United States        Air and Radiation        EPA420-R-01-032
           Environmental Protection                  April 2001
           Agency                       M6.EXH.009
vxEPA     Determination of CO Basic
           Emission Rates, OBD and
           I/M Effects for Tier 1 and
           Later LDVs and LDTs
                                  > Printed on Recycled Paper

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                                                               EPA420-R-01-032
                                                                      April 2001
                and I/M            for       1  and
                                    and

                              M6.EXH.009
                               Edward L. Glover
                                 John Koupal

                        Assessment and ModelingDivision
                     Office of Transportation and Air Quality
                      U.S. Environmental Protection Agency
                                  NOTICE

   This technical report does not necessarily represent final EPA decisions or positions.
It is intended to present technical analysis of issues using data, that are currently available.
        The purpose in the release of such reports is to facilitate the exchange of
     technical information and to inform the public of technical developments which
       may form the basis for a final EPA decision, position, or regulatory action.

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1.0    Introduction

       This document (M6.EXH.009) describes the methodology, data analysis and results of the
process used to develop basic CO emission factors, OBD (On-board Diagnostics n) effects, and
I/M (Inspection / Maintenance) credits for Tierl, TLEV (Transitional Low Emitting Vehicle),
LEV (Low Emitting Vehicle), ULEV (Ultra Low Emitting Vehicle) vehicles (referred
collectively throughout the document as Future Standards Vehicles (FSV) for MOBILE6. The
document "Determination of NOx and HC Basic Emission Rates, OBD and I/M Effects for Tierl
and Later LDVs and LDTs" (M6.EXH.007) shows the analogous methodology and the results for
NOx and HC pollutants for the FSVs.  These vehicles are current and future model year cars and
light trucks which must meet increasingly stringent tailpipe exhaust emission limits.  Of the four
types, the first three types (Tierl, TLEV and LEV) are held to the same numerical CO standards.
The fourth type (ULEV) meet a more stringent CO standard which is 50 percent of the Tierl
standard.

       Table 1 shows the emission standards limits in grams per mile for each vehicle type and
standard.  The limits in units of grams per mile are shown for the 5 year / 50,000 mile
certification point.  The other important parameter in regards to the certification standards is the
model year implementation schedule for all of the standards. This is the percentage of a particular
model year and vehicle class that will be required to be certified to the lower standard. This
schedule can be found in EPA document EPA420-B-98-001 "Exhaust Emission Certification
Standards". It is available on the EPA-OMS website.  The current website address is
"http://www.epa.gov/oms/stds-lh.htm"

       This document (M6.EXH.009) also provides a brief explanation of the derivation of CO
start and running emissions for all FSV classes (i.e., Tierl, TLEV, LEV and ULEV).  Results are
also provided in tabular and graphical form. A more detailed explanation of the concept of start
and running emissions and their derivation can be found in "Determination of Running
Emissions as a Function of Mileage for 1981-1993 Model Year Light-Duty Cars" (M6.EXH.001)
and "Determination of Start Emissions as a Function of Mileage  and Soak Time for 1981-93
Model Year Light-Duty Vehicles" (M6.STE.003).

       This document (M6.EXH.009) also explains the I/M credit methodology for 1994 and
later model year vehicles, and discusses the algorithm used to predict OBD effectiveness. This
OBD algorithm assumes:  (1) that 1996 and later cars are equipped with an onboard electronic
diagnostic (OBD)  system, but that 1994 and 1995  model year vehicles are not equipped; (2) that
the OBD system continuously monitors the performance of the car's emission control system,
and detects serious problem(s) which cause the vehicle's FTP emissions to exceed 1.5 times its
applicable certification standards, and (3) when such problems are detected, a code is registered
in the car's computer and a dashboard warning light is turned on to notify the owner.

       The I/M methodology presented in this  document for FSVs (M6.EXH.009) is similar to
the I/M methodology for 1981-93 model year vehicles presented in EPA  document M6.EVI.001.
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The two methodologies differ because of the presence of OBD and the different emission
standards for the FSVs. Also, a central I/M assumption for the OBD equipped vehicle fleet
(1996+ model years) is that OBD tests will be performed in I/M stations, and that these OBD
tests may eventually replace traditional emission tests for the 1996 and later model years. In
contrast, the I/M methodology for the 1981-93 model years is based strictly on the use of
traditional exhaust measurement tests.
Table 1
Tierl. LEV and ULEV CO Emission Certification Standards
(gram/mile units at 50K miles except where noted)
Veh Type
LDV
LDT1
(<6000GVW
<3750 Loaded Wt)
LDT2
(<6000GVW
>3750 Loaded Wt)
LDT3
(>6000GVW
<3750 Loaded Wt)
LDT4
(>6000GVW
>5750 Loaded Wt)
TierO
3.4
3.4
10.0*
9 o**
9 o**
Tierl
3.4
3.4
4.4
4.4
5.0
LEV
3.4
3.4
4.4
4.4
5.0
ULEV
1.7
1.7
2.2
2.2
2.5
* 100K mile Standard
** 50K mile Standard
       Most Tier 1 and later vehicles will be equipped with an OBD system and, if in an I/M
area, subject to OBD-based I/M rather than traditional exhaust I/M. However, some Tier 1
vehicles will not be equipped with OBD (model years 1994 and 1995), and some OBD-equipped
vehicles will be subject to an  exhaust I/M program (prior to calendar year 2001). Basic emission
rates are therefore required for the following cases, and are presented in this report:
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       No OBD/No IM (Base)  applies to pre-OBD Tier 1 vehicles (1994 and 1995 model
       years).  It is also used as a basis for the computations of BERs with OBD and/or OBD-
       based I/M.
       OBD-Only (OBD/ No IM) applies to 1994 and later OBD equipped vehicles where an
       I/M program is not present.

       OBD/IM applies to 1994 and later OBD equipped vehicles where an I/M program which
       conducts OBD checks is present.  An exhaust test may or may not be performed; it is not
       differentiated from an I/M program with both OBD checks and exhaust testing, since
       additional I/M reductions are not given for exhaust testing if OBD checks are performed.

       Exhaust I/M / OBD represents a situation in which an exhaust I/M test is conducted in an
       I/M program on vehicles which are equipped with OBD,  but the OBD I/M test is not
       performed. This situation can only occur on 1996 and later model year vehicles equipped
       with OBD, and subject to an exhaust I/M test.  It is a likely scenario until at least calendar
       year 2001 when the EPA approved OBD I/M test is expected to be available.

       Exhaust I/M / No OBD represents a situation in which only an exhaust I/M test is
       conducted in an I/M program (an EVI240, ASM, or Idle test). This scenario will apply
       only to the 1994 and 1995 model year vehicles which are not equipped with OBD
       systems.
2.0    Basic Emission Rate Derivation Concept

       The basic concept underlying the generation of Tier 1 and later BERs is similar to the
approach used to develop the I/M credits for 1981 through 1993 vehicles.  For the No OBD/No
EVI case, this concept segregates in-use vehicles into "normal" and "high" emitters.  High
emitters are those vehicles which have emission control systems which are malfunctioning in
some way, and are producing average emission levels which are considerably higher than the
overall mean emission levels; the threshold for defining a high emitter for CO is 3.0 times the
intermediate life (50,000 mile) certification emission standard.  The remainder of the fleet are
considered to be properly functioning, and are considered normal emitters; by definition, these
vehicles are below 3.0 times the intermediate life certification standard.  It is important to note
that all pollutants are considered independently when determining whether a vehicle is a high
emitter. Thus, a vehicle could be a high CO emitter, but a normal HC emitter.

       Although the segregation of vehicles into the "normal" and "high" categories (and their
thresholds) is a somewhat arbitrary modeling method, the concept that average in-use emissions
are driven by a group of vehicles emitting well above the applicable standard is supported by data
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from many years of EPA vehicle test and repair programs, as well as the bimodal nature of
emission control technology functioning (e.g., EGR valves, air pumps, and oxygen sensors
generally function correctly or not at all).  Two important assumptions in the development of
BERs for Tier 1 and later vehicles are a) the rate at which vehicles malfunction and become high
emitters is independent of the certification standard level, and b) the average emission levels for
high emitters becomes higher relative to the standard as the certification standard becomes
lower.

       The overall fleet emission factor is computed as a weighted average of the high and
normal emitters. Figure 1 is a general graphical view of the concept with the y-axis representing
emissions in grams per mile (grams for start emissions), and the x-axis representing mileage
and/or age. Age and mileage are related in that a specific mileage is associated with each age.
Three lines are shown in Figure 1 which show a) the average or basic emission rate, b) the
normal emitter emission rate, and c) the high emitter emission level.
                                        Figure 1
               GENERAL EMISSION FACTOR SCHEMATIC
        EMISSIONS
                                         MILEAGE
       The basic emission rate is shown as Line A. This line represents the average emissions of
the fleet as a function of both the normal vehicles and the high emitting vehicles.

       Line B represents the average emissions of the normal-emitting vehicles. These are the
vehicles which have emission control systems which are generally performing as designed. The
line is shown as a linear function of mileage and/or age to reflect the gradual deterioration that
normal vehicles experience, primarily due to catalyst degradation over the life of the vehicle.  It
was derived from a least squares linear regression of emissions versus mileage.
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       Line C represents the average emissions of high-emitting vehicles.  This line is a flat
horizontal line because emissions from these vehicles do not appear to be a strong function of
mileage and/or age, based on previous analysis of Tier 0 data.  The underlying phenomena
expressed here is that emission control malfunction will lead to high emissions regardless of
vehicle mileage; as discussed in subsequent sections, what changes as the vehicle ages is the
probability of malfunction, rather than the emission levels resulting from a malfunction.

       Line A represents the weighted average of lines B and C, based on appropriate weighting
factor for normal and high emitters. On a fleet-wide basis, these weighting factor represent the
fraction of high emitters in the fleet, as a function of vehicle age; on a per-vehicle basis, this
weighting factor can be considered to be the probability the vehicle will be a high emitter at a
given age.  This weighting factor can be derived at any given vehicle age A by transforming
Equations 1 and 2 into Equations 3 and 4.

Where:

Highs = fraction of High emitters, age = A
Normals = fraction of Normal emitters, age =A
AVE is the average emission rate, age = A
High_ave is the high emitter emission average (independent of age)
Norm_ave is the normal emitter emission average, age = A

       Highs + Normals = 1                                                Eqn 1

and

       AVE = High_ave * Highs + Norm_ave * Normals                       Eqn 2

Solving for the variables Highs and Normals produces:

       Highs = (AVE - Norm_ave) / (High_ave - Norm_ave)                  Eqn 3

       Normals = 1 - Highs                                                Eqn 4
3.0    CO Emission Methodology



3.1    Normal Emitter Emission Level

3.1.1   Overview

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       This section discusses the methodology and assumptions used to generate the basic CO
emission factors and CO I/M credits for FSVs.  A brief overview of the methodology is as
follows:

1.      Normal emitter running and start CO emission levels were calculated from 1994 and later
       vehicle FTP test results collected in an EPA test program. These data were used to
       calculate the zero mile emission level of normal vehicles.

2.      CO emission deterioration of 1994+ model year normal emitters was assumed to be the
       same as the deterioration of the 1988-93 model year PFI normal emitting vehicles.

3.      The average CO emissions  of a 1994+ High emitter was assumed to be the same as the
       average CO emissions from a 1988-93 model year High emitter.

4.      The fraction of high emitters in the fleet for NO OBD / NO I/M, and OBD and I/M cases
       were calculated.

5.      The OBD and I/M assumptions were applied to generate a 'with I/M' emission line.

6.      The ratio of certification standards between Tierl and ULEV was calculated, and applied
       to the zero mile normal emitter CO emission level to reduce the zero mile level for
       ULEVs.

7.      A summary of the important parameters such as normal emitter zero mile and
       deterioration rates, high emitter emission levels and after repair emission levels are
       shown in Table A-l.

       Each of these steps is discussed in detail in the sections below.
3.1.2   Normal Emitter Data
       The data sample used to develop the normal emitter emission levels consisted of test
results from 128 cars and 108 light trucks with model years 1994 through 1998.  It was collected
by EPA as part of its regular emission factor testing program.  This program recruits in-use
vehicles from the general public, and subjects them to a battery of tests that include the FTP.
This sample is not truly random, because of the recruitment process used by EPA and the
potential for outliers (High emitters) to self-select themselves out of the program. This self
selection bias has been thought to exist in past test programs, and can lead to understating of
average emission levels.  In this case however, the effect of any selection bias should be quite


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minor due to the young age of the vehicles, the low emission level of the vehicles (only normal
emitters were selected), and the difficulty of the motorist to create a bias by determining outlier
status in advance of recruitment and testing.  As a result, this sample is thought to be reasonably
representative of in-use emission behavior of vehicles with low mileage.

       This sample contained a mixture of Tierl and TierO certified vehicles (mostly Tierl).
Unfortunately, it contained no TLEV, LEV or ULEV certified vehicles because these are not
currently present in the regular fleet.  Thus, in the MOBILE6 model, LEV vehicles will be
considered to be equivalent to Tierl vehicles in terms of CO emissions.  ULEVs will be given a
slightly different treatment since their certification standard limits are half (more stringent) than
those of Tierl and LEV vehicles.

       The EPA data sample was split into normal  emitters and high emitters based on FTP CO
emission levels. Vehicles with CO emission levels less than three times their certification level
were judged to be normal emitters. Because most of the tested vehicles were new, virtually the
entire sample consisted of normal emitters.  The FTP CO emissions as a function of mileage are
shown graphically in Figures 2 and 3 for the car and truck data samples.

       The approach of reducing only the normal emitter emission levels between TierO, Tierl
and LEV is fairly conservative. It assumes only small CO emission benefits will accrue due to
technology changes designed to reduce HC emissions.  It also assumes that high CO emitters
(vehicles with malfunctions) will have as high CO emissions as the high TierO CO emitters.
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                       Figures 2 and 3
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July 26, 2001

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3.1.3   Tierl and LEV Vehicles

       The goal of this analysis was to use the 1994 and later vehicle data to develop the basic
CO emission factors for the normal emitting Tierl, LEV and ULEV vehicles. Originally, a
simple least squares regression of the emission results versus mileage was to be used. This
would produce a zero mile emission level and a deterioration rate versus mileage that could be
applied in the MOBILE6 model.

       Vehicle data from the FTP cycle were available, and were separated into running LA4
(Running emissions) and start emission using the method described in EPA document "The
Determination of Hot Running Emissions from FTP Bag Emissions"(M6.STE.002).  The running
and start emission data were least squares regressed versus mileage to produce the zero mile
emission level and deterioration rate (slope) for normal emitters. These values are shown in
Appendix B in the Statistical Diagnosis Section.  The results from this regression were not used
in the MOBILE6 model.  The zero mile emission values were not used  in the analysis because
the running emissions were found to be statistically not significant at a  95% confidence level or
even an 80% confidence level. The CO start emission zero mile regression level was statistically
significant, but was not used to keep consistency between the running and start emissions. The
regression slope was not used to predict the deterioration of the Tierl and later vehicle because
of the relatively low mileage levels of the vehicles in the sample. Its use would have required
complete extrapolation above 80,000 miles for cars and 100,000 miles for trucks.

       Instead the data were sub-grouped into a sample of normal emitters which had odometer
readings less than 25,000 miles, and the mean CO values for each car and truck sub-group were
determined. These mean CO values were used as the zero mile emission level of the Tierl and
LEV normal emitting vehicles.  The values are shown below in Equations 5a-d and 6a-d, and in
summary form in Table A-l, and in statistical output form in Appendix C. For comparison, the
difference between the zero mile CO emissions obtained from the two methods is fairly slight in
absolute emission terms. For example, for running LA4 CO emissions  from cars the regression
zero mile level is 0.117 g/mi CO, and the mean CO of vehicles with less than 25,000 miles is
0.282 g/mi. This compares with a value of 0.48 g/mi running LA4 CO  for the 1988-93 model
year PFI (ported fuel injection) vehicles.

       The CO deterioration rate for the 1994+ model year vehicles was assumed to be the same
as the deterioration rate for the 1988-93 model year PFI vehicles (see EPA report - MOBILE6
"Inspection / Maintenance Benefits Methodology for 1981-93 Model Year Vehicles"). This
assumption was made because EPA believes that the broader mileage range and larger sample
size of 1988-1993 PFI vehicles better represents fleet CO deterioration  than the newer low
mileage sample.  The combined effect of using the mean CO emission level of low mileage
vehicles in the sample to represent the zero mile emission level of the FSVs, and the
deterioration rate of the 1988-93 model year PFI vehicles to represent the in-use deterioration
estimate of FSVs is to: (1) assume that the lowering of HC standards in response to Tierl and
later requirements (CO standards were not changed) will reduce new vehicle CO emissions
slightly, but (2) that the long term deterioration levels will remain the same as the 1988-1993

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model year vehicles.

      Equations 5a-d are the equations used to model the CO running emissions from 1994 and
later model year normal emitters.  The variable 'odom' is in units of ten-thousand miles.
Equation 5a shows value of the normal emitter CO running emissions from cars; Equation 5b is
the analogous one for trucks. Both are in units of grams per mile.  Equation 5c shows value of
the normal emitter CO start emissions from cars; Equation 5d is the analogous one for trucks.
Both start emission equations are in units of grams per start.
Running Cars:
Norm_Ave(g/mi)
5a
Running Trucks:     Norm_Ave(g/mi)
5b
0.2821 + 0.2293 * odom
                          0.3219+ 0.2678* odom
Eqn


Eqn
Start Cars:
Norm_Ave(g/strt)
15.176 + 0.0703 *odom
Eqn
5c
Start Trucks:
Norm_Ave(g/strt)
21.884+ 0.1680* odom
 Eqn
5d
3.1.4  ULEV Vehicles

      The normal emitter running and start CO emission levels of ULEVs are the same as the
normal emitter running and start emission levels of the Tierl and LEVs, except the zero mile
levels are 50 percent less. The 50 percent reduction was used because the ULEV standards are
numerically half of those of the LEVs. The actual values are shown in Equations 6a through 6d.
Running Cars:       Norm_Ave(g/mi)
                   6a
                          0.1411 + 0.2293 *odom
                                 Eqn
Running Trucks:     Norm_Ave(g/mi)
                          0.1609+ 0.2678* odom
                                 Eqn
                                6b
Start Cars:
Norm_Ave(g/strt)
7.588 + 0.0703 * odom
Eqn
6c
Start Trucks:
Norm_Ave(g/strt)
10.942+ 0.1680* odom
 Eqn
6d
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                   July 26, 2001

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       The Truck4 category also has a different certification standard than the Truck2 and
Trucks vehicles. Since no Truck4 data were available, its zero mile normal emitter CO emission
level was determined by applying the ratio of the Truck4 and Trucks certification standards to
the Truck2/3 zero mile CO emission value. The values for the heavier Trucks are shown in
Table A-1

       The rationale for reducing the zero mile level of the ULEVs proportionally to the standard
is that basic emission levels for properly operating vehicles should receive some benefit of
reduced standards for lower standard levels.  This approach assumes that brand new normal
emitters for the ULEV standards will on average achieve the same compliance margin
("headroom") as the normal emitters observed in the sample.

3.2    High Emitter Emission Level

       High Emitter basic CO emission rates (BERs) are meant to estimate emissions from
vehicles that significantly exceed their certification standards due to malfunctioning emission
control systems.  A key assumption in the development of high-emitter CO BERs is that, as HC
and NOx emission standards are lowered for Tierl and LEV classifications (CO standards are not
changed until ULEV), emission levels for CO high emitters will not change relative to the
performance of the TierO High CO emitters.  The rationale for this assumption is since emission
control equipment on these high emitters will be degraded or completely malfunctioning,  they
will emit largely independent of their certification  standard level. To illustrate, compliance with
the 3.4 g/mi CO standards is primarily a function of the effectiveness of a vehicle's fuel delivery
system control. Thus, vehicles which have become High CO emitters due to a loss of fuel
delivery system control are expected to have similar CO emission performance regardless of
whether they are TierO, Tierl, or LEV certified. This assumption may not apply to ULEV
certified vehicles, since their certification level is reduced by 50 percent from the LEV level,  and
different technologies may be used to control emissions on these vehicles. Nevertheless, this
assumption is being extended to the  ULEVs since there are no in-use data available on high
emitting ULEVs.

       The FTP high emitter average CO emission levels used for the  1994 and later model years
are the same values used for the 1988-93 model year PFI vehicles (cars and trucks have separate
values). These values for Running and Start emissions for cars and trucks are shown in
Equations 7a through 7d.  These values will be used for all 1994 and later model years including
Tierl, LEV and ULEV vehicles.
Running Cars:       High_Ave(g/mi)     =      36.106                            Eqn
                                                                                 7a

Running Trucks:     High_Ave(g/mi)     =      33.283                            Eqn
                                                                                 7b
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Start Cars:           High_Ave(g/strt)     =     38.060                            Eqn
                                                                                 7c

Start Trucks:         High_Ave(g/strt)     =     83.862                            Eqn
                                                                                 7d
       These extrapolations from TierO vehicles could not be reliably verified from the relatively
small 1994+ data sample, since only one High emitter was present in the 1994-1998 model year
sample. However, this vehicle's FTP emissions were quite high at 215 g/mi CO.
3.3    High Emitter Fractions - No OBD / No I/M

       This section describes the fraction of high emitters in the fleet given the base case of no
OBD and No I/M.  The numerical values are the same as the no I/M high emitter fractions of the
1988-93 PFI vehicles, and were derived from the general Equation 3 with TierO values. The rate
at which vehicles become high emitters under the No OBD / No EVI scenario was also assumed
constant for all standard classes. The age-based high emitter fractions for Tierl and later
vehicles are shown in Appendix A.  These values are referred mathematically as HighBASE(i) in
subsequent calculations.

       Reduced CO certification standards are not expected to influence the rate at which
emission control technology malfunctions, because a) manufacturer's design and durability
practices are not expected to differ between TierO and later standards, and b) many cases of
emission control degradation and/or malfunction are owner-induced, outside the manufacturer's
liability for in-use emission performance, and unlikely to change due to the new standards.
Separate rates of emission control technology malfunction were used for LDVs and LDTs, only
because separate car and truck rates were used for the 1988-93 model year PFI vehicles.
3.4    High Emitter Fraction - OBD and OBD I/M
       Separate BERs were developed for all standards and vehicle classes to account for the
effects of OBD and OBD-based I/M programs.  The methodology used to account for these
programs is based on reducing the fraction of high emitters in the fleet from the No OBD/No EVI
case.  Thus, emission levels for normal and high emitters were not changed under these
programs, only the fraction of highs in the fleet. This methodology introduces a new category of
vehicle into the fleet: "Repaired" emitters. These vehicles are high emitters that are flagged by
an OBD system and undergo successful repair. For the OBD-only and OBD/EVI cases, these
vehicles are treated distinctly from normal and high emitters.
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       OBD effectiveness is defined by three parameters: a) the probability the OBD system will
detect a failure (MIL-on Rate), b) the probability an owner will respond to a MIL-on (Response
Rate), and c) the average after-repair emission level for responding vehicles (Repair Level). At
the time of this analysis, sufficient in-use data were not available to empirically determine in-use
patterns for these parameters. Thus, assumptions were developed for the projected likelihood of
malfunction detection, owner response and repair level.
3.4.1   MIL-on Rate

       For all vehicle classes and standards, it is assumed that OBD will detect (i.e., set an
appropriate code and illuminate the MIL) 85 percent of the CO high emitters.  Because high
emitters are defined independently for all pollutants, this response rate is assumed to apply
equally to all  pollutants. The remaining 15 percent of the high emitters will not be identified,
and thus will  remain in the fleet as high emitters. No deterioration in the ability of the OBD
system to correctly identify high emitters is assumed.  Because this parameter is solely
dependent on the vehicle's OBD system, it is the same for I/M and non-I/M areas.
3.4.2   Response Rate

       In order to obtain emission reductions from a vehicle equipped with an OBD system, not
only must the system correctly identify the vehicle, but the motorist must also respond to the MIL
and take corrective action in a timely manner. A key assumption for this analysis is that the
response rate in OBD-based I/M areas (where repair is required) will be much higher than in non-
I/M areas. In OBD-based I/M areas, the MIL-on response rate is assumed to be 90 percent over
the entire life of the vehicle. Response was not set at 100 percent to account for waivers from, or
evasion of,  or delay in responding to the I/M program.

       For non-DVI areas, OBD response is assumed to be a function of vehicle warranty.  It is
assumed that an owner is much more likely to respond to a MIL-on when repairs will be paid for
by the manufacturer.  Three mileage bins were therefore developed: 1) 0 through 36,000, the
standard bumper-to-bumper warranty period; 2) 36,001  to 80,000, for which federal law
mandates that catalysts and electronic control modules (ECMs) remain under warranty; and 3)
above 80,000, for which no warranty is in effect (extended warranties are not accounted for in
this methodology).

       Under 36,000 miles, it is assumed that 90 percent of MIL-on vehicles will be repaired.
This is based on the judgment that for new vehicles still under warranty, owners will have little
hesitation in addressing a MIL-on. The 10 percent loss accounts for a delay in the response rate
and the small percentage of owners who will not respond to a MIL-on even with the warranty
incentive.
    r01032.wpd                     14                                July 26,2001

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       Between 36,000 miles and 80,000 miles, it is assumed that 10 percent of MIL-on vehicles
will be repaired. This response rate is greatly reduced from the pre-36,000 mile level to account
for the discontinuation of warranty coverage on several emission-related components (e.g.
secondary air, EGR, oxygen sensors, fuel injectors), and reduced willingness of owners to make
emission-related repairs on an aging vehicle in the absence of an I/M program.

       Above 80,000 miles, it is assumed that no MIL-on vehicles will be repaired. This
assumption reflects the end of warranties, the lower economic value of the vehicle, and the
(further) reduced willingness of owners to make emission-related repairs in the absence of an I/M
program.
3.4.3   Repair Level

       The emission level after an OBD-induced repair is assumed to be 1.5 times the applicable
50,000 mile certification standard. This creates a third emitter category - "repaired" emitters.
Repaired emitters are assumed to have constant emissions at the repaired level, although a subset
of these vehicles "migrate" back to the high emitter category.  The estimated post-repair level of
1.5 times the standard is the required threshold for illuminating the MIL. This level was chosen
as the after repair emission level (as opposed to a lower value) after considering three issues.
First, although many vehicles will likely be repaired below this level, others undergoing repair
will continue to be higher than 1.5 times the standard due to synergistic effects of multiple
malfunctions which considered independently would not trigger the MIL.  Second, the OBD
malfunction threshold requirement of 1.5 times the standard applies to the applicable full useful
life standard; thus, repairing to 1.5 times the 50,000 mile standard is below the required
threshold between 50,000 and 100,000 miles (in fact, ARB's most recent modification to OBD
for LEVs requires detection at 1.75 times the full-useful standard (100,000 mile standard) at all
mileages, thus increasing the gap between the repair level and MIL threshold). Third, these
vehicles are assumed not to deteriorate for the remainder of their life, unless they migrate into the
high emitter category. Thus, the repair levels can be lower than average normal emitter
emissions at higher mileages.

3.4.4   High Emitter Fractions

       Equations 8 through 10 were used to calculate the high emitter growth rate under the
OBD and OBD-based I/M scenarios (HighOBD and HighhOBDIM).  Overall, the high  emitter fraction
in a given year is a function of a) the number of high emitters in the previous year, b) the base
high emitter "growth rate" in the absence of OBD or I/M, and c) the OBD effectiveness
assumptions outlined in Section 3.4.1  and 3.4.2.  The subscript 'i' is the vehicle age. High(O) is
assumed to be zero. MOBILE6 will assign a value of 'odom'  for each age 'i'.

       Nonhigh(i)          =      1.0-HighBASE(i)                                  Eqn8

       Delta_High(i)       =      HighBASE(i)-HighBASE(i-l)                        Eqn 9

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       Growth_High(i)      =     Delta_High / Nonhigh(i)                         Eqn 10
HighOBD(i)  = HighOBD(i-l) + [(l-OBD)*MIL*Growth_High(i)*(l-HighOBD(i-l))] +
             [(l-MIL)*Growth_High(i)*(l-HighOBD(i-l)]                          Eqn lla
HighOBDIM(i)  =  HighOBDIM(i-l) + [(!-OBDIM)*MIL*GrowthJIigh(i)*(l-HighOBDIM(i-l))] +
                [(!-MIL)*GrowthJIigh(i)*(l-HighOBDIM(i-l)]                       Eqn lib
Where:

HighOBD(0)   =     0.0

HighOBDIM(0)  =     0.0

'MIL'        =     0.85

'OBD' is the OBD response rate; 0.90/0.10/0.0 for mileage bins (0 - 36K), (36K - 80K), and
(80K+), respectively. These are used in conjunction with Equation lla.

'OBDIM'  = 0.90

It is the effectiveness of the OBD I/M program at identifying High emitters, and is set at 90%.  It
is used in conjunction with Equation 1 Ib.
       HighOBD is the fraction of highs in the vehicle fleet equipped with OBD if no I/M program
is present. HighOBDIM is the fraction of highs in the vehicle fleet equipped with OBD if an OBD
I/M program is present.

       A further description of Equations 8 through 1 Ib for a given vehicle age is listed below.
The fraction of high emitters is the sum of the following:

1.      The number of highs from the year before, plus;

2.      The number of MIL-on highs added in that year due to OBD non-response (a function of
       "non-response" rate, MIL-on rate, and the high emitter growth rate applied to the
       available pool of "non-highs" - normals and repaired vehicles), plus;

3.      The number of highs added in that year that the OBD system did not detect (a function of
       MIL-"off' rate and the high emitter growth rate applied to the available pool of "non-
       highs").  The high emitter growth rate for a given year is the absolute increase in high

    r01032.wpd                     16                                July 26,2001

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       emitters under the No OBD / No IM case from the previous year divided by the fraction
       on Nonhigh - i.e., the available pool of vehicles which can become high emitters.
3.4.5   Repaired Fractions

       Once the high emitter fraction is calculated for the OBD or OBD/EVI cases, the fraction of
repaired emitters can be calculated as the difference between the fraction of high emitters that
would occur without OBD or I/M (HighBASE)and the fraction of high emitters with OBD and/or
I/M from Equation 11. In equation form,

Repaired(i)   =     HighBASE (i) - HighOBD (i)                                      Eqn 12
3.4.6   Normal Fractions

       The normal emitters are those vehicles which are not high or repaired emitters. At a
given age, the rate of normal emitters remains constant between the No OBD / No I/M, OBD-
only and OBD/EVI case; only the fraction of high emitters decrease, directly replaced by repaired
emitters. However, over time (as age increases) the fraction of normal emitters decreases due to
the growth in the fraction of high emitters.

       The CO emission emitter fractions for normal, high and repaired emitters for the OBD
Only and OBD/EVI cases are shown in Appendix A by vehicle class.
3.5    High Emitter Fraction - Exhaust I/M and OBD and Exhaust I/M

       For Tierl and later vehicle standards classes, this option contains three possibilities which
depend on vehicle model year and the presence of an exhaust test I/M program and an OBD I/M
program. An exhaust test I/M program refers to any type of exhaust I/M test such as the Idle test,
the Two Speed Idle test, the ASM test or the EVI240 test.

3.5.1   Exhaust I/M/NO OBD

       For Tierl and later vehicles this combination can only occur in the 1994 and 1995 model
years where OBD is not present on vehicles, and an exhaust I/M program is in place. Since this
scenario is really just an extension of the 1981-93 model year (no OBD is present), the same I/M
treatment of high emitters before and after I/M as is used for the 1981-93 model years will be
used.  The reader is encouraged to refer to EPA document M6.EVI.001 for more details.

3.5.2   Exhaust I/M with OBD

       For Tierl and later vehicles this combination can only occur on 1996 and later model year

    r01032.wpd                     17                                July 26,2001

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vehicles equipped with an OBD system. Under this scenario the I/M program conducts an
exhaust I/M test, but does not conduct an OBD I/M test. This is a likely scenario until at least
calendar year 2001 when the EPA OBD I/M guidance is expected to be implemented. The
fraction of fleet high emitters remaining after the I/M test under this scenario is the same as that
presented in Section 3.5.1. It is a function of the stringency of the exhaust I/M test, and uses the
same general treatment discussed in EPA document M6.IM.001. This scenario differs from the
one presented in Section 3.5.1 in the 'before'I/M failure rates or base failure rates. These are
lower than the exhaust I/M / No OBD because of the presence of the OBD systems on the
vehicles.  They are calculated using Equation 1 la.
3.5.3   Exhaust I/M and OBD I/M

       This scenario can exist for 1996 and later model year vehicles equipped with an OBD
system, and subject to both an OBD I/M inspection and an exhaust I/M test.  If an I/M program
should choose to implement this type of program (both OBD and exhaust I/M on the same
vehicles), the after I/M high emitter rate will be the same as the after OBD I/M high emitter rate
calculated in Equation  1 Ib. This assumes that a combined exhaust I/M and OBD I/M program
will be as effective as the OBD I/M only program.   This is not an unreasonable assumption since
the OBD I/M only program is assumed to identify 90 percent of the high emitters, and the
exhaust I/M tests have  identification rates which are in most cases considerably lower.
4.0    Basic Emission Factor Calculations for Various I/M and OBD
       Scenarios

       This section describes how the information described in the previous sections is
consolidated to compute emissions for each of the possible OBD and I/M scenarios.
4.1     NO OBD and NO I/M

       The No OBD and No I/M emission level for the Tierl and later vehicles is the basic CO
emission level. For CO emissions, it is essentially the same value as the 1988-93 model year PFI
vehicle CO emission level, except basic emission rates for normal emitters ar calculated with a
lower zero mile emission level.  The No OBD and No I/M emission level is the basis for the
subsequent CO emission levels; however, it only appears directly in the MOBILE6 CO output for
the  1994 and 1995 model year vehicles with no installed OBD system and no I/M program.

       The average No OBD and No I/M in-use running and start CO emission levels are
calculated for each vehicle, standard and age combination using the general Equation 2 repeated
here as Equation  13. The parameters in Equation 13 such as "High_ave" and "Norm_ave" are
calculated from Equations (5a-d or 6a-d) and 7a-d.  The fraction of high emitters which is used in


    r01032.wpd                    18                               July 26,2001

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Equation 13 is the value of HighBASE(i)) found in Appendix A in Table A-2 in column "Base".
Figures 4 and 5 show the CO emission levels for the cars and trucks for Tierl and LEV, and
ULEV vehicles. The line on each figure labeled "Base" is the NO OBD and NO I/M CO
emission line shown in terms of FTP emissions (running and start are combined together).

       Base© =      HighBase(i) * High_ave + Normal(i)*Norm_ave(i)                      Eqn 13
4.2    OBD and NO I/M

       The OBD and No I/M emission level for the Tierl and later vehicles is used in MOBILE6
as the CO emission level for 1996 and later vehicles if no I/M program is present. It differs from
the NO OBD and NO I/M case because of the ability of OBD to identify high emitters and
induce the vehicle owner to repair them absent an I/M program.  Calculation of the average CO
emission rate for OBD and NO I/M uses Equation 14. It is similar to the calculation described
above in Section 4.1 for the No OBD and No I/M case, and uses the same values for the normal
and high emitter emission level average parameters. The differences are the use of HighOBD
rather than HighBASE for the high emitter fraction parameter, and the after repair emission term.
The after repair emission term is the product of the after repair emission level (Rep_ave) and the
fraction of high emitters which are repaired ("Repaired" from equation 12). The value of
"Rep_ave" is the CO emission level which is 1.5 times the applicable 50,000 mile FTP
certification standard (See Section 5.0 for more details on Rep_ave).
OBD(i) =     HighoBD(i) * High_ave + Normal©*Norm_ave(i) + Repaired(i) * Rep_ave          Eqn 14

       The FTP CO emission levels for cars and trucks and Tierl and LEV and ULEV for the
case of OBD and NO I/M are shown in Figures 4 and 5.  These are indicated by the dotted line
and are under the legend heading of "OBD". In general, they are very similar to the "Base" NO
OBD  emission levels.  This reflects the relatively small impact of OBD on overall fleet CO
emissions in the absence of an I/M program.
4.3    OBD and OBD I/M

       The OBD and OBD I/M emission level for the Tierl and later vehicles is used in
MOBILE6 as the CO emission level for 1996 and later vehicles if an OBD I/M program is
present. It differs from the OBD and NO I/M case because of the ability of OBD I/M to identify
and force the vehicle owner to repair a high emitter.  Contrasting the two, the OBD and NO I/M
case can be viewed as a voluntary OBD I/M program, and the OBD and OBD I/M case can be
viewed as a mandatory I/M program. Calculation of the average CO emission rate for OBD and
NO I/M is done using Equation 15.  It is similar to the calculation done in Equation 14 for the No
OBD and No I/M case, and uses the same values for the normal and high emitter emission level
average parameters. The difference is the use of HighOBDIM rather than HighOBD for the high

    r01032.wpd                    19                               July 26,2001

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emitter fraction parameter.


OBDIM(i)      =      HighoBDIM(i) * High_ave + Normal(i)*Norm_ave(i) + Repaired(i) * Rep_ave   Eqn 15
       The CO emission levels for cars and trucks and Tierl and LEV and ULEV for the case of
OBD and OBD I/M are shown in Figures 4 and 5.  These are indicated by the line with the
circles on it and are under the legend heading of "OBD+IM". In general, these emissions are
considerably lower than the "Base" and "OBD" lines. This difference reflects the relatively large
impact of a mandatory OBD I/M program on overall fleet CO emissions after the main warranty
ends. The difference between the OBD line and the OBD+EVI line is the I/M benefit.
4.4    Exhaust I/M / NO OBD

       As mentioned in Section 3.5.1, for Tierl and later vehicles this combination can only
occur in the 1994 and 1995 model years where OBD is not present on vehicles, and an exhaust
I/M program is in place. Since this scenario is really just an extension of the 1981-93 model year
(no OBD is present), the same general calculation of before and after I/M CO emissions levels
will be done for the Tierl and later vehicles as was done for the 1981-1993 model year vehicles.
The "before" I/M CO emission levels are those calculated using Equation 13 and labeled as
"Base" in Figures 4 and 5. The "after" I/M CO emission levels "ExhBase" are calculated using
Equation 16. Except for the use of the HighBASE variable, this is the same equation that is used to
calculate the after I/M emission levels for the  1981-1993 model year vehicles.  However, for
more details on the development of 1981-1993 model years I/M credits, the reader is encourage
to refer to EPA document M6.EVI.001.
ExhBase(i) = Norm_ave*(l-HighBASE) + High_ave*HighBASE*(l-IDR) + HighBASE*IDR*W*High_ave*RW +
              Norm_ave*R*HighBASE*IDR*FIX + High_ave*HighBASE*IDR*NC                  Eqn 16

IDR is the identification rate of high emitters using an exhaust emission test.
R is the after repair emission level of vehicles repaired to pass an exhaust I/M test.
Fix is the fraction of vehicles which are repaired.
NC is the fraction of vehicles which are in non-compliance following their I/M test
W is the fraction of vehicles which receive a cost or other type of waiver.
RW is the after repair level of the vehicles which get waivered. It is shown as a fraction of the high emitter level.

4.5    Exhaust I/M with OBD

       As mentioned in Section 3.5.2, for Tierl and later vehicles this combination can only
occur on 1996 and later model year vehicles equipped with an OBD system. Under this scenario
the I/M program conducts an  exhaust I/M test, but does not conduct an OBD I/M test. This is a
likely scenario until at least calendar year 2001 when the EPA OBD I/M guidance is expected to

    r01032.wpd                     20                                 July 26,2001

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be implemented. The only difference between this scenario and the one discussed in Section 4.4
above is the different "before" I/M high emitter fractions. For example, this case uses the value
of HighOBD and the previous case uses the value of HighBASE for high emitter fraction.  This
difference can be seen by comparing Equation 16 with Equation 17.  Another comparison is that
this case uses the before I/M CO emission line labeled in Figures 4 and 5 as "OBD", and the
previous case of Exhaust I/M and NO OBD uses the line labeled as "Base".

ExhOBD(i) = Norm_ave*(l-HighoBD) + High_ave*HighoBD*(l-IDR) + HighoBD*IDR*W*High_ave*RW +
             Norm_ave*R*HighoBD*IDR*FIX + High_ave*HighoBD*IDR*NC                  Eqn 17
4.6    Exhaust I/M and OBD I/M
       As mentioned in Section 3.5.3, this scenario can exist for 1996 and later model year
vehicles equipped with an OBD system, and subject to both an OBD I/M inspection and an
exhaust I/M test. If an I/M program should choose to implement this type of program (both OBD
and exhaust I/M on the same vehicles), the before and after I/M emission levels will be the same
as the before and after OBD I/M emission level. This emission level is shown in Figures 4 and 5
under the legend label "OBD+EVI".  This is the lowest CO emission level which can be obtained
for a given standards class, vehicle type, and I/M program. It assumes that the additional exhaust
I/M program in conjunction with an effective OBD program is redundant.
5.0    OBD Repair Effects

       Separate running and start CO emission factors for normal and high emitters were
developed directly from start and running test data. However, development of the after OBD
repair CO emission levels are more problematic because there are no after repair test data, and
because of the OBD requirement for MIL illumination at 1.5 times a vehicle's FTP standard (see
Section 3.4.3 for a description and justification for the 1.5 times standard after repair level).  The
requirement of MIL illumination if the vehicle's emissions exceed 1.5 times the standard is a
difficulty in the context of this analysis because it is expressed in terms of FTP emissions rather
than separately in terms of the running or start emissions which are used in MOBILE6.

       Two simple multiplicative factors to express the  1.5 times FTP standard MIL illumination
in terms of running and start emissions  were developed based on a sub-sample of 1994 and later
model year test results.  The sub-sample consisted of 17  cars and trucks which had FTP CO
emissions greater than 5.0 g/mi (approximately 1.5 times standards) and less than 3.0 times
certification CO standards. The factors were developed by taking the ratio of the running and/or
start emissions and the FTP emissions.  They are shown below as ratios of running emissions
over FTP emissions, and start emissions over the FTP emissions. The values are:

     r01032.wpd                    21                                July 26,2001

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       Running CO (g/mi)/FTP CO(g/mi)        =      0.338                      Eqn 18

       Start CO(grams/start) / FTP CO (g/mi)      =      4.149                      Eqn 19


       The approach of using a sub-sample of 17 vehicles rather than the overall 1994+ sample
was selected because the ratios are a  function of the FTP CO emission level. The overall sample
contains mostly low normal emitters rather than the sub-sample vehicles which are close to the
1.5 times certification standards emission level that is being modeled.  The limited data and
simple analysis suggests that the low emitters have smaller running / FTP ratios and larger start /
FTP ratios than the vehicles which are close to the 1.5 times the standards level. For example,
use of the entire sample would produce a running / FTP CO ratio of 0.164 and a start / FTP CO
ratio of 9.74 versus the values of 0.338 and 4.15.  These "full sample ratios" would likely
improperly raise the after repair start emission level and lower the after repair running emission
level versus the ratios based on the sub-sample.

       For the statistically minded, the 90 percent confidence interval around the sub-sample
running / FTP ratio is from 0.277 to 0.398.  The corresponding sub-sample start / FTP ratio
confidence level ranges from 2.82 to 5.48.

       These ratios are used to calculate the value of Rep_ave (After repair emission level for
OBD vehicles) for start and running emissions used in Equations 14 and 15. For example, the
after OBD repair CO running emission level for a Tierl or LEV car is:

       1.5X * High Emitter Running Fraction  * CO Standard

       1.5 * 0.338 *  3.4 g/mi        =      1.724 g/mi running LA4 CO

and

       1.5 X *  High Emitter Start Fraction *  CO Standard

       1.5 * 4.149 *  3.4 g/mi        =     21.160 grams  CO / start
    r01032.wpd                     22                                July 26,2001

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Table A-l: CO Basic
Vehicle
Class
LDV/T1
LDT2/3
LDT4
Standard
Class
Tierl / LEV
ULEV
Tier 1 / LEV
ULEV
Tier 1 / LEV
ULEV
50K
Standard
(g/mi)
3.4
1.7
4.4
2.2
5.0
2.5
Mode
Running
Start (grams)
Running
Start (grams)
Running
Start (grams)
Running
Start (grams)
Running
Start (grams)
Running
Start (grams)
Emission Rates
"Normal" BER
(g/mi)
ZML
0.282
15.176
0.141
7.588
0.322
21.884
0.161
10.942
0.366
24.868
0.183
12434
DR
0.229
0.070
0.229
0.070
0.268
0.168
0.268
0.168
0.268
0.168
0.268
0 168
"High"
BER
(g/mi)
36.11
38.06
36.11
38.06
33.28
83.86
33.28
83.86
33.28
83.86
33.28
83 86
"Repaired"
BER
(g/mi)
1.724
21.160
0.862
10.580
2.228
27.383
1.114
13.692
2.532
31.118
1.266
15559
r01032.wpd
23
July 26, 2001

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Table A-2: CO Emitter Fractions
Age
(Years)
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
LDV/LDT1
All
Normal
0.991
0.992
0.976
0.954
0.943
0.928
0.913
0.899
0.884
0.870
0.857
0.844
0.832
0.820
0.809
0.798
0.787
0.777
0.767
0.757
0.748
0.739
0.731
0.723
0.715
0.707
Base
High
0.009
0.008
0.024
0.046
0.057
0.072
0.087
0.101
0.116
0.130
0.143
0.156
0.168
0.180
0.191
0.202
0.213
0.223
0.233
0.243
0.252
0.261
0.269
0.277
0.285
0.293
OBD Only
High
0.002
0.002
0.006
0.026
0.036
0.051
0.066
0.080
0.095
0.109
0.123
0.136
0.149
0.161
0.173
0.184
0.195
0.205
0.216
0.225
0.235
0.244
0.252
0.261
0.269
0.276
Repair
0.007
0.006
0.018
0.020
0.021
0.022
0.021
0.021
0.021
0.020
0.020
0.020
0.019
0.019
0.019
0.019
0.018
0.018
0.018
0.018
0.017
0.017
0.017
0.017
0.017
0.016
OBD/IM
High
0.002
0.002
0.006
0.011
0.014
0.017
0.021
0.025
0.028
0.032
0.035
0.039
0.042
0.045
0.048
0.051
0.054
0.057
0.060
0.063
0.066
0.068
0.071
0.073
0.075
0.078
Repair
0.007
0.006
0.018
0.035
0.043
0.055
0.066
0.076
0.088
0.098
0.107
0.117
0.126
0.135
0.143
0.151
0.159
0.166
0.173
0.180
0.186
0.193
0.199
0.204
0.210
0.215
LDT2 / 3
All
Normal
0.988
0.988
0.976
0.955
0.946
0.933
0.921
0.911
0.899
0.888
0.878
0.868
0.858
0.849
0.840
0.831
0.823
0.814
0.807
0.799
0.792
0.785
0.778
0.772
0.766
0.760
Base
High
0.012
0.012
0.024
0.045
0.054
0.067
0.079
0.089
0.101
0.112
0.122
0.132
0.142
0.151
0.160
0.169
0.177
0.186
0.193
0.201
0.208
0.215
0.222
0.228
0.234
0.240
OBD Only
High
0.003
0.003
0.006
0.025
0.034
0.046
0.058
0.069
0.081
0.092
0.102
0.113
0.123
0.132
0.141
0.150
0.159
0.167
0.175
0.183
0.190
0.197
0.204
0.210
0.217
0.223
Repair
0.009
0.009
0.018
0.020
0.020
0.021
0.021
0.021
0.020
0.020
0.020
0.020
0.019
0.019
0.019
0.019
0.019
0.018
0.018
0.018
0.018
0.018
0.018
0.017
0.017
0.017
OBD/IM
High
0.003
0.003
0.006
0.011
0.013
0.016
0.019
0.022
0.025
0.027
0.030
0.033
0.035
0.038
0.040
0.042
0.045
0.047
0.049
0.051
0.053
0.055
0.057
0.059
0.060
0.062
Repair
0.00$
0.00$
0.011
0.03'
0.04-
0.05'
0.06C
0.06*
0.07*
0.08!
0.09^
0.10C
0.107
0.11'
0.12C
0.127
0.13:
0.13$
0.14'
0.15C
0.15!
0.16C
0.16!
0.16$
0.17'
0.17*

-------
                   Figures 4 and 5
CO Emission Factors from Cars and Truckl  Vehicles
               LDV/LDT1 Tier! & LEV CO
             100        150         200

                   Mileage/1000
                 'Base '
                        -OBD '
                               -OBD+IM
                 LDT2/3 Tierl & LEV CO
                       150         200

                   Mileage/1000
                                            250
                                                       300
                •Base '
                        -OBD'
                               -OBD+IM

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                    Figures 6 and 7
CO Emission Factors from Truck2 and Trucks Vehicles
                     LDV/LDT1 ULEV CO
      50
                100
                           150

                      Mileage/1000
                                     200
                                               250
                                                          300
                   •Base '
                          -OBD '
                                 -OBD+IM
                       LDT2/3 ULEV CO
                           150

                      Mileage /1000
                                     200
                                                250
                                                          300
                   •Base '
                           -OBD '
                                  -OBD+IM

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                                   APPENDIX B
                   Statistical Diagnostics for CO Running and
                           Start Normal Emitter Levels
       This Appendix contains the statistical diagnostics from the regression of the normal
emitter CO emission versus odometer.  Standard least squares regressions were done on running
CO emissions versus odometer for cars and trucks separately, and start CO emissions versus
odometer for cars and trucks separately.
           ****   MULTIPLE   REGRESSION

Regression for 1994+ cars

Listwise Deletion of Missing  Data

Equation Number 1    Dependent  Variable..   HR505_CO

Block Number  1.   Method:   Enter      ODOMETER
                                                            * * * *
Variable(s)  Entered on Step  Number
   1..     ODOMETER
Multiple R           .37098
R Square             .13763
Adjusted R Square    .13079
Standard Error       .61807
Analysis of Variance
                    DF
Regression           1
Residual           126
F =
         20.10894
                Sum of Squares
                       7.68187
                      48 . 13358

            Signif F =   .0000
Mean Square
    7.68187
     .38201
Variable

ODOMETER
(Constant)
	 Variables in the Equation 	

          B        SE B     95% Confdnce Intrvl B

 1.24335E-05  2.7727E-06  6.94648E-06  1.79206E-05
     .117206      .091991     -.064842      .299254
                    Beta

                 .370985
Variable

ODOMETER
(Constant)
        T  Sig T

    4.484  .0000
    1.274  .2050
           ****   MULTIPLE   REGRESSION   ***
Listwise Deletion of Missing  Data

Equation Number 1    Dependent  Variable..   STRT_CO

-------
Block Number  1.  Method:  Enter
                                      ODOMETER
Variable(s) Entered on Step Number
   1..     ODOMETER
Multiple R            .07287
R Square              .00531
Adjusted R Square   -.00258
Standard Error      8.82307
Analysis of Variance
                    DF
Regression           1
Residual           126
F =
           .67256
              Sum of Squares
                    52.35654
                  9808.65890

          Signif F =  .4137
Mean Square
   52 .35654
   77 .84650
Variable
       - Variables in the Equation 	

        B        SE B     95% Confdnce Intrvl B
ODOMETER    3.24599E-05  3.9580E-05 -4.58687E-05   1.10788E-04
(Constant)    14.753554    1.313187    12.154795     17.352312
                                                                     Beta

                                                                  .072866
Variable

ODOMETER
(Constant)
     T  Sig T

  .820  .4137
11.235  .0000
End Block Number
         All requested variables entered.

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           ****   MULTIPLE   REGRESSION   ****


Listwise Deletion of Missing Data

Equation Number 1    Dependent Variable..   CO

Block Number  1.  Method:  Enter      ODOMETER
Variable(s) Entered on Step Number
   1..     ODOMETER
Multiple R            .41750
R Square              .17430
Adjusted R Square     .16775
Standard Error      1.23853
Analysis of Variance
                    DF
Regression           1
Residual           126
F =
         26 .59849
             Sum of Squares
                   40.80123
                  193.27996

         Signif F =  .0000
Mean Square
   40.80123
    1.53397
Variable
      -  Variables in the Equation 	

       B        SE B     95% Confdnce Intrvl B
ODOMETER    2.86548E-05  5.5561E-06  1.76595E-05  3.96502E-05
(Constant)     1.187217      .184338       .822418     1.552017
                                                                    Beta

                                                                  .417497
Variable

ODOMETER
(Constant)
    T  Sig T

5.157  .0000
6.440  .0000
End Block Number
        All requested variables entered.

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           ****   MULTIPLE   REGRESSION   ****


Listwise Deletion of Missing Data

Equation Number 1    Dependent Variable..   HR505_CO

Block Number  1.  Method:  Enter      ODOMETER
Variable(s) Entered on Step Number
   1..     ODOMETER
Multiple R            .34670
R Square              .12020
Adjusted R Square     .11190
Standard Error      1.05037
Analysis of Variance
                    DF
Regression           1
Residual           106
F =
         14 .48171
             Sum of Squares
                   15.97724
                  116.94662

         Signif F =  .0002
Mean Square
   15.97724
    1.10327
Variable
      -  Variables in the Equation 	

       B        SE B     95% Confdnce Intrvl B
ODOMETER    1.14258E-05  3.0025E-06  5.47314E-06  1.73785E-05
(Constant)      .173842      .150593     -.124724       .472408
                                                                    Beta

                                                                  .346696
Variable

ODOMETER
(Constant)
    T  Sig T

3.805  .0002
1.154  .2509
End Block Number
        All requested variables entered.

-------
           ****   MULTIPLE   REGRESSION    ****


Listwise Deletion of Missing Data

Equation Number 1    Dependent Variable..   STRT_CO

Block Number  1.  Method:  Enter      ODOMETER
Variable(s) Entered on Step Number
   1..     ODOMETER
Multiple R            .00946
R Square              .00009
Adjusted R Square   -.00934
Standard Error     13.38235
Analysis of Variance
                    DF
Regression           1
Residual           106
F =
           .00948
              Sum of Squares
                     1.69800
                 18983.24665

          Signif F =  .9226
Mean Square
    1.69800
  179.08723
	 Variables in the Equation 	

Variable              B        SE B     95% Confdnce Intrvl B       Beta

ODOMETER   -3.72482E-06  3.8253E-05 -7.95656E-05  7.21160E-05    -.009457
(Constant)
              21.096190
                           1.918655
                                       17.292269
                                                    24.900111
Variable

ODOMETER
(Constant)
     T  Sig T

 -.097  .9226
10.995  .0000
End Block Number
         All requested variables entered.

-------
           ****   MULTIPLE   REGRESSION    ****


Listwise Deletion of Missing Data

Equation Number 1    Dependent Variable..   CO

Block Number  1.  Method:  Enter      ODOMETER
Variable(s) Entered on Step Number
   1..     ODOMETER
Multiple R            .33380
R Square              .11142
Adjusted R Square     .10304
Standard Error      2.65967
Analysis of Variance
                    DF
Regression           1
Residual           106
F =
         13 .29152
                            Sum of Squares
                                  94.02251
                                 749.83013

                        Signif F =   .0004
                                    Mean Square
                                       94 .02251
                                        7.07387
Variable

ODOMETER
(Constant)
                      - Variables in the Equation  	

                      B        SE B     95% Confdnce  Intrvl  B
2.77174E-05
   1.778813
                         7.6026E-06
                             .381323
                                     1.26444E-05  4.27903E-05
                                        1.022802      2.534823
                                                                     Beta

                                                                  .333797
Variable

ODOMETER
(Constant)
                   T  Sig T

               3.646  .0004
               4.665  .0000
VEHICLE  by  MODEL_YR

                    MODEL YR
            Count
VEHICLE
                                                          Page  1  of  1
                                                                 Row

1. 00

2 . 00

1994
32

20

1995
21

10

1996
22

30

1997
26

24

1998
27

20

1999


4

Total
128
54.2
108
45. 8
            Column      52     31     52      50      47       4     236
             Total    22.0   13.1   22.0   21.2    19.9     1.7   100.0

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         Appendix C
1994+ Normal Emitters < 25,000 Miles
VEHICLE
CAR
TRUCK
Total
Mean
N
Std. Deviation
Median
Mean
N
Std. Deviation
Median
Mean
N
Std. Deviation
Median
Running CO
(g/mi)
.28205
77
.64849
.13200
.32188
50
.64250
6.0500E-02
.29773
127
.64387
.10300
Start CO
(g/start)
15.17562
77
9.26452
13.89300
21.88350
50
12.51306
19.85450
17.81652
127
11.11251
15.67400
FTP CO
(g/mi)
1.55696
77
1.20706
1.27800
2.14848
50
1.44522
1.74850
1.78984
127
1.33239
1.43700
    1994+ Normal Emitters All
VEHICLE
CAR
TRUCK
Total
Mean
N
Std. Deviation
Median
Mean
N
Std. Deviation
Median
Mean
N
Std. Deviation
Median
Running CO
(g/mi)
.44910
128
.66294
.19100
.59868
108
1.11458
.16000
.51755
236
.89929
.18450
Start CO
(g/start)
15.62002
128
8.81168
13.93250
20.95769
108
13.32026
18.42950
18.06269
236
11.39519
15.45700
FTP CO
(g/mi)
1.95212
128
1.35763
1.68150
2.80940
108
2.80829
1.94450
2.34443
236
2.18407
1.75150

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