A/C No. 6B
state* Off,«o« December 31,1987
Environmental Protection Air •nd R«di«won Page 1 Of 4
Agency Washington. DC 20460
cxEPA QMS
Advisory Circular
SUBJECT: Duration of Certificates of Conformity, Annual
Production Period, and Model Year
The purpose of this advisory circular is to clarify EPA's
definitions of model year, annual production period, and the
duration of certificates of conformity. Advisory Circular No.
6A is obsolete and should be discarded.
B. Background
Under the Clean Air Act of 1970, a certificate of
conformity is to be issued for a period "not in excess of one
year." Advisory Circular No. 6A interpreted the phrase one
year" to mean one model year. It did not, however, define all
relevant limitations governing the duration of one model year
and the annual production period associated with such model
year. This advisory circular clarifies the definitions of the
terms "model year" and "annual production period" in relation
to the coverage of certificates of conformity and to Corporate
Average Fuel Economy (CAFE) calculations.
C. Applicability
The definitions provided by this advisory circular are
effective immediately and apply to all light-duty vehicles and
trucks, heavy-duty vehicles and engines, and motorcycles.
D. Duration of Model Year
A—specific model year must always include January l ot
the calendar year for which it is designated and may not
include a January 1 of any other calendar year. Thus, the
maximum duration of a model year is one calendar year plus 364
days.
E. Definition of Production Period
•The"annualproductionperiod" for any specific model
within an engine family of light-duty vehicles or heavy-duty
engines begins either: (1) when such vehicle or engine is first
produced, or (2) on January 2 of the calendar year preceding
the year for which the model year is designated, whichever date
is later. The annual production period ends either: (1) when
the last such vehicle or engine is produced, or (2) on December
31 of the calendar year for which the model year is named,
whichever date is sooner.
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U.S. Environmental OAR/OMS A/C NO._££___
P'otection Agency PAGE_2_OF_!
F. Duration and Applicability of Certificates of Conformity
T!Section206(a)(l)oftEeCleanAirActof1970
provides that certificates of conformity may be issued for a
period "not in excess of one year." EPA regulations interpret
"year" to mean "model year" (40 CFR 86.085-30(a) (2.)). "Model
year" is in turn defined by section 202(b)(3)(A)(i) of the Act
to mean the manufacturer's annual production period.
Therefore, except as provided in paragraph F.2, below, a
certificate of conformity is deemed to be effective and covers
the vehicles or engines named in such certificate and produced
during the annual production period defined in paragraph E.
2. Section 203 of the Clean Air Act prohibits the sale,
offering for sale, delivery for introduction into commerce, and
introduction into commerce of any new vehicle or engine not
covered by a certificate of conformity unless it is an imported
vehicle exempted by the Administrator or otherwise authorized
jointly by EPA and U.S. Customs service regulations.1
However, the Act does not prohibit the production of vehicles
or engines without a certificate of conformity. Vehicles or
engines produced prior to the effective date of a certificate
of conformity, as defined in paragraph F.I, may also be covered
by the certificate if the following conditions are met:
a. The vehicles or engines conform in all respects
to the vehicles or engines described in the application for the
certificate of conformity.
b. The vehicles or engines are not sold, offered for
sale, introduced into commerce, or delivered for introduction
into commerce prior to the effective date of the certificate of
conformity.
c. The Agency is notified prior to the beginning of
production when such production will start, and the Agency is
provided full opportunity to inspect and/or test the vehicles
during and after their production. For example, the Agency
must have the opportunity to conduct SEA production line
testing as if the vehicles had been produced after the
effective date of the certificate.
3. Vehicles or engines imported by an original equipment
manufacturer after December 31 of the calendar year for which
the model year is named are still covered by the certificate of
1. EPA has issued regulations that permit entry of certain
imported nonconforming vehicles if they are modified to conform
with emission standards even if they are not covered by
certification.
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U.S. Environmental OAR/OMS A/C NO. BE
P-otection Agency PAGE 3 QP 4
conformity as long as the production of the vehicle or engine
was completed before December 31 of that year.2 (However,
see CAFE consideration in Section G.)
4. Vehicles or engines produced after December 31 of the
calendar year for which the model year is named are not covered
by the certificate of conformity for that model year. A new
certificate of conformity demonstrating compliance with
currently applicable standards must be obtained for these
vehicles or engines, even if they are identical to vehicles or
engines built before December 31.
5. The extended coverage period described here for a
certificate of conformity (i.e., up to one year plus 364 days)
is primarily intended to allow flexibility in the introduction
of new models. Under no circumstances should it be interpreted
that existing models may "skip" yearly certification by pulling
ahead the production of every other model year. While this
situation, to our knowledge, has not occurred in the past, a
practice of producing vehicles for a two year period would
violate Congress's intent of annual certification based upon an
annual production period. EPA is not currently setting forth
rules for how to determine when abuse has occurred since this
has not been a problem to date. However, manufacturers should
note our concern in this area and should continue to use normal
yearly production periods for existing models.
G. CAFE Considerations
The Motor Vehicle and Cost Savings Act, section 501(9),
does not use the concept of "introduction into commerce."
Rather, it defines "manufacture" to mean "to produce or
assemble in the customs territory of the United States, or to
import."" The resultant definition of "model year" for CAFE
purposes is equivalent to the definition for certification
purposes for all vehicles except for those produced before
December 31 of the calendar year for which the model year is
named but not actually imported until after December 31 of that
year. These vehicles, as discussed in paragraph F.3, are
included in that model year for certification because they were
produced before December 31 of that year. However, they must
be included in the subsequent model year CAFE calculation, as
they were not "manufactured" (i.e., imported) until after- the
expiration of that year. As an example, consider the case of a
t.This section does not apply to vehicles that may be covered
by certificates held by independent commercial importers unless
specifically approved by EPA.
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&EPA
U.S. Environmental
Protection Agency
OAR/OMS
A/C NO..
PAGE 4
6B
OF_i
1987 model year vehicle "produced" on December 15, 1987 but not
"imported" until January 21, 1988. This vehicle would still be
covered by the 1987 certificate, as it was produced before
December 31 of the calendar year for which the model year is
named. However, it must be included in the 1988 model year
CAFE calculations, as it was imported, and thus "manufactured"
for CAFE purposes, after the expiration of the 1987 calendar
year.
Richard Dr Wilson
Director, Office .of Mobile Sources
7277a
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Subject Index/
umted states office of Table of Contents
Environmental Protection Air and Radiation December 31 1987
Agency Washington. DC 20460 "cwcl '
vvEPA QMS
RECEiVEiAdvisory Circular
JAN 5 1988
ENVIRONMENTAL PROfECllON AGENCY
LIBRARY, REGION V
SUBJECT INDEX AND TABLE OF CONTENTS TO
QMS ADVISORY CIRCULAR SYSTEM
Attached is an updated cross-reference subject index and
an updated table of contents to the QMS Advisory Circular (A/C)
System. These documents reflect additions and replacements of
A/C's. This index and table of contents supersede those issued
November 17f 1982 which are obsolete and should be discarded.
The index and table of contents reflect deletion of
several A/C's which have been superseded or are no longer
necessary as explained in the attached list.
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Un,,edS«a«e, Off,«of
Environmental Protection Air and Radiation DeOStlbgr 31, 1987
A9»nc» Wathingtoo. QC 20460 page ! of 1Q
v>EPA QMS
Advisory Circular
SUBJECT INDEX
Circular
Subject Humber
Access to Certification Information 66
Application Format Data Release 66
National Technical Information Service (NTIS) 66
Administrative Ruling Appeals 45
Advisory Circular System, Description, Numbering, 1A
Organization and Scope
Air-Conditioning Usage
Alternative Dynamometer Settings 55C
Inertia Weight Determination 53
Road-Load Power 53
Test Vehicle Selection 53
Alternative Dynamometer Settings 55C
Annual Production Period 6B
Appeals
Administrative Rulings 45
Application for Certification of Heavy-Duty Engines
Auxiliary Emission Control Devices 76
Public Release, Information, Voluntary 66
Submission
Trade Secrets 66
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U.S. Environmental OAR/QMS
Protection Agency
A/C NO. I]ndex
PAGE 2 QP 10
Application for Certification of Light-Duty
Vehicles/Light-Duty Trucks
Alternative Dynamometer Settings
Auxiliary Emission Control Devices
California Certification Used for Federal
Certification
Frontal Area and Protuberance Calculations for
Road-Load Power Determination
Fuel Economy Regulations
Public Release of Information
Trade Secrets
Assigned Deterioration Factor
Assurance of Public Health
Compliance with 40 CFR 86.078-5(b)(1)(ii)
Compliance with CAA 202{a)(4) and 206(a)(3)
Auxiliary Emission Control Device
Carryover
Criteria for Judging Acceptability
Definition
Defeat Device
Field Fixes
Running Change
Before and After Testing
Scheduled Maintenance
Unscheduled Maintenance
55C
76/76-1
86
73
77
66
66
51C
46
76/76-1
24/24-2
24
24-2
24/24-2
24/24-2
24
24/24-2
12A
4A-1
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U.S. Environmental OAR/OMS A/C NO.
Protection Agency PAGE ? OF m
Break-In Maintenance 12A
California Test Vehicles, Retest 40
California Standards
Federal Certification Based on California 86
Certification
Fuel Economy Labels 83A
Light-Duty 84A
Car Line and Truck Line Determinations 89
Carry-Across Data 17P
Carryover Data
Application Procedures 17F
Defeat Device 24
Durability Data 17F
Emission Data 17F
Evaporative Emissions 17F
Running Changes 17F
Certificate of Conformity
Scope, Duration 6B
Coastdown Test Procedure 55C
Confidential Information 66
Confirmatory Testing at EPA 84A/54A
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&ERA
U.S. Environmental OAR/QMS
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A/C NO.
PAGE 4QF.10.
Components
Auxiliary Emission Control Devices
Failure
Field Fixes
Malfunction
Modification
Correlation, Laboratory
Defeat Devices
Optional Objective Criteria for Determination
Definitions
Auxiliary Emission Control Devices
Certificate of Conformity
Deterioration Factor
Emission Control System
Engine Family Determination
Field Fix
Model Year
Production Period
Unscheduled Maintenance
Deterioration Factors, Assigned
Diagnostic Procedures, Required
Driving Traces, Supplied with Test Vehicle
24
4A-1/36B
2B
4A-1
2B
52A
24/24-2
24-2
24
6B
51C
20B/20B-1
20B/20B-1
2B
6B
6B
4A-1
51C
4A-1
23A
Durability-Data Vehicles/Testing (See Testing, Durability Data)
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U.S. Environmental OAR/OMS A/C NO.
Protection Agency PAQE_L_ OF
Dynamometer
Air-Conditioning 53
Alternative Road-Load Determination 55C
Outdoor Chassis Dynamometer Approval 35B
Emission Control Component Modification (Field Fixes) 2B
Emission Control System
Approval for Use of Emission control Devices 76
Classification 20B/20B-1
Definition 20B/20B-1
Evaporative Emission Control Systems 59
Identification 77
Technological Advances 24-2
Emission-Data Vehicle/Testing (See Testing, Emission Data)
Engines, Shipment to EPA (Heavy-Duty Engines) 22A
Engine Family Determination
Heavy-Duty Engines 20B-1
Light-Duty Vehicle/Light-Duty Truck 20B
Engineering Report, Required 4A-1
Export Requirements 34
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U.S. Environmental OAR/OMS
Protection Agency
A/C NO. Index
PAGE J_ OF
Evaporative Emissions
Carryover Data
Control Systems
Family Determination
Preconditioning
Field Fixes
Freedom of Information
Fuels
Service Accumulation Fuel, Representativeness
Fuel Economy
Car Line and Truck Line Determinations
Guidelines for Data Vehicle Packages
High-Altitude Labels
Label Program
Test Schedules
Testing
Fuel Tank, Test Vehicle Heating
High-Altitude
Fuel Economy Labels
Inertia Weight Class
Inertia Weight Testing Option
Air-Conditioning Usage
17F
59
59
50A
2B/24/41A
66
26B/26B-1
89
77
77
83A
84A
72A/73/77
23A
77/83A
38
53
Laboratory Correlation
52A
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U.S. Environmental OAR/OMS
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A/C MO- Index
PAGE_L_OF
Labeling
California Requirements
Fuel Economy
Maintenance
After Shipment
Before and After Testing
Break-In
Instructions to Ultimate Purchaser
High-Altitude Modifications
Scheduled
Unscheduled
Warning Devices
Warranty Statement in Owner's Manual
Mileage Accumulation (See Also Service Accumulation)
Alternative Mileage Accumulation Procedures
Fuel
Outdoor Chassis Dynamometer
Transport to EPA
Manufacturers, Small-Volume
Model Year
Modification of Certified Vehicles
83A
83A
4A-1, 12A
23A
12A
12A/15A/38
15A, 24
ISA
12A, 36B
4A/4A-1/36B
36B
ISA
37A
26-B/26B-1
35B
23A
51C
6B
2B/64
MMT (Methylcyclopentadienyl Manganese Tricarbonyl) 26B/26B-1
Outdoor Chassis Dynamometer, Criteria for Approval
35B
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vxEPA
U.S. Environmental OAR/OMS
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Parameter Adjustments
Preconditioning
Production Period
Public Disclosure of Certification Information
Public Health Assurance
A/C NO. Index
PAGE _8 OF 10
91
50A
6B
66
46/76/76-1
Retesting
California Waivers
Valid and Voided Tests
Road-Load Power
Air-Conditioning
Alternative Procedure for Determination and
Use of Dynamometer Power Absorber Setting
Measurement of Vehicle Frontal Area and
Protuberance
Running Changes
Carryover Data
Defeat Devices (Auxiliary Emission Control
Devices)
General
Testing Schedule
Scheduled Maintenance
Criteria for Approval
Durability Data Vehicles
Emission-Data Vehicle Testing
Warning Devices
84A
84A
53
55C
73
17F
24/24-2
41A
84A
12A
12A
12A
36B
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&EPA
U.S. Environmental OAR/QMS
Protection Agency
A/C NO. Index
PAGE* OF
Service Accumulation
Alternate Schedule
Chassis Dynamometer Approval
Shift Points, Manual Transmission Vehicles
Shipment of Vehicles/Engines
Export Requirements
Heavy-Duty Engine Shipment
Light-Duty Vehicle Shipment
Small-Volume Engine Families, Assigned Deterioration
Factors
Statements of Compliance
Sulfur
Test Equipment
Air-Conditioning Usage
Lab Correlation
Manufacturer Test Sites, Secondary Laboratory
Outdoor Chassis Dynamometer
Use of Equipment Not Specified in Regulations
Test Fuels
Service Accumulation Fuels
37A
35B
26B/26B-1
23A/72A
34
22A
23A
51C
46
26B
53
52A
23A
35B
18
26B/26B-1
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A/C NO. Index
PAGE 10 Of 10
23A
4A-1/12A
84A
17F
17F
72A
38
23A/50A/52A
Testing
After Shipment
Before and After
Confirmatory Testing at EPA Facility
Durability Data
Emission Data
Fuel Economy, Shift Points of Transmissions
inertia Weight Testing Option
Manufacturer Test Site
Preconditioning 50A
Retesting
California Waivers 84A
Valid and Voided Tests 84A
Scheduling of Tests 84A
Shift Point of Manual Transmissions 72A
Vehicle Requirements 23A
Trade Secrets 66
Truck Line (See Car Line and Truck Line Determination)
Unscheduled Maintenance 4A-1
Warning Devices 36B
Vehicle Shipment/Preparation/Shipment (General) 22A/23A
Preconditioning Prior to Testing by Manufacturer 50A
Warning Devices
Warranty Statement
36B
ISA
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&EPA
United States
Environmental Protection
Agency
Office of
Air and Radiation
Washington. DC 20460
A/C Table of Contents
December 31, 1987
1 of 4
QMS
Advisory Circular
TABLE OP CONTENTS
Circular
Number Title
1A Introduction of Advisory
Circular System
2B Field Fixes Related to Emission
Control-Related Components
4A Unscheduled Maintenance
4A-1 Unscheduled Maintenance
6B Duration of Certificates of
Conformity, Production Period,
and Model Year
12A Break-In and Other Scheduled
Maintenance
15A EPA Review and Approval of
Maintenance Instructions of 1975
and Later Model Light-Duty Vehicles
and Heavy-Duty Engines
17F General Criteria for the Carryover
and Carry-Across of Certification
Data and the Carryover of Fuel
Economy Data for Light-Duty Vehicles
and Light-Duty Trucks
18 Approval of Use of Instruments Other
than Those Specified in the Motor
Vehicle Emission Control Regulations
20B Determination of Engine Families and
Classification of Emission Control
Systems for Heavy-Duty Engines
Date of
Issuance
February 27, 1978
March 17, 1975
November 14,1972
December 14,1973
December 31, 1987
April 2, 1974
July 30, 1974
November 16, 1982
September 7, 1972
June 27,1974
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PAGE_2_OF4-
20B-1 Determination of Engine Families and
Classification of Emission Control
Systems for Heavy-Duty Engines
22A Shipment of Heavy-Duty Engines to
EPA for Testing
23A Shipment of Light-Duty Vehicles and
Trucks to EPA for Testing
24 Prohibition of Use of Emission
Control Defeat Devices
24-2 Prohibition of Emission, Control
Defeat Devices - Optional Objective
Criteria
26B Representativeness of Unleaded
Service Accumulation Fuels
26B-1 Representativeness of Unleaded
Mileage Accumulation Fuels
34 Export Requirements for Light-Duty
Vehicles and Heavy-Duty Engines
35B Criteria for Approval of Use of an
Outdoor Chassis Dynamometer for
Mileage Accumulation
36B Warning Devices for Emission
Control System Maintenance
37A Alternate Mileage Accumulation
Procedure
38 Inertia Weight Testing Option -
Relationship to Coverage of
Certificate of Conformity
41A Changes to Vehicle or Engine Covered
by Certificate (Running Change)
September 20,1974
April 3, 1973
July 5, 1978
December 11, 1972
December 6, 1978
January 7, 1977
August 12, 1977
November 2, 1973
April 30, 1982
October 25, 1982
July 22, 1975
February 15, 1974
March 24, 1975
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PAGE_L_OF «
45 Appeals Procedure on Administrative
Rulings
46 Qualification by Manufacturers
of Statement of Compliance
50A Test Vehicle Preconditioning
51C Assigned Deterioration Factors
for 1988 Model Year Light-Duty
Trucks and Heavy-Duty Engines
52A EPA MVEL Laboratory Correlation
53 Air-Conditioning Usage
55C Determination and Use of Alternative
Dynamometer Power Absorber Setting
59 Determination of Evaporative
Emission Families and
Evaporative Control Systems
64 Certificates of Conformity for
Certified Vehicles Modified
Subsequent to Original Manufacture
66 Public Access to Applications
for Certification
72A Shift Points for Manual Transmission
Test Vehicles
73 Measurement of Vehicle Frontal
Area and Protuberance
76 Compliance with the Requirements
of §202(a)(4) and §206(a)(3)
of the Clean Air Act
76-1 Compliance with the Requirements
of §202(a)(4) and §206(a)(3)
of the Clean Air Act
77 Guidelines for Submission of Fuel
Economy Data Vehicle Packages
May 12, 1975
June 12, 1975
December 16, 1976
December 4, 1986
May 1, 1987
December 31, 1975
December 12, 1986
August 31, 1976
March 7, 1977
May 17, 1977
February 10, 1984
March 15, 1978
June 28, 1978
November 30, 1978
September 1, 1978
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•8-EPA
U.S. Environmental
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OAR/OMS
A/C MO. Contents-
PAGE _i_ OF ±
83A Policies Applicable to the Fuel
Economy Labeling and Compliance
Program
84A EPA Confirmatory Testing of Light-
Duty Vehicles and Light-Duty Trucks
86 Federal Certification Based on
California Certification
89 General Criteria for Making
Car Line and Truck Line
Determination
91 Parameter Adjustment
92 Application Formats for
Certification of 1982 Model Year
Light-Duty Motor Vehicle
July 6, 1984
July 29, 1983
July 17, 1979
December 14, 1979
February 8, 1980
September 23, 1980
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un.»H<:.*». n« « Deletions
United States Office of r»l___j~~ 11
Environmental Protection Air and Radiation December JJ-f
Agency Wein.ngtan. DC 20460 Page 1 of 3
v>EPA QMS
Advisory Circular
ADVISORY CIRCULAR DELETIONS
A/C No. Deletions to the Table of Contents
11 Importation of Certification Test Vehicles;
Approval of Operation on the Public Roads.
This A/C was adopted on May 5, 1972; it has been
superseded by 40 CFR 85.1701, et seq.
16 Approval of Emission Control Modifications for High
Altitudes on New Motor Vehicles or Engines.
This A/C was issued on June 8~,1972. Subsequently
there have been two Clean Air Act revisions, 1974
and 1977, as well as numerous regulation changes.
This A/C has been completely superseded by the
subsequent high-altitude rulemaking; Subpart Q of
Part 86 (Altitude Performance Adjustments) issued in
1980.
19B "Zero Miles."
The requirement for a zero mile test was deleted
many years ago; there are no continuing zero mile
requirements.
24-1 Modifications to High-Altitude Vehicles for
Temporary Operation at Low Altitudes; Prohibition of
Use of Emission Control Defeat Devices.
This A/C, issued August 27, 1976, expands upon A/C
No. 24 issued December 11, 1972 prohibiting the use
of defeat devices. It is directed at altitude
adjustment devices or maintenance instructions for
modifying vehicles for low altitude operation. This
A/C has been superseded by the subsequent Clean Air
Act amendments and high-altitude regulations.
25 Quarterly Production Reports.
Quarterly Production Reports are no longer required
under our regulations.
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&EPA
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A/C NO. deletions
PAGE 20F_3
27
Public Release
of
Information Contained in
Applications for Certification
of
Light-Duty
vehicles and Heavy-Duty Engines.
This A/C, issued March 19, 1973, contains an
outdated fee schedule and does not reflect changes
in the Freedom of Information regulations in the
past several years.
29-1 Emission Testing of Certification Vehicles.
This A/C is concerned with testing prior to the
"zero mile" test as well as other emission tests
performed during the life of an emission data or
durability vehicle. Our regulations have been
amended to allow manufacturers more flexibility in
how they conduct their test programs.
30A
Use of Unleaded Fuel in Noncatalyst Equipped
Vehicles.
Published on March 24, 1975, this A/C prohibited
manufacturers from gaining an advantage by using
unleaded fuel in test vehicles representing pro-
duction vehicles which would use leaded fuel. Our
fuels regulations, 40 CFR 80.24, were subsequently
amended to accomplish the same result.
32B/32B1 Compliance with Fuel Requirements
of
Lead
Regulations Regarding Unleaded Fuel.
These two A/C's were published shortly after
vehicles requiring unleaded fuel were available.
They add very little to the labeling and immediate
shut off requirements in 40 CFR 80.24.
60
EPA Leaded Gasoline Test Fuels.
Adopted on November 15, 1976, this A/C describes a
change in EPA test fuel. Applicable regulations
were subsequently adopted.
71/71-1 Criterion for Obtaining Exemption from Running
Change Fuel Economy Data Requirements.
These A/C's, adopted December 22, 1977 and April 11,
1979 have been superseded by subsequent fuel economy
regulations.
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74 Adjustment of Governors on Gasoline Fueled
Heavy-Duty Certification Engines."
This A/C concerns the effect of engine governors on
the heavy-duty durability cycle. Since there is no
longer a specified durability procedure and manufac-
turers develop their own deterioration factors, this
A/C is no longer necessary.
78 1979 Model Year Fuel Economy Labeling Program.
This A/C has been superseded by the subsequent
regulations and by A/C No. 83A.
80 Altitude Performance Adjustments for Vehicles In Use.
This A/C was adopted December 8, 1978 and deals with
voluntary submissions to EPA of high-altitude adjust-
ments under section 215 of the amended Clean Air Act.
This, by its own statement, was an interim A/C and
was superseded by Subpart Q of Part 85, which was
adopted on October 8, 1980.
35 1980 Model Year Fuel Economy Label Format.
Thelatestfueleconomy regulationprovided new
requirements for label formats; this A/C has been
entirely superseded.
87 Guidelines for Submitting Supplemental Running Change
Fuel Economy Data.
This A/C was adopted 'September 11, 1979. As with
other fuel economy A/C's, this A/C has been super-
seded by the subsequent fuel economy regulation
changes.
90 Guidelines for the Submission of Preliminary
Corporate Average Fuel Economy Report.
The PCAFE report has been eliminated.
9292a
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