in CO and ozone
must be qualified. Ozone is a regional scale pollutant, but the
area of highest concentration varies as the urban plume drifts
across the city and reacts photochemically. It is unlikely that a
particular monitor will coincide with the highest actual concentra-
tion. The station measuring the highest concentration will also
change from day to day. Due to this variation, ozone trends are
difficult to establish. Based on a photochemical dispersion model
calibrated for the Denver area, the State of Colorado was not able
to project attainment of the ozone standard by 1987 using Mobile I
emission factors and I/M.
The MVMA trend chart for CO stops at 1977- CO levels in 1978
were higher than 1977 and not significantly different than those in
1975 and 1976. In 1977 the National Jewish site had 94 exceedances
of the CO standard versus 125 in 1978, the CAMP site had 31 in 1977
versus 50 in 1978. Colorado was able to predict attainment of the
CO standard by 1987 using Mobile I and I/M, but the Mobile I
emission factors are lower than those used in the RA. Mobile I was
based on the assumption that 1980 and later model year vehicles
would exhibit the same ratio of high- to low-altitude emissions as
1975 and 1976 model year vehicles. Data from prototype 1980 and
1981 control system vehicles were used in the RA to update emission
factors for 1980-83 model year vehicles without high-altitude
standards. This analysis has since been revised to include new
information. The new vehicle CO emission rates for 1980 light-
duty vehicles at high altitude has been increased in the revised
analysis from 6.18 to 9.44 grams per mile (gpm) and for 1981-1983
from 2.88 to 6.24 gpm. Light-duty truck emission rates were
increased from 29.90 to 38.31 gpm for 1979 through 1982 model year
vehicles, and from 8.00 to 27.68 gpm for 1983. The deterioration
rates were assumed to be the same at high altitude as at low
altitude. This assumption may not turn out to be valid, especially
for light-duty vehicles. In the absence of standards, vehicles
will be designed for low altitude. This will cause emissions from
vehicles with disabled control systems to be higher than at sea
level due to richer mixtures. There may also be higher tampering
rates at high altitude due to poorer fuel economy or performance
from failure to design for high-altitude use. Furthermore, the
Colorado I/M program has been revised by the Colorado Legislature
and may not provide as much emission reduction by 1987 as was
assumed when attainment of the CO standard was demonstrated.
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The estimates in the RA for the air quality benefits of the
standards may be substantially higher if there is a higher reliance
on control technologies which are not inherently altitude compen-
sating. Ford Motor Company stated at the public hearing that most
of their vehicles would utilize non-feedback carburetors in model
years 1982 and 1983. The RA has been revised to account for this
change in technology by Ford. Other manufacturers may rely more on
technology which is not altitude compensating over at least part of
the vehicle operation cycle. These standards are necessary to
ensure that excessive emissions from such systems will not result
in high-altitude areas. The RA has also been revised to account
for the higher usage of light-duty trucks in the Denver area. The
reduction in total Denver area 1987 emissions has increased from
0.6 percent to 1.0 pecent for HC's and from 2.0 percent to 3.4
percent for CO.
Without the high-altitude standards, the State of Colorado and
other high-altitude states would be required to adopt additional
control measures to make up for the loss in motor vehicle emission
reductions. In order to be granted an extension beyond 1982, the
Clean Air Act requires that all reasonably available control
measures be adopted as expeditiously as practicable. Attainment of
the standards is required by 1987. It would not be reasonable to
expect high-altitude nonattainment states to provide any additional
measures beyond those that are already required in order to make up
for the lack of the interim standards.
2. Effects of CO on Health. Justification of the NAAQS for
CO is not necessary in an automotive emission regulation action.
Ambient standards are promulgated in separate rulemaking actions
which provide an opportunity for public review and comment.
However, a brief summary of the NAAQS for CO will be presented in
response to Chrysler's comment. The justification for the CO
standard is contained in the air quality criteria document. Air
quality criteria documents are required by Section 108(a) of the
Clean Air Act to identify effects on public health and welfare
caused by varying amounts of pollutants in the air. These criteria
must be supported by the latest available accurate scientific
information. The purpose of these criteria is to identify air
pollution effects and serve as the basis for NAAQS. The original
criteria document for CO, the National Air Pollution Control
Administration publication AP-62, was issued in 1970.
Section 108(c) of the Clean Air Act requires that the Admin-
istrator of the EPA from time to time review and, as appropriate,
modify and reissue criteria published pursuant to Section 108(a).
Section 109(d)(l) requires both that the Administrator complete a
thorough review and, as may be appropriate, make revisions in the
criteria by December 31, 1980, and at five-year intervals there-
after. EPA pubished a preprint of a revised criteria document for
CO in October 1979, (EPA-600/8-79-022). This document states that
fetuses, persons with cardiovascular or central nervous system
defects, sickle cell anemics, young children, older persons,
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persons living at high altitudes, and those taking drugs, comprise
groups at special risk to CO exposure. There is little information
regarding the high risk groups; however, it is apparent that
exposure for eight hours to CO concentrations as low as 15-18 parts
per million (ppm) may be detrimental to the health of persons
suffering cardiac impairment. Such concentrations are routinely
exceeded in high-altitude areas. In 1977, there were 18 days with
CO levels above 15 ppm in the Denver area.
CO affects health because it decreases the oxygen carrying
capacity of blood. At high altitude there is less oxygen avail-
able anyway, and so the effects are additive. While residents of
high-altitude areas may somewhat adapt to the lack of oxygen
(18 percent less available oxygen in Denver than at sea level)
overlong periods of time, visitors and tourists are not able to do
so.
3. Effectiveness of Interim Standards. The Colorado Depart-
ment of Highways comment that the interim standards are higher than
the high- to low-altitude ratio for 1978 model year vehicles
applied to the low-altitude standards disregards the effect of the
control technology which will be used to meet the low-altitude
standard. Data from prototype vehicles (tested at low and high
altitudes and representative of the types of control technology to
be used in 1982 and 1983) was used in the regulatory analysis to
determine the expected high-altitude emission rates without stan-
dards, as explained in the Justification of Standards Section.
The EPA Issue Paper referenced by Chrysler was also written
without consideration of the effect of control technology differ-
ences on the high-to low-altitude ratio. The issue paper and
Mobile I emission factors were developed prior to the availability
of emission data on prototype 1981 control systems. In the absence
of such data, the assumption that 1981-1983 vehicles would have the
same high- to low-altitude ratio as 1975 and 1976 vehicles is the
best that could be made. However, the high- to low-altitude ratio
has changed as the control technology has changed. The following
table gives the high- to low-altitude ratio for various technology
classes as calculated from Mobile I emission factors based on
actual test data.
Model Year High- to Low-Altitude Ratio
CO HC
Pre-1968 1.61 1.36
1968-1974 2.46 1.67
1975-1976 2.06 1.62
As can be seen, the ratio does vary with control technology.
1981 model year emission standards for low altitude are 0.41, 3.4,
and 1.0 grams per mile for HC, CO, and NOx respectively (excluding
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waivers). In 1975 and 1976, the standards were 1.5, 15, and 2.
Considerable changes in control technology will occur between the
1976 and 1981 model years, and the high- to low-altitude ratio can
also be expected to change. The use of prototype data provides a
better estimate of how emissions will vary with altitude than
assuming that the ratio will remain constant when the control
technology changes.
This same discussion applies to Ford's comment that high-
altitude emissions will continue to decrease proportionally with
low-altitude emissions. Ford also stated that some high-altitude
calibrations will be made available voluntarily, but the impact of
such a voluntary program would be impossible to estimate. In
fact, Ford was unable to determine the number of vehicles sold with
optional high-altitude calibrations in past voluntary programs.
The MVMA similarly relied on past trends in low- to high-
altitude emissions and did not consider the impact of the newer
technology's response to altitude changes. MVMA also referred to
the continued decline in high-altitude emission rates after 1977
when no high-altitude standards were in effect. This decline is in
part due to the turnover of vehicles, i.e., older high polluting
vehicles being replaced by new lower polluting vehicles. Another
factor in this decline was the carryover of 1977 certifications of
high-altitude vehicles into 1978 and 1979. With the change in
emission standards in 1980 this carryover stopped; therefore, the
rate of decline will not continue to be enhanced by this effect.
The MVMA statement that the emission reductions due to the
interim standards in the Denver area are so small as to be within
the errors of emission inventory analysis is misleading. An
emission inventory, particularly for motor vehicles, has many
sources of error. The reductions due to the interim standards were
calculated by holding those other sources of errors constant.
Thus, these sources of error were moderated in the analysis, and
the reductions indicated are as good an estimate of the impact of
the standards as can be made. As stated in the Justification of
Standards Section, the RA has been revised and the estimated impact
of the interim standards increased. The reductions presented in
the draft analysis were significant and favorably comparable to
other emission control strategies of similar cost as presented in
the RA. The revised estimates are even more favorable.
Another benefit of the standards will be to provide the
protection of the warranty provided by Section 207(b) of the Clean
Air Act. This warranty provides that properly maintained vehicles
failing an I/M test must be corrected at the vehicle manufacturers'
expense for the vehicle's useful life, although after the first two
years or 24,000 miles the manufacturer's liability is limited to
devices which are solely or primarily used for emission control.
EPA regulations will make this warranty available in low-altitude
areas beginning with the 1981 model year. Since 1981 vehicles are
not required to meet standards at high altitude, the warranty
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cannot apply at high altitude. Promulgation of the 1982 and 1983
interim high-altitude standards will end this inequity for con-
sumers in the high-altitude areas with I/M programs. Additional
air quality benefits may also result, since any cost limits on
maintenance required to pass an I/M program will not apply to
vehicles covered by the warranty.
The Utah Division of Environmental Health commented that the
high- to low-altitude ratio for pre-controlled vehicles (pre-1968)
was lower than for controlled vehicles (post-1968). The Clean Air
Act, however, requires EPA to base the high-altitude standards on
1970 model year emission rates. It is unfortunate that the high-
to low-altitude ratio for the 1970 control technology was higher
than either pre-controlled or catalytic converter controlled
vehicles because this relationship results in a more lenient
standard than if any other model year was used as the baseline.
This fact, however, should be considered upon setting the interim
standards. The most stringent standard that can be justified from
the available data on 1970 model year high-altitude emissions
should be used.
4. The Effect of the Standards on Ambient Nitrogen Dioxide
and Ozone. While controlling HC and CO emissions may cause an
increase in NOx emissions over what they would be without the
standards, the high-altitude NOx standard must still be met.
The high-altitude NOx standard is lower than present fleet average
high-altitude NOx emission levels. Even though high-altitude
emissions of NOx of 1982 and 1983 vehicles may increase slightly
over what they would be without standards, the high-altitude NOx
standard (1.0 gram per mile for light-duty vehicles) is much lower
than high-altitude NOx levels for any model year prior to 1981 (the
lowest new vehicle NOx rate prior to 1981 was 1.5 gpm and the
average fleet NOx rate for 1982 is 1.77 gpm). Thus, overall
ambient N02 levels will continue to decline with the interim
high-altitude standards.
Denver is the only high-altitude area with high levels of
N02- Denver only marginally exceeded the standard from 1975 to
1977, and in 1978 N02 levels were below the standard. Denver
also has levels of ozone which exceed the national standards.
Analyses of attaining the ozone standard by the State of Colorado
and EPA indicate that reductions in HC emissions are more critical
than reductions in N02» Furthermore, reductions in vehicle miles
traveled (VMT) in the Denver area are needed, in addition to
reductions in per-vehicle emissions, in order to provide enough
reduction in HC's to attain the ozone standard. These required VMT
reductions will also reduce ambient N02 levels.
5. The Effect of the Standards on the "Brown Cloud". The
assertion that the standards will have no beneficial eTfect on
Denver's "brown cloud" is based on the MVMA's "1978 Denver Winter
Haze Study." The MVMA study concluded that automobiles contribute
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about 14 percent of the "brown cloud." About 36 percent of the
cloud was unidentified, 14 percent was from diesel vehicles, and
about 27 percent was from fuel combustion in stationary sources.
The remaining 9 percent was water and crustal material. The study
relied highly on emission factors for these allocations. The only
emission data for particulates from motor vehicles at high alti-
tude, used in the study, were from ten 1970 model year vehicles
which were restored as completely as possible to a new vehicle
condition. Data presented by the MVMA does show that particulate
emissions from automobiles are increased by rich air-fuel mixtures.
However, the ten 1970 model year vehicles were tuned to manufac-
turers' specifications and may not have been as rich as in-use
vehicles. Furthermore, no catalytic converter vehicles were tested
to establish high-altitude particulate emission rates.
The lack of particulate emission data from in-use vehicles at
high altitude leaves the contribution of motor vehicles to the
brown cloud still very much in question.
The primary effect of the proposed standards will be to reduce
HC and CO emissions, by obtaining altitude compensation of non-
feedback vehicles and phases of feedback vehicle operation which
are "open loop." This compensation will provide leaner air-fuel
mixtures which will also lower particulate emissions. The effect
of these lower particulate emissions on the brown cloud cannot be
determined at this time, but the effect will tend to be beneficial.
6. Non-Resident Vehicles. Although there may be a signifi-
cant number of non-resident vehicles in the Denver area, high
levels of CO and ozone are primarily due to rush hour traffic.
Non-resident vehicles are not a significant part of rush hour
traffic.
7. In-Use Modifications. The State of Colorado is requiring
the use of high-altitude performance adjustments developed under
Section 215 of the Clean Air Act on vehicles failing the I/M
program. Such a requirement could also be used for the interim
high-altitude standards. Of course, the proposed regulations
require all new vehicles sold for principal use at high altitude to
be modified prior to delivery.
Recommendation
The finding required by Section 202(f)(3)(c) of the Clean Air
Act, that the interim high-altitude standards will result in a
significant improvement in air quality, should be made in the
affirmative.
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I. Issue - Leadtime
Summary of Issue
EPA proposed that the interim high-altitude standards take
effect in the 1982 model year for light-duty vehicles and light-
duty trucks.
Summary of Comments
Comments on the leadtime which is available before the stan-
dards become effective were directed at the time required to
develop the necessary hardware and the exaggeration of the normal
development time because of inadequate high-altitude test facil-
ities.
Major Subissues
Development Leadtime - Cars: Many manufacturers commented
that time was not available to develop hardware for the 1982 model
year. GM commented that their C-4 system could meet the 1982 date
only if any necessary modifications were extremely minor. In
another comment, GM stated that leadtime was nonexistent for 1982
because they have already begun certifying some subcompact models
for that year. Chrysler commented that they had enough time if
all that would be needed were modifications to the electronic
components of the control system. But if more significant hardware
changes needed to be made (i.e., MAP sensor), the decision would
have to have been made in the spring of 1980. However, in a later
communication with EPA (see the docket) Chrysler stated that they
would not need a MAP sensor. Nissan stated that for 1982, a final
decision on the system must be made in the summer of 1980, and also
that development would take one year. Ford commented that for the
1982 model year, development should begin in July 1980. Ford
also stated they didn't have enough leadtime for aneroids on all
vehicles but were planning to meet standards with unique calibra-
tion. AMC stated that they could not adapt GM's control system to
their vehicles by 1982 and possibly not by 1983 because of a lack
of experience with the system and conflicting resource commitments
with other programs. NADA commented that the interim standards
should not be finalized because manufacturers need until 1984 to
design high-altitude vehicles. Jaguar submitted two divergent
comments. First, they said there was insufficient leadtime for
testing to determine changes. Second, they said they were con-
fident they could meet the standards except for those engines
which were granted a CO waiver- Finally, Jaguar stated their
suppliers need 6-10 months notice before production starts to make
hardware change. Toyota and Puegeot generally commented there was
insufficient time to comply.
Development Leadtime - Trucks: Chrysler stated that there is
no time left to make the necessary carburetor tooling changes on
their 318-2 trucks. AMC maintained there was inadequate resources
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and time to modify their trucks for 1982 or even by 1983. They
claimed that extensive retooling and design would be needed. GM
stated that air pump capacity for 1982 would not be sufficient for
national production, but if allowed to put them on at altitude
only, they would have enough. GM also commented that the truck
standard should be delayed until 1983. Ford commented in a general
statement that there was inadequate leadtime for all of their
vehicles to meet the 1982 standards. IH commented there was
inadequate leadtime to incorporate aneroids on their trucks by the
1982 model year and indicated they would be forced to use fixed
calibrated carburetors.
Leadtime - Facilities; Several manufacturers commented that
there were inadequate facilities for high-altitude testing.
Ford stated that their facilities were limited. More specifically,
Fuji made two comments concerning their need to construct a high
altitude test SHED because of the likely unavailability of com-
mercial facilities at Denver, Colorado. In their comment at the
public hearings, they said it would take 22 months to build and
operate their SHED. However, in their written comments, they
indicated that 12 months would be needed. Nissan commented that if
demonstration tests are required, more facilities will be needed
and that even meeting the standards in 1983 would be difficult.
Analysis of Comments
Development Leadtime - General; The determination of adequate
leadtime involves two central issues: technical complexity and
availability of testing facilities. In this analysis the issue of
technical complexity is examined to find if enough leadtime is
available to adequately develop and certify high-altitude emission
control hardware for 1982 model year vehicles. The issue of
available facilities is examined in the section entitled, "Adequacy
of Existing High-Altitude Test Facilities."
Leadtime is dependent upon the complexity of the requisite
control technology and the effort required to translate the tech-
nology into production hardware. Manufacturers' comments lacked
adequate detail with which a specific analysis could be conducted.
Alternatively, this analysis of leadtime is based on "worst case"
examples which will require the longest time. If adequate time
exists in which to develop, certify, and produce the "worst case"
examples, than it is reasonable to expect that other less complex
and, hence, less time consuming changes can be made. Therefore,
this analysis begins with a delineation of "worst case" development
requirements to characterize the level of effort which will be
required to meet the 1982-1983 standards. After the hardware has
been described, it will be related to the historical development-
certification schedule of the automotive industry. Conclusions can
then be drawn regarding the adequacy of leadtime based on the
complexity of the required hardware and the way in which the
industry has historically dealt with similar problems in the past.
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Finally, this analysis will briefly review some of the comments for
support of the conclusion.
The principle control strategy for vehicles that do not have
the inherent capability to meet the standards is to enlean the
.fuel-air mixture to promote more complete combustion. After
carefully reviewing all of the comments and after conducting
an independent investigation, EPA Relieves that this will be
achieved with recalibrations of engine and emission control param-
eters. The required recalibrations will probably include short
leadtime tooling on both feedback and nonfeedback systems.
The most critical, or "worst case," hardware modifications include
calibration changes to carburetors for non-feedback systems and the
addition of electronic components for feedback systems. Other
techniques include changes to timing, air pump, and EGR.
Several commenters pointed out that not enough time is avail-
able for developing and tooling long-leadtime items. EPA is in
basic agreement with these comments. However, the Agency rejects
the position that major hardware and tooling changes are necessary
to accomplish the types of control strategies mentioned above.
For non-feedback systems, modifying carburetors to accomplish
enleanment can be accomplished by using either fixed calibra-
tions or automatically compensating aneroids. Aneroid controls
are preferred because they can provide near optimal control
at various altitudes and, because, if properly designed, they have
the potential of providing less complex and lower cost high-
altitude modifications. Aneroids are currently available on some
car/truck models; other models could easily change to existing
aneroid controlled carburetors; while still other carburetors could
be modified by machining air bleed passages or through simple
modifications to castings.
The remaining non-feedback carburetors, could be redesigned to
accept an aneroid only by more complex changes to die patterns.
This type of change is a long leadtime modification. In developing
the parameter adjustment regulations, manufacturers commented that
these more complex changes can take 1.5 or more years to complete.
Therefore, aneroids can not be used to comply with the proposed
high-altitude standards in all cases. In these instances, however,
manufacturers can obtain the same emission control results at the
design altitude by using carburetors specifically calibrated for
use at high altitudes (fixed calibration). This type of control
hardware has been certified for high altitude sales in the past
by GM. Fixed calibration carburetors cannot be optimized for
different altitudes and can be somewhat more expensive if vehicles
are modified from a low-altitude configuration to a high-altitude
configuration. But they do offer substantial control at high
altitudes.
Optimal high-altitude fixed calibrations can usually be
achieved by simple machining or readjustment of certain carburetor
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parameters. Fixed calibrations will not require long leadtime
retooling efforts as might be necessary if the whole carburetor
casting pattern had to be modified in order to accept an aneroid.
Recalibration of low-altitude engine/emission control systems for
high-altitude use can be accomplished by changing such items as the
fuel jet(s), the choke, the power enrichment circuit, the idle
fuel-air mixture, the idle speed, etc. The time to make the
tooling changes required to produce the above described fixed
calibrations is basically a function of the number of tests
that are needed. In the Regulatory Analysis for this rulemaking,
EPA has estimated that not more than about 150 tests on the average
(i.e., Federal Test Procedure not including evaporative emissions
determination) will be required for each IDV and LOT engine family
to determine high-altitude fixed calibrations. At the very slow
testing rate of only one test per day, the 150 tests can be finish-
ed in less than six months, thereby leaving plenty of time to
implement any minor tooling changes before August 1, 1981.
EPA currently estimates that 70 percent of the vehicles
manufactured in 1982 and 1983 will use feedback (electronically
controlled) fuel systems. All of these systems have an inherent
capability to compensate for changes in altitude. In this regard,
some systems have a greater range of compensating authority than
others. Although many systems appear to be able to automatically
meet the high-altitude standards, others will need to be recali-
brated. As delineated in the comments at the public hearings,
leadtime is most critical if a manifold absolute pressure (MAP)
sensor must be added to the feedback system. However, MAP sensors
are no longer expected to be necessary as indicated by Chrysler's
statement. Reprogramming the electronic cont.rol unit may be
required for some vehicles, but, as stated by GM and Chrysler,
it is not as difficult as adding a MAP sensor. Chrysler speci-
fically commented that adequate leadtime existed to recalibrate the
electronics.
At this point, the worst case items for feedback and non-
feedback systems have been delineated. It has been shown that
the requisite hardware changes do not involve long tooling or
development, leadtimes. What will be required are modifications to
existing hardware which include the two "worst case" examples of
recalibrating fuel systems: fixed calibrations, for non-feedback
fuel systems and reprogramming the electronics control unit for
feedback fuel systems. Now that the scope of the required changes
has been described, the worst case recalibration efforts can be
related to the historical development, certification, and produc-
tion cycle of the industry.
Current development, certification, and production schedules
vary with each manufacturer. Table 1 shows Chrysler's projected
schedule for certifying 1982 low-altitude LDVs and LDTs. EPA's
past experience with industry schedules shows that Chrysler's
schedule is somewhat optimistic. As an example, Chrysler projects
the submission of final certification documents to EPA is May 26,
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while the Agency .typically receives these submissions as late
as June or July. However, Chrysler's"scheme is useful as a repre-
sentative schedule of events.
Historically, manufacturers' production hardware calibrations
are determined through a series of iterations which occur through-
out the development and certification process. Calibration changes
can occur even after a certificate of conformity has been issued by
applying for "running changes." Therefore, depending on the
complexity, production calibrations can be finalized as late as the
beginning of production which usually occurs near August 1.
It may be argued that calibrations must be developed to a
great degree in time for the building of 50,000-mile durability
vehicles or, alternatively, at least in time for 4,000-mile
emission data vehicles. This is true for vehicles which must
currently be certified for compliance with low-altitude standards.
It is not true for compliance with high-altitude standards. As
discussed in the section entitled, "Number of Certification
Vehicles," manufacturers will not be required to build and ac-
cumulate mileage on high-altitude hardware for 50,000-mile dura-
bility or 4,000-mile emission data tests. Even though preliminary
calibrations would be specified to EPA earlier, specific calibra-
tions would not absolutely need to be developed and built until the
high-altitude emission tests were ready to be conducted. These
tests would not be performed until the 4,000-mile low-altitude
tests had been completed and the vehicles were ready to be modified
into high-altitude test configurations. Therefore, in "worst
case" situations the first high-altitude test hardware could be
delayed until a March-June time frame. Final production calibra-
tions might be completed as late as August.
From the time the final high-altitude standards are scheduled
to be published in November 1980, until the start of production in
August 1981 is about 9 months. EPA believes that this provides
the industry with adequate leadtime to meet the 1982 standards
for the worst case recalibrations. As discussed above, EPA is
convinced that the 150 tests which may be needed to recalibrate a
low-altitude engine family (reprogramming of the electronic control
unit requires even less testing) can be done in six months at
most. This conclusion is further supported by the fact that many
manufacturers appear to have already had significant experience
with the affects of altitude on fuel systems. This experience is
based on several things. Many manufacturers either have high-
altitude test facilities, as described in the issue entitled,
"Adequacy of Existing High-Altitude Test Facilities," or have
experience with non-facility high-altitude tests such as con-
ducted by AMC and others for driveability and performance demon-
strations. In 1977, manufacturers produced vehicles in compliance
with mandatory high-altitude standards. Several manufacturers have
participated in the voluntary high-altitude certification programs
subsequent to 1977. Among them are Volkswagen, GM, Ford, and
Chrysler. Finally, vehicles certified to the California standards
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must demonstrate control of emissions at high altitude, although
the requirement is' admittedly less rigorous than that necessary for
1982 and 1983 standards. All of the above examples indicate that
manufacturers have amassed a significant body of knowledge from
which they can draw upon when developing high-altitude calibra-
tions. This experience should enhance the rate at which high-
altitude hardware can be developed.
Although many of the general comments indicated that leadtime
was not adequate for the 1982 model year, there is support for the
conclusion that recalibrations can be produced in time for 1982.
Ford said that the time required to build, develop, and certify an
emission-data vehicle calibration is one year. Previously it was
pointed out that final calibrations could be delayed until very
near the start of production which is August. Assuming a worst
case situation in which Ford does not begin development until the
final rule is published (November 1980), and that they need to
delay the finalization of production hardware until August 1981,
they would still have approximately 9 of the 12 months they suggest
is necessary. When it is remembered that neither the 50,000-mile
durability vehicle nor the 4,000-mile emission-data vehicle will
need to be run for high-altitude certification, it is apparent that
adequate leadtime exists for Ford. The overall burden of meeting
the high-altitude standard is further moderated for Ford in
light of the fact that about 50 percent of their models in past
years have been available with a high-altitude option. This option
apparently consisted of an aneroid carburetor. Since Ford stated
that their aneroid carburetors could meet the standards, presumably
little or no effort need be directed at aneroid equipped vehicles
so their resources can be used to develop calibrations for the
remaining non-aneroid models. Ford also indicated at the public
hearings that they had been planning to meet the standards with
fixed calibrations rather than designing every car to meet both the
high- and low-altitude standards. Because EPA has deleted the
$40 modification limit, Ford can now proceed with their previous
plans.
Chrysler stated that they required three changes to recali-
brate vehicles to meet the high-altitude standards: reprogram the
electronic control unit, add a MAP sensor, and the addition of
aneroids to some truck families. At the public hearings, Chrysler
said that recalibrating the electronic unit could be delayed
until about October or September. They commented that the MAP
sensor was a more critical problem. However, since then they
have stated a MAP sensor is no longer necessary. Chrysler com-
mented on the aneroid carburetor leadtime issue subsequent to the
hearing.^/ They indicated that if they were allowed to place
aneroid carburetors on only the vehicles sold at high altitude,
they could avoid problems that might "make it impossible to design
and tool the necessary hardware in time for the 1982 year." By
deleting the $40 limit on the cost of modifications, EPA has
removed the obstacle which Chrysler alluded to. With the deletion
of mileage accumulation, Chrysler should have adequate leadtime.
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IH said they would not have enough time to add aneroids
and that their only approach would be to develop fixed calibrations
for high-altitude vehicles. Again, this will be possible now that
the $40 modification limit has been deleted. In comments on the
proposal, Jaguar stated they needed 6-10 months notice for their
suppliers to produce the necessary high-altitude hardware. If the
regulation is promulgated in November 1980 and production begin in
August 1981. Jaguar would have up to 3 months in which to develop
high-altitude calibrations. Further, in a letter dated April 2,
1980, Jaguar stated they are confident they can meet the standard
on all engine families except the 215 CID V-8 and the 326 CID
V-12._3/ Those engines have been granted waivers from the statutory
CO standard.4/ For waivered engines, EPA has provided an alterna-
tive high-altitude standard which is more lenient. The Agency's
technology review shows Jaguar should be able to meet that alter-
native standard. Furthermore, Jaguar has stated that they will be
conducting high-altitude testing for six weeks during July and
August 1980._3_/ GM, like Ford, will not require development
testing for many of the vehicles in their product line. Data
presented by GM shows that their C4 systems has the capability to
meet the standards for the majority of their LDVs. The potential
development burden is, therefore, greatly reduced and, hence,
leadtime required to recalibrate non-complying vehicles should also
be reduced. Based on the above, Ford, Chrysler, Jaguar, IH, and
GM, in particular, appear to already be well on the way to comply
with the 1982 and 1983 standards.
Development Leadtime - Specific: GM commented that leadtime
was inadequate for their subcompact cars which have already
begun 1982 certification testing. EPA has confirmed that GM has
begun durability testing for one model line of subcompact cars.
Apparently GM plans to introduce this model early in 1981.
These subcompacts utilize a new front wheel drive, transverse
mounted engine. There is no preexisting data to indicate whether
this engine would require additional development to meet the
high-altitude standards. However, the subcompacts will use the
same C-4 emission control system as other GM cars. For the other
cars this system apparently either has the inherent capability to
meet the standards or can do so with a relatively minor modifica-
tion. EPA believes that the use of the C-4 system in GM's new
subcompact model will allow the vehicles to be certified and
produced without significantly compromising GM's current production
schedule.
AMC commented that they will use GM's C-4 system on their 1982
LDVs. They claimed that this system had the ability to meet the
standards but they would be unable to recalibrate the system in
time to comply. AMC presented no data to substantiate this claim.
This same argument, however, was used in their application for a
waiver from the statutory CO standards which are applicable to 1981
and 1982 model year vehicles. In response to that waiver, EPA
carefully considered AMC's alleged leadtime problems.2/ The Agency
concluded that AMC could not complete development of the C-4 system
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for the 1981 model year but that they should be able to certify the
system by the 1982 model year. AMC was granted a CO waiver for
1981. By approving the waiver, EPA noted that the effort saved in
developing a system for 1981 should enhance AMC's ability to
calibrate and certify the C-4 system for 1982. Regarding the
high-altitude standards, AMC and GM have similar situations.
It appears that once the C-4 system has been calibrated at low
altitude, any recalibration, if required at all, will be a rela-
tively simple task. Therefore, there is no reason to believe that
AMC cannot comply with the high-altitude standards beginning in
1982.
EPA concludes, therefore, that adequate leadtime exists for
specific vehicles to comply with the high-altitude standards
beginning in the 1982 model year. This conclusion is based pri-
marily on the fact that time is available in which to develop and
certifiy the required "worst case" hardware, i.e., recalibrations
of low-altitude engine and emission control parameters. The
conclusion is further supported by the fact that most manufacturers
already have significant experience with the effects of altitude on
vehicle emissions and that many vehicles have already demonstrated
the ability to meet the standards.
However, EPA recognizes that in light of the late promulgation
date of this rule, that the resources, personnel and facilities,
may occasionally be strained to do all the work necessary for all
engine families. This problem is perceived to be particularly
acute in the truck field where the technical difficulties associ-
ated with compliance are greater, in part, because of the absence
of feedback control systems and the wide variety of configurations,
all requiring unique calibrations. Relief from some of the de-
velopment and certification burden will assure success for the
remainder. Thus, on exemption in 1982 for some fraction of the LDT
fleet based upon sales or number of models is very utilitarian at
this point.
Recommendat ion
Adequate leadtime exists for LDVs in which to develop, certi-
fy, and produce vehicles in compliance with the 1982 and 1983
high-altitude standards. LDVs manufactured for the 1982 model
years should be included in the high-altitude standards. It
appears that the manufacturers of LDTs may be excessively strained
to obtain the necessary certification for their entire fleets in
time for the start of 1982 production. On the other hand, the
problem seems not so severe as to abandon 1982 altogether. A
rational compromise is to provide a sales-based exemption for some
fraction of the LDT fleet, perhaps, 30 percent, as recommended by
Ford. This would alleviate the time constraints.
-------
Table 1
Chrysler 1982 MY Certification Program
Program
4k Data
Vehicles
50k
Durability
Vehicles
1980
JFMAMJJA
X
(6/23)
Hardware
Chart
Published
X X XX
(1/28) (3/24) (5/27) (7/1)
Hardware Emission Hardware Dur.
Chart Hardware Delivery Test
Published Calibrated Start
1981
SONDJFMAMJJA
XXX X XX
(9/25) (11/13) (12/15) (5/4) (6/30) (7/28)
4k 4k 4k 4k EPA Job fl
Final Hardware Start Stop Cert.
Calib. Delivery
Hardware
X
(5/28)
Cert .
to EPA
X
(12/1)
Dur.
Test
Stop '
o
VO
I
-------
J. Issue; Exemptions
Summary of Issue
The high altitude NPRM proposed to require all vehicles to
meet or be modifiable to meet the high-altitude as well as the
low-altitude standards. This would ensure the same selection of
vehicles at high altitude as at low altitude. However, EPA in-
tended to offer exemptions from the high-altitude rules to those
fuel efficient vehicles whose low power-to-weight ratios lead to
technical difficulty in achieving compliance and which tend to
make them unsuitable for high altitude use anyway because of poor
performance.
Summary of Comments
The variety of possible criteria that were suggested included
(1) exemption for vehicles having automatic compensating devices
(Honda), (2) exemption for all vehicles having fixed calibration
(GM), (3) exemption for all high fuel economy vehicles, based upon
power-to-weight ratio or percentage of sales (GM, AMC, Honda,
Chrysler, Ford).
In addition, most manufacturers objected to EPA's labeling
idea that exempted vehicles be labeled "unsafe at altitude" (Ford,
AMC, GM, Chrysler). A more accurate label would be "unsuitable."
Major Subissues
1. Need for Exemptions. This addresses the basic issue of
whether exemptions are necessary and desirable at all, and their
justification.
2. Circumscription of Exemptions. This section delineates
the various criteria which have been suggested by manufacturers and
EPA to be used to determine exemptions and responds to comments
about the proper labeling for exempted vehicles.
Analysis of Comments
1. Need for Exemptions. There are three possible reasons
for providing for exemptions: (1) to save the manufacturers the
needless expense of certifying for high altitude, certain vehicles
that are sold there in very small quantity, (2) to avoid having
the most fuel economic vehicles eliminated from the general market
because they could not comply with the high-altitude standards, and
(3) to offer relief to the manufacturers if there is insufficient
leadtime to complete the development and certification processes
before production. [The rule requires compliance with both the
high- and low-altitude standards (with modification, if necessary)
for certification; hence, failure to comply with either standard
precludes certification and, therefore, marketing at any location,
regardless of altitude.] The first argument is strictly economic,
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the second, technical and societal (need to conserve fuel), the
third, temporal.
EPA does not consider it particularly valid to exempt low
sales volume vehicles per se, if in fact their low sales do not
reflect a high-altitude performance problem, but only the special-
ized nature of the vehicle (e.g., trailer tow packages).
The issue of fuel economy is not restricted to vehicles of
maximum fuel economy in the absolute sense, but rather to those
vehicles within a utilitarian classification. Thus a half ton LOT
could be "fuel economic" in the relative sense of being superior to
other half ton trucks and yet certainly be inferior to the best
subcompact auto. The claim of technical difficulty is based upon
the fact that high fuel economy vehicles typically have low power-
to-weight and low drive train ratios (the latter obtained by a low
rear axle ratio). The problem such vehicles have with a high-
altitude standard is that the combination of reduced available
power (due to less dense air), the already low power, and high
gearing (low axle ratio) force the vehicles to spend excessive time
in the "power enrichment" mode during the FTP. This may produce
too much HC and CO, despite the usual calibration changes that are
effective at higher elevations: timing and carburetor flow.
Technical solutions appear to exist for the few possible "worst
case" situations. The most direct would be to disconnect the power
enrichment mechanism. While this sacrifices perhaps five or more
percent of the available power, it eliminates the source of the
ultra-rich operation. This may, however, lead to complications not
only in driveability, but more significantly, in durability because
of too-lean operation at maximum load. An alternative solution, if
permitted, is to change the rear axle ratio. This approach "gears
down" the entire vehicle and thus avoids some portion of the use of
the power enrichment. All in all, it is possible in isolated
cases -that either compliance is impossible or, if possible, it
results in a vehicle of unacceptable driveability or durability
unless axle ratio changes are permitted. Such vehicles are ex-
pected to be relatively fuel economic ones. On the other hand, no
such vehicles have yet been identified (see Technology issue). The
new vehicles, such as the Chrysler K and GM J cars, have emissions
performance unknown to EPA as yet.
The leadtime analysis suggests that there may be some manu-
facturers whose personnel resources would be strained to complete
all the requisite tasks leading up to and including certification.
The argument would be credible of course, only for the 1982 stan-
dards. If a portion of the fleet were granted an exemption, then
the work burden on the manufacturers is lightened and presumably
they could get the remaining portion properly certified in a timely
manner. As the issue is basically that of leadtime, therefore, the
analysis is not repeated here.
What, then, are the ramifications of providing or not pro-
viding exemptions? First, if exemptions are not offered, then all
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vehicles, including those with small or zero high-altitude sales,
must comply. There is a possibility, perhaps remote, that some
fuel economic ones will not be able to comply with the high-
altitude rules by the usual recalibration methods, including
automatic schemes. Those which cannot comply are faced with
certain options.
First, probably all of these vehicles can achieve compliance
by having the power enrichment disconnected. Being thus certified,
the vehicle will be offered for sale at low altitude, but probably
not sold at high altitude because of the anticipated durability and
driveability problems of such a high-altitude configuration. It is
possible that this extreme fix may not even suffice on a few
vehicle configurations, thus forcing the second option.
Second, they may retire from the general market (low, as well
as high altitude), thus costing the nation one fuel economic option
to the consumer- This concern is also addressed in the issue, Model
Availability.
The third possible option for non-complying vehicles, if
permitted, would be a change in the rear axle ratio. Such a
change was not a viable option in the proposal because of the $40
limit on modifications but is now possible because EPA is deleting
this requirement. Therefore, if now permitted, it could be expec-
ted that a number of less fuel economic vehicles might also incorp-
orate this fix instead of extensive recalibration of the carburetor
and timing, or the introduction of automatic compensating devices
(i.e., rather ordinary fixes). These vehicles would not suffer the
durability and driveability problems which might plague those few
whose power enrichment was cut off. With this situation, there
should be no vehicle-engine-transmission combination that could not
meet the standard and, hence, in a general sense to the consumer,
model availability is maximized. Manufacturers should be more
willing to sell these vehicles at high altitude because with the
power enrichment mode still available, the potential durability and
driveability problems will not occur. Also, these vehicles, unlike
other fuel economic, low power-to-weight vehicles, will tend to
have better performance (acceleration) because of the higher
gearing and, hence, are likely to be better received by the high-
altitude consumer. These vehicles, however, would likely be
somewhat less fuel economic.
However, it must be recognized that by allowing axle changes,
the overall drivetrain gearing ratio becomes a limited option to
the consumer. Thus, while he will be able to get any model,
engine, and transmission, he may not be able to get at high
altitude, all of the rear axle ratios that are available at low
altitude. While this may not seem a significant loss, as most
consumers are not particularly sensitive to the axle choices, it
should be remembered that those vehicle-axle combinations that
would not be available at altitude are most likely those of maximum
fuel economy (at least relatively) and may, therefore, have a large
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degree of public notoriety. Their failure to be sold at altitude
may have a significant impact on the public perception of model
availability, despite their lack of suitability for high-altitude
use.
In summary, then, if exemptions are not permitted, all engine-
vehicle combinations will have to be certified at both high and low
altitudes or will not be allowed to be sold at all. If axle ratio
changes are not permitted as a high-altitude control technology,
then some fuel economic vehicles may have to resort to discon-
nection of the power enrichment. With this fix, probably most
engine-vehicle-transmission combinations can comply, although a few
may not. Potential driveability and durability problems arising
from a lack of power enrichment may force some manufacturers
from offering those few vehicles at high altitude, despite certi-
fication. Of those offered though, all drivetrain options (axle
ratios) will be available. If, on the other hand, axle ratio
changes are permitted, then probably disconnection of power
enrichment will not likely be used. All engine-vehicle-trans-
mission combinations will be certified at high altitude although
many axles may not be. Those will tend to be the higher fuel
economy vehicles which may be especially sought by the public
despite poor performance at altitude. In any event, without
exemptions the manufacturers will have to finance development and
certification of high altitude configurations, despite the pur-
ported limited sales of very high fuel economy vehicles.
On the other hand, if exemptions are permitted and properly
circumscribed, then fuel economic vehicles (i.e., those with low
power-to-weight ratio which are underpowered at high altitude) will
be offered exemptions. This means, of course, that such vehicles
will not be sold at all at high altitude because they are not
certificated. It may be that these vehicles would have been low
sales volume vehicles anyway at high altitude, owing to their
relatively poor performance, and that little in the way of pur-
chasing options has been lost to the consumer. However, these
exempted vehicles, though few in number, are among the most fuel
economic and probably of considerable consumer interest despite
their poor performance at altitude. Their absence from the market
may impact the perceived model availability more than actual
sales.
For exempted vehicles, some savings lie in the avoidance
of the cost of development and certification of vehicles that have
little utility at high altitude. If technically feasible, however,
the manufacturer may elect to obtain high- as well as low-altitude
certification if he feels that the sales potential at high altitude
warrants the effort. Therefore, the availability of an exemption
will not automatically preclude all eligible vehicles from being
offered for sale at high altitude.
2. Circumscription of Exemptions. The scope of the exemp-
tion impacts heavily on industry's reliance on disconnection of
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power enrichment, use of axle ratio changes (if permitted), and
industry's overall cost of development and certification. A very
limited exemption, that which exempts only the worst performers at
high altitude, may still dictate in some instances disablement of
the power enrichment. Although certified, these vehicles probably
would not be offered at altitude. This may have a practical effect
of removing from sale at altitude entire carline/engine/transmis-
sion combinations. However, permitting changes of axle ratio
may lead to a greater offering at high altitude of vehicle-engine-
transmission combinations.
The principal negative considerations of allowing axle changes
are that (1) it would make in-use retrofit and dealer trade
modification exceedingly expensive, thus discouraging those
activities (Dealer trades could be preserved if trade-in of
the essentially new replaced axle were permitted by the manu-
facturer); and (2), it would remove the most fuel economic vehi-
cles from the market at high altitude. However, because any
exemptions do the latter to some degree, only an absence of
exemptions offers any hope of getting the most economic cars
to market at high altitude. Clearly, however, allowing axle
changes would limit to a larger degree the models available
at high altitude (both the more fuel efficient models and limited
sales models) than a performance or technological exemption.
The basic purpose for the exemption rule is, once again, to
avoid the loss of fuel economic vehicles from the low-altitude
market because those vehicles could not, without great difficulty,
comply with the high-altitude rule. This is less of a concern
if axle ratio changes are permitted. But allowing axle ratio
changes would likely significantly limit model availability at high
altitude.
With this purpose in mind, reasonable criteria for exemptions
can be evaluated. These are:
(1) Percent of sales volume.
(2) Fuel economy number.
(3) Unacceptable performance, as determined by design para-
meters.
(4) Unacceptable performance, as determined by acceleration
testing.
(5) All automatic altitude compensating vehicles.
(6) All fixed calibration vehicles.
(7) Any vehicle configuration for which a demonstration of
inability to comply is provided.
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The basic advantages and disadvantages of these are summarized
below:
(1) Percent of sales volume (10-30 percent)
(a) It provides the most economic exemption from the manu-
facturers' viewpoint.
(b) It does not consider technological feasibility.
(c) It is imprecise and may offer exclusion needlessly
or refuse it improperly.
(d) It, or a modification such as percent of models, cor-
rectly addresses the issue of inadequate leadtime for 1982.
(e) It fails to address the issue of technical difficulty,
poor performance, and fuel economy.
(f) Because it is likely to be defined favorably for the
manufacturers, there is likely to be maximum reduction in model
availability through excessive exclusion.
(2) Fuel economy number
(a) It is an absolute, unambiguous criterion that does not
require additional testing by the manufacturer.
(b) Fuel economy data is obtained during the certification
testing; hence, the information becomes available very late.
Earlier testing is invalid as the prototype would likely not comply
with even the low-altitude standards.
(c) This would exclude many vehicles in need of exemption,
namely those of lower absolute fuel economy, but relatively high
fuel economy for their size. Hence, it misses the point.
(d) Being an absolute criterion, as both the car and truck
fleets are scaled down, a continually larger fraction would be
exempted in succeeding years. Therefore, the value would have to
be revised annually.
(e) EPA will have to determine the appropriate cut-off
figure.
(3) Unacceptable performance, as determined by design parameters
(a) It is an absolute, unambiguous criterion that does not
require any testing; hence, there would be no unexpected failures.
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(b) The necessary data would be available very early to the
manufacturers.
(c) It is possible for a manufacturer to adjust his offering
to maximize exemptions.
(d) Being an absolute criterion, as both the car and truck
fleets are scaled down, a continually larger fraction would be
exempted in succeeding years. Therefore, the value would have to
be revised annually.
(e) The values of the parameters could be set annually
by each manufacturer's marketing strategy, thus solving (d) above.
(4) Unacceptable performance, as determined by acceleration
testing
(a) Acceleration requires testing to establish the minumum
acceptable level and to qualify certain vehicles for exemption.
Thus, it is time-consuming.
(b) Testing could not occur before the certification testing
because earlier prototype versions that do not meet the low-
altitude standards could not be trusted to have the same perfor-
mance as the certification version.
(c) The acceleration limit can be set annually by each manu-
facturer's marketing strategy.
(d) A simple maximum acceleration test may not properly
reflect adequate overall performance or the increase in the time in
power enrichment due to increased altitude.
(5) All automatic altitude compensating vehicles (but permit
sales)
(a) Exempts all those that most easily comply.
(b) Saves considerable certification expense with potentially
little air quality loss as all such vehicles are likely to come
close to compliance, if not in fact comply. However, the reduc-
tions would not be assured.
(c) Would exempt such a large portion of the fleet that
discrimination could be augued by those forced to comply.
(d) Would leave some fuel efficient, low-altitude vehi-
cles still forced with compliance with the high-altitude stan-
dards. The failure of these to comply would have a serious
deleterious effect on model availability of fuel economic vehicles
at low altitude.
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(6) All fixed calibration vehicles (but permit sales)
(a) Exempts all those whose non-certification most signifi-
cantly impacts air quality.
(b) Would exempt such a large portion of the fleet that
discrimination could be argued by those forced to comply.
(c) Would leave some fuel efficient, low-altitude vehicles
still forced to comply. Any failure to comply would impair
the availability of fuel economic cars at low altitude.
(7) Any vehicle configuration for which a demonstration of
inability to comply is provided
(a) This criterion meets the purpose of the exemption exactly
(technical ability).
(b) Like waivers, it requires continuing judgmental effort by
EPA.
(c) EPA could easily be inundated by industry applications
for exemptions.
(d) The subjective nature of the exemption could lead to
inequities and, therefore, claims of abuse of power by EPA.
(e) Every manufacturer could, and likely would, request
waivers regardless of his true capability to comply.
It is clear that some of the above schemes can readily be
rejected. Options (5) and (6) simply seek to serve special in-
terests. In fact, adoption of both together would result in no
regulation at all. Option (1) addresses exemptions for leadtime
considerations, but is irrelevant to the issues of fuel economy
and performance. Option (2) would miss all the relatively, but not
absolutely, fuel economic vehicles. Also, knowledge of exempted
vehicles would be available too late to be useful, and the manu-
facturers would be forced to invest in compliance efforts as a
hedge. Options (3) and (4) address the proper goal; that many
fuel economic vehicles of all sizes have technical difficulty
because of poor performance associated with its economy. Option
(4), however, like Option (2), keeps the manufacturers in the dark
until the last minute about the eligibility of their vehicles for
exemption. Option (7) directly addresses the reason for exemp-
tions, the technical inability of certain vehicle configurations to
comply using any means. However, its implementation is fraught
with difficulties as listed.
Some of the objections of the manufacturers to the proposed
labeling requirement are reasonable. The intended vehicles to be
exempted are not necessarily unsafe and labeling them as such would
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cause problems in future years when these vehicles may well be
offered at high altitude in response to market demands. Rather,
the label should reflect the true exemption criterion, namely that
the vehicle is presently considered by the manufacturers and
verified by test to have unsuitable performance for general high
altitude use and that the vehicle does not meet the requisite high
altitude standard. It is necessary to have exempted vehicles
labeled so that a dealer will know that the sale of that vehicle to
a high-altitude customer is forbidden; it is furthermore necessary
to explain the rationale of the exemption for the benefit of a
potential high-altitude consumer shopping an adjacent low-altitude
dealer.
Recommendation
The basic criterion for exemption should be based upon un-
acceptable performance at high altitude. This should offer relief
to those vehicles which might have technical problems. Of the two
schemes which are directed at unacceptable performance, Option (3)
is the simplest and most beneficial to the manufacturers while
compromising nothing to EPA over Option (4). Option (3), which
utilizes design parameters to measure performance capability,
should provide the manufacturers with the same exemptions as
Option (4), which utilizes acceleration testing. Yet, because the
exemption information is available early on, the manufacturers need
not expend effort attempting to comply as a hedge against unex-
pected failure to quality for exemption later on. Also, there is
no testing cost, nor concern with high-altitude testing facilities
for acceleration tests.
From the perspective of maximizing model availability, the
acceptance of axle ratio changes as a control technique would seem
reasonable. However, model configurations would likely be limited,
and the lost configurations would likely be those with low axle
ratios and high, advertised fuel economy. Otherwise though, some
relatively low power-to-weight vehicles may be forced to disable
their power enrichment mechanisms, leading in turn to possible
durability and driveability problems. This may discourage the
manufacturers from offering these vehicles at high altitude. On
balance, however, the potential cost problems with regard to in-use
and dealer-trade modifications if axle ratio changes were allowed,
may lead to an unacceptable restriction of those activities.
Therefore, axle changes should not be included in any vehicle
exemption criteria.
Finally, the labeling requirement should simply state that the
performance of the vehicle is unsuitable for high-altitude use
because of its poor performance and that it does not comply with
the required standard.
A second exemption provision, based upon a percentage of
sales, should be provided for 1982 because of the apparent exis-
tence of leadtime problems among a few manufacturers (See Leadtime
Issue, I). Several options are available. The sales-based
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exemptions may be given to LDVs, LDTs, or both. The actual per-
centage is arbitrary. To minimize the breadth of the exemption and
to ease the administrative burden, only one class of vehicles
should be considered. LDTs ought to be selected because the
leadtime analysis suggests that greater technical difficulties are
present among that group. Also, LDTs, are the fewer in number and,
thus, further enhance the restriction and ease the administration.
One manufacturer asked for a 30 percent and lacking any further
input, that is recommended.
Vehicles exempted under this provision should still be eli-
gible for sale at high altitude; to be otherwise, would be to
penalize the manufacturers for circumstances beyond their control,
namely the late promulgation of the 1982 rule.
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K. Issue; Model Availability
Summary of Issue
The 1977 high-altitude rule required simply that vehicles sold
at high altitude comply with the standard. Consequently, many
manufacturers found it more economical to eliminate certain
vehicle/engine/transmission combinations from the high-altitude
market than to undergo the development and certification expense.
This occurred with sufficient frequency to become a major annoyance
to the consumer and a potential economic handicap to the dealer.
The proposed rule sought to remove this deficiency by requiring
that all vehicles comply or be modifiable to comply at reasonable
cost ($40). This would have maximized model availability because
all vehicles would have had a high-altitude counterpart. The
dollar limit is being removed in this final rulemaking, but the
modifiable requirement remains. In addition, some room for a
limited number of exemptions to the rule is being considered.
These exemptions primarily would apply to high fuel economy vehi-
cles which might, have technical difficulty complying. Such exemp-
tions would preclude high-altitude sales, but would permit low-
altitude sales.
There are other potential restrictions to model availability
that have been raised as a consequence of the modification rule.
First, if a vehicle configuration cannot be made to comply with the
high-altitude standard, then it cannot be certified even for
low-altitude sale, except by exemption. If not exempted, the
configuration cannot be sold anywhere. Second, if exempted, the
vehicle still cannot be sold at high altitude. Thus, avail-
ability is affected.
For 1982, a special, sales-based exemption is being considered
in order to avoid possible failures to certify due to insufficient
time to get all the development and certification work done. Such
exempted vehicles would still be sold at high altitude. Failure to
have this exemption may seriously impact model availability at all
altitudes.
Summary of Comments
A number of commenters claimed that the $40 limit to modify
any vehicle configuration to its high-altitude equivalent would
reduce model availability rather than maximize it. This would
occur because the infeasibility of holding to $40 would prevent
certification altogether of some configurations (Honda, Toyota,
Ford, GM). Two manufacturers felt that the mere presence of this
rule on top of the other emissions and fuel economy rules would
reduce their sales offerings simply because of a lack of resources
(AMC, Chrysler). Some commenters pointed out a failure to certify
at all on either technical or business grounds would reduce avail-
ability at high and low altitude; the vehicles lost would likely be
the most fuel economical (Ford, NADA, Chrysler). Renault asserted
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the obvious fact that no manufacturer should be required to sell
anything at high altitude.
Analysis of Comments
EPA recognizes, on the basis of the 1977 experience, that the
regulation must be carefully structured in order to prevent
undue hardship either to the consuming public or to the dealers (at
high and low altitudes). The public seeks and, indeed, a free
competitive market demands, a variety of vehicles from which
to choose. The market is sensitive to selection among car lines,
engine size, and transmission options. It is usually insensi-
tive to axle ratio offerings except in a few specialized instances,
usually in the truck line, or trailer tow packages for cars.
On the other hand, it is sensitive to fuel economy, especially
to widely-advertised claims of exceptional performance. Impli-
cit in any claim of extreme economy is the presence of a very
high geared drive train, including a low numerical axle ratio.
Thus, any effort to maximize model availability should empha-
size those vehicle descriptors to which the market is sensitive.
In brief, EPA sees four situations which may reduce model
availability.
1) Technical failure to meet the high-altitude standard, but
configuration is exempted — results in configuration loss only at
high altitude.
2) Technical failure to meet the high-altitude standard -
results in nationwide loss of vehicle configuration.
3) Business decision to restrict sales despite compliance -
results in loss of certain configurations presumably only at high
altitude.
4) For 1982 only, inadequate leadtime may preclude the
timely certification of vehicles that are otherwise capable of
of certification.
The first situation is likely to occur if exemptions are
offered and result in a loss of availability at high altitude.
However, this loss is minimized by limiting the scope of the
exemption only to those vehicles which require it: certain low
power-to^weight vehicles whose weak performance would make com-
pliance difficult or impossible. These lowest performance vehicles
(low power-to-weight) are also those least suited for use at high
altitude because their low performance at low altitude degrades
into unacceptable performance at high altitude. Hence, these
exemptions will have minimal impact on the consumer at high alti-
tude, and of course, none at low altitude. However, those exempted
will also be the most fuel economic, and although unsuitable for
high altitude by the traditional criterion (performance), the
current interest in fuel economy, coupled with the intense national
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advertising of these vehicles, is likely to lead to some customer
interest in these exempted vehicles at high altitude wherein they
would not be available.
Of course, it should also be realized that a given car
line/engine/transmission combination or even car line/engine
combination can be eliminated from high altitude sales by the
exemption and not only certain axle ratio offerings. This is
especially true if the manufacturer offers only a single axle ratio
(e.g., Chevette).
The second situation should be avoided, especially if the
vehicle in question is particularly fuel economic as would likely
be the case. However; as technical difficulty has never been
demonstrated in any particular case and with the exemption criter-
ion properly circumscribed, any vehicle having technical difficulty
would be eligible for exemption. Thus, this adverse situation
(affecting the CAFE averages) is not expected at all.
The third situation may well occur and EPA has no control over
it. However, present experience shows that there is very little
actual restriction of, models available at high altitude. There-
fore, so long as the manufacturers are required to certify vehi-
cles, EPA expects that they will sell them at high altitude.
The fourth situation may occur in 1982 because of the short
time between promulgation and production. If it were likely to
occur extensively across the board, then it would be necessary to
conclude that promulgation for 1982 is unrealistic. However, for
the limited situations wherein leadtime may be a problem because of
insufficient personnel resources, abandonment of the rule for 1982
would be contrary to the needs of the high-altitude urban areas.
Hence model availability would be impacted unless an exemption were
granted for those vehicles unable to certify in time. While
exemption usually would imply forbidden sales at altitude, it would
make more sense here to allow sales, thus not penalizing the
manufacturer for his leadtime problem and simultaneously, retaining
model availability at high altitude as well as at low.
It is possible, though unlikely, that some low power-to-weight
vehicle is not eligible for exemption and simultaneously unable to
comply with the usual recalibrations which would not adversely
affect performance. If this were to occur, the vehicle could still
achieve compliance by the more extreme fix of disconnection of the
power enrichment mechanism in the high-altitude configuration.
However, this fix may render the vehicle unsatisfactory because of
degraded performance, driveability, or durability, and hence the
manufacturer may indeed not actually offer it for sale at high
altitude.
Recommendat ion
No action required; issue is resolved by the exemption pro-
visions. The more extreme scenarios suggested above are only
speculation with no evidence presently available to suggest they
may actually occur.
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L. jssue - EPA's Legal Authority
Summary of Issue
EPA proposed that all light-duty motor vehicles shall meet,
or be capable of being modified to meet, the high-altitude stan-
dards. Any such modification shall be capable of being performed
by commercial repair facilities at a cost to the ultimate pur-
chaser, or any subsequent purchaser, of $40 (1979 dollars). In
addition, the vehicle manufacturer would be liable to ensure that
all vehicles sold for principal use at high altitude are in the
configuration that provides for compliance with'the high-altitude
standards. The Agency also stated that the sale of high-altitude
vehicles for principal use at low altitude would not be considered
a violation of Section 203(a)(l) of the Act.
Summary of Comments
Industry representatives commented that EPA's $40 maximum
cost was unauthorized and constituted illegal price fixing.
Commenters also stated that manufacturers could not be held
liable for dealer actions and that EPA lacked authority to re-
call vehicles built to conform with the high-altitude standards
when operated at low altitude. One company commented that EPA no
longer had the authority to promulgate interim high-altitude
standards at all.
Major Subissues
1. Basic Authority. Ford stated that they believed that EPA
no longer had the authority to set a standard that would require
all vehicles to meet proportional or alternative standards at
high-altitude for 1982-1983 model year vehicles.
2. $40 Maximum Fee1. Most manufacturers commented that EPA's
maximum allowable charge constitutes price fixing and is in viola-
tion of the antitrust laws. Ford stated that forcing manufacturers
to reimburse independent repair facilities for high-altitude
modifications was equivalent to taking property without due process
of law. GM stated that even if EPA intends to use the maximum
charge to only assure that the modification could be done for $40
or less, and then allow the free marketplace to charge any price
that competition allows, the maximum charge is still illegal and
unauthorized.
3. Liability for Sale. Most manufacturers commented that
EPA had misunderstood the dealer/manufacturer relationship. GM
stated that the manufacturer does not sell or deliver vehicles to
the ultimate purchaser; therefore, they cannot be held liable for
the dealer's action. Furthermore, GM cited Section 207(h)(l) of
the Act as specifically imposing direct responsibility for the
ultimate sale of a vehicle upon the dealer.
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4. Recall Authority. Ford commented that EPA lacks author-
ity to recall vehicles based upon testing at any altitude other
than the altitude at which the vehicles in question are principally
to be operated.
5. EPA Has Not Met Statutory Requirements for Standards.
Chrysler commented that contrary to Section 202(f) of the Act, EPA
has not considered and made a finding with respect to:
A. The economic impact of the standards;
B. The availability of control technology; and
C. The likelihood of a significant improvement in air
quality.
6. Low Altitude Sale of High-Altitude Vehicles. Ford
commented that recall and performance warranty actions against
high-altitude vehicles found to be in noncompliance with low-
altitude standards would be illegal because those vehicles would be
adjusted or modified (if necessary) for principal use at high
altitude. Ford's concern is compounded by the fact that EPA
explicitly intended to allow the sale Of high-altitude vehicles at
low altitudes (the reverse situation was, of course, not allowed).
Thus, the number of high-altitude vehicles operating at low al-
titude could have been substantially more than if only residence
changes and transient operation accounted for such low-altitude
operation of high-altitude vehicles.
Analysis of Comments
1. Basic Authority. The Clean Air Act does not explicitly
forbid EPA from setting alternative standards for high-altitude
vehicles. Section 206(f)(l) repealed the high-altitude regulations
applicable to 1977 model year motor vehicles which did differenti-
ate between high and low altitudes. However, Section 206(f)(l)
continues on to state that:
"Any future regulation affecting the sale or distribution of
motor vehicles or engines manufactured before the model year
1984 in high altitude areas of the country shall take effect
no earlier than model year 1981."
Since the proposed regulations apply to the 1982 and 1983 model
year, the prohibition on high-altitude regulations has expired.
Furthermore, Section 202(f)(2) assumes EPA will have to set
alternative standards, as the subsection forbids the Agency from
setting standards that are more stringent at high altitude than at
non-high-altitude locations. There would have been no reason for
Congress to include this subsection if it desired to forbid EPA
from setting alternative standards. The clear intent of Congress
is to enable EPA to set standards which are numerically less
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stringent or as stringent for high altitude until the 1984 model
year. Therefore, Ford's interpretation of the Clean Air Act
appears to be incorrect.
2. $40 Maximum Fee. EPA disagrees with those manufacturers
who considered the $40 maximum allowable charge to be illegal.
However, for other reasons, EPA has decided to delete the proposed
$40 limit (see 45 Federal Register 49254, July 24, 1980). One, EPA
agrees with many"commenters that $40 no longer represents a reason-
able upper limit for high-altitude modifications. Two, EPA agrees
that one result of maintaining the $40 limit would be to encourage
some manufacturers to place unnecessary emission control hardware
on all vehicles, rather than just vehicles sold at high altitude.
Since high-altitude sales represent only about 3 percent of
national sales, this could significantly increase the total cost of
the standards. Furthermore, since the emissions reductions would
occur at high altitude only, the cost effectiveness of the stan-
dards would diminish.
Another option would have been to raise the maximum allowable
charge. However this, would have greatly eroded the potential
benefits of a maximum charge, and would have made the concept
practically worthless. Thus, EPA has decided to delete the maximum
allowable charge altogether.
3. Liability for Sale. The question presented is whether
the vehicle manufacturers can be held liable for the sale of
motor vehicles configured to meet low-altitude emission standards
for use at high-altitude locations. Section 203(A)(1) of the
Clean Air Act prohibits the vehicle manufacturer from the "...
distribution in commerce, the sale, or the offering for sale, or
the introduction, or delivery for introduction, into commerce . . .
of any new motor vehicle or new motor vehicle engine . . . unless
such vehicle or engine is covered by a certificate of conformity
issued (and in effect) under regulations prescribed under this
part." Section 206(a)(l) provides that a certificate of conformity
shall be issued if the Administrator determines that the vehicle
conforms to the emission standards prescribed under §202. The
requirement that all vehicles meet the applicable emission stan-
dards is clear. The only distinction drawn by Congress with regard
to high-altitude use of vehicles is in §202f(l); §202f(2) merely
prohibits the establishment of high-altitude emission standards for
certification which are more stringent than non-high-altitude
standards.
Recognizing the technological difficulties of designing
a vehicle which could meet emission standards at all altitudes,
the proposed regulations do not require that all vehicles be
capable of meeting standards at high altitudes, but that they
be capable of meeting the standards by adjustment or modifica-
tion, §86.082-8(h)(i). The flexibility in the regulation does
not relieve the manufacturer of his responsibility to see that
the vehicle as sold meets the standards. Because §203(a)(l)
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prohibits the manufacturers from selling a vehicle without a
certificate of conformity to the emission standards, it is the
Agency's position that if the manufacturer sells a vehicle which
conforms only to low-altitude standards for principal use at a high
altitude, that vehicle would not be covered by the certificate of
conformity, so that the manufacturer would violate §203(a)(l). The
questions which arise with respect to §86.082-30 (4)(i) and (ii) of
the proposed rules arise because of the nature of the dealer/
manufacturer relationship.
The standard dealer/manufacturer arrangement is a franchise
type agreement under which the manufacturer sells the vehicles to
the dealer, who resells them to the ultimate consumer. The vehicle
manufacturers assert that because they do not sell vehicles to the
ultimate consumer that they should not be held responsible for the
improper sale of vehicles, that the independent dealers should be
responsible for their own actions. The use of "... the offering
for sale, the introduction, or delivery for introduction, in
commerce . . ."in §203(a)(l) strongly indicates that Congress did
not intend the manufacturers to escape liability for prohibited
acts through their distributor agreements. Given that Congress was
aware that automobiles are primarily sold through manufacturers'
dealers, the proscription of only the "sale" to the dealer — but
not to the ultimate consumer — is illogical. Such a narrow and
crabbed reading would mean that neither the manufacturer nor the
dealer would be liable for the distribution and sale of non-
certified cars. In addition, §203(a)(4)(A) prohibits the manufac-
turer from selling a vehicle which does not conform to §207(a).
Section 207(a) requires the manufacturer to warrant to the ultimate
purchaser that the vehicle will conform to the applicable regula-
tions under §202. It is thus much more likely that Congress
intended "sale" as used in §203(a) (1) to mean the sale to the
ultimate consumer since that is the apparent use of the term in
§207(a). Both §203(a)(l) and §203(a) (4)(A) create a duty on the
manufacturer running to the ultimate consumer, not just to his
dealer.
Although the manufacturer may shift the performance of the
required acts to another party, the responsibility for the proper
performance of the duty cannot be shifted, because §203(a)(l) and
§203(a)(4)(A) place their prohibitions solely on the manufacturer.
The requirement that a vehicle conform to standards creates a
non-delegable duty. The doctrine of the non-delegable duty is
usually applied only when violation of a duty can result in
harm to an individual or the public. The public health concerns
connected with air pollution certainly qualify.
In U.S. vs. Ira S. Bushey & Sons, Inc., 363 F Supp 110, the
court held that the public interest of preserving the environmental
integrity of the waters dictated that the parent company be held
liable since it profited from the operations of its subsidiary.
While the facts are somewhat different the case does show that
courts look behind the apparent structure of a business where the
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public interest is concerned to determine where liability should
finally rest. In a case involving similar facts under the Food,
Drug and Cosmetic Act, U..S. vs. Par fait Power Puff Company, Inc.
163 F2d 1008 (7th Cir 1947) the doctrine of the nondelegable duty
was used to hold a manufacturer and distributor of hair products
criminally liable for introducing an adultered and misbranded
product (hair lacquer pads) into interstate commerce, when another
party the defendant contracted with to manufacture and distribute
the product changed the contents of the product and shipped them
into interstate commerce. In holding the defendant liable, despite
their orders to the other party to discontinue manufacture, the
court stated that:
"In other words, one who owes a certain duty to the public and
entrusts its performance to another, whether it be an indepen-
dent contractor or agent, becomes responsible criminally for
the failure of the person to whom he has delegated the obli-
gation to comply with the law, if the nonperformance of such
duty is a crime. Defendant may not put into operation forces
effectuating a placement in commerce of a prohibited commodity
in its behalf and then claim immunity because the instrument-
ability it has voluntarily selected has failed to live up to
the standards of the law," U.S. vs. Parfait Power Puff, 163
F2d-1008, 1009.
The situations are analogous because the liability arises
under a Congressional enactment intended for the benefit and
protection of the public. While Parfait Power Puff involved
a criminal statute, this is not a distinguishing factor as crim-
inal statutes are usually read more strictly than civil statutes.
Thus, under the doctrine of a nondelegable duty, a manufacturer
cannot use its distribution system to escape liability for viola-
tions of §§203(a) (1) and 203(a)(4) of the Clean Air Act.
In spite of the direct responsibility placed upon the manu-
facturers by the Clean Air Act to ensure that vehicles sold
conform to emission standards, the vehicle manufacturers have
stated that they feel the imposition of liability for the sale of
low-altitude vehicles for primary use at a high altitude holds them
vicariously liable for the actions of their independent dealers.
The essence of vicarious liability is the imputation of fault upon
a person who otherwise is faultless. This imputed negligence is
founded upon the existence of some relationship between the par-
ties, such as the relationship between master and servant or
employer and employee.
The manufacturers have stated that no such relationship exists
between themselves and their dealers; that the dealers are indepen-
dent businessmen over whom the manufacturers have no control. The
courts have tended to agree that no agency relation exists between
the auto manufacturers and their dealers for general purposes,
based on a theory of "right to control". Anson v. General Motors
Corporation, 337 F. Supp. 209, 213 (ND Ohio 1974). When it has
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been demonstrated that the manufacturer has a right to control a
specific area of performance, such as the making of repairs or
predelivery service, a limited agency relation has been found.
Yale & Tonn, Inc. v. Sharpe, 118 GA App 480, 104 S.E.2d 318, 323,
324 (Ga: Ct~. App. 1968) Tmaking repairs); Ford Motor Company v.
Pittman, 227 So.2d 246, 250 Fla. Dist. Ct. App. 1969) (no delivery
service check).
The manufacturers should be able to exert control over the
sale of vehicles configured for low altitude for high-altitude use,
either through sanctions on the dealers for violations, or some
sort of indemnification arrangement should the dealer not conform
to the manufacturer's procedures. In addition, the manufacturers
will have to dictate how the modifications and adjustments are to
be made, which will entail a large measure of control. Because of
the limited agency relationship, the vehicle manufacturers (the
principal) will be liable for the actions of the dealers (the
agents).
Even if the dealers are not the agents of the manufacturers
for the sale of low-altitude vehicles for high-altitude use,
holding the vehicle manufacturers vicariously liable for such a
sale is not necessarily impermissible. Although several recent
cases have invalidated EPA assignments of vicarious liability, they
are factually distinguishable, and involve different statutes.
Vicarious liability was deemed unacceptable in Amoco Oil Co. v. EPA
(Amoco I), 501 F2d 722 (1974) because the regulation imposed
liability by an irrebuttable presumption. In that case, Amoco
challenged new regulations which would hold the refiner liable for
the sale of gasoline contaminated with lead from a pump normally
used to dispense unleaded gasoline. The court felt the regulation
should provide an opportunity to show that the contamination of the
gasoline resulted from an unforeseeable act of vandalism by a third
party or from an unpreventable breach of contract by a distributor
(501 F2d at 748), but otherwise did not question the validity of
holding the refiner vicariously liable.
EPA revised the regulation in question to reflect the decision
in Amoco I and the new regulation was challenged in Amoco Oil
Co. v. EPA (Amoco II). 543 F2d 270 (1976). In striking down the
regulation the court stated that:
"In the absence of any indication of a specific intention
on the part of Congress to create a 'new tort1 the traditional
common law rules of vicarious liability must apply" (543 F2d
at 275).
The traditional common law rule is that there must be a
closely integrated relationship existing between the person to be
held vicariously liable and the negligent party, the essence of
which is control of the acts of the negligent party (543 F2d at
276). The court then looked at the traditional lessee-lessor
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relation and determined that Amoco could not be held liable for the
actions of its tenant under the Common Law. The court was careful
to state however that they were "... not prepared to raise the
general rule as a complete bar to refiner liability..." Amoco II
at 276.
The proposed high-altitude regulations are distinguishable
from the regulations promulgated under §211(c)(1)(B) of the Clean
Air Act and which were held invalid in Amoco I and II. Section
211 (c)(l)(B) provides that the administrator may regulate the sale
of any fuel additive which would impair the performance of any
emission control system or device. The language of the Clean Air
Act does not mention or place any express obligations or restric-
tions on the refiners. Sections 203(a)(l) and (a)(4) and 207(a) do
place express obligations on the manufacturers to see that they
sell only certified vehicles. Sale of an uncertified vehicle is in
essence a "new tort" created by Congress to place liability on the
manufacturer. It is especially important to keep in mind that EPA
could require all vehicles to meet standards at high altitudes
without modification.
In Amoco v. U.S. , 450 F. Supp. 185 (W.D. Mo. 1978) the court
disagreed with EPA's interpretation of its own regulation and found
that the refiner was not a retailer simply because it leased the
premises to the actual retailer. The court found that because of
EPA's interpretation of the regulation it was, in effect, holding
Amoco vicariously liable under the same circumstances as Amoco II
without the further justification for its actions found in the
vehicle certification requirements as discussed above.
The most recent decision of Chrysler Corporation v. EPA,
600 F2d 904 (DC Cir. 1979) which invalidated EPA regulations
promulgated under the Noise Control Act is also distinguishable.
Unlike the statute involved in Chrysler, Congress here clearly
expressed its intent that the vehicle manufacturer be held liable
for selling uncertified vehicles in §§203(a)(l), 203(a)(4) and
207(a). By contrasts in the Chrysler case, the regulations placed
warranty liability on the manufacturer of an unfinished truck for
work performed by a subsequent manufacturer who completes the
truck. Besides not finding any authority in the Noise Control Act
of 1972, the court noted that the legislative history expressly
stated that the manufacturer was to be liable only for changes
in noise emissions .which were in fact in each manufacturers'
control. The proposed high-altitude regulations require that the
manufacturer be liable only for his own vehicles and for the
modifications and instructions done to his specifications.
EPA has concluded that the requirement of the proposal whereby
the manufacturer must affix a label to high-altitude vehicles
stating that the vehicle was sold to the ultimate purchaser
for principal use a high altitude is legal and appropriate.
EPA recognized, however, that in certain instances, the manufac-
turer may not know the ultimate destination of a specific vehicle.
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Due to consumer demand, some low altitude vehicles may be modified
by dealerships to comply with the certified high altitude config-
uration (and thereby retain the certificates). The Agency has
therefore revised the regulations to allow a dealer to perform
these modifications and then to affix a label stating the vehicle
has now been modified for principal use in a high altitude loca-
tion. However, it should be emphasized that in making the neces-
sary modifications and affixing the high altitude label, the dealer
is merely acting on the manufacturer's behalf. The manufacturer is
still responsible for assuring that the vehicle is in the config-
uration appropriate for the destination of its ultimate use and
that the vehicle bears a label consistent with that destination.
One other point raised by the vehicle manufacturers is that
§207 (h)(l) of the Clean Air Act requires the dealer to furnish the
purchaser with a certificate that the vehicle conforms to the
applicable regulations under §202. While this section does place a
duty onto the dealer, there is no reason why that should release
the vehicle manufacturers of their duty to also certify the vehi-
cles as required by §203.
4. Recall Authority. Paragraphs (h) of §86.082-8 and (h) of
§86.082-9 require that all light-duty vehicles (LDVs) and most
light-duty trucks (LDTs) must be capable of complying with both the
low and high-altitude emission standards, "by initial design,
adjustment, or modification," with a possible waiver of this
requirement for certain low-power, high fuel economy LDVs. Accord-
ingly, certificates of conformity certify compliance with both low
and high-altitude emission standards (§86 .082-30(a)(3) ) .
EPA may perform surveys of in-use high-altitude vehicles to
determine whether they conform to regulations prescribed under
section 202 throughout their useful lives. Since the high-altitude
regulations are being promulgated under the authority of sections
202(a) and 202(f), a manufacturer whose in-use vehicles do not
comply with these regulations may be ordered to remedy noncon-
forming vehicles when it can be determined, from available infor-
mation, that a substantial number of properly maintained and used
in-use vehicles do not comply with these section 202 regulations.
One of the regulatory requirements, as stated previously, is that
all LDVs and LDTs (except that certain low-powered vehicles may be
exempted) must be capable of meeting the applicable emission
standards for any altitude of operation.
If in-use testing at high altitudes indicates that a sub-
stantial number of vehicles in use at high altitudes do not comply
with high-altitude standards, a recall order may be issued for
the high-altitude vehicles. However, testing conducted at high
altitudes on high-altitude vehicles may not warrant the recall of
low-altitude vehicles. Action to recall low-altitude vehicles
would be appropriate only when the Administrator could determine
from the high-altitude data that low-altitude vehicles did not
comply with section 202 requirements for low-altitude vehicles.
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However, circumstances can be foreseen where testing at high
altitudes may warrant a recall of low-altitude vehicles. This
action would be appropriate, for example, when a defect in design
or materials existed in a component (e.g., a malfunctioning three-
way catalyst) which was necessary to assure vehicle compliance at
either altitude.
A similar analysis could be made of the issue of whether
low-altitude testing would predict that high-altitude vehicles
operating at high altitudes were failing to comply with the sec-
tion 202 requirements and, therefore, warrant the recall of high-
altitude vehicles.
5. EPA Has Not Met Statutory Requirements for Standards.
Chrysler correctly pointed out in their written comments that
section 202(f) of the Clean Air Act permits EPA to promulgate
interim high-altitude standards only after the Administrator has
considered and made a finding with respect to: (1) economic
impact, (2) availability of emission control hardware, and (3) the
likelihood that any significant improvement in air quality will
result.
All three of these issues were specifically addressed in the
draft Regulatory Analysis which was prepared as a support document
for the proposed standards. These issues were further discussed in
the Preamble of the proposal. For the final rulemaking, these
issues will be again analyzed and made available for public
review. Therefore, the Administrator has met the conditions
of section 202(f) for promulgating high-altitude standards for 1982
and 1983 model year light-duty motor vehicles.
6. Low Altitude Sale of High-Altitude Vehicles. After
further consideration, EPA agrees with Ford that the low-altitude
sale of vehicles that are designed or modified for sale at high
altitude would be in violation of section 203(a)(l) of the Act. In
the NPRM EPA stated that the sale of high-altitude vehicles at low
altitude would be legal. However, Ford's comment correctly pointed
out that sections 207 (b) and (c) of the Act allow that recall or
performance warranty protection may only be undertaken upon
making the determination that vehicles are in noncompliance with
applicable standards. Therefore, the Agency could not require
recall or performance warranty action if such vehicles were found
to be in noncompliance with the low-altitude standards if the
Agency were to allow the sale of high-altitude vehicles at low
altitude.
The possibility does exist that high-altitude vehicles
operating at low altitude would not meet the low-altitude stan-
dards, especially the NOx standard. Hence, it would be illegal for
EPA to allow the sale of high-altitude vehicles at low altitude
anyway because such vehicles may not meet the statutory require-
ments. In the proposal, EPA believed that a low-altitude consumer
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who lived at an altitude that approached the official 4,000 foot
cut-off point between high and low altitudes would be better off
concerning fuel economy, performance, and HC and CO emissions if he
were to operate a high-altitude vehicle rather than a low-altitude
vehicle. However, since the possibility exists that not only would
these "fringe area" low-altitude consumers buy high-altitude
vehicles but many consumers who live at very low altitudes would
buy high-altitude vehicles, the Agency has concluded that the
change to the Final Rule is necessary.
Recommendation
It is recommended that low-altitude vehicles be sold at low
altitude only and that high-altitude vehicles be sold at high
altitude only. In view of the revocation of the $40 maximum
allowable charge, it is recommended that no other changes be made
in this Final Rule.
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M. Issue; Parameter Adjustment
Summary of Issue
In the proposal EPA anticipated that some manufacturers might
be concerned about the effect of the parameter adjustment regula-
tions on compliance with the proposed high-altitude regulations.
EPA admitted that the parameter adjustment requirements might
increase the costs of high-altitude compliance, but otherwise found
the two sets of regulations to be compatible.
Summary of Comments
Many commenters argued that the parameter adjustment regula-
tions would make compliance with the proposed high-altitude regula-
tions more difficult and expensive. One commenter expressed
concern over whether vehicles that were certified as high-altitude
vehicles at 5,400 feet and which had sealed parameters would
perform satisfactorily and meet emissions requirements at lower
high-altitude elevations (e.g., 4,200 feet).
Major Subissues
1. Possible Conflict Between High-Altitude and Parameter
Adjustment Regulations. Many commenters argued that the parameter
adjustment regulations, which begin to take effect in 1981, would
make it more difficult and expensive to comply with the proposed
high-altitude regulations.
2. High-Altitude Areas Near 4000 Feet. One commenter
inquired into the assurances EPA had that vehicles with sealed
parameters that met high-altitude certification requirements at
5,400 feet (Denver) would also perform satisfactorily and meet
emissions requirements at lower elevations which are still defined
as high altitude (e.g., 4,200 feet).
Analysis of Comments
1. Possible Conflict Between High-Altitude and Parameter
Adjustment Regulations. Beginning with the 1981 model year, LDV
and LDT manufacturers must comply with "parameter adjustment"
regulations (44 Federal Register 2960). The parameter adjustment
regulations will permit EPA, and require manufacturers, to test
vehicles with their engines adjusted to any combination of settings
within the physically adjustable ranges of their adjustable para-
meters, as opposed to the previous practice of setting those
adjustable parameters to the manufacturer's specifications. For
gasoline-fueled LDV's and LDT's with carburetion systems, idle
air/fuel mixture and choke valve action (e.g., bimetal spring
tension and vacuum pull-off adjustments) will be subject to EPA
adjustment beginning with the 1981 model year, and idle speed and
initial spark timing will be subject to adjustment beginning with
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the 1982 model year. Gasoline-fueled LDV's and LDT's with fuel
injection systems will follow the same schedule, except that choke
parameters will not be affected. There is as yet ho schedule for
adjusting specific parameters on diesel-powered LDV's and LDT's.
These schedules do not exclude the possibility of EPA determining
other engine parameters to be subject to the parameter adjustment
regulations in subsequent model years, though EPA is required to
give manufacturers adequate notice before determining additional
parameters to be subject to adjustment.
There are several actions manufacturers may take to facilitate
compliance with the parameter adjustment regulations; it is antici-
pated that many manufacturers will simply choose to either narrow
the physically adjustable ranges of certain parameters or else make
them entirely nonadjustable (i.e., "fix" or "seal" them)- Parame-
ters which potentially need no adjustment during a vehicle's life,
such as idle mixture and choke valve action, are likely to be
fixed or sealed by many manufacturers, while parameters which do
often require adjustment in service, such as idle speed and initial
spark timing, will likely have their physically adjustable ranges
narrowed.
It is likely, however, that some of the parameters which are
limited or sealed due to the parameter adjustment regulations
might be some of the same parameters that would be adjusted or
recalibrated by some manufacturer in order to comply with the
1982/1983 high-altitude standards. This is really only a problem
for non-original equipment high-altitude vehicles which might have
to be recalibrated (due to a dealer trade for example). Idle
mixture, choke bimetal spring tension, and ignition timing are
parameters which might both be affected by the parameter adjustment
regulations and part of the recalibration recommended by manufac-
turers for high-altitude vehicles. It is certainly plausible that
in the absence of parameter adjustment regulations, these para-
meters could be allowed enough variance such that recalibration to
high altitude could be performed simply and cheaply, while the
existence of parameter adjustment regulations would make such
recalibrations more difficult and costly. EPA has recognized this
situation; in the NPRM EPA stated that "the two sets of regulations
are completely compatible, although the existence of parameter
adjustment regulations may increase the cost of the high-altitude
regulations in some instances."
No commenter disagreed with EPA's conclusion that the para-
meter adjustment and high-altitude concepts are compatible. A
number of commenters did argue, however, that the constraints
imposed by the parameter adjustment regulations would prohibit the
manufacturers from providing the requisite high-altitude modifica-
tions for less than the $40 maximum charge proposed in the NPRM.
It was pointed out that, according to the parameter adjustment
regulations, parameter adjustments cannot be approved if they can
be defeated in less than 30 minutes or for less than $20. If one
adjustment must cost at least $20, there is little else that could
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be done and still keep the charge under the $40 maximum proposed in
the NPRM. If at least two such parameters had to be adjusted to
meet the high-altitude standards, then by definition the $40
maximum charge would be exceeded.
EPA agrees that the monetary restrictions imposed by both the
parameter adjustment and proposed high-altitude regulations would
make compliance by manufacturers with the latter very difficult.
Thus, despite the fact that we consider it unlikely that manufac-
turers will choose to comply with the high-altitude regulations by
recalibration of parameters outside of their physically adjustable
ranges (unlikely except in the case of dealer trades), this is yet
another reason why EPA determined the $40 maximum charge to be
undesirable. EPA has thus decided to remove the $40 maximum charge
from the regulations.
2. High-Altitude Areas Near 4000 Feet. It must be empha-
sized again that EPA expects the great majority of 1982 and 1983
LDV's to employ three-way catalytic converters with oxygen-sensor
feedback control over the carburetor air-fuel ratio. Many of these
vehicles will not require any high-altitude modifications and
should meet emissions standards (and should have acceptable per-
formance and driveability) over a wide range of elevations. It is
anticipated that some LDV's and all LDT's will not utilize three-
way systems in 1982 and 1983. EPA expects most (if not all) of
these non-three-way catalyst vehicles and some three-way catalyst
vehicles to utilize aneroid (pressure sensing) devices to meet
high-altitude requirements. Because most aneroids act as automatic
altitude compensating devices, again the stated concern would not
be relevant. In fact, the commenter's concern applies only to the
few (if any) vehicles which would require either recalibration of
engine parameters outside of their physically adjustable ranges,
separate high-altitude parts. It is true that such high-altitude
vehicles would have somewhat different emissions and performance
characteristics at, say, 4,200 feet than they would at the high-
altitude certification elevation of 5,400 feet. And if certain
parameters were sealed, field adjustment would be more difficult.
There is no problem in this regard with HC and CO emissions,
of course, since it is well known that lower elevations promote
leaner mixtures and lower HC and CO levels. Leaner mixtures do,
however, produce higher NOx levels. The recent MVMA high-altitude
baseline program found that 1970 vehicles tested in St. Louis (520
feet) emitted approximately 87 percent more NOx than the same
vehicles tested in Denver (5,490 feet). Assuming a linear rela-
tionship between the percentage NOx increase and altitude, one
might expect about a 21 percent increase in NOx emissions going
from 5,400 feet to 4,200 feet. Of course, it must be noted that
these were 1970 vehicles not designed with high-altitude emissions
performance in mind. In its April 7, 1980 supplement to its
comments on the high-altitude NPRM, GM reported relevant data on
four of its 1977 high-altitude cars which required certification at
high altitude. One car that was tested at Milford, Michigan
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(950 feet) and in an altitude chamber (5,000 feet) recorded a NOx
level 63 percent higher lower at Milford than at 5,000 feet, while
a second vehicle emitted 8 percent less NOx at Milford when com-
pared to its emissions in the altitude chamber. The third vehicle
was tested at Milford and at Denver and recorded 1 percent higher
NOx emissions at Milford. A fourth vehicle was tested at Milford,
Denver, and in an altitude chamber and the results were incon-
sistent. The NOx emissions at Milford were 58 percent higher than
at Denver but 9 percent lower than in the altitude chamber. No
explanation was given by GM for this inconsistent data. It would
seem from these data which represent special 1977 high-altitude
vehicles that the NOx emission increases for specially-designed,
high-altitude vehicles at lower elevations are somewhat lower and
less predictable than the MVMA data would indicate. In conclusion,
EPA agrees that it is very probable that 1982/1983 high-altitude
vehicles certified in Denver will have somewhat higher NOx levels
at high-altitude elevations nearer 4,000 feet; we would expect the
increases to average on the order of 10 to 20 percent. This is
unfortunate, but we see no easy solution. Similar situations exist
at low altitude; for example, a vehicle certified at Ann Arbor (850
feet) would emit greater NOx levels when driven at or nearer sea
level. But these emissions increases are not excessive. As the
LDV and LOT fleets become dominated by three-way catalyst emission
control systems, such problems will disappear.
With regard to vehicle performance and/or driveability the
discussion is somewhat more straightforward. Defining acceptable
performance and driveability is the manufacturer's prerogative; EPA
does not involve itself in such judgments. Clearly, no manufac-
turer would attempt to sell vehicles at 4,200 feet that did not
have acceptable performance and driveability. While the change in
altitude from 5,400 feet to 4,200 feet would indeed cause leaner
combustion on non-altitude compensating vehicles, we are relatively
certain that the effects on performance and driveability would be
minor. In the same submission referenced above, regarding its
special 1977 high-altitude vehicles, GM stated that "in no case did
General Motors release for production a high-altitude engine which
we felt was commercially unacceptable at sea level." If GM found
no major performance or driveability problems with its 1977 high-
altitude vehicles at sea level, we would anticipate no problems
whatsoever with 1982/1983 high-altitude vehicles at 4,200 feet.
It is true that the emissions standards have become more stringent
since 1977, but on the other hand emission control systems have
also become much more sophisticated.
Recommendation
In view of the fact that EPA has already decided to remove the
$40 maximum allowable charge, it is recommended that no additional
action be taken.
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N. Issue; Fuel Economy
Summary of Issue
In the NPRM, EPA did not claim that there would be any effect
of the high-altitude regulations on fuel economy.
Summary of Comments
A few commenters argued that it would not be possible to
modify certain high fuel economy vehicles to meet the proposed
high-altitude standards. Others commented that to do so would
require major modifications which could degrade fuel economy, and
because of the proposed $40 maximum charge, such vehicles might be
prohibited from being sold at both high and low altitudes. Final-
ly, very few comments (and almost no data) were received as to the
fuel economy effects of the types of modifications which EPA
expects to be utilized to meet the high-altitude standards.
Major Subissues
1. Modifiability of High Fuel Economy Vehicles. A few
commenters argued that it will not be possible to modify some high
fuel economy vehicles to meet the proposed high-altitude standards,
or else that such vehicles would require a major modification such
as an axle ratio change. Accordingly, some high fuel economy
vehicles might be prohibited from sale at high altitude, or would
only be available in slightly less fuel efficient configurations.
In addition, because of the proposed $40 maximum modification
charge, many vehicles requiring an axle change to comply with the
standards might also be prohibited from sale at low altitudes as
well. All of these conditions would lower a manufacturer's cor-
porate average fuel economy.
2. Effect of High-Altitude Modifications on Fuel Economy in
General. Many comments were received on the general question of
the effect of the high-altitude regulations on fuel economy. In
other words, given that most (or all) vehicles will be able to meet
the high-altitude standards without major design changes, will the
high-altitude modifications increase or decrease fuel economy?
Analysis of Comments
1. Modifiability of High Fuel Economy Vehicles. The .manu-
facturers which claimed that some of their vehicles could not be
modified at all, or without major changes, to meet the proposed
standards did not supply data to support their positions. Without
such data, it is impossible for EPA to completely evaluate their
claims.
First, examining the question of fuel economy at high alti-
tude, as discussed elsewhere (see Technology Issue) EPA has con-
cluded that most types of vehicles now sold in high-altitude
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areas are capable of being modified to meet the high-altitude
standards without major modifications (like axle ratio changes)
that might negatively impact fuel economy. EPA recognizes that
there is a remote possibility that some high fuel economy vehicles
might not be able to comply with the high-altitude standards,
but these are generally the same low-power vehicles which are not
now normally sold at high altitude due to performance limitations.
Thus, EPA disagrees with those manufacturers which claimed that
their corporate average fuel economy at high altitudes would be
negatively impacted by these regulations.
With respect to the fuel economy of manufacturers' low-
altitude fleets, EPA is convinced that these regulations will
have no effect whatsoever. The availability of exemptions for
certain low-power vehicles will enable the manufacturers to
market certain high fuel economy vehicles at low altitude that
possibly could not certify to the high-altitude standards.
And the revocation of the $40 maximum charge eliminates the
possibility that a manufacturer would be prohibited from selling
vehicles at low altitude because of an excess cost for high-
altitude modifications.
2. Effect of High-Altitude Modifications on Fuel Economy in
General. Having dismissed the above argument that major vehicle
modification or availability problems would reduce average fuel
economy at either high or low altitude, the issue remains as to
whether the types of modifications we expect to be used to comply
with the high-altitude standards would have a zero or positive
effect on fuel economy.
The basic parameter of interest with respect to altitude
changes is the air/fuel ratio of the combustion chamber mixture
(determined primarily by the carburetor or injection pump in the
gasoline-fueled engine and primarily by the injection pump in the
diesel-fueled engine). For each vehicle, the manufacturer iden-
tifies the optimum air/fuel ratio for optimization of emissions,
fuel economy, driveability, performance, etc. As the altitude of
the vehicle increases, and the atmospheric pressure decreases, less
air will necessarily enter the combustion chamber. Unless com-
pensated for, the engine will thus have a lower air/fuel ratio (a
"richer mixture") and will suffer higher hydrocarbon and carbon
monoxide emissions, and typically worse fuel economy. As discussed
elsewhere, some manufacturers are expected to utilize three-way
catalytic converters with oxygen sensor feedback systems by 1982
which, in varying degrees, compensate for altitude changes. Other
manufacturers, who are not expected to use these systems, will
definitely need to make minor changes, such as the addition of
aneroid carburetors, adjustments of idle mixture, spark timing,
choke, etc. Spark timing, in particular, can have an important
effect on fuel economy. At high altitudes, where NOx emissions are
naturally lower, there exists the ability to advance the timing to
improve fuel economy.
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Generally, the net results of the modifications which manu-
facturers are expected to adopt will be an increase in the air/fuel
ratio (a "leaner mixture") to one that is as close to the optimized
air/fuel ratio as possible. This would be expected to increase
fuel economy. Again, the manufacturers provided very little data
relevant to this issue. In fact, their written comments practically
ignored this issue and EPA had to rely on questioning at the public
hearing to obtain the opinions of several manufacturers. These
voluntary decisions to ignore the effects of the proposed regula-
tions on fuel economy, at a time when fuel economy is such a
critical issue to the manufacturers (both because of rising fuel
economy standards and because of market demand for more fuel
efficient vehicles) are, at the least, interesting.
American Motors Corporation (AMC) and General Motors (GM) were
two manufacturers which ignored this issue in their written com-
ments but which were asked to respond at the public hearings. AMC
admitted that it was possible that the addition of an aneroid (to
adjust the timing) would improve fuel economy. GM stated, "[I]f
you use the barometric sensor to adjust the spark and timing, that
should result in a fuel economy advantage to the consumer." Asked
to quantify the fuel economy benefit, they estimated it to be 2.7
to 2.8 percent. EPA would expect the same type of fuel economy
benefit due. to fixed calibration changes for high-altitude vehi-
cles.
Ford also declined to comment directly on this issue, pre-
sumably because they predicted they would need major design modi-
fications to comply with the proposed standards. In their written
comments submitted at the public hearing, however, within the
context of a discussion of octane requirements at high altitude,
Ford provides a little insight into their position. To quote:
"1979 truck data indicate that unique calibrations using aneroid
fuel metering and spark advance devices improve driveability,
improve wide open throttle acceleration times by as much as 7
percent, and improve steady state fuel economy by as much as 16
percent versus the non-aneroid system. Nevertheless, the octane
quality of fuel available at high altitude caused the deletion of
the 6° [spark] advance feature. This resulted in a 2 percent loss
in performance and loss of most of the fuel economy benefit of the
combined altitude compensating devices" (emphasis added) . Thus,
while discussing the problems their engines may have with lower
octane fuels, they also pointed out the possible fuel economy
benefits of aneroid systems. More evidence of Ford's position on
this issue has been found in "A Special Message to Ford Division
Dealership Personnel" dated November, 1979. In discussing the
merits of their "Special High Altitude Performance Package", which
features a special altitude-compensating carburetor, they reported
that a series of LOT tests at altitudes of 600, 1900, 5200, 8000,
and 14,200 feet resulted in an average 10.7 percent improvement in
fuel economy at a steady speed of 55 mph with the high-altitude
package. It is clear from Ford's statements in this "message" that
they consider their high-altitude packages to improve fuel economy.
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Finally, EPA consulted the recent MVMA high-altitude baseline
program (draft SAE paper by J.B, Edwards, et al, June 11, 1979).
Twenty-five 1970 vehicles were adjusted to manufacturers' speci-
fications and tested at St Louis (elevation 520 feet), tested at
Aurora, Colorado (elevation 5490 feet) as received (thus, still
calibrated to low-altitude conditions) and adjusted to manufac-
turers' specifications and tested again at Aurora. The relevant
comparison involves the testing at Aurora before (which could
represent a vehicle calibrated at low altitude but operated at high
altitude) and after (which could represent a "controlled" high-
altitude vehicle) readjustment to manufacturers' specifications.
The average fuel economy of the 25 vehicles was 2.4 percent greater
after readjustment to specifications than before, again indicating
that high-altitude modifications which would tend to recalibrate
engine parameters (especially air/fuel ratio) as close to ideal
conditions as possible would likely increase fuel economy.
In conclusion, it appears that there will be a slight fuel
economy benefit associated with these regulations. The very
limited data available to EPA indicate that the benefit might
be in the 2 to 3 percent range for vehicles which presently
have no altitude compensation. But many vehicles already have
some type of altitude compensation or else altitude compensation
options, so the fleetwide fuel economy benefit would be some
fraction of the range quoted above. Based on the very limited data
base and the uncertainties involved, EPA will not enumerate any
fuel economy benefit and will not credit any monetary savings to
better fuel economy. EPA does expect, however, that there will be
a small fuel economy benefit from better high-altitude emissions
performance.
Recommendation
Although EPA does expect a slight fuel economy benefit as a
result of these regulations, it is recommended that EPA not attempt
to quantify any fuel economy benefit nor any resulting monetary
savings.
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