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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 III
Pages 334 - 557
May 18, 1977
Reported by:
JERRY R. SMYTHE
THOMAS R. WILSON
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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.
KARL HELLMAN
Chief, Technology and Evaluation Staff
U. S. Environmental Protection Agency
Washington, D. C.
EPA STAFF
DANIEL M. STEINWAY
Attorney-Advi sor
U. S. Environmental Protection Agency
Washington, D. C,
JAMES MC NAB, III
Attorney-Advi sor
U. S. Environmental Protection Agency
Washington, D. C.
MARILYN J. HERMAN
Program Analyst
U. S. Environmental Protection Agency
Washington, D. C.
oOo
THOMAS R. WILSON
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INDEX Page
CALIFORNIA AIR RESOURCES BOARD 338
THOMAS AUSTIN
Deputy Executive Officer, Technical
KINGSLEY MACOMBER
Chief Counsel
DONALD DRACHAND
Chief, Engineering Branch
GARY RUBENSTEIN
Manager, Special Projects Section
FORD MOTOR COMPANY 391
DONALD A. JENSEN
Director, Automotive Emissions and Fuel
Economy Office
EUGENE WEAVER
Emissions Planning Associate
HELEN PETRAUSKAS
Attorney
GENERAL MOTORS CORPORATION 426
EDWIN E. NELSON
Assistant Director of Automotive
Emission Control
RICHARD I. PETERSEN
Attorney
HAROLD W. SCHWOCHERT
Staff Engineer, Automotive Emission Control
KENNETH HANSON, Staff Engineer, Chevrolet Motor
Division
AMERICAN MOTORS CORPORATION 495
WILLIAM C. JONES
THOMAS R. WILSON
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Page
530
WILLIAM J. MARTIN
Staff Engineer, Vehicle Emissions
AUTOMOBILE IMPORTERS OF AMERICA 543
DONALD SCHWENTKER
Attorney with Busby, Rivkin, Sherman, Levy
and Rehm of Washington, D. C.
MOTOR AND EQUIPMENT MANUFACTURERS ASSOCIATION 552
MARC FLEISCHAKER
Attorney with Arent, Fox, Kintner,
Plotkin and Kahn of Washington, D. C.
oOo
INDEX (Cont'd)
INTERNATIONAL HARVESTER COMPANY
THOMAS R. WILSON
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CARB 338
CHAIRMAN JACKSON: If you are ready, Mr. Austin, we
are ready.
MR. AUSTIN: Thank you.
This next portion of my prepared statement deals with
the exhaust emission standards for 1979 and subsequent model
year passenger cars, light-duty trucks and medium-duty
vehicles.
The primary purpose in implementing the 1979 and
subsequent model-year standards for passenger cars, light-duty
trucks, and medium-duty vehicles is to impose the maximum
feasible control of hydrocarbon and NO emissions upon these
lighter-duty vehicles so long as such control continues to be
cost-effective. CO standards were based on the level of
vehicular CO control we estimate will result in the eventual
attainment of the Ambient Air Quality Standard for CO. This
level is not, in our opinion, the lowest technologically
feasible CO standard. Our proposed standards for 1979-1982 can
be found in Table III of the prepared statement.
In making our waiver request on this item, we are
acting under the assumption that Congress will amend the Clean
Air Act so as to require less stringent standards than those
adopted by the Air Resources Board. Because of lead time
considerations, however, it is necessary for EPA to consider
our waiver request now, even though current federal statutory
standards are more stringent than the standards the ARB has
adopted for 1978 and subsequent model years.
If California is ever to achieve and maintain the
Ambient Air Quality Standards for oxidant, nitrogen dioxide and
THOMAS R. WILSON
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CARB 339
particulate matter, we will need to require all hydrocarbon
and NOx reductions from motor vehicles that are technologically
feasible and economically reasonable. We do not believe,
however, that the maximum feasible control over CO is either
necessary or reasonable in California. Control of CO beyond
that level required to meet the Ambient Air Quality Standards
will probably increase the costs of compliance and may reduce
the feasibility of achieving the lowest possible NO standards.
Compromises in three-way catalyst system design to achieve a
3.4 grams per mile CO standard may very well increase NO
X
emissions. This may occur due to either oxidation of ammonia
generated over the three-way catalyst bed to NO in a clean-up
oxidation catalyst for CO control, or it may be caused by
changes in the air/fuel ratio schedule to provide improved CO
control at the expense of NOx< Cost increases could be caused
by the addition of secondary air injection and oxidation
catalysts needed for CO control at the 3.4 grams per mile
level but unnecessary at the 9.0 grams per mile level.
If Congress decides to carry over the 1977 federal
standards of 1.5 hydrocarbon, 15 CO and 2.0 grams NO to 1979
and later years, then it is obvious that California's 1979
and subsequent emissions standards are more stringent. If,
however, Congress mandates a .41 hydrocarbon, 3.4 CO and 2.0
grams NO^ standard, we believe that our package is still more
stringent overall, even though the California CO standard is
numerically higher.
Although the ARB is convinced that a 0.41/3.4/1.0
grams standard for HC/CO/NO is feasible by 1980 and 1981, we
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CARB
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do not believe that this low CO standard will be necessary for
California. We believe that the Administrator should consider
California's emission standards as a total package, one that
is in fact more stringent than any federal package being con-
sidered for the same time period.
At this point, I would like to mention an error made
in adopting our hydrocarbon standards for 1980 and subsequent
model years. It was our intention to adopt hydrocarbon
standards that, for 1970-type emission control systems, were
the equivalent of 0.41 grams per mile total hydrocarbon
content. The 1980 HC standard is a non-methane standard, and
should be 0.39 grams per mile in order to properly reflect
the 90% control required by the Clean Air Act. In addition,
we understand that if EPA adopts a non-methane hydrocarbon
standard, it may be at the 0.39 grams per mile level. In an
April 25, 1977 letter to EPA, I requested that this issue be
considered at the present waiver hearing, since it constitutes
the correction of an error in drafting rather than a
tightening of the standard from its current 1977 level. Were
we to actually enforce a 0.41 non-methane hydrocarbon standard
in 1980, this would constitute a relaxation of the current
requirement and would undoubtedly be less stringent than the
hydrocarbon standard which Congress will require EPA to enforce
for 1980 and subsequent model years.
Parenthetically, I might add that as a practical
matter this point may be irrelevant, since there's some
likelihood that the .41 total hydrocarbon standard will be
mandated by Congress for the 1980 model year, in which case
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CARB
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California would be ineligible for a waiver of a .41 non-
methane standard. We have to have the federal standard
enforced on California cars.
In summary, we believe that the California standards,
as a package, not only represent a needed step in improving
California's ambient air quality, but are more stringent
overall than standards presently under consideration by
Congress for the same time period.
For passenger cars, the 1979 exhaust emissions
standards will be carried over from 1978; they will remain at
0.41 hydrocarbon/9.0 CO/1.5 NO . But for 1980, the NO
X X
standard will drop to 1.0 grams per mile, and these standards
will be carried over to 1981. As Table IV illustrates,
American Motors, Audi, BMW, British Leyland, Chrysler, Ford,
General Motors, Nissan, Isuzu, Maserati, Mazda, Porsche, Saab,
Toyota, Volkswagen, and Volvo have certified vehicles at or
below 1.0 grams per mile NO for 1977. Saab and Volvo are not
only below 1.0 grams per mile, but are well below 0.4 grams
per mile NO due to their use of three-way catalyst systems.
X
The fact that nearly all major manufacturers have
already certified passenger cars at levels well within the
1980 standards, in itself, indicates that neither technologi-
cal feasibility nor lead time problems are involved with meet-
ing these standards. However, we do not expect manufacturers
to use current systems to meet the 1980 and later standards.
At the November 1976 Board meeting, most manufacturers indi-
cated that they would rely on three-way catalysts as a more
fuel efficient approach to achieving low NO levels. ARB
5 R. WILSON
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CARB
342
Staff Report 76-22-2(a) details why we believe that sufficient
time exists to allow the introduction of three-way catalyst
systems in California by 1980.
Although it was not raised as a significant issue
at our November 1976 Board meeting, there have been questions
raised regarding the feasibility of three-way catalysts due to
the rhodium supply issue. We have thoroughly investigated
this question, and have concluded that there is sufficient
rhodium available to supply not only all California vehicles,
but all vehicles nationwide.
We will be happy to supply additional information
for the record on this subject if any manufacturer argues
that rhodium availability creates a feasibility problem with
respect to any standard for which we are requesting a waiver.
At the November 23, 1976 Board meeting on these
standards, Ford Motor Company clearly indicated its belief
that the standards were feasible for the 1980 model year.
Other manufacturers were less positive regarding their
capability; however, most did not claim the standards are
infeasible for 1980.
Projected hardware costs, including first costs of
research, development, and tooling, which would lessen or
disappear entirely when systems went into large-scale pro-
duction, ranged from $0 for those manufacturers whose existing
systems needed only slight modification to meet the standards,
to a high of $506, British Leyland's upper limit.
Analysis of the manufacturers' estimates led the
ARB staff to conclude that the 1.0 grams per mile NO standard
5 R. WILSON
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CARB 343
would cost an average of $75 per car. This is due in part to
a cost savings associated with the use of three-way catalyst
systems, since air injection systems may no longer be required.
Many manufacturers believed that there could be a consumer
gain in fuel economy associated with the use of three-way
catalyst systems.
For 1979, light-duty trucks will be split into two
weight classes on the basis of inertia weight: 0-3999 lbs.
and 4000-5999 lbs. In 1981, medium-duty vehicles of similar
inertia weights will be combined with these light duty truck
classes, since the ARB staff believes that emissions control
capability depends on inertia weight rather than on rated
gross vehicle weight.
The lighter classes of light duty trucks and medium-
duty vehicles are almost identical to passenger cars in design
and weight, and, therefore, these vehicles should be able to
meet the passenger car standards with the application of
existing technology already being used on passenger cars, such
as three-way or oxidation catalysts, exhaust gas recirculation,
and air injection.
The ARB contends that there is no technological
feasibility or lead time problem; the systems exist and are
already successfully in use. In order to avoid excess certifi-
cation costs, however, light duty trucks will not be required
to drop the 1.0 grams per mile standard for NO until 1981.
Otherwise, they will have to comply with the same standards
as passenger cars.
The heavier classes of light duty trucks, those with
THOMAS R. WILSON
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CARB 344
inertia weights ranging from 4000-5999 pounds, will be
required to meet standards of 0.50 grams per mile hydrocarbon,
9.0 CO and 2.0 NO in 1979 and 1980, and standards of 0.50
x '
hydrocarbon,9.0 CO and 1.5 N0x in 1981.
At the October workshop, all manufacturers expressed
the belief that they would be able to comply with the light
duty truck standards for 1979 except that American Motors
expressed concern that it might not be able to comply with a
0.41 hydrocarbon standard. A look at Table IV will show
that American Motors has actually certified models in the I-TC
engine family at 0.41 grams per mile HC for 1977.
The 1981 standards for all light duty trucks could be
met with further development and application of existing
technology. American Motors said that it could use air
injection, EGR, and a warm-up oxidation catalyst at a hardware
cost of $80, and $0 projected maintenance cost. Ford would
use a combination of air injection, exhaust gas recirculation,
an oxidation catalyst and a three-way catalyst at a cost of
$250 and a maintenance cost in the range of $30-50 for replac-
ing oxygen sensors. Toyota projected no additional costs to
make its air injection, EGR, oxidation catalyst system comply
with the 1981 standards.
Medium-duty vehicle standards will be carried over
from 1978 to 1980 to avoid excessive certification costs,
since these vehicles have been forced to comply with new
standards every year for the past three years. For the same
reason, ARB has decided to delay for two years the plan of
breaking down medium-duty vehicles by inertia weights and
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CARB
345
combining them with light duty trucks. For 1979 and 1930, we
used a hybrid system, so that light-duty trucks are broken
down into classes by inertia weight, but medium-duty vehicles
are still rated by gross vehicle weight. In 1981, however,
medium-duty vehicles of 0-3999 lbs. and 4000-5999 lbs. inertia
weight will be combined with the corresponding classes of
light-duty trucks and will have to meet the same standards.
Medium-duty vehicles of 6000 lbs. or greater will still have
separate standards. In 1981, these standards will be
0.60 hydrocarbon/9.0 CO grams per mile and 2.0 grams per
mile NO .
x
Manufacturers suggested the use of systems similar
to those they would use to meet the passenger car and light dut;
truck standards to meet the standards on medium-duty vehicles.
In fact, we believe that the same technology which has been
successfully applied to passenger cars can be applied, with
little further development, to light duty trucks and medium-
duty vehicles, especially to those of the same inertia weights.
Passenger cars in the same weight class as the lighter light-
duty trucks and medium-duty vehicles are currently meeting much
lower standards than those the latter vehicles will have to
meet in the future. Therefore, the Air Resources Board staff
believes that there are no problems of either lead time or
technological feasibility involved with meeting these standards
The ARB staff's cost/effectiveness estimates for the
1979-1981 standards based on manufacturers' cost estimates
are presented for your information. For passenger cars, we
estimate that the 1980 reduction to 1.0 grams per mile NO
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CARB
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will cost about $0.73 per pound of NO control, with a fuel
X
economy benefit of 5%. The estimated costs for trucks are
somewhat higher, both because the manufacturers' cost estimates
included the cost of possible chassis redesigns to accommodate
the new catalyst systems, a cost which should quickly be
amortized, and because the staff's estimates of possible fuel
economy penalties for light-duty trucks and medium-duty
vehicles are probably exaggerated. We have hopes that these
manufacturer anticipated fuel penalties will disappear prior
to the 1979 model year. For light-duty trucks the staff
believes the 1979 split standard of 0.41 grams per mile and
0.50 grams per mile will cost $2.86 per pound of hydrocarbon
reduced, with a possible fuel economy penalty of 5%. Elimi-
nation of the fuel penalty reduces this to $1.07 per pound of
hydrocarbon contro. The 1981 light-duty truck and medium-
duty vehicle standards should cost about $0.75 per pound NO
reduced and $0.70 per pound of hydrocarbon plus NO reduced
over the 1979 levels, with a possible fuel economy penalty of
5%. These costs are well within the range of other ARB
programs.
That concludes my prepared statement. I am assuming,
Mr. Jackson, that you do not want me to get into the testimony
we prepared on the issue of idle mixture adjustability.
Do you wish me to cover that now, or are we going to
wait on that until this afternoon?
CHAIRMAN JACKSON: I think we ought to go ahead and
hear your testimony on the maintenance.
MR. AUSTIN: Okay. Fine.
5 R. WILSON
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CARB
347
Commencing with 1980 model passenger cars and 1981
model light-duty trucks and medium-duty vehicles, the Air
Resources Board will require manufacturers to design the idle
mixture adjustment mechanisms on their vehicles, if any, to be
either essentially non-adjustable or limited in adjustability
so that the vehicle will meet the required emission standards
at any adjustment possible. The precise language for the
regulation was developed in consultation with vehicle manu-
facturers, especially Ford, as a response to the tampering
problem recognized by the Environmental Protection Agency,
ARB, and the manufacturers. At the ARB's December 1976 meeting,
when the adjustability requirement was adopted, no manu-
facturer indicated its opposition to the regulation. Although
some manufacturers indicated that they would prefer to volun-
tarily develop tamper-resistant designs, no manufacturer
indicated an inability to comply with the proposed regulations.
The only potential issue we see was raised by
American Motors last October, dealing with American Motors
dependency on vendors for carburetion. However, the Board
adopted Ford* s proposed language regarding nonadjustability
with the intent of alleviating lead time problems such as those
raised by American Motors. Since American Motors did not
comment on the revised regulation, we can only assume that its
lead time problem has been resolved.
General Motors and Ford both have indicated that they
would comply with the ARB's nonadjustability regulation by
1980. As a matter of fact, both manufacturers have indicated
that they will voluntarily incorporate tamper-resistant designs
THOMA8 R. WILSON
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CARB
348
on their vehicles prior to 1980.
One other potential issue is the question of whether
ARB's regulation is inconsistent with Section 202(a) of the
Clean Air Act because it incorporates a design standard.
In the first place, we do not believe that this is
an appropriate issue for discussion at a waiver hearing. The
Administrator has pointed out many times in the past that his
discretion regarding consistency is limited to an analysis of
whether California's regulations require duplicate testing by
the vehicle manufacturers. Clearly, California's non-
adjustability regulations do not require duplicate testing,
since any system designed to meet California's requirements
will also meet all applicable federal requirements, of which
there are none.
Even if the Administrator does believe that this
issue should be considered, we disagree with the contention
that the ARB's regulation is a design standard. The non-
adjustability regulation established performance requirements,
such as: "the idle mixture adjustment mechanism must not be
visible, even with the air cleaner removed." Manufacturers
can comply with these requirements in any number of ways, and
are not confined to specific designs by the ARB's regulations.
Furthermore, one method of complying with the nonadjustability
requirement is to design an idle mixture adjustment mechanism
with a range that allows the vehicle to meet the emission
standards at any setting. This concept is identical to the one
EPA is applying to 1980 model motorcycles, and we fail to see
how it could be construed as inconsistent with the Clean Air
THOMAS R. WILSON
CtKWlBO SHORTHAND fWPORTfM
(41S)
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CARB 349
Act.
In summary, the ARB's regulations regarding non-
adjustability of the idle mixture were adopted after consulta-
tion with the vehicle manufacturers, and were not opposed by
any manufacturer when adopted by the Board. We believe them
to be technologically feasible within the lead time remaining
and consistent with the federal regulations.
I might offer a brief amount of additional testimony
on this item.
Based on our discussions with the vehicle manu-
facturers recently and a review of some of the statements that
have been prepared, there's still some confusion regarding
the basis for the standards which were established, par-
ticularly for light-duty trucks and mediums-duty vehicles. I'd
like to have Gary Rubenstein just briefly clarify our basis
for the standards, since that, we think, is something you are
going to hear about later today.
MR. RUBENSTEIN: One of the major complaints,
apparently, by some of the vehicle manufacturers deals with
the ARB's distinction of light-duty trucks and medium-duty
vehicles on the basis of inertia weight rather than on the
basis of gross vehicle weight rating. These vehicles are in
fact emissions tested and must demonstrate compliance with
the emission standards at their inertia weight and not on
the gross weight rating.
The inertia weight is determined based on loading
the vehicle to 300 pounds over its curb weight in the same
manner as passenger cars are. The higher horsepower values
rHOMAS a WILSON
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CARB 350
reflect a real difference in frontal area, not because of
structure designs or any particular purpose. So, we see no
real justification for establishing different emission
standards within this class of vehicles based on gross weight
rating rather than inertia weight.
The objective of the Board's position was to develop
standards that would require essentially the same emission
control technology that is used on passenger cars but which
when applied to light-duty trucks, because of their higher
inertia weight can't be reduced that significantly because of
the purpose they are designed to serve, would still comply
with the emission standards. And the standards were upgraded
in that manner.
MR. AUSTIN; Our position on this is it makes no
more sense to test trucks at their gross vehicle weight than
it does to test passenger cars at their gross vehicle weight.
Since the inertia weight, based on the studies that the
Department of Transportation has done and EPA has done, the
inertia weight is more representative of the actual loading
conditions the vehicles can experience in typical customer
use. And, therefore, it's the emission control during those
conditions that we are most interested iri.
MR. RUBENSTEIN: One source of information that we
used in developing those standards was data presented to us by
General Motors where they tested several light-duty trucks or
medium-duty vehicles on both 4,000 pounds and 6,000 pounds
inertia weight with no distinction between changes to engine
calibration.
THOMAS R. WILSON
CERTIFIED SHORTHAND MPOKTEM
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CARB 351
The average ratio of the 6,000 pound emissions to
the 4,000 pound emissions for those vehicles tested were
1.24 for hydrocarbons, 1.54 carbon monoxide, and 1.21 for
NO . The 1.24 ratio that GM found for hydrocarbons compares
with the ratios of our standards which range from 1.20 to
1.28 for the different classes.
The 1.21 ratio for NO^ compares with the ratios of
1.33 all the way up to 2.5 in applying our standards.
It is obvious that the hydrocarbon and NO standards
are, if anything, more generously ratioed in the ARB regula-
tion than is demonstrated by GM's test data. The carbon
monoxide standard is not ratioed because we did not believe
that a .41 or comparable hydrocarbon level that there would be
in fact any problem in terms of CO emissions because they will
be well below the nine gram standard.
Some of the manufacturers have — Again reading
testimony that will apparently be presented later today —
questioned some of these assumptions, and the basis for some
of their questions are, in our opinion, frequently invalid and
sometimes misleading. In particular, a statement that
General Motors is apparently planning on presenting later
today indicates that a comparison of assembly-line test data
for 1977 light-duty trucks and passenger cars which are
identical engines and, as they stated, have identical emissions
control hardware, have a hydrocarbon ratio at a projected
50,000 miles of 2.08 as compared to the calculation of 1.22
for a California standard.. They suggest that instead of
having a truck standard of .5 or ,6 grams per mile compared to
THOMAS R. WIUION
BttTWMW •HOBTHAtfO RVPORTCm
(41ft
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CARB
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.4 hydrocarbon standard it should be as high as .85.
The basis for their statement appears to be very
wrong. First of all, the 1977 trucks and cars were obviously
designed to meet two different emissions standards. Although
they have the same emission control hardware, it's obvious
that General Motors air injection EGR oxidation catalyst
system has two distinct levels of control, since those same
systems were used for all passenger cars to comply with a
.9 hydrocarbon standard in 1976, and then with minimum modi-
fications allowed to meet a .4100 carbon standard in 1977.
It appears to us that the 1977 trucks are using the configura-
tion that was comparable for the 1976 passenger cars.
The second problem we have with that assumption that
they made is that they projected those emissions to 50,000
miles, using certification deterioration factors. This is a
point we raised with General Motors before, but apparently
they ignored us.
The 1977 light-duty truck certification data was
based on durability tests and run on 1976 model light-duty
trucks which used certification fuel with a higher lead con-
tent. The 1977 passenger cars' deterioration factors were
based on using a 1977 certification fuel. A more correct
analysis of the effects of the difference between passenger
cars and light-duty trucks on deterioration can be obtained by
looking at comparable truck families and passenger cars in
1976 when the same certification fuel was used. That analysis
indicates that there is no significant difference between the
truck and passenger car deterioration factors. As a matter of
THOMAS R. WILSON
ewmmto #ho*twand
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CARB 353
fact, if anything, the truck factors are slightly lower than
the car factors.
We questioned, I guess, General Motors' intent in
continuing to raise this issue after we brought it to their
attention and after we explained to them why we have such
problems with it.
A third item in that paragraph — Which, by the way,
this entire paragraph deals with hydrocarbon emissions
primarily, ratio of hydrocarbon emissions — GM contends that
this could be affected by a 50 percent increase in the horse-
power. We question this assumption, again based on data
GM presented to us, which indicates that the increase in
horsepower between the 1977 and 1978 truck procedures affects
carbon monoxide and NO emissions but has no significant
effect on hydrocarbon emissions. We again question their
statements on the establishment of our standards and on the
appropriate level for those standards.
MR. AUSTIN: We would be happy to answer any
questions you might have on our testimony.
MR. GRAY: In your testimony this morning, you did
not mention specifically your requirement that vehicles
certified must make the same percent emission control at
sea level as compared to 6,000 feet altitude.
Could you elaborate upon your requirement there, and
in particular — perhaps it's just an updating. There has
been mention in the Ford testimony to be presented later
that CARB has presented a public notice of its intent to amend
this part of the regulations. It's a point of confusion, at
rHOMAS a WILSON
3tBTICI*D •HOUTHANO RIKMTTiM
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CARB 354
least on my part right now, and could you give us an update on
the situation there, and perhaps more specific questions could
be directed.
MR. AUSTIN: I believe we already have sent out the
staff report on the proposed change.
MR. RUBENSTEIN: That's right.
MR. AUSTIN: The earlier language was of some con-
cern to a number of manufacturers because it appeared to be
very broad and could have been construed to have required
altitude compensation systems on exhaust gas recirculation
valves, on spark advance, on all systems which affect
emissions.
We decided that we didn't have any justification
for asking for that degree of altitude compensation; that it
appeared to us that the basic problem that we found with
vehicles operating at high altitude has to do with the mixture
enrichment that occurs as the air density drops at altitude
and then the carburetor continues to meter fuel based on the
velocity of the air rather than the mass of the air. We felt
that we were going to get the CO control we need only by
making sure that enough compensation was built into the
vehicle to maintain lean enough bare fuel ratios at high
altitudes for CO oxidation to occur, both within the engine
and within the exhaust system if it was being controlled in
the exhaust system. Our principal problem at altitude is
CO; therefore, it was CO control we were interested in.
We have come up with some hew language which now
replaces the old language, with the old language reading:
i R. WILSON
•HOHTkAW ftlPOMTlftS
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CARB 355
"Evidence must be supplied that the emission control systems
on certified vehicles provide approximately the same percen-
tage control of emissions at altitudes of up to 6,000 feet as
these systems provide at sea level." We are replacing that
language with the following language: "Evidence shall be
supplied that the air fuel metering system, or secondary air
injection system, is capable of providing sufficient oxygen
to theoretically allow enough oxidation to attain the CO
standard at barometric pressure equivalent to those expected
at altitudes ranging from sea level to 6,000 feet elevation."
That language may, on the surface, sound somewhat
complicated. When you think about it, basically all we are
asking the manufacturers to do is demonstrate to us that with
the air densities that will occur at 6,000 feet they are still
going to end up with a stoichiometric exhaust mixture, or
leaner, ahead of the oxidation catalyst for a catalyst-type
system; or, if they are talking about a thermo reactor
system, they are going to have to show us that the air pump
is going to deliver sufficient oxygen to get the exhaust
leaner than stoichiometric at altitudes of 6,000 feet so that
there will be a potential for CO control.
MR. HELLMAN: Will this requirement require addi-
tional testing by the manufacturers?
MR. AUSTIN: No, We are only asking for evidence to
be supplied, and in the new language we talk about demonstratin
that there is theoretically enough oxygen to do the job. As
far as we are concerned, that will be sufficient. We don't
think this is a complicated enough issue to require any
rHOMAS R. WILSON
SMTIFIfD IHORTHAND MflMtCM
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\ CARB 356
special testing.
If we can just look at the air injection rates or
look at the kind of compensation systems that are built into
the vehicles, we should be able to make a good judgment based
on a paper analysis. We don't think testing is required.
We have done a little bit of our own testing. We
took our Volvo to Denver and ran some tests on it, and we found
that with the typical kind of three-way catalyst system that's
at least being used by Volvo the system continues to be self-
compensating, up to 5,000 feet at least, and we understand
that that particular system is self-compensating up to 14,000.
We don't see,any particular problem in being able to make
those kind of judgmentswithout test data on other systems.
MR. GRAY: If you published a notice to change your
regulation, and as I understand it from Ford's testimony you're
actually planning to consider what specific wording would be
used to replace the current wording at your June Board meeting,
do you think it's reasonable that, considering the potential
for change here, that this is a topic we can thoroughly
explore at this hearing?
MR. AUSTIN: Yes, because the new language is
nothing more than a clarification of the way we interpreted
the old language. Transcripts of our Board meeting where we
adopted the language, I think, will bear that fact out. We
made numerous statements on the record that we weren't
expecting absolute compensation of all systems, and we stated
our intent very clearly to concentrate on the air-fuel ratio
issue.
THOMAS R. WILSON
IBBTIPIBO SNOHTHANO WOKT1M
Wa-SIMMSVMO*
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CARB 357
We continued to have — We tried to modify the
language at the last Board meeting. That still presented a
problem for some of the manufacturers. Their basic concern
was: we understand the way you are going to interpret this,
we have heard what you said, but this is something we are
going to have to live with for a long time and we may not be
dealing with the same people three or four years from now.
They requested that we modify the language so it becomes more
apparent that we are only talking about the systems which
affect CO emissions and in fact only those systems which
significantly affect CO emissions. And that's basically what
we have done.
MR. GRAY: But you haven't yet adopted that new
specific language yet? The true situation that you have just
described hasn't changed yet; has it?
MR. AUSTIN: No, it hasn't changed yet, but the new
specific language right now is our interpretation of the
existing language.
MR. GRAY: Have any of the manufacturers had an
opportunity to review and comment upon that new language?
MR. RUBENSTEINs It was sent to them several weeks
ago. I don't know whether or not they have reviewed it in
that time.
MR. AUSTIN: Mr. Gray, I should point out to you that
the publichhearing at which this new language will be con-
sidered has been noticed for June 6th, prior to the closing
date of this hearing's record. Therefore, we will be able to
submit to you prior to the closing date for the record of this
THOMAS R. WILSON —
StftTtmiO SHORTMAMO WPONTIM
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CARB 353
hearing the final version of the language on altitude compen-
sation. We are not expecting any significant opposition to
this. The Board has delegated the authority to conduct this
hearing to the Executive Office. I'll be conducting the
hearing, and I — Oh, the Board's indicated that they will
consider delegation, in which case I will be conducting the
hearing.
We talked to a couple of auto manufacturers who told
us they have no problems with any of the items on the agenda,
but you may want to get into that with the manufacturers later
today.
MR. HELLMAN: Mr. Austin, you indicated in your
testimony that there were a large number of vehicles today
which met the proposed passenger car standards, including the
1.0 NO level. However, in your testimony, you indicated that
X
it was ARB's opinion that the same systems that were used on
the vehicles that you indicate currently meet those levels
would not be used in the future period.
Is it your contention that there is something that
prohibits a manufacturer from using the types of systems that
already meet the standards for the future?
MR. AUSTIN: No, there's nothing that prohibits a
manufacturer from using current systems. It's just that the
current systems don't allow achievement of the one gram NOx
standard with as high a level of fuel economy as more advanced
systems will, such as the use of three-way catalyst. There's
going to be a lot of incentive for the manufacturer to go to
more sophisticated systems for that very reason, since fuel
THOMAS ft WILSON
SHTICICO tHQRYHANO NtPOIITIBa
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CARB
359
economy penalties associated with the current systems are
going to make it tougher for them to meet the federal fuel
economy standards and they end up restricting the model mix
they are able to offer. Because of that incentive, we
expect them to move into the direction of going with three-way
catalysts for one gram NOx level, and essentially most of the
manufacturers indicated they planned to do that at our Board
meeting in November.
MR. HELLMAN: Yes, but just to clarify it: you
would agree there is nothing prohibiting this technology from
being considered available to meet those standards?
MR. AUSTIN: I would agree with that.
MR. RUBENSTEIN: I think we should also add, while
we are on the subject, that two manufacturers that are omitted
from the list, both Honda and Subaru, although neither of
them have certified vehicles for local standards to date, have
indicated to us that they could in fact comply with the .41,
.9, and one gram standard by 1980.
MR. HELLMAN: The technology that you indicated
that would more probably be used in today's technology includes
systems that you refer to as three-way catalyst systems.
Could you describe for the record what goes into
making up one of these systems?
MR. AUSTIN: The three-way catalyst system used
by Saab and Volvo, for example, on current 1977 California
production vehicles looks identical to the 1976 system which
these manufacturers use, in that they are still using a
monolithic underfloor catalyst. There has been a change in
3 R. WILSON
•MOflTMANO fttPOftTIM
Uitl tillUBimi Mil
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CARB
360
the composition of the noble metal that's deposited on the
surface of the catalyst, a change that probably has a lead
time of at least several days associated with it.
Other than that, they have had to install an oxygen
sensor in the exhaust system and equip the fuel metering
system with a feedback mechanism to respond to inputs from
the oxygen sensor to continually adjust the air/fuel ratio
back and forth so that the average is very close to stoichio-
metric .
Similar systems to the Volvo and Saab system are
undergoing certification right now on 1978 cars. Some of
these systems are using carburetors which incorporate an
oxygen sensor, feeding back a signal to a controller, which
then modulates a metering rod in the carburetor to raise and
lower a metering jet to modulate the air/fuel ratio that way.
The basic catalyst is indistinguishable externally
from the current generation catalyst. The only difference
being the bath that the wash coated substrate or the alumina
pellets are put through.
Other three-way catalyst systems will incorporate
clean-up oxidation catalysts, and in that case there will be a
more significant change in the configuration of the system;
in that an air pump will still be required and more than one
catalyst required in the system, with the first catalyst
operating in the three-way mode, working to reduce both
hydrocarbon, CO, and oxides of nitrogen, and a clean-up
catalyst following that catalyst to do additional oxidation
on hydrocarbons and CO.
THOMAS R. WILSON
5«OTI#ieo •HOATHM® MPORTUWI
<41t> MtttMMtVMM
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CARB
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MR. HELLMAN: The basic three-way catalyst that you
see for this system is quite similar to catalysts that are in
use today?
MR. AUSTIN: Similar in that —
MR. HELLMAN: Let me clarify my question.
In terms of size and shape and the overall manu-
facturing catalyst and adopting it and putting it on a vehicle,
it's not three times bigger or anything like that?
MR. AUSTIN: That's correct. There is no signifi-
cant difference in the size or shape. In fact, in most cases
the three-way catalyst will be identical to the oxidation
catalyst in most respects. It will quite often be in the same
container, the container will be manufactured out of the same
materials on the same assembly line.
In the case of pelletized converters, very likely
we will see the same pellets being used, manufactured out of
the same materials, using the same manufacturing process, and
the only change will be the treatment that these pellets
receive when they are coated with the active ingredients in
the catalyst. There will be some change in that composition.
MR. HELLMAN: In terms of the fuel metering systems
that you feel will be used in these future systems, would you
classify them as modifications to the conventional carburetor
or totally new carburetors?
MR. AUSTIN: Well, we are seeing both types of
systems being developed, modifications to conventional
carburetors and new fuel metering systems.
For 1978 when we will start to see some carbureted
THOWAS RmSQN
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CARB 362
three-way catalyst systems being sold in California, the type
of fuel metering system would be most accurately described as
a modification to the conventional carburetor. The carburetor
will come down the same assembly line and will be manufactured
using most of the same tooling. There will be some modifica-
tions to the manufacturing process to incorporate the changes
that are necessary to operate the carburetor with feedback
control. There will be, in addition, in some carburetors you
will see an additional diaphragm being added to the carburetor
which will be connected to a metering rod and a vacuum can be
put on top of the diaphragm to cause the rod to be raised or
lowered into a jet. That is kind of like a subsystem that is
being added onto a conventional carburetor, and the basic
manufacturing process will remain unchanged.
We are expecting to see some new fuel metering
systems by 1980, though, at least from some manufacturers,
since starting from scratch many of the manufacturers may
end up with a fuel metering system that is less expensive than
a fuel metering system that results from modification of a
conventional carburetor or it may also have some improved
characteristics from the drivability or fuel economy or even
emission control standpoint. So, it can be done in a number of
ways.
MR. HELLMAN: These modifications to the carburetor
and the new carburetor, do you understand that that work is
development work, is going on right now in the manufacturers'
facilities?
MR. AUSTIN: For the 1978 three-way catalyst cars, we
IR. WILSON
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CARB 363
are expecting to see in California, the development work is
complete. For three-way catalyst cars which are not expected
to be offered for sale until 1979-1980 model years, the
development work is continuing.
MR. HELLMAN: It's underway at the present time?
MR. AUSTIN: Yes.
MR. HELLMAN: And that is part of the reason you
feel that there is sufficient time available to complete this
already ongoing development program that in your opinion seems
to be industry-wide in order to meet the standards that you
propose?
MR. AUSTIN: I think that's a fair statement.
MR. HELLMAN: Thank you.
MR. GRAY: I have a follow-up question upon the
basis of your adjustment ratio between passenger cars and
light-duty trucks and medium-duty vehicles.
As I understand your intent, the standards for
light-duty trucks and medium-duty vehicles are essentially
those levels which you feel would result with the application
of the technology necessary to meet the passenger car
standards; is that correct?
MR. RUBENSTEIN: That's correct.
MR. GRAY: Do you have any other data, other than
the GM data that you referenced, that you were able to use to
make this judgment as to the appropriate factor?
MR. RUBENSTEIN: Data submitted to us by Ford,
which in turn I believe referenced some EPA documents for at
least hydrocarbons at any rate, came to the same general
I R. WILSON
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CARB 364
conclusions. The methodology was somewhat different, because
if you looked at the distinction between medium-duty vehicles
and light-duty vehicles and passenger cars as opposed to
looking at the difference solely of inertia weight, I believe
you can analyze the same data looking for just the effect of
inertia weight, you come to the same conclusion.
MR. AUSTIN: I think we probably should clarify,
though, the statement which Mr. Rubenstein made earlier in our
testimony, that being: if we looked at the GM data, for
example, it appears as though we have set standards which are
going to be less stringent for the heavier weight classes of
light-and medium-duty trucks. When we started working on the
package, it wasn't our intention to do that. But it became
apparent to us that, at least in terms of the support or lack
of opposition that we'd see at the Board meeting when we went
to adopt these standards, and for other reasons, the schedule
that we ended up adopting was reasonable.
But we are not saying today that we believe the two
gram level of NO control,for example, on a 6,000 test weight
truck is equivalent to a one gram level of NO^ control on a
3500 pound truck. The truck meeting the two gram standard
probably is going to require less emission control than the
truck meeting the more stringent standard, and I think there
is data from both truck experience and passenger car
experience that would support that.
X think that right now,, for the standards that we
are adopting for 1981 and subsequent model years, we are
probably still going somewhat easier on the heavier truck
THOMAS ft WIL80N
3*RT|PH0 SHORTHAND RBfOKTfM >*.«> ......
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CARB 365
classes than we are on the lighter truck classes.
One of the concerns we had in setting these
standards had to do with applying the light-duty-type
emission control to the heavier classes of vehicles for the
first time. There were arguments made by International
Harvester and others that there may be problems associated
with the use of catalysts, for example, on some of the heavier
categories of trucks which may not exist on some of the
lighter categories.
International Harvester, for example, was concerned
that the use of catalysts on the heavier classes of trucks
would probably result in more severe thermal problems, more
severe temperature problems than on lighter trucks.
Because of those problems, they felt they'd have to
choose a different catalyst location. They may have to
locate the catalyst more rearward in the vehicle, and since
the emission test is a cold start emission test that more
rearward catalyst location could very well reduce the amount
of control they could get from that catalyst by increasing
the time between the start of the test and the catalyst light
off when it starts to work efficiently on hydrocarbon and
carbon monoxide.
That was one of the considerations that went into
our establishment of the standards. International Harvester
didn't argue that it was impossible to use catalysts on the
heavier vehicles. They were just arguing that it may be more
difficult to use catalysts and, therefore, the geometry of
the exhaust system may have to be scproewhat different and that
i a WILSON
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CARB
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geometry may result in a more difficult job of meeting emission
standards than on lighter vehicles.
I think there's probably somewhat greater of a
problem for the heavier classes of vehicles, and the schedule
of standards that we've put together does give the heavier
vehicles somewhat more cushion. It appears to not push the
heavier vehicles quite as hard, but in fact it may be much
closer to equal emission control than would be apparent just
from a superficial evaluation of some of the data that's
available.
It's our intention to monitor how well the heavier
classes do in meeting these new standards and make adjustments
in the future if we find that in fact we can achieve sub-
stantially more control on the heavier classes of light and
medium-duty vehicles.
MR. GRAY: Okay. I guess what I am really pushing
for is any additional specifics relative to the determination
of the appropriate adjustment factor. As I understand it,
the data that you referred to that was at least considered in
your judgment as to the adjustment factor represented several
light-duty GM trucks.
MR. RUBENSTEIN: Yes.
MR. GRAY: Can you tell me how many?
While you are looking for that, may I ask: Is that
information included in one of your staff reports that's been
submitted to the record? If not, would you try to put it in
a form such that you can submit it to tbe record?
MR. DRACHAND: Sure. We qan give you all the
! 8K0dTHA*»B MROtSSft!
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CARB 367
support data relative to the standard setting at the Ford
meeting, the way it was proposed.
MR. RUBENSTEIN: What I am reading from is a presen-
tation which, I guess, was a slide presentation given to us by
Chevrolet Motor Division in November of 1976, and I can just
give you a copy of that.
MR. AUSTIN: We'll submit it for the record. I do
not believe it's in the record either of our own hearing on
this or the record of this hearing yet.
MR. RUBENSTEIN: This was based on tests of three
trucks, three different configurations, and each data point
was in fact an average between two and five tests.
MR. GRAY: As I understand the description of the
test program, there was a baseline test for each of the trucks
running, 4,000 pound inertia weight, no adjustments were made
to the vehicle, the vehicle again was tested at 6,000 pounds.
MR. RUBENSTEIN: That's correct. I don't know which
inertia weight those vehicles were in fact certified to. They
may have been certified to 4,000 or to 5,000 or to 4500.
MR. GRAY: Okay.
Do you have information as to whether or not the
road load was changed on these vehicles from the 4,000 to the
6,000 pound test point?
MR. RUBENSTEIN: It's not on this piece of paper,
but I believe when we discussed it with General Motors, it
was strictly an inertia weight change and there was no change
in — although there was a change in horsepower — I guess I
can't answer the question. I believe that they used the
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CARB 368
horsepower correspondent to the inertia weight.
MR. GRAY: Okay.
To what extent, if at all, were you able to consider
the effect of different N/V — that's gearing of passenger
cars as compared to trucks?
MR. RUBENSTEIN: We've had some amount of trouble
dealing with those comments from manufacturers, since we find
ourselves on one end of the spectrum hearing criticisms that
trucks have higher N/V's and consequently can't meet these
kinds of emission standards and the other end of the spectrum
that good fuel economy axle ratios are too low to meet
California's emission standards. We are not really sure how
the N/V ratio really comes into play. It appears to be very
much model specific and configuration specific, and we were
more concerned with what we thought was a more significant
factor, which was the inertia weight.
MR. AUSTIN: We considered N/V in developing our
standards, and part of that consideration consisted of a
review of some EPA publications that attempted to find and
quantify the effect of N/V on emissions. In particular,
that's been addressed in several technical appendices which
the Administrator has made on passenger car standards, since
that was an issue at several suspension hearings in the past.
It appeared to us, based on both EPA's own analysis and data
which we had reviewed independently, that if there is an
effect, it's not a substantial effect. In fact, it s very,
very difficult to find.
We saw no reason to give special consideration to
1QMA8 ft Wii arm
WW.0 *HORTHANO MPONTiM m
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CARB 369
the relatively small differences in N/V ratio between typical
trucks and passenger cars that exist today. And, so, we did
not make any specific numerical adjustment to any passenger
emission standards based on different N/V's.
MR. GRAY: If you are assuming that same technology
which would be applied on light-duty trucks as would be used
on passenger cars, why do you concede there will be an
expected fuel economy penalty on light-duty trucks?
MR. AUSTIN: Fuel economy penalty compared to the
current light-duty trucks. We are talking about a different
baseline. That's why we are talking about a difference in
fuel economy, I believe.
MR,. GRAY: I realize that.
Does that mean that you anticipate that a fuel
economy penalty will continue to be in effect for California
passenger cars by that time frame?
MR. AUSTIN: By which time frame, 1981?
MR. GRAY: 1980-81.
MR. AUSTIN: No, because by 1981 we are anticipating
a substantial change in the systems used to meet the passenger
car standards. The analysis we did for trucks was based on
the assumption that the current passenger car emission control
systems would be used on trucks in that time frame.
MR. RUBENSTEIN: We did not project that three-way
catalyst would be used on trucks until 1981.
MR. AUSTIN: We are assuming that the trucks won't
go to the more sophisticated control systems until sometime
after 1981. That may not be a valid assumption. If there's
i R. WILSON
SHORTHAND ftEJKMTaM
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CARB
370
adequate pressure to maximize the fuel economy of trucks as
well as cars, we may end up seeing three-way catalyst^, for
example, used on trucks much earlier than we anticipated.
MR. GRAY: Does that mean to say that with the use of
three-way catalyst technology that you would not expect a
penalty for the imposition of these standards as compared to
no standards at all on those trucks?
MR. AUSTIN: I believe that the standards that we've
adopted for trucks can be met without any fuel penalty beyond
that fuel penalty which may be caused by the compression
ratio necessary to run on unleaded fuel. That's a few percent.
So compared to a vehicle that's absolutely optimized for fuel
economy and nothing else and may have exhaust emissions that
are 20 times higher than we are talking about, yes, there may
be a penalty. Maybe it's five percent.
As a practical matter, we expect the penalty to be
somewhat lower than that in the initial years of certification
when heavy trucks use catalysts for the first time, but we
see the potential for that penalty to be reduced or eliminated
as more sophisticated systems are applied.
MR. HELLMAN; Your proposed adopted light-duty truck
standards, do they have any special clauses in them for
vehicles that have four-wheel drive?
MR. AUSTINS No.
MR. RUBENSTBINt There is the same languagethat
EPA has in their truck regulations regarding testing of four-
wheel drive vehicles.
MR. AUSTIN# There is no relaxation of the standards
, i nmi.ui n iii.l .11 I 1111,11. il imih , i Hi I j 1.1.1. i y i.iiiiiiiii|iii j-IJ III in |i(lliwWjW|Wpiwli mjiii ilyuil I|ji.
THOMAS R. WILSON
omtii»i«qi smohthakp
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CARB
371
for four-wheel drive vehicles.
MR. HELLMAN: The difference is in drive line,
gear ratio, and possibly power-to-weight ratio for these types
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of vehicles which can potentially be used both on and off road
have been suggested as a reason why these vehicles should have
more lenient standards.
How do you approach that issue within your proposal?
MR. AUSTIN; The differences in power-to-weight
ratio between the vehicles we are talking about here and
typical passenger cars is certainly not greater than the
difference in power-to-weight ratios between passenger cars
which are all required to meet the same standards, and all
different types and categories of passenger cars have in fact
been certified at California 1977 standards. We are talking
about power-to-weight ratios that vary all over the place;
from very, very low power-*to-weight ratios to very, very high.
The difference between the typical power-to-weightratios of
these trucks and cars is not substantial compared to the
difference that exists between passenger cars.
MR. HELLMAN: It has been mentioned that the transfer
case mechanism and the transmissions used in some four-wheel
drive vehicles may require shifts to be much longer in dura-
tion with the manual transmission vehicle on the test than
would be the case for a passenger car; therefore, hydrocarbon
spiking is & much more severe problem for these Vehicles.
Did you consider that? *
t®. AUSTIN* We didn't specifically consider that
issue. However, hydrocarbon spiking is — the degree of
THOWAt R. WILSON
(MfMW wmmtm
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CARB 372
hydrocarbon spiking, the problem it gives you, is a function
of the type of fuel metering system, the type of emission
control system that you are using on the vehicle. If you
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have an uncontrolled vehicle and you shift it rapidly and
shift it slowly, you may very well see higher hydrocarbon
emissions associated with a slow shift. I think I could
quite easily generate some data to show that inherent penalty
associated with shifting slowly.
However, if I was interested in solving the problem,
I would not run an essentially uncontrolled fuel metering
system and emission control system that wasn't designed to
accommodate hydrocarbon spikes. I would use some kind of
mechanism to hold the throttle partially open on shifts or
allow it to close slowly, and I'd be looking for ways to reduce
the amount of accelerator pump shock that was necessaxyon the
axle after the shift and the working on ways to solve the
problem that way.
A number of manufacturers have indicated that
because of hydrocarbon spiking, they have not beer! able to
offer cars with manual transmissions. But other manu-
facturers — Volvo, for instande, who is meeting the statutory
emission standards in 1977, markets a vehicle with a manual
transmission and has no problem in meeting the standards by
a wide margin; *
So I think it's a problem that theoretically could
be argued to exist for heavy vehicles, but as a practical
matter, can be easily c©ntroli#&,
MR* R0BENSTE1Nj Their*1« al8@ aUdtblr ^.nt- ftldiffis
WOWWI
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CARB 373
this same subject, which is that there are a number of manu-
facturers in California who have only introduced manual
transmission models on some of these vehicles and have not
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introduced automatics because they see certifying an automatic
transmission model in California standards being higher than
a manual transmission.
So, again, the problem seems to be manufacturer
specific and not necessarily due to any lack of technology.
MR. GRAY: Okay. I have one last question regarding
the potential — regarding the concern for potential different
interpretations under your adjustability regulation.
There has been some concern that the Board or the
Executive Officer may be able to interpret in different ways
what special tools are and has other flexibilities for judg-
ment. In regard to how the CARB might interpret those
requirements, I'd like to read a short portion of the Ford
testimony and ask your response to it.
"At the December 14, 1976 hearing, CARB staff
offered the interpretation that, if the recommended
idle air/fuel mixture service procedure called for
removal of the carburetor to perform the adjustment, the
'special procedures' provision would be satisfied.
Ford believes that the 'special tools' provision is
satisfied by a design which permits adjustment only with
a tool not manufactured as a standard hardware item
and not likely to be available to most car owners."
Do you agree that those would be appropriate
interpretations of those provisions, and would they satisfy
THOMA8 R. WH.SON ; 7 "" "" " ?
emttpicc shoMhawo Atiom'tiii
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CARB 374
this CARB requirement?
MR. AUSTIN: We'd have some problem with the
carburetor that could be adjusted with a special tool if the
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special tool was readily available to franchise dealers. If
all that stood between a vehicle being maladjusted was the —
if the only thing preventing the maladjustment was the avail-
ability of a special tool and the special tool was readily
available to a franchise dealer, we'd have a problem with
that.
MR. GRAY: If it also required removal of the
carburetor, then both conditions must be satisfied? The
removal of the carburetor and then a special tool, would that
satisfy —
MR. AUSTIN: If it requires removal of the
carburetor to do the adjustment, and not just if the manual
says removal of the carburetor but if it really requires
removal of the carburetor to do the adjustment, and it
requires a special tool, we'll buy that.
MR. RUBENSTEIN: I'm not sure if it in fact requires
removal of the carburetor that a special tool would be needed
in addition to that. The procedure says special tools and/or
procedures.
MR. GRAY: So you axe saying that if it actually
required the removal of the carburetor to perform the adjust-
ment, in those plain terms, it would satisfv vour requirement?
MR. AUSTINs That's one of the situations that would
satisfy our requirement. That's ncM^ thebonly situation.
That's one of them.
THOMAS RW1W©N
pwiww mmmm mmm-
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CARB
375
MR. GRAY: I understand that, but I wanted to get
nailed down at least one specific solution that would defi-
nitely satisfy the requirement.
v
MR. AUSTIN: That would definitely satisfy the
requirement. In fact, I'm not sure if we have stated this
clearly in the past. But if to adjust the carburetor, one
was required to remove it, we wouldn't be particularly con-
cerned that a special tool was required after that point. As
long as it required carburetor removal to adjust it, it's
fine if a number two Phillips head screwdriver could do the
job as far as we are concerned.
MR. GRAY: Okay. I think that clarifies the special
procedures, at least to the extent that example can.
Let me just.ask: What would be your interpretation
of "special tools"? What would satisfy that particular
provision of the regulation? It essentially says —
MR. AUSTIN: Special tools — special tools by
themselves aren't particularly significant. You have to read
the sentence in its entirety.
We are not interested in seeing carburetors that
can be adjusted by just taking a screwdriver and popping off
a little plug and turning a screw. We want to see a procedure
that's going to be time consuming and expensive in order to
accomplish the adjustment. Special tools may be one of the
things that makes the procedure difficult, time consuming,
and expensive. -
That'e basically what we are looking for*n ws doii't
want people to be able to adjust these carburetors with or
cmtifhb Mmnmtmammim
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CARS
376
without special tools in two minutes and undo a hundred dollars
of CO emission control that was designed into the vehicle.
MR. RUBENSTEIN: I'd also like to clarify that the
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difficulty is not related to the manufacturers' instructions
for setting the carburetor mixture, but it's related to what
is in fact necessary to adjust the mixture. A manufacturer
can have a very complicated procedure that will take at least
4 5 minutes to an hour to do it and require a special tool and
all sorts of work, but if you can adjust the carburetor
incorrectly with a screwdriver in five minutes, that's not
acceptable.
MR. GRAY: I think you have seen some of the Ford
designs that they would be considering offering to meet these
requirements. Do you consider any of those approaches
satisfactory?
MR. AUSTIN: From what I have personally seen of
Ford's designs — and I'm not sure I have seen all of them, but
I saw several concepts that they were working on. Of the ones
I saw, I considered all of then to be satisfactory.
But I'm not sure I've seen everything, and I
certainly haven't reviewed the detailed instructions that they
give for adjusting these. But what they are working on, it
looks good to me.
MR. GRAY: So ym ^wotfUl -think* though, to of
the interpretation of this language that — where you say the
mixture adjustment mechaniamrequiresspecial tools and/or
procedures sto make the adjustments, it will notsuff ice only
if special tool* are required to aake the adjustmentlis tbat
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CARB
377
correct?
MR. AUSTIN: That's correct. That in itself will
not be sufficient for ARB approval.
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MR. RUBENSTEIN: One possibly absurd case would be
if there was a special tool that was only available at a
district zone office and was not for sale and was checked out
every time it was signed out or something like that —
MR. AUSTIN: But that is absurd.
MR. GRAY: So you don't feel that special tools is
something you can define, because it may vary with the specific
situation?
MR. AUSTIN: That's right. Basically, what we are
looking for is to see procedures for adjusting idle that are
sufficiently complicated that they are unlikely to be used by
dealers or owners on a fairly routine basis; they are unlikely
to be used by mechanics who are trying to respond to someone's
drivability complaint which may have nothing to do with the
idle air/fuel ratio. But with current systems, it takes him
one or two minutes to see if he can do something with the
idle. Even if special tools are required., we don't 'want to see
carburetors that can be maladjusted in one or two minutes in
the future. And, so, special tools Will be something we look
at, but they've got to be part of an overall procedure which
is difficult and time consuming and unlikely to be done as
frequently as id£e air/fuel ratio adjustments are doner today.
MR. GRAYs Do you agree that the way this part of
the regulation is worded that the final judge would be the
alternative!' 'that is, a test <^ndugte<£bsf' -'Officer*
mi ir' i ' iT'f u rn ini • i»iiri»iirnrti-ili»-t*
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CARB 378
The way this is read, if the adjustment can be made
with special tools or special procedures, it seems like it
would be easy to argue that a different type tool or a
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different type procedure satisfies that requirement literally.
If it did not satisfy the Board's interpretation or intent,
then essentially you would be compelled to follow up in the
alternative?
MR. AUSTIN: This is responding to a somewhat
different situation. We are allowing an option. If the
manufacturer can either design a carburetor that's very
difficult to adjust, very difficult to maladjust; or he can
design a carburetor that is easy to adjust but when it's
adjusted can only be adjusted within a range that will not
result in violations of the CBS emission standards.
This Item 2 refers to manufacturers taking that
latter approach. If the manufacturer has not attempted to
make the carburetor difficult to adjust, then we are saying
the Executive Officer should have the right to require a
special emissions test of that vehicle with the carburetor
adjusted anywhere the Executive Officer thinks it should be
adjusted, at the rich extreme, at tfri lean extreme or whatever,
and the test results should be below the standards in order
for that approach to be acceptable. It's ah alternative to
the approach of making the carburetor difficult to-adjust.
CHAIRMAN JACKSONs Beforewe leave this subject of
adjustability, MrV AU8tift> I'd like to ask a broader
philosophical question about it.
SUV® yew* made any fcttift&t try to* anAlyii fti;' .
THOMAS it wttapN '
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CARB 379
potential backlash associated with this kind of an approach
to emission control; in that you are not, in my judgment,
doing anything to what causes misadjustment, and that's
drivability? If we still continue to have the standards
changed and fuel economy standards are implemented, significant
problems with drivability, then we have taken away the
potential for any kind of reasonable adjustment.
You made the point in your testimony that you are
talking about adjustments that will be expensive and time
consuming. Do you foresee any problem with the public
reacting with cars that have poor drivability which we are
not trying to control and for which there is no aready means
for adjustment to accommodate their problems?
MR. AUSTIN: In one sense, we hope there are some
problems. In another sense, we hope there are not.
We hope there are problems at the dealership- level,
and we hope that a number of the dealerships start writinq
some very nastv letters to the manufacturers saying that the
vehicles that are beinq delivered to them to sell to the
customers are very difficult to sell now, that they can't be
tampered with and adiusted to provide the idle quality and
drivability that the customers would prefer. That would be
somethinq that would be very beneficial. It puts some
additional pressure on certain manufacturers who have been
havinq anextremely difficult time in buildinq commercially
acceptable products in the last #ew years# at leaston certain
of their models.
'Simm may be some members o„f
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CARB 380
frustrated by the lack of a nob to twiddle with. We just
made the judgment that there wouldn't be so much adverse
reaction that it would create any real political problem for
the air pollution control program in California, principally
because of the fact this is going to come in on brand new
vehicles. It's going to come in slowly. Not all vehicles
are going to be changed overnight to this type of adjustment
mechanism. And, therefore, we hope it's something that the
public will gradually be exposed to and gradually learn to
live with. It won't be such a disruptive change as other
programs which have affected vehicles owned by the public
in the past. It will be something that's phased in very
slowly. And, therefore, we are not anticipating any substantia
amount of pressure from the public.
CHAIRMAN JACKSON: Have you rejected out of hand the
concept of regulating drivability?
MR. AUSTIN: No. In fact, we are now in the process
of putting^together a case against one particular manu-
facturer in this area. We've had some discussions internally
on the concept of regulating drivability. We are not anxious
to get into it. It's goixig to mean new test procedures. It's
going to complicate the certification process. It's going to
add cost to the certification process* And, therefore, itVs
going to add cost to the vehicle# Therefore, we'd lik# to
avoid it if at all possible# •
In general, we have been vary satisfied with the
1977 cars in particular. I think that; moat ot -the Vcars-
being offered in California drive significehtiy hatter than
THOMAf ft WlilQN ¦r; 1 " a-OJ
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CARB 381
cars that were available in previous model years. By and
large, the manufacturers have done a good job.
But there are a few glaring examples of vehicles
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that are just totally unacceptable, in my personal opinion
not even safe for operation, and when we look at vehicles on
dealership lots, look for tampering, we find very strong
correlations between incidents of tampering and the particular
engine family and different engine families. Some engine
families have very, very littler, tampering being done on them;
other engine families have extraordinary rates of tampering.
If you procure some of these vehicles that are
being tampered with so frequently and use them and drive them,
it doesn't take any kind of expert to see why the tampering
is going on. The tampering is clearly a function of the
drivability of the vehicle.
For that reason, we think there may be justification
for taking enforcement action against manufacturers who have
provided vehicles to the public which are just not acceptable.
CHAIRMAN JACKSON: The other part of the backlash
I was talking about is if you make a vehicle virtually
unadjustable and you still have |his drivability problem, the
level of tampering you see may be more egregious, in terms of
attempts to try to make the vefcis&e perform. It's unlikely in
my mind if someone is going to pay $6,000 or more for an
automobile that won't perform witftput trying to dp everything
humanly ,.|»as^ble,,to .get itto wher^ it ' s acceptable .in terms .
of its performance, evenif that includes removing parts qf ,
the e^i»siqpV;C»nt^
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CARB
382
drivability but nevertheless in the minds of the consumer it
may have something to do with a drivability problem.
MR. DRACHAND: I think one thing you have to keep in
mind here in the regulations we are proposing is that limiting
or not allowing adjustment of the carburetor is not solely to
prevent tampering. We found in the field in California that
maladjustment could be because of ignorance on the part of
the service industry and malfunctioning in some vehicles.
So, maladjustment could be unintentional.
We also found that certain people believe that
by tampering with the carburetor they can improve drivability,
although this is not entirely true.
Most of the tampering found in recent years is on
EGR systems. We can clearly say that the tampering found on
carburetors is purely due to poor drivability.
Because of the new procedures that manufacturers are
coming out with, Ford with the propane and possibly General
Motors in the future, the service industry is not sophisticated
enough to know how to adluat carburetors correctly. But they
feel that they should, even though the manufacturers say don't
touch it for 50,000 miles. As long as there is a screw
there, the guy is tempted to keep adjusting it;
So, one of the tfcing* we are trying to do is prevent I
that adjustment.
CHAIRMAN JACKSON: lagree with your observation.
I do think, at least my own personal opinion of some of this
is1 on the of the serviceindustry being unable to respond
to the more sophisticated setup technique*.
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CARB
383
I have several other questions, Mr. Austin. One is:
What position would you take, to the extent that you speak
for the CARB, if the Administration's position is adopted by
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amendment to the Clean Air Act? On the emissions standards —
the Administration's position on the emissions standards.
MR. AUSTIN: I addressed that in my prepared
statement.
To some extent, there are, I guess, two issues
there. Maybe I should ask you to clarify your question.
One issue has to do with the Administration's
recommendation for a carbon monoxide standard which is sub-
stantially lower than the carbon monoxide standard for which
we are seeking a waiver. The 1981 model year, I guess,
would be the year of conflict.
I'm not sure, though, whether there's not something
more to your question than that.
CHAIRMAN JACKSON: What I was suggesting was: Wbuld
the CARB, as in the case of motorcycles, be willing to accept
a federal program for vehicle control in California if the
Administration's position is adopted in Clean Air Act amend-
ments?
MR. AUSTIN: There were discussions at the staff
level and with the Board memberson that specific question.
It was our original understanding thait the Administration was
going to recommend a .4 grainpermile ISO standard for the
1981 model year. Had that recommendation actually been made,
;wie :w6re going to considerjust going with the fedeirsi program
'for the sub»e<2uerit ia©d«l ¦ •«!&' M' tfttr 4m
THOMA8R.VWUON ^ ''' ' ' '' ' " ' ' 1
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CARB 384
separate standard for 1982 when we are considering dropping
the N0X from the one gram level.
However, the Administration did not recommend
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establishment of a .4 NO standard in 1983 and instead
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recommended that the EPA study the need for a .4 NO standard
«?v
and make a decision as to the actual standard for 1983 at
some later point in time.
As far as we are concerned, that's just too vague
and ambiguous a situation for us to sign onto at this time.
And, therefore, we intend to pursue our own separate program
for the 1982 and subsequent model years.
CHAIRMAN JACKSON: With the assumption that you
will adopt a lower NO standard in some future year?
MR. AUSTIN: We believe we need far more than one
gram per mile for vehicle NO control. We need something
lower than that if we are going to continue to work as best we
can toward the achievement of the ambient air quality standards
for oxidant, N02 and for particulate matter.
CHAIRMAN JACKSON: Just for my own information, why
did you throw in particulate matter?
MR. AUSTIN: In Southern California, our people
believe that approximately 70 percent,of our particulate
problem is photocheaically generated particulate and that the
two principal constituents of thafcvparticulate are sulfates
and nitrate*, and ofthe particulate/-.which' creates thebulk of
visibility problem.possibly nitrates are the most significant
particulate* nitrates eaanate^frqia emission* from no tor
vehicles aiuS stationary sources# .i&ad, therefore, we think in j
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CARB
385
order to achieve the federal total spent particulate standard
and the state visibility standard we are going to need to
pursue N0„ control in addition to control of, directly emitted
X v
particulate matter and sulfur dioxide emissions which end up
being part of the particulate problem.
CHAIRMAN JACKSON: You mentioned in your testimony
a report on the availability of rhodium and suggested that you
would provide that report for the record if so requested,
and I would like to request —
MR. AUSTIN: I didn't mean to imply that there was
a report. What I was saying is that if this is still an issue
based on the testimony that you receive today from the auto
manufacturers, we will put together a supplemental submission
on this issue. We have some additional information on rhodium
availability that we haven't released publicly before. We
are not anxious to put together a report on this, but if we
need to, we will.
CHAIRMAN JACKSON: Then I assume you are going to
attend the balance of these hearings and astutely listen to
the manufacturers, and if they bring up the point, you will
supply us with that information?
mr. AUSTIN» That's correct,
CHAIRMAN JACKSONiGood enough.
MR. RUBENSTEIN; In ;?aNovember 23rd staff report
from last year, there was a brief analysis of the rhodium
situation which stated our petition.;
CHAIRMAN JACKSONs I assume you are going beyond
that with t&i* language in your s »
THOMASFimSON — . " . ' , ,:v ¦ ¦ ¦
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CARB
386
MR. AUSTIN: That's correct.
CHAIRMAN JACKSON: You also mentioned that you were
going to consider at a Ford meeting this issue about the
amended language with regard to altitude compensation and
that you thought the adoption of that language would be
affected before we could make a determination on this waiver
request before us.
MR. AUSTIN: Yes.
CHAIRMAN JACKSON: Our silence on that point does
not mean our guarantee that that will be considered as a part
of these proceedings. If you have any documents which support
your lead time contentions about the standards which you are
requesting waived, we'd like to see those submitted to the
record?
MR. AUSTIN: Anything in addition to the lead time
discussion that appeared in the staff report, I am assuming
you are asking for.
CHAIRMAN JACKSON: That's correct. Anything that
has not been provided for the record which would support your
position with regard to the availability of lead time.
Finally, something that you did not mention in your
testimony but which I think will be mentioned before the day
is out, and that's th# effect of MMT on your proposal.
MR. AUSTIN: I think you ;sais^piQlSably iright, thit
very likely will be mentioned before the day is out.
Let ttie give you a summary of what the Air Resources
Board is doing o*£ th« subjeefe!1of MMT at the present time,
tf* ink*?. hsione meeting - At which *:
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CARB
387
presented a report from the staff on the status of the
MMT issue. We summarized the effect on vehicle emissions,
summarized the effect on refineries of using /MMT or not using
MMT, we did some analysis of the potential adverse health
effects associated with manganese oxides increasing in the
atmosphere, including not only the direct health effects but
the expanded effects that manganese oxide will have on ambient
sulfate concentrations.
We believe that expanded use of MMT in motor vehicle
fuels will result in additional catalysis of sulfur dioxide
emissions into sulfate. Our preliminary analysis suggests
that in one day in the South Coast Air Basin if we have
sufficient humidity, which quite frequently occurs when we
have high sulfate levels in the first place, the additional
MMT, the additional manganese oxides in the atmosphere caused
by use of MMT in gasoline could increase our atmospheric
sulfate levels by ten percent.
There is no federal standard for sulfate at this
time. California has established a standard of 25 micrograms
per cubic meter. We have reviewed some data from EPA programs
which has indicated to us that tint's probably a level in
excess of what a federal standard, will end, up being* At
the present time, we are more than double that standard in
the South coast Air Basin. And*s,-.therefore* use of mkkp we
see as something that will aggravate an already dangerous
situation* So for that reason alone, wears very, very
concerned about: the-use. of MWT . £,?¦ ¦
We also summarized all of the data on j&e effects
THOMAS*.WNJ80N ' : ' " Vv '
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CARB
388
of MMT on exhaust emissions and came to the conclusion that
MMT significantly affects hydrocarbon emissions. The reasons
for that effect are fairly obvious. Vehicles'•have been
run with MMT and without MMT, engines have been torn down,
and it's clear that MMT is causing a substantial amount of
deposit formation in combustion chambers. This deposit
formation is having a similar effect on the deposits that
lead additives used to cause. Hydrocarbon emissions are
increasing because of the entrapment that occurs of the
mixture in this deposit. When the deposit is removed, the
hydrocarbon emissions go back down. We are not aware of any
tests that have shown that engines can be run without this
deposit formation if MMT is used in the fuel. There are
appparently no scavengers that work well with MMT.
It's a situation that's happening now in use, and
it's going to get worse as more MMT is used. Those increased
deposits are increasing engine hydrocarbon emissions. There
has been some argument, primarily made by manufacturers of the
additive or potential manufacturers of the additive, that £he
additive beneficially affects the catalyst to the extent that
there is no net effect on tailpipe emissions levels.
We have analyaea the 44ta available in tMt area and
disagree with those kinds of conclusions. It appears to us
there is going fee be a clear tailpipe effect, and we are
therefore very sympathetic with the manufacturers'concerns
that the use of MMT is going to change to some extent the
situation with respect to feasibility of meeting certain
emission standards in the future with acceptable levels of
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fuel economy.
The staff is right now working on a report which
/
«
will be presented to the Board at a public hearing which has
been scheduled for July 6, 1977, and we expect to have that
report out approximately 30 days in advance of the hearing.
I think it's very likely that the staff will be recommending
to the Board that regulations be adopted to regulate, probably
eliminate, the use of MMT in motor vehicle fuels sold in the
State of California — in unleaded fuels sold in the State of
California.
We've shared this information with the Environmental
Protection Agency. We have done an analysis of what we see as
the agency's burden under Section 211 of the Clean Air Act to
regulate additives in motor vehicle fuels. We are now in the
process of finalizing that analysis which we are going to
submit to EPA. Our initial impression is that sufficient
data now exists for EPA to ban the use of MMT under Section
211 of the Clean Air Act, and we will be supplying more
information to EPA regarding that analysis in the future and
will be encouraging the agency to step up its program'to
regulate MMT.
CHAIRMAN JACKSON: Then we can assume that the
standards for which you are predicting lead time and available
technology are based on non-MMT fuel?
MR. AUSTINs The analysis that we've done in our
staff reports and the analysis we talked about today, yes,
based on the assumption that sterile fuel would be used
to certify these vehicles.
I*. WIUON
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CARB
390
I'm not sure how our conclusions are modified if
the situation changes and we are forced to certify vehicles on
/
fuel containing one-eighth gram per gallon of MMT. I suspect
that we'll still conclude that improvements in the degree of
emission control achievable from trucks are feasible. I
believe we'll probably conclude that our current standards
are feasible. I suspect that the most sicrnificant chanae will
be our estimate of the fuel economv oenaltv associated with
anv of these emission standards.
However, we haven't done that analysis. It may
very well be that as more data becomes available, we would
have some question regarding the feasibility of some of the
longer range standards we've adopted, particularly the one
gram per mile NO standard that we see as resulting from the
use of three-way catalysts for passenger cars. Again, there
niay be ways to meet the standard with the use of MMT, but
there may be a very significant difference in the level"of
fuel economy associated with meeting those standards if MMT
is in the fuel.
CHAIRMAN JACKSON: We are ready to change witnesses,
and we will take a five-minute break.
Thank you, Mr. Austin.
MR. AUSTIN: Thank you.
(Short recess.)
CHAIRMAN JACKSON: Good morning, Mr. Jensen. Are
you ready?
MR. JENSEN: Yes.
CHAIRMAN JACKSON: We are ready.
WILSON
tsw,,b •hoathand wonm
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FORD
391
MR. JENSEN: Okay.
Mr. Chairman, before I read portions of my statement,
I'd like to indicate and collaborate with what Mr. Austin
said concerning the November hearing in respect to the
standards under consideration today in this waiver.
I testified in Los Angeles at the November Board
meeting and did support the standards, said they were feasible,
and today as I read this statement, you will see that this
has changed somewhat, primarily because of the MMT issue
which we will get to in a minute.
I wanted to make it clear that a lot of the
developments on MMT have occurred after the November hearing.
*
We started a three-way catalyst fleet just about that time I
reported to the Board meeting in November, and we also started
a truck fleet with MMT on durability and have data which we'll
cover today. But I do want to verify what Mr. Austin said,
that without MMT, we had indicated feasibility and supported
the California Board proposal.
With that introductory remark, the first page of
the written statement covers the four separate changes in
passenger car standards. At the bottom of the page, we
start talking about the '79 standards of .41, 9.0, and 1.5
grams per mile HC, CO, and NO , a waiver may be granted if,
and only if, EPA at the same time eliminates its requirement
that one-eighth gram per gallon manganese be included in the
certification mileage accumulation fuel.
The Ford Motor Company position on MMT is indicated
for emphasis in italic type.
NOMAS R. WILSON
iRTimtO SHORTHAND RgPORTIRS
(419) 143*81 M/461-30H
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FORD 392
MMT has long been recognized as a very effective
anti-knock agent for gasoline. However, its use in the past
has been limited because of low availability, high cost,
and the indication of possible problems, such as spark plug
fouling.
With the growing required use of unleaded fuel for
practically all emission control systems on cars since 1975
models, the use of MMT has become more attractive. At the
maximum dosage of 0.125 grams manganese per gallon recom-
mended by Ethyl Corporation, it could provide an octane gain
on the order of two numbers, that is, 89 octane to 91 octane
gasoline. According to Ethyl Corporation, this ^ain would
result in a one percent crude oil saving if MMT were used
nationally at their recommended level. After several years
of litigation, EPA is now mandating a phase-down of the lead
content in gasoline used by pre-1975 cars and most trucks of
whatever vintage. The use of MMT in conjunction with the EPA
regulation calling for lead phase-down which began in 1976
and goes to .5 grams per gallon in 1979 is also expected to
aid in the production of sufficient lead-free gasoline to meet
demand during the next few years when a shortage is possible.
Current use is only about an average of 0.01 grams
manganese per gallon because most of the major oil companies
today are not using this additive; however, some refiners are
using as much as 0.125 grams manganese per gallon.
Based on the projected increased use of MMT by oil
1
companies by 1979, EPA has established a requirement that
1979 certification fuel include 0.125 grams per gallon of
I R. WILSON
SHORTHAND MPOBTBM
(418) S43-31B4/4«1.3Mi
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FORD
393
manganese.
Because the use of MMT is increasing and because
there are many different engines and emission control systems
to evaluate, it is not possible to define accurately all of
the adverse effects of MMT or to predict the degree to which
those effects can be eliminated by other additives or by
changes in the engine or emission controls!*. At this time,
however, some very important conclusions can be made with
respect to MMT use with the 1979-1980 emission control
systems:
First, the addition of MMT at the 0.125 grams of
manganese per gallon level will cause a significant increase
in hydrocarbon emissions on many engines. This occurs
because of engine deposits of manganese oxides, as Mr. Austin
mentioned. It can also foul sp:ark plugs and can seriously
increase hydrocarbon emissions. In fact, as shown in our
statement here, a Ford three-way catalyst test fleet had
tailpipe hydrocarbon increases that doubled the .41 hydrocarbon
standard in less than 20,000 miles.
At this time, we do not know of scavengers or other
design changes that could be made to eliminate this problem.
We have no reason to believe solutions csould be discovered in
time for the 1979 and 1980 model year.
The effects of hydrocarbon emissions increases that
have been observed to date would preclude Ford from certifying
vehicles at the .41 grams per fflile hydrocarbon standard for
50,000 miles as *979 iodide
and currently in force 1977 and 1978 mod*!,
I R. WILSON
SHORTHAND MMftTSM
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FORD
394
This inability to certify stems from the very low probability
that certification vehicles could be run for 50,000 miles
without experiencing a prohibitively high deterioration in
control effectiveness for hydrocarbons.
Ford believes that there have been sufficient data
generated to date that warrant elimination of MMT from lead-
free gasoline until offsetting additives or new technology
has been developed. Ford's recommendations are, therefore,
as follows:
First, if a. hydrocarbon standard of .41 grams per
mile is required for 1979 or 1980, there has been sufficient
data generated that shows that MMT cannot be required in the
certification fuel as specified by the existing EPA Advisory
Circular on this subject.
Secondly, EPA should pursue the possibility of vol-
untary action by oil companies or by Ethyl Corporation to
eliminate MMT to the degree necessary to permit its exclusion
from certification fuel. Further, consideration should be
given to revisions in the EPA lead phase-down program in order
that elimination of MMT can be effected without a serious
loss in gasoline production. r-
Next, the EPA waiver to California for 1979 standards
of .41 gram, per mile hydrocarbon must be denied or condi-
... _.j the requirement to use MMT in
tioned upon the elimination o£ tne
1979 certification fuel.
EPA should initiate proceedings under Section 211
^ whether or Mt use of lit®
of the Clean Air Act to determine
Mr. Austin, as you know;
should be prohibited or restricted. «
also made this fsomment. * '
J R. WILSON
tHORTHANO MPOftTtM
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395
FORD
Finally, if EPA determines that it does not have
sufficient authority to take timely action, the fuel additive
provisions similar to Senate Bill 252 should be enacted by
Congress.
These are serious conclusions and recommendations.
They are based in part on the following Ford data:
On a development fleet of three-way catalyst
V
equipped vehicles, average hydrocarbon feedgas has increased
37 percent in the 0-15,000 mileage interval with MMT fuel,
compared to a seven percent decrease in the case of companion
vehicles running without MMT in the fuel. Later data on one
pair of these same vehicles show that the engine hydrocarbon
increase is continuing at the 25,000-mile point with the MMT
vehicle exhibiting an hydrocarbon emissions increase of 2.12
grams per mile, compared to a slight decrease for the non-MMT
vehicle.
On the same vehicles at 15,000 miles, average
tailpipe hydrocarbon increased 118 percent, .31 grams per
mile,, for the MMT vehicles, compared to 61 percent, or .20
grams per mile, for the non-MMT vehicles.
In a certification fleet of 12 truclcs uaing con-
ventional oxidation catalysts, ten vehicles showed a large
tailpipe hydrocarbon increase of 102 percent at 15,000 miles,
or about three times what wouldhave been expected in the
absence of MMT.
Heavy deposits of mahganeee oxides on spark plugs,
combustion chambers, oxygen sensorsj and catalysts have been
found at the 1/8 gram manganese pergallon level of MMT usage.
THOMA8 R. WILSON
CBRTIPltD 9HOOTHAN0 MWRTIRS
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FORD
Ford's data, which are supported by data generated
by others, show that for vehicles required to meet a .41 gram
per mile hydrocarbon standard, the magnitude of the hydro-
carbon emissions increase associated with 1/8 gram per gallon
level of manganese can be greater than the total standard —
that is, greater than .4 grams per mile — thereby precluding
successful certification. It has been postulated that by
using three spark plug changes during certification, the
resulting "sawtooth" data points would permit development of
an acceptable deterioration factor. This is not accurate.
Ford's data demonstrate that the effects of MMT are so pro-
nounced that only a small percentage of durability vehicles
which start with hydrocarbon levels below .1 grams per mile
would finish durability without exceeding the .41 grams per
mile level; and those that did would have deterioration factors
in the 3-4 range, which would preclude a successful 4,000
mile certification-program.
At this point, there is an attachment which I'll
have Dr. Weaver read when I finish the statement — not read,
but explain, and rather than interrupt here, let me finish
the statement and then go to Dr. Weaver's explanation of the
attachment if I may. ¦
We go on here to indicate the second passenger
car issue is the California revest lor waiireir for its 1980
standards. As Mr. Austift twsiitieiied, to Mil this stiwi&ird
by 1980, Ford is planhing to ias^e thi»e-way catalysts with
electronic engine 'controls. This"'Sy*titt'>iS^t^lli^iio that
used in the three-way catalyst develbpment fleet which I just <
8R WILSON
•HOHTMAND RIPOftTSIUI
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FORD 397
got through talking about, which I indicated was adversely
affected by MMT. We recommend that California's request
for waiver of its 198 0 standards be denied or conditioned on
elimination of the use of MMT during certification.
With regard to the restrictions on adjustment of idle
air/fuel mixture, you've covered that with Mr. Austin. Ford
believes the effort to limit such adjustments is appropriate
because it should minimize a major portion lof tampering and/or
maladjustment of current emission control systems. We did
support this when it was considered by the Board.
The question of requirement for special tools and/or
procedures is the key issue you have already discussed with
Mr. Austin, and we think it should be clarified with respect
to the waiver.
The last new passenger car requirement is that
"evidence must be supplied that emission control systems
on certified vehicles provide approximately the same percentage5
of control of emissions at altitudes of up to 6,000 feet as
these systems provide at sea level".
We agree with the intent that Mr. Austin expressed.
We are just waiting, as you know from the prior discussion,
to see what language is put in the record to clarify the
issue.
Ford believes that Requirements imist be
sufficiently specific to enable manufacturers to determine
if its vehicles are in compliance. At the same time, the
manner in which compliance is to be demonstrated should be
flexible. As Mr . Austin indicated, this flexibility-is
THOMAS R. WIL80N
ocnrtXiB wowrwroo wttorrtm
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required because of the many different control systems and
the impracticability of a full-scale altitude test procrram
at 6,000 feet.
In anv case. Ford believes that the new California
proposal must be evaluated, amended as mav be appropriate, and,
of course, considered at a public hearinq bv CARB, which has
been indicated will be held on June 6, 1977. Until CARB
takes final action, any consideration of this item by EPA
at a waiver hearing is meaningless and should be deferred
until CARB adopts final requirements.
On light-duty trucks and medium-duty vehicles, we
run into the same situation we discussed earlier. We
recommend that California's request for a waiver of preemption
be denied or conditioned on elimination of the use of MMT in
certification fuel. The basic reasons for this position are
the same as in the case of passenger cars.
If MMT is eliminated from certification fuel, Ford
believes that it can certify to the new 1979-1980 light-duty
truck standards with current emission control technology and
some potential compromise in fuel economy and model avail-
ability. At this time, we cannot quantify these compromises,
because they are a function of many variables, including the
availability of manpower and re®au.sc«s that can be allied. >
At this time, Mr. Chaiwua®* I would like to leave
the remainder of ten# 11 and 12 in the record without reading
it. ;
We believe both EPA and CARB should be aware that,
at the present time, it appears that.the potential workload to
THOMAS K WILSON
CERTJflftO BMONTSM
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FORD
399
meet requirements for federal passenger car emissions and
fuel economy, 1979 federal light truck emissions and fuel
economy, 1978 California medium-duty vehicle emissions, 1980
California SHED standards, and the new federal heavy duty
emission standards and test procedures will force an alloca-
tion of resources at Ford that will result in compromises in
California truck fuel economy and model availability. It was
this consideration that led Ford to recommend that California
carry over its truck standards in 1979 and make the changes in
1980 concurrent with its changes in SHED evaporative emissions
standards.
In addition to lead time and workload problems,
another consideration raised by Ford at the November 23, 1976
CARB hearing was the objection to an inertia weight break
point and support for a GVW break point concept for emissions
standards. Ford continues to support break points based on
GVW's of 4,000#, 6,000#, and 8500#. The California break
points and standards proposed require unique certification to
cover differences in California and 49 state standards. While
this situation has existed for a number of years, the 1979-
80-81 California proposals will require incremental workload
for California much higher than in the past. The light-duty
truck task becomes much more difficult if the 1979 light-duty
truck 0-3999# inertia weight proposal is adoptedr for example,
a full size pickup truck falling in the 3500# inertia weight
class would be required to certify at .41/9.0/1.5 (HC/CQ/NOv)
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FORD
11.2 horsepower. This proposal results in a certification
task more difficult than the passenger car task.
This example illustrates why the inertia weight
classification break point proposed by California would
restrict a manufacturer's incentive to reduce vehicle weight
if the weight reduction causes the vehicle to fall into a
lower inertia weight class with a more stringent; emission
standard. Going further, this could result in federal
vehicles not subject to the inertia weight classification
break points being manufactured and sold at a lower weight
than similar vehicles sold in California. If this occurs,
the fuel economy of California vehicles would be penalized
not only by more restrictive emissions standards, but also
by heavier weight.
The inertia weight break points are not consistent
with the Federal Clean Air Act and the Energy Policy and
Conservation Act, both of which deal in GVW break points and
federal emissions and fuel economy regulations which also
specify GVW break points. In addition to the inconsistency
of the IW class approach, the California proposal clearly
imposes additional incremental workload by requiring the
manufacturer to deal with inertia weight break points on top
of the federal practice of imposing GVW break points.
The CARS IW break point plan for 1981 does not
reflect vehicle function as it should, making proper allowance
for heavier GVW's as does the current CARB arid federal
standards. It proposes placing all vehicles in the 6000-»
8500# GVW group into a light duty truck category defined by the
THOMAS R. WILSON
CMTimO ftHONTHAHO RtPORf(M
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FORD 401
4 000-5999# IW span. The 5999# break point is set so high that
it encompasses all vehicles below 8 500# GVW and does not make
proper allowance for the heavier weight and larger engines
needed in this weight group for adequate fully loaded vehicle
performance. These vehicles are not light-duty vehicles in
the sense that they function similar to passenger cars.
Equally disturbing is the lower IW break point of
3999# below which light duty trucks will be required to meet
car level standards at EPA test conditions more stringent
than the car procedure (PAU settings 70% higher than a 3500#
IW car). Manufacturers striving to reduce weight from the
current 4000 IWC to 3500 IWC will be faced with a near
impossible emissions certification task.
In summary, the CARB inertia weight class proposal
for emissions break points and the break point levels are not
needed to improve air quality and, if adopted, would impose
considerable additional burden on manufacturers of light- and
medium-duty trucks.
We would hope that CARB would not treat these
concerns as a closed issue but would provide further oppor-
tunity to consider them.
In conclusion, Ford believes that the waivers
requested by California for its 1979-80-81 passenger car and
truck emission standards can be granted only if there is a
satisfactory resolution to the problem. A waiver for idle
air/fuel mixture adjustment requirements is appropriate if
properly clarified. A decision as to altitude requirement
must be deferred until final action is taken.
I R. WILSON
SHORTHAND REPORTERS
(418) S43-ai«4Mai-aooa
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FORD 402
At this point, I'd like to have Dr. Weaver explain
the tables that are included in the attachment.
Gene, would you take over, please.
DR. WEAVER: I think most of you have copies of
the statement in front of you. I will not read the page and
a quarter that's there, but I would like to go through it
informally.
I'd like to start off by describing the three-way
V
catalyst fleet, which we refer to as the source of the data.
The three-way catalyst development fleet consisted
of systems which had a three-way catalyst for removal of
oxides and nitrogen first, followed by an air introduction
from an air prop, and finally a cleanup oxidation catalyst.
Not all of the systems were like this, but this was the major
system described. The data we will refer to here will be
entirely of this type of a system.
There were a total of 14 vehicles, with six of
these vehicles operating with MMT and the remaining eight
without MMT.
Since these vehicles are at different mileage points
at this point, we've selected four matched pairs of vehicles,
one of each pair on each of the two fuels which were at
20,000 miles or above, and this is the data which then has
been summarized in this attachment.
The fuels for the base fuel is the 1977 certifica-
tion fuel. The fuel containing MMT was the 1977 base fuel
plus an eighth of a gram manganese as MMT and sulfur compounds
bring the sulfur level up to that specified in the Advisor's
5 R. WILSON
SHORTHAND REPORTERS
(418) S43-3194/461-30M
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FORD 403
Circular 26(b), .03 percent sulfur.
The engines included in these four matched pairs are
the 250 CID engines, the 302 V8, and the 400 CID V8. Main-
tenance on these vehicles was at 30,000 miles for the 250 and
302 and 50,000 miles for the 400.
The data obtained on the fleet includes the CVS
tailpipe results, and we also had facilities to simultaneously
measure the emissions coming from the engine. That is, the
v"
engine out or feed gas to the catalyst. These measurements
were made at each 5,000 mile interval, beginning at zero
miles. Also at these mileage intervals, an examination was
made of the catalyst for any possible plugging. The spark
plugs were examined for deposits, and sensors, which are
a part of the system, also were examined. I think I neglected
to mention when I described the system initially that a sensor
is a very important part of this system, and the cars were
equipped with feedback carburetors.-
Table 1 indicates a tabulation of the hydrocarbon
data for base fuel and MMT fuel, from zero to 35,000 miles
in the case of the base fuel because that's as far as those
vehicles have gone. Each of these columns correspond to
four vehicles on MMT fuel and four vehicles on the base fuel.
The data only goes to 20,000 miles on the MMT fuel because
that's as far as we have data at this point.
At the bottom, there is a summary of the increases,
and I'd like for you to note the increase between zero and
5,000 miles for the MMT fuel is .23 grams per mile hydro-
carbons and for the interval, 5,000 to 20,000 miles, is
HOMAS R. WILSON
WTIFI8D SHORTHAND REPOftTffRft
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FORD 404
.55. That's actual data from these matched pairs.
Tables 2 and 3 correspond to the data after a least
square fit, Table 2 for the tailpipe data and Table 3 for the
engine out data.
I think that's all I need to say about those two
tables.
Figures 1 and 2 will be a graphical presentation of
the data which is contained in Tables 2 and 3.
Now if we look at Figure 1 — I'll hold this up so
you know what I'm talking about, and I can point it out a
little better.
This is identical to Figure 1 that you have in your
handout.
This axis here is hydrocarbon tailpipe emissions
at grams per mile, and mileage is across the bottom (indicat-
ing) . The least square fit, of course, goes from 4,000 miles.
And we've only drawn the curve as far as we have data and have
not extrapolated any further. The same with the base fuel,
which is lower. The actual data at zero miles is indicated,
so that you get some feel for where we are starting from.
Now this increase which you see here to the MMT
fleet relates back, as has already been described, to the
deposit effect of the manganese oxides and the increased
engine out emissions from the engines. The catalyst
efficiency has not changed, and so the increase which we see
here can almost entirely be explained by the deposit effect
and the subsequent increased hydrocarbon emissions from the
engine. So this demonstrates the data that we are working
fHOMAS R. WILSON
SMTlHeo SHORTHAND REPORTERS
(418) 843*3194/441 <30M
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FORD 405
with.
And I think I need not say more at this time to save
time about the data in Table 2, except just to note that there
is practically a flat line for the base fuel but there is an
immediate increase from zero miles for engine out on Figure 2
with the MMT fuel. The only reason we need this information
here is so it's clear the source of the problem. The source
of the problem is the deposits in the engine.
Now let's see what effect this has on our ability
to certify, and to do that I'd like to look at Figure 3.
In a normal certification, when we are trying to
meet a standard of .41 and we are going to put out a fleet of
durability vehicles, we'd like to have them at 50,000 miles
meet an objective of about .35 grams per mile and would like
to have a DF of about 1.5. This, then, defines an engineering
objective at 4,000 miles of .23 grams per mile.
Now we are not smart enough to take a green engine
and run it for 4,000 miles and measure emissions and have it
come at exactly .23, so we expect a scatter of the data as
sort of indicated by the dashed lines. Of course, we are not
smart enough to predict exactly what the DF is going to be
either, so there will be more variation as we get out to
50,000 miles. We have demonstrated that we can certify
without MMT under these conditions.
Now just to show — and this is purely a mathe-
matical exercise now. To demonstrate what the effect of the
increase in hydrocarbon emissions between 4,000 and 50,000,
what this means in terms of DF and our problem of certification.
5 R. WILSON
SHORTHAND BfPnorcoo
(418) M3-31M4S1-30M
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FORD 406
Let's just assume — And I am not basing this on any data.
I am just assuming we have a rather moderate increase in
hydrocarbon emissions between 4,000 and 50,000 miles of .25.
That's only roughly twice what we expect to get without MMT.
Now you see that that would define our 4K objective, then,
as .1 grams per mile hydrocarbon, and this would then define
a DF of three and a half, 3.5. And this is a rather diffi-
cult job, then, if we have only a moderate increase between
4,000 and 50,000 miles, .25 grams per mile. The certifica-
tion procedure becomes very difficult.
Now let's look at some of the data we got from the
three-way catalyst fleet and see how it fits into this general
plan.
Look now at Figure 4. We again have the same
format of hydrocarbon and plotted against 50,000 miles. I
have plotted actual data which we got on the four pairs of
cars from the three-way catalyst fleet, starting at zero miles
at .33, and now this dashed line corresponds to the data which
has been fitted, at least square fit, and the 4K intercept is
•61. At 20,000 miles, you will note we are at the point of
20k intercept of 1.02 grams per mile.
Now let's assume that we are smarter now than we
were when we started this fleet in December and through
some improvements which we haven't defined yet, we could make
this 1.02 the 50K value. That would give us the solid line
going from .61 grams per mile at 4K, out to 1.02 grams per
wile at 50,000.
Now that brings the DF down to 1.67, which sounds
I R. WILSON
SHORTHAND REPORTER*
(418) S43 J194(4ei-30M
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FORD 407
pretty reasonable. But we still have the problem that we are
way above the standard. So let's move that down, keep the
same slope, and move it down so it will just intercept with
the standard at 50,000 miles. Unfortunately, you see that we
are practically at zero at 4,000 miles, which gives you DF
approaching infinity.
My point here is: even if we have a reasonable
slope of 1.67 and if through some, again, undefined improve-
ments can keep the increase between zero and 4,000 miles to
a minimum, we still are in an impossible situation.
Finally, in Figure 5, I have reproduced the normal
situation in the solid line at the top, going from .23 grams
per mile at 4,000 miles, out to .35, which we know we can do
that. I have indicated the zero mile value would be about
.21 for zero mile vehicles.
Let's just assume for the purpose of an example
that we could get by with a DF of two or we could achieve
a DF of two with MMT. That would then define a 4K value of
4.175 for a 4K objective. That seems rather reasonable
until you compare it with what we see in the way of actual
data of increments between zero and 4,000 miles. With the
data which we presently have from these four vehicles which
operated with MMT, where we saw over the interval of zero to
5,000 miles roughly .2 grams per mile, and I have rounded that
off — or estimated for 4,000 miles that might be .18, you
see the increment which we observed between zero and 4,000
miles is bigger than our objective at 4,000 miles. So, we
have to end up with a negative value at zero miles in order to
J R. WILSON
SHORTHAND RSPORTEB8
<41«)
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FORD
408
meet this objective.
To me, it looks pretty impossible to certify if the
data which we have from the three-way catalyst fleet really
represents the situation, both for the increases between zero
and 4,000 miles and the increases between four and 50,000 miles.
Remember, there's two portions we have to work in order to
certify. It seems to be impossible that we'd be able to
certify using an eighth of a gram of manganese in the certi-
fication fuel.
MR. JENSEN: That concludes our statement, Mr.
Chairman.
To sum it up, we did testify to California we can
make the standards. We have the technology, and all those
statements in November were based on clear fuel.
Now we've had to indicate here today that we don't
think it's possible with MMT in the fuel and specified by
EPA.
We would be glad to answer any questions.
Oh, one other thing on MMT. We have been meeting
with both Ethyl Corporation and individual oil companies, and
we do have a presentation here of the status that we gave to
the oil companies and to Ethyl Corporation which we can make
a part of the hearing record.
We'd be glad to answer any questions at this point.
CHAIRMAN JACKSON: You made quite a point out of
the MMT thing. In fact, convinced me there is a problem.
Have you or do you plan to take any action to
advise Ford owners not to use gasoline with MMT in it for
3 R. WILSON
SHORTHAND REPORTERS
(418) S43-3U4/481.30fl8
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FORD
409
'75 and later model year cars?
MR. JENSEN: We haven't taken such action. As I
indicated, we are learning a lot, almost on a daily basis.
Last November we had some evidence, particularly in
that truck fleet that catalysts were being plugged up with
MMT. We thought this was the problem. Now, as we have run
these other fleets, we have seen the increase in hydrocarbon
without the catalyst plugging. We are not sure what's
happening to the '75 and '76 models. I don't think we have
data on that.
Have we, Gene?
DR. WEAVER: No.
MR. JENSEN: We just haven't got that kind of
information so we could advise the owners to take any par-
ticular action yet.
Of course, with .01 grams in the field at the
present time, it isn't the problem that would come along in
1979 when, presumably, it would be much higher.
CHAIRMAN JACKSON: That's .01 with regard to the
average, I guess; is that right?
MR. JENSEN: Yes.
CHAIRMAN JACKSON: It could be locally very much
higher than that?
DR. WEAVER: That's right.
MR. JENSEN: That's right.
CHAIRMAN JACKSON: But your answer is you don't
think you have sufficient basis for advising your owners not
to use gasoline with MMT?
3 R. WILSON
SHORTHAND B6P0RTERB
(415) 543-31S4/461'309t
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FORD 410
MR. JENSEN: Have you got any data at all, Dr.
Weaver?
DR. WEAVER: No.
MR. JENSEN: No, sir.
CHAIRMAN JACKSON: And you are convinced now that
it's a hydrocarbon as opposed to a plugging problem?
MR. JENSEN: Gene?
DR. WEAVER: There are four problems, and we have
demonstrated all of these. They are described in detail in
this status report which we prepared for the oil companies.
There is a problem of catalyst plugging, which we
have documented two cases. The most recent case is not in
this book, but I will leave a photograph here — it came from
the three-way catalyst fleet — where the catalyst is
partially plugged and plugged sufficiently so that it's
affecting the performance of the catalyst.
CHAIRMAN JACKSON: What mileage?
DR. WEAVER: At 20,000 miles.
CHAIRMAN JACKSON: So you have not eliminated
plugging?
DR. WEAVER: It is a problem, but we have hopes
that we can understand it and live with it.
There is a problem of spark plugs, and there again
we hope that we can learn to live with that. We can always
increase the maintenance schedule.
Thirdly, there is a potential problem with sensors.
Sensors are a very important part of the three-way catalyst
system, and there are louvers in the sensor which permits the
^OMAS R. WILSON
'•"TlFilo SHORTHAND REPORTERS min .«•
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FORD
411
exhaust gas to communicate with the electrodes which are the
heart of the sensor. If the manganese oxides completely plug
these louvers as they have in this case — this is the first
case where we actually have an example of the oxides com-
pletely plugging the louver so that the sensor no longer
functions. This also we observed very recently, since the
status report was written, and this sensor no longer operates
because of MMT.
CHAIRMAN JACKSON: At what mileage?
DR. WEAVER: 20,000 miles.
So, I have mentioned those three problems which we
think maybe we can live with. But we know no way how to
approach or how to live with the increase in hydrocarbons due
to deposits in the combustion chambers.
MR. JENSEN: That's why most of our testimony today
is addressed to hydrocarbon increased problems rather than
these other things.
As Gene said, we are trying to develop programs
which, hopefully, can work around the others.
MR. GRAY: While we are still on the subiect of
MMT test fleet, the fiqures that vou presented in your
attachment with three-way catalyst results, I believe each
of those tables carries the MMT fleet to 20,000 miles.
DR. WEAVER: That's right.
MR. GRAY: I am referring, again, to the attachment
that Ford submitted regarding the three-way catalyst fleet,
and the question deals with the MMT fleet that has accumulated
20,000 miles.
S R. WILSON
SHORTHAND RIPOBTSRS
W) S4S-31M4«1-3QM
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FORD
412
I believe the statement was made that this dif-
ference is due, in your opinion, entirely to engine out
emission change; is that correct?
DR. WEAVER: Primarily. There could be an effect
due to spark plug deposits, deposits of manganese oxide on
spark plugs, which could affect combustion. But we have not
seen this to any major effect on this fleet. We have seen
this on the medium-duty truck certification fleet where we've
got major differences in hydrocarbon emissions when we changed
spark plugs but did not otherwise disturb the deposits.
It's impossible for us to be really positive that removing
the spark plugs affect the deposits around the spark plugs
sufficiently to show this decrease in hydrocarbon emissions.
That's why I'm a little bit reluctant to be all that positive.
MR. GRAY: I would group spark plug effects with
engine out emissions.
DR. WEAVER: Okay.
MR. GRAY: That's why I wanted to separate that
from the plugging issue.
DR. WEAVER: Yes, sir.
MR. GRAY: Have you had an opportunity to inspect
any of these catalysts to see if there is a deposit formation,
and have you likewise been able to inspect any of the oxygen
sensors on these vehicles?
DR. WEAVER: Yes, That's a regular procedure each
5,000 miles. We have photographs — the best that we can
do without destroying the converter at every 5,000 mile
interval, and that catalyst at 10,000 miles showed some smaller
5 R. WILSON
SHORTHAND REPORTERS
(418) 543-3194/461'3096
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deposits which you could see increased to what you see there
at 20,000 miles. We have photographs on all the vehicles in
the fleet.
MR. GRAY: This is the 20,000 mile catalyst that's
part of this fleet (indicating)?
DR. WEAVER: Yes.
MR. GRAY: And yet you are not seeing any decrease in
conversion efficiency even with this amount of plugging?
DR. WEAVER: I have to qualify that because that
amount of deposit does affect the catalyst efficiency of that
particular vehicle. I also need to say that that vehicle was
on a 250 CID engine, and the 250 CID engine shows a lesser
effect on engine out hydrocarbon increases than the others
which are in the flfcet, the 302 and the 4 00, but the data
which I presented averaged all across those engine families.
MR. JENSEN: For some reason that we don't know,
different engine families react differently in the hydro-
carbon buildup.
You might want to talk about that.
DR. WEAVER: I really can't explain- it. It
apparently has something to do with the combustion chamber
design.
In the medium-duty truck official certification, we
see a lesser effect as far as deposit formation on the spark
plugs, and presumably in the combustion chamber, although we
have not had a chance to examine these engines yet.
On the 351 W engine, for example, it appears as if
the effect is less on that than it is on the other engines
THOMAS R. WILSON
CeHTI^ieo SHORTHAND HEPOflTEHS
(418% A4I.444*"** «***
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FORD 414
which are in that certification, which are the 300 and the
351 M, and the 4 60 engines.
MR. GRAY: Have you carried any of your three-way
catalysts beyond 20,000 miles with MMT?
DR. WEAVER: No. That's the maximum that this
fleet is at now. No individual is above that.
MR. GRAY: This fleet is continuing at the present
time?
DR. WEAVER: Yes.
MR. GRAY: You plan to run it the full 50,000 miles?
DR. WEAVER:- I can't guarantee that. Because the
results are so discouraging, we may terminate the fleet at
some point and start another fleet.
I should add at this point that we are starting a
fleet — this fleet was not designed to look at MMT. It was
a development fleet for a 1979 certification process, and
because it's not giving us the complete answer we want on
that, we want to design and do a test fleet specifically for
MMT. And this fleet will have in it ten identical vehicles,
two on each of four different levels of MMT, including zero,
.03 grams of manganese per gallon, .06, and an eighth of a
gram. Those will all be identical with three-way catalysts.
There will be an additional three-way catalyst
system which will run on the highest level of an eighth of a
gram. There is a total of ten vehicles in that fleet. That
test has iust bequn. We hope to use that fleet to answer some
of the type of Questions we are askinq, too.
MR. GRAY: So is it fair to conclude that while with
THOMAS R. WILSON
'BRTIFIED SHORTHAND R6PORTIW
(416) S43-3194/4I1-30M
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FORD 415
the current three-way catalyst fleet that you have you feel
the difference in emissions between the MMT fueled vehicles
and clear fueled vehicles at least through the 20,000 mile
test point is due primarily to engine out emissions but that
the plugging effect catalyst activity effect may come into
play or may not, you just can't make a technical judgment at
this point?
DR. WEAVER: That's correct.
MR. GRAY: This is a broader question. Have you
seen any technology that will allow or has the potential for
allowing certification to the levels that we have been
talking about today with MMT in the fuel?
DR. WEAVER: No, sir. I know of no technology
which would permit that.
CHAIRMAN JACKSON: One other question before we
leave the MMT issue.
On Page 5 of your statement, you are referencing
a possible voluntary action by the oil companies or by Ethyl
to eliminate MMT to the degree necessary to permit its
exclusion from certification fuel. That's sort of an
interesting and intriguing choice of words. What is the
degree necessary?
MR. JENSEN: When I don't know the answer, I always
ask Dr. Weaver to respond.
DR. WEAVER: I think we worded it that way because
we don't know what that level is. If we knew that it was
1/32 of a gram, why, we would say that. But we don't know.
That's one of the reasons we are running this fleet, is to try
5 R. WILSON
SHORTHAND REPORTERS
(41S) 643-3194/481-3096
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FORD
416
to answer that specifically. We realize that's an important
question to answer.
I might add that there is also a CRC fleet which
will be, hopefully, funded and started shortly which will
attempt to answer some of these questions also.
MR. HELLMAN: Dr. Weaver, you mentioned scavengers,
none of them defined. Wasn't ethyl citrate considered at
one time to be a scavenger?
DR. WEAVER: I don't believe it's properly called
a scavenger. We have discussed this with the people who
discovered this — this is Ohio Oil Company — and they
describe it as a modifier of the deposit. They believe it
affects the form of the deposit on the spark plugs. They
have no information that has any effect on the deposits in
the combustion chamber or that it might affect the hydro-
carbon emissions.
MR. HELLMAN: So that to reinforce what you said,
there isn't any additive that you are aware of that could be
added to the additive package that includes MMT to alleviate
the combustion chamber process?
DR. WEAVER: That's right. I'm not aware of any
additive.
MR. HELLMAN: You mentioned that some of the
difference in the deposit formation in the engines could be
due to the combustion chamber design.
Do you know what causes that, or you weren't sure?
DR. WEAVER: Ethyl Corporation has suggested
squish, and I don't even know what squish is. You probably
5 R. WILSON
SHORTHAND REPORTERS
(418) 543-3104/461-3098
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FORD
417
know, and I'm sorry that's not very helpful.
MR. HELLMAN: Suppose there were a combustion
chamber that was found to result in less adverse effect from
MMT. Would there be sufficient time for Ford to introduce
such a chamber for the years we are talking about?
DR. WEAVER: No, there would not.
First of all, we have not identified exactly what
changes would have to be made in order to achieve the result
you suggested. Since we don't know what that change is, it's
very difficult to put a time on how long it will take to put
that into effect. But it doesn't look like it's possible
for the time that you are talking about.
MR. HELLMAN: Is it possible that the combustion
chamber could be coated with something that would reduce the
buildup?
DR. WEAVER: I guess that's possible, but I have no
information.
MR. HELLMAN: Again, it would be a lead time problem;
is that right?
DR. WEAVER: Yes. Again, we'd have to demonstrate
that such a thing would work, and there's not enough time to
do it. We need to start certification very shortly now.
MR. HELLMAN: Were the exhaust temperatures on these
vehicles that were run typical?
DR. WEAVER: They are typical of that kind of system.
They are lower than many of the systems which we have built
previously.
MR. HELLMAN: There has been mention in the past of
5 R. WILSON
SHORTHAND REPORTERS
(418) 84 J-J194M61-3QM
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FORD
418
a threshold for plugging in MMT.
DR. WEAVER: Yes.
MR. HELLMAN: These were below?
DR. WEAVER: Well below the threshold of 1500
degrees, yes.
MR. HELLMAN: California will give a credit for
methane in the exhaust. Were the results that you mentioned
total hydrocarbons?
DR. WEAVER: This analysis was strictly on the basis
of total hydrocarbons, but if you wanted to look at any of
these graphs, if you merely replace .41 with 3.9, then you
would have objectives which would be non-methane. It
certainly would be easier to meet non-methane objectives of
4,000 miles than total hydrocarbons. But in my opinion, it
still doesn't make the problem go away.
MR. HELLMAN: Does MMT change the percentage of the
exhaust of catalyst carbons in methane?
DR. WEAVER: No, it does not.
MR. HELLMAN: It's the same?
DR. WEAVER: Yes.
MR. HELLMAN: So there is no beneficial impact on
the credit for methane in the exhaust?
DR. WEAVER: No effect that I have been able to
see.
MR. HELLMAN: If you redid your analysis based on
non-methane hydrocarbon, assuming that California would allow
procedures for computing it or measuring it, would that change
your conclusions about the ability to meet the .41 standard?
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DR. WEAVER: No, it would not be changed.
MR. GRAY: Just to clarify the data you presented,
the data that you have collected thus far comparing MMT to
clear fuel was at the 1/8 of a gram level of MMT?
DR. WEAVER: Yes, it was.
MR. GRAY: You have not investigated other levels?
DR. WEAVER: We are starting such a fleet now.
MR. GRAY: I just wanted to be sure that was clear.
Okay. While you've the same qualification to your
support of the California waiver for light- and medium-duty
trucks that you made for passenger cars — That is, the need
to remove MMT from the fuel — can you provide a technical
judgment as to the appropriateness of those levels as compared
to the passenger car levels with regards to the differences
between these vehicles?
In other words, if you installed the same basic
technology that you are using for passenger cars on the light-
and medium-duty trucks, do you think that those adjusted levels
are reasonable? They are reasonably adjusted to account for
whatever differences there are between these types of vehicles?
DR. WEAVER: I guess I don't get your question yet.
MR. GRAY: As I understand your statement, you have
provided general support to that waiver request with the
qualification that MMT should be taken out of the fuel?
DR. WEAVER: Yes.
MR. GRAY: I want to pursue that and ask: Do you
think that those levels, light-duty truck and medium-duty
truck levels, as compared to the passenger car levels are
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420
technically reasonable from an adjustment standpoint?
MS. PETRAUSKAS: I'm sorry, Mr. Gray, but what do you
mean by "from an adjustment standpoint"?
MR. GRAY: The levels are different. As the CARB
mentioned earlier, their intent was to establish levels for
those vehicles that would be essentially equivalent to the
levels that those vehicles would have with the passenger car
technology.
In other words, if you took your passenger car
technology and applied it to the light-duty and medium-duty
vehicles, in their judgment those were the levels that you
would achieve. I am asking if that seems to be a reasonable
technical adjustment to account for the differences among
those vehicles.
MR. JENSEN: We didn't analyze it that way, but we
didn't argue about the levels that are here. Our truck people
and our truck engineers looked at it and said we could meet it
with three-way catalysts as we could with the — probably with
three-way catalysts because of the fuel economy benefit that
Mr. Austin mentioned earlier.
MR. GRAY: Okay. So a general answer would be that
the same basic technology could allow you to achieve those
levels as well as the passenger car levels?
DR. WEAVER: Yes, sir.
MR. HELLMAN: I'd like to ask you to clarify the
statement you made about the three-way catalyst.
On Page 10 of your prepared statement, the third
line, you indicate if MMT is eliminated from the fuel, you can
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FORD x
meet the 1979-80 light-duty truck standards with current
emission control technology.
Do I take what you just said about the three-way
to mean you feel you could do it with either system?
MR. JENSEN: Yes. One of the reasons we are speaking
of current technology is we do know what the fuel economy
requirements are going to be in the energy act for passenger
cars. As you know, the DOT has set them for '79 model trucks,
but we don't know what's going to be set beyond that.
President Carter has indicated in his energy message
that he is going to crack down on fuel economy standards for
trucks too. As Mr. Austin mentioned, there are benefits in
three-way catalyst technology with respect to fuel economy
that we have to consider if you are going to squeeze down
on trucks. We don't know what it is yet.
MR. HELLMAN: Okay. If I were to say as far as
only the emission controls go, you feel that with the current
oxidation-type system you could meet these levels and you
could also meet them with the three-way system but the choice
of the system may depend on things that are not directly
related to the emission standards, such as fuel economy
standards?
MR. JENSEN: At the Air Resources Board hearing, we
submitted some materials on this. If you want, we can submit
that for the record. It agrees with what I've said, but you
may want this in the written record.
MS. PETRAUSKAS: What it does is it provides an
assessment of the likelihood of knowledge that we think would
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be used at various levels and the recommendations we would make
with respect to standards.
It was Attachment C to Mr. Jensen's statement of
November 23rd. We'd like to submit it for the record at this
hearing.
MR. GRAY: Okay. I have one more question regarding
the light-duty truck area.
You mentioned a concern regarding the grouping that
California has established for trucks, and you indicated that
at least at this time you do not have any vehicles in the
zero to 3,999 pound test weight category.
The question is: Do you expect that situation to
continue? Do you anticipate that Ford will in the future offer
a vehicle in that grouping?
MR. JENSEN; We don't think so. We think everything
would fall in the middle group there, 4,00 0 to 5,999.
The incentive for going down to the lower level
you'd lose with the difference in the hydrocarbon standards.
Our truck people tell me that the way this stands
now we'd all be in the middle group.
MR. GRAY: Is there any way that these graduated
standards would discourage you from going to a lighter truck?
Would that influence your decision?
MR. JENSEN: I think so. If you have to meet a
.41 grams of hydrocarbon rather than .5, you'd probably — if
you were on a borderline, you'd stay with the .5 rather than
go down to a lighter truck.
MR. HELLMAN: Let me clarify something for the
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FORD
423
record.
Ford markets a vehicle called the Courrier which is
a lightweight pickup truck.
MR. JENSEN: Yes.
MR. HELLMAN: Your statements don't refer to that
vehicle, do they, since the vehicle is apparently certified
by another manufacturer?
MS. PETRAUSKAS; The importer of that vehicle, but
the contractual relationship between us and Toyo Kogyo is
such that Toyo obtains all of its required certification for
the importers and marketers of the vehicle.
MR. GRAY: The next question I have is related to
the adjustability issue.
You made the statement that if the recommended idle
air/fuel mixture service procedure called for the removal of
the carburetor in the qualifications that you provided for
your support of that regulation, would you think it equally
appropriate to say if the recommended idle air/fuel mixture
actually requires the removal of the carburetor? Is that
what was intended, or am I reading too much into it?
MS. PETRAUSKAS: It's not clear whether you are
characterizing our testimony or CARB's.
MR. GRAY: I'm trying to relate the two, so perhaps
we can resolve some of the confusion that exists now.
California made some specific statements regarding
what they would accept, and the purpose of that question was
to see if indeed your qualifications on your support are now
satisfied. I think California said that it would not
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FORD
424
necessarily suffice that the service procedure called for the
removal of the carburetor if in fact the carburetor was not
necessarily removed during servicing. In other words, if it
did not actually require the carburetor to be removed/ even
though the service instructions said remove it.
MS. PETRAUSKAS: Mr. Gray, I think the concern we
had was what alternate demonstration of compliance would be
acceptable other than demonstration that the carburetor would
have to be removed. That's why we questioned the manner in
which the special tool or special procedure matter would be
implemented.
MR. GRAY: Let me ask it this way, then —
MS. PETRAUSKAS: If I understood what was said this
morning — Well, maybe I'll let you characterize it.
MR. JENSEN: The intent that Mr. Austin expressed
verbally as he answered your questions seemed to satisfy our
problem. It clarified it.
MR. GRAY: Okay. Well, that gets to the heart of
the question.
MR. JENSEN: Yes.
CHAIRMAN JACKSON: One final question, Mr. Jensen.
Did you follow the question I was asking Mr. Austin
about the potential backlash associated with the adjustability
regulations?
MR. JENSEN: Yes.
CHAIRMAN JACKSON: Do you have a view on that?
MR. JENSEN: We think it's our responsibility to
build cars that are competitive and drivable, and we think we
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FORD
are doing it with '77 models.
As a matter of courtesy, we know that they are look-
ing at this in California. We have offered to work with them
and have our drivability experts show them at least how we
determine whatfe drivable, what's good performance for the
customer. We think it's our responsibility no matter what
they do.
We've supported the idea of restricting maintenance,
because we want to get away from this in-use tampering and
so forth. We think we can do that and give a good, drivable
automobile to the customer so there is no backlash. That's
our job, and we will do it.
CHAIRMAN JACKSON: Will the corporation take the
position that in the event that you did have a customer that
did have a problem that you, as opposed to the dealer, will
cover that problem?
MS. PETRAUSKAS: I don't understand your question,
Mr. Jackson.
CHAIRMAN JACKSON: If you do by chance produce a
f
car that does not have adjustable parameters on it and it
doesn't perform acceptably, a reasonable man would agree that
it doesn't perform acceptably, would the corporation —
company in your case — take the responsibility of making that
right to the consumer or would you leave it up to the dealer
or just exactly what position would you take?
MS. PETRAUSKAS: We fix some of those problems
today under our 12-month or 12,000-mile warranty.
CHAIRMAN JACKSON: I'm talking about all of those
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FORD/GM
kinds of problems.
MR. HENSEN: We refer people initially to the
dealers. If the dealers can't take care of it, then we have
a district man who works for the company who goes out and
works with the customer and the dealer. We try to go through
the dealer, but we also have an appeal procedure where you
can get all the way to the Dearborn office.
But it's our job to keep those customers happy one
way or another, but the first step is usually with the dealer
and then we follow it up with the district service representa-
tive who goes out and works first with the dealer and then
with the customer so we end up with a satisfied customer.
CHAIRMAN JACKSON: Your answer is, then, the
company will take that responsibility?
MR. JENSEN; They do now, and they will continue to
do so.
CHAIRMAN JACKSON: Mr. Jensen, thank you very much.
MR. JENSEN: Thank you.
CHAIRMAN JACKSON: I think it's time to take the
noon recess, and we will reconvene at 1:15.
(Noon recess.)
MR. NELSON: Good afternoon. My name is Ed Nelson.
I am Assistant Director of Automotive Emission Control,
General Motors Environmental Activity Staff.
This afternoon I have three other members of
General Motors with me to help answer your questions.
These gentlemen are Mr. Hanson at the end of the
table, Mr. Schwochert. Mr. Hanson is a staff engineer from
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GM
427
Chevrolet Motor Division, and Mr. Schwochert is also a staff
engineer with the Environmental Activity Staff.
On my left is Mr. Petersen, an attorney with General
Motors legal staff.
At this time, I'd like to ask which of the subjects
you'd like to consider first. Is there any particular order
that you desire us to discuss these items?
CHAIRMAN JACKSON: I think so. I have mine ordered
in the following order: 1980 and subsequent model year exhaust
emissions standards for passenger cars, 1979 and subsequent
model year exhaust emissions standards for light-duty truck
and medium—duty vehiclss, and adjustability of idle mixture
mechanism.
MR. NELSON: Okay. At this time, I'd like to ask
Mr. Schwochert to present the General Motors statement on
1980 and subsequent standards.
MR. SCHOWCHERT: General Motors offers the following
comments regarding EPA's consideration of granting California
a waiver which would implement an NOx passenger car standard of
1.0 grams per mile fot 1980 and subsequent model years. This
waiver, if granted, would continue the present HC and CO
standards of 0.41 and 9.0 grams per mile respectively.
New emission standards usually require the intro-
duction of new or improved emission control hardware. To this
end, GM has told both California and federal officials of our
plans to inroduce in California starting with the 1978 model
year, two engine families using Phase II catalyst systems.
That is, systems with three-way catalysts and
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GM 42 8
closed-loop fuel metering. This introduction is dependent
upon successful completion of the certification requirements
which are presently underway.
The limited volume introduction technique is an
effective and, we believe, a prudent way of doing business.
The introduction of this new emission control hardware two
years prior to the 1980 model year will allow GM to gain
production and field experience prior to mass introduction when
this hardware may be required to meet more stringent emission
standards. Both EPA and ARB recognize that bringing on line
"New Technology" is what allows more stringent standards to
be met.
Assuming success of 1978 and 1979 introductory three-
way programs, General Motors plans to offer for sale in the
1980 model year in California vehicles with three-way catalysts
and closed-loop fuel metering in as many sizes and weight
categories as can be certified to meet the emission standards.
At this time, we cannot predict if this emission control
hardware, as applied to a full product line-up, will result
in certification of all models currently offered for sale in
California. Considerably fewer model-engine-transmission-
carburetor combinations are presently available in California
compared to the remaining 49 states. It is too early to pre-
• availability will diminish even
diet if the California model avaa-xaoiJ- *
further in 1980.
The present Clean Air Act Amendment considerations
,sflr..hie discussion of more stringent
have resulted in considerable
. standards and associated fuel economy
federal exhaust emission stanaacu*
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GM
429
levels. Using the 1977 federal vehicle as a baseline, GM
has estimated from the available data that the fuel economy
penalty associated with standards of 0.41, 9.0 and 1.0 grams
per mile hydrocarbon, CO and NOx respectively will be in the
range of 0-20%. 1977 model GM vehicles for California
presently experience an average of 11% fuel economy less
compared to 1977 model federal vehicles. The present experi-
mental data are too inconclusive to predict whether 1980
model California vehicles will show an additional penalty or a
gain over 1977 model experience.
The use of three-way catalysts and closed-looped
fuel metering will increase the emission control system hard-
ware first cost. Using the 1977 federal vehicle as the base,
,, . „ iq estimated to be $110 to $130.
the cost increase range is es^xu«»<-=
Several unknowns greatly increase the complexity of
this subject of future exhaust emission standards and may have
large impacts on technological feasibility, fuel economy,
model availability and emission control hardware costs. The
are (1) Will future engines and
major unknowns at this time
4.^0 he subiected to the fuel additive
emission control systems be suoj
. , • which could make emission
MMT or similar outside influences wnicn c
. , (2) Will California restrict the
control more difficult/
Mrs emission systems? (3) Will
allowable maintenance on future emxsa
*»hiish the CO standard at 3.4 grams per
federal legislation establish tne v.
1 stringent than the California
mile or some other level more strmgen
mile? General Motors contends that
standard of 9.0 grams per mile/
¦important considerations and could have a
these questions are important
„u ^vmoloaical feasibility of meeting
major influence on the techno
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GM
430
this standard.
With respect to the applicatin of the proposed
standards for diesel-powered passenger cars based on the data
available to GM today, it is very likely that the one gram per
mile NO standard, in combination with the .41 gram per mile
hydrocarbon standard, will remove the present GM diesel
engines as alternative power plants for the 1980 model year
passenger cars. We continue to have serious reservations
about the ability to achieve one gram per mile NOv with diesel
engines.
These reservations stem from the limited experience
with emission control diesels compared to the vast amount of
experience of gasoline engines. Additional time is required
to fully assess the emission control capability of diesel
engines, including the effects of EGR which may be required to
obtain lower NO levels on engine durability.
The effects of future diesel emission control
concepts on gaseous hydrocarbon emissions, particulates, smoke,
noise and odor are also required. We recently recognized
that tests on certain of the hydrocarbon measures increases
the reservations about the ability of diesel engines to meet
more stringent standards.
General Motors also believes the issues concerning
the need for this NO standard are considerably more complex
than the issues surrounding the need for HC and CO control.
It is generally agreed that reduced NOx will increase formation
of photochemical oxidant near the emission source which
generally is also the area of greatest population density.
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GM
431
However, the effect of reduced N0x on immediate downwind
areas which also have their own emission sources is not at all
clear. A question that exists is how will the levels of both
NO2 and oxidant be affected in all portions of the Los
Angeles Basin and other areas of the state. Will the control
of one air pollutant, oxidant, be traded off for control of
another, N02, and is this a good trade-off?
The questions are extremely complex and neither GM
nor anyone else has all the answers at this time. General
Motors suggests that prior to granting the waiver, EPA should
be convinced that this is the correct control strategy for
California. GM is concerned that this N0x standard may result
in a net trade-off which will aggravate oxidant concentrations
in some California locations which already have oxidant prob-
lems, while reducing the N02 concentrations in these same
areas which presently do not exceed the N02 Air Quality
Standard.
That completes this statement on the 1980 passenger-
car standards. Would you like to go into the next statement?
CHAIRMAN JACKSON: Yes.
MR. SCHWOCHERT: With respect to California's
request for a waiver to require light-duty trucks and medium
duty vehicles to effectively meet passenger car exhaust
standards, General Motors offers the following comments.
The HC and CO standards would become effective with
the 1979 model year for light-duty trucks and all three
exhaust constituent standards would be effective for both
classes of vehicles in 1981. Furthermore, if the waiver is
THOMAS R. WILSON
CIRTIPIfO SHORTHAND MMMTBM
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GM
432
1 granted, essentially all GM 1981 model year medium-duty
2 vehicles would be required to meet the same exhaust standards
3 as light-duty trucks.
4 General Motors certainly acknowledges that
5 California has special air pollution problems which require
6 emission control strategies different from the remaining 49
7 states. We have always recognized the need for additional
8 hydrocarbon control and do not question that this condition
9 continues to exist.
10 The question which we believe is pertinent to this
11 issue of more stringent truck standards is technological
12 feasibility. Based on GM development test results at this
13 time, we have not to our satisfaction demonstrated the ability
14 to meet the required hydrocarbon levels. We believe it is
15 our responsibility to report our data as it exists at any
16 given time. A summaryof hydrocarbon development test data on
17 our 350 cubic indidisplacement V-8 and 250 cubic inch displace-
18 ment six cylinder engines with both automatic and manual
19 transmissions is shown on the figure attached to the statement
20 that we have provided to the panel. As is noted on the figure,
21 this data is predicated on fuel without MMT.
22 Our development work has not gone far enough to
23 positively identify the truck models which will be available
24 in California if the waiver is not granted. Based on present
25 development work and past experience,it is quite likely that
26 our manual transmission offerings will be reduced, if not
27 eliminated, because of their greater difficulty of meeting
28 the more stringent hydrocarbon standards. If manual
THOMAS R. WILSON
CEMTIFICO SHORTHAND RBPORTIR#
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transmissions cannot be offered in California, granting this
waiver for more stringent emission standards will be incon-
sistent with the energy conservation measures we are being
encouraged to make by other regulatory agencies. NHTSA is
encouraging GM to increase the usage of manual transmission
vehicles by offering sales incentives. This encouragement
is of little value if these veihcles are removed from the
marketplace by overly stringent emission standards.
For informational reasons, it may be appropriate to
review the engine and transmission restrictions that already
exist in California due to different emission standards. For
the 1977 model year, only two engine displacements are offered
in California light-duty trucks compared to four-engine
displacements in federal vehicles. Four-speed manual
transmissions are not offered in California at all and even
manual three-speed transmissions are not available in some
models.
For 1978, we plan to offer only three engine
displacements in California for medium-duty trucks compared to
six of the comparable federal vehicles.
We also cannot accurately quantify the fuel economy
penalty associated with these more stringent standards because
our development work has not yet progressed far enough to
identify the emission control system calibrations that can be
used to meet the standards. Since present passenger car
control systems and calibrations do not provide the required
degree of control especially for hydrocarbons, the engine
calibration changes that are required to decrease engine
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GxM
434
hydrocarbon emissions have historically shown associated fuel
economy penalties. If the waiver is granted, we believe,
DOT will have to account for the fuel economy loss associated
with more stringent exhaust emission standards when
establishing the maximum feasible fuel economy level for this
type of vehicle.
The present development test results reflect the
inherent differences between the emission levels achievable
by trucks compared to passenger cars. On numerous occasions,
GM has testified to both EPA and ARB that we do not support the
concept that light-duty and medium-duty trucks can or should
be regulated to the same emissions levels as passenger cars.
Customers purchase trucks in preference to passenger
cars either because they intend to use them as commercial
vehicles, or because they require special utilitarian features.
Some of these utilitarian features are the ability to carry
cargo or passengers or both, the ability to be used for off-
highway operation, the abililty to be used as a tow vehicle,
and many other features. Light-duty trucks are designed to
be versatile and to carry heavy loads as well as bulky cargo.
They are used in agriculture, construction, wholesale and
retail trade, and for personal and recreational purposes.
Light-duty trucks are designed and developed in
order to be capable of serving a commercial purpose. These
trucks do not and cannot use passenger car drive trains except
in rare caess. Even when passenger car drive trains are used,
trucks are tested at higher dynamometer horsepower loadings.
Further, the differences from passenger cars occur because
trucks must use higher transmission and axle ratios to perform
HOMAS R. WILSON
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their designed vocational functions, with a high percentage
incorporating manual transmissions. This limits their emission
control capability compared to passenger cars.
Even the passenger carrying derivatives of trucks —
the vans, truck station wagons, and the Blazer off-road-type
vehicles, are designed to retain the cargo and load carrying
capabilities of the parent work-oriented vehicle. These
trucks, which are modified to carry passengers, are still
fundamentally trucks and are capable of the same duty cycle as
the basic commercial vehicle. Their design, development and
production are totally integrated with trucks and they probably
would not exist at all as a primary vehicle.
Some of our passenger car lines have been downsized
and others are currently being downsized primarily for fuel
economy considerations. On the other hand, the light-duty
truck category has been extended from 6000 to 8500 pounds GVWR
by regulatory action. Downsizing is not an option in dealing
with trucks if they are to continue to retain their vocational
capability. In the near future, most of our lightest trucks
will equal or exceed the weight of our heaviest cars. When
this is considered along with the higher dynamometer horse-
power settings and higher N/V ratios of trucks, we believe
that trucks, even when using similar emission control systems,
cannot have the same ultimate emission control capabilities
as passenger cars. Therefore, we must conclude that there is
a definite difference between passenger cars and trucks which
we believe should be appropriately recognized.
Accordingly, we find the exhaust emission standards
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established by the ARB for light-duty trucks and medium-duty
vehicles which are keyed to passenger car levels as not tech-
nically justified or properly proportioned. Although we agree
with the ARB staff's concept of attempting to adjust the
emission standards as a function of test weight so that the
emission standards can be met with similar emission control
hardware, we do not believe the proposal has accomplished
this objective with respect to the hydrocarbon standard.
Based on General Motors development work to date, our data
indicate that the hydrocarbon standard has not been generally
adjusted for vehicle size so that similar passenger car
control systems, when applied to trucks, do not achieve the
required emission levels.
A review of present model year assembly line test
data supports our questioning of the ratio of trucks to
passenger car standards, but we do not believe that this is
sufficient evidence in itself to establish the proper
relationship. GM 1977 model year passenger cars and light-
duty trucks with 350 cubic inch displacement engines —
these vehicles are from engine families 710J45 and 712J4 —
have essentially the same emission control hardware. A
comparison of the ratio of truck to car hydrocarbon emissions
based on 1977 GM assembly line test data through March 31
projected to 50,000 miles and adjusted for methane is 2,08
compared to 1.22 for the standards established by California.
This morning there was some discussion regarding the use of
DF. If one looks at the data without the application of
DF, the ratio of cars to trucks becomes 1.59 to 1.77, depending
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on whether or not you adjust the trucks hydrocarbon emission
for methane. If these data alone were used to establish
the truck hydrocarbon standard which would be equivalent to
0.41 grams per mile for passenger cars, the standard would
be 0.8 5 grams per mile for trucks. These data are based on
comparable dynamometer road load horsepower settings for
light-duty trucks and passenger cars. The new test procedure
for 1978 and subsequent model year trucks increases the
dynamometer horsepower setting by as much as 50%. GM does
not propose that the standards be increased by this amount
in the above example, but we have used the example to demon-
strate that the standard established by California does not
account for the actual difference between truck and passenger
car emissions.
Additionally, the ARB's categorization of trucks
by test weight has not, in our opinion, accomplished the
objective of adjusting the standards upward for larger trucks.
Almost all of General Motors trucks fall within the 4000-5999
pound inertia weight category although they span a gross
vehicle weight range of about 3500 pounds. Our present diesel
engine, based on the data available to GM today, is likely to
be removed from California trucks in 1979 because of the
.5 gram per mile hydrocarbon standards. This condition is
further complicated by the recently recognized test uncer-
tainties of hydrocarbon measurement.
In conclusion, for these reasons, General Motors
recommends that the EPA delay the waiver for the proposed
California standards and require manufacturers to work with
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the Air Resources Board in establishing the truck standards
which will accomp ish the Board's objective regarding the
use of the best available emission control hardware on
passenger cars and trucks.
It is General Motors position that a temporary delay
in implementation of more stringent truck standards is in the
public interest. This delay will provide time for proper
adjustment of the test categories and allow establishing the
correct relationship between passenger car and truck standards
within the categories of various truck weights.
A slight delay of one of two years will not have a
significant impact on California's air quality. Information
presented by the ARB staff shows that hydrocarbon emissions
are projected to be reduced by eight tons per day in 1990 as a
result of the truck hydrocarbon exhaust emission standards
under consideration today. This reduction should be viewed
in light of the ARB staff's overall projection of 1273 tons
per day of hydrocarbons in 1990. Using these projections,
the reduction achieved by the proposed truck exhaust hydro-
carbon standards amounts to only six tenths of one percent if
implemented as adopted. A delay of one to two years will only
reduce the eight tons per day projected benefit by only a
small fraction of the eight tons per day in 1990.
MR. NELSON: Mr. Jackson, we have some additional
comments that we would like to make to help clarify some of
the issues that were brought up this morning. We'd just as
soon do that before you get into the question-and-answer
session with regard to this issue.
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We've got one more statement that we'd like to
continue to read at this time.
MR. SCHWOCHERT: General Motors offers the following
comments regarding EPA's consideration of granting California
a waiver for requiring that idle mixture mechanisms on 1980
and subsequent model year passenger cars and 1981 and subse-
quent model year trucks be designed so that maladjustment is
discouraged or difficult to perform.
The EPA hearing announcement which noticed this
subject referred to the regulation as . . imposing a
restriction on allowable maintenance." To General Motors'
knowledge, California has not adopted any regulations which
restrict allowable maintenance and we therefore conclude that
idle air/fuel mixture adjustability is the subject which is
being considered.
The issue of idle air/fuel mixture adjustability is
addressed in Section 5.e of "California Exhaust Emission
Standards and Test Procedures for 1980 and Subsequent Model
Passenger Cars, Light-duty Trucks and Medium-duty Vehicles"
as amended December 14, 1976. Our interpretation of the
requirement set forth in this section is that if the adjust-
ment mechanism were hidden from view such as would occur if
the idle mixture screw were located in a counterbore in
the throttle body and the cavity were covered with a metal
plug or if the carburetor had to be removed from the vehicle
to provide access to the idle mixture mechanism, then the
California regulation will be met.
General Motors currently is engaged in a program
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which will result in carburetor idle mixture adjustment
mechanism design changes that we believe will accomplish the
objective of the California regulation. Earlier this year, GM
produced about 5,000 production vehicles with sealed idle
mixture screws. This limited production program should
provide the field experience required to implement the design
changes across all GM product lines. We currently plan to
implement the covered idle mixture screws carburetor design
for most GM carburetors by the 1979 model year.
This California requirement is not objectional to
General Motors as long as the rulemaking does not nullify the
programs at GM that have been underway well in advance of the
ARB's consideration of this subject. We assume our current
designs, such as used in the 5,000 car program, do meet the
California regulation.
MR. NELSON: Thank you. We have several comments
that we would like to make on the issues that were brought up
this morning that were either quite confusing and/or mislead-
ing.
Number one, we want to answer questions on the
General Motors' program that was designed to determine the
emission characteristics as a function of inertia weight.
Number two, we would like to explain for the record
the situation where GM was accused of misleading the staff last
November on deterioration factors and the charge that we were
continuing to use the same information in a GM statement that
was presented today.
As number three, I'd like to object to the ARB
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staff statement this morning that implied that GM made a
recommendation in an oral statement as to the specific hydro-
carbon standards for California. The General Motors'
statement did not include a specific recommendation, but
instead an illustration of one of the problems with the
car and truck relationship.
Now at this time I'd like to ask Ken Hanson to answer
the questions on the program that was designed to evaluate
emissions as a function of inertia weight.
MR. HANSON: If you don't mind, Ed, I'd like to take
the deterioration factors up first. There seems to be some
confusion on that as to what are comparable deterioration
factors as compared to the emission characteristics of trucks
and cars.
As the ARB pointed out, if you compare the cars and
trucks for 1977 that have comparable engines, the deteriora-
tion factors are not comparable because most of the trucks
were carried over from 197 6 when the certification fuel was
different. I recognize that fact, and the ARB also suggested
that a comparison of 197 6 deterioration factors between cars
and trucks shows there is relatively little difference in the
hydrocarbon deterioration.
Well, I have a problem with that comparison in that
most of the cars for '76 were carried over from '75, and they
did not have the benefit of the 1976 knowledge.
I think it's also significant that in those early
days of catalyst technology, 1975 and 197 6, we were on a
fairly steep learning curve, not only with the catalysts, but
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the associated systems that went along with it. Just as an
example, our catalyst supplier has informed me that the
catalysts that eventually were put into production in 1975
were quite a bit better than the prototypes we actually
certified with. This was strictly due to the technology
developed in the manufacturing process.
I think the best possible comparison that you can
make between car and truck deterioration factors, considering
all this, would be for 1975. During the 1975 model year, all
of the trucks and all of the cars were recertified. They
all used the same fuel and they all used the same generation
of catalysts. If this deterioration issue is so important,
I'd like to read these numbers into the record.
This is a comparison of cars versus trucks using the
same engines and the same catalytic converter control systems
run on the same fuels and the same catalysts. The average
numbers for the federal cars was 1.51 hydrocarbon deteriora-
tion. The comparable number for trucks was 2.09. For the
California vehicles, the hydrocarbon deterioration factor for
cars averaged 1.38, and the factor for trucks averaged 1.84.
I think this information continues to make us believe that
there is difference in deterioration between cars and trucks,
and we think there are probably some inherent reasons for
those differences.
Also, I'd like to point out that in the graph
attached to our statement, we tried to describe the state of
development of our trucks targeted at the California 1979
standards, and we assumed some deterioration factors to project
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the data at 50,000 miles. The deterioration factors we
assumed were 1.15 for V-8 engines and 1.30 for six-cylinder
engines. These factors are very optimistic and considerably
lower than any factors discussed thus far. In the case of
the six-cylinder, it is considerably lower than the existing
passenger car deterioration factor.
I'd also like to point out that these factors are
based on clear fuel tests for 50,000 miles.
Some other General Motors' data that was quoted was
relative to the effect of the new truck test procedure on
hydrocarbon emissions, and we did present some data last
November on that subject.
As you know, we worked with the EPA to develop a new
dynamometer horsepower factor for trucks. When that factor
was eventually promulgated and accepted, we just went to work
using that particular factor. We really didn't make any
attempt to evaluate that new dynamometer horsepower setting to
the old one. So, we went back through our development work
to see if we could find any back-to-back tests, and we did
find this one. I believe the ARB quoted the results this
morning, that for the 50 percent increase in dynamometer
horsepower on 250 automatic transmission vehicles, there was
no change in hydrocarbons, an 18 percent change in CO, and a
16 percent change in oxides of nitrogen, higher of course.
We don't know what the effect would be on other
vehicles, and it was really of little concern to us because
we hadn't used the new factors, so we have gone to work using
those. What our truck development people have told me lately
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is that we have underestimated the effect of that dynamometer
horsepower setting, and it's causing a great deal of problems
we are having with hydrocarbons.
I think it must be recognized that the increases in
CO and oxide of nitrogen have to be dealt with within the
calibrations. Generally, as oxides of nitrogen are reduced
through EGR and other methods, there is an interaction with
hydrocarbons.
The other General Motors' data that was referred to
was a specific test program that was run on a number of trucks,
three different models, comparing the emissions at 4,000
pounds inertia weight and 6,000 pounds inertia weight. For
the record, I would like to say that those were all run at
constant horsepower, because horsepower is no longer a function
of inertia weight. Also, this particular program was not
run to make any comparison between truck and car capability.
The object of the program was to try to compare the range of
values that we might expect within one class that the ARB has
established.
As you know, they have established break points of
4,000 pounds GVW and 6,000 pounds GVW initially for the three
different classes of trucks and the three different levels of
emissions.
To repeat the data that the ARB quoted, we found
an increase of 2 3 percent in hydrocarbons, 44 percent in
CO, and 21 percent in oxides of nitrogen. This would be with
the same systems, same calibrations, just changing the inertia
weight from the lower extreme of 4,000 to the upper extreme of
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6,000 pounds. The way the regulations are working out,
essentially all of our vehicles are in that middle range,
so the graduated emission standards essentially do not affect
us at all.
I would expect the increase in hydrocarbon, the
2 3 percent increase, to become greater as the oxides of
nitrogen and the CO is brought under greater control.
That's all the comments I have about that.
MR. NELSON: Thank you for allowing us to make the
additional statements. We are now ready to answer questions.
CHAIRMAN JACKSON: With regard to your statement on
1980 and subsequent model year exhaust emission standards,
I think the record will reflect that on Page 2, in the last
paragraph of your item listed No. 1, you inserted the word
"could" in the sentence, "Will future engines and emission
control systems be subjected to the fuel additives MMT or
similar outside influences which could make emission control
more difficult?"
By inserting that word, did you intend to infer
that you are not sure that MMT will make the meeting of
emission standards more difficult?
MR. NELSON: We are definitely sure that MMT will
make emission control more difficult. We pretty much agree
with the statements that were made this morning on the
hydrocarbon increases and the effect it would have or
potential effect it could have on emission control systems.
CHAIRMAN JACKSON: Do you believe it would be
appropriate to say "will make"?
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MR. NELSON: Well, we were talking about general
unknowns in the future, and it wouldn't have to be MMT. It
could be one that has a similar problem.
CHAIRMAN JACKSON: Well, with regard to MMT, is it
correct to say "will make"?
MR. NELSON: Yes, sir.
MR. GRAY: Are you aware of any technology that
can meet these levels with MMT in the fuel or has the potential
even?
MR. NELSON: The problem that we visualize today
with today's technology is that we would have to change the
calibration to a point where we might lose fuel economy, and
we have not run across a technology which would allow us to
do the same job without loss in fuel economy. So, no, we
do not have the technology that would allow us to get there.
MR. GRAY: Without fuel economy penalty or at all?
MR. NELSON: With today's experience, without a
fuel economy penalty.
MR. HELLMAN: My understanding of what Ford mentioned
earlier this morning was that they thought with MMT fuel they
could not make the emission standards at all, and you are
saying that — do I interpret correctly that what you are
saying is that you could meet the standards with MMT in the
fuel; however, the fuel economy performance for vehicles
calibrated in that manner would be unacceptable?
MR. NELSON: We have presented some information
here that would allow one to believe that if progress occurs,
we might be able to certify one engine without MMT in the fuel,
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and I am suggesting that if we had to certify with MMT, we
would have to recalibrate to include the hydrocarbon increase
and thereby have a fuel economy loss.
MR. SCHWOCHERT: Mr. Chairman, I don't think we are
trying to say that based on what we know today, we can certify
with MMT in the fuel. We don't know. We can't make the
judgment today whether we could or could not certify with MMT
in the fuel.
As a matter of fact, we can't even make the judgment
today whether we can certify in all of our product lines
without MMT in the fuel. We don't have that particular
information that says we can certify today with MMT in the
fuel. But it would be more difficult, certainly, because of
the hydrocarbon increases if you were able to certify to the
198 0 standards.
CHAIRMAN JACKSON: Do you have enough information to
say whether technology is available to meet the standards for
which a waiver is requested if MMT is not in the fuel?
MR. HANSON: If MMT is not used in the certification
fuel, based on these results that we have shown thus far, we
think that we can probably certify one engine/transmission
combination. I'm talking about trucks.
Are we getting confused here between trucks and
cars?
CHAIRMAN JACKSON: I was asking the question with
regard to both.
MR. HANSON: Well, my response would be for trucks.
Now with MMT in the fuel, we have very little experience on
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trucks. I would have to believe that they would behave
similar to what passenger cars have shown today.
CHAIRMAN JACKSON: How about with passenger cars,
the same question?
MR. SCHWOCHERT: As we have pointed out, we are
going to offer a couple of engine families in 1978. Our
programs are geared toward certification with the same types
of systems in 1980 that we are presently certifying for a
couple of engine families in 1978.
Right now we don't have any information that says
that at least on some vehicles we will not be able to certify
at these levels. As we pointed out in our statement, we
don't know. We can't say at this time whether we can certify
across all model lines, but we are heading in that direction
or working toward that end.
CHAIRMAN JACKSON: Then it's fair to conclude that
the technology to certify at the levels contained in the
application for waiver is available?
MR. SCHWOCHERT: We don't have any information
that we can say it's not available.
MR. PETERSEN: What are we talking about again, cars
or trucks? Are we talking about manuals or automatics?
CHAIRMAN JACKSON: We are talking about passenger
cars. We know that you've got one truck line that you can
certify, at least.
MR. HANSON: Out of the four present combinations
that are available in California, it looks like one will make
it. I guess what disturbs us is that the one that shows the
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best promise is the least fuel efficient. It's the biggest
engine, automatic transmission,
CHAIRMAN JACKSON: I have submitted here from the
CARB a couple question that I'd like to go ahead and ask
because of the broad scope of the inquiry.
General Motors has made several statements regarding
air quality. Does GM believe that CARB has not considered
the questions raised by GM on Page 3 of their statement, and
I presume that is in reference to Page 3 of the statement on
passenger cars?
MR. SCHWOCHERT: Is that the question?
CHAIRMAN JACKSON: That's the question.
MR. SCHWOCHERT: As I understand the question, do
we believe that ARB has not considered these items that we
presented?
CHAIRMAN JACKSON: That's correct.
MR. SCHWOCHERT: What we are concerned about is
what is known about these issues and the possible trade-offs
that could result in oxidant and NOj-
I'm not suggesting — we haven't suggested, I
don't think that we have not considered these issues. We
believe that based on the information that's available to us
from our own studies and from an interchange that occurred at
a seminar sponsored by the Air Resources Board in early
January in Los Angeles that the answers to the questions are
not at all clear at this time. What we are suggesting by our
comments on Page 3 is that the EPA ought to be convinced that
this is the correct control strategy. We are not yet
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GM
convinced, based on the information that we have seen from
the Air Resources Board that we saw presented at the seminar
held in January and the work that we have done, that this is
the correct control strategy. And what we are suggesting is
that before you grant this waiver, you ought to be also
convinced this is the correct control strategy.
It appears ARB is convinced, because they have gone
ahead and adopted the standards.
CHAIRMAN JACKSON: I presume you are familiar with
the position we have taken over and over again about public
policy matters as they relate to waivers. We usually defer
to California's judgment on things that do not relate to
technology and lead time.
MR. SCHOWCHERT: This issue, in our judgment,
borders on the one of compelling and extraordinary circum-
stances. If you trade off one compelling and extraordinary
condition that aggravates another compelling and extraordinary
condition — one, if there is such a trade-off, and we believe
there is such a trade-off, then we think this is something that
has to be evaluated under those provisions of the statute.
CHAIRMAN JACKSON: Either way, will it cause the
compelling and extraordinary conditions to go away?
MR. SCHWOCHERT: I don't think that — by "going
away," are you saying will they meet the oxidant and M02 air
quality standard?
CHAIRMAN JACKSON: By either of the two strategies.
MR. SCHWOCHERT: I don't believe the ARB is pro-
jecting that they would not meet the —
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CHAIRMAN JACKSON: No. I am asking you. You are
making the point about the review of the strategy because of
the trade-off having some effect on the compelling and
extraordinary conditions, and I'm suggesting is the trade-off
you are advocating also going to make the compelling and
extraordinary conditions go away?
MR. SCHWOCHERT: I don't think we would say they
will go away. It will perhaps affect the various distribu-
tions of the two primary constituents, oxidant and NO^, that
we are concerned with.
CHAIRMAN JACKSON: The second question by the CARB:
GM contends that the present experimental data are too
inclusive to predict whether 1980 California model vehicles
will show an additional fuel penalty or gain over 1977
California models.
Can you report on the fuel economy levels of your
1978 certification durabilty vehicles which use three-way
catalysts and how these results affect your above statement?
MR. NELSON: I appreciate the interest shown by
ARB. It's the first time to my knowledge they have ever
asked us for a fuel economy estimate. It's a new turn of
events.
We already made an estimate in our report that the
gain in fuel economy could be up to 20 percent, but based on
some other data, it could actually be down to no different
than where we are today. So, we don't have enough information
to make a precise evaluation of where it will end up.
CHAIRMAN JACKSON: Gain could be up to 2 0 percent?
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MR. NELSON: Up to 2 0 percent.
MR. SCHWOCHERT: Penalty.
MR. NELSON: Oh, is it penalty?
MR. HANSON: On federal.
MR. NELSON: That's comparing it to the '77 federal.
MR. HELLMAN: A gain?
MR. NELSON: No. I said it backwards. It's a
penalty.
CHAIRMAN JACKSON: That's too bad.
MR. SCHWOCHERT: Mr. Jackson, we'd just as soon not
use the '78 durability data right now to make an estimate on
what the penalties or gains would be. We think that a better
estimate will be able to be made once the data cars are
certified, and they will have to comprehend the deterioration
factors that are going to be generated from the durability
cars. We think an appropriate evaluation can be made once
the data cars have been certified, which will be soon.
MR. GRAY: But at the present time you can't make
a judgment any more closely than a 20 percent range? Current
models that you say experience 11 percent fuel economy penalty
as compared to the '77 federal models, and the next statement
that was quoted then really refers to that statement in that
you are not sure whether you will get an improvement relative
to that current loss or have additional losses.
Can you not say that you think the '80 system
which you have mentioned should give you more fuel economy,
at least in a general context, won't be better than the
California 1977 vehicles? It seems to imply that the three-way
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catalyst system in your best judgment may not give you an
improved fuel economy situation over your current 1977
California vehicles.
Is this a correct impression to leave the record
with?
MR. SCHWOCHERT: We are talking about different
emission standards in 1980 than we have in 1977, so with that
in mind, we don't feel confident that we can predict that the
average fuel economy in 1980 will be greater than 1977. We
don't feel that we can predict at this time where we will
stand relative to the present penalty range that we are
quoting when we refer to the 1977 federal vehicles.
MR. GRAY: Is that saying with the current '77
GM system on California passenger cars that experiences an
11 percent fuel economy penalty as compared to federal
vehicles may be your optimum system?
MR. SCHWOCHERT: For what year?
MR. GRAY: For 1980, as we were talking about.
MR. SCHWOCHERT: I don't think we are suggesting
that at all, Mr. Gray.
MR. GRAY: Well, let me put it a different way.
It seems like the answer is still nebulous, of sorts.
The only change from 1978 to 1980 in the passenger
car area is a change in the oxide of nitrogen standard from
1.5 to 1. For that change, you are going to introduce the
three-way catalyst, I think you said elsewhere in your
statement.
It was my impression that one of the main reasons
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you were going to introduce that system wasn't to get the
extra gram of NO control because it's a more costly system
as compared to '77 systems.
I believe you also mentioned that the main reason
was to get a fuel economy gain as compared to the '77 systems.
So this seems almost to be inconsistent with that kind of
reasoning.
MR. HANSON: Let me try to answer your question,
Mr. Gray.
On average, the 1977 California vehicles suffer a
penalty of about 11 percent compared to comparable federal
vehicles, and our development fleet right now on three-way
catalyst systems comparing it to 1977 vehicles shows either
no change with three-way catalysts, meaning lower emission
levels, to a 20 percent penalty.
So if you try to project how that is going to turn
out in California in 1980, it could be a plus or a minus.
And I think it will be both ways. It will depend on the
particular model that you are talking about. I imagine some
models would have better fuel economy; some may have worse.
This is at the present state of the art.
MR. (GRAY: What do you think the main advantage of
the three-way catalyst system is and why make the commitment
to change if you can meet one gram per mile without a three-
way catalyst system?
MR. SCHWOCHERT: I think that's your conclusion.
MR. GRAY: Can you —
MR. SCHWOCHERT: We didn't state that in our statemen
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MR. GRAY: Let me ask you directly, then.
Can you meet a one-gram NO level without a three-way
X
catalyst?
MR. SCHWOCHERT: Right now, we think that the most
desirable system to meet this more stringent NO^ standard is
a three-way system.
Can we meet it? Perhaps we can meet it on some
engine families, but we think there are penalties associated
with meeting it. Larger engines and smaller vehicles is
a direction that we think one would have to go if you are
trying to meet a one-gram standard, meet it in all respects,
not just certify it at one gram per mile or slightly lower,
but meet it on an assembly line testing and Title 13 testing.
So our first choice system, if you will, to meet
the one-gram N0x standard is a three-way catalyst system. We
think that's the principal reason for going to a three-way
catalyst in 1980 with a one-gram NOx standard is because of
the exhaust emission standard change, not because of fuel
economy considerations, although that's certainly a benefit or
consideration that influences you. The primary reason is
the more stringent NO standard.
X
MR. HANSON: I don't think there is anything inherent
in a three-way system that ought to give you better fuel
economy. As a matter of fact, it has some inherent things
that should give you lower fuel economy. But I think at very
low emission standards, it will give you better fuel economy
than possibly some of the alternatives.
MR. HELLMAN: Let me try to discuss this issue.
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Have you ever had a vehicle in 1977 certification,
for example, that when the DF was multiplied by the 4,000 mile
emission values, the resultswere less than the standards
proposed by California for 1980?
MR. SCHOWCHERT; Yes, we have. As you heard this
morning from the ARB testimony, they listed a group of
vehicles for various manufacturers that showed NO lower than
one gram per mile.
MR. HELLMAN: And CO less than nine and hydrocarbon
less than 0.41?
MR. SCHWOCHERT: They were California vehicles.
So, since the present standards are less than .41 and nine,
the answer would be yes.
MR. HELLMAN: So that there have been instances in
which your current systems have met those levels?
MR. SCHWOCHERT: That's right, for certification
purposes. We don't believe that the NO^ levels are in most
cases enough below the standard to give us confidence that
we could certify and produce and continue to meet all of the
assembly-line test requirements, the Title 13 test requirements
and the end-use requirements with these vehicles.
Generally speaking, the NOx levels are not suf-
ficiently below the standards.
MR. HELLMAN: How much below do they have to be?
MR. HANSON: Well, those vehicles that you are
quoting were designed to comply with a one and a half standard.
You can see some of these are drifting down to the below one.
I am sure that you will find others as high as 1.4. If you
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look at the distribution of certification values, you may
get targeted at one standard, you may find some as low as
.4 . I think this always happens in a certification program.
CHAIRMAN JACKSON: Does that mean that you would
not attempt to sell vehicles who are a half gram or less than
a half gram from the standard after you apply the deteriora-
tion factor?
MR. NELSON: I don't understand what you mean by
you wouldn't attempt to sell.
MR. HELLMAN: Let me see if I can clarify the
question.
You said that just because a vehicles projected
emissions were less than the numerical value of 1.0, doesn't
mean you wouldn't go ahead and sell it because it might be
too low.
A minute later Mr. Hansen said that there were
vehicles certified, and I assume sold, at 1.4 NO .
X
So it seems on the one hand you are saying that
just because it's a little below the standard, doesn't mean
we can feel we are confident enough to go through Title 13 and
assembly-line testing, and on the other hand, there may very
well be vehicles that you are selling now that are certified
very, very close to the standard.
Do you think those statements are consistent?
MR. HANSON: I was using 1.4 as an example. What
we typically tried to do is not overcontrol or undercontrol
the vehicles. We want them to pass on assembly-line testing
and Title 13 testing. On the other hand, we don't want them
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to be considerably below the standard either, because if they
are, they have been compromised in some way and paying a
penalty relative to the other vehicles they are competing
with.
MR. HELLMAN: Where is the design target set for a
given standard? One is the design target for 1.5?
MR. HANSON: I'd say for 1.5, after the deteriora-
tion factors are known, the design target would probably be
in the range of 1.1 to 1.2.
MR. HELLMAN: Is that after 50,000 miles?
MR. HANSON: No. After the deterioration factor is
known and assumes there is no NOx deterioration. I think it
averages out to about zero.
MR. HELLMAN: So no cars would be sold by GM if it's
over 1.2 at the 1.5 standard?
MR. HANSON: No, I wouldn't say that. We would make
a judgment as to what percentage of the cars would be in com-
pliance and so on, but you can't —
MR. HELLMAN: So it's possible you could sell one
very close to standard?
MR. HANSON: It's possible we could, sure.
MR. HELLMAN: And, therefore, the arguments that you
use to indicate that California's selective picking of some
cars that just happened to be a little bit below one NOx
wasn't any good, actually could be used?
MR. HANSON: No. I think the point I was trying to
make is that if you have a target — Let's take a number, say
1.2, and you design all of your vehicles and all of your
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combinations to achieve that target. By the time the actual
certification results get in, there will be quite a range of
those numbers because you just can't dial in exactly the
number that you anticipate.
So the certification values may fluctuate quite a
bit and may even be different than production values. These
are all values that we have to consider in our program.
MR. SCHWOCHERT: Dr. Hellman, I don't recall anyone
saying that the ARB data — Challenging ARB's listing of the
vehicles, and you seem to suggest that somebody was challenging
the listing of vehicles.
MR. HELLMAN: No. If you remember Mr. Gray's
question, he asked if your current system could meet one NO .
I don't think he felt and I don't feel he got a direct
answer.
MR. SCHWOCHERT: We don't think that our current
systems in general are at a low enough level that we would
have confidence in certifying those systems at one gram
NO .
x
MR. HELLMAN: Certifying for the future?
MR. SCHWOCHERT: Yes.
MR. HELLMAN: But you did say it would be possible
that if a vehicle in certification would just squeak by, you
would think seriously about selling?
MR. PETERSEN: I don't think we said that. I think
the statement was made that we have other concerns besides
just certification, assembly-line testing and in-use com-
pliance and so on and so forth. I think you are putting words
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in our mouths up there.
MR. HELLMAN: Maybe you can generate some words when
I ask you the question what the design targets are for a
given standard. You said 1.2 or 1.5 standard, assuming
DF was close to one. What about the standard for 1.0 NOx?
MR. HANSON: Just making a judgment on what kind of
design target there would be for a certification standard for
1.0, I would say in the .6-.7 range.
MR. HELLMAN: Does that include DF?
MR. HANSON: No, of course not. It would have to
be adjusted if the DF was greater than one.
MR. HELLMAN: Well, what level does the car have to
be at 50,000 miles? That's my question.
MR. HANSON: Projected at 50,000 miles?
MR. HELLMAN: Yes.
MR. HANSON: To be certifiable, it has to be just
under standard, of course.
MR. HELLMAN: But I mean your design target for your
engineering.
MR. HANSON: .6 to .7.
MR. HELLMAN: At 50,000 miles?
MR. HANSON: Yes. This is because of the variability
that might be expected, both in certification and production.
MR. HELLMAN: Okay. So that if, therefore, the
vehicles that were below 1.0 but above .6 or .7 would be too
close to the standards for you to have high confidence that
you could certify?
MR. HANSON: Yes. It would be higher than the
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design target.
MR. HELLMAN: I think there is a parallel issue
here in terms of the fuel economy range, that the fuel economy
could be better than, equal to, or worse than California as
an unknown area.
At the top of Page 2 of your statement, you mention
something about model availability, and you term it "Model-
Engine-Transmission-Carburetor Combinations." At the end of
the paragraph, you say, "It is too early to predict if the
California model availability will diminish even further in
1980. "
Is there parallel here so that I can say it's too
early to predict that it will not be the same or greater than
or less than it is now?
MR. SCHWOCHERT: I think to some degree that will
depend upon where the federal standards are and what type of
systems will be used to meet the federal standards in 1980.
But if you want to assume that there will be similar
differences between federal and California standards in 1980
as presently exist, then I don't think there's any real
reason why we predict that the model availability will be
any greater in California in 1980. We would hope that we
can hold the same type of model availability situation in
1980 as presently exists in California.
MR. HELLMAN: Which has diminished from the federal?
MR. SCHWOCHERT: Which has diminished, yes.
MR. HELLMAN: You can make the prediction that the
model availability won't increase?
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MR. SCHWOCHERT: If there is a continuing difference
in federal versus California standards, I think that's a fair
statement.
MR. GRAY: In a general sense, to be sure that we
haven't muddied the waters with respect to your testimony and
with the qualification known as MMT in particular, you don't
see any doubt that you will be able to certify for the changed
standards for passenger cars; is that correct?
MR. SCHWOCHERT: Right. Now, we would certainly
estimate that we will be able to certify some vehicles in
1980.
MR. GRAY: Let me change the question area to light
trucks and medium-duty vehicles. I'll try it from a broader
perspective first, and if I can satisfy the concerns, I won't
need to go into the specifics that you have mentioned in your
testimony.
On the one chart that you presented with your
testimony, you show a range for light-duty trucks representing
your current status of development efforts. Let me ask a
broader question: What's the best you can do with three-way
catalyst technology in this time frame?
MR. HANSON: As applied to light-duty trucks?
MR. GRAY: Yes.
MR. HANSON: Well, the data that you are looking at
here is with two-way catalyst technology. Are you suggesting
that we might improve the hydrocarbons by using three-way
catalyst technology?
MR. GRAY: I am asking what levels you can achieve
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with the best technology you have available.
MR. HANSON: Okay. Three-way catalyst technology
has not been expanded to trucks yet. I would speculate that
we would have a tougher time with the hydrocarbons used in
a three-way catalyst as compared to a two-way catalyst.
As you know, there is some compromise in the three-
way catalyst for oxidation efficiency, and also the engine
hydrocarbons will probably be higher as a result of running
a fuel ratio of 14 and a half instead of 17. So, I would
anticipate that the hydrocarbon job would be tougher with a
three-way catalyst.
MR. GRAY: You can meet 1.5 grams per mile with the
current oxidation catalyst system on light-duty trucks and
medium-duty vehicles?
MR. HANSON: Certainly.
MR. GRAY: Okay.
MR. HANSON: The standard we are addressing here is
.5.
MR. GRAY: Not for NO .
x
MR. HANSON: Oh. This is hydrocarbon data that we
are talking about.
MR. GRAY: The question was — You said you planned
to use only the current oxidation catalyst systems.
MR. HANSON: Yes.
MR. GRAY: Since in 1981 the standard for light-duty
trucks for NOx is one and a half grams per mile, I'm saying that
means that you plan to use that system and achieve that level
of N0x control.
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MR. HANSON: Okay. I didn't realize you were talking
about 1981 and oxides of nitrogen.
In that event, I am sure we would consider three-way
catalyst technology on the trucks. We have no quarrel with
the 1979 oxides of nitrogen standard or CO. It's only the
hydrocarbons that we are having the problem with, and this is
what we are attempting to report right here.
MR. GRAY: I guess I am a bit confused. Can you
meet a 1.5 grams per mile NOx standard?
MR. HANSON: In 1981?
MR. GRAY: In 1981.
MR. HANSON: I'd have to say we probably will, yes.
MR. GRAY: With the current system you are working
with?
MR. HANSON: We are meeting two with it now. I
think it may have capability of getting to one and a half.
MR. GRAY: So you do not have any plans to initiate
a program in light-duty and medium-duty trucks to apply three-
way catalyst technology?
MR. HANSON: We have no plans at this time. As you
know, we are trying to develop this technology on passenger
cars and introduce it on passenger cars, we certainly would
address that subject sometime in the future as to whether or
not this technology ought to be applied on trucks or not.
MR. GRAY: Okay. Then from your perspective, the
hydrocarbon control, is the limiting factor that you are
dealing with now?
MR. HANSON: At this point in time, this is the one
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we are having the problem with, yes.
MR. GRAY: And what are the lowest levels that you
feel you could achieve by 1979 on light-duty trucks and
medium-duty vehicles?
MR. HANSON: Hydrocarbon?
MR. GRAY: Yes.
MR. HANSON: Well, as you can see by the bar here,
our best effort, the range seems to be right around the
standard, .5. We show what our target is there. It's a
level of about .32, and I'd say that job would be finished
when that bar would surround that target.
Now we have some more time to continue to develop
these. As I mentioned, I feel confident that that one
particular engine/transmission combination will achieve a
certifiable level eventually. The other three are more
difficult, as you can see.
MR. GRAY: What's your projection of the best that
you can achieve with a manual 350 cubic inch displacement
engine system?
MR. HANSON: I don't know. It's difficult to try to
project that. The way I see it right now, we would have
trouble getting it far enough below the standard to consider
it certifiable. Manual transmission V-8.
MR. GRAY: Right, but I am just asking for your
best judgment based upon your experience, since 1979 is
increasingly near. What's the level you think you can
achieve with your technology? I assume you've got some feel
for it. You have been looking at it.
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MR- HANSON: I think it may get down close to the
standard. But as I mentioned we have to be better than the
standard to have confidence in our ability to certify them and
produce them to the standard.
MR. GRAY: Let me ask you, if that's a specific
answer, do you feel that within this time frame that for these
two-engine families and transmissions combinations that you
feel reasonably confident that you can reach about the standard;
it's just you are not comfortable that you can get sufficiently
below it?
MR. HANSON: Yes, I'd say that's true.
I kind of base that on, too — When you asked about
the manual transmission — even for the 1977 model year we
have some V-8 light-duty trucks with a manual transmission
that's not available in California because of emission
reasons. The manual is currently available in lower inertia
weight vehicles.
MR. GRAY: I understand.
MR. HANSON: We cancelled the higher inertia weight
vehicles.
MR. GRAY: Okay. Now I want to add another
dimension to the question. What percent of the hydrocarbons
will be methane at these levels with those systems?
MR. HANSON: What percentage of hydrocarbons will
be methane?
MR. GRAY: Yes, at the .5 hydrocarbon level.
MR. HANSON: Well, I don't know. I would guess that
it would be around ten percent or so.
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MR. GRAY: Ten percent methane at a .5 gram per
mile hydrocarbon level with an oxidation catalyst?
MR. HANSON: I would guess possibly 15. We have
recently applied for a methane adjustment factor for our
trucks, and we applied for a factor of .91.
MR. GRAY: What is it for passenger cars?
MR. HANSON: .82, as I recall. .81.
MR. GRAY: Why do you think they are different?
The same systems; aren't they?
MR. HANSON: Yes.
MR. GRAY: Isn't it because — I mean could it be
because the current light-duty truck standards are higher
than the passenger car standards?
MR. HANSON: Yes, that may have something to do with
it. Also, the levels achievable might be slightly different,
too. I am sure that you know that a lot of these passenger
cars are running in the .2 to .4 gram per mile range on
hydrocarbons. I doubt if we can get these trucks down that
low.
MR. GRAY: At least the data that I am aware of
from General Motors and other manufacturers of these systems
show at these levels a very high percent methane, more like
at least the 19 percent that you mentioned for your light-duty
vehicles.
MR. HANSON: These systems that you are referring to
are the systems that are currently in production out here,
and we have just applied for a .91 factor.
MR. GRAY: At the .41 grams per mile level?
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MR. HANSON: No, that's at a .9 grams per mile.
MR. GRAY: I know. That's why I wanted to direct
the question at a .5, because it has a great impact on the
percent methane from all the data that we've seen, a lot of
which is GM data.
MR. HANSON: Okay. I guess the best answer I can
give to your question is that I would expect it to be somewhere
between .81 and .91 adjustment.
MR. GRAY: Don't you think that that would give you
sufficient margin if you can get .5 grams per mile total
hydrocarbons?
MR. HANSON: It would help, yes. I doubt if that
margin will be sufficient.
MR. GRAY: Twenty percent margin, you don't feel
that's sufficient, 19, 18?
MR. HANSON: No, I wouldn't say so, not if —
MR. GRAY: You wouldn't introduce a vehicle in
California that had 19 percent —
MR. PETERSEN: Mr. Gray, will you give Mr. Hanson an
opportunity to answer your questions? They are coming so
fast that I don't think he's really getting an opportunity —
MR. GRAY: I'd be glad to give full opportunity for
a very specific answer, yes.
MR. HANSON: I guess I can't tell you exactly what
this design target has to be, and it depends quite a bit on
the distribution of emissions that you are going to get. We
tried to show the distributions that we are getting currently
by giving you a range, and I guess I wouldn't feel comfortable
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until the top of that block was at least below that standard.
In answer to your question about methane, yes, it
is going to help.
MR. GRAY: You are saying with all these things
together you don't know what you are going to be able to do
in 1979 for the California market?
MR. HANSON: I think I already answered that
question. I said at this point in time, I would predict that
we will have one engine/one transmission combination that
will be certifiable. It depends on what we learn over the
next several months whether these other three will be or not.
MR. GRAY: Well, I thought I had gotten answers in
your discussion here that you felt reasonably confident you
could get the other systems to a .5 gram per mile level, and
with the methane adjustment factor that would bring you to
15 to 20 percent below that level. I'm just asking for your
technical judgment. Isn't that sufficient to give you
confidence that you could sell those vehicles in California?
MR. HANSON: No, I don't think 20 percent would be
adequate.
MR. GRAY: With a 20 percent margin, you would not
plan on introducing those vehicles?
MR. HANSON: I don't think that would assure me I
would certify them. In other words, you are saying that if
I could average .5, the adjustment, if it were as high as
20 percent, would allow me to average .4. You have to do a
little better than average. Every certification vehicle
has to pass. Ninety percent of the assembly-line vehicles
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have to pass.
MR. GRAY: What makes your vehicles different from
Ford systems? Do you think there are any basic differences?
MR. HANSON: No, I don't think so.
MR. PETERSEN: I'm not sure we are qualified to
answer that question, Mr. Gray.
MR. GRAY: I think that your technical people
probably have a pretty good feel for the basics of the Ford
emission control system from the literature.
MR. PETERSEN: I think that's an assumption, and I
think that emission control development technology is replete
with trade secret information and restrictions and —
MR. GRAY: Mr. Petersen, if your technical people
would care to give that answer, I think we would be glad to
hear it. I would just be surprised if the technical experts
you bring with you weren't familiar with the other manu-
facturers' basic emission control systems to the extent they
would know the general differences. Certainly, there are
different calibration concerns, but you can't say you can't
even address that question.
MR. PETERSEN: Are you talking about future emission
control hardware, Mr. Gray?
MR. GRAY: I am talking about the technology
required to meet these standards, the basic systems.
MR. PETERSEN: I can assure you that we are not
knowledgeable of Ford Motor Company's future emission control
hardware, and I would certainly hope that they are not
knowledgeable of our future emission control hardware.
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CHAIRMAN JACKSON: Your point's noted.
MR. GRAY: My only problem is: are you
knowledgeable of your own? From what we have been hearing
today —
MR. SCHWOCHERT: I think, Mr. Gray, as far as I am
concerned, the important thing that we can do is we can
submit the information we have from our development to you and
you ask other manufacturers to submit their information and
MR. GRAY: I guess the perplexity of this is that,
you know, at least from what we can see on the face of it,
is that the system that GM would use and the other manu-
facturers would use would be basically the same. That makes
sense with respect to the optimum control strategy. On the
one hand to see one manufacturer not having the same types of
problems that General Motors is having, at least raises some
concern as to why. And that's the reason for the probing
here.
MR. HANSON: I don't know as we are having different
types of problems. You didn't really have a technical dis-
cussion with Ford, but you are having one with us now. I
think that —
MR. GRAY: Well, certainly — I mean Ford said that
if MMT was not in the certification fuel they could certify
at least at these levels the light-duty trucks and medium-
duty vehicles.
GM claims that at this point they only feel
reasonably confident that they could introduce one engine
family with one transmission.
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MR. HANSON: Mr. Gray, I read in the Ford statement
that that was qualified. They said there was potentially some
loss in fuel economy and model availability. I'm not saying
anything different than that.
MR. GRAY: I think we had a very direct answer to
that during the question period, and that terminated the
questioning.
MR. HANSON: I think I am saying the same thing.
Model availability is certainly a concern here.
MR. GRAY: But you have only said specifically that
you can offer reasonable confidence that there will be one
engine family and one transmission for sale in California.
MR. HANSON: I have reasonable confidence I will
certify that one. How many more I will certify I don't have
reasonable confidence. Maybe you misunderstood. I didn't
say I had reasonable confidence there would only be one. I
said I had reasonable confidence that I would have this one.
MR. GRAY: Okay. I guess I am. I don't really
see the significance of the difference there, but I'll accept
it anyway.
CHAIRMAN JACKSON: I have a question from the CARB.
Is it correct to conclude from Mr. Schwochert's
earlier testimony model availability — that is, model
availability in California in 1980 — will depend on the level
of federal standards, that the model availability in
California is at least to some extent a function of marketing
decisions as opposed to technological feasibility?
MR. SCHWOCHERT: Certainly, Mr. Jackson, other
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GM 4 73
considerations besides emission standards themselves enter into
the decision regarding what models will be offered for
California. Emission standards is one of the considerations.
CHAIRMAN JACKSON: So we can assume, then, that your
answer is in the affirmative, that marketing decisions do
indeed affect model availability?
MR. SCHWOCHERT: That's certainly one of the factors.
MR. HELLMAN: With respect to the differences in
emission control technology that might be used in the future,
the catalysts that you ran on these trucks, were they of
the pelleted underfloor oxidation catalyst-type that is
commonly used on many GM cars?
MR. HANSON: Yes, it is exactly the same catalyst.
MR. HELLMAN: It's 260 cubic inch catalyst?
MR. HANSON: Yes.
MR. HELLMAN: Do you know what kind of loading that
catalyst has?
MR. HANSON: It's the same as the passenger car. I
think it's a five-to-two ratio.
MR. HELLMAN: Same kind as the passenger cars?
MR. HANSON: Yes.
MR. SCHWOCHERT: Yes.
MR. HELLMAN: Other manufacturers use other kinds
of catalysts. Do you know what a monolithic catalyst is?
MR. HANSON: What was your question?
MR. HELLMAN: Do you know what a monolithic catalyst
is?
MR. HANSON: Yes. We have one in production in
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GM
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California.
MR. HELLMAN: On a truck?
MR. HANSON: No. It's on a passenger car.
MR. HELLMAN: Is there any difference in the way
that this type of catalyst works on the emission tests?
MR. HANSON: This particular catalyst I am referring
to was introduced as an experiment. It's a dual catalyst
system. We use a monolith close coupled to the engine and
the reconverter underflooring.
One thing that we had noticed about that type of
system, it has substantially higher deterioration than just
the underfloor only. It does achieve lower levels, but
projected to 50,000 miles the levels are about the same.
MR. HELLMAN: In terms of considering only a single
catalyst on a vehicle, does a monolithic catalyst warm up
faster than a pellet in your opinion?
MR. HANSON: If they were both located at the
same distance from the exhaust manifold, I would say that it
would, yes.
MR. HELLMAN: Is the cold start portion of the
test a very significant part of overall emission results you
get?
MR. HANSON: I think it is in some vehicles. It
varies as to how big a problem it is. There are various
solutions for that problem.
MR . HELLMAN: So would you project any emission
control improvements to your trucks for 197 9 if you used the
monolithic catalyst versus a pellet?
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MR. HANSON: I couldn't project that at this point
in time. We do have programs comparing monolith and
pellet catalysts. We are trying to sort out the differences,
the advantages and disadvantages.
MR. HELLMAN: Could you introduce such a catalyst
which might be a big change from your current approach for
'79 on trucks?
MR. HANSON: I really can't answer your question.
If we got it from an outside supplier, it's a possibility.
The one that we are using on passenger cars is not large
enough, I know that.
MR. HELLMAN: Thank you.
MR. GRAY: I have one last clarification, I guess,
question on light-duty trucks and medium-duty vehicles.
You made the statement on numerous occasions
GM has testified to both EPA and ARB that we do not support
the concept of light-duty and medium-duty trucks can or should
be regulated to the same emission levels as passenger cars.
And I'm not really sure the point that you were trying to
make there for these trucks. The levels aren't the same,
and in fact the ARB stated specifically that their objective
was not to impose the same standards but to simply ensure
that the same types of technology were introduced in these
vehicles so that the amount of emission control that's
available with that kind of technology would be forthcoming
from that type of vehicle.
So, is there something behind this statement that's
not apparent to us?
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MR. NELSON: Mr. Gray, I am a little bit confused
by the question, because we think that the truck has a
tendency for higher emissions than the passenger car. If
you put the same control system on the truck as you do on
the car, it won't necessarily give you the same answer. In
fact, it probably won't.
We have an illustration in here that illustrates in
one case we take a comparable engine in both a truck and a
car and we find an appreciable difference, as we pointed out
in the statement, in the hydrocarbon emission characteristics.
MR. GRAY: I think that's the whole point that the
ARB was making, that they do have different levels of the
standards based upon inertia weight and that in their best
judgment from the data available to them at least it was
their argument that those different levels corresponded to
the adjustments that would be appropriate because of those
differences that you pointed out in your testimony. If it's
an issue that those adjustments are not technically
appropriate, I think technical information presented by GM
could have constructively been used in that regard. But if
there is a basic opposition from GM for the utilization of
that type of technology on light-duty trucks, then that's
a matter beyond the technological feasibility issue.
I'm hoping to get a simple answer as to the purpose
of that statement in your testimony.
MR. HANSON: Mr. Gray, we agree completely with what
the ARB is trying to do. We tried to work with them on this
particular matter. Historically, we have always used the
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GM
same emission control hardware on the trucks as the cars.
We think that's very cost beneficial.
I guess what we are saying is that we liked the
way they adjusted the adjustments for oxides of nitrogen.
Even though they didn't make an adjustment for CO, we agree
with it technically that it's achievable, and I guess what we
are talking about is that the relationship between cars and
trucks as far as hydrocarbons are concerned may not be the
correct relationship.
MR. GRAY: But you can't offer any additional
information as to what relationship would be more technically
correct?
MR. HANSON: No, we can't, and we thought about how
we might gather that information. It may be possible to find
some. We just used the assembly-line test data through
March 31st as an example. That is one source of information
that's available in large volume.
MR. GRAY: I guess those data are available, but
those were to different levels as I recall, and it becomes
at least uncertain as to how directly you can apply such
information. It's information you can consider, definitely.
MR. HANSON: Yes.
MR. GRAY: But the applicability is not, I don't
think, straightforward.
MR. HANSON: That's true. We recognize those
problems, but we were trying to keep as many things constant
as possible. We are talking about the same engine, the same
transmission, the same emission control systems, and a large
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volume sample of cars and trucks.
MR. GRAY: There seems to be two extremes here,
one a level that the ARB made as a judgment as to what, from
the data they had available, was the most appropriate adjust-
ment factor, and then the other extreme which I think in your
testimony you qualified in that context about .8-.5.
MR. HANSON: We said we weren't recommending that
standard, but that was another one you could arrive at from
using data like this.
MR. GRAY: Do you think the adjustment is somewhere
between .5 and .8 —
MR. HANSON: Yes, I do.
MR. GRAY: — or do you very well think it could be
.5 or .45 or —
MR. HANSON: No. I think the proper adjustment is
somewhere in that range, and I think the ARB probably recog-
nizes that. They have a standard of .9 for 6,000 pounds
GVW and up and a standard of .5 for 6,000 down. Eventually,
all the trucks get to .5. For a comparable standard on
passenger cars, it is .41.
I guess what we are saying is there are reasons why
trucks have emission characteristics. There are reasons why
they are different than cars, and these reasons are probably
going to expand in the future. Cars will be down sized.
Trucks will not be down sized to any appreciable extent.
MR. HELLMAN: Aside from weight, I think on Page 3
of your statement on trucks you indicated that dynamometer
horsepower setting is higher and the transmission and axle
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ratios were higher —
MR. HANSON: Yes.
MR. HELLMAN: — and that a high percentage of
trucks incorporate manual transmissions.
MR. HANSON: Yes.
MR. HELLMAN: Do a high percentage of trucks
incorporate manual transmissions because of their utility?
I think you called it vocational use.
MR. HANSON: Yes. I have a figure I got from our
Marketing Department. It's for all classes of trucks. Thirty
four percent are manual transmissions. I'm sure that's a ratio
considerably higher than passenger cars.
MR. HELLMAN: And because of the vocational nature?
MR. HANSON: That's for the job they have to do,
yes.
MR. HELLMAN: Could you explain why?
MR. HANSON: One reason is for gradability purposes.
MR. HELLMAN: An automatic transmission will not
provide the same gradability as a manual will?
MR. HANSON: I think it can be made to, but
generally manual transmissions and trucks tend to have more
forward gears.
MR. HELLMAN: Yes?
MR. HANSON: Fuel economy is important to truck
operations. A lot of trucks are operated by fleets. Manual
transmissions do get better fuel economy.
MR. HELLMAN: When calibrated to the same emission
level?
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MR. HANSON: Yes. That's our experience today.
MR. HELLMAN: The need for an automatic — the need
for a manual transmission in a truck, if an automatic trans-
mission which may have some advantages for emission control
could be used, it would only seem to make the reason to use it
based on fuel economy and not necessarily on emissions; isn't
that right?
MR. HANSON: I'm not sure I understand your question.
The 34 percent figure I am quoting to you is based
on marketing information. Both manual and automatics are
offered. Thirty-four percent by manuals for all classes of
trucks.
MR. HELLMAN: I guess I am asking a question which is
different from a consumer preference question or consumer
sales question.
You indicated on your chart that the manual trans-
mission vehicles appeared to have a tougher time meeting the
emission standards; is that correct?
MR. HANSON: From a hydrocarbon standpoint, yes.
MR. HELLMAN: From a hydrocarbon standpoint, which
you indicated was your basic single problem?
MR. HANSON: Yes.
MR. HELLMAN: What I am trying to get at, is there a
real reason because of a truck's utility or its need for them
to have a manual transmission? You indicated that you thought
an automatic transmission could give you the same gradability
as a manual, so you don't really need it in terms of meeting
emission standards?
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MR. HANSON: In other words, we don't need a manual
transmission for meeting emission standards. No. I'll
agree.
MR. HELLMAN: The other one is drive ratio, or
overall N/V?
MR. HANSON: Yes.
MR. HELLMAN: Why is that higher on a truck than
on a car?
MR. HANSON: Primarily for the reasons of gradability
the truck has to operate to a certain GVW which is generally
higher than a car, all of our trucks are designed for offroad
operation at full rated load.
MR. HELLMAN: And that is because you want a lot of
torque at low speed; is that it?
MR. HANSON: Torque multiplication, yes.
MR. HELLMAN: Doesn't an automatic transmission
torque converter do that?
MR. HANSON: Yes, but not to the same degree that a
manual does.
MR. HELLMAN: The current ones don't do it to the
same degree that some current, say, four-speed manuals do?
MR. HANSON: Uh-huh (affirmative).
MR. HELLMAN: But it's not impossible that advanced
transmissions such as might even be in development that might
have more gears —
MR. HANSON: More torque multiplication?
MR. HELLMAN: — might do the same?
MR. HANSON: I think in the extreme case you are
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talking about an awful lot. Our manual four-speed trans-
missions, for instance, have first gear ratios up in the range
of five- and six-to-one. With an axle, it might be another
three and a half or four. That's a lot of multiplication.
MR. HELLMAN: Do you shift gears on the emission
test if the first gear ratio is five-to-one?
MR. HANSON: No, we don't. We drive it in the
upper three gears. We have a problem with that. That is
tougher to certify than a manual three speed because of the
gear spacing.
MR. HELLMAN: The ratio of the ratio, so to speak?
MR. HANSON: Yes, the ratios that are left after you
take the first gear out of the four-speed manual truck
transmission. That's one of the reasons why we don't offer
a four-speed in light-duty trucks in California, whereas we
do federally.
MR. GRAY: I was going to introduce this question by
saying I think it's a pretty straightforward question, but
I'll hold off on that. It does relate to the adjustability
issue.
On the first page of your testimony, third paragraph,
you make the statement, "Our interpretation of the requirement
set forth in this section" — referring to California
regulations — "is that if the adjustment mechanism were
hidden from view such as would occur if the idle mixture screw
were located in a counterbore in the throttle body and the
cavity were covered with a metal plug or" — and I want to
come back to the word "or" in a minute — "if the carburetor
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had to be removed from the vehicle to provide access to the
idle mixture mechanism, then the California regulation will be
met."
Is it your interpretation that the California
regulation would be met if the adjustment can be made when
the carburetor is on the vehicle, or should that "or" be
"and"?
MR. SCHWOCHERT: The California procedure, the
198 0 and subsequent model year certification procedure,
Section 5e(i) says, "The mixture adjustment mechanism is
not visible, even with the air cleaner removed."
That would seem to suggest that if you can't see
the mixture adjustment screw that that satisfies that
requirement. So that would be the first condition we are
talking about.
And the second condition is related to the
difficulty of making the adjustment. If you have to take
it off the car, that's certainly — as we heard this morning,
I think that satisfies the ARB requirement, if the carburetor
had to be removed from the car to do whatever you had to do to
make the mixture adjustable.
MR. GRAY: Let me ask it a different way, maybe
more specifically.
Do you expect the carburetors that you have made
commitments to introduce for most GM carburetors in the
1979 model year to require removal of those carburetors
before they can be adjusted?
MR. SCHWOCHERT: We haven't committed a specific
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design for model years beyond what we have introduced this
year, and we are looking at designs that range from a plug
like is on the present 1977 model years that perhaps can be
removed without removing the carburetor, to some type of
cap or covering that we think would definitely require removal
of the carburetor.
So we are looking at a range of designs. Our
objective would, I think, be headed toward making or coming
up with a design that would require removal. So, we are
looking at a range of possible —
MR. GRAY: Within that range, though, you do plan to
require that carburetor be removed before it can be adjusted?
That's a criterion that you have in your choice of the means
of complying with this regulation?
MR. SCHWOCHERT: That's right. In our judgment at
least, it would require removal of the carburetor to make
that adjustment. You can be fairly destructive, perhaps,
and access the idle adjustment screw. But in our judgment,
we are looking at ranges that would cover that possibility or |
that consideration of removing the carburetor.
CHAIRMAN JACKSON: I have a final question, I
believe.
I have been intrigued by the statement that Mr.
Hanson made about the GM plans not to down size trucks. Is
that firm? In other words, you don't think fuel economy
considerations will cause you to down size trucks?
MR. HANSON: Since trucks are performing a little
different job than passenger cars, they are designed to haul
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bulky cargo and/or heavy loads, and that is their primary
purpose. We don't see that down sizing a good alternative.
Should the market indicate to us that it is, I am certain we
would consider it.
CHAIRMAN JACKSON: How about the fuel economy
standards?
MR. HANSON: It will be met with whatever it takes.
I guess what I am referring to is we currently offer a down
size model truck. There is a growth trend in trucks right
now in every segment of the business except in mini trucks.
If there was an indication there was a real need for that
type of trucks, perhaps we would consider a new smaller truck
than we have right now.
The small truck I was referring to that we offer is
an imported model.
CHAIRMAN JACKSON: Yes. I am familiar with it.
MR. GRAY: Could you address that from the context
of not compromising the capacity aspect, the GVW for example,
the cargo volume aspect of the vehicle, say more specifically
reducing the frontal area of the vehicle? In particular,
for pickups I think a large portion of that frontal area is
due just to the way you package your occupant, the hat
clearance room, and the way the person sits as compared to an
automobile for example.
MR. HANSON: What are you suggesting, we package it
for a smaller person?
MR. GRAY: No. Without a ten-gallon hat. No, I
am not suggesting anything here. I am asking.
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GM
You had mentioned the significant impact of frontal
area road load on NO^ emissions in particular and also con-
sidering the influence of frontal area on fuel economy, and
since a reduction in the frontal area in particular of pickup
trucks would not necessarily compromise the utility of that
vehicle, I would just like you to address why that wouldn't be
a very real consideration in your plan.
MR. HANSON: In other words, what you are saying is
to make the seats shorter and bring the top of the cab down?
MR. GRAY: That would be a very straightforward way
of reducing frontal area.
MR. HANSON: Yes, I think that might get considered
in a new vehicle design program. Certainly, we would be
considering changes that would either reduce the frontal area
or make it more aerodynamically efficient than it is now.
It does take a new vehicle program, as you might
well realize.
MR. GRAY: So that is a consideration in terms of
that aspect of down sizing? That's very real in GM's mind?
MR. HANSON: Smaller frontal area is as long as it
doesn't interfere with the cargo area that the truck is designed
to carry, yes, I think that's a possiblity.
CHAIRMAN JACKSON: Thank you, Mr. Nelson.
MR. PETERSEN: Mr. Jackson, we have a couple more
minor points.
This morning in response to some questioning from
Mr. Hellman, I believe regarding hydrocarbon spiking with
manual transmission vehicles, Mr. Austin stated that Volvo has
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a 1977 vehicle which meets the statutory standards and it's
equipped with a manual transmission.
Did I understand that correctly?
CHAIRMAN JACKSON: You have to ask him.
MR. PETERSEN: Is that correct?
MR. AUSTIN: Yes.
MR. PETERSEN: It's common knowledge that California
owns ten of these vehicles, and we assume that the CARB has
performed a number of emission tests on these vehicles.
If the hearing officer agrees, we believe it might
be appropriate to have CARB submit for the record all data
derived from the testing of these vehicles in order to support
the implied contention that hydrocarbon control with — or
the manual transmission per se was not a problem in hydrocarbon
control.
CHAIRMAN JACKSON: Would that in your mind satisfy
the question?
MR. PETERSEN: Well, I don't think it would satisfy
the question, but it would certainly shed some light on the
question.
MR. AUSTIN: Mr. Jackson, the State of California
does not own any manual transmission Volvos. All our Volvos
are automatic transmission vehicles.
MR. PETERSEN: Has the State of California emission
tested any manual transmission Volvos?
MR. AUSTIN: No.
MR. PETERSEN: The second item Mr. Austin agreed to
provide a report on rhodium availability for the record. I
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GM
488
think he qualified that with if the manufacturers make an
issue of that.
We are certainly not making an issue of that.
However, we believe that such a report is appropriate, in
that it is relevant to supporting the CARB's contentions that
future standards they have adopted are technologically
feasible. We would respectfully request the hearing officer
to request California to submit this report for the record.
CHAIRMAN JACKSON: Are you arguing that there isn't
any rhodium problem?
MR. PETERSEN: No. I stated we are not raising that
issue. However, we think it is relevant to the issue of
technological feasibility and relevant to the hearing record.
CHAIRMAN JACKSON: But you are not contending that
it's a problem?
MR. PETERSEN: We are not contending that it is a
problem.
CHAIRMAN JACKSON: What else are you not contending
that is a problem you think we ought to consider?
MR. PETERSEN: I've got several more —
CHAIRMAN JACKSON: Get the point?
MR. PETERSEN: I've got several more things.
Lastly, there is some question regarding a hydro-
carbon standard which is the subject of this waiver for
198 0 and subsequent model years. It is my understanding that
the regulation adopted by California, which is the subject of
this discussion, specifies a .41 gram per mile hydrocarbon
exhaust emission standard and that the EPA notice in the
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GM
489
Federal Register was based on the regulation adopted by
California.
If California has failed to reflect their true
intent in the adoption of the regulation specifying .41 grams
per mile, then they should be directed to amend this regula-
tion and request another waiver. Only then can proper notice,
meeting the requirements of due process, be given and
interested parties be accorded the right to respond accord-
ingly .
I might add that EPA cannot grant a waiver for a
standard which California has not adopted. Therefore, if
the purpose of this hearing is to consider a .39 per gram
(sic) hydrocarbon standard, then it is out of order since
no such standard has yet been adopted by the State of
California.
CHAIRMAN JACKSON: You wouldn't accept a clarifica-
tion offered by Mr. Austin with regard to that matter?
MR. PETERSEN: Yes, I think we are objecting to
that.
CHAIRMAN JACKSON: Excuse me?
MR. PETERSEN: I think we are objecting to —
CHAIRMAN JACKSON: You mean object because he did
it?
MR. PETERSEN: The eleventh hour clarification for
the record on a standard which has not been adopted, I think,
is objectionable, yes.
CHAIRMAN JACKSON: I think he didn't say that it
had been adopted. He said it was an error of some sort
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GM
490
resulting in not being accurately reflected in the corres-
pondence. And you are not accepting that as a matter of
fact, that it was an error? I am certain that you are not
contending that you were not on notice that this matter would
be before us at this proceeding.
MR. PETERSEN: We are not contending that General
Motors was not on notice. However, we think that the pro-
cedures which have been followed here violate fundamental
principles of fairness in regard to due process. I certainly
have no way of knowing how many other interested parties were
misled.
CHAIRMAN JACKSON: You are suggesting that you are
unwilling to accept a clarification offered by Mr. Austin,
that you do not believe what he is saying. Is that what you
are saying to me?
MR. PETERSEN: It is our understanding that the
hydrocarbon standard which was adopted by the Board was a
.41 per gram (sic) hydrocarbon standard. Is that incorrect?
Gram per mile, I am sorry.
MR. AUSTIN: We currently have a waiver for a
.41 gram per mile total hydrocarbon standard. It was our
intention to adopt a standard for 1980 that was the equivalent
of a .41 gram per mile total hydrocarbon standard, but on a
non-methane basis.
Due to an error in drafting, it appeared in the
regulations as a .41 gram per mile non-methane hydrocarbon
standard. That would have constituted a relaxation from the
standard for which we already have a waiver. We did not
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GM
491
intend to relax the standard. We intended for it to be the
non-methane equivalent of .41 total.
Perhaps the hearing officer should ask General
Motors if they would object to merely having our present
waiver for a .41 total hydrocarbon standard continued into
1980, or perhaps if GM feels they are being prejudiced in any
way by the clarification that we are offering at this
hearing.
MR. NELSON: Mr. Jackson, I'd like to comment.
One of the problems we have had is trying to make
an evaluation of the effect of the change, and until we have
an opportunity to make that evaluation, I don't think it's
appropriate to make a change in the standards.
At first glance at least, it appears that the
diesel hydrocarbon standard would be changed without any
compensation necessarily due to the hydrocarbon correction.
On the surface, it appears as though the correction process
that was described this morning by Mr. Austin is totally
acceptable. But we haven't had a chance to evaluate in a
thorough fashion the implications that such a change may
have. It's affecting more, as I see it, than just the
hydrocarbon standard on gasoline vehicles. It may affect
diesel technology also, because it does change the standard.
It isn't a big change, I admit that. I think the adjustment
appears to be correct, but we haven't had an opportunity to
review that thoroughly and present our comments. So it
seems like the cart came before the horse.
CHAIRMAN JACKSON: Well, then, it's not to say that
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492
GM
you weren't on notice and that you do accept the statements
that Mr. Austin has made as fact, and that what you are
saying is that you need more time to evaluate the appropriate
response for consideration?
MR. NELSON: It's very possible that if we had more
time that we would say it's a fine idea and go ahead and do
it, but we haven't been able to make that assessment.
CHAIRMAN JACKSON: Well, the record will be open
for a considerable period of time after the hearing, and I
presume that will be sufficient time for you to respond.
MR. SCHWENTKER: Didn't you say the record was only
open until the 10th?
MR. STEINWAY: June 10th.
MR. GRAY: What I understood Mr. Petersen to say
was that GM was misled in the deliberations that the ARB
had, the workshops, the public hearings, the Board action
with respect to what was being considered; is that correct?
MR. PETERSEN: I never used the word "misled." I
stated that the Board adopted a .41 grams per mile standard,
that the notice for the hearing was based on that regulation,
and that now we are told that really the regulation adopted
by the Board does not reflect their true intent and that
the true intent was .39 grams per mile and that they, of
course, will amend their regulations and are asking EPA to
grant a waiver, a type of a blank check in allowing ARB to
amend their regulations after the fact. I think that's got
due process problems. I think it's got Section 209 problems
in that I don't believe EPA is authorized to grant a waiver on
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GM
on regulations which have not been adopted by the State of
California. Certainly this is an argument that you are going J:o
tomorrow in regard to the general waiver provision, and that's
the extent of my comment, Mr. Gray.
MR. GRAY: Let me ask one specific question to
clarify that.
Was GM aware of California's intent to that whole
hearing process? Were they commenting on a .41 non-methane
equivalent or a .41 non-methane total?
MR. NELSON: We were commenting on the standard that
was in the regulation that was before this hearing. We did
receive late in April an announcement that ARB intended to
take action. Now we have not formulated a position and have
not made a judgment as to whether that change is appropriate
or not. So it doesn't appear proper to have a hearing before
we have had an opportunity to comment to ARB on the supposition
that future action may be taken. And I would suggest if you
want to consider this that there may be future statements that
will be pertinent to the subject at hand.
MR. GRAY: Is that to say that you were not aware of
the .41 equivalent?
MR. PETERSEN: I believe Mr. Nelson just made a
statement that we effectively were denied the opportunity to
submit meaningful comments on the .39 standard.
MR. GRAY: I think he effectively didn't answer the
question, and that's just what I am asking. Is that your
position? You do not want to answer the question?
MR. NELSON: Mr. Gray, I would like to state again
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GM
that, yes, General Motors did receive late in April an
announcement of the intended ARB action, which we have not had
an opportunity to evaluate or discuss with ARB. So, we have
not been given an opportunity to present comments that we
have.
MR. GRAY: I understand that, Mr. Nelson.
Prior to that process, that April notice, are you
saying that GM was unaware of the intent of this standard's
adoption that it be a .41 non-methane equivalent, "yes" or
"no "?
MR. NELSON: It's my understanding that there was
some verbal communication in the past of an intent to change
the standard, but I don't think verbal communication should
be the signal to make a change. We just received in April
the first official notification of a change.
MR. PETERSEN: Verbal communication doesn't provide
a very sound basis for meeting the requirements of due process
of law.
CHAIRMAN JACKSON: Then, Mr. Nelson, we can be
assured that whatever comments you have on this will be
submitted to the record?
MR. PETERSEN: I don't think we can be assured that
we have had adequate time, Mr. Jackson.
CHAIRMAN JACKSON: You don't have adequate time?
This is a technical matter. You might want to ask your
engineers.
MR. NELSON: It could have some technical ramifica-
tions that we haven't had an opportunity to evaluate, and we
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GM/AMC
would intend to provide ARB at the appropriate time comments
we have. If we can get those comments formulated in time
for the hearing, we would be happy to do that.
CHAIRMAN JACKSON: In time for the record?
MR. NELSON: In time for the record, yes.
CHAIRMAN JACKSON: Thank you.
We will take a five minute break, and then we will
hear from American Motors Corporation.
(Short recess.)
CHAIRMAN JACKSON: If you are ready, Mr. Jones?
MR. JONES: Yes, I am ready.
Before I get into the main body of my presentation,
I would like to acknowledge the fact that there are many
issues today and I'll touch on some of the primary issues
and only one of the secondary issues. A lot of issues
deserve and need further comment on, but there are limitations
right now.
You indicated a preference for order with GM. I'm
set up to start with '79. I've got a chronological order,
but I'll be just as happy if you want me to go to passenger
car '80 and then go back.
CHAIRMAN JACKSON: We'll accept your orientation.
We are the ones that have to live with the record, and we
can do it.
MR. JONES: Okay. Then starting with 1979 light-
duty truck exhaust emissions standards and test procedures,
specifically the .41 hydrocarbon, the nine CO, and the
1.5 N0x.
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AMC
There seems to be a little confusion today on where
everybody is falling with respect to the .41 hydrocarbon
standard. We are under 4,000 pounds inertia weight. There-
for, everything that I talk about will refer to the .41
hydrocarbon standard that is proposed for under 4,000 pounds
inertia weight.
In the following statement, American Motors will
address the proposed 1979-model light-duty truck regulations
and the need for the regulation to recognize that four-wheel
drive vehicles designed primarily for off-highway operation
have inherent limitations with respect to hydrocarbon control
when they drive the federal test procedure.
We recognize that the proposed California light-duty
truck standards for the 1979 model year are more stringent
than the federal standards of 1.7 hydrocarbon, 18 CO and 2.3
NO . In fact, due to the hydrocarbon stringency there will
X
be no manual transmission options in our Jeep CJ vehicles in
1979 if the waiver passes. In our automatic transmission Jeep
CJ vehicles, we expect a fuel economy loss of about two miles
per gallon.
In 1978 we will drop manual transmission options
from our heavier Jeep Cherokee and truck models due to the
0.9 hydrocarbon standard. We are not threatening this. This
is fact. I think we testified — in fact, I know we testi-
fied to this at the waiver hearing last August that this
would happen, and it has happened. We are able to certify
the lighter Jeep CJ vehicles at the 1978 hydrocarbon standard
0.9 but the resulting model availability is considered
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incomplete when compared to the 49-state availability.
Our current passenger-car technology lets us comply
with the 1977 and 1978 0.41 non-methane hydrocarbon standard
but cannot be readily adopted for our Jeep four-wheel drive
CJ vehicles. Mechanical and physical differences between
our Jeep CJ vehicles and our cars prohibits the carry-across
of current passenger car emission control systems. Completely
different drivelines, transmissions, power-to-weight ratios
and axle ratios are used on our four-wheel drive vehicles.
Equating, as the proposed 1979 California standards do, all
light-duty trucks under 4,000 pounds inertia weight to
passenger cars is not realistic with respect to our Jeep
vehicles that are designed primarily for off-road operation.
This point is recognized by other governmental agencies. In
fact, the NHTSA has created a separate classification for
four-wheel drive vehicles up to 6,000 pounds GVWR which is
distinct from two-wheel drive trucks and vans, which are
distinct from passenger automobiles. This separate classifi-
cation recognizes that off-road vehicles are designed for a
different use than cars and should have a separate and less
stringent standard.
To design and develop different emission control
systems capable of meeting the 1979 proposed light-duty truck
emission levels will take more lead time than we have available.
These vehicles have the following two major challenges that
require technological solutions before we can meet the
proposed standards:
1. The transfer case mechanism for the four-wheel
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AMC
drive system restricts the packaging of most of the larger
commercially available catalytic converter candidates that
would be required to meet the 0.41 HC standard.
2. The four-wheel drive system's frictional
characteristics coupled with a manual shift transmission
present a hydrocarbon spiking problem whenever the gears are
shifted, which amounts to seventy-one times for our three-
speed and seventy-three times for our four-speed during the
FTP. It takes approximately three times longer to complete a
shift on a manual shift transmission Jeep vehicle than it does
for an AMC passenger car.
These two factors constitute the primary tech-
nological challenge. We contend that we do not possess nor
can we be expected to achieve the technological feasibility
in the lead time remaining to meet the 1979 California
standards for light-duty trucks. We believe that the 0.41
hydrocarbon standard for light-duty trucks designed primarily
with four-wheel drive is not supported by current technology
or the lead time remaining. Therefore, we request that EPA
I
deny this portion of the waiver for four-wheel drive vehicles
designed primarily for off-highway operation.
The next issue that we would like to take is the
consistency issue. The consistency issue concerns the inertia
weight divisions proposed for the light-duty truck and medium-
duty vehicle classifications are considered inconsistent with
the federal regulations. The proposed classification system
based on inertia weight should and could be consistent with
the comparable federal classification which is based on the
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traditional gross vehicle weight. Therefore, the waiver
should not be granted in this arbitrary and inconsistent form.
That concludes my 1979 light-duty truck comments.
The next comments will pertain to the 1980 passenger car
exhaust emissions standards.
Under the stringency comment, American Motors
suggests that it may be premature for the Environmental
Protection Agency to waive federal preemption to allow
California to enforce standards that by law must be more
stringent than applicable federal standards. We do not know
what Congress will establish as the 198 0 emission standards
at this date and we therefore do not know how the stringency
issue of Section 209(b) can be applied at this time.
The next consideration is lead time. Introduction
of technology, even on a limited basis, capable of meeting
the 1.0 gram per mile NOx standard has not been demonstrated
on any of our vehicles.
The proposed standard of 1.0 represents the level
that presumably will require American Motors to commit to
closed-loop feedback carburetors and three-way catalytic
converter systems which, from our standpoint, are unproven.
Other technical paths, while potentially offering superior fuel
economy at today's emission levels, cannot meet the level of
1.0 grams per mile NO with its associated NO engineering
X X
target of 1/2 a gram.
Three-way catalyst technology creates an inherent
fuel penalty since it requires the engine to turn at a richer
air/fuel ratio than is best for fuel economy. We recognize
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AMC
500
that the potential of negating this effect may exist through
intensive optimization of the engine and its control system,
but this in turn adds to the lead time requirement.
Effective utilization of three-way catalyst
control systems on our future engines will require reliable
electronic engine control. We were only recently able to
obtain complete workable automotive electronic emission
control systems for our advance test and development programs.
At this time the lack of availability of an adequate number
of these systems hinders our development programs. As a
result we cannot state our specific lead time requirements
today. We are finding many unresolved three-way catalyst
system questions that dictate a degree of caution should be
taken in approaching this new technology.
An overview of the facts leads us to conclude that
we could not achieve sufficient experience and confidence in
our four-, six-, and eight-cylinder California engine families
by August of 19 78 — which is our Part I submission time for
1970 — to allow reasonable certification success. If we
could concentrate on one-engine family we might somehow succeed,
but a one-engine family Calfifornia product line is not
viable from a marketing standpoint.
Some specific questions involving the status of
three-way catalyst systems that should cause concern for the
motor vehicle industry, the ARB and the EPA are:
1. What are the durability characteristics of the
various microprocessors, oxygen sensors, feedback carburetors
and other system components? Are they adequate to support
extended maintenance intervals?
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2. What are the certification and actual use
impacts the fuel additive MMT may have on these systems?
3. How will these all-new engine control systems
affect the service industry?
4. Do three-way catalytic converter systems permit
unregulated pollutants at a level that may necessitate future
regulatory standards?
5. What are the emissions and fuel economy
trade-offs? Will three-way catalyst systems restrict progress
toward better fuel economy?
Regulations that require an industry to adopt a
specific type of technology should be approached with caution.
Regulators should obtain answers to questions of this type
before emissions standards are enacted. Also, proper concern
for our national commitment to conserve fuel should be qiven
top priority; and regulations that do not allow this should
not be permitted.
I have some consistency issues, consistency being
consistent not only with federal but consistent within
themselves. I have a mixed bag.
We find four inconsistencies within the proposed
1980 regulations:
1. Passenger cars equipped with an oxidation
catalyst are permitted an 0.8 9 methane correction factor.
Light-duty trucks required to meet the same hydrocarbon
standard and equipped with an oxidation catalyst are denied
this consideration.
2. Equivalent inertia weights are referenced to a
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proposed federal regulation, Section 86.129-79. Our concern
is based on the legality of this issue. California should
await finalization of the EPA requirements and then adopt
them. This has not been adopted. This section is strictly-
proposed right now.
The California regulation clearly states that it is
based on Part 86, Title 40, CFR, as they existed on November
23, 1976; therefore, the adopted section that I just mentioned
in this regulation is inconsistent with the current federal
regulation and is consequently not proper for waiver. The
consistency requirement of Section 209 of the Clean Air Act
precludes waiver of a California regulation that needlessly
requires different testing from the EPA requirements such as
here where the test procedures do not necessarily correlate
or measure relative stringency.
I refer you to your own waiver decision of July 11,
1975.
3. The inertia weight divisions for light-duty
truck and medium-duty vehicle classifications are inconsistent
with the federal regulations. This classification system
based on inertia weight should and could be consistent with the
comparable federal classification which is based on the
traditional gross vehicle weight.
4. The last inconsistency is Section 5(d) of the
proposed regulation which relates to an altitude performance
standard on emission control systems equating their sea-level
performance to their altitude performance up to 6,000 feet.
It is an unqualified and arbitrary regulation. Numerous
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questions are triggered by this kind of regulatory language
and could be avoided if proper time and effort were taken to
consider the real issues and attempts were made to be con-
sistent .
We did receive notice. We received a one sentence
explanation of California's intent on May 2nd of this month.
We still have questions.
Under the allowable maintenance issue, our comment
is very brief.
The only issue involving this subject is more
properly referred to as an anti-tampering measure, Section
5e, involving the mechanism for adjusting the idle air/fuel
ratio. We did not oppose this issue when it was adopted at
the December 14, 197 6 ARB meeting. j
j
Now to address the 1981 medium-duty vehicle exhaust
emissions standards. The principal concern we have with
the 1981 standards are the 0.5 hydrocarbon, 9.0 CO and 1.5 NC>x
proposed for the medium-duty vehicle class. This would be the
class under 6,000 pounds, where all of our vehicles would lie.
As a result of the EPA waiver, January 11, 1977, granting
California permission to enforce new 1978-model medium-duty
vehicle exhaust emission standards and test procedures, we
were forced to drop our 1978 California Jeep manual trans-
mission Cherokee and truck models, which I referred to very
early in the presentation, because of the 0.9 hydrocarbon
emission standard. What was not mentioned is the fact that
even concentrating on our automatic transmission vehicle,
having a one-engine/transmission combination available in these
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vehicles, has not caused us to be able to certify in 1978 in
an orderly and timely fashion. We are running extremely
late. In 1978, to certify to the point nine hydrocarbon
standard, we do not expect certification to be completed
until late October, which is going to put a hardship on our
dealers in California who are already very, very sensitive to
the fact that we are no longer offering the manual trans-
mission vehicles.
Unless we can make some significant technological
progress between now and 1981 on the hydrocarbon control
problem in four-wheel drive vehicles, we will be forced to
withdraw completely from this segment of the California market
if this waiver is granted.
We do not require these more stringent standards
to continue our efforts at reducing the emissions from these
off-highway vehicles. We are working diligently at American
Motors to find ways to market these excluded vehicles right
now. Additional regulatory incentive is not necessary. What
is necessary is regulatory recognition that these vehicles as
well as our light-duty CJ vehicles represent a distinct
class — four-wheel drive vehicles — that justifies separate
and less stringent emissions standards.
We will refrain from commenting on the 1.0 grams
per mile N0x for light-duty trucks under 4,000 pounds inertia
weight until we have the hydrocarbon problem solved or
resolved. We hope that adequate consideration of our sugges-
tions for separate classification would address this issue
also.
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I have, as a result of the California report this
morning, a correction to make.
On Page 23, Table 4 of the California report, you
gave some values for our '77 vehicles. You erroneously
placed them in an inertia weight class of 4,000 to 5,999.
They don't belong there. They are 3500 pound vehicles.
Therefore, it looks like we can make — you know,
your table says it looks like we can make the .5 standard
when, in effect, we are talking about a .41 standard.
Also, I'd like to mention that I think the data in
that table is going to be scrutinized quite thoroughly by
our EPA, and I would like to comment further on that data now
that I hope I have cleared up the inertia weight error.
The hydrocarbon data that you see there represents
deterioration factors. I am told the deterioration factors
are applied to the 4,000 mile data, as you see in that table.
The deterioration factors for those three vehicles were one
per hydrocarbon. This is about as good as you can be. You
can't be any better than one.
We are going to have to recertify those vehicles
against a lower standard. We don't expect nor would we
have even the remotest expectation to be able to generate
another one DF. We are very fortunate to have those one's
today. We have no magic, no ability to reproduce a one
DF, so please consider that when looking at those hydrocarbon
values against a .41 hydrocarbon standard.
Okay. That finishes my comments, with one other
comment. I guess maybe it's a question that will come up.
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But our CJ vehicles, our manual transmission
vehicles, constitute 80 percent of our market in California.
Our automatic transmission CJ vehicles constitute 20 percent.
It's a piece of data that I didn't know where it fit in my
presentation so I threw it in at the end. But I think it's
very relevant. It is to us.
That concludes my comments, and I'll be happy to
answer any questions.
CHAIRMAN JACKSON: I'd like the record to reflect
the correction you were referring to was to a table in the
CARB testimony; isn't that correct?
MR. JONES: That's correct, Table 4, Page 23.
CHAIRMAN JACKSON: You were addressing your comments
to the CARB when you were remarking about the correction?
MR. JONES: Correct.
CHAIRMAN JACKSON: I have one question to start
with, Mr. Jones.
On Page 2 of your statement, you indicate that the
1978 .41 is a non-methane hydrocarbon standard. What led you
to believe that it was a non-methane hydrocarbon standard?
MR. JONES: The California proposal. It was written
up as a .41 according to my recollection.
MR. GRAY: I think on Page 2 of your testimony,
if you can refer to the specific statement —
MR. JONES: Yes, I see the statement.
MR. GRAY: For the 1977 and '78 model years which
California is currently implementing, you had referred to a
.41 non-methane hydrocarbon standard. You said that's what
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you understand it to be.
MR. JONES: I am sorry, it's a total hydrocarbon
standard right now of .41. Is that any different than saying
a non-methane hydrocarbon standard of .41?
MR. GRAY: Essentially, you are implying that .41
non-methane hydrocarbon standard was the same as the .41 non-
methane equivalent standard. Is that the context in which you
were using it?
MR. JONES: I believe so, yes.
MR. HELLMAN: You corrected the table that was put
together by the California Air Resources Board based on
information that you have that certain vehicles in there were
in a different inertia weight class than were apparently
considered by California. There are two vehicles — I'll give
you the ID numbers. D6U-38K and D6U-41K in your family
I — Roman Numeral I, I believe — TC at 3500 IW. I
believe certified results for those two vehicles — for the
first vehicle, D6U-38K, is 0.41 hydrocarbon, 6.5 CO,
1.2 NO ; and for D6U-41K, 0.36 hydrocarbon, 3.9 CO, and
X
1.3 NO .
X
Tl;ere is another vehicle at 4,000 which is D —
Oh, P077-5K, which is 0.5 hydrocarbon, 7.7 CO, and 1.6 NO .
X
But since I don't believe you have the details of
the information with you here, I'd like to ask you if you
could check back with your own records and find out whether or
not those vehicles, which apparently have had those numbers
like that, are correct as I read them into the record. Would
it be possible for you to do that, Mr. Jones?
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MR. JONES: Sure.
MR. HELLMAN: On Page 2 of your statement, you said
that there are "completely different drivelines, transmissions,
power-to-weight ratios and axle ratios are used on our" —
"our" meaning AMC1s — "four-wheel drive vehicles."
Does the power-to-weight ratio used in the four-
wheel drive vehicles match in any way a power-to-weight
ratio that you market in passenger cars?
MR. JONES: There's some overlapping today. There
won't be any overlapping in the 198 0 and beyond time frame.
MR. HELLMAN: On Page 3, you said that "The
transfer case mechanism for the four-wheel-drive system
restricts the packaging of most of the larger commercially
available catalytic converter candidates that would be
required. .
I have two questions here. Does this imply that
there are some that will fit; and, number two, which catalysts
are these that you feel may be necessary to meet the 0.41
hydrocarbon standard?
MR. JONES: Okay. The very first question, no.
It means that we are limited in testing all of the available
candidates, but all of the available candidates that we have
tested or looked at or talked to manufacturers about,
catalyst suppliers about, won't fit. I left myself open
there because I — We didn't talk to everybody, and there
may be one out there. I just didn't want to exclude the
whole realm of possibilities, but we are looking very hard.
We are in the process now of looking very hard at anybody that
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has a catalytic converter with enough volume to handle the job
and that we can package.
MR. HELLMAN: What volume is it that you need to
handle the job?
MR. JONES: Well, it certainly is greater than our
current volume of 17 5 cubic inches. We haven't got a magic
number. It would certainly be in the range of 260. But as
you know, I think you know, the 2 60 GM pelletized converter
will not fit under our CJ. When we put a V-8 engine in a
CJ vehicle, we are required to use the 160's.
MR. HELLMAN: Let me clarify something. This
space problem, is it common to all of the engines that you use
in the CJ or just the V-8's?
MR. JONES: No. The space problem is common to all
the engines that we use. The larger the engine, the larger
the throughput or the output, the larger the catalytic con-
verter needs to be . So a V-8 engine represents a large
engine. Therefore, it needs more cleanup.
MR. HELLMAN: And the 260 cubic inch nominal size
that you mentioned was for a V-8; is that right?
MR. JONES: Yes. That would be in about the range
of it. If we could package it, we might stand a chance of
being able •— Let's say we would like the luxury of being
able to look at it. Right now, since we can't package it, we
don't test it to the point where we would be a viable candi-
date .
MR. HELLMAN: Can you tell me exactly where the
interference between the transfer case and the catalyst?
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MR. JONES: Yes. It's about as direct of an inter-
ference as it can be.
The transfer case occupies the ideal location. If
you could just eliminate it, you could put in the catalytic
converter. Just trying to move the catalytic converter a
little bit further downstream or a little bit further to the
front, that option does not exist. You have to move it a
bunch, and we just don't have a bunch under there to move.
MR. HELLMAN: It's your position, then, that even
though it might be technologically feasible to move one or the
other that it would take you more time than you have left?
MR. JONES: Oh, definitely.
MR. HELLMAN: The second part of this statement
that you made had to do with the shifting of the four-wheel
drive vehicles.
Can you explain for the record why it takes three
times longer to shift?
MR. JONES: I really wish I could give an elaborate
description of a CJ vehicle. I contemplated having one here
to demonstrate it. I anticipated this question.
I am not a transmission expert. I have some limi-
tations in this area.
The four-wheel drive manual shift transmission,
again because of the power train, requires the gear mechanism
for the engagement of the gears to be a tower rather than a
side. By doing so, it requires a little more driver effort to
shift the gears.
It has served us well. This transmission that we
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currently have, it's a heavy duty transmission. It is not
similar in any respect to a passenger car manual transmission.
It has pleased our customers who purchased this type of
vehicle, especially in the State of California, since eight out
of ten of them buy it. It is a major task. It's not a very
comfortable thing. I personally find it a very difficult
thing to shift on a regular basis, but the people that buy
these vehicles for the purposes that they buy these vehicles
enjoy the effort. They don't complain about it. Therefore,
we are not — We don't have the incentive to go out, and we
have never had the incentive before, let me put it this way,
to go out and change the effort that it requires. The time
it requires, of course, is three times longer to complete
the shift on an average than a comparable passenger car
j
i
transmission.
That should kind of explain, if I put it in terms
that you can understand, the problems of feedback to the
carburetor and the accelerator pump and the power piston in
the carburetor.
I have to profess that I am not an expert in this
area, and I can only talk in generalities. I hope I gave
you a feel for it.
MR. HELLMAN: Okay. The number of times a vehicle
is shifted causing hydrocarbon spikes — you mentioned 71
and 7 3 times during the test — is that comparable to passenger
car number of shifts during the test?
MR. JONES: It's a little higher. A little higher.
Some additional shifting that goes on.
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MR. HELLMAN: But the major reason for the hydro-
carbon problem would be the length of time of the shift?
MR. JONES: Correct. Correct. We have means, as
everybody does in the industry, of compensating for a small
shift spike, keeping the throttle cracked or allowing it to
close gradually. These devices have been used successfully
by all manufacturers in the industry for a long time, and
the fact that ARB made such a point about it this morning
causes me to make the point that these are not adequate. We
can only go so far with these devices, and when the time
element is three times greater than a passenger car, these
devices fall off. They don't work. Believe me, if they
worked, we wouldn't be here complaining about it today. We
would be using them and be selling our manual shift trans-
mission in 1978 in our senior vehicles, in our Jeeps, trucks,
and pickup trucks, and our Cherokee vehicles. They just
don't work.
MR. HELLMAN: Does anything happen to the air
injection on your CJ vehicles when you shift?
MR. JONES: Yes.
MR. HELLMAN: What happens to it?
MR. JONES: There is a diverter valve on the system.
It's a common type of valve that is vacuum operated.
A diverter valve serves many functions — or
several functions. One of those is to protect against
backfire. So when it sees a high vacuum spike, which is
indicative of a closed throttle — a person takes his foot off
the throttle to engage the clutch, it sends and diverts the
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air from the exhaust manifold to the outside ambient condition
so that a backfire will not occur in the exhaust manifold and
cause damage to the exhaust system.
MR. HELLMAN: Would it be possible to instead of
diverting that air to the atmosphere to divert it to right in
front of the catalyst instead to provide the air that might
be necessary to oxidize the extra HC that might be caused
during this spiking?
MR. JONES: Certainly. That's certainly possible.
We've thought about that. We've — I don't know if we have
any data. I don't even know if we've tried it. We've dis-
cussed it many times over the past couple years, and we've
come to the conclusion, rightfully or wrongfully, that there
is not enough potential there to pay the price, the plumbing
price, to do it. We just don't see it being a big enough
gain.
I don't know if we have data to substantiate that
opinion or not, but that is our judgment.
MR. HELLMAN: So using that approach would not allow
you to alleviate this hydrocarbon problem caused by the
spiking which is due to the longer shift time and allow you
to meet the standard in your opinion?
MR. JONES: No. It's not — Right now we don't
consider it significant enough to help. Certainly we are
going to continue looking at it as other schemes and other
potential means open up.
If for some reason in a year or two from now we
have a line that is already going to and from the oxidizing
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converter for another reason, then we have already paid the
cost and possibly we can tap into that line. Then it might
be to advantage, but just to go ahead and spend the money on
that small of a gain is not feasible to us in our estimation.
MR. GRAY: With regard to your 1979 light-duty
trucks, could you give us a very specific answer to what you
would anticipate being able to offer in California if you have
to comply with these standards?
MR. JONES: I'd be delighted to give specifics. I
try to be specific.
Before I give my specific answer, which I intend to
do, I have not, in my specific answer, qualified it for three
conditions: the first condition I have not qualified it for
is the fact that there is no automatic methane correction
factor. In other words, right now the only — trucks are
not allowed a .89. That is the way the current regulation is
written, and that is the way my comment will reflect.
Second, I do not have a total handle on the increased
road load horsepower. Therefore, I will say that it does not
have any — It is not sensitive at this point to the road load
horsepower increases that we are going to see in the 1979
model year.
Third, we are talking for all practical purposes
as far as I can tell against a .39 non-methane hydrocarbon
standard.
There is a time element there. I recognize that.
I am stretching my model year over to another year, but those
are the three points that I want to qualify and be very precise
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on when I give you my estimate.
For our CJ vehicles — I have a fourth qualifier,
I am sorry. This does not consider what our DF is. I told
you before we will never, to our fondest expectations, hit a
one again as the standards come down as low as they are now.
A 4,000 mile vehicle will — We can achieve, we
believe, .5 hydrocarbon on our CJ vehicles. It does not
consider the DF.
Our senior vehicles, which are our Cherokees,
Wagoneers, pickup trucks, .6 hydrocarbon, the same qualifiers,
looks achievable.
Is that specific enough. Are any of my qualifiers
clouding the issue?
MR. GRAY: No. I think that's specific enough.
Maybe my follow-up questions will tell how well I understood
it.
Looking at the CARB data that you referred to
earlier, I think those four tests were from a CJ —
MR. JONES: Yes.
MR. GRAY: — vehicle of 3500 pounds inertia weight?
MR. JONES: I believe so. I don't have the exact
numbers in front of me, but I'll accept that.
MR. GRAY: I thought that was a clarification that
you made to the record.
MR. JONES: I'm saying that we don't have any 4,000
pound CJ's, so I was correcting the inertia weight.
MR. GRAY: It's less than 4,000 pounds?
MR. JONES: Correct.
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MR. GRAY: Is there any possibility of increasing
the weight of that vehicle such that it would fall within the
4,000 pound inertia weight category? How close are you?
MR. JONES: We are not very close at all. In fact,
nationwide some of our CJ vehicles tip the scale at 3,000.
We qualify for the 3,000 pounds in California because of the
high usage of certain optional equipment and because of
additional emission control equipment. We fall now into the
3500 pound class, but nationwide those vehicles are certified
many of our CJ vehicles are certified at 3,000 pounds.
MR. GRAY: As far as you can see, there aren't
additions like heavier rollbars and stronger protective
devices for the front, bumpers if you will, extra fuel tank
capacity that would raise your vehicle weight even though
that full capacity might not at all times be necessary? You
don't think those kind of things are practical relative to
where you stand now in order to meet the 4,0 00 pound inertia
weight grouping?
MR. JONES: Not only are they not practical, but
they are very unreasonable. We have a higher commitment
called fuel economy nationwide in the 1979 and beyond model
year. We wouldn't be throwing weight into a vehicle in that
indiscriminate fashion just to certify in the State of
California. We wouldn't even conceive this. At least I
wouldn't conceive this. I can't speak for everybody.
MR. GRAY: I don't mean to imply that these are
indiscriminate areas. I mean they are areas that might make
the vehicle more attractive and would still allow you to
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certify in the State of California. Those are the types of
areas that I was asking about.
If you can answer with confidence that those are
not practical approaches, then that's sufficient.
MR. JONES: Not when you are talking 500 pounds on
a 3,000 pound vehicle. That's incredible.
MR. GRAY: I guess you have one V-8, the CJ?
MR. JONES: Yes.
MR. GRAY: It's a V-8 which is probably the heaviest
vehicle configuration —
MR. JONES: Okay. Okay. Let me rephrase your
question.
If we made every optional equipment item standard
in California and got full use of all the optional weights,
could we achieve a 4,000 pound vehicle, therefore getting the
benefit of the higher hydrocarbon standard? I guess that's
possible. I just don't see us doing that.
MR. GRAY: Well, with the seriousness with which
you raise the issue, I'm just trying to explore —
MR . JONES: Yes. I hadn't even — Up until now,
I hadn't even considered the question. You brought in a new
aspect, and I think it is possible if we wanted to take a
market strategy of that type.
MR. GRAY: If we are addressing the issue of whether
or not that type vehicle can be sold, I think that probably
any strategy that has any possibility of —
MR. JONES: I finally understood your question.
MR. GRAY: I am just trying to pursue are there any
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other approaches if you aren't able to better your best
estimates as to the emission levels.
Do you feel that a non-methane provision for light-
duty trucks would be enough to let you get under?
MR. JONES: I'd like to answer that question not
as directly as I have answered some of the other questions.
I think it's — If you are going to have a methane
correction factor in a regulation like the ARB's proposal,
they ought to be at least consistent in their own regulation.
They shouldn't discriminate on a basis that I can't under-
stand between passenger car measurements, test procedures,
and light-duty trucks in this case. I do wish them to make
a distinction about four-wheel drives, and I don't want to get
into that aspect of it because that wasn't part of your
question. But I think a reasonable regulation does not make
arbitrary differences like they've set up in this regulation.
MR. GRAY: I guess the reason I asked that is it
seems that it's at least an appropriate consideration, and
yet if it will not give you the extra capacity that you need
to certify, additional consideration of it is a moot point.
So, therefore, I would ask if you could be more
specific in response to the extent that you can regarding what
a non-methane allowance will do for you relative to compliance.
MR. JONES: By itself, we do not consider a non-
methane allowance a saving regulation.
MR. GRAY: From the test results that the CARB did
include, it appears that you certified at least that one
engine family with those three test vehicles, one at .41, one
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at .36, and the third at .47.
I am pursuing this line of questioning because it
appears that even today you would be quite close with respect
to at least that one engine family.
MR. JONES: It intrigues me how you can take data
that averages out to the standard being discussed, which is
.41 hydrocarbon, and say that that's good enough to indicate
that we have the potential to meet that standard. To me,
that data indicates that we do not have the potential, that
we could not in good judgment go out and certify those
vehicles if that were their value under the 1979 test pro-
cedure .
MR. GRAY: For 1977, you were shooting for a —
MR. JONES: .9.
MR. GRAY: Right, .9 hydrocarbon.
MR. JONES: We roughly engineered our target at
about half the standard, so those happened to hit half the
standard.
MR. GRAY: I only reference these numbers because
they represent three different vehicles, two of which barely
comply with the .41 number. Nonetheless, it would have
certified you in California to sell those configurations
no matter how close. With these other considerations, in
addition to the fact that you were trying to achieve a
different level, there may be some potential for a little
extra optimization at the expense of fuel economy or what
have you. It appears, at least on the surface, that to some
extent you may be close, so close that such things as a
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non-methane allowance factor might be very important to you.
So, that's the reason I am trying to get a better handle on it.
MR. JONES: By itself, a non-methane hydrocarbon
allowance is not going to make it — I can't offer anymore
insight into our capability of meeting a .41 hydrocarbon
standard than I think I have already indicated for the record.
MR. GRAY: Okay. Just in a summary sense, you
would try to meet '79 light-duty truck standards, but at this
point you do not know how many vehicles or model types you
would be able to certify in California; is that — Where do
you come out in that net effect sort of situation?
MR. JONES: The net effect is we do not have — As
the statement I read indicated, we do not expect at this point -•
at this point when we are actually getting ready to start our
1979 certification, within a few months anyway, for all
practical purposes we are done with our development, we know
sitting here today that we cannot certify our manual trans-
mission vehicles, which constitutes 80 percent of our CJ
vehicles sold here in California, which is 80 percent of our
family I-TC.
MR. GRAY: Does that mean to say you feel reasonably
confident you could certify the automatic?
MR. JONES: Doing everything in our power on the
automatic transmission vehicle and accepting a two mile per
gram loss, it is possible to certify the automatic transmission
CJ vehicle in California in 1979. Possible. We won't really
know for a few more months.
CHAIRMAN JACKSON: Is this .41 data that we were
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referring to, is that for an automatic or a manual?
MR. JONES: I'm afraid I can't — I didn't come
prepared with the '77 cert data, so I don't even know anything
about that data other than I accept it. I'm not challenging
it. It looks reasonable.
CHAIRMAN JACKSON: What we were mulling over here is
whether or not if it was an automatic, could you have it
carried over for subsequent model year certification?
MR. JONES: Well, I believe our '77 cert data
for family I-TC already carried over from '76. I'm not sure
of that. And I believe we are asking for a carryover until
'78.
CHAIRMAN JACKSON: I was just talking about '79.
MR. JONES: So you are saying — I don't think the
test procedure changes and everything will allow that. I
think in '79 you start with a clean sheet of paper.
Can you carry '78 over into '79 in California?
MR. RUBENSTEIN: As far as I know. The problem you
run into is the federal horsepower schedule change.
MR. JONES: That's one of the things I thought would
disqualify any '78 information, but I can —
CHAIRMAN JACKSON: We may work this out here and
have you certified already.
MR. JONES: Hey, if you can come up with a way,
great.
I'm not an expert in all the finesse of the regula-
tions .
MR. GRAY: A permanent boat trailer attached to the
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CJ5.
MR. JONES: A 500 pound boat trailer. I understand.
MR. GRAY: That's all the questions I had on light-
duty trucks.
MR. HELLMAN: You indicated that the approaches that
Mr. Austin discussed, which tend to reduce the hydrocarbon
spikes, are not effective on the manual transmission CJ
vehicles. Is that because the shift takes so long?
MR. JONES: Primarily.
MR. HELLMAN: You couldn't recalibrate those throttle
crackers, or whatever terminology you want to use to describe
those, to stay on longer when you shift?
MR. JONES: Well, it's not just a problem of the
throttle cracker by itself or the delay solenoid by itself.
It's the total time event. The throttle cracker and the
solenoid delay helps if you are going to be going back in
relatively quick. What happens is there is enough of a RPM
during that time interval where you beyond the accelerator
pump. Most of the time you end up getting back in the power
valve or power enrichment circuit of the carburetor, and when
you do that, you've got big problems. And that's the problem
that we see.
So, we've gone beyond in time the accelerator
function. We did use and we currently use throttle crackers
and delay valves at hydrocarbon standards less stringent than
this because they do help to a degree. But the degree that we
are looking for now is just too great for these devices to
bear.
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MR. HELLMAN: If you could conceptually divide up
the test into the hydrocarbon spiking modes and other modes,
would it appear to be a possibility to exist to get more
hydrocarbon control on the other modes which are not spiking
modes to offset the spiking modes? Have you considered that
approach?
MR. JONES: Karl, I don't know of any of the modes
when you are shifting 73 times on the cycle that are spike
free. There's a few, and certainly that's the kind of
optimization we just haven't had the luxury to work on.
MR. HELLMAN: So that a device like an extra catalyst
downstream, to go to that extreme, of the current catalyst is
not considered feasible or practicable by AMC?
MR. JONES: A downstream device for hydrocarbon
control would not have the operating temperature sufficient to
oxidize hydrocarbon. It would be great for CO, but it wouldn't
help the hydrocarbon problem. You need hot feed gas, hot feed
temperature to oxidize hydrocarbons. You need something close
coupled ahead of the current, not behind.
MR. HELLMAN: Okay. Thank you.
Let's switch the subject and talk about your remarks
on the 1980 passenger car exhaust emissions standards.
Your lead time discussion says, "Introduction of
technology.- even on a limited basis, capable of meeting the
1.0 gram per mile NO standard has not been demonstrated on any
X
of our vehicles."
Does that mean that you are maintaining that you
have not the technology in production today?
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MR. JONES: No. That means that our advanced
development has not matured — I think I will put a "period"
right there.
MR. HELLMAN: Did you run a fleet of a small number
of cars, approximately four, that you call the Ohio fleet?
MR. JONES: Correct.
MR. HELLMAN: Do you remember what the NO numbers
J x
were on those cars?
MR. JONES: Yes. They started out below one gram.
We did not have sophisticated feedback means for the carbure-
tion in those four cars, and they — I think one of them went
rich and did stay below the one gram NO ; went out of bed on
A
CO and hydrocarbon; another one went lean and immediately went
beyond the one gram NOx>
The purpose of those vehicles run on this Ohio fleet
were kind of a crude test gained at answering primarily the
durability. Will these things, these new devices, live on
a vehicle that goes 50,000 miles on a very high mileage
schedule? It was a way of gaining durability more than it was
of gaining emissions performance.
MR. HELLMAN: Nevertheless, even though the vehicles
were not equipped with feedback carburetion and you were
trying to find out whether or not the systems were physically
durable enough, some of them did either come very close or
some were below one point on NO .
x
MR. JONES: Oh, yes, I am sorry. One of the vehicles
was extremely low. I'd almost forgotten.
On the Gould unit, we had a reducing catalyst. In
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fact, everything looked really great on that vehicle. We were
out to 25, 30,000 miles, I believe, on that vehicle when we
ran into a durability problem. A couple years ago — In fact,
up until about a year ago, we were very high on a reducing
catalyst for standards below one gram NO . We felt the best
X
path was not three-way catalyst technology, but separate
oxidizing, separate reducing converter technology. We thought
a base metal catalyst that Gould Corporation was telling us
about and telling the world about as the solution to the .4
NO was worthwhile to look at. We invested considerable time,
x
We put the catalyst on as many cars as we could.
This Ohio fleet that you are talking about, Karl, had
one or two of them on, I can't remember specifically. It turns
out — I think everybody realizes what happens with a base
metal catalyst in today's sulfur-sulfate situation. They
deteriorate rather rapidly after a given point in time.
MR. HELLMAN: The four cars I am talking about, two
were Engelhard/Walker and two were Engelhard/Maremont. Those
are the four I am talking about.
MR. JONES: I am sorry, the fleet I am referring to
was the previous year. You are referring to the latest Ohio
fleet?
MR. HELLMAN: Right.
MR. JONES: I am sorry.
MR. HELLMAN: What's your conclusion based on the
durability results? Did the vehicles run through with no
major problems to the emission control system?
MR. JONES: The conclusion I can't address. I don't
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know the specifics of the latest Ohio fleet as far as — to
answer your question directly.
It was, again, a durability exercise. We were
satisfied with the overall durability performance. It was
not an emission exercise.
MR. HELLMAN: This line of questioning bears on the
fact that you stated later on that the three-way catalytic
converter is not proven, and I just wanted to, for the record,
indicate that you have run cars with three-way catalysts on
them and they did run for 50,000 miles and the problems that
you experienced during the tests were strictly fresh air
opening ducts in the air cleaner snorkles, burned out choke
gaskets, throttle cable sticking, and cracked manifold on two
of the vehicles. None of those problems appear to be directly
related to the fact that there was a three-way catalyst on the
vehicle.
MR. JONES: That's correct.
MR. HELLMAN: So for the physical durabilty of
catalysts, AMC does have information that appears to indicate
that the physical durability does not seem to be an insur-
mountable obstacle.
MR. JONES: The physical durability is not insur-
mountable, no. We ran that test to, again, prove out — it's
just one form of proving out whether we've designed the thing
with enough structure and enough durability to go 50,000 miles.
It's a quick way of getting 50,000 miles. It has no — We
take emission — I should say Ohio takes emission measurements
for us on these vehicles. We are very happy to look at
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emission performance, but the main purpose is stricly an
accelerated durability test. We were pleased with the
durability of the three-way catalyst containers and the two-
way catalyst internal working as a result of this test. It
told us things we have to know before we can market the device,
but it did not tell us about the emission performance.
MR. BELLMAN: Would the emission performance with
continued development be worse than it was on the Ohio fleet?
MR. JONES: No. They were not representative
systems of what we would envision marketing as far as the
sophistication of the engine controls.
MR. HELLMAN: With the closed loop control of the
fuel metering, you would expect the results to be somewhat
better?
MR. JONES: Certainly.
MR. HELLMAN: I come back to the "Introduction of
technology, even on a limited basis, capable of meeting the
1.0 gram per mile NOx standard has not been demonstrated on
any of our vehicles."
Does that introduction mean that introduction into
commerce that you have not yet certified such configuration?
MR. JONES: Again, it gets back to where we were
five or ten minutes ago. It gets back to the fact that our
advanced engineering programs have not matured to the level
that we have any confidence or have demonstrated any confidence
or any data that we could share with you that would say yes,
it looks like we can do it.
MR. HELLMAN: And this is primarily because of the
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inability for you to have run vehicles with closed loop fuel
metering and the electronic control unit in conjunction with
the three-way catalyst yet?
MR. JONES: Yes.
MR. HELLMAN: Okay. But the results are likely to
be better than what you ran before?
MR. JONES: We would anticipate and hope they would
be better.
MR. HELLMAN: On Page 5 of this statement, you say,
"Other technical paths, while potentially offering superior
fuel economy at today's emission levels, cannot meet the
NO level of 1.0 gram per mile with its associated NO engi-
X x
neering target of 0.5 gram per mile."
What other technical paths are you talking about?
MR. JONES: I'm specifically referencing lean burn
technology that has, in our judgment, a more conducive fuel
economy reward but inherent, unfortunately, minimal NO
potential around the one gram level. A standard that hits
one gram does not make what we know about lean burn technology
applicable.
MR. HELLMAN: Is it the 1.0 level or the 0.5 level?
MR. JONES: The 1.0 is the standard. When I talk
about the standard, I infer an engineering target of .5.
MR. HELLMAN: So that your lean burn technology
doesn't incorporate devices or technical approaches like the
Nisson NAPS-Z approach or the Mitsubishi MCA-JET approach?
MR. JONES: No. Unfortunately, our vehicles are
heavier than those, and we've not seen that technology carried
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into, say, our six cylinder vehicles of three to 3500 pound
inertia weight class.
MR. HELLMAN: Your statement about "Three-way-
catalyst technology creates an inherent fuel penalty since it
requires the engine to run at a richer air/fuel ratio than is
best for fuel economy," what are you comparing this to? Are
you comparing it to an engine map with some idealized con-
dition, or would you compare the three-way to an oxidation
catalyst system calibrated for the same emission level?
Would you say that the three-way still has an inherent fuel
economy problem?
MR. JONES: That's a very difficult subject to give
a nice, clean concise answer to. I am going to try anyway.
The fact that our current engines have evolved over
a long process, we know where they achieve the best fuel
economy as far as the air/fuel ratio. We know this is to be
at least two air/fuel ratios leaner than three-way catalyst
technology says we must calibrate to.
We also know, due to recent engine mapping, which is
still in its infancy in our engine dynamometer rooms, that
optimization under a described set of standards does not allow
for some trade-offs. We haven't had the opportunity, nor do
we conceive that we will have the opportunity by 1980, to
take advantage of this trade-off.
MR. HELLMAN: Okay. So this is based on what you
understand about the way your engine performs now? It's not
based on a comparision of a vehicle calibrated to these
standards with three-way system and another system?
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MR. JONES: Correct.
MR. HELLMAN: Okay.
CHAIRMAN JACKSON: Thank you, Mr. Jones.
MR. JONES: Thank you.
CHAIRMAN JACKSON: Mr. Martin, we are ready.
MR. MARTIN: All right.
My name is William J. Martin, staff engineer,
vehicle emissions for the International Harvester Company. I
have a statement to read into the record at this time.
International Harvester Company has reached a
critical point in its business of engineering and producing
medium-dity vehicles, the only offering to be produced by IH in
the 0-8500 pound GVW 1979 and subsequent model year emission
class of vehicles.
These vehicles are our Scout line of sport/utility
light trucks produced in four models: Scout II, Terra,
Traveler and SS-II manufactured for the sport/utility market.
The vehicles rated at 6200 pounds GVWR use 4-196, 304 and 345
CID engines and are available in both two-wheel and four-wheel
drive versions. One three-speed and two four-speed manual
transmissions, as well as an automatic transmission are
available. The V-304 is a federal engine only and was elimi-
nated from California production in 1977. On four-wheel
drive models, an IH single-speed transfer case is standard
with an optional two-speed Dana Model 20 available. The Dana
Model 44 rear axle is used and is available with 3.07, 3.54,
3.7 3 and 4.09 ratios.
IH, as a manufacturer of heavy-duty trucks, designs
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and builds its own gasoline engines for use in its gasoline-
powered truck models. IH does not build passenger car
engines. Gasoline engines available in International Scouts
are heavy-duty engines designed for truck-tractor operation,
or are derivatives thereof. For example, the V-34 5 engine
is the standard engine in our Loadstar and Cargostar models
with GVW ranges of 14,800 to 30,200 pounds. The V-304, once
standard in these truck models, has been replaced by the
higher horsepower V-34 5. Heavy-duty engines such as the V-304
and V-345 are qualified by operation at full rated power and
speed for 1000 continuous dynamometer hours.
The V-304 and V-345 engines are a family of engines
which include a 39 2 cubic inch displacement. IH's four-
cylinder engine, the 4-196, is actually half of the V-392. It
is this derivative with only minor modification to the tooling
which makes the four-cylinder engine feasible. All four dis-
placements are built over the same machine tool line. Thus,
it is presently feasible for IH to produce the displacements
noted due to the economics of the total volume produced.
One of the selling features for which IH's Scouts
are designed is to pull trailers. Certainly, cars pull
trailers, but they do not offer the flexibility of off-highway
recreational use once the destination is reached and the trailer
is parked. Scouts are designed to perform a variety of work
functions which include construction, agriculture, wholesale
and retail trade, as well as recreational and personal
transportation. Also, multi-purpose vehicles such as the
IH Scout are designed for uses which require the capability of
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not only leaving the roadway, but of climbing steep hills,
fording streams and operating in extreme weather conditions.
MPV's also perform a series of specialized work applications
such as snow plowing, winching, and other related uses.
On November 23, 1976, the CARB adopted standards of
0.50/9.0/1.5 grams per mile for 1981 models which will be
applicable to IH's line of Scout vehicles. Emission control
technology required or under consideration applicable to the
stringent 1981 standards is: three-way catalyts, closed loop
fuel system, EGR, air injection, electronic spark timing
control, modulated air inlet control, fast choke, etc.
Although IH has much concern as to the successful
application of the available technology to its line of
Scout vehicles, we believe that the Board's scheduled imple-
mentation date with the more stringent standards would possibly
allow for the orderly development and phase-in of this
technology on our vehicles, assuming that the technology can
be applied to this class of vehicles with no durability issues
surfacing.
With the requirements defined and the implementation
schedule known, IH has estimated the cost effects associated
with these requirements. For the 1981 model year, product
cost increase due to hardware has been estimated at $316 per
unit. Although such a product cost increase is significant,
IH believes that its pricing would be competitive since other
manufacturers would incur similar penalties. However, IH's
product tooling and development costs are estimated at approxi-
mately $7.4 million. At a sales forecast of 2593 units per
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IH
533
year in 1981 and 3121 units in 1982, this represents over
$1,294 per unit over the applicable two-year life of the 1981
standards. Clearly, the product cannot support such expendi-
tures. Should EPA grant California the waiver to enforce
their 1981 standards of 0.5/9.0/1.5 grams per mile hydrocarbon,
CO and NO respectively, IH's costs will be excessive and IH
X
can only conclude that it will be forced out of the California
marketplace.
As a small-volume manufacturer, development and
tooling costs are outstripping our ability to remain competi-
tive in the marketplace. Until this time, differences in
California emission standards versus federal requirements
have not presented such a wide disparity in development costs,
although certain engine options have had to be dropped from
the California market.
As stated earlier, IH does not build passenger cars.
We do not have the large volumes to spread the high develop-
ment and tooling costs associated with the advance technology
required for accelerated scheduled reductions in emission
standards for medium-duty vehicles. Historically, truck
emission standards have followed passenger cars. For those
truck manufacturers who are also high volume passenger car
manufacturers, technology is a hand-me-down situation. Tooling
and development costs benefit from the economics of high vol-
ume operations.
Attachment 1 lists IH sales of Scout vehicles in the
State of California from 1970 through 1977 model year.
Federal 4 9-State volumes are shown for comparison purposes.
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IH
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Additionally, we have included sales volumes for our light
line of pickups and Travelalls produced during the 1970-75
model years. Production of these models was discontinued in
1975. Regulatory requirements as well as competitive
pressures dictated that these models be discontinued.
As contained in California's 1978 Exhaust Emission
Standards and Test Procedures, IH has received the waiver for
its 1978 medium-duty models, our Scouts. With both California
and federal standards being essentially the same for the 1979
model year, IH is developing catalytic control systems to be
used nationwide. As a result, IH's development costs of
$3,950,000 for the 1979 models will be spread over 31,900
units per year instead of 2,516 units per year for California
only. Although future federal action is unknown, California,
by virtue of its more stringent standards, is apparently
preceding federal requirements by an estimated two years,
which results in the use of highly complex and costly tech-
nology attributable to California production only. An
expenditure of $7.4 million would be in addition to the
$3.9 million invested for the 1979-80 models.
Faced with the above situation, IH has considered
purchasing available technology. Purchase of a competitor's
engines and control technology, as well as the use of
identical transmissions and axles, would first appear to
indicate that IH's development costs could be substantially
reduced. However, exhaust emission certification of vehicles
in the 0-8500 pound class is a complete vehicle certification
program which ultimately rests with the vehicle manufacturer.
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Component installation costs as well as development of emission
control hardware in our application would be involved. While
the specific economics are unknown at this time, initial
estimates suggest that the development costs may be 15% less;
installation, tooling and plant rearrangement costs will be
higher. Therefore, we believe that the net costs will be
greater than that incurred in using our own engines.
At this time we have had difficulties establishing
an appropriate family of purchased engines that could be
available. IH has initiated studies with a number of
potential suppliers. Many aspects of such a joint venture
must be considered which must lead to a stable position
through the 1980's.
Any plan such as this would place IH with a single
source for its gasoline engines. Under normal business
conditions, acceptable working relations exist; but under
other conditions such as rapid market expansion, IH1 s produc-
tion would be jeopardized. For example, IH had, prior to the
197 3-74 oil embargo, purchased six-cylinder engines from an
automotive manufacturer to supplement its line of eight-
cylinder engines. When the oil embargo hit, IH was unable to
purchase the volume of six-cylinder engines it needed due to
the demand upon its engine supplier for six-cylinder engines
in its own vehicles. The supplier's capacity to produce
such engines was outstripped. This situation ultimately led
to their refusal to continue sales to IH.
Any decision to purchase engines for our Scout line
of vehicles would dictate that these engines be used nationwide
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iri 1981. This action would trigger the end of production
at Indianapolis of our four-cylinder and small V-8 engines.
Loss of this production in a plant presently operating at less
than acceptable volume would cause extreme economic disrup-
tions due to lack of sufficient time to prepare for work
replacement in a coordinated manner. Seventy-five percent of
the plant is devoted to a 4-196 and small V-8 production.
Thus, IH concludes that it would be no better off in
considering the purchasing of technology than to pursue the
continued development on its own engines. In fact, purchasing
engines from a competitor would hasten the end of production
of its highest volume small V-8 engines as used in its heavier
duty truck applications.
In summary, International Harvester Company requests
of EPA to deny California the waiver requested. The cost of
the technology required is such that it effectively precludes
IH from its use.
The situation noted is a result of California's earlier
implementation of more stringent medium-duty vehicle emission
standards than the federal government, which requires tech-
nology that is more sophisticated and costly in the 1981-82
time frame.
IH's low volume prevents spreading major development
and tooling costs over its vehicle production as can be done by
large volume passenger car manufacturers working to an
earlier schedule.
International Harvester Company requests of EPA to
weight the benefits to the State of California against the
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difficulties and the economics faced by the low volume manu-
facturer. IH's forced withdrawal from the California market-
place would have a threefold effect on all parties concerned.
First, IH would not be in the California market-
place and would lose our projected 2600 annual sales. On the
surface this appears to be a detriment to IH only. However,
removing a competitor form an active marketplace gives an
entry to the remaining competitors for more active penetration
in the same market with a different price/demand relationship.
In effect, the California consumer could be paying more for
a similar product in the same marketplace.
Second, IH has approximately 50 dealers in the State
of California whose only IH product line is Scouts. I'll add
at this point we have another 50 dealers that are not exclusive
IH dealers. In the event IH was forced to discontinue the
sale of Scouts in California, one of two circumstances would
occur with these dealers.
Due to the overhead and related costs associated
with their sale of Scouts, they would either attempt to
overcome those costs by acquiring a similar or related
product line, or eliminate those costs by cutbacks of
employees and expenditures. Even if they chose the prior,
there would be a time delay in setting up a new line of
merchandise. In effect, there would be loss of gross income,
expenditures, and their related benefits to the people of
California.
In addition, there are approximately 20 IH dealers
who sell Scouts as their main association with IH trucks but
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do sell, in lesser volumes, large IH trucks. If these dealers
lost the Scout, a large percentage of their business, it would
probably, due to lack of volume on larger models, force
termination of their business ties with IH trucks.
Third, if IH were forced to stop selling Scouts in
the California market for a period of two years or until
certification became practical and economical with our sales
in the remaining 48 states, re-entry into the California
sport/utility market would be difficult, costly, and in all
probability would never reach the levels of market penetration
that IH would have attained if continued sales had been
allowed. Our dealership organization would disintegrate. IH
could not maintain a dormant marketing force in California
for two years. Thus, once out of the California market,
IH does not anticipate re-entry at a future date.
In closing, IH urges EPA to deny California a waiver
for its 1981 and later model year medium-duty vehicle emission
standards until such time as federal requirements require
similar technology.
That's the end of my written statement.
CHAIRMAN JACKSON: Mr. Martin, is it fair to
conclude from the statement that you have made that in your
judgment it is technologically feasible to meet the standards
applicable to IH's product line that are proposed by the
CARB but for reasons of cost it's not a practical thing for
IH to do?
MR. MARTIN: Yes, with one clarification.
We think maybe the numbers can be reached. We still
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IH 539
hold reservations about the durability issue on this line of
vehicles, and until —
CHAIRMAN JACKSON: Not durability in terms of
certification, though?
MR. MARTIN: Well, we have reservations there, too.
The deterioration factors, we have concerns over those, but
the deterioration and the durability and customer use is a big
item to us.
CHAIRMAN JACKSON: Have you run any of these vehicles
with this hardware on them that gives data to justify your
concern?
MR. MARTIN: We have not run this kind of hardware
vehicle applications at this point in time. We are only
basing it on our knowledge of two-way converters, of that
experience we have to date and in the past, and we know from
the public record.
MR. GRAY: Mr. Martin, just to follow up that
general area regarding costs.
It appears that the big problem in terms of cost
impact is the area of tooling and development costs —
MR. MARTIN: That's correct.
MR. GRAY: — as compared to your current medium-
duty vehicles.
What additional systems would have to be added to
the vehicles to meet the '81 standards?
MR. MARTIN: We are talking about the three-way
converter?
MR. GRAY: Yes.
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IH 540
MR. MARTIN: We have plans for the probable need of
a warm-up model of some sort, exhaust system rearrangements.
We have some combustion chamber work to do; that's because of
the ORI problem. We anticipate some changes there. The
electronic spark control, some of the items I mentioned on
the one page.
MR. GRAY: Okay. Looking at those items, I guess the
concern that I still have is that it appears that many of
these things are the type of components that you could purchase
from a vendor, certainly the three-way catalyst and probably
even the closed loop fuel control system and the electronics
associated with that, the electronic spark control system
rather than to purchase another manufacturer's engine as you
discussed in your statement.
Do you not consider it practical to purchase these
components so that you would not have to incur the tooling
costs and extensive development costs that you have indicated
here?
MR. MARTIN: Oh, we don't do any development of,
say, the three-way converter itself. We buy that. We buy
the closed loop fuel system, the carburetor. But the
development cost is the application in the vehicle; does it
meet the standard? All of the vehicles that we have to use
in the fleet, we have something like 50 vehicles we are talking
about. All of that and the rework, the tooling. We have to
buy into the tooling to be able to buy any of these components
from another manufacturer. We would share in that tooling
cost. So, that's part of what we mean by tooling costs.
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IH
541
MR. GRAY: Would you give us a better segmentation
of the tooling costs versus development costs that make up the
$7.4 million?
MR. MARTIN: Okay. $4.9 million is the development
cost; $2.5 million roughly is tooling. That's product tooling
cost. We don't have a firm estimate yet on what plant or
facility cost would be involved. There could be some there
very well. We know there will be, but how much we don't know
at this time.
MR. GRAY: In calculating your $4.9 million for
development, you assumed you would have to run 50 different
vehicles through a development program?
MR. MARTIN: Right, development and certification
program.
MR. GRAY: Explain why you would need that many
vehicles.
MR. MARTIN: Well, I don't know if I can do it
adequate enough, because I don't have that detail.
There is a development fleet that is first run of —
and I don't remember how many vehicles are in it, six or eight
vehicles. Then there is a pre-certification fleet that
would then be run of that many more vehicles, and then a
certification fleet itself would be planned.
Then there are some other vehicles for other uses
that have to be taken care of other than just on "evap"
systems and things like that.
MR. GRAY: This would cover the costs associated with
developing and recertifying all the current versions that you
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542
IH
offer in California? This wouldn't reflect any IH decisions
regarding concentrating on a limited number of engine/vehicle
combinations?
MR. MARTIN: It's already limited. There's only
two engines, the 4-196 and the 345 is what we are speaking of.
MR. GRAY: And these 50 vehicles would be to develop
and certify those two engine families in California?
MR. MARTIN: That's correct. There's four models
involved.
We didn't discuss anything in this testimony about
the diesel engine. We kept that a separate subject.
MR. HELLMAN: You indicated that the cost for the
1981 system would be $316 per unit. That's retail price
equivalent?
MR. MARTIN: That's a sticker price increase.
MR. HELLMAN: Sticker price increase. What is that
compared to today's truck?
MR. MARTIN: That's over a '79 system.
MR. HELLMAN: That's over a '79 system which does,
as you indicated before, include a converter?
MR. MARTIN: A two-way converter.
MR. HELLMAN: That's in addition to this 1979
system?
MR. MARTIN: That's right.
CHAIRMAN JACKSON: Mr. Martin, you have rejected the
idea of using diesel engines?
MR. MARTIN: We have a diesel engine right today,
and we are hoping that it will still be in our marketing plans
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IH./AIA
543
for 1979. At least we are working with the supplier of that
engine in hopes that it will still be in there, but if we lose
V-8 engines or four-cylinder gasoline engines, there's not
going to be too much left over for diesel. The sales volumes
of the diesel have been going down ever since we first intro-
duced it. It's not really an acceptable engine for the
vehicle in the amount of horsepower that's available. It
doesn't have the power that a gasoline engine does that the
market expects.
MR. GRAY: Do you know how your sales split between
two-and four-wheel drive vehicles?
MR. MARTIN: We are at about 80 percent four-wheel
drive, 8 0 to 8 5 percent. The last I heard, Mr. Gray, that
was a year or so ago. It stays right there pretty constantly.
CHAIRMAN JACKSON: Thank you, Mr. Martin.
MR. MARTIN: Thank you.
CHAIRMAN JACKSON: We will take a five-minute break.
(Short recess.)
CHAIRMAN JACKSON: Mr. Schwentker, we are ready for
you.
MR. SCHWENTKER: Good. I'll only take a couple
minutes.
My name is Don Schwentker. I am with the Washington/
New York law firm of Rivkin, Sherman and Levy, and we are
general counsel for the Automobile Importers of America.
I think that consideration of the waiver of
requirements that are not formally adopted by the ARB is
premature. I agree with some of my colleagues that spoke on
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AIA
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this point earlier today, specifically the high altitude
amendment that's expected to be considered at a public hearing
on the 6th of June. We were just notified of this recently.
The record closing on the 10th of June is hardly sufficient to
comment on a regulation that's to be adopted on the 6th of
June.
The same thing is true of the non-methane hydrocarbon
standard of .39. That has not yet been adopted. We received
notification by telephone of the hearing to adopt the .39
hydrocarbon standard not from the California Air Resources
Board but from John Rugge who works for you, Ben, which is a
rather unusual way to learn of a public hearing on a California
standard. To say that that kind of rule making is sloppy, I
think is an understatement.
California rule making does proceed in a rather
informal way, to use a charitable expression, and I have been
involved with it for nine years. It is not unusual to have
a notice of a public hearing for a hearing that's to take
place in 3 0 days with the test procedure to be available only
to find that the test procedure is not available and there is
not sufficient time to comment on it before the hearing.
So to consider it a waiver hearing of a regulation
that has not yet been adopted, I think, is indeed premature.
Adding material for the record, if requested by the hearing
officer, is an entirely different situation than being
expected to comment for the record on something that is
adopted after the close of the public hearing. I don't
think that is what is meant by a public hearing. I think that
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AIA
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adding material for the record is fine if you ask for addi-
tional data to be submitted or if a witness realizes during
his testimony that he has something he would like to add
later on, but I don't think it's appropriate for us to be
limited in our comments on a particular regulation by adding
something for the record.
I'd like to comment also on the question that was
asked of General Motors earlier on model availability and
whether or not marketing considerations were an additional
factor considered.
Marketing considerations are indeed important in
California, but these decisions are, in most cases — and I'm
sure I am right with respect to other than imported automobile
manufacturers. Marketing decisions are based on the cost of
compliance with California standards, drivability and fuel
economy considerations that are, among other things, related
to meeting these California standards. They are only
marketing and commercial decisions to the extent that decisions
are made that it is not practical to offer a particular con-
figuration in California due to the high cost of meeting the
California standards or due to drivability problems with a
particular configuration or fuel economy problems. So, it's
not really fair to say that this is just purely a marketing
decision not to offer a particular configuration in
California. A purely marketing decision, presumably, would
be based on a decision not to offer a particular configuration
in California if California's emission standards were the same
as the federal standards. That's just simply not the case.
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AIA 546
There are many configurations that are not offered in
California because of the California standards. Some of
them are directly related to not being able to meet the
standards with the particular configuration, and in other
cases, there are these side effects that I am talking about.
I also would like to see clarification of this
air/fuel ratio anti-tampering provision. I listened to all
of the discussion today, and I still don't understand where
we are with respect to whether the carburetor has to be
removed or whether it need not be removed or whether the tool
that's to be used must not be available from Pep Boys or it
must only be available in the zone office or whatever. I
think that clearly needs to be cleared up.
When you read the requirement literally, there are
two alternatives: one, that the executive officer may ask
that the emissions test be done at any particular setting
within the range and the vehicle must meet the standard; or,
in the alternative, that the mixture adjustment mechanism is
not visible even with the air cleaner removed. And special
tools and/or procedures are required to make adjustments.
If I understand what that means, I think it means
that, number one, the mixture adjustment mechanism must not
be visible; and, number two, a special tool must be required
to make the adjustment, or a special procedure — whatever
that is — must be required to make the adjustment. And I
sure would appreciate some clarification on that.
Also in the ARB testimony this morning, Gary
Rubenstein said that Honda and Subaru said they could meet the
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AIA
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.41, 9.0 and 1.0 standard. I don't think he said all of it.
I think Honda and Subaru also said that the standards create
drivability and fuel economy problems, and that was not
mentioned by ARB. The implication was that Honda and Subaru
endorsed the .41, 9.0 and 1.0 standard.
With respect to the vehicles that meet the
California 1980 numbers today, not only must we consider the
engineering target criteria and the uncertainties resulting
from future use of MMT that were described earlier today, but
the fact that federal fuel economy standards that become more
stringent in the years to come and as well weight increases
that may result from meeting more stringent federal safety
standards for bumper protection and occupant crash protection,
to name a couple.
Also I'd like to mention that Table 4 in the ARB
presentation that lists the 1977 certification vehicles that
meet the '79 standards is an impressive list, but it could be
a lot longer, because it's my understanding that all of the
vehicles that are sold in California this year met the 197 9
California standard.
That's a poke. They meant 1980, but the graph
says 1979.
CHAIRMAN JACKSON: I'm glad you added that little
bit on the end there.
MR. SCHWENTKER: We've got to have some fun; don't
we?
CHAIRMAN JACKSON: Mr. Schwentker, when did you
first learn of the fact that the .41 standard was to be a
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AIA
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non-methane equivalent?
MR. SCHWENTKER: You mean that the .41 standard was
to be changed to .39?
CHAIRiMAN JACKSON: That it was to be a non-methane
equivalent.
MR. SCHWENTKER: Well, I guess I learned that it
was to be a non-methane equivalent at the time I received the
California test procedure that proposed to authorize the
Executive Officer to hold a hearing to consider adoption of
the standard as .39, and that was about the sixth of May.
CHAIRMAN JACKSON: But you were never under the
impression that the .41 was a non-methane equivalent or that
it was intended to be a non-methane hydrocarbon standard, the
equivalent of .41 non-methane?
MR. SCHWENTKER: Well, I didn't understand that,
that's for sure.
CHAIRMAN JACKSON: You never knew that before
John Rugge called you and informed you that —
MR. SCHWENTKER: John Rugge called me to inform me
of the date of the hearing, and I got the call from John Rugge
the same day that I got the mail from the California ARB
containing the staff report that's to be presented to the
Board at its next meeting that discusses this problem and the
high altitude problem and "evap" problem and there's about
five problems considered by that one staff report that I
received, I think, on the 6th of May.
My complaint is really a procedural one. With
respect to the .39, no one has had an opportunity to comment
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AIA
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whether .39 is an appropriate number. I don't know whether it
is or not. I am not arguing that. I am arguing from a pro-
cedural point of view I think it's inappropriate to consider
granting a waiver on a standard that's not yet been adopted.
If the California Administrative Procedure Act is
to be followed, they are to give notice of a public hearing
and they are to take testimony and they are to consider that
testimony. If you today can grant a waiver for a .39
standard, it would appear that the decision has already been
made. I don't know whether the number is right or not. I
just think that the people ought to be given an opportunity to
comment on it and consider it first, of course.
CHAIRMAN JACKSON: I have two questions here sub-
mitted by the CARB for you, Mr. Schwentker.
The first one is: Are you stating that the
proposed regulations requiring the .39 gram per mile standard
and high altitude regulations were not available at least
3 0 days prior to the June 6th public hearing which ARB has
scheduled?
MR. SCHWENTKER: I didn't say that those were not
available. I am saying that I received them in the mail, I
think, about the 6th of May. I can't tell you exactly, but I
think it was the 6th of May. And, yes, that would be just
exactly 30 days or 31 days from June 6th.
What I said was I received notification of the date
of the hearing from John Rugge on the telephone and that
notification I think I received on the 7th of May. I could
check my telephone diary and confirm that. But I think I
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received it on the 7th, and it was either the same day or the
day after that I received the staff report in the mail.
Now the staff report, and I have a copy with me,
only says that it is making a recommendation to the Board
that the Board authorize the Executive Officer to hold a
hearing. Now that thing is dated May 26th, because that's
the date that it's to be presented to the Board.
CHAIRMAN JACKSON: Will AIA members be submitting
comments on the .39 gram per mile standard and high altitude
regulations to CARB at the June 6th hearing?
MR. SCHWENTKER: I don't know.
CHAIRMAN JACKSON: And the follow-up to that:
Can't these comments also be supplied to EPA for consideration
in the waiver deliberations?
MR. SCHWENTKER: Well, I'm sure that can be done.
You know, any comment that is furnished to the ARB certainly
can be furnished to EPA, but that's not the point I was trying
to make. The point I was trying to make is that normally in
a waiver hearing, one discusses regulations that are adopted
and are on the table before us. Right now the ARB is pro-
posing to adopt the .39 non-methane hydrocarbon standard on
June 6th. What if they don't? What if they adopt something
else? Maybe the comments will be so persuasive that ARB will
adopt something different than what they propose, God forbid.
Then where are we?
CHAIRMAN JACKSON: Who do you know that has that
persuasive power?
MR. SCHWENTKER: I keep looking for somebody.
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There's bound to be somebody somewhere.
CHAIRMAN JACKSON: There is a fact included along
with these two questions that I thought I would read into the
record, which is the .39 gram per mile standard and high
altitude regulations were available at ARB and mailed to
manufacturers on April 27, 1977.
MR. SCHWENTKER: The fact that they are available is
lovely. If one knows that they are available, then he can go
by there and pick them up.
The point I am trying to make is that I got them
out of my mailbox on about the 6th of May or the 7th of May,
and I'll have to check if you really want to know which day
it was, whether it was the 6th or 7th.
What I mentioned earlier was, when I talked about
sloppy rule making, the fact that frequently notification is
sent out of a public hearing that is to be held 30 days in the
to satisfy the requirements of the California Adminis-
trative Procedure Act, but the regulations that we are to
discuss are not available at that time. And that happens
more than just occasionally. That happens all too frequently
In this particular instance, I did have the staff
report about 30 or 31 days before the June 6th hearing. I'm
sure that's why the June 6th date was picked.
I'm just complaining about the way we find out about
things, and I'm complaining about having to consider something
at a waiver hearing before it's formally adopted. I just
think that's inappropriate.
CHAIRMAN JACKSON: Thank you very much.
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AIA/MEMA
MR. SCHWENTKER: Thank you.
CHAIRMAN JACKSON: Your comments are duly noted.
MR. FLEISCHAKER: I think I am the wayward son at
this hearing, because I am going to discuss a little different
issue than has been discussed but which I think is important
and I appreciate the opportunity to do it today.
CHAIRMAN JACKSON: Is it on the agenda?
MR. FLEISCHAKER: In my opinion, it is.
CHAIRMAN JACKSON: Then you may proceed.
MR. FLEISCHAKER: My name is Marc L. Fleischaker,
and I am an attorney with the Washington, D.C. law firm of
Arent, Fox, Kintner, Plotkin & Kahn. j am appearing today
on behalf of the Motor and Equipment Manufacturers Associa-
tion, MEMA, a national trade association representing
approximately 750 manufacturers o-f
urers ot automotive parts. The MEMA
member manufacturers produce vehicle equipment both for use
as original equipment by the automobile manufacturers, and
sale to vehicle owners through the automotive aftermarket.
MEMA opposes granting California a waiver to
implement yet unadopted certification test procedures
applicable to 198 0 and subsequent model year passenger cars,
light-duty trucks and medium-duty vehicles imposing a
restriction on allowable maintenance. I might just add here
I am not talking about the anti-tampering regulation which has
been discussed by several other witnesses, but it will be
clear in a minute what I am talking about. MEMA opposes
the grant of this waiver because (1) it is premature, (2) it
fails to meet the prerequisites for a waiver under Section
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MEMA
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209(b) of the Clean Air Act, (3) it would be severely
anticompetitive in its effect, and (4) it will have a detri-
mental effect on vehicle emissions in the State of California.
With respect to the timing of the proposal,
California Air Resources Board Resolution No. 77-16, upon
which the request for a waiver is based, has not been approved
by the California Air Resources Board, and will not be
approved at least until the May 2 6 meeting of the Board in
San Diego. Consequently, if the EPA were to grant a waiver
at the current time, it would be doing so blindly, since it is
not yet known what the regulations adopted by the Board will
contain. As will be discussed more fully below, MEMA believes
that the EPA should not grant the State of California a waiver
from federal preemption to implement regulations unless the
EPA knows precisely what those state regulations contain.
Since there is no way at the currert time for the EPA to know
this, it would be premature for the waiver to be granted.
I gather that there's some agreement with this
particular point since it's not, apparently, up for a waiver
today. However, I think it's appropriate to discuss the merits
of it, not only because it appeared to be on the published
agenda for this hearing. I might note in that regard that
this regulation has the exact same title and was considered
on the same dates as the regulation on the anti-tampering
proposal, but also because —
CHAIRMAN JACKSON: Excuse me, Mr. Fleischaker.
MR. AUSTIN: If I might clarify, Mr. Jackson, we
have not applied for a waiver for the regulations which this
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MEMA
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gentleman is discussing. You noticed our regulations
regarding anti-tampering and described them in a manner that
I think has led him to conclude that you are considering here
regulations which we have yet to adopt and yet to request
a waiver from EPA on.
MR. FLEISCHAKER: I think that is an accurate
statement of the facts, but I would think it's not inappro-
priate to proceed for the reason that it did appear to be
on the agenda, number one; and, number two, that is being
considered again by the Air Resources Board at the May 2 6th
Board meeting.
CHAIRMAN JACKSON: I think I can clear up the issue.
You are right, the notice may be somewhat misleading. The
reason is we quoted in the notice — or paraphrased, I should
say, in the notice language from a document which was read into
the record on the first day of this hearing, which is a letter
to the Administrator from the California Air Resources Board
dated January 20th, 1977 in which on Page 3 the California
Air Resources Board said under Heading 3, "Allowable
maintenance. In another action taken after a duly noticed
public hearing in its December 14 , 1976, meeting, the Air
Resources Board amended the certification test procedures
applicable to passenger cars, light-duty trucks, and medium-
duty vehicles to impose a restriction on allowable maintenance.
In essence, the test procedures now require a sealing or
redesign of carburetors so that they cannot easily be mis-
adjusted . "
The restriction on allowable maintenance language
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picked up in our notice, and I think that it's probably
appropriate to say that that was improper on our part, one,
and probably not an entirely appropriate phrase to be used in
this particular letter.
MR. FLEISCHAKER: I just might note that the
California proposal, I suppose you would call it, on this
is entitled "California Exhaust Emissions Standards and Test
Procedures for 1980 and Subsequent Model Passenger Cars,
Light-Duty Trucks, and Medium-Duty Vehicles." It states
on this, "Adopted November 23, 1976, amended December 14,
1976."
It's precise with what was in the Federal Register.
CHAIRMAN JACKSON: And the only amendments they
adopted were the anti-tampering amendments; is that right?
MR. AUSTIN: That's correct.
CHAIRMAN JACKSON: I think that effectively precludes
the relevance of the testimony that you are offering before us,
in that it relates to a matter that's not before the
Administrator for decision.
Is there any argument about that?
MR. AUSTIN: Not from the Air Resources Board.
MR. FLEISCHAKER: I would agree it's not before the
Administrator apparently for decision. I'd like to submit it
for the record if I might, nevertheless, and make some comments
on the general waiver which clearly is —
CHAIRMAN JACKSON: A topic for discussion tomorrow.
MR. FLEISCHAKER: A topic for discussion.
CHAIRMAN JACKSON: Do you plan to be here tomorrow?
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MEMA 556
MR. FLEISCHAKER: No, I don't.
CHAIRMAN JACKSON: I will accept your comments on
the general waiver. I would respectfully request that you
withdraw the request to include in the record the comments on
the matter that's not before us. That falls in the category
of other things that don't affect us that we should consider.
So if we could move to your comments on the general
waiver.
MR. FLEISCHAKER: Did you want my concurrence to
that or not?
CHAIRMAN JACKSON: That would be nice.
MR. FLEISCHAKER: But you are going to do it in any
event, exclude it?
CHAIRMAN JACKSON: That is correct.
MR. FLEISCHAKER: Then you don't need my con-
currence .
CHAIRMAN JACKSON: We like to be as amicable about
these things as we can.
MR. FLEISCHAKER: MEMA wishes to state its opposition
to granting California a general waiver of federal preemption
for all standards and test procedures, including accompanying
enforcement procedures adopted by the California Air Resources
Board in the future that relate to the control of emissions
from new motor vehicles or new motor vehicle engines. We
are concerned that California, as we belie\e it has in the case
of the proposed regulation which I am not discussing, will
interpret the phrase "related to the control of emissions from
new motor vehicles" broadly so that it encompasses numerous
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MEMA
matters not primarily designed to control emissions from new
motor vehicles. In this case, I am specifically referring to
matters which are more closely allied to maintenance practices
than to certification practices.
Furthermore, in adopting the Clean Air Act Congress
intended that a specific showing should be made by California
that its standard is stricter than the federal standard, that if:
is technologically feasible, that extraordinary conditions
exist in California, and that the California rules are
consistent with Section 202(a) of the Clean Air Act. Other-
wise the Congress itself could have granted a blanket waiver,
rather than setting forth specific criteria, and noting that
the waiver should be granted only after notice and opportunity
for public hearing, and in general requiring the state to
prove that a more stringent standard is necessary than the
federal standard.
That's my summary comment on the general waiver.
CHAIRMAN JACKSON: Thank you very much, sir.
We will reconvene at 9:00 a.m. in this room
tomorrow morning and take up the matter of the general waiver.
(Whereupon, the proceedings adjourned at the hour
of 5:44 o'clock p.m., to be reconvened at the hour of 9:00
o'clock a.m., Thursday, May 19, 1977.)
oOo
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