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UNITED
STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
oOo
PUBLIC HEARING
on
CALIFORNIA WAIVER REQUEST
May 16 - May 20, 1977
Conference Rooms A-B-C
EPA REGION IX Office
San Francisco, California
VOLUME II
Pages 213 - 333
May 17, 1977
Reported by:
RICHARD S. ADAMS
5 R. WILSON
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19290
HEARING PANEL
BENJAMIN R. JACKSON - Presiding Officer
Director, Mobile Source Enforcement Division
U.S. Environmental Protection Agency
Washington, D.C.
CHARLES GRAY
Chief, Standards Development and Support Branch
U.S. Environmental Protection Agency
Washington, D.C.
MICK LIEFERMAN
Mechanical Engineer
U.S. Environmental Protection Agency
Washington, D.C.
EPA STAFF
DANIEL M. STEINWAY
Attorney-Advisor
U.S. Environmental Protection Agency
Washington, D.C.
JAMES McNAB, III
Attorney-Advisor
U.S. Environmental Protection Agency
Washington, D.C.
MARILYN J. HERMAN
Program Analyst
U.S. Environmental Protection Agency
Washington, D.C.
oOo
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215
I_ N D E X Page
CALIFORNIA AIR RESOURCES BOARD 216
THOMAS AUSTIN
Deputy Executive Officer, Technical
KINGSLEY MACOMBER
Chief Counsel
DONALD DRACHAND
Chief, Engineering Branch
GARY RUBENSTEIN
Manager, Special Projects Section
GENERAL MOTORS CORPORATION 225
EDWIN E. NELSON
Assistant Director of Automotive
Emission Control
RICHARD I. PETERSEN
Attorney
HAROLD W. SCHWOCHERT
Staff Engineer, Automotive Emission Control
MR. HANSON
Staff Engineer, Chevrolet Motor Car Division
FORD MOTOR COMPANY 286
DONALD R. BUIST
Executive Engineer for Certification
Engineering and Testing Laboratory
JOHN P. EPPEL
Associate Counsel
AMERICAN MOTOR CORPORATION 312
WILLIAM C; JONES
Manager, Emissions and Energy Standards
oOo
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CARB
216
TUESDAY, MAY 17," 1977 10:00 O'CLOCK A.M.
oOo
CHAIRMAN JACKSON: Are you ready, gentlemen?
MR. AUSTIN: Shall we proceed?
CHAIRMAN JACKSON: Yes.
MR. AUSTIN: For the record, I am Tom Austin,
Deputy Executive Officer for the California Air Resources
Board. With me today are Mr. Macomber, our Chief Counsel;
Mr. Drachand and Gary Rubenstein from the Vehicle Emission
Control Division.
My comments this morning are on the subject of
the evaporative emission standards and test procedures for
1980 and subsequent model year light-duty and heavy-duty
vehicles for which we have requested waiver.
The two gram evaporative emission standard which
the board adopted for 1980 and subsequent model year light-
duty and heavy-duty vehicles uses test procedures similar
to EPA's own procedures for 1978, and is identical to the
procedure previously waived by the Administrator in his decisii
on California's six gram per test standard.
The ARB procedure incorporates a one gram background
allowance that applies only to emission data vehicles, and
is based on data submitted by vehicle manufacturers which
indicated that the background emissions of typical 4,000 mile
data vehicles were approximately one gram higher than
sabilized background emission levels.
Since background emissions remain relatively
constant after 90 days, the test procedure requires
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CARB
durability data vehicles to be aged the equivalent of at
least 90 days before starting mileage accumulation so that the
deterioration factor will be independent of background
emissions.
The ARB's background allowance will decrease the
lead time required to meet a two gram standard by eliminating
the necessity for manufacturers to bake or artificially
stabilize background emissions on hundreds of test cars and
will increase the standards feasibility, while still provid-
ing the desired degree of control.
The allowance for background evaporative emissions
is consistent with EPA regulations in that it does not require
any additional testing by either the manufacturers or EPA.
Although this allowance might be interpreted as providing
less stringency than a two gram standard without an
allowance, it is clearly more stringent than EPA's six gram
standard, and consequently satisfies the stringency require-
ment for a waiver.
On October 7th and 8th, 1976, ARB scheduled a
workshop with vehicle manufacturers to discuss the feasibility
of the two gram standard and the lead time required to meet
it.
Daimler-Benz stated that its fuel injection vehicles
could probably meet a two gram standard by 1980. In addition,
manufacturers such as Chrysler, who plan to install electric
fuel metering systems on their 1980 vehicles, should achieve
similar evaporative emission characteristics, since electronic
fuel metering systems do not use a carburetor float bowl.
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CARB
218
Other manufacturers such as Ford and American
Motors argued that a background allowance was needed to make
the two gram standard feasible.
I would like to add a point of clarification here.
I believe Ford did specifically state that with a one gram
background allowance they believe they could comply with the
two gram standard. AMC, however, I do not believe made
that same claim.
At a subsequent public hearing on November 23rd,
1976, Ford indicated that it could achieve a three gram
evaporative emission standard with no background allowance
on their carbureted vehicles.
In a study conducted for EPA, Exxon Research and
Engineering Company modified six 1974 and 1975' model year-vehicles
to demonstrate the feasibility of the two gram standard.
Evaporative emissions due to air cleaner overflow,
canister overflow and carburetor leaks were substantially
reduced by modifications such as venting the carburetor bowl
to the carbon canister, using a fan to lower the hot soak
temperature, increasing the canister size, increasing the
purge rate, closing the bottom of the canister to preclude
seepage, and sealing the carburetor and accelerator pump
shafts to prevent leakage.
Average evaporative emissions for six vehicles was
1.5 grams, v.with no vehicle higher than 1.9 grams.
The cost of these modifications range from a minimum
of two dollars to a maximum of twenty-five dollars per car.
Many of the changes made by Exxon are simply
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CARB 219
extensions of methods already in use and are not expected to
present any durability problems to manufacturers who have
more than two years of lead time.
We have compiled a list shown at Table 1 of the
prepared statement of six 1978 durability vehicles whose
average emission shows that systems currently exist which can
meet the two gram standard. Most of these systems use a
large carbon canister and incorporate an external carburetor
bowl vent and/or have fuel injection.
Ford Motor Company can certify one engine family
which meets the two gram standard without the background
allowance. Toyota, Volkswagen and General Motors have
durability vehicles whose average emissions are comfortably
below the two gram per test.
We expect that even more manufacturers will
demonstrate these low levels as the 1978 certification program
progresses.
Another list shown on Table 2 is of 1978 engine
families which could probably comply with the two gram
standard with certain modifications. These vehicles, emitting
between two and three grams, may be brought into compliance
by providing adequate sealing around the carburetor and
accelerator pump shafts. This is supported by the Exxon
report which concluded that carburetor leakage represents
the second most significant source of evaporative emissions
after air cleaner overflow.
As we have mentioned before, we do not believe that
the cost/effectiveness of the ARB control programs is a proper
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CARB 220
subject for consideration at waiver hearings. Since the ques-
tion is so often raised, however, we will address it at this
time.
Our estimates indicate that the emission reductions due
to the two gram evaporative emission standard would cost
about 41 cents per pound. Calculations and assumptions behind
this figure can be found in the ARB November 23rd, 1976
staff report.
Just for the record, that 41 cents per pound figure
is substantially lower than many other both stationary and
mobile source control programs in other words, that we
see the two gram evaporative standard as being one of our
more cost/effective hydrocarbon control programs.
Besides being cost/effective, the new standards will
result in a hydrocarbon reduction of 15 3 tons per day within
the South Goast Air Basin. This represents a 38 percent
reduction in hydrocarbon emissions from motor vehicles and
a nine percent reduction in hydrocarbon emissions from all
sources.
In conclusion, we believe the two gram evaporative
standard is technologically feasible within the lead time
remaining; that the Administrator must therefore grant ::
California a wstiver to implement this standard.
Thank you. I would be happy to answer any questions
on this issue.
Mr. Jackson, perhaps before we get some questions on
one particular area, I should offer a point of clarification.
There has been some concern expressed to us recently regarding
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CARB
221
the way we intend to interpret our two gram evap standard
as it applies to heavy-duty vehicles.
Ford Motor Company has submitted to us a proposed
method for determining the compliance with our standard on
heavy-duty vehicles. It consists of running a SHED test of
the evaporative control system itself, removed from the
vehicle, while it is going through a typical cycling as it
would during actual vehicle operation.
Ford is concerned as are other manufacturers that
if the entire vehicle must be tested, that background emissions
from such a large vehicle may make it impossible to meet
the two gram standard, even with a one gram background
allowance.
We have decided that Ford's recommended approach
for certifying heavy-duty evaporative control systems is
acceptable to the Air Resources Board. We will be sending
an advisory circular to that effect before the close of the
hearing record.
We are also planning to amend our procedures in
the future to write that advisory circular into law, in
effect, to make it clear that we are attempting to achieve
control over heavy-duty vehicles that gives us essentially
the same degree of control that the two gram standard would
achieve on a passenger vehicle. This will clarify our intent
and make it clear that we will not be requiring full SHED
tests of completed heavy-duty vehicles equipped with evaporativi
control systems.
Basically what we are looking for is to see systems
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CARB 222
installed in heavy-duty vehicles that provide essentially the
same degree of control as two gram systems installed on
passenger cars, and we have already accepted Ford's approach
to demonstrating that compliance. We will be issuing the
advisory circular and will submit that for the record.
MR. GRAY: You made the statement that the ARB's
background allowance will decrease the lead time required
to meet a two gram standard by eliminating the necessity for
manufacturers to bake or artificially stabilize background
emissions,will not increase the standards feasibility, and
yet still provide the desired degree of control.
Do you expect the background emissions to be such
that the fuel emissions will be below two grams per test?
MR. AUSTIN: I do not understand the question.
MR. GRAY: Do you expect the manufacturers to not
take advantage of that situation and still stabilize the
background emissions on their data cars, their test cars?
MR. AUSTIN: They may be able to get away with
doing that. However, we will be requiring the durability
vehicle to run about; 50,000 miles without any background
allowance. That should give us some pretty good indication
of the capabilities of the evap control system. We will not
allow the durability vehicle to start until it has been aged
either 90 days or the equivalent of 90 days. Given that fact,
we should be reasonably confident in the capabilities of the
system based on the durability of vehicle test. It is
conceivable, if I understand the thrust of your question
it is conceivable that manufacturers may go to great lengths to
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CARB
223
lower the background emissions from emission data vehicle,
still take credit for the one gram background allowance, in
order to minimize his risk when he is going through the
data vehicle certification process. That is a possibility.
It is something I guess we are prepared to live with.
MR. LIEFERMAN: You state some costs here for
implementing this regulation. You are stating a cost of
about 41 cents per pound of hydrocarbons reduced. Do you
know what the cost per vehicle that is calculated from
you mentioned, the cost on the Exxon vehicles was from two to
twenty-five dollars per vehicle
MR. RUBENSTEIN: The 41 cents a pound is assuming
the maximum of $25 per vehicle.
MR. LIEFERMAN: So anything that would cost less
than $25 per vehicle would reduce that 41-cent figure?
MR. RUBENSTEIN: Proportionately, correct.
MR. LIEFERMAN: Thank you.
MR. GRAY: I have one last question. You also
made the statement that Ford recently indicated they could
achieve a three gram hydrocarbon evaporative emission standard
with no background allowance. Could you expand upon that a
bit? How did they actually present information that would
indicate that that level could be achieved without any back-
ground allowance? Did they separate the background and the
test program?
MR. AUSTIN: Gary, you can correct me if I am wrong,
but I think we are referencing statements that Ford Motor
Company, Mr. Jensen, I believe, made at our board meeting when
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CARB
224
we decided to go with the one gram background allowance. I
believe in his testimony, Mr. Jensen's testimony, he indicated
that because of the problems with background, the best Ford
could do would be three grams. We then got into a discussion
whether it would make a significant difference to Ford whether
the standard was three grams or the standard was two grams
with one gram background allowance. And Ford's position was
that since their primary concern was over the background
problem on data vehicles, that they could live with the three
gram standard. Is that your understanding?
MR. RUBENSTEIN: Right. I believe that is correct.
MR. GRAY: The way I would interpret the statement
Ford has said they could meet a four gram standard with an
allowance or with background included. If you subtracted
out background it could only meet three grams. I am wondering
if this is
MR. AUSTIN: No, that .is not the propdr interpreta-
tion.
MR. DRACHAND: I think what he said is, including
background they can meet a standard of three grams per test,
which includes fuel evap emissions and background emissions.
MR. GRAY: No background allowance means that the
background would be included in the test?
MR. DRACHAN: Correct.
MR. AUSTIN: Correct.
CHAIRMAN JACKSON: Just for a point of clarification.
Your regs apparently indicate that the one gram allowance
for background will apply to '78 and '79 on its face. Is that
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CARB/GM 225
what you intend, or is that an error or what?
MR. RUBENSTEIN: It was an oversight in drafting.
We don't expect it will be applied, and that position hasn't
been waived by EPA for 1978 or '79, so it could not in fact
be applied.
CHAIRMAN JACKSON: But you are not asking for a
waiver, and you do not intend to ask for a waiver for that?
MR. AUSTIN: I understand the question now. That
is correct. We are not asking for a waiver that would allow
us to apply a one gram background allowance to 1978 or '79
vehicles.
CHAIRMAN JACKSON: As I understand it, for these
model year vehicles, you have to do both the bench test for
durability and the actual durability?
MR. RUBENSTEIN: That is correct.
CHAIRMAN JACKSON: There won't be any kind of
application of any kind of factor for the bench test, I
assume?
MR. RUBENSTEIN: No. The bench test is part of
the -durability procedure, and the durability procedure does
not have any background correction factor.
CHAIRMAN JACKSON: Thank you, Mr. Austin.
MR. NELSON: Mr. Jackson, I am Ed Nelson, Assistant
Director of Automotive Emission Control, General Motors
Environmental Activities Staff. With me today again are
Mr. Petersen and Mr. Schwochert, and, in addition, we have
Mr. Hanson, a staff engineer from the Chevrolet Motor Car
Division.
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GM
226
At this time I would like to have Mr. Schwochert read
the prepared statement.
MR. SCHWOCHERT: General Motors appreciates the
opportunity to comment on the question of California's
request for a waiver to impose, in 1980, a two gram test
evaporative emission standard using the SHED measurement
technique. In a number of communications with EPA since early
last year, we have explained our belief that, insofar as
automotive emissions are concerned, evaporative control is
inexpensive hydrocarbon control up to some point. Also,
we have stated our belief that control to some level below
the 1978 standard of six grams per test appears, with
present knowledge, to be feasible. We have noted the desir-
ability of withholding judgment on the precise definition of
that level of feasibility until experience with certification,
production and at least limited field use of cars certified
to the six gram per test SHED standard is in hand.
Consistent with the foregoing and reinforced with
our recent experience both with certification to the six gram
per test level and developmental attempts to achieve
substantially lower levels, it is recommended that EPA establisl
approximately one year from now, a national automotive
evaporative emission standard and test procedure for 1981
at the level which available technology will allow with consid-
eration given to cost-benefit. We believe it is clear that
technological feasibility for the two gram per test standard
has not been demonstrated.
We further believe that California must demonstrate
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GM
227
technological feasibility before waiver can be granted.
As 1978 certification now approaches completion,
we will be able to devote increasing attention to lower
evaporative emission levels. The knowledge gained from the
experience of 1978 certification and production should allow
EPA to make a better judgment on the level for a more
stringent evaporative emission standard for passenger cars.
We would hope and expect that within that period
of time the questions of test procedure which we believe still
exist, including durability demonstration and high altitute
requirements could be resolved.
In its technical support for the establishment of
the 1980 two gram per test standard, California stated that
feasibility had been established by an Exxon program run for
the Environmental Protection Agency. It was stated that the
six vehicles modified by Exxon averaged 1.5 grams per test
with no vehicle higher than 1.9 grams per test.
Our study of the report shows one of the three tests
of the Pontiac car at 2.5 grams, one of two tests of the
second Chrysler car at two grams, and the initial Chrysler
car showed measurements of 2.1 and 2.5 grams per test at
the best configuration. While it was implied that the
additional modifications made to the second Chrysler car
would have achieved the two or 1.9 grams per test level on
the first car, there was no demonstration of that assumption
described.
We pointed out in our March 18, 1976 response to
the Environmental Protection Agency's two gram notice of
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QM
228
proposed rule making that the existing data showed test
variability to be very large relative to such a standard
on the order of .89 grams standard deviation, about 2.11 gram
mean on a two barrel Vega test car program. We estimated
that, on the basis of test variability alone, a one gram per
test design target was necessary to provide reasonable
confidence that a system could be certified to a two gram
standard. Our experience since that time has not altered
that conclusion significantly.
We must respectfully reject the conclusion that
average measurements below two grams per test from the six
experimentally modified cars demonstrates feasibility.
As an example of the test variability problem,
which includes test-to-test, site-to-site, car-to-car and lab-
to-lab variability, the comparative data of Tables 1 and 2
show that there is currently an "offset" between two
industry laboratories and the EPA-Ann Arbor laboratory of
nine to sixty-eight percent. Even at the low end of that off-
set range, three of the thirteen tests of the six Exxon cars
in thei£ final configuration would have failed a two gram
standard assuming Exxon measurements were comparable to
the two industry laboratories.
At the upper end of that offset range, ten of the
thirteen tests would have been failures. In other words,
if we had applied this offset we would have seen more failures
than is indicated by the Exxon data, and probably someplace
between three and ten of the thirteen tests could have been
considered to be exceeding the two grams.
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GM
229
Another recent example of test variability is
provided by the data from a GM practice test which shows
large variations in deteriogaLtiion factors as defined by the
1977 regulations of identical experimental cars, with no
apparent reason except test variability.
In addition to the test variability question, it is
important to note that the Exxon program involved a number
of test procedure differences from currently established
regulations by both EPA and California. All of these
procedural differences of which we are aware acted to produce
lower evaporative emissions in the Exxon program.
Examples include additional preconditioning
operation/ a cooling fan system which provided lower fuel
tank temperatures, preconditioning with "weathered" test
fuel and for at least one car in its final configuration
artificial purging of the caninster.
As the Exxon report pointed out, there was no
assessment of the durability characteristics of the
modifications evaluated. That omission was acknowledged
in the California support document, but the belief was none-
theless expressed that "most manufacturers" could still meet
the two gram per test standard by 1980. It is our conclusion
that "belief" should not constitute a demonstration of
technological feasibility.
It is well to point out here that the expected
benefit from a two gram standard, if it could be achieved,
is less than half that estimated by California. To explain,
we concur with the estimate of .7 grams per mile as
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GM 230
"equivalent" to the six gram per test standard. We do not
agree with the California estimate of .15 grams per mile as
"equivalent" to the two gram per test level in its implied
distribution of the emissions between the diurnal and hot
soak test phases assuming this "equivalent" is based on
precise achievement of a two gram standard. A realistic
distribution of .5 grams to the diurnal and 1.5 grams to the
hot soak yields a 2.2 gram per mile equivalence. In addition,
our current certification experience suggest that the 1978
certification level will be much closer to the three grams per
test and than the six grams per test standard that is,
.32 grams per mile equivalent.
While it may not be possible to make a precise
estimate of 1978 production car emission levels from such
preliminary data, we believe that the actual improvement which
would result from a two gram per test standard would be
less than half the California estimate of .55 gallons per
mile.
Current data from our 1978 certification program
support our continued confidence that some evaporative
standard level below six grams is feasible although two
of the "data cars" need improvement to the six gram level.
It should be kept in mind, however, that these are
demonstration cars whose emission control performance levels
should provide a reasonable margin below the standard. Also,
the ultimate criteria, for certification purposes, of pass/
fail against the established standard is the EPA laboratory,
and the previously mentioned offset should be added to these
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GM 231
data when judging the ability to achieve a lower standard.
While these data do support confidence that a standard below
six grams may be feasible, they clearly indicate that a
realistic target for a two gram standard has not yet been
achieved except possibly for two or three individual cars.
Much has been learned in the development work and the
certification effort for the.1978 standard. As indicated in
our last annual report to EPA, for example, the application
of carburetor bowl-to-canister vent lines in a number of
cases severely aggravated fuel tank or diurnal emissions,
a source which had previously been believed to be under
excellent control. We believe that the possibility of high
diurnal emissions has been solved with subsequent development
work. More experience will be gained within the next few
months as production begins and studies are performed to
assess the evaporative control capabilities of the production
cars.
As we have previously indicated to both EPA and the
California ARB, our efforts in evaporative emission control
development have been concentrated on achievement of the
1978 standard. The difficulty of this task was even greater
than anticipated as a result of the requirement for achieve-
ment at high altitude with the present fuel volatility
specification. Nonetheless, in recent months as the
certification effort winds down, we have been able to devote
increasing effort to the pursuit of a lower level of
evaporative emissions. These efforts have, as in the past,
concentrated on further reducing the hot soak losses from the
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carburetor and evaluating the need for added vapor storage
capacity.
We have previously indicated to EPA our intent
to apply an accelerator pump seal to one type of carburetor
for 1978. In that particular application, the seal reduced
hot soak emissions by one to two grams. Since in this case
the application of a seal to that particular leak source
constituted a "fix" of what might be considered an excessive
leak, we expect lesser improvements from application of the
same "fix" to a vehicle already operating at relatively
low hot soak emission levels. Our experience has shown this
to be the case. At lower levels of hot soak emissions,
recent development work has indicated that such seals appear
to reduce hot soak emissions by a much lower on the order
of .25 grams but still, at least on some carburetors, a
measurement amount. Our certification and production
experience with the seal being applied to the 1978 carburetor
will provide some better insight into pursuing that approach
for improved evaporative emission control.
Another approach which appears to show some
promise of a modest incremental improvement at low levels of
hot soak emissions is the addition of charcoal to the air
cleaner. As indicated in our March, 1976 submission, that
particular approach was evaluated a number of years ago.
Its current reevaluation is based on the concept that the
carbon air cleaner would be used in addition to the carbon
canister vapor storage device rather than an alternative to
it. The experimental charcoal air clearner units thus far
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evaluated have shown modest reductions at low levels of hot
soak emissions. We have thus far been able to hold air
flow restrictions to relatively low levels. The resultant
power losses still represent an area of concern. In addition,
the related questions of durability, safety and field
maintenance have not been investigated.
While it is not clear that there will be a general
need for increased vapor storage capacity in the canister
beyond that being incorporated in the 1978 system larger
canisters are being evaluated,and a first design has been
completed and engineering samples will soon be available for
evaluation.
We expect that certain vehicles, particularly for
high altitude, may require multiple canisters, even for
1978.
We believe the issue of non-fuel background
emissions is not adequately addressed by the California
regulation being considered. This becomes more important
for a control level below the 1978 six gram per test standard.
The one gram per test allowance provided by California for
the "Certification Data Cars" is appropriate and consistent
with recommendations we have made in the past. No allowance
is provided for the Durability Test Cars at any age or
mileage accumulation. Yet the regulation would require that
the interpolated emissions from the Durability Cars be under
the two gram standard at both 50,000 and 4,000 miles. There-
fore, the background emission treatment requires better
resolution before a lower standard is established.
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As EPA considers the evidence presented in the
matter of this waiver, the special problem of evaporative
emission control at high altitude should be reviewed. As we
interpret the California regulations, the 1980 standard at
issue here would not apply to high altitude areas, and we
are planning accordingly. Our recent experience shows that a
standard based on evaporative control capability near sea level
may not apply to similar emission control at high altitude.
As previously suggested, we believe this is one of the
procedural areas which should be resolved before a new
evaporative, control standard is established.
Another area of concern is the question of
evaporative control for trucks. The 1980 California regula-
tions being considered would apply the same standard to
light-.and medium-duty trucks as to passenger cars. The
passenger car test results used to justify the two gram per
test standard do not relate directly to control of truck
evaporative, emissions. It is well established that fuel
tank emissions are proportional to fuel tank size,and truck
fuel tanks are substantially larger than passenger car fuel
tanks. Also,the horsepower setting (imposed by the exhaust
emission regulation) for trucks is higher, resulting in
higher engine and exhaust system temperatures aggravating the
problem of carburetor and fuel tank emissions. Additionally,
the configurations of certain truck types, vans, result in
higher engine compartment temperatures.
The issue of technological feasibility of
evaporative emission control for trucks is an issue which has
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not been addressed separately from passenger cars. The court,
in International Harvester versus Ruckelshaus, directed that
truck emission control should not be treated under the
blanket of passenger car requirements. We therefore urge
the EPA and the California ARB to give the earliest possible
consideration to the question of truck evaporative emission
control as a separate issue.
General Motors believes the feasibility of the 1980
California two gram per test evaporative emission standard
has not been established. We recommend that EPA establish,
in approximately 12 months, a uniform national evaporative
standard for 1981 at a level determined by the additional
knowledge and experience obtained from the 1978 program.
Finally, we believe that truck evaporative emission standards
should be treated separately.
Thank you.
Mr. Jackson, for the record we would also like to
enter several documents. I will indicate briefly what
these documents are, and pass them on to Ms. Herman. Is
that satisfactory?
CHAIRMAN JACKSON: Yes.
MR. SCHWOCHERT: The first document is General
Motors' response to EPA proposed evaporative emission
standards and test procedures dated February 27th, 1976.
The next document is GM's response to proposed
EPA evap emission standards and test procedures, a supplement
to the first report. It specifically addresses the two gram
standard. That is dated March 18, 1976.
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GM 236
The third document is a letter from General Motors,
Mr. T. M. Fisher to Mr. John P. DeCaney, dated October 19th,
1976.
Another letter from General Motors, Mr. Tom Fisher,
to Mr. John P. DeCaney, dated February 2nd, 1977.
And, finally, General Motors' statement to the
California Air Resources Board when they adopted the present
proposed two gram standard. That is dated November 23rd,
1976. And, of course, the appropriate section that talks
about that standard, we would like to have as part of this
record.
This statement also addresses some subjects we will
be talking about tomorrow, and we would like to>make that part
of tomorrow's record, the specific sections that deal with
those subjects.
Thank you.
MR. GRAY: Let me ask a question of the positive
aspects of your testimony first, if I might. That deals
with your recommendation that the EPA establish approximately
one year from now a national automotive evaporative emission
standard, a test procedure for 1981, at a level which
available technology will allow, with consideration given
to cost-benefit.
What is your current best judgment as to what that
level should be?
MR. SCHWOCHERT: At this time I would like to reserve
that best judgment, because we have programs set up to monitor
the evaporative levels of production cars once we start
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production, and we would like to see what those levels are
relative to the certification levels.
MR. GRAY: So it may very well be below two grams?
MR. SCHWOCHERT: It is possible that it could be
below two grams. I would not expect it to be below two
grams based on our present experience, but it could be.
MR. GRAY: I wanted to ask some comments on your
testimony regarding the study conducted by Exxon for the
Environmental Protection Agency, and I would offer you to
respond to those points, because they are points to mainly
clarify what you have said to put it in the proper context.
First, you refer to one of three- tests on a
Pontiac car that measured 2.5 grams. I think it is fair to
point out that that test was the only test out of the final
15 tests that was above two grams. It appears that since
you have studied the Exxon report you also concur with this
judgment, that since those three tests had high diurnal
emissions, that the feasibility for even more significant
controls was certainly there, and, in fact, as a result of
that observation on our part, the Exxon Corporation replaced
the existing canister with a Vega canister and Vega purge
system, and that two additional tests were run. These tests
were 1.52 grains per test and 1.75, and, .of course, including
background measurements.
I might also add that the purpose of that study was
I think clearly expressed in the report, and that was to,
among other things, provide a preliminary investigation of
the difficulty of achieving the two gram level. In fact,
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Exxon's responsibility was to achieve a two gram level and
then stop. There was essentially to be no optimization
beyond that level, even though in many cases it was felt
additional control could be achieved.
I might add that, for example, with the Pontiac
vehicle, that the fixes incorporated on that vehicle amounted
to a cost increase of about $2.30, and about half of that
was to get the vehicle from the base line level of about
ten to eleven grams per test, as I recall, to six grams. So
the added cost of getting the vehicle from six grams to below
two grams was about $1.10, $1.20. And that seemed to be more
typical of the kinds of technology which appear to be adequate
9
in that program.
Commenting on the statement you made regarding the
Chrysler car, the Chrysler car appeared to be the more
difficult car in that test program. It was a large engine;
the engine compartment was very hot and resulted in high hot
soak emissions. The initial car that you referred to wherein
the Exxon tests were only able to get to 2.1 and 2.5 grams per
test at the best configuration is a bit misleading in that
Exxon was only able to try a few things on that vehicle before
they were facing some legal action to return that vehicle.
It was a loan or a leased vehicle, and they had no opportunity
to provide anything except a very preliminary effort to reduce
those emissions. Because of that reason they subsequently
obtained a second Chrysler of a similar configuration and
did some additional work, and, of course, did bring that
vehicle to below two grains. So that is the reason that it
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was implied, that had there been time, the first Chrysler
vehicle could have been brought to the same levels of the
second Chrysler vehicle or lower.
MR. NELSON: Mr. Gray, I have a comment on your
discussion. We are certainly happy to receive additional
explanation, but the statements we have made were based upon
the report as we saw the report published, and did not have
the benefit of additional explanation. I would like to have
the record indicate that statements we have made refer to
the report as it was written.
MR. GRAY: I believe that my statements are simply
a result of my review of the report last night. And I
believe most the information I share with you now and that
is why I offer it to you, to see if you would like to comment
on the validity of those comments. I do not believe that
it is privileged information. I think it is adequately
expressed in the report.
MR. SCHWOCHERT: I guess I would like to ask a
question. You indicated 15 tests, and, as we count them, I
counted 13. Perhaps did you include the two additional
Chrysler tests? If you did, both of those tests did exceed
the
MR. GRAY: No. I included the additional two on
the Pontiac, which were the second go-around on the Pontiac.
MR. SCHWOCHERT: I do not think those data were
part of the report.
MR. LIEFERMAN: It was mentioned in the report that
two tests were run on the Pontiac.
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GM 24 0
MR. SCHWOCHERT; But the data --
MR. LIEFERMAN: With the Vega system it said that
those tests were below two grams. However, I do not believe
that the actual numbers were in the report.
MR. SCHWOCHERT: All right.
MR. GRAY: I think it may be in a footnote to one
of the tables in the report. That is where I found the
numbers last night, to be able to quote them. That table
may not be the same table in the published report, and, if
not, we can clarify that at a later point. But those were
the values on those two tests, and the 15 were just included,
or included those two as well, since those were the last 15
tests in the program.
MR. SCHWOCHERT: I do not think that we said any-
thing in our statement that would conflict with your statement
that says only one test of fifteen exceeded the two gram
standard. I do not think there is anything in our statement
that suggested there:was a conflict there of our interpretation.
We did later on talk about laboratory offset, and, of course,
one can continue to talk about those 15 tests in that same
light if you wanted to, and that changes the situation some-
what.
MR. GRAY: Yes.
MR. LIEFERMAN: I had another question or two on
this Exxon report and some comments that you made in regard
to it. You made one statement that preconditioning, vehicle
preconditioning is done with weathered test fuel. I was wonder-
ing if you were referring to the point that fuel, a fuel drain
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and 40 percent fuel was not done prior to the vehicle
preconditioning? What did you mean by "preconditioning is
done with weathered test fuel," if that was not the thing
you were referring to?
MR. NELSON: I believe the statement refers to
these as separate items. The point was made that additional
preconditioning, over what is normally done, was done in this
case, and fuel was weathered, and, therefore, did not have
the normal volatility for the evaporative emission test, and
therefore would tend to give artificially low emission numbers.
MR. LIEFERMAN: Due to decrease in the reed vapor
pressure of the fuel? How much of a decrease in reed vapor
fuel would you expect due to two or three LA four cycles?
MR. SCHWOCHERT: I do not have an estimate of the
amount, but it is a function, of course, on the temperature
that the fuel has been exposed to in that particular vehicle,
and it certainly is significant, because this is the type of
thing that causes a vehicle to have problems with cold starts I
after it has been operated and allowed to soak.
MR. LIEFERMAN: So you feel that two or three LA
four cycles would result in a significant decrease in reed
vapor pressure in the fuel in the vehicle fuel tank?
MR. SCHWOCHERT: I do not know how we would
quantify "significant," but I would say definitely would have
an effect on reed vapor pressure, tending to lower the reed
vapor pressure for subsequent evaluation.
MR. LIEFERMAN: I talked to John Clark this morning,
in fact, of Exxon, who is the author of this report, and asked
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him what he thought it would, how much it would reduce reed
vapor pressure, and he felt that a tenth or two-tenths of a
PSI might be the maximum expected decrease for that type of
operation.
MR. NELSON: We do not have available today any
definitive data on the subject, but we would be happy to
submit for the record some details of the effect of
volatility of this type of thing.
MR. LIEFERMAN: We would be interested in seeing
data like that.
MR. NELSON: We will submit it.
MR. LIEFERMAN: There were some analysis of the
fuel in the appendix of this report. The fuel is analyzed
during two different parts of the test for reed vapor pressure.
Both of those analyses did show 9.0 reed vapor pressure. If
there was a one- or two-tenths decrease due to this extra
preconditioning, that would give you a fuel of maybe 8.8 PSI.
Now, the federal spec for the test fuel is from 8.7 up to 9.2
PSI, so I think the point I want to bring out is that even
if it did undergo that amount of reduction in reed vapor
pressure which Mr. Clark had estimated, that it would still be
within the reed vapor pressure range of the test fuel
specifications.
MR. NELSON: We cannot guess on that right at this
time, but we will submit for the record exact magnitude of
the change.
MR. LIEFERMAN: One other point. You mention the
cooling fan system provided lower fuel tank temperatures in
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this study as opposed to, I presume, the standard emissions
testing. Could you give me the details on why that cooling
fan was different?
MR. SCHWOCHERT: It is my understanding that the
volume air flow was considerably greater than the fans that
are just used for emission, exhaust emission testing and during
the run phrase of the evap test, so you would expect lower
fuel tank temperatures.
MR. LIEFERMAN: Do you know what the volume flow
rate of that fan was?
MR. SCHWOCHERT: No, I don't recall it offhand, but,
again, we could review the situation and supply that informa-
tion for the record.
MR. LIEFERMAN: Again, when I was talking with
Mr. Clark this morning I asked him about that point, and he
said that vanes were on the inlet of that fan, and it was
adjusted to give a fifty-three-hundred cfm flow rate. So
if you have different information, then we have a discrepancy
that perhaps should be
MR. SCHWOCHERT: We did visit Exxon and obtain some
of this information in talking to Exxon. I did not bring that
information with me. We can address these two subjects before
the record closes.
MR. LIEFERMAN: Good. I think that needs to be
cleared up.
MR. GRAY: I would like to get in in some depth into
your discussion on variability, test variability. Beginning
with that discussion on the second page, last paragraph of
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your statement, you state, "We pointed out,in our March
18, 1976 response to the EPA two gram NPRM, that the existing
data showed test variability to be very large relative to
such a standard that is, .89 grams standard deviation
about a 2.11 gram mean on two barrel Vega test cars. We
esimated,that on the basis of test variability alone, a one
gram test design target was necessary to provide reasonable
confidence that a system could be certified to a two gram
standard."
And you said, "Our experience since that time has
not altered that conclusion significantly."
My first question there is, you say "two barrel
Vega test cars." How many cars is that?
MR. SCHWOCHERT: That information is contained in
our March 18th, 1976 response to the two gram standard. I
do not know if you have that with you.
MR. GRAY: If this is based upon the data entirely
that was submitted then, as we understood, interpreted that
data, there were nine Vegas in that sample program. And I
just wanted to clarify before I commented upon that discussion,
that that was the same program that we reviewed in your
submittal, and that there was no new information . . .
MR. SCHWOCHERT: That is correct, I think. There
may have been a test or two additional basically the same
program that you reviewed in our March 18th submittal.
MR. GRAY: If that is the case, I would appreciate
any clarification for the record that you can provide as to
how we would analyze that data to be sure that we are not
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misinterpreting that data base, because you make such a
significant point here that is, that you. would have to
design to a one gram level in order to meet a two gram
standard.
MR. SCHWOCHERT: The clarification that is included
is a reasonable confidence that we would test the cars
below a two gram level at your laboratory.
MR. GRAY: Yes. And if you can comment upon this
summary analysis of that data that I would like to read at
this time for the record as to any areas where we may be
misunderstanding or misuing that data, I think it would be
quite valuable, considering the significance you place in
your testimony upon the influence of that data that is,
that you have to target for 50 percent of the standard.
We have the understanding that that data comes from the nine
Vegas, and that the test data takes into account car-to-car,
test-to-test, and lab-to-lab variability. As we understand
it, nine vehicles, of the nine vehicles included in the data
base, two of them had accumulated 50,000, and one had
accumulated 35,000 miles. The average emission level for
these three vehicles was 3.65 grains per test, as compared to
an average of 1.97 gram per test for the other six vehicles.
Consequently, data from all nine vehicles show a car-to-car
variability. The car-to-car standard deviation was about
35 percent. This contributes heavily to the low engineering
design target you have calculated for one gram per test.
The Vega that was used in the so-called first EPA MVMA,
Motor Vehicle Manufacturer's Association, cross-check program
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has generated the most recent information available to us,
at least, in regards to the test-to-test and lab-to-lab
variability of a two gram per test vehicle.
I think the test on that vehicle resulted in a
standard deviation of about .2 grains,or ten percent of the
mean value. With this combined test-to-test and lab-to-lab
variability of ten percent, the maximum mean emission level
of a particular vehicle that is, that a particular vehicle
can have in order to be below two grams of a single test at
a ninety percent confidence level is 1.7? grams.
Also, in the certification process, a re-test can
be requested if a vehicle fails the first test, or a ninety
percent probability of passing at least one of the two tests
again, assuming the standard deviation of ten percent, a
vehicle mean the vehicle mean is 1.9 grams per test. The
much lower engineering design target of one gram per test
that you stated that you think you would have to target for
appears to us to be mainly a result of two factors, a single
test per car assumption and a high car-to-car variability.
And the high car-to-car variability is because of what appears
to be deteriorations of the threer.high mileage vehicles in
that nine vehicle sample.
Now, that is a summary analysis of how we see
that data being appropriately used, and at this time we invite
your comment as to how we may have misused that data.
MR. NELSON: I think, Mr. Gray, it will take us
some studying to answer the questions you point out. I would
like to indicate a couple factors in regard to trying to
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certify a large percentage of the models that a particular
manufacturer may have. The process with the variable that
you- describe does require the manufacturer to have a target
somewhat below the standard. And I would invite you to look
at Table 3 Table 4 in the copy of the statement, and note
the types of numbers in general which show the degree below
the standard we feel we have to be to avoid unnecessary risk
of not being able to certify a vehicle because of lab-to-lab,
car-to-car, and other variables in the program.
In regard to picking a level that would allow us
to certify a vehicle, I might call your attention also to
Table 2, which points out in a cross-check program that was
conducted by Motor Vehicle Manufacturer's Association and
EPA, where the individual member companies participated in
testing the same cars at different laboratories, it points
out that the difference can be as high as 68 percent; a
car that looks like it would need a two gram standard comes
out above four grams at one laboratory.
So when you take some of these factors into
consideration, the manufacturer has to allow an appreciable
cushion below the standard in order to certify large percentage
of his products. But we would like to elaboratore on the
data more before the hearing closes.
MR. GRAY: We would appreciate that, because we
think that is at the heart of the real issue on variability.
We would be glad to comment on the tables that
you provide in your submittal. I think that at least
the comment is in order that the more recent MVMA correlation
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program, as I recall, had no vehicles that achieved levels
of below two grams per test, first of all; that at this
particular time there is at least at EPA laboratory, a
significant effort to install four new SHED's for the
certification process; and we had at this point not even begun
our check-out of those SHED's. And I think that probably
some of the other motor vehicle manufacturers have had the
same sorts of efforts underway to get their facilities ready
to begin certification testing, and this program may not be
indicative of the true test-to-test variability.
Beyond that, I think it is appropriate to mention
that when we are talking about variability, that the variabili
associated inherently with the test procedure rightly is a
responsibility of the regulating agency, at least in my
opinion. But I think the responsibility becomes a little
grayer when we talk about even the offset that might exist
between laboratories, because the manufacturers generally
had the opportunity to have a good feel for what that offset
is, and in so doing, knowing how their lab correlates to
the EPA lab, and, in a sense, can adjust their design targets
appropriately. So, from a statistical standpoint, it is not
a random effect, necessarily. So that is another factor that
can be considered.
And the last factor is the car-to-car variability
which I think probably is of more concern relative to the
responsibility for that variability. It is very apparent
from a technical perspective that someone to design a
vehicles with an evaporative emission control system, that
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could be very variable on the test. And if the regulating
agency had to have, had to assume the responsibility for
vehicle-to-vehicle variability or even test-to-test
variability on the same vehicle, then there might be the
very real opportunity for that variability to grow to such an
extent that the standard would have to be significantly
inflated such that you could account for variability.
So, to imply that a regulating agency should be
responsible for a vehicle variability appears to be asking
too much at: minimum of a regulating agency. And I think that
in this discussion the different types of variability should
be cleanly separated and certainly discussed fully, but
certainly cleanly separated so that judgment can be made
independently.
MR. NELSON: Mr. Gray, I would like to comment.
From my interpretation of your discussion, you are assuming
that there will be a considerable amount of progress in under-
standing these areas as we go down the road. I think that
is very consistent'Wi£h what we are seeing and as soon as
we have experience with the '78 SHED test, we can make a
better assessment of an appropriate standard that could be
adopted later on for application nationwide. So I am
appreciative of your assumption that progress will be made in
those areas.
MR. GRAY: Of course, the results that we ask you
to comment on are over a year old, and results of that
program with the only vehicle we have seen in a cross-check
program below two grams per test indicated the design target
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of 1.9 would be sufficient to give you 90 percent confidence
that you could pass a standard with the two tests allowed.
It is to that specific analysis that we would appreciate
MR. NELSON: We will be happy to submit that
additional information to the record.
MR. PETERSEN: Mr. Gray, you made a rather lengthy
speech there, and made several conclusions that I do not think
any one of us were able to copy all those down. So before
we leave on Thursday or Friday could we get a copy of your
specific questions in order to adequately respond before
the record closes?
MR. GRAY: In regards to questions as a result of
that discussion, three points were of significance, I think,
relative to a GM response. That is, variability should be
discussed in the context of the test procedure variability,
test-to-test in a given vehicle, and, thirdly excuse me
vehicle-to-vehicle of the same type. And, then, lastly, lab-
to-lab variability. Because these increments of variability
do not necessarily all lump together in a straightforward
manner to allow calculations of a design target from a
statistical base, and so it was just an explanation of why
it seems appropriate that those four increments of variability
be considered separately in any subsequent, submittal you
may provide, so that we can sort them out in an easier fashion,
if you will.
I guess I do have a little bit more follow-up in
that general area. You mentioned the variability problem in
Tables 1 and 2, which Mr. Nelson, I think, called our attention
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to at least Table 2 a moment ago.
From that data, which included all these types of
variability, you concluded that, depending upon which end
of the offset range you consider, that from three to ten of
the twelve Exxon tests which you had been discussing would
have been failures.
It seems very difficult for me at least to get
from that data to that conclusion. And it appears that if
any assumption is valid where we are really comparing, in a
sense, apples and oranges, to come to that conclusion, that
if anything, I think there are reasons why we can speculate
that the Exxon test, had they been run in the EPA laboratory,
would at this time have been even lower.
For example, the Exxon program did not control the
maximum temperature of the SHED during the hot soak. And
as GM comments to the EPA rule making action established a
six gram federal standard would indicate, the temperature
of the SHED during the hot soak would be expected to have a
significant influence on the hot soak emissions. The point
I am trying to make here is that if we get into the game of
speculating what would have happened if we had tested those
cars in the EPA laboratory, I think we have to do. much more
than we can do simply by referring to an aggragate of
variabilities and then trying to cast some significant data
upon the validity and appropriateness of that data.
If there is other data that you would like to offer
in this area to more specifically support your speculation
or your judgment, if you will, that that many of the cars
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would have failed in the EPA laboratory, I think we would
be very willing to review that data as well.
MR. SCHWOCHERT: As you know, Mr. Gray, that
discussion merely uses the data as measured by Exxon, and
applies the nine percent and sixty-eight percent offsets.
It does not try to account for the differences in procedures
that existed between EPA, present EPA practices and Exxon
practices, or for the differences that you have just discussed
regarding the control of the SHED temperature during the hot
soak; it does not try to account for those differences.
MR. GRAY: That is true, but you could equally well
conclude that since the average of those tests as I recall
were 1.9 grams or less for the individual vehicles, that
from the data that we have seen, that there would be more
like a ninety percent confidence that they would have passed
one of two tests at the EPA laboratory. So there seems to
be a big void between these two areas of judgment that
relate very directly to the argument you are making. That
is, to meet a two gram standard you have to target to some-
thing like :50 percent lower than that standard. And it is
a very significant point, and we would appreciate anything
we can stimulate from you in that regard, as regards to
clarifying this technical issue at hand.
MR. HANSON: Mr. Gray, could I make one comment
on what you are saying? You have identified three different
areas where variability has been established to some degree,
and I guess it is the degree we are concerned with, and trying
to project what that may be like in the future in the way of
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design targets. There is another area where this variability
does seem to crop into the picture, and that is in the
determination of the deterioration: factor. We see them
positive and negative randomly, and overall it averages out
about zero deteriorations. But that is another one that
has to be considered, and the manufacturer, of course, has
to design for all these variabilities if he wants to be
assured of getting certified.
If we ran enough tests and averaged them all out,
I think that would be another matter. Then variability would
not be such a big thing.
MR. GRAY: What I was referring to was statistical
confidence, if you could pass one of the two tests for a
given vehicle not an average
MR.HANSON: Yes.
MR. GRAY: You can relate the two with averages
and standard deviations as to what you would have to target
for. And that was the only reason for using that type of
discussion.
MR. HANSON: I understand that point in that
example, yes.
MR. GRAY: Would you like to expand, Mr. Hanson,
on the significance of the deterioration? factor variability
that is, how it relates or should relate to the issue of
variability, again? Could you expand on that?
MR.HANSON: Yes. I think it has been our
experience on these development vehicles that have run 50,000
miles of similar configuration that the DF's generated is
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pretty well random in character, and it can go in either
direction. But we think overall they average out to about
zero. Of course, when we run for certification we are not
talking about several cars within an engine family that will
be averaged it's one that will determine what the DF is.
MR. GRAY: Do you have any repeat data on each of
these cars? As I understand Table 3, which includes the*
data that you are referring to on the varying deterioration.,
factor, that is a calculated 50,000 mile deterioration.,
factor?
MR. HANSON: Yes.
MR. GRAY: Do you have any data on how a given
vehicle from test to test varied in its emission level?
MR. HANSON: I think that may be in here but in a
different table, not for those particular cars. I do not
know how many repeat tests might have been run at each data
point on these cars, but there probably was some.
MR. GRAY: Since they were development cars, I
would assume that you would have run, with the investment of
a fifty-thousand mile car, that you would have probably run .
more than the minimum required. Could you provide whatever
data that you have that resulted in these deterioration
factors, so we could get a better handle on the test-to-test
variability, even if we are not able to have back-to-back
tests so that we could at least have test-to-test as a function
of changing mileage?
MR. HANSON: Yes. I would imagine that a few of
the data points there; might have been multiple tests runv and
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we can supply that information.
MR. GRAY: But beyond that, your point is that there
is a variation in deterioration ' factors. But as I understand
this table, those are all different vehicles. How would you
conclude that the only apparent reason that these
deterioration: factors are different is because of test
variability when they are different vehicles?
MR. HANSON: I would not say because of "test
variability" because of other factors that are strictly
random. And if you can get a factor, either positive or
negative, and you never know which way it is going to be,
I think you have to allow for that when you are designing the
system.
MR. SCHWOCHERT: In this context, the discussion of
test variability applies to a very broad definition of test
variability that is, it includes car-to-car, site-to-site,
lab-to-lab, that type of context. The cars were all identical
as far as they could be built that is, there was the same
system on them, and they were of the same engine configura-
tion, same carburetor Well, there were three different
families represented, as you can see in the table. But with-
in a family all the cars were identical. And in a broad
sense, then, any differences have to be related to test
variability if it includes the car-to-car definition as
well in other words, the systems are identical but the DF's
generated are not identical.
MR. GRAY: These being development cars, there is
some possibility that these, systems were not totally
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identical, I assume Well, I think that by looking at the
test-to-test data on a given car we will be able to better.
distinguish whether or not these were in fact real differences,
whether or not in fact these were real differences between
cars. And certainly if you have real differences between
cars with what you feel is the same system, that is a problem
that has to be addressed.
I am not trying to belittle that technical problem,
but I am just trying to put it in the proper context of test
variability versus technical issues associated with one
system on different vehicles gives different results. And,
in particular, I am concerned about using the data just as
presented because of the negative deteriorations factors,
and, as you well know, the significant influence of background
emissions on the deterioration- factor may very well over-
shadow these kinds of differences.
So it appears that it would take a fairly indepth
technical analysis of these data .and the condition of these
vehicles and the possible differences among the vehicles
before we can conclude anything about why they are different.
I would just ask that before we are asked, before
the EPA is asked to accept the conclusion that the significant
differences are due only to test variability, as the
conclusion in the statement, that we be provided with a more
complete picture as regards to the causes of these differences.
I am not challenging that they are real differences, because
that is apparent. But I do not think on the face of it we
can be expected to accept that these would be due just to test
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variability.
I would encourage you to provide at least the
information related to system differences and to condition of
the car as it might relate to background emissions, and, of
course, any testing that you may have done for background
emissions in particular.
MR. SCHWOCHERT: We would be glad to provide that
additional information, but, as you point out, there are
real differences, and, of course, you appear to be questioning
whether we can build development cars the same and put the
same hardware on them. That is one of the reasons why we
feel need and it is imperative that we look at the emission
levels of production cars. If we cannot build production cars
the same, surely we ought to look at the variability associated
with production cars and see what that looks like before we
make a final determination of what the ultimate standard might
be. So, I think we have similar concerns.
MR. GRAY; My only point is that before we can
conclude really anything about why these numbers are different,
we need to know more about the cars, just simply the influence
that background emission might have, something that's
completely within your control, might very well overshadow
these kinds of differences. And I think that that is the
point I am trying to make, that we need that kind of
information before to can responsibly use these data.
MR. NELSON: We will provide the data you have
requested.
MR.LIEFERMAN: I have one question here. I noted
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in your presentation you mention two types of controls that
may be needed to lower evap levels, one being an accelerator
pump shaft seal, and the other being the addition of another
caninster. I was wondering what your estimate is as to the
cost of those two particular modifications?
MR. SCHWOCHERT: We cannot specifically comment
on the cost. With respect to the accelerator pump seal,
Exxon made some estimates, and we are not talking about large
costs I think associated with accelerator pump seals. Wis
do not think it is appropriate at this time to talk about
the costs associated with the carbon caninster or in the air
filter, because that program is really in its infancy, and
there are lots of problems that might not make that a feasible
program at this time.
MR. LIEFERMAN: Did you have any specific problems
with the costs that Exxon stated in their study?
MR. SCHWOCHERT: I do not think we have any gross
problems with the costs, no, I do not think so.
MR. LIEFERMAN: Very good.
MR. GRAY: Are they too high? I mean, realistically,
that may sound a bit facetious, but we did try to be
conservative in the estimation of those costs. Would you
think that they are reasonable or perhaps conservative?
Can you offer anything more than ... I mean in specific,
we did try to itemize the types of changes we are talking
about so we could get constructive comments you know, a
casting change to a carburetor, a seal change of this type,
so that the manufacturers could really criticize us where we
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need to be criticized. And if you have anything to offer
there, it would certainly be helpful.
MR. NELSON: Mr. Gray, our primary objective in
the early stages of development work is to find the combina-
tion of hardware that does the emission control job. Cost
at that point of development is a second order kind of
consideration. And so we have not looked at the Exxon report
in the manner that would allow us to give you an accurate
evaluation of their cost estimates.
MR. GRAY: Then if we do not hear anything in a
follow-up submittal by GM, then it would be reasonable for us
to assume that those costs would be as good as any costs
that we can speculate on with regard to technology necessary
to meet the two gram per test standard?
MR. NELSON: We will respond to the cost question.
MR. GRAY: Thank you. If you would like to refer
to your written comments on Page 4, the middle of the first
full paragraph. You are discussing the effectiveness of
additional evaporative controls. You make the statement
that a realistic distribution of emissions between diurnal
and hot soak portions of the test at a two gram per test
total level would be more like .5 grams for the diurnal and
1.5 grams for the hot soak. Could you provide us with the
basis for that judgment?
MR.NELSON: Yes.
MR. SCHWOCHERT: The basis for that judgment/ Mr.
Gray, is, if you look at diurnal emissions from a large
number of vehicles, it looks like that diurnal emissions are
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on the order of .5 grains. And we assume then that a car is
going to precisely meet the two gram standard, then that
leaves a balance of one and a half grams for the hot soak.
X think you probably have the data that we would make that
judgment from, but we would be glad to assemble that again.
But that is the basis.
If you look at a lot of historic data where diurnal
emissions are controlled, whereas you do not have breakthrough
on the canister, you will find that they are about half a
gram.
MR. GRAY: I guess I would tend to agree with you,
but let me be sure I understand your response there, because
I think it is quite significant. You feel that it is
reasonable to expect that diurnal emissions can be controlled
to .5 grams per test?
MR. SCHWOCHERT: I think if we look at data on
vehicles, present vehicles, and even vehicles of earlier
vintage that may have had emissions as high as six or seven
or eight grams per test, that generally the diurnal emissions
were in that order. So I think that to answer your question,
yes. :
MR. GRAY: Let me give you one more chance at it.
Do you think it would be a valid judgment for us when looking
at the limited data at the two gram level or below to conclude
that for those vehicles that have diurnal emissions above a
half gram that their diurnal emissions could easily be
controlled to a half gram, thus reducing the total overall
evaporative emissions?
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MR. SCHWOCHERT: I would not want to conclude on
the face "easily controlled to a half gram." One would have
to identify why you are getting higher diurnal emissions
what is the source of that higher diurnal emission? Then
you would measure on a fair number of vehicles.
MR. GRAY: I guess the reason I am pursuing that
type of questioning is that when skimming through the test
results on the vehicles that are achieving levels on the
order of two grams per test, there are some number of those
vehicles that have diurnal emissions that are quite
significant, more like the one gram level in fact, some
of the vehicles have higher diurnal emissions than hot soak
emissions. And so at this stage it is a problem of projecting
what can be done based upon the preliminary studies that
have been accomplished thus far. What I was asking for was
the reasonableness of making that judgment when looking at
vehicle emission results.
MR. SCHWOCHERT: I do not think we can make a general
statement in that regard. As you know, the fuel tank, or
diurnal emissions are quite high for an uncontrolled vehicle
that is, if you just vented the tank in the atmosphere they
are quite high, so you're talking about essentially collecting
all of the vapors, from a practical standpoint, and so just
a very small amount of vapor is being uncollected, of course,
will have a big effect on the ultimate number, ultimate level
that you achieve during that diurnal. So I think it is
difficult to make a blanket statement.
MR. GRAY: You have discussed in a general sense
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some of the work you have been doing in an effort to achieve
levels below the six gram standard and at least a couple times
mentioned you are planning more work. Could you give us
more of a quantification as to what that program currently
involves and what you anticipated involving in the next
few months, like number of vehicles, types of systems? The
discussion was of a general nature. We are looking at charcoal
in the air cleaner. We are looking at larger canisters. I
mean, is this one engineer that is looking at it from just a
concept feasibility standpoint, or do you have in a large
fleet of vehicles where you're actually trying out these
concepts? I mean, could you expand some more upon actually
what you are doing with regards to advancing the technology
for evaporative control something as simple as how many
vehicles are in the program would help quantify.
MR. SCHWOCHERT: I cannot give you that information
right today, how many vehicles we have in test programs
devoted to achieving lower emission levels than the 1978
certification and production will yield. I cannot give you
that exact number today.
But the types of things we are trying to do are
to, besides the programs we have talked about, the specific
control techniques we are talking about, we are trying to
identify the source of the remaining small amount of hot soak
emissions, and will develop programs that try to control those
sources once we have identified them.
MR. GRAY: As you might guess, I am leading up to
trying to encourage GM to provide us any new information that
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you may have, new test results of vehicles designed to meet
lower levels, since it has been some time since we have
received any test results from General Motors, so let me
leave you with that request, that to the extent that you have
test results with these concepts, employing these concepts, I
think it would be beneficial to the determination before us
if we were able to review that data.
MR. NELSON: We will certainly try to provide EPA
with any data we can, and I thought we were having a pretty
good record of sharing or reporting to EPA the status of
the various programs that we do, at least on an annual basis.
And, as you can tell from the volume of these reports, there
is a considerable amount of activity on each program.
MR. GRAY: Maybe I misunderstood that, Mr. Nelson.
To my knowledge, and I take the risk of being mistaken here,
I am not aware of any test data that EPA has received from
GM on systems that have a potential for meeting the evaporative
emission levels of two grams or lower, since the March, 1976
submittal.
MR. SCHWOCHERT: I think that is basically correct.
I think that is right.
MR. GRAY: Is there a chance we can get any
additional information that you may have?
MR. NELSON: As I understood your request, you were
saying that you would appreciate for General Motors to share
some of the data that they were obtaining on future evap
emission systems. We would be happy to try to provide that
to EPA.
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MR. GRAY: Thank you. Yes, that was my request.
I guess there is one more general area that you
mentioned two or three times in your statement. That is
relating to your belief that technological feasibility for
the two gram per test standard has not been demonstrated.
I think that was the general statement, it is in different
forms repeated a couple of times in the statement.
What is behind that .kind of a statement? As X
understand Section 202 of the Clean Air Act, it is not the
burden of the regulating agency, whether it be the California
Air Resources Board, because of their need to be consistent
with that section, or the EPA, as far as that goes, to
demonstrate technological feasibility as 1 understand General
Motors defines it, which is essentially that the regulating
agency first has to develop the technology for every
evaporative emission family before that concept is provided.
And that seems to go so much beyond the requirements of
202 (a), which as I think a layman would read them, say, make
a judgment regarding the potential for developing technology,
and make a reasonable judgment as to the time it would take
for that technology to be developed. And in this particular
case, even as long as a year ago there were, I think, eight
production cars and at least fifteen experimental cars that
were achieving levels of 1.9 grams per test or lower. That
is over a year ago. And, of course, there has been new
information presented today, and I trust additional work done
by the manufacturers that would add to that demonstration
of at least technical feasibility.
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What is behind your contention that it is important
to even consider"a technological feasibility in the pure
sense has not been demonstrated'." Where do you think the
burden of the regulating agency should be drawn with respect
to 202 (a)? I mean, that statement creeps in so many times,
maybe it is a good time to get better explanation of what
you mean by it.
MR. PETERSEN: Let me respond briefly to that, and
I think perhaps Mr. Schwochert has some comments on that ques-
tion.
I am glad that you raised it. If you hadn't, I
would have. Several questions have been raised here this
morning, and as Mr. Nelson and Mr. Schwochert have stated,
we111 attempt to submit for the record information pertaining
to some of the questions raised many of the questions
raised serious doubts as to the validity of California's
contention that adequate technology exists to meet the
proposed standard. And, in this regard, I think that, and
in direct answer to your question, I think that the regulatory
agency there are two of them involved here both
California and EPA have the burden of establishing or making
a finding that adequate technology will exist in the proposed
regulation. You cannot reverse the burden and place the
burden on the manufacturer to prove that adequate technology
does not exist. That is too big a burden to place on a
manufacturer. I think it would be impossible to carry that
burden.
MR. GRAY: Let me be sure I understand it
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MR. PETERSEN: I think that history has shown that
that burden does rest with the regulatory agency.
MR. GRAY: I think if you challenge the
California Air; Resources Board has not fully demonstrated
technical feasibility I think that even looking at a GM
lead time chart for implementing evaporative emission
technology on production vehicles, which was, I think, submitte<
in response to the original California request for waiver
of their six gram per test evaporative emission standard,
and if we were at that point we would not be talking about
1980. We would be talking more of, not later than 1979
MR. PETERSEN: Are you talking about a lead time
chart that goes to a six gram standard or two gram standard?
MR. GRAY: I am talking about lead time, a lead
time chart that relates to hardware incorporation, this lead
time
MR. PETERSEN: Which standard applies here is
certainly relevent.
MR. GRAY: The chart does not reference a level.
It talks about types of changes to be made to evaporative
emission control hardware. At that particular point in time
I think it is fair to say that the hardware was not totally
defined with respect to that necessary to meet the six gram
standard, so I assume it was for that reason that this chart
was put together in the framework for these types of changes,
that it would take this kind of time. I am saying that if
we were talking only about a requirement to implement existing
technology, the lead time picture would be quite different.
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MR. PETERSEN: I do not want to detract from what
Mr. Schwochert will respond on this question, but I think
that the standard is certainly relevant to that type of lead
time question. And I think that the record is going to
establish this morning that several of the questions that
you raised are directly relevant to the California contention
that adequate technology does exist or has been demonstrated,
if for no other issue than lab-to-lab variability.
MR. GRAY: Setting aside the issue of whether or
not this morning, today the question of technological
feasibility will or will not be determined, are you saying
that it is the burden of the regulating agency to show that a
regulation is technologically feasible in GM's definition
MR. PETERSEN: Certainly. Of course I am saying
that. Otherwise the agency could adopt any standard
MR. GRAY: According
MR. PETERSEN: could pull a standard out of the
air and say, "Unless the manufacturer can prove to us that
that standard is not feasible, it is a valid, legal standard."
MR. GRAY: I call your attention to GM's definition
of technological feasibility, and that is the context in which
I asked the question. And that is, that technology be
demonstrated on one of at least the basic types of vehicles
that would be applicable under the regulations, and for
evaporative emission control, that would be at least a hundred
different systems. And to expect a regulatory agency to
demonstrate those levels
MR. PETERSEN: I do not think we are going that far.
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MR. GRAY: Well, that is the past definition of
technological feasibility that GM has offered, and the
terminology is used again here. And that is why I raise the
issue.
MR. PETERSEN: I am unaware of any publication by
General Motors that says technology has to be adequately
demonstrated on 100 percent of configurations which we plan
to make available in order for the regulator to promulgate
a standard, but I think perhaps we are getting into
MR. GRAY: I think you can find your definition of
technological feasibility in the GM response to the EPA notice
of proposed rule making for an evaporative emission standard,
and in that document, technological feasibility, as I recall,
is defined in the sense of technology being demonstrated on
the variety of vehicle configurations, and, by definition,
vehicle configuration
MR. PETERSEN: I think that is different than saying
a hundred percent of the configurations
MR. GRAY: That is why I used "100," because by
the definition of "evaporative emission control system," that
corresponds to an evaporative configuration, as best I can
understand your description of what a configuration is.
MR. PETERSEN: I was not referring to "evaporative
configuration." I was talking about individual vehicle
configurations
MR. GRAY: Someone said there are no two vehicles
alike. But as regards to the basic factors that you have to
consider, there are 100 emission families, about, we are right
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GM 269
now considering, and for a regulating agency to take on the
burden of demonstrating that technology means that that agency
would have to develop the technology and essentially to find
the required hardware for all the manufacturers before the
agency could implement a standard.
CHAIRMAN JACKSON: I think it is fair to say that
whatever definition General Motors used does not necessarily
define the definition for the agency in its interpretation
of its regulatory functions or its deliberations over
California waivers.
MR. GRAY: I guess that just to get clarification
here, is it GM's position that we are dealing with technological,
feasibility as you mentioned in your statement, or not?
MR. SCHWOCHERT: I think one thing that should be
considered regarding assessing technological feasibility is
to, if you applied a certain type of control concept to a
group of vehicles, and some of the vehicles did not achieve
the level of control that you were striving for, that you at
least would understand the reasons associated with the high
emissions. And X think part of our discussion involves your
saying that a reasonable target to provide a certain amount
of assurance that we would certify vehicles at two grams is
1.9, and we believe the target was considerably different than
that. And I think that is perhaps the big reason for the
questioning that is occurring.
CHAIRMAN JACKSON: I think it is rather immaterial,
really, because General Motors has stated by-. 1981 they
could do it in fact, they recommended a standard in 1981.
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GM 270
So the technology is there. It is not a matter . . .
MR. PETERSEN: Not a two gram standard, I do not
believe.
CHAIRMAN JACKSON: You recommend just a standard,
but not a two gram standard?
MR. SCHWOCHERT: We are recommending that we look
at the data that becomes available upon completion of
certification, and, in our case at least, an assessment of
what the production, the levels of production cars are, use
those data to establish a standard that
CHAIRMAN JACKSON: What production cars? The '78's?
MR. SCHWOCHERT: Yes, sir, the *78 production cars.
We have internal . programs where we plan to look at production
evaporative emission levels or evaporative emission levels
of production cars as soonc.as we start producing them.
CHAIRMAN JACKSON: It seems a bit backwards. I
thought you went through development cars first and then
projected that to production. Are you saying you have to go
through production then before you can go back through
development?
MR. SCHWOCHERT: I think maybe a little discussion
of evaporative controls compared to exhaust emission control,
for example, might be in order.
In exhaust control we have some freedom regarding
calibrations and the calibrations we can make to achieve
certain levels, and there are fuel economy emission trade-offs
that we are considering.
With evap control it is quite different. You provide
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271
a certain type of hardware, and that hardware achieves some
emission level. And that is what we are talking about in
1978. We are providing the type of hardware that comes close
to limiting, we think, the ultimate level of control that you
can achieve from an evaporative emission standpoint. So we
believe that is necessary to evaluate really where we stand
with the use of the hardware that is going to be used in 1978.
CHAIRMAN JACKSON: I think just on the basis of my
experience, which certainly is limited to some extent, that
we have more data here in front of us with regard to
technological feasibility of this particular standard than
we have some other standards in the past that have proven
achievable after the industry finally was convinced that that
standard was going to remain on the books.
I just, a cursory review of the information that we
do have, appears, though, that it is fairly well established
that it can be done.
My question, I guess, to General Motors is, what
would be the consequences of granting the waiver that
California has requested in specific terms, given that by
appears to be technologycat hand which will enable cars to
meet a two gram standard?
MR. NELSON: Well, Mr. Jackson, I think that it is
an impossible question to answer because of some of the things
we discussed earlier in our statement about variability of
testing and all the eventualities that could occur in the
down-the-road process of getting certification. Certainly we
do not want to speculate on what might happen in such a
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theoretical case at this point in time.
CHAIRMAN JACKSON: X do not know how theoretical
it is to you. It is not all that theoretical to me based
on the information I have seen here, that it is not like a
situation where we haven't seen any hardware at all that
will produce this result. We can argue about variability, we
can argue about a hundred percent configuration. There is
evidence to indicate that there is technology which, if applied
correctly, will reduce emissions to the below two grams, as
measured by the SHED.
Now, given that, and given that General Motors is
obviously aware of that and has the development programs
in place to a certain extent which allows us to evaluate the
consequences of an action that is before us my question is
in more specific terms: What would be the reaction of General
Motors to such a granting? What measures would you take?
MR. PETERSEN: Are you asking whether we legally
challenge the waiver?
CHAIRMAN JACKSON: No. I am talking about what you
would do with regard to your development programs. What are
the consequences? What General Motors be in a position where
they could not manufacture cars in 1980 for sale in California?
MR. SCHWOCHERT: First of all, with respect to the
General Motors vehicles, I assume there are some General Motors
vehicles in this category of vehicles that demonstrate
feasibility in your mind. We are basically providing the
same type of control on all our vehicles, and will be providing
that same type of control in 1978. Some of these vehicles
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achieve lower levels than others. There is no holding back
of evaporative control, in a general sense at least, in 1978,
providing this next step, that is going to meet the six gram
standard. So it isn't a question of applying the technology
from our vehicles that achieve two grams,to ones that achieve
2.5 or three or 3.5 or four, whatever they achieve; it is
already there. It is identifying where we can get additional
control. I cannot speculate on the consequences of
CHAIRMAN JACKSON: You have not done that? You
have not identified where you are going to get additional
controls?
MR. SCHWOCHERT: That is right. We could not take
specific vehicles and tell you where right now what we
have to do on those specific vehicles to achieve the lower
level.
CHAIRMAN JACKSON: Well, what percentage of the
vehicles are you talking about that would not be able to
meet a two gram standard with your '78 hardware?
MR. SCHWOCHERT: I do not think that we could
identify those percentages right now. We would be guessing as
to whether they could meet the levels
CHAIRMAN JACKSON: There are cars that are going
to be certified
MR. SCHWOCHERT: Yes.
CHAIRMAN JACKSON: Is certification under way,
completed or what?
MR. SCHWOCHERT: It is under way.
MR. PETERSEN: I think that is one of our
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recommendations, to wait until the certification is completed,
because that program is going to provide a lot more insight
into this whole question.
CHAIRMAN JACKSON: When will it be completed?
MR. PETERSEN: July.
MR. NELSON: Sometime this summer.
CHAIRMAN JACKSON: But is it fair to say that that
is a full scale effort on the part of General Motors to meet
a two gram standard? It is not, is it? It is an effort to
make sure that you don't bust a six gram standard.
MR. PETERSEN: There is an across-the-board
application of our best technology at hand, that is correct.
CHAIRMAN JACKSON: That is the best '78 cars
have the best technology known to General Motors for evaporative
emission control?
MR. SCHWOCHERT: At this point in time.
CHAIRMAN JACKSON: The best technology known to
General Motors.
MR. PETERSEN: I think we have answered that. It
is feasible. I mean, certainly you can build a system that
And I am not an engineer that that's best technology
within reason, that is feasible.
CHAIRMAN JACKSON: I am looking at data here which
Mr. Gray points out to me is certification data.
MR. GRAY: Table 1.
CHAIRMAN JACKSON: This is for General Motors. And
we see evaporative emissions that exceed the six gram
standard at EPA, and at General Motors that exceed the six
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275
gram standard, on one car.
On another car, General Motors is 5.06, and another
car, General Motors, 1.95.
MR. SCHWOCHERT: That table was included to indicate
or display the paired car certification test data that were
available at the time this report was put together between
General Motors laboratory and EPA laboratory on certification
of cars at that time.
CHAIRMAN JACKSON: Are these the cars that have
the best available technology on them for evaporative emission
control?
MR. SCHWOCHERT: They have the 1978, the hardware
that obviously is going to be used in '78 production.
CHAIRMAN JACKSON: I assume that, but is it the
best available evaporative emission control hardware available
to General Motors?
MR. SCHWOCHERT: How do you define best available
hardware?
CHAIRMAN JACKSON: That which gives you the lowest
emissions.
MR. SCHWOCHERT: The answerwauldhave to be no, in
that broad sense of definition. You could put fuel injection
systems on those cars, for example, and probably from past
test results, those vehicles would achieve lower levels of
evaporative emission control.
CHAIRMAN JACKSON: Is there any difference in the
system on the last vehicle and the first vehicle?
MR. SCHWOCHERT: I guess the first vehicle, there are
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two repeated tests. The first and second displays are the
same vehicle. It may be that a description of those test
results are in order. That vehicle has undergone additional
testing at both EPA and General Motors, and it was found
that the vent line from the carburetor float bowl to the
canister distorted the air horn such that we were not getting
a proper seal. There has been some additional work done on
the vehicle because of the prototype nature of the carburetor,
and the emission levels, the latest emission levels on that
vehicle X think are like four and a half grams. So that
vehicle, it wasn't displayed to represent what the '78 hard-
ware will do. It was back-to-back tests at both laboratories.
CHAIRMAN JACKSON: Does it have the same hardware
on it, the control hardware as the last vehicle? Is it
different hardware?
MR. SCHWOCHERT: Basically it has the same control
hardware, yes.
CHAIRMAN JACKSON: What accounts for the difference
in performance? Do you know?
MR. SCHWOCHERT: No, I do:not know. And, generally,
that is, I think, where we are. It is identifying a couple
of grams of hot soak emission and their source.
CHAIRMAN JACKSON: What is this back to Mr. Gray's
point a while ago for which we did not get a: definitive
answer on, it appears as though, if I can glean anything at
all from the conversation, is that your 1978 certification
completes your 1981 development fleet. Do you have any other
cars running for development purposes for the 1981 standard
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that we are talking about here?
MR. SCHWOCHERT: Yes.
CHAIRMAN JACKSON: For 1980?
MR. SCHWOCHERT: In a general sense we discussed
the programs that we are looking at to achieve lower evaporativo
emission levels. For example, we are looking at the sealing
of the accelerator pump shaft.
CHAIRMAN JACKSON: You do not know how many cars
you have in that developmental program?
MR. SCHWOCHERT: Right today Iicannot tell you how
many, specifically how many. Wis have indicated we are going
to supply for the record additional test data to EPA regarding
these development programs.
CHAIRMAN JACKSON: You have indicated that the
California approach lumps gasoline fuel trucks in with light
duty passenger cars, and that you think they ought to be
separated out with some reference to International Harvester
versus Ruckelshaus. Is there any other reason why they ought
to be separated out?
MR. NELSON: Mr. Jackson, the basic difference
between the truck and the car is the, what you might call the
vocational function of trucks in other words, it is
designed and built to carry a load of cargo or people, which
causes the truck to have different characteristics on emissions,
both exhaust and evaporative, than passenger cars such
things as higher axle ratio, heavier vehicle loads, larger
frontal area in the case of many of the delivery trucks. The
truck exhibits different characteristics than the car. So
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that was the point, that trucks, according to the court
decision as I understand it, were looked upon as being
different in emission characteristics than cars, and so
technological feasibility ought to be looked at on trucks
separately from passenger cars.
CHAIRMAN JACKSON: Fine. What are the consequences
of the different look? I mean, does that mean that it cannot
be done or can be done? It's easier to do, harder to do?
MR. NELSON: Basically what it means is that the
evaporative emission characteristics you measure from a
truck will be higher than a similar type of vehicle that
happens to be a passenger car. A truck, as I pointed out,
was designed with different axle ratios and the ability to
carry a load, and generally it runs with temperatures in
the engine at a higher level than the temperature of a
comparable passenger car and causes more carburetor emission
losses and more tank emission losses because of the increased
temperatures underneath the vehicle, and, in some cases,
increased temperature in the engine compartment.
So the basic problem is, it has higher evaporative
emissions in its uncontrolled emissions, so to give it the
same level of control requires a different approach, more
technology than the passenger car.
CHAIRMAN JACKSON: We know that for a fact? That
is documented somewhere, that you have a level of control
down to something approaching two grams, and you know what
the hardware differential is in terms of that control?
MR. SCHWOCHERT: We do know that evaporative
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emissions, both diurnal and hot soak, are higher from trucks.
This subject has not been treated at all in the discussion
truck emissions have not been treated at all in discussion
of technological feasibility, and we are just suggesting
that we take a separate look at it. Again, once the '78
certification is complete, we can look at the truck versus
passenger car data.
MR. PETERSEN: Are we using the same control hard-
ware on light trucks that data should indicate some
difference.
MR. HANSON: Yes.
MR. SCHWOCHERT: In some cases we are using more
control hardware with respect to dual canisters, for example.
CHAIRMAN JACKSON: I guess it is fair to say that
you conclude that they have higher emissions, but you do
not know the effectiveness of the condition of more of the
same kind of technology you have will cause emissions to go
down below or around two grams?
MR. NELSON: Mr. Jackson, the main point was that
the same hardware based on previous experience does not do
the same job on a truck as it does on a passenger car, so
it takes more, either a bigger canister, different control
system, than it does on the car because of the tructts higher
emission characteristics.
CHAIRMAN JACKSON: I can go along with bigger
canisters. That is the same technology, just more of it.
That seems to be what we are talking about. Are you really
talking about different kinds of systems as opposed to just
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systems with better capacity because emissions are higher?
MR. SCHWOCHERT: I do not think we can comment on
that, because we do not know how to achieve two grams right
today; we do not know how to achieve two grams on the various
passenger cars or trucks. So we do not know if the hardware
will be different or not.
MR. GRAY: Do you have any data, say, comparing under-¦
hood temperatures of trucks, light,medium-duty trucks, to
light duty vehicles with the same engine?
MR.NELSON: Sorry, Mr. Gray, I did not hear the
question completely. Would you kindly repeat that?
MR. GRAY: I asked did you have any data that would
compare the under-hood temperatures, any under-hood
temperatures carburetor temperatures or just any under-hood
temperature of light--and medium-duty trucks to light-duty
vehicles with the same engine?'
MR. NELSON: I am sure we probably have such data
back in Detroit. We do not have any with us today.
MR. GRAY: It is your recollection that that data
indicates that when the light-duty truck is driven over the
same preconditioning procedure as the light-duty vehicle, as
specified in the regulations, that the under-hood temperatures
for the truck are higher?
MR. NELSON: In some cases it definitely is, because
the truck engine operates at a higher speed and, in some cases,
the truck does not get the same engine compartment environment
that the passenger car gets, so it is definitely different,
and in many cases higher.
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MR. GRAY: Would you provide us those data that
show that?
MR. NELSON: We will be glad to look and see what
data-we have available. We have provided in the past, and will
be happy to do so for the record detailed explanation of why
trucks are different than cars.
MR. GRAY: I think the issue is whether or not the
technology would need to be different because of different
operating conditions. Some people have provided the judgment
that because there is more open space under the hood of a
light truck or medium duty truck that the under-hood temperatures
would even be maximum hot soak temperature would even
be less than for the same engine in a light-duty vehicle.
And that is the area that I would specifically appreciate
information on. And the specific temperature of interest
would be maximum hot soak temperature, and, if you have
carburetor temperature/ that would be preferable. But
ambient under-hood temperatune would be satisfactory.
MR. HANSON: Mr. Gray, different vehicles have
different configurations. In some cases you might find a
larger engine compartment in a truck, and in other cases
you will find a smaller engine comparment. 1 guess the
point is here, even if they were equivalent, there are
inherent reasons why trucks are going to heat the fuel tanks
and the carburetors higher than the comparable passenger car.
MR. GRAY: I imagine there is a wide variation
within light-duty vehicles. I am not saying there isn't.
But the issue is, is there a wider variation in light-duty
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GM 28 2a
vehicles with or without light-duty trucks being considered?
In other words, are light-duty trucks at the top
end of the light-duty vehicle variations, or do they fall
within those variations? Where do they fall relative to
the light-duty vehicle driving forces for evaporative emissions"'
And I do not think we are really addressing the issue of fuel
tank size, because it is generally acknowledged that the fuel
tank, at least the tanks of some trucks, have larger volume
than light-duty vehicles. But even in that area you have
overlap again. I think the hot soak emissions, as your own
testimony would support, is a more difficult emission to
control. Since it is generally accepted that peak carburetor
temperature is the best correlator to hot soak emissions, I
think if you have that kind of data, you could support your
argument very strongly.
MR. HANSON: If we do not have it, we can certainly
generate it. But within this range, the smallest and tightest
engine compartment we know of is the truck, it is in the vans.
I do not think you will ever find a passenger engine compart-
ment that small, because that is really squeezed in the
passenger area of these vehicles. And the same thing with
the range you are talking about on fuel tanks yes, there
is a range of sizes on cars and a range of sizes on trucks,
and they overlap slightly, but there is still considerable
difference within that range.
MR. GRAY: I trust that the information you provide
us will cover vans as well as other types of pickups, and,
to the extent you can, the range of .passenger car applications
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28 2B
as well.
CHAIRMAN JACKSON: I suppose it has been pointed out
to us by the CARB that in their statement on Page 14, Table
1, that there .is a list of vehicles that I believe are '78
durability vehicles, evaporative emission vehicles. One is
listed as having evaporative emissions of 1.78 grams per
test. And I think it has been pointed out that that is a
light-or medium-duty truck.
And then on Page 15, GM Vehicles 3, 4 and 5, which
have evaporative emissions ranging from 2.49 to 2.62, are
also either medium-or light-duty trucks. Compare that data
with the data we just saw from the certification of General
Motors *78 fleet, this data would seem to be lower in its
light-duty trucks, medium-duty trucks.
MR. PETERSEN: I think Mr. Gray has asked a number
of questions which we will be glad to respond to on how
trucks differ from passenger cars in regard to their evaporative
emission characteristics.
CHAIRMAN JACKSON: It doesn't look to me like it
goes in the right direction.
MR. PETERSEN: One point that we have raised is
that it is our knowledge that the regulator has not treated
trucks separately from the passenger vehicle.
CHAIRMAN JACKSON: Has General Motors in the
application of this technology here with regard to these
vehicles that I am talking about, one with 1.78 grams per test,
did you treat it differently? Did you use the same kind of
control technology?
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GM 283
MR. PETERSEN: I am not sure we know exactly what
those vehicles are today, and I think that unless ray colleagues
disagree, we would prefer to respond to that before the
record closes.
MR. HANSON: I think we have already answered that.
On the trucks we are using all the hardware we are using in
the cars in '78, and in some cases more of it.
CHAIRMAN JACKSON: So, getting back to my point a
while ago with Mr. Nelson, it appears more of a volume issue
as opposed to "it's harder to control."
MR. HANSON: For the six gram standard, that may be
correct.
CHAIRMAN JACKSON: I am talking about this level of
emissions.
MR. HANSON: This level of emissions is the result
of our efforts to meet a six gram standard.
CHAIRMAN JACKSON: Yes. But, again, getting back
to those 1978 cars, the data that we were just looking at a
while ago, we were seeing emissions around four to six.
MR. HANSON: Yes?
CHAIRMAN JACKSON: And I assume they have the same
technology on them that these have, but the point was that
these are harder to control, but you are getting lower emissions
out of these.
MR. NELSON: Mr. Jackson, I object to the assumption
that these trucks We do not know at this point in time which
of these are trucks and which are cars, and we would
certainly like to have an opportunity to review the data and
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GM 284
submit for the record a response to the question you are posing
CHAIRMAN JACKSON: I would appreciate it.
MR. NELSON: We will do that.
MR. PETERSEN: I am not sure any valid conclusions
can be made on the basis of three or four emission results
anyway.
MR. LIEFERMAN: There is certainly a wide variation
in engine compartments in trucks. Trucks go anywhere from
around 6,000 pounds or under up to large, much larger trucks.
Do you have any feel for the hot soak losses, how they compare
between, let us say, light duty trucks and a much larger,
heavy duty gasoline vehicle?
MR. NELSON: We do not have any specifics with us
today to tell you exactly how they differ. We told you in
general terms, and we will be happy to submit more indepth
analysis of the data we have.
MR. LIEFERMAN: We have done some limited testing,
and we find generally that on the very large trucks, the engine
compartments are much more open than on the lighter ones,
and your under-hood temperatures are typically less than your
tighter engine compartments, and hot soak losses do not seem
to be any different on those large vehicles than they are on
passenger cars. I just asked the question, wondering if you
had done any tests on those larger, vehicles.
MR. SCHWOCHERT: I am not aware of the recent test-
ing I assume we are talking about heavy duties and
connotation of extremely large vehicles. And, of course,
when you address that group of vehicles, the question is, what
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GM 285
does the run phase look like for those vehicles? And I do
not know what you have assumed the run phase looks like for
those vehicles, but certainly it does not look, as far as the
demonstration of exhaust emissions go, it does not look like
the one phase of the light-duty smaller vehicles. So that
certainly is a question you know, what is the history of
the vehicle prior to subjecting it to the hot soak portion of
the test.
MR. HANSON: If you are comparing the engine
compartment of, say, the pickup line up through 60 series,
which would include most of the conventional jobs, I think
those engine compartments are exactly the same. It is the
same sheet metal, essentially, used on those. But what
generally happens is, though, it gets lifted up higher in the
air, and there is generally more ground clearance as you go
to bigger axles and wheels.
MR. GRAY: I think the concern we were trying to
address was that for those trucks, the factors you were mention--
ing that might be expected to result in higher emissions
that is, higher road load, different axle ratios, generally
just a greater load on the engine for the same drive, that
at least from the limited testing that we had done, that
because probably of the greater volume of air around the
engine that we did not see any significant differences. So
I do not know if this is saying we have a worse case situation
somewhere between light-* and medium-duty trucks or whether it
says anything, but if you have any additional information
there, I guess that would help clarify it.
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GM/FORD 286
MR. SCHWOCHERT: I guess we were just suggesting
that this issue be addressed separately, and we were not
aware of any separate addressing of the issue prior to oral
discussion here today. And you apparently have addressed this
issue separately, and we are not aware of that information
again at least I was not aware of that information.
CHAIRMAN JACKSON: Thank you very much.
We will now take Ford's statement and then break
for lunch.
MR. BUIST: I am Donald R. Buist, Executive
Engineer, Automotive Emissions and Fuel Economy Office of
Ford Motor Company. With me today is Mr. John P. Eppel,
Associate Counsel, Ford Motor Company. We appreciate this
opportunity to present our testimony relative to California's
request for a waiver of preemption to enable California to
enforce its 1980 Model Year Evaporative Emission Standard of
two grams per test. This standard is applicable to light-!-,
medium- and heavy-duty vehicles.
As we have indicated in the past, Ford has long been
a supporter of further control of evaporative emissions as a
logical step in reducing overall hydrocarbon emissions.
Basically Ford supports California's request for a waiver
with respects to its two gram evaporative emission standard
for 1980, assuming that three important matters of test
procedure can be resolved. Let me first address the two that
deal with light-and medium-duty vehicles.
Ford currently has a development program in place
which is targeted to have proven technology available in time
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FORD 287
for 1980 California certification. Our program is in its
early stages and we, to date, do not have the technology
across all our car lines to meet a two gram SHED requirement.
Our basic approach is to first develop a solid data base on
the following points:
Determine representative vehicle background levels
and how they can best be controlled.
Assure compatibility of evaporative emission
controls with exhaust emission controls for future systems.
Quantify and qualify all sources of evaporative
emission leaks that require control.
Resolve current test-to-test variability problems.
We are now in the early stages of this program.
Once completed, we plan to proceed to final hardware system
development and proveout.
We remain apprehensive about the risks inherent
in this two gram program, particularly our ability to
successfully complete 50,000 mile durability. At this point,
the two issues that give us the most concern are background
levels on aged vehicles and test variability. At the
November 23rd, 1976 GARB Hearing, Ford testified in support
of the decision to grant a one gram allowance for 4,000 mile
vehicle background and test variability. Because of the
length of that hearing and the very many new requirements
being considered, there was little opportunity for considera-
tion of Ford's proposal for allowance for 50,000 mile
vehicles. However, we were told by CARB staff that the matter
could be addressed at the EPA Waiver Hearing.
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FORD
288
We are now convinced, based on test data included
in Exhibit 1 of this statement, that the lowest practical
background to be expected on typical durability vehicles (after
doing everything practical to get the level to a minimum)
is in the range of .2 to .6 grams per test, or ten to thirty
percent of the standard.
Coupled with the .2 to .6 gram per test background
is SHED test variability. Current SHED test variability
experience indicates that results are only accurate to
within plus or minus .8 grams per test. Over and above
"expected test variability " is an associated phenomenon we
call "test fliers." These are results which, for some unknown
reason, are extremely beyond the expected variability range
and usually exceed the standard. Test fliers are currently
being experienced in the 1978 Certification Program. To date
we have had a total of four vehicles out of thirty with
fliers. The flier situation becomes extremely serious because
we have found that, unlike exhaust emissions, the majority
of evaporative test fliers do not produce customer complaints
and, therefore, can only be corrected in the certification
program with the start of a new vehicle, which, of course,
substantially delays completion of certification.
Similar situations of wide varidations in test
results have also recently been experimented at both the
Ford and EPA labs with vehicles in the MVMA SHED Correlation
Program. Unexplained variations up to four grams per test
have occurred. Ford appreciates the fact that CARB has taken
steps to handle the large fliers on durability vehicles with
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FORD 289
the use of their "outlier criteria." However, the
deterioration factor will still be greatly influenced by test
variability and, of course, emission data vehicle results
will be influced by both expected variability and fliers.
Although we are not positive, we suspect the reasons
for test fliers and rather large variability is a combination
of vehicle hardware and SHED test technique variability. The
hardware variability is obviously our problem,and we are
working hard to resolve it.
The test technique variability is, we feel, due
to the fact that everyone is working with a new procedure
and associated test hardware. In fact, EPA itself has only
within the past week completed construction of its new
certified SHED's.
Of course, we anticipate that much of this concern
will be alleviated as everyone gains more experience with
both vehicle hardware and test technique. However, until
that experience is gained, Ford believes that to be eligible
for a waiver the GARB procedure should incorporate a durability
vehicle background allowance of .5 grams per test. Ford
would suggest that CARB's waiver be conditioned upon CARB
modifying its regulations to authorize the Executive Officer
to grant such a background allowance to a manufacturer who
can demonstrate that he has taken all reasonable steps to
reduce background to a stable minimum prior to start of
durability.
In addition. Ford believes that in order to protect
two grams per test feasibility, California's evaporative
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FORD
290
emission procedures should be made consistent with its
exhaust emission procedures by permitting durability vehicles
to exceed the standard at the intercepts. Emission data
vehicles would, of course, be required to go below the
applicable standard. This is commonly referred to as line-
crossing. This would greatly reduce the very real and
demonstrated risks associated with test variability.
Ford believes a provision for line-crossing is
technically sound. There is no basis for concluding that the
deterioration factor generated under a procedure permitting
line-crossing is any less meaningful than one obtained in the
absence of line-crossing.
On the other hand, line-crossing mitigates the
spurious effects associated with shortcomings in the
present procedure and, as a practical matter, renders
-technologically feasible a requirement whose feasibility
might otherwise be subject to serious question.
A "background" allowance of .5 grams for durability
vehicles has much the same effect. Without debating the
propriety of, in effect, imposing a standard on nonfuel
hydrocarbon emissions, Ford does not believe anyone has
analyzed the feasibility of controlling background emissions.
In the absence of any data which indicates that real life
background can be controlled to essentially "zero" levels
(as opposed to stabilized to "zero" levels), such control is
improper.
In summary, with the ability to line-cross and
a durability vehicle background allowance, Ford's confidence
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FORD
291
to successfully certify at a two gram level for 1980 would be
at an acceptable level.
Mr. Jackson, I originally planned to read the rest
of the statement which deals with our concerns associated
with the heavy duty vehicles. However, in view of Mr. Austin's
statement, we appreciate the fact that he has taken our
recommendations into consideration, and I will not although
I want to submit my statement for the record I will not
bother to read it with respect to heavy duty vehicles.
We, however, look forward to reviewing the final
language that goes into the carb procedure with respect to
heavy duty vehicles and their certification.
That completes^ the reading of our statement.
MR. EPPELZ: ¦ Mr. Jackson, I have a couple of points
if you want to go through a little longer before lunch.
There was a discussion this morning of what the meaning of
technological feasibility is. It was surprising to jme in
view of the International Harvester case. I do not think
engineers or lawyers have to speculate when a judge tells you
how to do it. And I guess I direct Mr. Gray and the others
to go back and read that case. It tells the agency what its
responsibility is, and it tells the manufacturers what their
responsibility is. I think that is a closed issue. If you
want, I can burden the record by reading it to you.
CHAIRMAN JACKSON: I think we have*- copies of that
which we can refer to. I appreciate your edification there.
We will now adjourn and reconvene at 1:30.
(Luncheon recess taken at 12:30 o'clock p.m.)
oOo
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FORD
292
TUESDAY, MAY 17, 1977 1:30 O'CLOCK P.M.
oOo
MR. LIEFERMAN: I had a question on the curves
that are shown in Exhibit 1 for the background levels of
several different vehicles. I was wondering what curve fitting
technique was used to generate the shown curves on that
particular graph. Was there a certain curve form used for
those lines, or were they . . .
MR. BUIST: As I recall, there was a curve fit
technique used for the upper curve, which was the average of
12 cars. I am not positive, but I think the other curves were
just drawn in on based on the data points.
MR. LIEFERMAN: On that bottom curve, that one
vehicle that was tested without any sealer or sound deadener
in it, it looks as though the last data point shown there,
which is Day 19, seems to be well, it is lower than the
other data points prior to that. I was wondering if you had
gotten any more data on that particular vehicle since the
data shown here?
MR. BUIST: I think we picked up one more data point
since this, which is about 40, and I can submit this data
for the record? but it was out at about 47 days, and if you
go to the 47th day and put a little box in at .2 . . .
MR. LIEFERMAN: Well, I think by looking at that
curve then that does suggest a stabilized level of very near
.2 grams.
MR. BUIST: Right.
MR. LIEFERMAN: Is there any reason, or would there
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FORD
29 3
be any difficulty in preparing durability vehicles with sound
deadener and sealer removed, as was done with this vehicle,
which showed a level of essentially .2 grams within five or
fifteen days after production?
MR. BUIST: I do not think it would be basically
difficult to do. We would just by-pass that particular step
in the build process.
The data indicates to us that that may not be
necessary because of the slope of the other curve without the
sound deadener out at the 30 to 4 0 day point, the scatter of
data indicates that possibly does not make any difference.
It kind of says to us that, yes, there is a significant
difference in the five-to twenty-day area, but after that the
two start to come together again for some reason, and that
reason we are not sure of.
MR. LIEFERMAN: I guess looking at the bulk of the
data here then on the *77 vehicles implies a stabilized level
of very near .2 grams at the 40-day level and thereafter,
regardless of what sealer was removed or not.
MR. BUIST: We conclude that there is some kind of a
background level at about the 30-day point that at least at
this point in time everything we have determined that could be
reasonably done to a vehicle to bring its background down would
be somewhere between maybe .3 and .6, and the data is scattered
there, so we are not sure where that actual point will be.
We are looking at a hundred durability vehicles, and
the background on a hundred durability vehicles is going to
have some variability, but we anticipate it will be in the area
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FORD
294
of half a gram some below, some above.
MR. LIEFERMAN: I think we need to really recognize
the factor, though, that for that one vehicle, which was
essentially a "best try," where no sealer
MR. BUIST: It was not a first try, it was the "only
try."
MR. LIEFERMAN: All right, the "only try." It is
about .2 grams?
MR. BUIST: Yes.
MR. GRAY: Let me just ask a point of clarification.
Did you say a hundred durability vehicles would be used next
year?
MR. BUIST: That is a typical Ford Motor Company
durability fleet.
MR. GRAY: For the evaporative emission control
families concept?
MR. BUIST: For the total.
MR. GRAY: For exhaust standard evaporative emissions?
MR. BUIST: Yes. We cannot really say at this point
how many would be run for evap.
MR. LIEFERMAN: I might just bring out the point
that on Exhibit 2 you show some curves there for some back-
ground data on some heavy duty vehicles. Those tests were
run at our lab in Ann Arbor, as you know.
MR. BUIST: Right.
MR. LIEFERMAN: We do have data now beyond the data
*
shown here out to about 65 days of operation. That more recent
data has shown that the levels have gone down considerably
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FORD
295
more than what is indicated here by the lines that are drawn.
At the 65-day level, used an exponential curve fit for the
data. Some data was eliminated due to the fact that we found
some tests where we had propane leaks
MR. BUIST: Correct.
MR. LIEFERMAN: from the system. And at the
65-day level the "hot" background value on the exponential
curve was right at .5 grams.
MR. BUIST: What was "cold"?
MR. LIEFERMAN: And the cold was about .2 grams
for that one truck that we did test. I just wanted to bring
out the point that we did get some more data here.
MR. BUIST: My point in presenting it out through
the 30 day, roughly 30 days, is to equate it to light duty
vehicles and what background could be expected at a 30-day
level, which is kind of a four-thousand-mile car, at the
four-thousand-mile point.
MR. EPPEL: Would you submit those for the record
so we could see them, the test results?
MR. LIEFERMAN: Yes, we can do that. I have given
those test results to Ford people connected with the test,
but we can submit those.
MR. BUIST: I was not aware of that.
MR. GRAY: You mentioned, I guess, that there were
two major issues that gave you concern with regard to the
two gram level, the first being background, and the second
being test variability. I think we probably covered test
variability in a broad sense this morning well enough.
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You do bring up one new aspect of test variability,
I guess, an aspect that you called "test fliers." When you
see such an abnormally high test result on a vehicle, is this
a random occurrence in other words, would the following
tests likely give you the same high result?
MR. BUIST: Not necessarily, and that is what
bothers us. If it did, it probably would be easy to find.
I can give you an example. We had a four-thousand mile car
in the '78 certification program which got a very high level,
like seven to eight gram area on the first test at our shop
at four-thousand miles; the second test it got down much lower
that. It went to EPA and repeated that same high level, and
then came down again. And I cannot explain why.
MR. GRAY: Have you been seeing this long enough
that you have started investigating the problem?
MR. BUIST: Oh, yes. We have seen it all along
through SHED development.
MR. GRAY: And you haven't anything that you can
offer us as to why it might be happening?
MR. BUIST: No. I guess if we could solve it we
wouldn't be talking about it here now. When we have a vehicle
like that, the standard procedure is to go into the SHED with
a sniffer, FID sniffer, and try to find the source of the high
level. The problem is, by the time you find the high level
you have lost the rabbit. The vehicle is out of the SHED most
of the time, if it is going through its normal grimbo of
being tested, so the trick is to find the level while the
vehicle is still in the SHED, and then sniff around and try to
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find the source, and it's not always that easy/ particularly
if you put the vehicle back in for a second test and it is
down to where you expected it to be.
MR. GRAY: Have you seen the high levels in any
two repeat tests? Maybe that's a different way of asking
it, but . . .
MR. BUIST: I do not recall any, but I am sure
statistics would have to say we have had it in development.
MR. GRAY: I am just trying to get at whether or
not it is a random occurrence or somehow related to the
preconditioning of the test sequence or something of that
sort.
MR. BUIST: At least in the certification process the
preconditioning is the same is every instance and that is
our objective, of course, in development, too, or the test
isn't worth anything.
MR. GRAY: Of course, the preconditioning could be
different, depending upon the situation of the vehicle prior
to the test, of course at least in the first test it could
be quite different as compared to the second.
MR. BUIST: Yes, but that is an easy one to find
and flag out once you go back and review the data and how
the test was run. That falls out rather quickly.
MR. GRAY: Have you looked at it to the extent that
you can offer a judgment of statistical confidence that when a
vehicle experiences this abnormally high result, what confidence
you have it would not experience that same high level in the
second test? In other words, how it relates to the
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certification process which allows the two tests?
MR. BUIST: I do not think we are smart enough, Mr.
Gray. I could not step up to that one. I do not think I
know.
MR. GRAY: Is there any way you can look at the
data with regard to that kind of a question to give you a
judgment as to what percent of your configurations would fail
both tests because of this problem so that we can get a
better grasp of the problem, the significance of it?
MR. BUIST: Well, as I indicated in here, we had
four out of thirty thus far in the program, in the initial
throes of the program
MR. GRAY: That experienced a test flier?
MR. BUIST: Right.
MR. GRAY: But my point was, as I understand the
test flier concept, it's experienced, but it is not consistent,
it is not repeated. And that is why I was asking the question
of what Confidence would there be that of those four vehicles
that for two back-to-back tests they would fail both tests?
MR. BUIST: I do not know. I cannot answer the
question.
MR. GRAY: You make a very positive constructive
recommendation with regard to this matter before us. Can I
press your recommendation a bit in the area of, while you
have recommended essentially a 2.5 gram level for the durabilit
vehicle . . .
MR. BUIST: We have indicated that we are trying
very hard to get our confidence level to an acceptable point to
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meet two grams in eight, and we are trying to get there, and
hopefully we will in time.
Our point in addressing the background issue and the
ability to line cross is to reduce the risks associated with
getting there. And that is the sole reason for it.
We also believe, though, that in addition to that,
that the data that we have been able to collect thus far
indicates that problem the best we can do on background on a
vehicle, on a fifty-thousand mile vehicle, is in the area
of two-tenths to six-tenths, maybe three-tenths to six-tenths,
somewhere in there. That is probably the best we will be
able to do to get it down. And it looks like it will probably
stay there.
So those two items would greatly reduce our risk
of not being able to make it.
MR. GRAY: Do you have any feel at all about the
risk that you would have with just the California standard as
it exists now, the two gram, the durability vehicle . . .
MR. BUIST: That is very difficult to assess at
this point. At this point in time we have roughly one year,
twelve months, maybe fourteen months to be ready, approximately
a year from now that people, manufacturers will be starting
78 or '80 certification durability. In that year we have
to get our confidence level up to an acceptable point to us
to start the durability program. Right now it is not there,
and we do not feel we have the feasibility across the total
product line right now to get there, but in a year we hope
to.
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MR. GRAY: Do you anticipate a need for different
hardware to meet this requirement as compared to the existing
six gram requirement?
MR. BUIST: Yes, of course.
MR. GRAY: Could you elaborate on the kinds of
different technology that you think will be used?
MR. BUIST: We are anticipating maybe more use of
dual canisters, more than one canister per vehicle; possibly a
different type of charcoal; additional sealing in the
carburetor area will undoubtedly be required choke shaft
seals, carburetor-to-air cleaner, different type of seal
there, possibly. That is the kind of approach.
MR. GRAY: Do you see the problem being any more
difficult for your light duty trucks and medium duty trucks
as compared to your light duty vehicles?
MR. BUIST: In trucks they have their own little
unique situation in that the fuel tank configurations are
different than passenger cars; fuel tanks are located on some
trucks behind the driver's seat, other trucks they are way in
the back, or they are in the quarter panel or the truck panel.
There are different situations for trucks that
probably will require more hardware, but probably essentially
the same kind of hardware. Maybe trucks will require dual
canisters across the board that is just as an example
where passenger cars may not; maybe only unique passenger cars
would require dual canisters.
MR. GRAY: We have often heard it argued that the
exhaust system heats up the fuel tank on light duty vehicles
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because of the limited space available to put a fuel tank. I
would guess that on some light duty trucks that that problem
is not as significant.
Is there any situation where, that you can think of
where the control might even be easrier for light duty or
medium duty trucks?
MR. BUIST: No. One does not come to mind. I think
that the hardware we are looking at to get from six to two
would probably with the exception of canister sizes in
relationship to fuel tanks and the number of fuel tanks on
trucks in a lot of cases there are fuel tanks, auxiliary
tanks will probably dictate a canister change, but the
same type of seals will be used.
MR. GRAY: Is it fair to say that when all of these
differences are considered that it is not a significantly
more complex technical problem with light and medium duty
trucks as compared to the spectrum of light duty vehicle
problems?
MR. BUIST: We did not address that issue in the
statement.
MR. GRAY: If you do not feel comfortable making
a judgment at this time, I think a follow-up submittal would
be appreciated for sure.
MR. BUIST: I think the fact that we did not make
the judgment or address the issue in this statement answers
your question.
CHAIRMAN JACKSON: Oh, you don't think it is. I
see.
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MR. GRAY: I see.
MR. BUIST: It is not flagged out in the statement.
CHAIRMAN JACKSON: It's not that big a deal. I see.
MR. EPPEL: The things that are a big deal to us
are addressed in the statement.
MR. GRAY: I am sorry. I misunderstood what you were
saying.
This is not specifically covered in your statement
the subject is and let me press on it a bit if I may.
In discussing the concept of line crossing, you
indicate there is no basis for concluding that the deterioration
factor generated under a procedure permitting line crossing
is any less meaningful than one obtained in the absence of
line crossing. That is on Page 4 at the bottom.
To get a situation where one vehicle would line
cross and another would not, the former vehicle would have
to have higher emissions. Is it reasonable with respect to
evaporative emission control technology in the physical
process to conclude technically that the influence of the
evaporative emission levels would not, could not have any
influence on the deterioration characteristics of, say, the
charcoal in the canister, the amount of . . .
MR. BUIST: I do not think it is related to charcoal
in the canister. We are afraid it is related to plain
variability. We suddenly line cross at 45,000 miles or 50,000
miless we're in trouble. That is the whole point I am trying
to make, that line crossing would eliminate that last minute
risk, and also make it consistent with exhaust emissions.
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MR. GRAY: I understand that point associated with
the risk of certifying or the risk of losing a durability
vehicle, but what I am asking is: For two vehicles, one with
a higher emission level than the other, the former with a
higher emission level which line crossed for I guess it is
somewhat independent of whether or not it line crossed for
the question (sic) two vehicles with different emission
levels.
MR. BUIST: From the beginning?
MR. GRAY: Yes, from the beginning. Is there any
reason to believe that they would have the identical same
slope, which for evaporative emissions would give you the
same additive deterioration factor? In other words, does . . .
MR. BUIST: I still do not understand your question.
MR. GRAY: Does the evaporative emission level
influence the slope of deterioration?
MR. BUIST: I do not understand.
MR. GRAY: Would the evaporative emission level
influence the deterioration characteristics, the deterioration
factor?
MR. BUIST: It would influence your factor; greatly
influences your end result or the factor you get.
MR. GRAY: Would you think that a vehicle that had
higher evaporative emissions would have a higher deterioration
factor initially at higher initial evaporative emissions?
MR. BUIST: I do not think you can generalize that,
because we have concluded that DF's are very sporadic. You
can run ten cars and get ten different DF's, some plus, some
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minus, some zeros. I do not think you can generalize the
statement.
MR. GRAY: So, based on your experience, you do not
feel that you can correlate the deterioration factor to the
initial emission levels? Is that a fair conclusion?
MR. BUIST: Yes, I think so.
CHAIRMAN JACKSON: Mr. Buist, would you characterize
the state of technology with regard to evaporative emission
control as existing to meet the 2.0 gram per test standard,
but in need of optimization?
MR. BUIST: Our objective to meet a two gram standard
our design objective is to somehow get a tight handle on
what vehicle background levels are, and then hopefully between
background levels and some minimum level of background fuel
system, the combination of those two, hopefully will be less
than one gram. That is our design objective.
The thing that makes that difficult is that for
every design engineer that has to work with a vehicle to
develop a two gram level, he has to be confident that he knows
what the background is on his vehicle so that every time he
runs a test he knows what piece of that or he can assume what
piece of that total is background, and that has been very
difficult for us. Background has been jumping around on the
development vehicles.
MR. EPPEL: Could I comment for a minute? I think
you are asking for an exercise in semantics. The basic issue
is, is there something there that is going to allow people to
get certified? You have to make a judgment. And whether you
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characterize technology as existing but in need of optimization
or whether you characterize it as non-existent, to me is
irrelevant. The question is, can people get certified and
using what is available now and using what can be reasonably
expected to be available in the future. That is the agency's
judgment. And whether we characterize it one way or the other
doesn't really matter. It seems to me you have to look at
the data you have; you have to explain away the data that we
might have to the contrary; and you have to justify the fact
that your data, and our data "explained away," if we have
them, can sustain a finding that enough vehicles could be
certified to satisfy the demand that people in California
in this case, or nationwide in the case of the 202 (a) decision
will have automobiles when they want to go buy them. It is
as simple as that.
CHAIRMAN JACKSON: Let me ask you this, without
characterizing your non-response: Do you feel like you are
going to use any new or different technology to certify for
1980 to two grams per test?
MR. BUIST: Short of not having a system, Mr. Jackson
I guess I would say it is possible we will need new technology.
But we do not have the system today, so that is hard to answer.
CHAIRMAN JACKSON: What is your projection based on
that you can certify two grams?
MR. BUIST: I do not understand.
CHAIRMAN JACKSON: What are you basing it on? You
certainly have shown a great deal of confidence of your
ability to do it. What is it based on?
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MR. BUIST: It is based on our ability to get from
today's six gram level to two, and just one year from the time
we have to do it our confidence level is not as good as it
should be but it is at least at the point where we anticipate
that with a little help in reduction in risk we probably
could get there. And we are going to try.
CHAIRMAN JACKSON: But is that as a result of using
some techniques that you have not described here?
MR. BUIST: No. It is as a result of working with
prototype pieces of hardware like I described, sealing various
areas and trying those in the SHED, going to different types
of canisters or putting dual canisters on, trying different
purge rates, et cetera. And I guess we have concluded the
data we have today makes us feel that it is reasonable to expect
to get there a year from now with a little help, with greatly
reduced risk.
CHAIRMAN JACKSON: And the little help you are
asking for in terms of these conditions is basically to reduce
the risk associated with the variability, I guess you would
say, in the measurement technique?
MR. BUIST: Right.
CHAIRMAN JACKSON: But not necessarily any question
or concern about the technology itself?
MR. EPPEL: To reduce the risk so that in our
judgment, anyway, then you can make a finding consistent with
what the statute requires you to do. We are telling you what
we think we need in order to have an acceptable confidence
that we can supply vehicles to the public and meet this standar
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CHAIRMAN JACKSON: But you have no question at all
if we were to grant the waiver that you would be producing
cars for sale in California in 1980?
MR. BUIST: I do not have the confidence to answer
that question right now. We are going to try to be ready.
CHAIRMAN JACKSON: Hive you made any judgments in
the corporation about what percentage of the model line would
be available?
MR. BUIST: I am not aware of that judgment.
MR. EPPEL: We told you, these are risks. Who knows?
Maybe the risks will all g6 our way and we'11 have a hundred
percent of our products and everybody will be happy.
CHAIRMAN JACKSON: What I am trying to get at is
the characterization of the risk in other words, how much
of a risk is it? Are we talking &bout a substantial risk?
I mean, to make the recommendation that you have with the
potential impact it could have would seem to characterize
the risk as very minimal in ray judgment, that you are fairly
well confident that you can meet the two gram standard,
because to make a recommendation as you have done here without
that with the obvious consequence of not being able to
sell cars in California in 1980 would be fairly dubious.
MR. BUIST: I would say the risks are substantial
without the two recommendations.
CHAIRMAN JACKSON: Without the two recommendations,
which account for
MR. BUIST: You asked me to put a number on what
"substantial" is, and I can't.
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CHAIRMAN JACKSON: But those two recommendations
account for the variability associated with testing in
the SHED as opposed to the risk that you won't be able to
come up with technology that you think is a necessary
requisite?
MR. BUIST: They are tied together, technology and
variability.
CHAIRMAN JACKSON: I was just saying, if it was
test-related variability or if it was car-related variability.
MR. BUIST: It is both. I indicated that it is
both. We are trying to get rid of the car variability, a
piece of it. That is
CHAIRMAN JACKSON: That is separate from the "fliers"!
MR. BUIST: Fliers could be caused by the way the
SHED was run, or could be caused by the variability in a
vehicle, maybe the carburetor didn't act the way it should
have or something. It could be either one.
CHAIRMAN JACKSON: And you have not failed to
include in the list that you gave the panel earlier any other
control techniques that you might consider for 1980?
MR. BUIST: Well, if you are asking, "Did I miss
one piece of hardware that may be on for 1980," yes, I probably
did. But the basic approach for 1980 is to seal the vehicle
up. Ideally, that is what we would like to do. We would
like to be done to where we would worry about nothing but
vehicle background but that's an ideal approach. Hopefully,
we would love to get there someday.
CHAIRMAN JACKSON: So that is the technology we are
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talking about?
MR. BUIST: Yes.
CHAIRMAN JACKSON: Sealing of the
MR. BUIST: The fuel system.
CHAIRMAN JACKSON: Sealing the apertures that would
permit evaporation of gasoline . . .
MR. BUIST: That is the name of the game.
CHAIRMAN JACKSON: And the only other issue is
background?
MR. BUIST: Yes. Now, to get it sealed on one
test is one thing; to get it sealed for all vehicles and
make the vehicle operate properly once it is sealed is
another. That is what takes time.
CHAIRMAN JACKSON: Havevyau projected any costs
associated with your configurations that will meet the two
gram standard in 1980?
MR. BUIST: No, I am not aware of a cost projection
for that.
CHAIRMAN JACKSON: Can you make any judgments about
whether the $25 cited in the Exxon study is reasonable or
unreasonable? Is that an upper limit?
MR. EPPEL: The $25, was that an RP retail
price equivalent number? What kind of number was it?
MR. LIEFERMAN: It was supposed to be the cost
increase to the consumer for buying a new vehicle so equipped.
MR. EPPEL: On a particular vehicle, an average
vehicle or
MR. LIEFERMAN: Across the board
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CHAIRMAN JACKSON: An across the board
MR. GRAY: It was an extreme range. It ranged from
one dollar to, in one case, twenty-five dollars that man
had a fan.
MR. LIEFERMAN: Of the six vehicles, the lowest
was two dollars and the highest one was twenty-five dollars.
The others were in between there.
MR. EPPEL: I think the problem we are having is
we do not keep numbers that way. I guess we could give you
the retail price equivalent cost of what a six gram system
is.
MR. BUIST: I think we have indicated in the past
that six gram per passenger car was around seven. Per trucks
it was around 18, and the difference is dual, additional
canisters.
MR. EPPEL: As to the rest of it, I think that what
Don was saying is that we have, not yet established a system
so that the finance people can account for -the costs and
spread them across the product line and come up with a retail
price equivanlency.
MR. GRAY: Do you see that there is any possibility
that you will need an under hood ventilating fan?
MR. BUIST: That is the last thing in the world we
want.
MR. GRAY: It seems to me that that is the most
significant cost increment. And I was just wondering if
there is . . .
MR. BUIST: We are doing everything in our power not
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to have an under hood fan.
CHAIRMAN JACKSON: That is not a part of your
technological approach?
MR. BUIST: oh, it is there. And I suppose if we
need it
CHAIRMAN JACKSON: It is available, then?
MR. BUIST: I do not know if it is available.
MR. GRAY: You do not anticipate having
MR. BUIST: But you talk about under hood fans
we have looked at them, but their ability to operate on a
reasonable, reliable basis, we have not been able to develop
one that is acceptable to us.
MR. GRAY: But do you anticipate having to use
them? Do you think that the other techniques that are
available in the spectrum of ways to seal the system, et
cetera . . .
MR. BUIST: I do not anticipate at this point that
we will need an under hood fan.
CHAIRMAN JACKSON: Have you developed any data,
developmental data or other data that relates to technology
to meet the two gram standard that is not available to EPA?
MR. BUIST: We submitted data last December in
the annual report that I am sure, as I recall, addressed
two grams. We submitted a letter to Mr. DeCaney in September
addressing two grams specifically.
CHAIRMAN JACKSON: I would ask then that any such
data that you may have in your possession now that you would
go ahead and forward it for our consideration in this
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proceeding.
MR. BUIST: Data since our last submittal?
CHAIRMAN JACKSON: Yes. No repeat data.
It may be also appropriate to characterize the
technology that you use with regard to the vehicles that the
data is from.
MR. BUIST: Very good.
CHAIRMAN JACKSON: Thank you very much, gentlemen.
Please proceed.
MR. JONES: I would like to introduce myself. My
name is Bill Jones. I am representing American Motors.
My function is Manager, Emissions and Energy Standards.
Addressing the proposed 1980 evaporative emission
standard of two grams per test,American Motors Corporation
necessarily agrees the California evaporative emission
standard of two grams per test for the 1980 model year
constitutes a more stringent standard than the applicable
federal requirements. On the other hand, this standard
is not consistent with Section 202 (a) of the Clean Air Act,
specifically as respects the technological feasibility of
the standard within the lead time available; and,therefore,
the Administrator must deny the waiver.
We believe that we have demonstrated good faith
toward achieving low SHED emissions levels. We were among
the first in the industry to demonstrate a completely
functional SHED installation that meets the requirements of
both California and the EPA. We have two SHED's fully
operational at this time.
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Our position is that insufficient lead time remains
to comply with a standard of two grams per test by the 1980
model year, and is based primarily on the following two points:
There has been inadequate opportunity for American
Motors to commit engineering manpower and equipment to this
task due to the difficulty and the short lead time allowed
for the development of systems to meet the standard of six
grams.
The imposition of the more stringent and complex
durability requirement for the 1979-1980 model years will
delay our development efforts.
I am going to give you a candid look at our emissions
control development results, our evaporative emissions control
development results.
I am not holding anything back here, although I am
not giving specific data; I am giving figures here which we
are encouraged by, but I will get to that.
Development of our systems to control evaporative
emissions for 1978 began in January, 1976, and by May, 1977,
the program is essentially 90 percent complete. During this
period of 16 months our SHED testing capabilities have been
expanded and almost totally committed to the 1978 program.
Our achievements in evaporative emissions development to date
have allowed us to bring the level of emissions as determined
by the SHED test for the pre-1978 vehicles from an average
of about 15 grams per test down to the range of three to five
grams per test. In fact, recent development work on a few
stabilized vehicles has been in the range of one to three grams
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per test, which is very encouraging to us.
The best result achieved to date is 1.1 grains on a
two gram development system on a stabilized vehicle. A 1978
system on this same vehicle tested at 3.3 grams. This in
effect is a sixty-seven percent reduction, but still a long
way from the zero emissions level required to assure
compliance with the more stringent durability factor and the
unknown test and vehicle variations encountered in the
certification program.
The proposed standard of two grams for 1980 passenger
cars, light-duty trucks and medium-duty vehicles requires a
vapor tight fuel system. Despite close intensive work with
our carburetor suppliers we have not been able to demonstrate
that a completely sealed carburetor is available for the
1980 model year. In view of this, we are forced to conclude
that current non-fuel injection technology does not support
a standard of two grams in 1980.
We believe the non-fuel hydrocarbon allowance of
one gram per test for emission data vehicles fails to make
the task of a standard of two grams significantly easier
to achieve, because we are required to determine deterioration
factors on "stabilized" vehicles with emission levels that
are below the standard for the equivalent of 50,000 miles.
If a compelling need for a standard less than the current
standard of six grams per test is determined, we believe that
a standard of four grams is the lowest that available
technology will permit. In addition, we would recommend that
all bests be conducted on stabilized vehicles until more facts
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have been developed to define the magnitude of this non-fuel
hydrocarbon background.
A little bit about an area that impacts our lead
time, but I recognize is not a genuine item for discussion
here today but since it does not impact our lead time, it
is the '79 bench test.
The California procedures amended October 5, 1976
required us to develop a bench test for the determination of
deterioration factors under some rather severe conditions
for the 1979 model year and beyond. On February 11, 1977,
the ARB issued Manufacturers Advisory Correspondence No. 76-3,
which clarifies somewhat the bench-test methods for determina-
tion of the deterioration factor for the 1979-1980 model
years.
This correspondence outlined the specific considera-
tion to be contained in a proposal submitted for approval of
a durability bench test. The "acceptable component test
schedule" was useful in defining the test fixtures required
for the bench test. This equipment as described involves
special orders and long lead times.
It was obvious to American Motors after analysis of
this test specification that use of this test constitutes a
more difficult standard for 1979 and will consequently delay
our efforts to concentrate our resources on the proposed
1980 standard of two grams.
In the past it has been the policy of the federal
and state agencies to prescribe detailed, proven and
universally applied test procedures to show compliance with a
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regulated standard. The ARB bench tests are a departure from
that more desirable and fair policy. The ARB proposal allows
approval of varying proposals by individual manufacturers,
and this could result in unfair advantage to some manufacturers
In addition, after a new test procedure has been
regulated, a manufacturer needs at least 18 months of lead
time for its orderly application to certification vehicles.
Since American Motors is unfamiliar with this
type of testing, and none of our components have ever been
subjected to it, we have no assurance that all components
will pass the test or what types or degrees of failure we
will encounter. Failure of any one item would, in most cases,
result in emissions in excess of the standard, which would
require further design modifications to the system plus
additional verification testing. Many components are special
order items requiring development/design/tooling and therefore
are long lead-time items. Also, correlation of bench test
results with actualvehicle experience is another time consuming
effort that must be considered.
Although American Motors is in agreement with the
bench test concept and recognizes its technical superiority
to the 50,000 mile durability vehicle test, we realize that
it may place a more stringent requirement on our 1979 and
later model year programs. This would require system
modification and verification testing and would further dilute
our efforts to develop systems to meet a new standard of two
grams per test for the 1980 model year.
We submit that lead time evaluations for establishing
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the consistency requirement for waivers under Section 209 of
the Clean Air Act. must be based on the evidence introduced at
the waiver hearing. As the EPA indicated by its thorough
discussion on considerations of lead time in the May 20, 1975
waiver decision, lead time is measured from the date of the
EPA's waiver decision; and, clearly, under the Act, a more
stringent California requirement is not final or enforceable
until the waiver is granted.
In this particular case, the waiver was not granted,
finalizing the California requirement until at least January
17, 1977; and, in fact, it is still open to question because
of the EPA's consideration of it at the January 27, 1977
hearing. This week we were notified that it was signed.
So this is a little out of date, but not by much. Days are
hardly an improvement.
Again, the law states that reasonable lead time
must be provided. In this instance, reasonable lead time is
not being given under the proposed schedule of requirements.
To summarize our position, American Motors urges
the EPA to deny the requested waiver for the standard of
two grains per test for the 1980 model year for the following
reasons:
A more stringent requirement has been proposed by
California which does not withstand the test of Section 202
(a) .
The standard of two grams per test SHED requested
by the waiver is not technologically feasible within the
lead time remaining, even with the addition of one gram for
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non-fuel hydrocarbon background on emissions data vehicles.
We have applied our engineering capability to its
fullest extent and, consequently, have demonstrated good
faith effort toward achieving low SHED emission levels.
California requires, but has not prescribed, a
detailed,proven and universally applied test procedure for
the 1979 model year for the determination of deterioration
factors. This will result in a dilution of effort in develop-
ing evaporative emission systems which will meet the proposed
standard of two grams per test.
That is the conclusion of my remarks.
MR. GRAY: Your-principal position regarding the
two gram per test standard was that insufficient lead time
in your opinion at this point remains to comply with that
standard by 1980 model year. Is that to say that with
additional lead time that you feel that the two gram per test
standard is feasible? I am trying to clarify exactly what
your position is in that regard.
MR. JONES: We do not have answer as far as the
technological feasibility of the two grams per se.period with-
out putting a year on it. We are not used to thinking in those
terms. We have always had a deadline.
You would have to give me the other part of the
question in order for me to analyze that. I just cannot give
you a definite answer. You have not given me a total question.
Every standard has a date. I do not know of any standard
that doesn't have a date.
MR. GRAY: Your statement here was that your
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position is that there is insufficient lead time for that
level of control for 1980 model year
MR. JONES: Correct.
MR. GRAY: And my question is, can you meet that
level for 1981 model year, 1982 model year at what point
is there sufficient time in your judgment for American Motors
to meet that level?
MR. JONES: We have been encouraged by some very
recent test results down around the one to three gram level.
I would be naive to say that there is sufficient evidence at
this date that would allow us to meet the two gram standard.
We depend on some of the major automotive companies, two >of
whom you have heard this morning, to supply us with carburetors,
We cannot move past their technology in carburetor sealing.
We depend on them to supply us carburetors that will meet
adequate sealing requirements.
MR. GRAY: Can you buy from either, or are you
constrained to«buy some carburetors from one and others from the
other?
MR. JONES: We are not constrained from purchasing
we can purchase from either, and all that we want, too.
CHAIRMAN JACKSON: That would leave you with an
obvious option if you wanted to meet the standards in 1980,
then.
MR. JONES: Well, yes. There are other considera--
tions as well. When you have been dealing with a certain
carburetor manufacturer, you are not going to switch to another
carburetor manufacturer because Carburetor Manufacturer B offers
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you the seal that you desire from Carburetor Manufacturer A,
because there is also the other side of the coin called
"exhaust emissions," and it may be superior there. So there
are many considerations to take into account. You don't just
jump from one carburetor manufacturer to another carburetor
manufacturer. You usually work with them in concert, hoping
that they will develop",; because the incentive is there for
them to develop
CHAIRMAN JACKSON: Aside from the' fact that you
don't do that as a general practice, is that the case indeed,
that carburetors you get from Ford have an emission problem?
MR. JONES: I cannot answer that question. I do not
understand it.
CHAIRMAN JACKSON: You said that the reason you could
not jump from one carburetor manufacturer to the other is
because of emissions. You said tailpipe emissions were a
consideration.
MR. JONES: Yes.
CHAIRMAN JACKSON: We were asking with regard to
sealing technology why you couldn't buy from one or the
other that would obviously have the sealing technology. You
said the reason you couldn't do that was because of emissions.
Does that mean that one of those manufacturers has a carburetor
that has emission problems?
MR. JONES: No, that does not mean that there is an
emission problem. I am saying that it is a consideration. I
do not even want to use the word "problem." It is a
consideration, a vital consideration.
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CHAIRMAN JACKSON: AH right. Now, aside from the
fact that you generally do not want to change carburetor
manufacturers for one reason or another, why couldn't you?
MR. JONES: Ideally and theoretically there is no
reason why we couldn't. It would incur extra costs. There
would be considerations of that nature recertification,
recalibration, working with a new supplier, that does take
additional lead time in some cases. They are not insurmount-
able problems. Certainly, we have the flexibility to do as
you say, as long as we do it in an orderly fashion.
MR. GRAY: Going to control levels, you make a
statement that the best results achieved to date is 1.1 grams
on a two gram development system on a stabilized vehicle.
You say that a 1978 system on the same vehicle tested at 3.3
grams. What was the system on the '78 vehicle?
MR. JONES: It is what we are certifying.
MR. GRAY: What was the basic system? Could you
elaborate on the components of the system, the characteristics
of it? I would like to establish a base line so I can then
ask you what changes did you make.
MR. JONES: I am not intimately familiar with all
of the hardware that constitutes our '78 system, although I
could reference you to our '78 Part 1. It is in there.
But I recognize you want to ask the next question,
and maybe I would be more prepared to answer that one than
going through and listing the base line. Maybe if I gave you
the differential that would satisfy you.
MR. GRAY: Let me ask you one question before you
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address the differential, then, in the absence of specifics
on the base line.
Can you generalize and say that that system, that
'78 system, is a similar system that you would use on all
your '78 vehicles, or is there a significant variation among
the vehicles?
MR. JONES: We have a basic system, and we have some
vehicles due to plumbing problems that we have had to intro-
duce some rather drastic measures that we would not like to
think are long-term measures as far as evaporative control.
We have had to include on some of our larger
engine vehicles, where space under the hood does not permit
a real neat plumbing arrangement, liquid traps in our line.
This is something that when we experienced very high SHED
results from some of our V-8 engine installations, the only
way we could bring the vehicle down to our engineering target
of around three grams is to make sure there wasn't any liquid
in the lines. This required a trap, because we could not re-
route the lines. The lines were high cost real estate areas,
and it would require longer lead time than we had for the '78
program. In other words, we had some Band-Aids on our '78
system that I would not like characterized as things that
we would be projecting on out into the future.
MR. GRAY: What lines are you referring to? The
purge lines?
MR. JONES: Yes. We were overloading our canisters
not just to the normal route, but with actual liquid.
MR. GRAY: Can you characterize the percent of your
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vehicles that would be subject to those special fixes?
MR. JONES: Primarily our V-8 engine installations,
which constitute approximately 15 percent of our vehicles.
MR. GRAY: Is it fair then to say except for those
cases, that the other vehicles employ the same system?
MR. JONES: Yes.
MR. GRAY: Now, if you could address the question
then, from that basic system, what changes did you make to
achieve that level of 1.1 grams per test?
MR. JONES: The difference between the 3.3 and the
1.1, it was a new, high absorbent charcoal in the same size
canister; charcoal in the air cleaner, the ring? and an
improved choke shaft seal. Those were the three prime
and only ones that I sun aware of.
MR. GRAY: How many test results did you have? I
mean, this is a very encouraging level, and I am just wonder-
ing how many tests . . .
MR. JONES: That is a single car.
MR. GRAY: A single test result, or is that an
average of several tests?
MR. JONES: That is an average of three or four
tests, to my knowledge, on a single car.
MR. GRAY: Have you see any noticeable change in
the vehicle's performance characteristics as a result of this
charcoal in the air cleaner? Or do you think it impacts
MR. JONES: We have not been able to take this car
out and give it an adequate performance test or hot fuel
handling test or any of the other normal performance tests that
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AMC 324
we would conduct on a finalized system.
MR. LIEFERMAN: Have you evaluated the exhaust
emission characteristics with that system?
MR. JONES: To my knowledge, there is no significant
interaction at this point on that particular car with exhaust
emissions. We do not run as many exhaust emission tests as
we want because it is primarily an evap test car. But we
do have data that does not suggest that we are losing on
that car. We have other cars that say we are on other
systems.
MR. GRAY: That kind of leads me back to the ques-
tion that I asked you earlier and really did not press on,
and that is lead time. Those changes, in and of themselves,
seem pretty simple on the face, at least. If those changes
could do it for your basic system, why would it require
significant lead time to incorporate those kinds of changes?
MR. JONES: First of all, those changes still do
not meet our internal taraget of less than a gram, closer to
zero grams. We could not, with the limited number of tests
that we perform, with any kind of confidence, say that if we
were able to attain a 1.1 gram on all of our cars, that that
would be good enough for us to make a two gram standard.
MR. LIEFERMAN: Because of variability? Why would
that be? Because of test variability?
MR. JONES: It would be, first of all, because of
our limited resources. Our risk is very high on our cars
because of the fact that we have a limited number of tests
that we perform. So we want to have a less than one gram.
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preferably between zero and a half a gram, engineering target
to assure us of reasonable success in certifying. Certainly
I cannot expound any more than the two people that have gone
ahead of me today on the variability question. That
variability question is so huge and has so many at least
four different aspects that I am aware of that we, quite
honestly, cannot afford the time to break it down into its
logical components and attack each one of these. We will
therefore dial down our internal target. That is why I say
1.1 is not good enough for us. We will therefore dial down
our internal target before we say that we have a vehicle that
is certifiable.
MR. GRAY: With the additional year or so left
before you have to commit to a particular configuration, I
guess, for a 1980 model year vehicle, do you think at this
point, in order to be responsive to such a need, that you would
follow upon this particular approach?
MR. JONES: Oh, sure. We are going to work very
hard. And I would hope that my presentation today would
convince you that we are on the right track. But even being
as candid as I can, it is a very large mountain, and I think
it would be naive to expect us to be able to climb that
mountain from where we sit today.
CHAIRMAN JACKSON: Do you see it as a lead time
argument then as opposed to technological feasiability
argument?
MR. JONES: I would put the emphasis on lead time.
The statement, I believe, is technological feasibility in the
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lead time remaining. And my emphasis is "in the lead time
remaining," yes.
MR. GRAY: But if you are able to successfully
employ these three basic changes to your current '78 system,
and you were reasonably successful, as you were at least
on this one vehicle, is there any reason why that kind of
technology, if it was sufficient, could not be employed for
1978 excuse me, for the 1980 model year?
MR. JONES: We would probably use this technology
if the standard were four grams, which we are proposing, if
the lower standard is required for 1980. It is a matter of
going very fast In *78 you have a six gram standard. We
are 90 percent of the way home on that. You are coming back
with an order of technology that is saying two grams. We are
going to use even if the standard were three grams or four
grams, we would use exactly the same knowledge, because it
is the best we have. I cannot push this point any further.
We are not holding back on this technology. This
will be implemented with a lower standard, hopefully not two
grams, by the 1980 model year. The two gram looks like more
than this technology can support. And that is our position.
MR. GRAY: As far as this kind of technology, there
is not a lead time set with respect to 1980, it is more a
question of whether or not this technology will give you the
control you need to reduce your risk for your full product
line. I mean, you just said, as I understood it, that your
plan in any case would be to have these kinds of technology
changes incorporated on your 1980 model year vehicles.
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MR. JONES: I must have misrepresented my position
here. Sorry if I gave you that impression. What I am saying
is that if there was a different standard not the two
gram but/ say, a four gram I took a hypothetical case,
and I should not have done that. I recognize now that I just
confused the issue, and I did not mean to do that. I said
if there was a four gram standard or a three gram standard
or a two gram standard with a one gram background for all
whether it be durability or 4,000 miles we would employ
the same technology, because it the best we have available to
us.
We have a lead time problem at the two gram level.
The technology does not support nor does the lead time remain-
ing support the two gram between now and 1980, and we have no
plans right now to put that technology in if the standard
were to remain at six grams.
MR. GRAY: Fair enough. Independent of the standard,
then, is it feasible for you to introduce these three changes
in your '78 system by 1980 model year, irrespective of what
level
MR. JONES: It is not even feasible. Because
realistically looking at the conditions that we are working
under today, with an undefined bench test and with
MR. GRAY: I said independent, though, of the test
procedure itself, could you make those changes change the
carbon in the canister, put a seal on the choke shaft, and
charcoal in the air cleaner?
MR. JONES: We certainly could put the charcoal
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I cannot commit to the improved seal I do not know what the
exact lead time is for 1980 on the choke shaft seal without
consultation with the carburetor suppliers.
There are more than one carburetor suppliers if you aro
talking all of our vehicles here. But the charcoal is, we
have potential capability of getting that in by 1980.
But as far as the sealed carburetor, where the choke
shaft is the primary problem, I cannot answer that question
today. I do not know the exact lead time. It is a critical
issue, and I will not treat it glibly here.
MR. LIEFERMAN: On this one vehicle that did show
this 1.1 gram average level, you said three or four tests,
to your knowledge, were run on that vehicle. Do you know
if any of the tests run on that vehicle exceeded two grams?
MR. JONES: I am not conversant with the individual
data points on that. I am sorry, but I cannot answer that.
I can supply that information to you if it was critical to
the hearing, but I do not have it with me.
CHAIRMAN JACKSON: That, and all other data which
you may have that has not been supplied to the agency or CARB
which would relate to the two gram standard.
MR. JONES: We do not have much, but what we do have
we will be glad to submit.
CHAIRMAN JACKSON: We appreciate that. Thank you
very much.
MR. GRAY: I have one last question. Do you see any
technological difference between the control of your light-
duty trucks, medium-duty trucks put them in a category by
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themselves and your light-duty vehicles? American Motors
does have at least a medium-duty truck, don't they?
MR. JONES: Yes.
MR. GRAY: The answer is, yes, you do have a medium-
duty truck, or, yes, you see a difference in technology?
MR. JONES: Yes, we see a difference in technology.
MR. GRAY: Could you elaborate on why?
MR. JONES: Not very well. All of our medium-duty
vehicles are Wagoneers and Cherokees and trucks are Jeep
products. They employ a different enough fuel system that
the technology we have and we tend to bolt on to these
vehicles do not achieve the same level of control. We are
not smart enough today to say that it isn't just due to our
inexperience with testing. But there seems to be an order
of magnitude of difficulty, and I do not know if that is
directly transferrable into technology. It may be that the
more tests you run and the longer you develop the system,
you will find out some of its idiosyncrasies. Because of the
lead time constraints we are under right now this is a factor
we are not able to look at this to the degree that we
look at our passenger cars. Everything has its order of
priority. It's a very tight situation.
We wished that when we worked out something for,
let's say, our V-8 Matador we could just run to the Cherokee
and say, "Okay, guys, bolt it on, it's going to work." But
it does not happen that way. And I just wish we were smart
enough to know why.
MR. LIEFERMAN: Do your light-duty trucks for '78
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have essentially this basic system that your passenger cars
have for '78?
MR. JONES: Yes. Our Jeep C-J's, yes.
CHAIRMAN JACKSON: What kind of emission levels are
you getting from them relative to the
MR. JONES: I knew you were going to ask that. I
don't know the answer. I will supply that, though. That is
a question, but I do not have the answer.
MR. LIEPERMAN: You did mention the non-fuel hydro-
carbon background being a problem. Have you run any tests,
background tests on vehicles?
MR. JONES: We ran a few early tests, and we came
to the conclusion that we were wasting more time trying to
isolate the background than we could afford to developing our
'78 system. So we had to abandon that rather interesting
but semi-nonproductive type of testing.
MR. LIEFERMAN: I guess I am a little surprised.
You bring up the fact that it is an important thing to define,
the magnitude of the non-fuel
MR. JONES: It is important.
MR. LIEFERMAN: level.
MR. JONES: Yes. And when you are talking a two
gram standard it is vital that you are as intelligent about
that. And that is why I feel that some of the smaller
manufacturers are not going to have a handle on that as quickly
as maybe some of the larger manufacturers, and thus be able
to use it to their advantage.
MR. LIEFERMAN: You see any reasons why your
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particular vehicles might have different background
characteristics than vehicles of other manufacturers?
MR. JONES: No. I do not think we are unique in the
background area. In fact, I would venture to say we are
probably very similar.
CHAIRMAN JACKSON: Mr. Jones, do you know that the
application of these three control techniques that you have
suggested above the '78 package would not result in your fleet
meeting the two gram standard?
MR. JONES: I guess I can only answer that by saying
that we have no data that would suggest that if we were to
attempt to certify at a 1.1 engineering target level that
we could not make the standard. I certainly think that that
is an extremely risky situation, one in which we would not . .
CHAIRMAN JACKSON: It wouldn't be the most desirable
situation?
MR. JONES: Yes.
CHAIRMAN JACKSON: If the waiver were granted, what
would your company do?
MR. JONES: Basically, we would not be able to do
anything more than we are doing right now, and that is getting
'79 vehicles cleared out before the 1980 situation was
addressed, getting the bench test defined, getting our '79
products moved out.
If some breakthrough in technology was achieved as a
result of your passing the waiver and putting the heat on,
I could only speculate that this technology would be available.
We certainly would jeopardize any orderly fashion of
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certification for 1980. It would be a very chaotic although
we are learning to live with chaos it would certainly be
a very chaotic series of events close to certification. We
are right now, '78, going to be delayed in our certification
in California for at least one engine family that I am aware
of, and that is without the problems that you are talking
about here today. So I could only be quite candid with you
and say that if you pass the waiver, this one engine family
is down a single configuration now, and we would probably
lose that engine family, we would probably lose other vehicles
from our other engine families, and it would probably hurt
very bad.
CHAIRMAN JACKSON: But to say what you would do,
is it fair to say that you would attempt to incorporate the
three items of control technology on your cars to see whether
you could certify or not?
MR. JONES: I guess we have not assessed that point.
We are hoping that some other standard is available in 1981.
At this point, to say what I do not think those three are
enough.
I do not understand your question.
CHAIRMAN JACKSON: I think you understood it. Your
response indicated that you did. Your point being that you
are not sure that that is enough.
MR. JONES: We are pretty sure it is not enough,
because if it was enough we would like to say that it is.
CHAIRMAN JACKSON: If your differentials are
consistent with that which you showed us and your testimony,
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in terms of *78 certification data, wouldn't that be a fairly
strong indicator of your ability to do that? In other words,
you have shown here a *78 package with these three additions
to it, and you have a 1.1 gram per test result. And if you
showed certification of the rest of your vehicles with the
*78 package being somewhere in the neighborhood of three,
wouldn't that be a fairly strong indication that you could
get to below two with those vehicles?
MR. JONES: That might be an indication, but it
certainly is not realistic when one looks at the calendar.
CHAIRMAN JACKSON: Thank you very much, Mr. Jones.
I would like to remind the witnesses for tomorrow
that we will attempt to start at 9:00 a.m.
We will convene the hearing today and reconvene
tomorrow morning at 9:00 a.m.
Thank you.
(Whereupon, the proceedings adjourned at the hour
of 3:00-O?clock p.m., to be reconvened at the hour of 9:00
o'clock a.m.,Wednesday, May 18, 1977.)
oOo
THOMAS R- WILSON
CERTIFIED SHORTHAND REPORTER8
/iir\ Ma.siB4fMl.3098
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