Proceedings of the EPA/Industry
Workshop on Paperwork Reduction
in the Certification Process
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Mobile Source
Air Pollution Control
Certification Division
Ann Arbor, Michigan 48105
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Proceedings of the EPA/Industry
Workshop on Paperwork Reduction
in the Certification Process
December 12-14, 1977
U.S. Environmental Protection Agency
Office of Air and Waste Management-
Office of Mobile Source
Air Pollution Control
Certification Division
Ann Arbor, Michigan 48105
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TABLE OF CONTENTS
I. Introduction
Sa< Background
B. Workshop V0b~jec.tives
C. Workshop Topics Explored
II. Summary of Workshop Recommendations
A. Recommendations from Discussion of Workshop Topics
B. Miscellaneous Recommendations
III. Session Reports
IV. Appendix
A. Workshop Agenda
B. Session Chairpersons and Participants
C. Workshop Attendees
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I. Introduction
A. Background
Since the establishment of the certification process in 1968, the
amount of information EPA needs to certify vehicles and trucks has
increased at least ten-fold; EPA currently processes 100,000' pages
of material in the course of reviewing one model year's applications
for certification and issuing certificates. Approximately 60 to
80% of these pages—the proportion varies from manufacturer to
manufacturer—consists of revisions or amendments to documents
previously submitted to EPA at earlier stages of the certification
process. Every one of these revisions must be reviewed/and eval-
uated. This involves comparing each revision line-by-line with
the application pages proposed for replacement, manually filling
the revision (if approved) into the proper section of the appli-
cation, and storing the replaced pages elsewhere. These clerical
tasks of proofreading and paper-shuffling, repeated thousands of
times during a model year, drain the resources available to both
EPA and the industry to do the technical evaluations essential
to the certification process and adversely impact the timely
certification of vehicles and engines.
B. Workshop Objectives
The workshop attempted to discover, propose, and consider a
variety of techniques designed to reduce this 100,000 page-
per-annum paperwork burden. More generally, workshop parti-
cipants were invited to consider any method or procedure that
might improve the efficiency of application processing. Although
the session chairpersons sought primarily to stimulate ideas
rather than to develop concrete implementation strategies, some
efforts were made to assess the operational feasibility of the
streamlining strategies discussed.
C. Workshop Topics
Prior to the workshop, representatives of EPA and industry
determined that each of the following subjects should be treated
in a specific workshop session: 1) Standard Indexing and
Terminology in the Certification Program, 2) Sequenced Sub-
mission of the Application for Certification, 3) Referencing
within the Application, and 4) Computerization of the Application
for Certification. The findings and recommendations of these
sessions are summarized in Section III and discussed at length
in the workshop reports reprinted in Section IV. Short intro-
ductions to these topics are provided below:
1) Standard Indexing and Terminology in the Certification Program.
Although EPA annually provides industry with a recommended format
for the Application for Certification, these guidelines are sufficiently
general so that manufacturers eventually submit applications which
differ materially in structure and detail. This lack of uniformity
impedes comparisons across manufacturers' data necessary to EPA
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analyses, and, more importantly, slows the process of cert-
ification review, because each certification engineer must
familiarize himself/herself with the formatting idiosyncrasies
of every application he/she must process. This problem is
aggravated by the discrepant technical vocabularies employed
by the various manufacturers; one company's "aspirator" equals
another's "reed valve" equals another's "pulseair," and the
certification engineer must devote some energy to mastering
these differences in terminology. The purpose of this workshop
session, therefore, was to explore the feasibility and usefulness
of (1) a standardized indexing scheme, to be employed by all
manufacturers, which would definitively establish within the
application the physical location of specific units of infor-
mation; and (2) a standardized terminology for describing
emission-related systems and hard-ware.
2) Sequenced Submission of the Application for Certification.
In general, manufacturers wish to have their vehicles and engines
certified well in advance of anticipated production dates. In
their understandable eagerness to begin.the certification process—
to have their durability-data vehicles selected and accumulating
mileage—they will regularly submit entire applications ten or
eleven months prior to the projected "job 1" date. This
operational deadline regularly necessitates that the first hastily
produced application will contain omissions or deficiencies, and
often guarantees that the application must be revised and up-
dated as design marketing and production needs shift and/or
become clarified. These changes and the paperwork they create
might be reduced if sections of the application were not submitted
until such time as EPA engineers needed to review the precise
material those sections contain. For example, manufacturers might
first submit only that material needed for the selection of the
durability-data vehicle fleet. If these data were approved,
manufacturers could then submit other material necessary for
selection of emission-data vehicle fleets. Such sequenced
submission of portions of the application would relax the
manufacturers' submission deadlines, thereby providing additional
time for the manufacturers to assure the currency and accuracy
of the application; this measure could greatly reduce the number
and volume of revisions required to the original application.
The aims of this session, consequently, were (1) to assess the
feasibility and desirability of a sequencing scheme; and (2)
assuming that sequencing was judged worthwhile, to identify
those factors (e.g., EPA's information requirements, industry's
operational constraints) which would influence development of
a sequencing plan.
3) Referencing within the Application.
Referencing would seek to reduce the size of an application for
certification by eliminating duplication and redundancy from the
document. In some applications, identical information may apply
to several different engine families and, according to current
procedures, is printed or copied in several different places in
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the application. Other data, such as description of test
facilities and equipment, are often repeated verbatim from
one year's application to the next. Wasted time, effort, and
paper inevitably result when manufacturers must generate and
EPA engineers reread these identical pieces of information.
A more economic procedure might be to submit certain material
only once, and then simply reference that submission whenever
its contents would be required for review. The aim of the
Referencing session was to assess the feasibility and utility
of a standardized referencing method.
4) Computerization of the Application for Certification.
At the present time the manufacturers submit all of the Part I
and Part II Application information in hard copy to EPA. Some
of that information pertaining to specific vehicles to be tested
is subsequently transcribed by EPA engineers onto computer input
forms and then entered into the computer files. If EPA refines
its data-processing capabilities and if manufacturers were to
submit as much of the Application as practical to EPA in computer-
compatible format, tremendous gains in the speed and efficiency
of application processing could eventually be realized. In the
area of revision processing, for example, both the industry and
EPA could use a text-editing program to compare proposed revisions
with the corresponding original pages, and the computer could
mechanically locate more rapidly and accurately the differences
which staff members must now spend hours identifying. Com-
puterized applications would further provide an extensive data
base, which EPA certification engineers could consult when
faced with a complex decision regarding matters of fleet
selection, running change testing requirements, etc. Such
a data base, by making available for comparison a body of
precedent certification judgments, would enable EPA certification
staff members to make decisions with greater confidence and speed.
The aims of this workshop session, in summary, were to 1) identify
the data-processing and word-processing capabilities of EPA and
manufacturers and 2) explore the costs and benefits of a more
fully computerized certification program.
Other certification streamlining techniques were discussed and submitted
in form of suggestions at the individual sessions, in the papers presented,
in the reports of the sessions, and finally at the question and answer
session during the last day of the workshop. All of these are summarized
in Section III of the report apart from the main conclusions and rec-
ommendations.
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II* Summary of Workshop Conclusions and Recommendations
Workshop participants agreed that the application of indexing,
sequencing, referencing, and computerization to the certification
process would result in substantial benefits to industry and EPA.
Strategies for implementing techniques are described in detail in
the Workshop Reports reprinted in Section IV, but the fundamental
recommendations will be summarized below. This summary will also
include various other recommendations, proposed by industry, covering
both changes in administrative procedure and modifications to the
certification protocol itself. These suggestions (Recommendation 3
below) were not examined in detail during the workshop, and con-
siderable further investigation will have to be done before they
can be evaluated and implemented.
Recommendation 1: Revise the format of the application for certi-
fication. A new application format should be developed, establishing
a standardized terminology and incorporating techniques of indexing,
referencing, and sequencing. This application should be sufficiently
standardized so that it will be fully compatible with computerization,
and yet general enough to be used for light duty vehicles, light-duty
trucks, heavy-duty engines, and motorcycles. It should be so structured
that errors in submission will be actively discouraged. The possibility
of making all applications a set of standard forms, distributed by EPA
and then filled out by manufacturers, should be considered.
Follow-up actions:
- Establish an eight-member task force to devise standard
names for all application sections and subsections and
develop an indexing method adaptable to all classes of
applications.
- Establish a second eight-member task force to develop a
sequencing strategy.
- Hold joint task force sessions to coordinate efforts and
results by February 1978 so that the new format will be
ready for Model Year 1980.
Recommendation 2: Increase the use made of automatic data-
processing during the certification review. Although some
certification information, such as engineering drawings and blue-
prints, cannot be submitted to EPA in machine-readable form,
strategies to computerize the certification process should be
developed and tested.
Follow-up actions:
- Identify the technical data whose computerization would
be most beneficial to EPA and industry.
- Review the new application format to assure its compatability
with computerization.
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- Develop new and/or modify existing software to
facilitate on an experimental basis a computer-assisted
certification review.
- Develop and run a pilot project in which technical data
from selected engine families would be received and
processed in machine-readable form. Processing steps
might include: durability-data vehicle fleet selection,
preliminary emission-data vehicle fleet selection, pro-
cessing of revisions via a text-comparison program, etc.
- Evaluate the pilot project. On the basis of the project's
results, initiate further follow-up actions.
Recommendation 3: Miscellaneous Recommendations. The following
suggestions propose modifications to administrative practice and
the certification protocol itself. Many of these urge changing
the procedures for running and testing durability-data vehicles
and deriving deterioration factors. These include:
- Use broader family definition to reduce the number of 50K
certification vehicles.
- Freeze durability regulations at least six months prior to
the start of mileage accumulation.
- Reformulate the definitions of exhaust emission families Co
reduce the number of 50K certification vehicles required.
- Change the mileage accumulation route to raise average
speed from 30 to 35 or 40 mph.
- Eliminate the current 50K vehicle certification program and
derive D.F.s from bench testing.
- Give manufacturers the option of using a standard deterioration
factor or running a vehicle.
- Eliminate the requirement for 50K certification testing and
calculate D.F.s from previous fleets or in-use vehicles.
Other recommendations for modifying the certification process are:
- Reduce the information required for submission. Only those data
frequently accessed by EPA should be submitted; hard copy data
rarely utilized could be accessed from industry at EPA's request.
- Define in a more formal fashion the fleet selection criteria
such that the manufacturer can select his own durability and
emission data vehicle fleets.
- Eliminate requests for duplicate information in Parts I and II
and zero mile books.
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- Eliminate the need for resubmission of duplicate applications
for carry-over. Grant carry-over on the basis of a letter of
request and requisite updated information, such as revised
sales figures.
- Eliminate repeated EPA approvals of the same data. EPA should
establish a single approval point for reviewing information
common to light-duty vehicle and truck applications and make
efforts to standardize the reviewing criteria practiced by
the various certification teams.
- Reduce the number of emission-data vehicle tests by testing
only the worst case vehicles.
- Permit manufacturers to implement running changes concurrently
with their submission, assuming that manufacturers are willing
to assume the normal legal consequences of the running change
vehicles failing subsequent certification tests.
- Define more clearly the meaning of Auxiliary Emission Control
Device (AECD).
- Review the requirements of the certification and fuel economy
programs to identify where redundancy can be avoided.
Several other recommendations are listed in the reports to the workshop
sessions (see especially Section III,pp. 54-64) which, in the
interests of paper conservation, will not be reprinted here. EPA is
currently reviewing the practicality and usefulness of these mis-
cellaneous recommendations and will begin implementing as soon as
possible those identified as feasible and consistent with EPA's
regulatory function.
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III. Session Reports
Many of the papers presented during the workshop have been
included in the following reports.
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Report of the Session on
Standard Indexing and Terminology
Paperwork Reduction Workshop
December 12, 13, and 14, 1977
Greg Dana
Jan. 9, 1978
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TOPIC
The topic of this session of the Paperwork Reduction Workshop was
Standard Indexing and Terminology; our purpose was to explore the
feasibility of these ideas and make plans for implementing them.
PROPOSALS AND COMMENTS
A. There are differences between light-duty, heavy-duty, and motor-
cycle informational requirements which could make the indexing
scheme presented (W. Henny - Cummins) more complex; some changes
would be necessary for light-duty and motorcycle (proposals for
indexing are contained in Attachments I and II).
B. It is possible for an indexing system to go into too much detail,
thereby reducing its flexibility and its ability to be used by many
manufacturers.
C. Is there a need to standardize terminology? A cross-reference
listing or dictionary may be better.
D. Emission control devices have been developed independently and
are necessarily different. An attempt to standardize terminology
would be futile.
E. Agreement can be reached on broad topics of emission control
(e.g., "EGR system" should evoke the same meaning for all manufacturers).
F. It was noted that there is an SAE paper on standardized termin-
ology: "Emissions Terminology and Nomenclature—SAEJ1145a" (see
Attachment III).
G. Pre-printed formats are used in Sweden—some manufacturers attempt
to use the EPA format as a pre-printed format and find it very
inadequate—adding revision date blocks to the format pages and
allowing more space to fill in the required data would help.
H. Reasons were given why a pre-printed format is not useful:
1. Cannot be used by a word processing system
2. Rearrangement of the data permits more efficient use of the
page
I. Standardized forms and terminology should be developed for items
frequently submitted, such as data and maintenance logs (see Attachment
IV).
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J. Standardization of fuel economy and emission certification data
input requirements would be beneficial.
COMMENTS NOT DIRECTLY PERTINENT TO SESSION TOPIC
A. What is an Auxiliary Emission Control Device (AECD)? There is
not a good definition.
B. What are the essential items needed for durability selection?
C. Standardization and non-redundancy of data input, not only within
EPA but between other government agencies, would be desirable.
CONCLUSIONS
A. There is a need to develop a standard indexing system for the
application format.
B. There is a need to determine the differences between light-duty,
heavy-duty, and motorcycle which impact upon a common indexing system.
C. There is redundancy in the data submission requirements of the
various EPA programs.
D. Standard terminology is useful and necessary in the broad sense,
such as used in an indexing system, but it is not feasible on a
detailed level. A cross-reference dictionary may be useful.
E. When the format is revised, EPA should bear in mind that some manu-
facturers use it as a pre-printed format and this should be taken into
consideration whenever possible.
RECOMMENDATIONS
A. EPA should look at the requirements of the certification and fuel
economy programs to see where redundancy can be avoided and formats
can be standardized.
B. A task force should be organized to explore ways to implement the
ideas of standard indexing and terminology. The target of this task
force is to develop a plan which can be implemented in the 1980
model year application format.
1. A task force was organized consisting of the following people:
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Wllli Henny - Cunnniris
Merle Liskey - AMC
Dan Bonawitz - Toyota
Greg Dana - EPA
Bob Wilson - GM
Bill Kostin - Ford
John Thomson - EPA
2. It was decided that this task force would be combined with the
task force on referencing; both this task force and the task force on
sequencing will work together developing a plan to restructure the
application format using the ideas of this workshop with implemen-
tation planned for the 1980 model year.
Attachments
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INDEXING OF THE APPLICATION
W. HENNY
CUMMINS
DECEMBER 12, 1977
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BASE REQUIREMENTS OF INDEXING SYSTEM
. LOGICAL SYSTEM TO FACILITATE
REFERENCING.
, UNIVERSALLY ADAPTABLE SYSTEM
TO ACCOMMODATE LD, MD & HD
AS WELL AS VARIATIONS IN
PRODUCTS.
. PROVIDE FLEXIBILITY TO ADD,
MODIFY OR DELETE WITHOUT
DISTURBING REST OF SUBMISSION.
. ADAPTABLE TO COMPUTER.
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QNE TIME SUBMISSION
RABIJA
SECTION
I
TECHNICAL REPRESENTATIVES
SECTION
II
MAILING INFORMATION
SECTION
III
STATEMENT OF CONFIDENTIALITY
SECTION
IV
TEST FUELS
SECTION
V
FACILITY & TEST PROCEDURE DESCRIPTION
SECTION
VI
GENERAL TECHNICAL INFORMATION
SECTION
VII
TEST ENGINE MAINTENANCE
SECTION
VIII
ENGINE LABEL
SECTION
IX
DETAILED SPECIFICATIONS
SECTION
X
TEST DATA & ENGINEERING REPORTS
SECTION
XI
RUNNING CHANGES
SECTION
XII
AMENDMENTS
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PART General Description
SECTION Technical Information
SUBSECTION Fuel System
PARALLEL SUBSECTION
ITEM Injector Type D
PAGE
PARALLEL ITEM
X.
1.
X.
6.
X X A
1
X X. X X A
3. 0 1
2.
X.
1.
X,
0 S 2
X X X
7. 0 1
X X. X X
L
PAGE
^ITEM Piston & Rings
^FAMILY
'"SECTION Specifications
LPART
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PART 1
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SECTION 6 - TECHNICAL INFORMATION
General Engine Description 1.6. 1-0
Engine family group codes 1.6. 1-1.
Individual engine family codes 1 - 2.
Critical parts list (CPL) codes 1-3.
Common Specification
Fuel Rates 1.6. 2 - 1.
Compression ratio tolerances 2-2.
Horsepower and torque values 2-3.
Valve rocker arm ratio 2-4.
Emission Control Systems
Aneroid 1.6. 3 - 1.
Air/Fuel Control (AFC) 3-2.
AFC vs. aneroid - performance curves 3-3.
Air Signal Attenuator (ASA) 3-4.
Torque limiting system 3-5.
Torque limiting system - performance curves 3-6.
Fuel System - PT
General description 1.6. 4-1.
Fuel flow diagram 4-2.
PT (TYPE D) injector 4 - 3.01 & 02
PT (TYPE E) injector 4 - 3.01 & 02A
PT-G fuel pump fuel flow and governor 4 - 4.01 to 04
PTG-VS fuel pump fuel flow and governor 4 - 4.01 to 04A
PTG-VS road speed governor 4-5.
Injector differences 4-6.
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PART 2
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SECTION 1 - SPECIFICATIONS
Common Parameters 2. 1. 1
Engine groups 2.1. 1. 1
Block 2
Cylinder head 3
Intake valves 4
Exhaust valves 5
Valve stem & seal 6
Manifolds 7.1-4
Fuel System 8
Emission control system 9
Piston 10
Aftercooler 11
Individual Engine Family Specifications 2. 1.
Revisions 2. 1. x x x .1
Engine parameters .2
CPL's & top ratings .3
Flow curve .4
Injector description .5
Valve events .6
Piston rings .7
Change history .8
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2.1. 092 - 7.
PISTON, RINGS, COMBUSTION
CHAMBER
CPL CODES
0155
0187
0220
0270
0189
0217
Configuration
(See Page PII-I-15)
Fig. 1
Fig. 2
Fig. 2
Compression Ratio - - - -
¦ - 14.1
14.3
15.8
Surface to Volume Ratio -
8.2
9.9
11.7
Piston Material - - - - -
Aluminum
Aluminum
Dimensions: a (cleg) - ¦
23.5
33
33
A (in.) - ¦
3.367
3.210
3.298
B (in.) - ¦
3.762
3.777
3.777
C (in.) - ¦
1.400
1.390
1.315
D (in.) - ¦
.695
.530
.655
E (in.) - ¦
.328
.070
.060
F (in.) - ¦
________ Not Appl.
4.020
4.030
No. of Piston Rings - - ¦
4
4
4
Type: First
________ Keystone
Keystone
Keystone
Second ------
-------- Keystone
Keystone
Keystone
Third
________ Keystone
Keystone
Keystone
Oil
________ Grooved &
Expander
Grooved &
Expander
Grooved S
Expander
Matl: First ------
-------- Cast Iron,
Chrome
Cast Iron,
Chrome
Cast Iron,
Chrome
Second ------
Cast Iron
Cast Iron
Third ------
_ _ _ Cast Iron
Cast Iron
Cast Iron
Oil
Chrome
Cast Iron,
Chrome
Cast Iron,
Chrome
SUBMITTED MAY 9 1977
REVISION NO.
DATE
PAGE IS 0 SATISF ACTOR yQ UNSATISFACTORY
DATE EPA REP
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PT (TYPE D) INJECTOR
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1.6.4 - 3.01
Tv/o (2) different PT (TYPE D) - commonly called PTD - injectors are used:
. PTD "Standard" (see next page)
. PTD "Top Stop" (see next page)
The PTD "Top Stop" injector functions like the PTD "Standard" injector except
that the upward plunger travel is limited by a stop device which retains
the injector spring at a preloaded position. The details of the "Standard"
and of the "Top Stop" injectors are shown on the next page Via - 4a.4 The
lower portion of the "Standard" injector and the "Top Stop" injector are
identical. The injector cup, barrel and plunger which determine the
performance of the engine are unchanged.
Fuel Injection Cycle - PTD Injector
Metering
Fuel enters (9) the injector at low pressure as determined by the
throttle and/or governor. The metering orifice (10) controls the
quantity of fuel that enters the injector cup (1) at a pressure
determined by the fuel pump and the time interval during which this
metering orifice in the barrel (3) is uncovered by the injector
plunger (4).
Injection
When the plunger moves down fuel entry through the feed orifice in
the barrel is cut off. When the plunger continues down it forces fuel
out of the cup at high pressure through the injector spray holes as a
fine spray that permits complete burning of the fuel in the combustion
chamber.
Purging
As the plunger moves down the groove in the plunger connects the
feed orifice in the barrel to the scavenging orifice just above it
and fuel begins to flow through the return passage (16) to the fuel
tank. After injection the plunger remains seated until the next
metering and injection cycle, fuel flowing freely to cool the injector
and also warm the fuel in the tank. The timing of metering and
injection is determined by the engine camshaft and fixed for the
most efficient operation at all engine speeds.
SUBMITTED FED 3 \':J1
REVISION NO.
DATE
PAGE IS ~ SATISFACTORY ~ UNSATISFACTORY
DATE EPA REP
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PART II
PROPOSED INDEXING SYSTEM
General Section
Section I
Mailing Information
II - 1.1
Section II
Statement of Compliance
- 2.1
Section III
Training & Special Tools
- 3.1
Family Section
Section I
Deterioration Factor II -
(Family) - 1.1
Section II
Official Values
- 2.1
Section III
Models Covered
- 3.1
Section IV
Durability-Data Vehicle Logs
- 1.1
Section V
Emission-Data Vehicle Logs
- 5.1
Section VI
Label
- 6.1
Section VII
Maintenance
- 7.1
Section VIII
Part Numbers & Production Checks
- 8.1
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Emissions Terminology and
Nomenclature—SAE J1145a
SAE Recommended Practice
Last revised October 1977
THIS IS A PREPRINT AND WILL
APPEAR IN THE 1979 EDITION
OF THE SAE HANDBOOK
Society of Automotive Engineers. Inc.
400 COMMQNWIALTH ONIVI, WARftCNOAtl. M 19091
PREPRINT
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EMISSIONS TERMINOLOGY AND
NOMENCLATURE-SAE J1145a SAE Recommended Practice
1
Report of Automotive Emissions Committee approved August 1976 md tat revised October 1977.
/. Purpose—This SA£ Recommended Practice wu prepared 10 standardize
terminology and nomenclature in order to facilitate clearer undemanding for
engineering discussions, comparisons, and the preparation of technical papers.
2. Scopi—Thu recommended practice applies to nomenclature of emissions
and emissions reduction apparatus as applied to various engine* and vehicles
Modifying adjectives are omitted in some cases for the sake of simplicity.
However, it is considered good pract.ee to use such adjectives when they add
to clarity and understanding.
3. Auxiliary Air SjtUmt
3.1 Air Distribution Manifold—The manifolding which distributes and
proportions air to the individual exhaust pom Note. The manifolding may
consist of external tubing or integral passageways.
3.2 Air Pump Diverter Valve-A valve which interrupts the delivery of
air to the exhaust pons—typically during vehicle deceleration in order to
prevent engine backfires.
3.3 Air Injection Tube—A tube in the exhaust manifold or cylinder head
which directs injected air from the air distribution manifold to the vicinity of
the exhaust valve
3.4 Air Injection Relief Valve—A pressure relief valve, usually integral
with the air pump or air pump diverter val\e, which limits the maximum
delivery pressure of the injected air
3.5 Bypass Valve—Use Air Pump Diverter Valve
3.6 Gulp Valve—A valve that briefly admiu a metered Row of air to the
intake manifold after a sudden closure of the throttle Note This prevents an
over-rich mixture being caused when high vacuum evaporates liquid fuel in
the manifold
3.7 Pulsating Air System-A system which uses sub-ambient pressure
pulses in the exhaust system to introduce ambient air into the exhaust sys-
tem for the purpose of oxidizing HC and CO.
4. Catalytic Systems
4.1 Ease Metal Catalyst—A catalyst in which the active catalvtic mate*
rial b one or more non-noble metals such as copper or chromium
4.2 Catalyst-A substance which accelerates a chemical reaction but
which itself undergoes no permanent chemical change. Note' For automo-
tive emission control applications, catalysts are classified as oxidation cata-
lysts (oxidizes HCand CO), reduction catalysts (reduces NOx), or three-way
catalysts (oxidires HC and CO and reduces NOx simultaneously).
4J Catalyst Poisoning—The deterioration of catalyst efficiency when
foreign materials—such as lead, phosphorus, or sulfur—are introduced to the
catalytic convener, lessening or eliminating the chemical action of the cata*
lysis on the exhaust pollutants
4.4 Catalytic Convener—An aasemblv, including such major compo-
nents as a structural shell, substrate, and the catalyst matenal. Depending on
the type of catalyst—oxidation, reduction, or dual—this assembly decreases
HC and CO emissions, or NOf emissions, or all three of these exhaust pollu-
tants.
4.5 Caulyvt Assembly—Use Catalytic Convener
4<6 Catalytic Efficiency-Use Conversion Efficiency.
4.7 Conversion Efficiency-The percentage of a given exhaust constit-
uent that is changed into chemically different speaesas a result of the oper-
ation of the convenor.
4.8 Convener Bypass—A method for routing exhaust gas around a
catalytic converter—tvpically to prevent convener damage due to excessively
high operating temperatures
4JJ Ouaf-CataJysi Svttem—A system that uses two catalyst beds, one
oxidation and one reduction, to decrease the HC. CO, and NOa pollutants in
the engine exhaust These two beds may be packaged together or in two
separate containers
4.10 Ught-OfT Temper* ture-The temperature at which the conversion
efficiency teaches a given value.
4.11 Monolithic Substrate—A unitary catalyst substrate usually of hon-
eycomb structure
4.13 Noble Metal Catalyst—A catalyst in which the active matenal is
made from a precious metal such as platinum, palladium, rhodium, or ruthe-
nium
4.13 Oxidation Catalyst—A catalvst that promotes the oxidation of HC
and CO to form water vapor and carbon dioxide
4.14 Pelleted Substrate—A catalyst substrate having such forma as peb-
bles, beads, small cylinders, or small spheres.
Tb« 0 symbol b for the convenience of the user in locating areas wtitre
tachnlcaj revisions have been made to the previous issue of the report.
If th» symbol Is next to the report title, it indicates • complete revuioo
of the report.
4.15 Rare Eanh Catalyst—A catalvst in which the active material is a
rare eanh element such a* lanthanum and cerium Not* The rare eanh
elements range in atemic number from 57 to 7|
4.16 Reduction Catalvst—A catalvst that promotes the chemical redue-
tion of nitrogen oxide» i\0,i b\ reaction with carbon monoxide (CO), free
hydrogen (H3) or hydrocarbon (HC) The desired products of the chemical
reaction are nitrogen gas. carbon dioxide, and water
4.17 Stmuiuneouj Oxidation Reduction CiuJyir-Use Th/ee-Way
Catalyst.
4.18 Space Velocity—The exhaust flow in ftVh fmVs), measured at
standard temperature and pressure, divided by the catalyst volume in ft3 (mJj
equals the space velocity
4.19 Substrate—A thermally stable material, usuallv catalyticallv inen.
to which the active catalyst is affixed, imbedded, or in some other way joined.
Pellets and monolith represent two physical forms of substrate.
4.20 Three-Way CataJyst-A catalyst that simultaneously oxidizes HC
and CO and reduces NOx exhaust emissions. Note: For maximum conver-
sion efficiencies, the engine must operate over a very narrow range of air-
fuel ratios near stoichiometric conditions.
4.21 Wuhcoai—A matenal applied to the substrate by the catalvit
manufacturer to prov.de increased surface area for depositing the catalvst
5. Qtewutal Terms
5.1 Aldehyde—A class of chemical compounds having the general for-
mula RCHO. where R is an alkyl (aliphatic) or aryl (aromatic) radical
5.2 Aromarici—A hydrocarbon having a ring-type structure with the
general formula C1H;> — 6 and containing three double bonds in the nn^
5.3 Methane—A hydrocarbon represented by the chemical formula CH«.
5.4 Naphthenes (Cycloparaffins)—A hydrocarbon having a nng-ttpe
structure with only single bonds between the carbon atoms.
5.5 Olefin—A hydrocarbon having a chain s:ructurt with one or more
double bonds between two of the carbon atoms. The general formula ts
C«H*
5.6 Oxides of Nitrogen (NO,)—The sum total of the nitric oxide and
nitrogen dioxide in a sample expressed as nitrogen dioxide.
3.7 Paraffin—A hydrocarbon having a chain structure, and the general
formula CaH,a"r2.
5J Polynuclear Aromatic Hvdrocarboas (PNA)—Relatively high mo-
lecular weight compounds svnthesiztd in all combustion processes Thev
consist of three or more fused carboevclic nngs, each of which contains five or
six carbons. BeruofajDyrrne has often been measured as an index to the total
and was chosen because it is a potent carcinogen
5.9 Stoichiometnc-The exact proportions of substances for a specific
chemical reaction that will combine with no excess of any reactant. Note
An example is the ratio of air and hydrocarbon fuel which ideally combines
to form only Nj. COi. and H2O.
5.10 Suifate-An ion having the formula SO4. Note: Exhaust con-
stituents including SO3, H1SO4, and some metallic sulfates, are measured
as sulfate too and hence are referred to as sulfate emissions.
5.11 Zero Grade Air (Air Zero Gaj)-Aii containing less than 1 ppm
hydrocarbon on a methane equivalence basis. 1 ppm carbon monoxide,
400 ppm carbon dioxide, and 0.1 ppm nitnc oxide. Note: This gas is nor-
mally used to zero hydrocarbon analyzers and may also be used to zero
analyzers for carbon monoxide, carbon dioxide, and oxides of nitrogen. It
should not be used to zero analyzers measuring at or neaz ambient concen-
tration of carbon dioxide.
& £nft»# Hardrnmn
6.1 Air Cap Pipes—Double walled exhaust pipes with either an annular
air space or other insulating matenal between two basically concentnc pipes.
6J2 Air-Fuel Ratio Control Device—A device which limits the amount of
fuel to that which can be burned with the air available during acceleration of
a turbocharged diesel engine.
6.3 And-Diesel Device—A device to close the throttle further or block
the idle fuel within the carburetor when the ignition u turned off
6.4 Break cries* Ignition System—A system which differs principally
from a conventional ignition system in the following two wavs. First, the
conventional cam and breaker points are replaced by a pulae generator
Second, a solid state electronic device uses the pulse generator signal to switch
ignition coil pnrnary current on and off.
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-23-
2
63 Carburetor Deceleration Combustion Control Valve—Use Fuel
Decel Valve
6.6 Closed»Loop Control—Use Feedback System for Controlling Air*
Fuel Ratios.
6.7 Coolant Override Valve—Use ThrrmaJ Vacuum Switch.
6.8 Deceleration Spark Advance Control-—A device that advances spark
timing during deceleration conditions.
6.9 Deceleration Throttle Modulator—A device %»hich regulates the rate
of closure of the carburetor throttle.
6.10 Dual Diaphragm Distributor—A distributor with two vacuum dia-
phragms which can either advance or retard spark timing depending on the
vacuum signals applied to it None Spa-k is olten retarded at idle and during
deceleration for emission control but advanced for pan-throttle fuel economy.
6.11 Electronic lgruoon System—Use Breakeriess Ignition System
6.12 Exhaust Gas Recirculation (EGR)—A syitem which returns a
portion of the exhaust gases to the combustion chamber. The lower combus-
tion temperatures in turn reduce the formation of oxides and nitrogen.
6.13 EGR Control Valve—The valve which controls the amount of
recirculated exhaust gas entenng the engine induction system.
6.14 EGR Vacuum Port—The carburetor port or opening from which
vacuum to control the EGR system is sensed.
6.13 Exhaust Port Liner—A sheet metal or ceramic component inserted
in the exhaust ports for the purpose of reducing heat losses from the exhaust
gas.
6.16 Feedback System for Controlling Air-Fuel Ratios - A system which
uses feedback signal generated from an exhaust gas sensor to control the
air-fuel ratio of the combustion mixture.
6.17 Fuel Decel Valve—A valve which uses engine vacuum dunng de-
celeration to either open the throttle slightly or to meter an additional amount
of air-Fuel mixture from the carburetor around the closed throttle blades,
thereby providing more complete combustion.
6.18 Heat Shield—A device, usually a sheet metal shield, placed adja-
cent to a high temperature component (exhaust syitem) to protect the sur*
rounding environment.
6.19 Insulated Pipes -Use Air Gap Pipes
6J0 Lean Reactor-A thermal reactor system that typically operates
at air-fuel ratios leaner than stoichiometnc.
6.21 Positive Crankcase Ventilation (PCV)—A system which routes
gases from the crankcase (blowby and air) to the air induction system of the
engine
6£2 PCV Valve—A valve that regulates the flow of gases from the
crankcase into the intake manifold
6.23 Proportional Exhaust Gas Recirculation—An EGR system at-
signed to recirculate a fixed percentage (based on engine air flow) of the
exhaust gas.
6£4 Quick-Acting Cboke—An clecincal or mechanically operated de-
vice designed to shorten the chobng period dunng engine start-up.
6.23 Quick-Heat Intake Manifold—An exhaust-heated intake manifold
having relatively large crossover passages and. Typically, a thin sheet metal
section in the plenum floor. Nott The sheet metal floor may have fins,
convolutions or similar means to obtain a high rate of heat transfer between
the crossover exhaust and the intake charge. The objective of these manifolds
is to provide rapid intake mixture warmup by promoting evaporation of fuel
droplets
6£6 Reactor Liner—A sheet metaJ or ceramic component inserted in the
thermal reactor for the purpose of reducing heat losses from the exhaust gas.
6.27 Rich Reactor-A thermal reactor system that typically operates
la the range of aii-fuel ratios richer than stoichiometric.
629 Spark Advance—The number of degrees before top dead center at
which the spark discharge occurs.
8£9 Spark Delay Device—Calibrated restnetor in the vacuum advance
hose which delavs the vacuum spark advance
630 Spark Port—The carburetor port from which vacuum to control the
distributor spark advance is sensed.
.. 631 Speed Controlled Spark—A svstem. generally used with an auto-
matic transmission, that controls the vacuum to the disinbutor preventing
vacuum advance below a selected vehicle speed.
6J2 Steve—The portion of the intake manifold which is heated by
exhaust gases. Non This term may also denote a svstem which heats carbu-
retor inlet air by passing it over the exhaust manifold. May also denote a heat
exchanger that supplies hot air to the bimetal coil of an automatic choke
(choke stove)
633 Temperature Modulated Air Cleaner—An inlet air ivsiem, usually
consisting of a stove, tubes, and control valve, for controlling the temperature
of thp air entenng the carburetor within a specified range.
634 Thermal Reactor—An enlarged exhaust manifold ¦¦often with in-
terior flow passages and/or insulation—thai permits the combustion process
to continue after the exhaust gases leave the engine combustion chambers
Note The reactor retain* (he exhaust gases at a high temperature for the time
required to oxidize HC and CO
6.33 Thermal Vacuum Switch—A coolant temperature sensing vacuum
control valve which modulates distributor and EGR vacuum to increase spark
advance either ai an override or protection device
6.36 Transmission Regulated Spark—Use Transmission Spark Control
Valve
637 Transmission Spark Control Valve—A valve that routes manifold
vacuum to the distributor advance unit only when transmission is operating in
one or more specific drive gear ratios
6.38 Vacuum Control Valve—Use Thermal Vacuum Switch.
6.39 Venturi Vacuum Amplifier—A device which amplifies carburetor
ventun vacuum in order to modulate manifold vacuum to control the EGR
valve.
7. Exhaust Emutioru
7.1 Black Smoke—Particles composed of carbon (soot), usually (ess than
1 ftm in sue, which have escaped the engine's combustion process.
7.2 Brake Specific EraiMioos— Mass (grams or pounds) of pollutant
emitted per brake horsepower hour.
7.3 Diesel Smoke—Panicles, including aerosols, suspended in the en-
gine's gaseous exhaust stream which obscure, reflect, and/or refract light.
7.4 Emission Index—Grams of pollutant emitted per kilogram of fuel
burned.
73 Exhaust Emissions—Any substance (but normally limited to pollu-
tants) emitted to the atmosphere frum any opening downstream from the
exhaust port of the combustion chamber of an engine.
7.6 Parts per Million Carbon (ppmC)—The mole fraction times 10* of
hydrocarbon measured on a methane equivalence basis.
7.7 White and Blue Smoke—Panicles composed of essentially colorless
liquid (droplets) which reflect and refract the observed light Note The
observed color results from the refractive index of the liquid in the croplets
and the droplet size. White smoke is usually due to condensed water vapor or
liquid fuel droplets. Blue smoke u usually due to droplets resulting from the
incomplete burning of fuel or lubricating oiL
& Eveporxitiat Ewtunom
_ 8.1 Carbon Canister for Evaporative Emissions—A component of an
evaporative control system which is used to collect and store evaporative
hydrocarbon emissions from the fuel tank and/or carburetor
8.2 Charcoal Canister—Use Caibon Canister for Evaporative Emissions.
8.3 Diurnal Breathing Lasses—Fuel vapors emitted dunng the con-
trolled increase in fuel tank temperature. Nots- This temperature increase
simulates the dailv range of ambient temperatures which fuel tanks expenence
in service.
8.4 Evaporative Emissions—Fuel vapors emitted into the atmosphere
from the fuel syitem, that is. gas tank, carburetor, etc, of the vehicle
83 Fuel Tank Check Valve—A mechanical device at the fuel tank
which prevents liquid fuel from entering the evaporative storage svstem
8.6 Hot Soak Losses—Fuel vapon emitted during a specified period
beginning immediately after the engine is turned off.
8.7 Purge Valve—A vacuum or electrically actuated device in the evap-
orative emission control system used to release entrapped hydrocarbons (o the
engine induction system.
8.6 Refueling Emissions—Hydrocarbon emissions that can occur dunng
filling of the vehicle fuel tank. Non- These emissions are made up of dis-
placed fuel tank vapor, entrained droplets in this vapor, liquid spillage, and
nozxle dnp dunng insertion and removal of the nozzle from the hller neck.
8.9 Running Losses—Fuel vapors emitted during operation of tne vehi-
cle under the specified test schedule
8.10 Vapor Canister—Use Carbon Canister for Evaporative Emissions.
8.11 Vapor Separator—A trap in the evaporative emission control system
to prevent liquid fuel from passing into the vapor storage device
9. Futi Sjitmi
9.1 Filler Tube Restrict or—A device in the fuel tank filler pipe that will
only admit a smail diameter fuel filler nozzle dispensing non-leaded fuel.
9.2 Fuel Filler £ap—The cap on the fuel filler tube which normally
provides a^xmuve seal and may contain relief valves for pressure and vacuum
venting
9 J Fuel System-The combination of fuel tank, fuel tines, pump, fil-
ter, and vapor return lines, carburetor or injection components, and all fuel
system vents and rvaporatnre emission control systems or devices.
tO. CfivrW _
10.1 Curb Weighl-The weight of the vehicle in operational status with
aD standard equipment, the weight of fuel at nominal tanlr capacity, and
the weight of optional equipment.
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-24-
10.2 Dies*! Engine—Any compression ignition internal combustion en*
gine, using the basic diesel cycle, thai is. combustion results from the spraying
of fuel into air heated bv compression
10J Gas Turbine Engine—Any engine using the basic gas turbine or
Brayton cycle consisting of adiabatic compression, constant pressure heating,
and adiabatic expansion
10.4 Cross Vehicle Weight (gvw)—The manufacturer's gross weight
rating, consisting of the curb weight plus pay load
10.5 Heavy Duty Engine—Any engine which the engine manufacturer
could reasonably expect to be used for mouve power in a heavy-dutv vehicle
10.6 Heavy-Duty Vehicle—Any motor vehicle designed primarily for
transportation of property and rated at more than G000 lb (2722 kg) gvw or
designed primarily for transportation of persons and having a capacity of more
than 12 persons
10.7 Light-Duty Vehicle—A motor vehicle having a rating of €000 lb
(2722 kg) gvw or less and designed primarily for the transportation of persons
on a street or highway and having a capacitv of 12 persons or less.
10.8 Light-Duty Truck—A motor vehicle having a rating of 60001b
(2722 kg) gvw or less and designed primarily for the transportation of properiv
or designed for ofTstreet or otrhighwav use
10.9 Loaded Vehicle Weight—The manufacturer's estimated weight of a
vehicle in operating condition For the purpose of emission testing, it is the
curb weight of a light-duty vehicle plus J00 lb (136 kg)
10.10 Spark Ignition Engine-Any internal combustion engine using
the basic Otto cycle, with combustion initiated by in electric spark.
II. Tut Procfdurt and Fquipmmt
11.1 Analytical Train—The entire system required to obtain and analyse
a particular constituent in exhaust gas Typically, this tram will include such
items as sample piping, paniculate filter, condenser, sample pump, analytical
instrument, and flow meter.
11.2 fiatcb or Grab Sample—A sample taken in a sealed springe over a
short period of time for a composite analvsis
11.3 Beer-Lambert Law—For purposes of diesel smoke measurement, an
equation expressing the relationship between the opacitv of a smoke plume,
the optical path length through the plume, and the opacity of the smoke per
unit path length, may be used
Opacity = I - e_CL
where:
e — base of natural logarithms
K = attenuation (or extinction') coefficient
L = path length through the smoke, in
11.4 Calibrating Gas—Gas of known concentration used to establish
instrument response.
1IJ Chassis Dynamometer—A laboratory power absorption unit capa-
ble of simulating to a limited degree the road operation of a vehicle. The
dynamometer possesses the capability to simulate the inertia and road-load
power developed by a vehicle.
11.6 Chcmilurainescem Analyzer—An instrument in which the intensity
of light produced by the chemtluminescence of the reaction a proportional to
the concentration of the component analyzed, as with the reaction of nitnc
oxide and ozone.
11.7 Constant Volume Sampling—A technique for sampling exhaust gas
in which a sampling pump draws a constant volume flow rate This flow is
provided from both the exhaust of a vehicle and from dilution air Note The
technique allows for monitoring of continuous emissions on a mass basts and
also (with the addition of a second pump) provides an aggregate total mass
sample from a vehicle operated through an entire test evele
11.8 Detector—That component in an analytical instrument which re-
sponds to a particular exhaust gas constituent.
11.9 Driver Aid—An instrument intended to guide the vehicle driver in
operating the vehicle in accordance with thr acceleration, deceleration, and
cruise operating modes of a ipecific driving procedure
11.10 Dynamic or Continuous Sampling—A technique in which a por-
tion of the exhaust is continuously withdrawn and pumped through an
analytical train.
11.11 Fitter Cell—Thai portion of the NDIR instrument which is filled
with a particular gas in order to reduce interference signals
11.12 Flame Ionization Defector (f ID)—A hydrogen-air diffusion flame
detector that produces a signal proportional to the man flow rate of hydrocar-
bons entering the flame per unit time
11.13 Gas Chroraatogram—The recorder output versus time of a detec-
tor signal from a gas chromatograph. which shows deflections to indicate, for
example, the pretence of individual hydrocarbons
11.14 Hang-Up—A term to descube the phenomena whereby higher
pokcular weight hydrocarbons are retained in the sample train, causing an
3
initial low analvrer reading, followed bv higher reading* in lutxequent icsts.
Excessive hangup causes errors in ih: anaktts of the hydrocarbons in exhaust
8"
11.15 Cm Chromatograph-An instrument commonly used (o detect
individual gases m complex gaseous mixtures. Note: In automobile ex*
haust gas analysis such instruments can be used to separate and determine
the concentration of individual hydrocarbon species in a complex hydro-
carbon mixture.
11.16 Hexane Equivalent Concentration (ppm hexane)—The concen-
tration of a propane calibrating eai in terms of its hexane eqimaleni concen-
tration For NDIR. hexane equivalent concentration has been established as
propane concentiation times 0 52. For FID. hexane equivalent concentration
equals propane concentration times 0 50
11.1? Idle Speed—The engine's Ioh idle speed as specified by the manu-
facturer
11.18 Inertia Weights—A series of weights on a chassis dynamometer
used to simulate the test weight of a vehicle
11.19 Intermediate Speed—The peak torque speed or 60s? of the rated
speed, whichever is higher.
11.20 Mode—A particular event (for example, acceleration, deceleration,
cruise, or idle) of a vehicle test cvele.
11.21 Nondispersive Infrared (NDIR)—Electromagnetic radiation used
as the light source in NDIR instrument capable of measunng CO. COz, NO.
and unburned hvdrocarbons in eAhaust cis
11.22 Nondivpersive Ultraviolet (NDLiV)—Electromagnetic radiation
used as the light source in NDL'V instruments capable of measuring NOj
concentrations in exhaust gas.
11.23 Non-Methane Hydrocarbons (NMHC)—All organic hydrocarbon
compounds, excluding rr.ethane. present in an exhaust samnie
11.24 Smoke Opacimeter—An optical instrument designed to measure
the opacity of diesel exhaust gases. The full flow of exhaust gases passes
through the optical unit. One such smoke opacimeter ii described in S.AE
J255
11.25 Span Gas—A single calibrating gas blend routinely used in cali-
bration of an instrument such as those used for detecting hydrocarbons,
carbon monoxide, and nunc oxide
11.26 Steady-State Condition—An engine operating condition at a con-
stant speed and load and at stabilised temperatures and pressures.
1IJ7 Opacity—The fraction of light transmitted from a source which a
prevented from reaching the observer or instrument receiver, in percent
(Opacity = (I — Transmittance] X 100)
I1J8 Photographic Smoke Measurement—A measurement technique
which relies upon an instrumental or visual comparison of the photograpnic
image of a smoke plume with an established scale of blackness or opacitv to
determine (he opacitv of the original smoke plume
11.29 Probe—A device inserted into some portion of an eneine or vehicle
system in order to obtain a representative gas or liquid sample
11.30 Proportional Sampling—A method of obtaining a composite sam-
ple of exhaust gas representative of all driving modes in a test evele This
sample, when analvzed. will represent the average molar concentration of a
constituent properiv weighted for mass flow rates.
1131 Rated Power—The maximum brake power output of an engine, in
honepower or kilowatts, as stated bv the manufacturer
11.32 Rated Speed—The engine speed at which the manufacturer speci-
fies the rated brake power of an engine
11.33 Rated Torque—The maximum torque produced by an engine, as
stated bv the manufacturer.
11.34 Reid Vapor Pressure—The vapor pressure of gasoline at 100'F
(37 8*C) determined in a special bomb in the presence of a volume of air
which occupies four times the volume of liquid fuel (ASTM procedure D 3231
11J5 Reference Cell—That portion of the NDIR instrument which
provides the reference signal to the detector
11.36 Resolution—The minimum distinguishable reading, for a given
(race width and scale combination, expressed as a percent of full-scale
11.37 Sample Cell—That portion of the NDIR instrument which con-
tains the sample gas being analyzed
I US Sampling—The technique of obtaining an accurate sample of
exhaust gas for analysis Sampling mav be grab, continuous, or proportional.
11.39 Test Cyde— A sequence of an engine or vehicle operating modes
usually designed to simulate read usage of the vehicle.
1M0 Test Fuel—A fuel for use in a given test and having specific
chemical and physical properties required for that test
11.41 Trans minawe—That fraction of light transmitted from a sourer,
through a smoke-obscured path, which reaches the observer or instrument
receiver.
-------
-25-
(Opacity \
Transmittancc s 1 —)
100 /
11.42 Variable Dilution Sampling—Use Constant Volume Sampling.
11.43 \ariible Rate Sampling—A technique to obta:n an exhjutt sam-
ple which lakes a specific and constant fraction (for example, 1/1000) of the
total exhaust stream at each mode so that when the acqregate sample a
analyzed for its molar constituents, it is weighted in proportion to the avtiA^e
flow fate through the cycle.
11.44 Visual Smoke Measurement—A measurement technique which
rrlm upon human observation of an engine's smoke plume to rate '.hat
pluine's appearance against an established scale of blackness or opacity (usu-
ally a gray scale on eitrter a transparent or opaque white base
-------
-26-
STANDARD NOMENCLATURE FOR 1978
EMISSION TEST LOGS
Initial Certification
O-K
4K
4K HWFET
4K EPA
4K EPA (OFFICIAL)
4K EPA HWFET
4K EPA RETEST - COMMENT (i.e. F.E. 10% out)
4K EPA HWFET RETEST - COMMENT
4K CONF. TEST
4K CANADIAN
4K CANADIAN HWFET
*Running Change or Post Certification
B/L R/C DISP-# (i.e. 302-21T)
F/L R/C DISP-# Fix # (if multiple fixes in R/C)
CANADIAN B/L R7C DISP-#
CANADIAN F/L R/C DISP-#
EPA F/L R/C DISP-#
EPA HWFET F/L~R7C DISP-#
CVS-CH TEST
Note: All EPA Tests should include EPA Test # (i.e. EPA Test
Number 78-5344)
~Mileage is not to be included in remarks concerning post-
initial cert, testing.
SHED TESTS
1978 SHED D.F. TEST
(4K HARDWARE)
1978 SHED D.F. TEST
(5OK HARDWARE)
1978 SHED D.F. TEST
(SLAVE HARDWARE)
HWFET
VOID TEST // EXPLANATION
-------
-27-
STANDARD NOMENCLATURE FOR 1978
Void Tests
Void Tests should carry the usual remark followed by the
word "Void" and an explanation (i.e. 4K EPA HWFET - Void //
Vehicle prepped at wrong H.P.)
Fuel Economy Data Vehicles (FEDV)
City F.E. Test
HWFET
EPA City F.E. Test
EPA HWFET
Note: All EPA Tests should include EPA Test #
(i.e. EPA Test Number 78-5166)
Retests or Voids should be handled in the
same way as initial cert, tests.
Durability Vehicle Tests
0-K
"X"K where "X" equals the test mileage as given on the
Sigma-3 or TC-8 (i.e. 5,10,15,20,etc.)
Tests before or after scheduled maintenance should be
entered as follows:
30K B/4 Sched. Maint.
30K Aft. Sched. Maint.
Tests before or after unscheduled maintenance should be
entered as follows:
21K B/4 Unsched. Maint. - Appr./EPA Name Date
21K Aft. Unsched. Maint.- Appr./EPA Name Date
Tests required at EPA should be entered as follows:
50K EPA
Confirmation Tests should be entered as follows:
50K Conf.
Revised: 12-1-77
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-28-
EPA-INDUSTRY WORKSHOP ON
CERTIFICATION PAPERV7QRK REDUCTION
December 12, 13, and 14, 1977
DECEMBER 13
Session I
Sequenced Submission of the Standard
Application for Certification
Chairperson: Virginia Sink, Chrysler
EPA Contact: B. Patok
CONCLUSION
It was agreed that the concept of a sequenced submission
of the application for certification in very desireable to
reduce paperwork, redundancy, and expenditure of time. How-
ever, agreement was not reached on the specific information
required at each sequencing step, expecially that needed for
emission data fleet selection since final calibrations are
not available at the time when selection is made.
A Task Force on Sequencing was established to recommend
the items needed at each step. A detailed recommended format
will be submitted to the Indexing and Referencing Tast Force
at its meeting on January 10, 1978 for consolidation.
PROBLEM IDENTIFICATION
- Repeated submission of information common to all
applications.
- Duplication of information in Parts I & II.
- Duplication of information in Part I and Zero Mile
Books.
- Late start on durability vehicles jeopardizing time-
lines of Job tfl with emission data vehicle calibrations
being developed against unknown deterioration factors.
RECOMMENDATIONS
A Task Force on Sequencing was appointed which will supply
its report to the Tast Force on Indexing and Referencing before
its meeting on Janualy 10, 1978. The results of these task
forces considerations should result in a proposed detailed
format with a definition of referencing and index requirements
which should be implemented as soon as feasible.
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-29-
EPA-INDUSTRY WORKSHOP ON
CERTIFICATION PAPERWORK REDUCTION
DECEMBER 13 (Cont'd.)
PAPERWORK REDUCTIONS IDEAS FROM SESSIONS
(Short term for immediate paperwork reduction)
Eliminate request for duplicate information in Parts I
& II and zero mile books (i.e., part numbers, sketches,
vehicle logs, engineering evaluations, etc.).
Permit referenceing between applications.
• Define in a more formal fashion the fleet selection
criteria such that the manufacturer can select his own
durability and data vehicle fleets.
. Submit the Part I information sequencially to allow
fleet selection before all calibration information is known
in detail and to avoid large/many updates.
(Long term for paperwork reduction)
Establish a new method to prove durability.
Use broader family definition to reduce the number of
50K certification vehicles.
-------
-30-
SEQUENCING
OF THE
APPLICATION FORMAT
FOR CERTIFICATION
October 16, 197 7
Mobile Source Air Pollution Control
Certification Division
Proposal
-------
-31-
PROBLEM:
Application format as presently composed does not give
sufficient guidance to manufacturers for an orderly
submission. Certification personnel sifts through huge
amounts of paper to detect deficiencies, categorizes them
and notifies the manufacturer. This procedure has been
found to be inefficient with respect to review time and
manpower. Present format not suited for computerization.
RECOMMENDATION:
Develop the format into a tool with which any manufac-
turer may work his way through the certification process
in an orderly step by step progression. Organize the
format subject matter into sequential building blocks
leading to certification. Each such section will tell
the manufacturer precisely what information he must sub-
mit and for what specific approval purpose. This will
encourage manufacturers to concentrate their efforts and
resources on the one specific section which hinders the
progression because of missing information. A manufac-
turer, nevertheless, may submit any partial information
for any section at anytime, but he wfll know himself,
without EPA notification, in what areas he is deficient
and what else he must do to progress.
For the purpose of computerization a rigid format is
essential and it must be followed precisely by each app-
licant. The "Sequenced Application Format" meets this
requirement as well.
An organizational breakdown based on the 1979 Format has
been prepared and is attached.
- 1 -
-------
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-------
-33-
CERTIFI CATION - NORMAL PROGRESSION
- 3 -
-------
-34-
No Section:
(Formerly: Introduction, General Instructions,
Sections XI, XII, XIV)
Introduction
General Instructions (Note: 2 copies of application required,
one for MSED).
Elements from Fleet Letter
Fuel Filler Inlet
Data Reporting Procedures
Telephone Log
P.12: Revision cover letter required for revision, including
taped revisions.
Disposition: Put in letter to manufacturers, A/C.
R-avise to include ref. to computerization.
- 4 -
-------
-35-
Section 1.
General Information
(Formerly: Part I Application, Sections I, III)
Model Year
Manufacturer's Name
Kind of Application (LDV, etc.)
Standards to comply with
Mailing Address
Technical Representatives' Names, Phone Numbers, (U.S. Importer's
Name).
Chain of Command*
Statement of Business Confidentiality
Disposition: Tape compatible, except chain of command.
^Flagged O.K. for later submission.
- 5 -
-------
-36-
Section 2.
Durability-Data Vehicle Selection
(Formerly: Sections VI minus non-essentials,
Sections VII a&b, IXa, XIII)
(Note: Emission-Data Vehicle Selection at
Manufacturers Special Request, See Section 5.)
Elements from Fleet Letter ("add." vehicles, multiple
engine families)
Exhaust Family Discriminators, Specific (EPA list)
Exhaust Family Discriminators, "may be" (EPA list)
Exhaust System Discriminators, (EPA list)
Exhaust Sub-System Discriminators (EPA list)
Fuel Systems
Evap. Family Discriminators (EPA list)
Evap. System Discriminators (EPA list)
AECDs
Exhaust Family Sales
Evap Family Sales
Vehicle Description, Sales, Displacement, etc.
Maintenance Schedules
Emission Control System Descriptions
Graphics, as Required
Exhaust Family Names
Evap Family Names
Disposition: EPA durability-data vehicles selected, go to: Paper
& tape (Pt 17), tape compatible (except graphics?),
program vehicle books to Part II (i.e., Section 7)
- 6 -
-------
Section 3.
Testing Approval
(Formerly: Sections IV, VE & C)
Elements from Fleet Letter ("Zero-Miles" requirement)
Fuel Analysis
Test Equipment and Procedures, Exh. & Evap.
Starting Instructions
Shifting Instructions
Dyno H.P.: Durability
-Emission-Data (Ref. Section 5)
Disposition: On tape and Fuel analysis tn comparator
-neciuired prior to Section 5.
-------
-38-
Section 4.
Mileage Accumulation Approval
(Formerly: Section VA)
Elements from Fleet Letter
Mileage Accumulation Roijte
and/or
Mileage Accumulation Dynamometer
Disposition: Route on tape, Dynamometer on paper
-------
-39-
Section 5.
Emission-Data Vehicle Selection
(Formerly: Sections VI Minus Durability Parameters,
Vill)
Elements from Fleet Letter (p.3-engine/evap code etc.)
Exhaust Family Parameters (Minus Discriminn(;ors, ref. Section ^!)
Exhaust System Parameters (Minus Discriminators, ref. Section 2.)
Evap Family Parameters (Minus Discriminators, ref. Section 2)
Evap Systems Parameters (Minus Discriminators, ref. Section 2)
Graphics as Required
Engine Codes (Calibrations)
Evap Codes (C il ibrations)
AECDs (Calibrations)
Optional Equipment
Dispos i.tion:
On tape (except grapli i cs ?), A-veh Lcle selection
program, emission-data vehicle selection on paper
& i ape (l't II), vehicl«: boohs to Part II (i.e., 1)
- 9 -
-------
Section 6.
Reserved
-------
-41-
Section 7.
Certification
(Formerly: Pt. II Application Sections I, II, IIIA,
IIIB, IV, V, VI, and New Information)
* EPA Durability-Data Fleet (new) (ref. Section 2)
* EPA Emission-Data Fleet (new) (ref. Section 5)
**Vehicle Books (new)
Carryover Information
Maintenance Log, including unscheduled (Note: Data bank for
concurrent reporting)
Engineering Reports (Data bank for concurrent reporting)
Remainders as Presently Specified in Pt II
Certificatey Information (new)
Disposition: All on tape, except engineering reports
*Compare tapes
**Referenced information
- 11 -
-------
-42-
December 12, 1977
EPA Industry Workshop on Certification Paperwork Reduction
III. Sequenced Submission of the Standard Application for Certification
Background
EPA has accurately described in the topic discussion attachment of the 11/16/77
Harrington letter what is probably the greatest concern/highest jeopardy pro-
blem in the current certification process; the inability to get durability
data vehicles approved to begin mileage accumulation in a timely manner, such
that Job #1 is not jeopardized. The resultant late start in 50K mileage ac-
cumulation requires that UK production calibrations be developed against an
"unknown" D.F., which presents an excessive risk to the manufacturer. It is
impossible to develop an optimum calibration which balances the need for high
confidence in emission and fuel economy compliance. Thus, an excessive number
of running changes are often required to optimize the calibration after initial
certification.
Subsequent time delays in review and revision of UK calibration Part I ap-
plication preceding fleet pick and approval to begin mileage further delay cert-
ification and jeopardize Job #1.
Ford Proposals
The following proposals would eliminate or reduce the problem:
. Eliminate the requirement for 50K certification testing.
- D.F.'s could be calculated from analysis of abundant data from pre-
vious fleets by very general system e.g., separate D.F. for oxidation
catalyst/air/EGR, oxidation catalyst/non-air/EGR, TWC/air/EGR, etc.
These D.F.'s would be inherently more representative than current
method because of increased sample size.
- D.F.'s could be generated for only new general systems as describe
above with a large enough sample size for statistical confidence.
- Durability would be proven using the extensive PV and DV testing re-
quired in-house to release a new part to production.
. Replace the current 50K vehicle certification program with a bench D.F..
similar to the evaporative system bench D.F.
- A larger sample size would be feasible and more testing at each inter-
val (UK & 50K) could be contained to reduce test-to-test variability.
- ECD's and AECD's could be bench cycled on corporate rapid aging
which incorporate thermal and vibrational aging more representative;
of customer operation than the current durability cycle.
-------
-43-
EPA Industry Workshop on Certification Paperwork Reduction (oon't)
. Use broader family definition to reduce the number of 50K certification
vehicles required.
- There is no significant statistical correlation between current
criteria for family differentiation and D.F.
- Such criteria as deck height, cam to crank centerline and valve dia-
meter should be eliminated and displacement criteria widened.
. Speed up the mileage accumulation cycle to allow faster mileage accumul-
ation i.e., UO or 50 MPH average.
Allow the use of an assigned D.F. fo?; low volume pilot programs to speed
the implementation of new technology to the field.
. Tighten up the fleet selection criteria such that the manufacturer could
select his own durability and data vehicle fleets and begin running im-
mediately upon submittal of all Part I information. The time consuming
detailed review of the application by EPA could be completed as mileage
is being accumulation.
- Ford has always and will continue to be responsive to all EPA questions/
concerns on system/part definition without the threat of holding up
the vehicle from accumulating mileage.
- The manufacturer would assume the risk of disqualification for a mis-
pick or a potential defeat device. 50K jeopardy would certainly be
minimal.
. Submit the Part I information sequencially to allow fleet selection before
all calibration information is known in detail and to avoid large/many
updates. However, for this sequencing to improve certification timing/
workload significantly, EPA will be required to sign up to a specific
turn-around timing for review/approval. A detailed timetable for submittal/
review for "ideal" certification timetable is shown on Exhibit I.
-------
-44-
Summary
It is believed that the current 5QK certification requirements leave much to be
desired in terms of yielding representative deterioration factors and hardware
durability results. It is well known that the 50K certification requirement and
its' corresponding long lead timing for Part I application, detailed review by
EPA and mileage accumulation is one of the biggest Jeopardies in a manufacturers'
ability to meet Job #1 for vehicle manufacture. Therefore, proposals have been
presented to substitute methods of obtaining deterioration factors and proof of
hardware durability which would be more representative, less time consuming mid
less paperwork consuming.
It is hoped that, although some of the proposals are rather far-reaching and
would have a large impact on EPA/industry ways of doing business, they be given
serious consideration based on their merit in meeting the intent of the Clean Air
Act requirements while saving considerable engineering energy which could be jut
to better use.
-------
Exhibit I
IDEAL I960 CERTIFICATION TIMING
SEQUENTIAL APPLICATION SUBMISSION AND CORRESPONDING EPA TURN-AROUND TIKE
Incidenc^^ocument Submitted to EPA (Per 1979 EPA Suggested Part I & II Application Format)
Weeks Prior
To Job #1
Approximate
Date
. / /Sections Via- A. Common Engine Family Parameters; VId- A. Common
5OK Fleet Selectiao Part I Sections -'to EPA./ Evaporative Family Parameters; Vlla-b- Engine/Evaporative Family
• Sales: XXa- Vehicle Description; X A. - Proposed 50K Data Fleet
92
10/2U/77
5QK Fleet Selection From EPA
90
11/07/77
-.1 /Sections I., II, III, IV, V (Common Sections); Via - B, C, D, E, F, & G
50K Calibration Part I Sections —'to EPA./ (Calibration Parameters); VTd - B & C (Evap. Individual Config. Para-
/ meters): Vie - Schematics; VIII; IXb, X B & C; XI, XII, X2II, & XIV.
88
11/21/77
EPA Approval to Begin 50K Mileage Accumulation
85
12/15/77
UK Cert. Development Vehicles/Hardware Required
56
07/1E/7E
50K Vehicles Complete Mileage Accumulation
50
09/OU/7£
UK Part I to EP^^Fart I Update (Common Sections Vla-A.;VId—A.;VIIa—b;IXa;X—A.)
U2
11/07/7&
UK Fleet Selection from EPA
39
UK Calibration Part I Sections to EPA
36
15/5/7=
EPA Approval to begin UK Mileage Accumulation
35
' 1 '"ni '"7C
UK Vehicles Complete Mileage Accumulation
22
2/2E/-^
Certification Received From EPA
20
a/1i/^c
Engine Job I
12
6/06/75
Vehicle Job I
0
9/T5/'75
2/ Ford Format is slightly different i.e.-EPA Section V±a- Ford Section Villa.
-------
-46-
W. A. Kostin
Revised:12-9-77
SEQUENTIAL SUBMISSION OF PART II 5OK AND DF DATA
(SEQUENCING)
EPA should review and approve the complete durability data vehicle
log plus associated DF shortly after a "prime" vehicle has completed
testing. Furthermore, the manufacturer should be permitted to
reference this EPA approved DF submission rather than resubmit the
same information in the Part II.
Advantage to EPA; It helps to reduce peak work load, since EPA
would be able to review the DF and logs, in some cases, several
weeks before final Part II submission. Also, only the data logs
for 50K vehicles intended to be certified, prime vehicles, would
be submitted to EPA for this early review.
Advantage of Manufacturer: It reduces the amount of time EPA
would require to review and approve the final Part II submission.
Therefore, it could shorten the time required to certify a family.
Also, it could save about 1700 pages of duplication for Ford,
since we would avoid making 3 additional copies of an average 12
page log for 47 Part II submissions.
REDUCE AVERAGE TIME REQUIRED TO APPROVE RC BY 2 DAYS
(SEQUENCING)
EPA should not require, as a pre-condition for subsequent approval
of a RC, that the manufacturer submit a data log update consisting
wholly of the final EPA fix test results. Instead, EPA should
approve the RC on the basis of: (1) the fully-up-to-date mainte-
nance and test logs describing all the events preceding the final
EPA fix test, and (2) the fact the manufacturer's test vehicle
has passed the final EPA fix test.
Such a procedure could save an average of two working days in
obtaining EPA approval after test completion. Also, updated logs
showing both the final EPA fix and HWFET tests would be submitted
to EPA shortly after the test results are received from EPA. The
single submission would eliminate the added submission of the
HWFET.
EPA CAN REDUCE PAPER WORK BY
ELIMINATING THEIR SEPARATE VEHICLE BOOK FILE
Presently, EPA requires that we submit them three copies of each
data log update affecting the Part II. EPA files one copy in their
certification book file, and one copy in their Part II update file,
and forwards one copy to Washington.
I recommend that EPA eliminate their vehicle book file. That elimi-
nation could save Ford about pages of duplication. Also, it
could save about 1-2 days in getting certificate on some families.
This is because EPA has delayed issuance of a certificate until thov
have received a vehicle book file update. Occassionally, those
updates are not sent, lost, or misfiled.
-------
-47-
Ford Motor Company
The American Road
Dearborn, Michigan 48121
December 21, 1977
Ms. Margaret J. Stasikowski
Chief, Operations Office
Certification Division
Mobile Source Air Pollution Control
2 565 Plymouth Road
Ann Arbor, Michigan 48105
Dear Ms. Stasikowski:
Subject: Final Report - Session on Referencing Within the
Application EPA-Industry Workshop on Certification
Paperwork Reduction
Attached is the final report for the session on
Referencing Within the Application. The report contains many
of the oral and written comments, made by the participants
in that session.
Also included with this submission is a list of Ford
recommendations for short term, 1979 model year procedural
revisions which can reduce Part II Certification paperwork
plus EPA review time. A paper is attached which discusses these
Ford recommendations. Furthermore, a brief listing of short
term proposals, prepared by other manufacturers, for reducing
certification paperwork is attached.
It is my understanding that each of these short term
recommendations or proposals for reducing paperwork will receive
a "yes, no, or give us more information" type of response from
EPA at the next manufacturers meeting. We would appreciate such
a response.
Sincerely yours,
W. A. Kostin
Certification Programs Department
Automotive Emissions and Fuel
Economy Office
Attachment
-------
-48-
Session Report
REFERENCING
WITHIN THE APPLICATION
Submitted For
EPA-Industry Workshop on
Certification Paperwork Reduction
December 12, 13 and 14, 1977
Prepared by:
W. A. Kostin
on
December 21, 1977
Includes Oral and Written
Comments of Session Participants
-------
-49- w« A. Kostin
12-19-77
REFERENCING WITHIN THE APPLICATION
Problem—LDV Format Needlessly Increases Workload
The current light-duty vehicle (LDV) application format contains
duplicate and redundant information which needlessly increases
workload of both EPA and the regulated industry.
Facts Bearing on the Problem
1. In 40 CFR 86.079-21 (a), separate applications are required
for each class of vehicle and set of standards.
2. In 40 CFR 86.079-31, provisions are made for separate certi-
fication of portions of a manufacturer's product line.
3. Past certification practice has been to require engine
descriptions to be completed for each family, even where the
differences were minor.
4. Approval of carryover has been conditioned on resubmittal of
information from past model years.
5. Test data submitted during the certification program had to
be resubmitted in the Part II before certification could be
granted.
6. Referencing is already being used in some parts of the light-
duty motor vehicle application such as use of reference to
the Part I where there has been no change in component
calibration from test vehicles to production.
7. Referencing is used more extensively in the 1979 heavy-duty
engine application for certification through a new general
section and through a mechanism which eliminates resul mittal
of certain information each year.
General Solution: Referencing
Five general referencing techniques can be implemented which will
have a substantial impact on the amount of information which the
industry must prepare, and which MPA must review and store. To
a certain extent these techniques were used to develop the new
1979 Heavy-Duty (HD) Engine Application format. The five techni-
ques are described next.
-1-
-------
-50-
1. Reference Between Model Years
One technique, reference more between model years. To accom-
plish this, a special permanent section of the Application would
be created (similar to Section 1A of the HD Application) which
would contain information that does not change greatly from year-
to-year. Such a section would be submitted once by the manufacturer
and then updated by amendment. No new re-submittal would be
required each model year.
The permanent Part I section would also include space for the
inclusion of test data as it is generated and submitted. This
provision would eliminate the need to resubmit data for carry-
over determinations.
One potential problem in this area is the ability to reconstruct
the application as of a certain date. Periodic microfilming
would solve this problem.
Another potential problem is: the New EPA Team may require the
revision of carryover information previously approved by the
preceding Team. The revision may be due to the new Team's belief that
the old Team overlooked an information requirement specified in
the old Application format. Nevertheless, the year-to-year
referencing technique won't save paper unless there's a uniform
interpretation among the Teams of the kind and form of the
information to be submitted in the Application.
2. Reference Within the Application Itself
A second major technique for reducing needless paper work and
review would be to restructure the Application so that more
referencing can be done within itself. One extension of this
technique would be to describe families which differ in only
a few areas once in a common section. Then, in each engine
family section only the differences would be described.
To successfully achieve a reduction in paper work plus review
time via this technique, the list of differences must be small
relative to the list of common items.
Another extension of this technique would be to have a common
section which describes the operation of all emission control
devices used on all LDV's or LDT1s. Then only brief description
of the production specifications for the device would appear on
applicable calibration description sheets throughout the
Application.
A general requirement of any technique for referencing within
the application is: it must not cause an increase in the time
required by the EPA Team to assemble and review a module of
information. In other words, the referencing technique should
not force the Team to repeatedly refer to several different
places in the Application in order to accomplish a review of a
single document such as an engine code (calibration) description.
-------
-JJl-
3. Reference Between Applications
A third technique for reducing certification paperwork is to
reference between the LDV, LDT and HD engine Applications.
For example, the same statement of Emissions Systems Warranty
is contained in these Applications. Certification paperwork
could be reduced if referencing between Applications was
permitted or utilized.
Generally, the duplicate submission of the same information
in distinct Applications results from the fact those records
are simultaneously needed by two different EPA offices, such
as tho Passenger Car Team and the LD Truck Team. As a
consequence, referencing between Applications may increase
work load for EPA.
4. Index the Application
One means to facilitate referencing is to implement a rigid
system for indexing the Application. Two examples of
indexing schemes are shown by Figures 1 and 2.
Four-basic requirements of an indexing system are that it should be:
(1) logical; (2) adaptable to computerization; (3) universally
applicable to LDV; LDT or HD applications; and (4) flexible
enough to permit the addition modification, or deletion of same
page without disturbing the remainder of the Application.
A corrollary requirement for any referencing scheme based on
indexing is: There should be a block on each indexed page which
shows the latest revision number and date.
Only be use of this block can the EPA reviewer easily identify
which of two pages assigned the same unique index is the latest.
5. Avoid Unnecessary Referencing
A fifth referencing technique is to avoid referencing notes or
statements which create additional paper-work. One extension of
thir. rule is to avoid using a referencing note expression which
conl.ains a time and date. For example, do not state, "See
Section V, page 6, dated Doc. 3, 3977 for a current description of
tho cn J ihrat i on". This kind of referencing generates; extra paper-
work, since bol:h tho reference note and the Section V must be
iipdatod whenever page 6 of Section V is revised.
Another extension of this rule is to eliminate unnecessary refer-
encing in tho 1979 Part TT of the revision date for the final
production curves and calibrations contained in the Part .L, As
a consequence of this referencing requirement, both the 197!) Part I
t lie formally updal:cd when-
ever there's a minor revision (typographical error) on tho curvi
calibration sheet which docs not require a running change. reqn:: .
Alr.o, this requirement generates extra review work load for EPA . !
tho manufacturer.
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-52-
Recommendation—'Develop New 1980 LDV and LPT Format
Develop a now format for the 1980 Light Duty Vehicle (LDV) and
Light Duty Truck (LDT) Application for Certification which
utilizes the referencing techniques described herein as well
as those techniques utilized in the Application format for
1979 Heavy Duty engines. The task force formed from the session
on Standard Indexing and Nomenclature should undertake this
recommendation.
Some of the desired features of the recommended new 1980 format
are as follows:
A special permanent section, similar to Section 1A of
the 19 79 HD Application, should be created in the
19 80 LDV and LDT Application Format which would
contain information that does not change greatly
from model year to model year.
The now 19 80 LDV and LDT Format should enable the
manufacturer to submit in a single section informa-
tion common to one engine displacement-.. Then each
derivative engine family section would contain only
the engine parameters unique to that family. For
example, this new section could contain two sub-
sections: one for base engine parameters, and
another for manifold and combustion chamber drawings.
The new 1980 Format should minimize the amount of
Application information which a manufacturer would
be required to resubmit in order to obtain a certi-
ficate for a carryover engine family. Ideally, a
manufacturer should only be required to submit a
letter of request plus possibly some altered sales
projections in order to obtain a certificate. (The
task force on Standard Indexing and Nomenclature has
been assigned the responsibility for proposing an
Application Format for achieving this recommendation).
Recommendation—More Uniform Interpretation of Information
licquiT.rii in Application
There should be a more uniform interpretation and application
among the EPA Teams of the kind and specific format of the
information required t:o be submitted within the Application by
each manufacturer. Thin should preclude the instances where
t he new Team require!:; the revision of carryover information
previously approved by the preceding Team.
I; :tab 1 i :;h Single Approva 1 Point for LDT and LDV
ril'A should establish organizationally a single approval point
for the submission of and approval of information common to
the 19/9 LDV and LDT Applications for Certification.
-------
-53-
Reconunendation—Manufacturers Should Investigate Indexing
Each manufacturer should thoroughly investigate—and where prac-
tical try out during the 1979 or 1978 model year—the rigid indexing
systems that Cummins has used in its 1978 IID Engine Application
for Certification.
Recommendation—Where Practical, Implement Revisions to 1979 Format
Implement as many short term revisions as practical to the 1979
LDV and LDT Application which would enable referencing to be employed
to reduce paperwork. Because 1979 Part I's have already been sub-
mitted to EPA for review, these short term revisions will probably
be limited to the Part II and the Zero Mile Vehicle Book.
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-54-
flpeclfic Proposals — Short Term
The specific proposals listed below were made by various manu-
facturers who attended the session on Referencing. Because of
insufficient time, these proposals (recommendations) were not
discussed at the Session. Nevertheless, because of these proposals
may reduce certification paperwork and EPA review time, each
proposal should receive a "yes, no, or give us more information"
type of response from EPA.
1. EPA should not require a manufacturer to resubmit a complete
previously approved Application as a condition for obtaining
approval of a carryover engine family. Since a carryover in
itsel f precludes substantial changes in the Application, the
letter of request with possibly altered sales figures should
be sufficient. This could be implemented even for model year
'79 and would result in a substantial paperwork saving.
2. Delete the stipulation from the 1979 LDV and LDT Application
Format which requires the manufacturer to resubmit complete
copies of the durability data vehicle as well as emission data
vehicle test and maintenance logs within the Part II.
3. Submit the calibration curves only once during the whole
certification process. Apparently, some manufacturers have
been required t:o resubmit the same curves in the Part I,
Part II, and zero mile banks for 4K and 50K vehicles. Changing
of the calibration curves could still be maintained until the
zero mile test with emission vehicles has been scheduled.
4. Don't ask for the listing of a certain part as AECD when it is
already described in the text part - or vice versa. Decide
to. use either this or that method of description.
5. The whole text in Section Via is to be questioned. Shouldn't
it be sufficient to use self-explanatory drawings and schematics
only, with some written information similar to our tabular
description of the AECD's?
-------
FIGURE 2 - INDEXING FOR COMPUTERIZATION
inncxuis -55-
The use of Indexing In computerization must
bo fully considered.
- Section Indexes should use sufficient codes
to fully define the lowest levels of datn.
0fS.17.Tli.22
Major
Sect ion
Sub
Sect ion
Topi c
Sub-topic/
Pa^e
- Dating conventions on each parce should
allow for thn dcterril nat I on of orlplnal
submission or revision text.
| Issued: 12/01/77
{Revised: New (Original Submission)
|Issued: 12/01/77
l^Rovlr.rcl: 12/15/77
- A manufacturer code should be Included to
allow for tlif por, 111 ve determination of
the siibml tt I n/t company.
10 - Ford flotor Company
Ml - General Motors Corporation
C.'ll - Chrysler Corporation
- Tarh sheet should contain a refnrence block
with all mandatory Indnxlnn Information,
Mfr
Index
1 11 Li U(! < 1
Kev 1 ;;ed
Compul'cr Ilclcii'.;: |ii:pf".
I ( ; ir; I'l uiii 11¦ ¦ 1m on .
I)'m .cinl11! r I !i, i " t /
-------
-56-
FIGURE 1
PART General Description
SECTION Technical Information
SUBSECTION Fuel System
PARALLEL SUBSECTION
ITEH Injector Type D
PAGE
PARALLEL ITEM
X. X,
1. 6,
X X A
: 4
X X. X X A
3. 0 1
2.
X.
1.
X,
0 9 2
X X X
7.0 1
X X. X X
I
PAGE
-ITEM P1s ton fit -Rings
-FAMILY
"SECT ION Specifications
¦PART
-------
-57-
EPA-INDUSTRY WORKSHOP ON
CERTIFICATION PAPERWORK REDUCTION
December 13, 1977
Participant List
Topic 3: Referencing within the Application
Name Representing
Virginia Sink
Chrysler Corporation
R. C. Smith
EPA
J. Thomson
EPA
T. Hiramatsu
Toyota
D. Bonawltz
Toyota
Gene Bolton
General Motors Corporation
Merle Liskey
American MOtors
M. R. Wilson
General Motors Corporation
Bill Kostin
Ford Motor Company
Hugh Daugherty
Cummins Engine Company, Inc
B. Patok
EPA
Mark Wolcott
EPA
Karl Weber
Mercedes Benz
Richard Mazur
EPA
Les Ryder
EPA
M. Stasikowski'
EPA
R. E. Harrington
EPA
B. W. Schomer
BMW
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-58-
Ford Motor Company
W. A. Kostin
12-19-77
SHORT TERM 1979 MODEL YEAR
PROCEDURAL REVISIONS WHICH CAN
REDUCE PART II CERTIFICATION PAPER
WORK AND SHORTEN CERTIFICATION TIME
Estimated
Savings
1700 pages
annually;
2 days
Reduced Cert,
time by 2
days; 800
pages annually
7500 pages
annually
2-3 days in
obtaining a
certificate;
1700 pages
annually
five mnn-days
470 pages
minimum; poten-
tially avoid
2340 extra pages
Proposal
I. EPA should review and approve the com-
plete durability data log plus associated
DF shortly after 50K test completion.
Then, the manufacturer should be permit-
ted to reference this approved DF submis-
sion rather than resubmit the same
information in the final Part II.
II. EPA should approve a RC on the basis of:
(1) the submission of fully updated logs
describing all the maintenance and test
events preceding the final EPA fix test,
and (2) the fact the manufacturer's test
vehicle has passed the final EPA fix.
III. EPA should only forward Part II updates,
furnished by the manufacturer, to Wash-
ington on a quarterly basis. This
eliminates the handling of multiple
separate revisions to the same page.
'IV. EPA should formally permit and encourage
the establishment of master Part II
addendum information sections for 1979
LDV and LDT engine families. Individual
Part II submissions should not be
required to contain a time dated refer-
ence to the addendum.
V. After review of a "dummy" Part II sub-
mission, EPA should provide the manufac-
turer with a list of all desired changes
in format to be included in actual
subsequent Part II submissions.
VI. EPA should eliminate their requirement
that the manufacturer reference in the
Part II the latest revision dates for
the final production curves and calibra-
tions contained in the Part I,
-------
-59-
Estimated
Savings
750 pages VII,
annually;
(additional 1450
pages saved in-
ternally by Ford)
1920 pages VIII,
annually;
(additional 3840
pages for Ford)
EPA should not require a manufacturer to
resubmit complete copies of the emission
data vehicle maintenance and test logs
within a Part II submitted for initial
certification.
Remove the requirement for "preliminary"
engineering reports. The preliminary
engineering report is unnecessary since
it is a restatement of the report of con-
tact which is kept jointly by the EPA
and manufacturers. Also, the use of
"engineering judgment" could reduce the
total number of engineering reports
required. To date, Ford has submitted
two copies of 319 reports on 1978 MY
vehicles to EPA.
IX. The following changes in the Part I will
lower the amount of paperwork which must
be processed.
(a) Remove the requirement for dimensional
combustion chamber drawings. Since
cylinder heads change so infrequently,
we see no use for these drawings to
be included in the Part I.
(b) Test fuels need not be included in
the Part I; should only be included
if different from federal regulations.
-------
-60-
W. A. Kostin
Revised:12-9-77
12-19-77
I. SEQUENTIAL SUBMISSION OF PART II 50K AND DF DATA
EPA should review and approve the complete durability data vehicle
log plus associated DF shortly after a "prime" vehicle has completed
testing. Furthermore, the manufacturer should be permitted to
reference this EPA approved DF submission rather than resubmit the
same information in the Part II.
Advantage to EPA: It helps to reduce peak work load, since EPA
would be able to review the DF and logs, in some cases, several
weeks before final Part II submission. Also, only the data logs
for 50K vehicles intended to be certified, prime vehicles, would
bo submitted to EPA for this early review.
Advantage of Manufacturer: It reduces the amount of time EPA
would require to review and approve the final Part II submission.
Therefore, it could shorten the time required to certify a family.
Also, it could save about 1700 pages of duplication for Ford,
since we would avoid making 3 additional copies of an average 12
page log for 47 Part II submissions.
II. R/C APPROVAL RASED ON EPA FIX TEST DATA
IIPA should not require, as a pre-condition for subsequent approval
of a RC, that the manufacturer submit a data log update consisting
wholly of the final EPA fix test results. Instead, EPA should
approve the RC on the basis of: (1) the fully-up-to-date mainlc-
nance and test logs describing all the events preceding the fj nal
EPA fix test, and (2) the fact the manufacturer's test vehicle
has passed the final EPA fix test.
Such a procedure could save an average of two working days in
obtaining EPA approval after test completion. Also, updated log3
showing both the final EPA fix and HWFET tests would be submitted
to EPA shortly after the test results are received from EPA. The
single submission would eliminate the added submission of the
II17FET.
III. ELIMINATION OF THE REGULAR WASHINGTON UPDATE
Presently, 1.1-A requires that we submit them three copies of earli
data leg uj.d:i1e affecting the Part II. EPA files one copy in I i. ii
imi book file, and one copy in their Part II update i ' < ¦
and foi ./aid:; one copy to Washington.
-------
-61-
W. A. Kostin
12-8-77
12-19-77
EPA should discontinue the practice of forwarding copieB of all
routine Part II updates to Washington. Instead, EPA should only
forward to Washington Staff on a Quarterly basis updated Part
II*s containing information certified (approved) during that
Quarter. This quarterly update would be furnished by the
manufacturer to EPA. A/C-66 could be amended to provide for such
a submission.
The quarterly update would save both EPA and Ford paper work as
well as reduce work load, since multiple copies of revisions
made to the same page would not be sent to Washington. And,
the legal status of the information forwarded to Washington
remains unchanged since the records kept in Ann Arbor are those
required for any Court submission.
IV. AVOIDING THE REPEATED SUBMISSION OF MATERIAL
COMMON TO ALL PART II'S
EPA should formally encourage the establishment of master Part II
addendum information sections like Ford has created for 1978.
Each addendum would contain statements common to a major subset of
engine families such as LDV, LDT, MDV or IID families. The manufac
turer would be required to keep the addendum sections current.
And, the manufacturer would not be required to reference these
addendum sections in each individual Part II submission. Instead,
for example, the manufacturer would make the statement that the
LDV addendum section applies to all LDV Part II's.
Information which would be included in the addendum sections are:
Name of Representative
Statements of Compliance (Device Safety)
Emissions Systems Warranty
Recommended Customer Maintenance
Training Programs for Emission Controls
Samples of VECI Decals Plus a Statement of Label Location
Also, a separate Part II addendum .section should be created for
t:he Evaporative Emission DF data organized by Evap-control system
combination. This section would contain a chart depicting the*
correspondence between the applicable exhaust emission family and
the cvap DF. A partial example of this Evap. Section is attached.
ESTIMATED PAPER SAVINGS IN 1979:
A::nuii|ing there are 47 individual Part II submissions to bo made to
I;I'A and in 1979, and five copies are made of each submiss ion,
i lien cJioul /i?00 p.KjCr. o(: duplication can lac avoided by using tlu
fn.cjc: , I add .1 iinn section. 2»n additional pages oL" durl imt i mm
f'.u.ld 1 c saved if a common evap addendum section is used iMi J1
t w.:p i .':iiiiUos. Therefore, the total paper savings r:ould )ij _/
i: IK: singular mi!. i.sJon relieves IiPA of the a.l.k.d Liud i < I
revicw.i.iij '1/ repeated submissions of the same material.
-------
-62-
W. A. Kontin
12-8-77
12-19-77
V. PART II FORMAT CHANGES
Each year our initial Part II submissions to EPA include the
format changes requested by last year's EPA team. It seems
that no matter how well we prepare the Part II, the new team
invariably requests new additional changes in format.
Examples of actual minor changes in format, which required that
we update all Part II's previously submitted to EPA, are as
follows:
Change the transmission code from C-4 to Auto
(C--4) on all emission test logs.
Add the actual odo correction factor to the
header page of the log, even though it's
shown on all subsequent pages.
Add the latent revision date on the Calibra-
tion Description Sheet contained in the Part I
to the CAPL.
If identified early, these changes would be easily handled.
PROPOSED SOLUTION
Each ir.ember of the new EPA team should examine a manufacturer's
"dummy" Part II about four weeks before the scheduled submission
of his first "actual" Part II. As a result of this examination,
EPA would provide the manufacturer with a list of the changes
in format, which wouJd be included in all subsequent Part II
submissions. After publication of that list, EPA would agree
not to make additional minor changes in format which would
apply to Part II's in EPA's possession.
nrnEFiTs
Via could probably save at least 2-3 days in obtaining a certifi-
and about 350 pages of paper work.
-------
-63-
VI. ELIMINATE UNNECESSARY REFERENCING IN
THE PART II OF PART I DATA
EPA should eliminate their requirement that the manufacturer
reference in the Part II the latest revision dates for the
final production curves and calibrations contained in the
Part I. The explanation for this recommendation follows:
To reduce paper work, Ford submits in the Part I
only, instead of both the Part I and II, the final
production carburetor and distributor curves.
Ford also submits the calibration description
sheets only in the Part I.
However, EPA's recommended format for the 1979 Part II requires
the following:
"For any production curve or calibration referenced
in this section that is identical in all respects
to a curve or; calibration already submitted in Part
I of this application, reference the curve number
and latest revision date in this section rather
than re-submitting the curve or calibration. If
the curve or calibration differs from the Part I
submission, please explain the difference."
As a consequence, now both the Part I and II must be formally
updated whenever there'n a minor revision (typographical error)
v;hich docs not require a running change requer.t. In short,
added paper work and checking time is generated for both EPA
and Ford by this referencing requirement.
PArnn savings
This proposal could save EPA and Ford at least _470 pages
baaed on the experience of the 1978 certification program.
Potential additional savings of 2340 pages (estimated).
-------
-6A-
VII. Eliminate the Resubmltion of Data
Logs Within the 1979 Part II
EPA should not require a manufacturer to resubmit within the
Part II complete copies of the emission data vehicle maintenance
and test logs within a Part II submitted for initial certifica-
tion.
The primary reasons for this deletion are as follows:
1. The 1979 HD Application Format does not require the
resubmition of emission engine logs within the Part II.
2. The results of all certification tests and maintenance
are reported to EPA within 3 working days and one week,
respectively. These logs are filed in EPA's vehicle
bank, apparently a permanent file.
3. The final official 4000 mile certification test is
conducted by EPA; and the results are reported to EPA
on the Official Test Result summary page contained in
the Part II.
-------
-65-
SUMMARY REPORT
on The Session on
THE COMPUTERIZATION OF THE CERTIFICATION PROCESS
(Topic #4) of
The EPA - Industry Workshop on
Certification Paperwork Reduction
December 14, 1977
Chairman, G. F. Gruska, GM
EPA Contact, L. M. Tucker
-------
-66-
OBJECTIVE
The objective of this workshop session is to determine the
feasibility/time constraints for the utilization of computer
capabilities in the certification process in order to reduce
certification related paperwork and provide efficiency to
the certification approval process.
FACTS BEARING ON ISSUE
Because of the prerequisites of system/media compatability
and standardized formats, initial utilization of computer
capabilities in itself will not in general reduce the size
of the certification process submission, but makes the
process more efficient and reduces the total amount of
paperwork necessary to produce a submission. In order to
determine the impact to EPA and to the industry, a computer-
ization survey was passed out during the introductory session.
The information from completed surveys were subsequently
used during this session (a survey completed for the EPA
facility and summary are attached).
In general, any proposal should result in a definite reduction
in the time required by EPA to audit a certification submission.
A computerization proposal should also permit both industry
and EPA to internally reduce the amount of manual transcrip-
tion of data from one format to another format for data
input for presentation and associated error.
Concern should also be given to the security of the transmis-
sion media of the information and the impact of any proposal
on small companies. Finally, the computer also should not
be used to generate documents which can be more easily and
cheaply manually prepared, or to store information for which
there is no need and which can be stored more inexpensively
in hard copy form.
Some of the disadvantages and impacts of proposals for
computer applications should be mitigated by the results of
the indexing and sequencing task forces.
RECOMMENDATIONS
In general, it is recommended that all participants should
investigate the feasibility of internal uses of word processing/
automatic data processing. The following areas are being
recommended for short term implementation by EPA.
o Transmission of test log results in computer
readable media - This is a present EPA capability
which should be enhanced and encouraged. This
option will be affected by the work of the
indexing task force.
-------
-67-
o Single approval point - For every portion of the
certification submission, there should be a single
EPA element responsible for approval of the infor-
mation content. Although this is more a management
issue than one of computerization, it was felt
that the use of the computer could greatly assist
in the implementation and maintenance of such a
management policy.
The following have variable implementation time table,
depending upon the extent of the capabilities utilized.
These capabilities can be implemented sequentially (that is
provided that the initial system is to be extensible) and
have the feature that their use would reduce the amount of
paperwork needed to be submitted.
o Minimize required information to be submitted
(short to medium term) - This recommendation would
require that the major information elements within
the submission be categorized as to their required
accessibility, what elements need immediate accessi-
bility because they are highly utilized? Which
elements are only occasionally utilized and do not
need to be readily available? Within this proposal,
the second set of elements (occasionally utilized),
would be retained at the manufacturer and submitted
only upon request and within a reasonable time
frame.
o Computerize storage/retrieval of submissions
(medium to long term) - This proposal would require
EPA to provide the hardware and software necessary
in order to economically store and make readily
available to the EPA elements any processed submission.
(The complexities of updating initial submissions
under such a mode of operations was discussed with
the conclusion that it was not a major limiting
factor).
o Commonized data reporting forms - The implementation
time frame would be from short to long term depending
upon the extent of commonization., That is,
within the short term, the forms within the certifi-
cation branches could be commonized, medium term
throughout EPA, long term throughout the Federal
regulatory agencies.
o Common Data Base - This proposal extends the above
by the maintenance by EPA of a general data base
of certification related items. Information would
be submitted to the data base directly rather than
on specified report forms.
-------
-68-
Since implementation/development of many of these capabilities
are dependent upon the existing/future system capabilities
of EPA and industry, it is further recommended that EPA set
up committees to run pilot feasibility projects on these
different capabilities. These committees should be formed
by EPA based upon the information contained in the computeri-
zation survey forms completed during the workshop. (It is
requested that companies forward to EPA a fully completed
survey if they have not done so yet.) Besides discussing
selected portions of the above, these committees should also
consider other problems such as the concerns related to the
various forms of information transmission/input and the
efficacy of obtaining each capability with respect to EPA
and industry (small/large).
DISCUSSION
A computerized system has the capabilities of the storage
and the selective or wholesale retrieval of information, the
generation of report documents, the analysis of information,
and the transmittal of information. There are several
possible systems design categories with respect to the
certification process. These are:
Complete - all information stored and all capabilities
available.
Partial - all capabilities available but specified
groups of information are stored off line.
Limited - storage of test data only with some capabilities
available.
Manual - all information stored off line and no capabili-
ties available.
Of these possible systems, the first (complete system) was
not considered in further discussions since, although it is
technically feasible, it is not economically feasible at the
present. Further, the last system, manual, was also not
considered since EPA's present capabilities are at the
limited system design level.
These systems can be further subdivided by considering the
accessibility of information. That is, information can be
handled as text in which all elements are considered as
character strings regardless of whether they are numbers or
alphabet, or as items (data) in which elements have a meaning
other than a character string. Restricting the utilization
of computers to text forms is ofter referred to as word or
text processing.
-------
-69-
Word processing can be catagorized into several functional
levels as follows:
0 Manual typewriter mode - In this level all manipula-
tion of textual information is done by the operator.
1 Automatic typewriter - Here the mechanism provides
a capability to store limited amounts of text as
well as providing editing capabilities.
2 Mini computer based systems - These systems extend
the storage and editing capabilities available to
the operator as well as provide additional capabil-
ities of communication and long term storage.
3 "Large" systems based - At this level the textual
information is manipulated utilizing the full
capabilities of large scale computers.
There are certain processing efficiencies and cost tradeoffs
attributed to each of these levels. General Motors and
Cummings presented examples of the advantages and impacts of
implementing the second and third levels of word processing.
The workshop generated the following advantages and disadvan-
tages to the utilization of word processing:
Advantages:
Reduction of paperwork, especially during the
generation phase of the document.
Faster throughput/approval - for example, an
automatic revision checking capability.
Ease of changes/correction.
Ready accessibility to the information.
Minimum format restriction.
Assists referencing lookup.
A single approval center.
Cost.
Disadvantages:
Requires a functional computer.
Standard page format.
Analysis only on the gross (index) and character
levels.
Needs trained personnel.
Cost.
Requires machine readable copy.
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-70-
In general, the advantages can be summarized to Automation
and Productivity while the disadvantages to Changes in the
standard operating procedure.
Discussions on the item (data) form were initiated by a pre-
sentation of the advantages and impact by the Ford Motor
Company. The advantages of this mode that were identified
by the workshop are:
Analysis capabilities
Entry verification/validation
Faster throughput/approval, for example during
running changes
Efficiency of internal control by the minimization
of the proliferation of error
Provides for a centralized data base.
The last advantage, a centralized data base, also has accom-
panying disadvantage, that is the coordination and/or reorgani-
zation of requirements within the government. Other disadvan-
tages identified are:
Applicable only to selective information elements
Format/information restriction.
The disadvantages of the format restrictions should be
mitigated by the results of the indexing and sequencing task
forces.
A fundamental requirement of any system mentioned above, it
the transmission of information from industry to EPA. The
various modes of transmission are:
o Manual - this could take on various forms from the
present method of providing hard copy to the
keying in of information directly into the computer.
o Punched card - this mode is limited to small
amounts of information and primarily that of the
item (data) form.
o Magnetic tape - this is primarily utilized for the
transmission of large amounts of information.
o Diskette - an alternate for magnetic tape.
o OCR (optical character recognition) - these devices
allow the information contained on typed documents
to be inputted directly into the computer.
o Telecommunications - with this media there would
be a direct or indirect connection between industries
and EPA's word/data processing devices.
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-71-
With respect to any of these modes of transmission, there
are certain concerns that must be recognized. These are:
o Submission verification/accountability
o Security during transmission and subsequent access-
ibility
o Time required to "cycle" a submission
o Investment on the part of EPA and/or companies in
equipment or contracted services support. No
recommdation was made regarding which mode of
transmission should be used by EPA.
CONCLUSION
The overall conclusion of this session was that the utilization
of computer capabilities within the certification process
with proper cognizance of the concerns given above can
result in an efficiency in the approval process as well as a
actual reduction in the amount of paper necessary to gain
this approval. Further, this utilization is affected by and
can assist in the full efficacy of indexing, referencing,
and sequencing.
GFG/frg/w/382
12/23/77
-------
-72-
Attachment A
EPA-INDUSTRY WORKSHOP
OH CERTIFICATION PAPERWORK REDUCTION
December 12-14, 1977
COMPUTERIZATION SURVEY
Company Name: Environmental Protection Agency
Name of Person(s) Completing Survey: John Kargul
Mailing Address: 2565 Plymouth Road, Ann Arbor, Mi 48105
Phone No.: 668-4399
Note: If a computer system or device is given as an answer to a question,
please enumerate its characteristics.
I. BASIC COMPUTER SYSTEM DESCRIPTION
A. Do you have onsite or timesharing computer capability which
you currently do your certification work on? Yes
B. Describe your system
1. Mainframe Hardware: Ahmdal 470 V6 (Remote Time Sharing)
2. Configuration: Standard
3. Memory Size: 4 Mb
4. Operating System: Michigan Terminal System (MTS)
5. Timesharing Software: MTS
6. Communication Link (e.g., Host/Satellite, HASP/2780)
Host - HASP, DATA 100 Satellite - HASP Model 20 RJE
7. Other Major Features:
8. 0 of Peripherals: 0f the RJE
a. Card Readers: • 1 Speed: 200 CPM
b. Line Printers: 1 Speed: 300 LPM
c. On-line disk storage: 0 Size:
d. Tape Drives 1 Track 9 Speed 45 LPS
Density 1600
e. X-Y Plotter: fl
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-73-
f. Optical character recognition devices:
g. Microfilm writers: 0
h. Microfilm readers: . 0
i. Other:
9. Programming Languages available: FORTRAN. PL1. COBOL.
Assembler, ALGOL
10. Programming Languages Preferred: FORTRAN, PL1
11. # of Test Sites Supported: No Direct Hardwired Support
12. Other testing support equipment (e.g., calculators etc.):
HP-21MX, TI-960 Mini-Computers
HP-9825 Calculator
II. TEST DATA COLLECTION AND DERIVATION
A. Basic Test Data Description
1. % numeric test data: 80%
% text test data: 20%
2.
3.
4.
5.
% engineering drawings: 0%
• 100%
60%
40%
100%
% certification related data:
% experimental related data: _
How do you collect your numeric certification test data?
Currently we collect the data manually.
1. % lab instrument read and manually transposed: 100%
2. % manually derived: 0^
3. % computer read and stored:
0%
If an engine family is carried over from one year to the
next
what percentage of the data is:
1.
numeric:
15%
2.
text:
1
3.
drawing:
0%
4.
other:
0%
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-74-
III. BASIC DATA TRANSFER, ANALYSIS, STORAGE, AND REPORT GENERATION
DESCRIPTION
A. Do you transfer test data to .your computer system?
Yes X No If so, what percentage is
transferred and how?
1. Manual methods: 100% data sheet coding and card entry or terminal
2. Automatic methods: 0% entry.
3. Other: 0%
B. Do you transfer data between computer systems (local or
remote)?We could but we do not need to. How? 9-track
magnetic tape.
C. How do you validate the transferred data? not applicable
D. Do you have a high error rate? Not Applicable(%):
E. Do you consider your current method of data transfer
adequate? Not Applicable
F. How would you change it if you could? It would be nice to
establish a communication network between the systems.
G. How do you perform certification datr. analysis? Most of our
analysis is done manually (overall). ,
1. 80 % Manual; explain: All analysis of Part I's
and Part II's are done manually.
2. 20 % automatic data processing; explain: All EPA test
processing is automated, but not much else for certtification data.
3. _0 % other; explain:
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-75-
Types of certification data analysis performed:
1. % engineering analysis of numeric data: 30%
2. % engineering analysis of text: 40%
3. % engineering analysis of drawings: 10%
4. % statistical analysis: 20%
What kinds? Standard deviations, regressions.
How is your certification data stored? (% manual,
% automatic, % other)
1. Numeric: 100% automatic test data - 0% automatic Part I, Pt.II dats
2. Text: 100% automatic test data - 0% automatic Pt. I, Pt. II data
3. Drawings: 0% automatic
4. Other:
Do you have a Data Base Management System? No
1. What kind(s)?
2. How long have you had it (them) operational?
Do you have a Data Dictionary/Directory System? No
1. What kind(s)?
2. How long have you had it (them)?
Do you have a host language interface capability with your
DBMS? No What Lanuguages?
Do you have a query language capability with your DBMS?
No Is it adequate?
Do you have a graphics interface with your DBMS? No
Is it adequate?
Do you have a report generation capability with your DBMS?
No Is it adequate?
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P. What kinds of reports do you generate?
1.
X numeric data?
85%
2.
% text data?
SX
3.
% drawings?
5%
A.
% combination?
5%
5.
% other?
Q. Are EPA's requirements primary considerations in the procedural
aspects of data handling storage, and report generation
at your facility? Yes
Explain* °Ur Processin8 is completely specified by EPA's
requirements.
R. Are EPA's requirements satisfied as one of many users of
your information? Yes
1. % system use for EPA: 99%
1%
2. % system use for other: _J
WORD PROCESSING FOR CERTIFICATION PART I AND PART II PREPARATION
A. Do you have on-site, remote, or contracted word processing
service to process certification data? Yes - on-site
If so, what kind(s)? IBM Mag Card II typewriter
B. What is the text-editing capabilities of your WP service?
1. Limited (standard typewriter with a
few controls):
2. Moderate (includes internal programming and
A
core storage):
3. extensive (Shared Logic, or Mini Computer
based system, Computer Timesharing):
C. Explain briefly the configuration of your WP service:
IBM Selectric Typewriter plus a Mag Card unit
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D. List the type, size, and speed of each kind of storage
your WP service has. (e.g., magnetic cards, magnetic tapes,
disc or diskette, other) mag cards - 1 page per card
E. Does your WP service have searching capability?
F. Does your WP service have a reformating capability?
Explain: Not without extensive changes to the data.
G. List the type and speed of each display and printing device
your WP service has: IBM Selectric typewriter - 15 cps
H. What is the speed of your WP service?
It depends upon the length of the job, generally 1 day turn around.
I. What character type does your WP service use?
What ever type-ball you put on the Selectric
J. Does your WP service have a communication capability? ^es
a. with your computer-data storage system? yPB
b. with other WP devices?
If so, what is the protocol (IBM, ASCII, other), type
(dial up, hard wire), and speed?
Protocal is ASCII, dial-up type. 15 characters per second.
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K. How are your Part I's prepared? Not Applicable
1. % manual:
2. % automatic:
3. % other:
L. How are your Part II's prepared? Not Applicable
M. If manually prepared, do you have any plans to automate the
process? Not Applicable
If so, what are they?
N. How is the certification text entered into the WP
service? Currently no certification text is entered into
our word processing service.
WP
0. Are you satisified with the service for certification
work? Not APPlicable
V. GENERAL
What plans do you liavt: to modify or upgrade equipment and capabilities:
(please elaborate): We are currently developing a Real-Time Computer
System using dual SEL32/55's to process our certification and experimental
test data. The system will have a HASP link to a larger timesharing
service. We are also upgrading our work processing equipment to VYDEC
Model 1200 equipment which has full page CRT screen & keyboard, "floppy"
disk storage, and independent printer.
RETURN SURVEY TO:
Environmental Protection Agency
2565 Plymouth Road
Ann Arbor, Michigan 48105
Attention: Linda Tucker, Data Branch
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-£>
I. BASIC COMPUTER SYSTEM DESCRIPTION
AMC
GMC
CHY
FORD
PEUG
AUDI
TOYOTA
CUMMINS
Computer System(s)
1
HONEYWELL
IBM 370/158
(1) CYBER
(1)HONEYWELL
IBM
NONE
UNIV
XEROX
SERIES
NETWORK
6080
370/158
1100/42
SIG IX
1 Used for certifi-
600-6000
(2) CDS
(2)
time-
cation
-
SYSTEM 17
(3)Process
cont.
HP 2000 F
-
sharing
4. O.S.
GCOS
OS/SVS
TSO
(1)NOS/BE
(2)Mass
storage
O.S.
(1) GCOS/TSS
(2)
EXEC8E
TIY
6. COMM. LINK
HOST/
SATELITTE
HASP/2780
19.2KB
Link
between
(1) GERTS
(2)
TELEX
(time-
sharing)
d. TAPE DRIVES
10-9 track
3-9 track
(1)11-7/9
(1)15-7,9
10-9 tracJ
9 track
1800 BPI
800/1600 BPI
556/1600
BPI
(2)2-9
1600 BPI
track
800,1600 BPI
(2)1-9 track
800 BPI
800/1600
BPI
800/1600 BPI
f. OCR
NONE
NONE
(l)l-CDC
NONE
NONE
NONE
NONE
I
v©
1
-------
II. TEST DATA COLLECTION AND DERIVATION
AMC
DATA DESCRIP.
DATA
COLLECTION
Num
Text
Draw
Cert
Exp
Lab
Inst
Man
Comp
read
DATA CARRY-
OVER
Num
Text
Draw
Other
GMC
CHY
FORD
80%
80
50
30
95
25
90
20%
20
50
70
5
75
5
0
0
0
0
0
0
5
50%
100
75
90
40
3
75
50%
—
25
10
60
97
25
100%
0
0
20%
100
100
50
id 0
0
0
80%
100
0
40
0
100
100
0
0
10
20%
40
40
20
95
50
20%
30
40
75
5
50
5%
30
0
5
0
0
55% back
—
0
0
0
—
ground
work
I
00
0
1
PEUG
AUDI
-------
3-
III. BASIC DATA TRANSFER, ANALYSIS, STORAGE, AND REPORT GENERATION DESCRIPTION
AMC
A. DATA TRANSFER
TO COMP. SYSTEM
DATA TRANSFER
BETWEEN COMPUTER
SYSTEMS
CERT DATA ANALYSIS
J. DBMS
100% term
entry
NO
80% manual
20% AUTO
YES-part of
GCOS
GMC
CHY
FORD
100% term
entry
NO
100% AUTO
ADABAS
Fortram,PLl,
assembler
100% data
sheet/
term entr''
YES-CDC
Sys 17 to
CDC CYBER
60% manual
Fortram,
text edit
100% remote
terminal
input
YES-REMOTE
TERMINAL
INPUT
100% AUTO
TEXT EDITING
Special basic
Data Reportii i<
and Info
retrieval
PEUG
AUDI
TOYOTA
100%
terminal
entry
NO
95% manual
5% AUTO
NO
CUMMINS
100% data
sheet
entry
98% manual
2% AUTO
(EPA tests
NO
Keyed entry
& AUTO from
test cells
80% manual
(hand calc)
)20% on
Xerox
NO
I
or.
-------
"--4-
IV WORD PROCESSING FOR CERT PART I & II PREPARATION
A. DO YOU HAVE WP
CAPABILITY
B. TEXT-EDITING
CAPABILITY
STORAGE CAPABILITY
COMMUNICATION
CAPABILITY
WP Part I & II Prep
K.
L.
AMC
GMC
CHY
FORD
Contracted
Computer-
based
extensive
Tape, disc
NO
Possible ASCII
handivers
9600 band
YES
On-site
WANG WP-30
extensive
Disc-4000P
DISKETTES-
120P/ea
NO-will havfe
ASCII,
modem 30
cps.
1-70% Man
30% Auto
ilI-90% Man
10% Auto
On-site
File stora<
& report
gen.
limited for
part 1
extensive
for part I
disc
YES
ASCII
dial-up
30-120 cps
I-100% Man
II-50% Man
50% Auto
HONEYWELL
RUN-OFF
TEXT PRO-
CESSING
moderate
Buffer storage
timesharing
disk
YES
dial-up
IBM/ASCII,
30 cps time-
share service
I- 100% Man
II- 50% Auto
PEUG
AUDI
NO
Limited
TOYOTA
CUMMINS
NO
Cannot
Answer
WANG, ATMS
extensive
WAHG^BISKETTI
ATMS-DISK
WANG-NO
ATMS-YES
4800 band
IBM
I-10% Man
90% Auto
II-100% WANG
I
cx
to
I
-------
Plans
WP
COMPUTERIZATION
AMC
Patten after
Ford
Intergrate
parts of Cert
on new compute:
system
GMC
ADD
OCR
—5'
IV GENERAL
CHY
FORD
Not in
near
future
PEUG
AUDI
None Plannei
TOYOTA
CUMMINS
Move to
ATMS from
HANG
increase
comm. to
57.6 K,
add 1ine
printer,
card read<
augment
GCOS with
MULTICS,
Upgrade HP
2000 to HP
3000
automatic
dafea,-.-col-
lection
for span
measurement
& calc.
NONE
i
00
u>
1
-------
-84-
CQMPUTERIZATT ON AT CtlflMTN.S
CURRENT: WANG WORD PROCESSOR
, ON-LINE EDITOR
, "MASTER" DOCUi'iCDTS ON RETRIEVABLE MEDIA
. CREATION/CHANGE TIME GREATLY REDUCED
. MORE CONSISTENT PRODUCT
. ADDED A DISTANCE FACTOR IN CREATION/CHANGE
CYCLE
-------
-85-
COMPUTERIZATION AT CUMMINS
GOALS:
. EFFICIENT, FAST SERVICE
. ABILITY TO ELIMINATE KEYING REPETITIVE DATA
. ABILITY TO COMMUNICATE WITHIN CUMMINS
, MINIMIZE, AS MUCH AS PRACTICAL, THE PAPER FLOW
BETWEEN CUmiriS AND EPA
. UTILIZE CAPABILITIES OF COMPUTER TO REDUCE THE
WORK REQUIRED TO SUBMIT/PROCESS CERTIFICATIONS
f-i i (ci ch >- 4 S
-------
-86-
COMPUTERIZATION AT CUMINS
PROPOSED: ADVANCED IEXT MANAGEMENT SYSTEM
SAME AS CURRENT EL1JS.
- PROVIDE ABILITY TO COMMUNICATE WITHIN
CUMMINS
- WILL ALLOW CERTIFICATION RELATED DOCUMENTS
TO BE CREATED LOCALLY
- OPENS THE DOOR TO A MECHANIZED INTERFACE
WITH EPA
- WILL EASILY INTERFACE WITH ADVANCED
RETRIEVAL SYSTEM (STAIRS)
-------
-87-
A DISCUSSION OF THE PROPOSAL
TO COMPUTERIZE THE
APPLICATION FOR CERTIFICATION
Prepared By
W. A. Kostin
Of
Ford Motor Company
On
December 14, 1977
-------
-88-
W. A. Kostin
December 12, 1977
COMPUTERIZATION OF THE
APPLICATION FOR CERTIFICATION
Purpose
This paper presents some thought provoking ideas which should
be discussed during the EPA-Industry Workshop on Certifica-
tion Paper Work Reduction. The paper does not represent a
fixed formal position of Ford Motor Company on this matter.
Documents Most Likely
To Be Computerized
The documents, currently computerized, most likely to be sub-
mitted to EPA in computer readable format within about 1-2 years
are as follows:
1. Emission Vehicle Test Logs
2. EPA Official Test Results
3. Durability Vehicle Maintenance and Test Logs
4. FEDV Packages
(Examples of computerized versions of items 1-4
are attached.)
The following documents, currently not computerized, appear
feasible for computerization, but will probably not be imple-
mented at Ford for about 2'years:
Section VIII of Part I, Vehicle Description
Individual Calibration Description Sheets
The computerization of these documents is currently being
investigated.
Criteria for Judging
Whether to Computerize
The following criteria are proposed for judging whether to com-
puterize individual documents contained in the Part I or II.
1. The proposal should result in a definite reduction in If
the time required by EPA to audit a Part I or II —
especially a reduction in the time required after
Part II submission to get a certificate.
-------
-89-
COMPUTERIZATION OF THE December 12, 1977
APPLICATION FOR CERTIFICATION
2. The computerization should permit Ford and EPA
(if possible) to internally reduce the amount of
manual transcription of data from one format to
another different format for presentation. For
example: the computerization of 1978 emission
test log enabled Ford to practically automatically
generate FEDV packages, DF's and EPA Official
Test Result sheets. This was possible because
the latter documents were subsets of the emissions
data base. (In fact, about 5.5 man-weeks were
saved in the preparation of FEDV packages by
computerization.)
3. Where practical, the proposal should result in an
exact definition of the format and nomenclature
required for Part II data submissions. Specifically,
the certification vehicle test logs data should be
transmitted to EPA in a well defined format.
This would help avoid last minute minor changes in
Part II data format. Such changes directly delay
the issuance of a certificate and generate extra
paper work.
4. The computer should not be used to generate docu-
ments which can be more easily and cheaply manu-
ally prepared. For example: the emissions
systems warranty, statement of device safety, and
training statements are examples of documents
containing qualitative information that rarely
changes.
5. The computerization proposal should result in the
establishment of a data base by which additional
secondary statistical studies or problem searches
can be made. For example: the Ford durability
data vehicle maintenance was computerized so that
we could more easily do oil economy studies or
collect data on the repeated concurrence of
unscheduled maintenance. Also, the computeriza-
tion of the durability test data has enabled us to
more easily compute DF's as well as perform a
multitude of studies concerning alternative ways
for calculating the DF.
Internal Benefits Obtained By
Ford's Computerization of Part II
The computerization of the 1978 durability vehicle test and
-------
-90-
COMPUTERIZATION OF THE December 12, 1977
APPLICATION FOR CERTIFICATION
maintenance log plus 1978 emission vehicle test log has resulted
in the following internal benefits to Ford:
It saved at least 5.5 man-weeks via the computer pre-
paration FEDV packages. (2.5 hours saved per package
times 88 packages submitted to EPA for 1978 MY)
It enriched jobs by substantially reducing the repeated
clerical transcriptions of the same data on the differ-
ent forms.
It reduced typing of data logs by up to 50%.
It reduced by 5 0% the time required to update the logs
for a vehicle involved in back-to-back testing.
It improved the accuracy of the predicted value for
the durability data vehicle DF.
It helped us to reduce the amount of time required to
generate other management reports.
It substantially reduced the amount of overtime re-
quired to update the Part II.
It has eliminated the need to manually prepare a
separate additional test log, DF data sheet, and
Official Test Result Sheet for submission to CARD. In-
stead, these documents are generated by the computer.
These separate sheets result frcm CARB's unique
rounding, outlier and non-methane regulations.
It has avoided the extra expenses associated with pre-
printing data log and other Part II forms.
-------
-91-
Appendix
The three day workshop consisted of four sessions, introductory
presentations, and a closing discussion.
The Agenda and the list of attendees follows:
-------
-92-
APPENDIX
AGENDA
EPA-INDUSTRY WORKSHOP ON
CERTIFICATION PAPERWORK REDUCTION
December 12, 13, and 14
DECEMBER 12
Session I
9:00 - 9:15 Introduction
9:15 - 10:30 Present Certification Program
Organization, Informational Requirements ¦
EPA - R. E. Harrington
10:30 - 10:45 Break
10:45 - 11:30 Use of Automatic Data Processing
EPA - Linda Tucker
11:30 - 1:15 Lunch
Session II
1:15 - 3:00 Standard Indexing and Terminology in the
Certification Program
Chairperson: G. Dana, EPA
Supporting Manufacturers: Ford, GM, Cunmins
3:00 - 3:15 Break
3:15 - 5:00 Continue topic from early afternoon session
DECEMBER 13
Session I
9:00 - 10:30 Sequenced Submission of the Standard
Application for Certification
Chairperson: Virginia Sink, Chrysler
EPA Contact: B. Patok
10:30 - 10:45 Break
10:45 - 12:00 Continue topic from morning session
12:00 - 1:15 Lunch
-------
December 13 (continued)
-93-
Sesslon II
1:15 - 3:00 Referencing within the Application
Co-Chairpersons: W. Kostin, C. Doherty, Ford
EPA Contact: J. Thomson
3:00 - 3:15 Break
3:15 - 5:00 Continue topic from early afternoon session
DECEMBER 14
Session I
'9:00 - 10:30 Computerization of the Certification Process
Chairperson: G. Gruska, GM
EPA Contacts: L. Tucker
10:30 - 10:45 Break
10:45 - 12:00 Continue topic from morning session
12:00 - 1:15 Lunch
Session II
1:15 - 3:00 Summary Discussion
Streamlining the Certification Process
Subject Areas for Future Meetings
Discussion Leaders: E. 0. Stork
R. E. Harrington
3:00 - 3:15 Break
3:15 - 5:00
Continue topic from early afternoon session
-------
-94-
APPENDIX
EPA-INDUSTRY WORKSHOP ON
CERTIFICATION PAPERWORK REDUCTION
December 12, 1977
Participant List
Topic 1: Standard Indexing and Terminology in the Certification
Name
Representing
Greg Dana, Chairperson
Virginia Sink
R. C. Smith
Gene Bolton
Merle Liskey
M. Robert Wilson
Bill Kostin
W. Henny
B. Patok
Gregory Gruska
Mark Wolcott
R. Nunez
Karl Weber
Richard Mazur
Les Ryder
M. Stasikowski
R. E. Harrington
Chrysler Corporation
EPA
EPA
General Motors Corporation
American Motors
General Motors Corporation
Ford Motor Company
Cummins Engine Company, Inc.
EPA
General Motors Corporation
EPA
Chrysler Corporation
Mercedes Benz
EPA
EPA
EPA
EPA
-------
-95-
EPA-INDUSTRY WORKSHOP ON
CERTIFICATION PAPERWORK REDUCTION
December 13, 1977
Participant List
Topic 2: Sequenced Submission of the Standard Application for Certification
Name
Virginia Sink .Chairperson
R. C. Smith
T. Hiramatsu
D. Bonawitz
Gene Bolton
Merle Liskey
M. R. Wilson
Bill Kostin
B. Patok
M. Wolcott
Karl Weber
Richard Mazur
Les Ryder
M. Stasikowski
R. E. Harrington
John Goodman
J. G. Quick
Fred Maloney
Representing
Chrysler Corporation
EPA
Toyota
Toyota
General Motors Corporation
American Motors
General Motors Corporation
Ford Motor Company
EPA
EPA
Mercedes Benz
EPA
EPA
EPA
EPA
Ford Motor Company
Ford Motor Company
Chrysler Corporation
-------
-96-
EPA-INDUSTRY WORKSHOP ON
CERTIFICATION PAPERWORK REDUCTION
December 13, 1977
Participant List
Topic 3: Referencing within the Application
Name
Bill Kostin, Chairperson
R. C. Smith
J. Thomson
T. Hiramatsu
D. Bonawitz
Gene Bolton
Merle Liskey
M. R. Wilson
Virginia Sink
Hugh Daugherty
B. Patok
M. Wolcott
Karl Weber
Richard Mazur
Les Ryder
M. Stasikowski
R. E. Harrington
B. W. Schoner
Fred Maloney
Ronald Finney
Representing
Chrysler Corporation
EPA
EPA
Toyota
Toyota
General Motors Corporation
American Motors
General Motors Corporation
Ford Motor Company
Cummins Engine Company, Inc.
EPA
EPA
Mercedes Benz
EPA
EPA
EPA
EPA
BMW
Chrysler Corporation
Ford Motor Company
-------
-97-
EPA-INDUSTRY WORKSHOP ON
CERTIFICATION PAPERWORK REDUCTION
December 14, 1977
Participant List
Topic 4; Computerization of the Certification Process
Name
G. Gruska, Chairperson
R. C. Smith
A. Gioia
Gene Bolton
S. V. Yumlu
Bill Kostin
Vito Laudicina
L. M. Tucker
B. Patok
Virginia Sink
Mark Wolcott
Karl Weber
Richard Mazur
Les Ryder
M. Stasikowski
R. E. Harrington
John Kargul
H. J. Murawski
D. M. Buck
John Goodman
Representing
Chrysler Corporation
EPA
General Motors Corporation
General Motors Corporation
Mack Trucks, Inc.
Ford Motor Company
Cummins Engine Company, Inc.
EPA
EPA
General Motors Corporation
EPA
Mercedes Benz
EPA
EPA
EPA
EPA
EPA
Ford Motor Company
Ford Motor Company
Ford Motor Company
-------
-98-
EPA-INDUSTRY WORKSHOP ON
CERTIFICATION PAPERWORK REDUCTION
December 14, 1977
Participant List
Topic 5: Discussion
Name
E. 0. Stork, Discussion Leader
R. C. Smith
D. Bonawitz
Gene Bolton
M. R. Wilson
S. V. Yumlu
L. M. Tucker
B. Patok
Greg Gruska
Mark Wolcott
Karl Weber
Richard Mazur
Les Ryder
M. Stasikowski
R. E. Harrington
Virginia Sink
Bernard Steinhoff
D. M. Buck
Representing
Chrysler Corporation
EPA
Toyota
General Motors Corporation
General Motors Corporation
Mack Trucks, Inc.
EPA
EPA
General Motors Corporation
EPA
Mercedes Benz
EPA
EPA
EPA
EPA
EPA
Mercedes Benz
Ford Motor Company
-------
-99-
APPENDIX
EPA-INDUSTRY WORKSHOP ON
CERTIFICATION PAPERWORK REDUCTION
December 12, 13, 14, 1977
Final List of Attendees
Name
Representing
Eni Amito
J. F. Beddow
H. Eugene Bolton
Victor Bolton
Dan Bonawitz
Harold Borne
John W. Bozek
DeWayne M. Buck
Robert V. Cervenka
Daryl J. Chupa
C. Cole
Gene Crombez
Greg Dana
Hugh Daugherty
D. E. David
Roy Dennison
Mike Ellmann
Ronald Finney
Anthony J. Gioia
John Goodman
Gregory Gruska
R. M. Gulau
J. C. Hafele
Pawel Hans-H
Richard M. Hardesty
D. Hardin
R. E. Harrington
Willi Henny
Takamichi Hiramatsu
Cliff Hirano
Saburo Hori
Kenneth Johnston
John Kargul
Bob Kendall
James Kerns
Peter E. Kohnken
W. A. Kostin
H. Kusano
Bob Larson
Vito A. Laudicina
Merle E. Liskey
Albert G. Lucas
American Honda
Ford Motor Company
General Motors - EAS
Kawasaki Motors Corporation
Toyota
Ford Motor Company
Environmental Protection Agency
Ford Motor Company
Subaru
Ford Motor Company
Environmental Protection Agency
Chrysler Corporation
Environmental Protection Agency
Cummins Engine Company, Inc.
Kawasaki Motors Corporation
U. S. DOT, NHTSA
Environmental Protection Agency
Ford Motor Company
General Motors Corporation
Ford Motor Company
General Motors Corporation
Ford Motor Company
Caterpillar Tractor Company
Volkswagen Wolfsburg
U.S. EPA
Environmental Protection Agency
Environmental Protection Agency
Cummins Engine Company, Inc.
Toyota
Yamaha
Checker Motors Corporation
Environmental Protection Agency
Environmental Protection Agency
Mack Trucks
Ford Motor Company
Environmental Protection Agency
Ford Motor Company
Mitsubishi Motors Corporation
Environmental Protection Agency
Cummins Engine Company, Inc.
American Motors Corporation
General Motors Corporation
Dates
Attended
13
14
12
-
13
-
14
12
-
13
-
14
12
-
13
12
-
13
-
14
14
12
-
13
-
14
13
12
-
13
-
14
14
14
14
12
-
13
12
-
13
-
14
12
-
13
12
-
13
-
14
12
-
13
-
14
13
12
-
13
-
14
13
-
14
12
-
13
-
14
14
12
-
13
-
14
12
-
13
-
14
12
-
13
-
14
14
12
-
13
-
14
12
-
13
-
14
12
-
13
-
14
12
-
13
13
-
14
12
-
13
-
14
12
12
13
13
-
14
12
-
13
-
14
12
14
14
12
-
13
-
14
-------
-100-
Final List of Attendees (continued)
Name
Representing
Dates
Attended
Richard H. Lucki
Peugeot
12
-
13
-
14
Fred Maloney
Chrysler Corporation
13
Frank Maloziec
Fiat R&D
12
14
W. J. Martin
International Harvester
12
Jim Marzen
Environmental Protection Agency
12
-
13
-
14
Richard Mazur
Environmental Protection Agency
12
-
13
Henry J. Murawski
Ford Motor Company
12
-
13
-
14
Lawrence Murray
Environmental Protection Agency
12
-
13
Kaznynki Nakamura
Honda
13
Roy Nelson
Chrysler Corporation
14
Richard R. Nunez
Chrysler Corporation
12
L. Lawrence Nutson
Volkswagen-Audi
12
Daniel C. Pasquantonio
Chrysler Corporation
13
-
14
Bernie Patok
Environmental Protection Agency
12
-
13
-
14
J. G. Quick
Ford Motor Company
13
T. N. Ronayne
American Motors Corporation
14
Les Ryder
Environmental Protection Agency
12
-
13
Dr. Manfred Schlawne
Daimler-Benz
14
John Schmidt
Harley-Davidson
12
-
13
-
14
Mike Schmitt
Yamaha Motor Corporation
12
-
13
B. W. Schoner
BMW of North America
12
-
13
-
14
E. Schubarth
Audi
12
-
13
-
14
Helmutti Schweitzer
Daimler-Benz
14
Donald M. Schwentker
AIA
14
Bert Searing
Motor Vehicle Mfgrs. Assn.
14
M. Virginia Sink
Chrysler Corporation
12
-
13
-
14
Robert C. Smith
MSAPC, EPA
12
-
13
-
14
Margaret Stasikowski
Environmental Protection Agency
12
-
13
-
14
Bernard Steinhoff
Mercedes Benz of North America
12
-
13
-
14
E. 0. Stork
Environmental Protection Agency
14
Ken Takahashi
Nissan
12
-
13
-
14
John C. Thomson
Environmental Protection Agency
12
-
13
-
14
Linda M. Tucker
Environmental Protection Agency
12
-
13
-
14
C. D Tyree
Environmental Protection Agency
14
L. D. Verrelli
Environmental Protection Agency
12
-
13
-
14
Karl Weber
Mercedes Benz
12
-
13
-
14
G. D. White
Ford Motor Company
12
14
M. Robert Wilson
General Motors Corporation
12
-
13
Mark Wolcott
Environmental Protection Agency
12
-
13
-
14
S. V. Yumlu
Mack Trucks, Inc.
12
K. N. Ziwich
BMW of North America
14
Total Attendance for 3-day Period:
83
Attendance - Monday, December 12
Tuesday, December 13
Wednesday, December 14
56 - 67% of total attendance
57 - 69% of total attendance
62 - 73% of total attendance
82% of Monday's attendees returned on Tuesday (including 10 new registrations)
72% of Tuesday's attendees returned on Wednesday (including 16 new registrations)
------- |