CALIFORNIA AIR RESOURCES BOARD
State Building
Auditorium, Room 1138
107 South Broadway
Los Angeles, CA
April 25, 1985
10:00 a.m.
AGENDA
Page
85-5-1 Public Hearing to Consider Adoption of 001
Regulations Requiring Malfunction and Diagnostic
Systems and Amendments Extending the Maintenance
Interval for Oxygen Sensors for 1988 and Subsequent
Model Year Gasoline-Powered Vehicles.
85-5-2 Public Hearing to Consider Amending the Emission 125
Control Warranty Requirements for Fuel Injection
Pumps on Light-Heavy-Duty Diesel Engines.
85-5-3 Consideration of the South Coast Air Quality 146
Management District Request for Revisions of the
Boundaries of the South Coast Nonattainment Area
for NO2.
Other Business
a. Closed Session
1. Personnel (as authorized by State Agency Open Meeting
Act, Govt. Code Sec. 11126(a).)
2. Litigation (Pursuant to the attorney-client privilege,
Evidence Code Sec. 950-962, and Govt. Code Sec.
11126(q).)
b. Research Proposals
c. Delegations to Executive Officer
ITEM NO.: 85-5-3
Consideration of the South Coast Air Quality Management
District's Request for Revisions of the Boundaries for the South
Coast Nonattainment Area for Nitrogen Dioxide.
BACKGROUND
In March 1983, the South Coast Air Quality Management District
(District) requested that the Air Resources Board (ARB) recommend
that the Environmental Protection Agency (EPA) modify the
boundaries of the nonattainment areas for three pollutants in the
South Coast Air Basin. Specifically, the District requested the
ARB to remove Orange County, the South Coast Air Basin portions
of Riverside and San Bernardino Counties, and part of Los Angeles
County from the basinwide nitrogen dioxide (NO2) nonattainment
area. Also, the ARB was asked to redesignate portions of the
basin to attainment for carbon monoxide (CO) and particulate
matter.
The ARB staff informed the District that more information was
needed to evaluate the requests concerning CO and particulate
matter. The EPA has since clarified its CO policy which states
that a CO nonattainment area must include the entire urbanized
area. Based on this policy, the staff believes that the
District's request for redesignation of the boundaries of the CO
nonattainment area would not be approvable by EPA. The District
has not yet provided the information for total suspended
particulate matter which the staff requested and which is
necessary for us to complete our evaluation.
The deadline in the Clean Air Act for attainment of the national
primary, i.e., health-based, ambient air quality standard for NO2
is December 31, 1982. The South Coast Air Basin is the only area
in the country which has not yet attained the NO2 standard, and a
revised plan demonstrating attainment has yet to be submitted to
EPA.
The District's NO2 request was supplemented by a number of
eastern basin cities which wrote to Chairman Duffy requesting
redesignation of Riverside and San Bernardino Counties to
attainment for the NO2 standard because there have been no
violations of the standard in those areas since 1979. These
cities are concerned that their continued inclusion in a
nonattainment area will inhibit industrial growth. They are also
concerned that EPA might impose sanctions on the nonattainment
area for failure to attain the NO2 standard.
Only the NO2 redesignation issue concerning Riverside and San
Bernardino Counties is before the Board at this time. There has
been no further interest expressed by the District to redesignate
to attainment for NO2 Orange County and part of Los Angeles
County.
It has been the policy of EPA that NO2 is a regional pollutant
and that only a regional designation of nonattainment is
appropriate. The ARB staff generally concurs with EPA's policy
and has so informed the District.
Jeb Stuart, SCAQMD Air Pollution Control Officer, presented
testimony at an ARB public meeting in September 1984 in support
of the district's and the cities' request to delete Riverside and
San Bernardino Counties from the NO2 nonattianment area.
At that meeting, the ARB staff acknowledged that there were no
violations of the standard in Riverside and San Bernardino
Counties. However, the staff recommended against changes to the
nonattainment area boundaries because NO2 is a regional pollutant
in the South Coast Air Basin.
Bill Simmons, representing San Diego Gas and Electric Company,
presented arguments to the Board in favor of removing Riverside
and San Bernardino Counties from the nonattainment area citing a
report recently prepared by Dr. Allen Eschenroeder for
presentation to the District Board at its public hearing on the
stationary internal combustion engines rule. The District staff
has since stated to its Board, during a discussion of another
subject, that the Eschenroeder report failed to demonstrate that
sources in the eastern portions of the South Coast Air Basin do
not impact the areas where the standard is exceeded.
Recently, however, Dr. Eschenroeder completed a new modeling
analysis to determine the extent that emissions from sources in
the eastern counties of the South Coast Air Basin contribute to
annual NO2 concentrations at the downtown Los Angeles and Burbank
air monitoring stations. We informally received a copy of this
analysis (copy attached) which utilizes ARB's trajectory models
and ARB's gridded emission inventory. Dr. Eschenroeder's
conclusion is that oxides of nitrogen (NOx) emissions from
Riverside and San Bernardino Counties contribute only
infrequently to NO2 concentrations at the downtown Los Angeles
and Burbank air monitoring stations and make only a one percent
contribution to the annual average.
More recently, ARB staff became aware of other aspects of EPA's
policy which could constrain redesignation for NO2 in the South
Coast Air Basin. The ARB has requested clarification (see
attached EPA memo and ARB letter).
ITEM NO.: 85-5-1
Public Hearing to Consider Adoption of Regulations Requiring
Malfunction and Diagnostic Systems and Amendments Extending the
Maintenance Interval for Oxygen Sensors for 1988 and Subsequent
Model Year Gasoline-Powered Vehicles.
RECOMMENDATION
Exhaust and evaporative emissions increase significantly when
current high technology vehicle emission systems malfunction.
Additionally, the service industry is faced with considerable
difficulty in properly diagnosing and repairing these complex
systems. To counter these problems, the staff recommends that
the Board adopt regulations that require 1988 and subsequent
model-year vehicles to have an on-board emission control
malfunction indicator lamp to notify the owner of an emission
control system malfunction, and a diagnostic system in the
vehicle's computer which will help the mechanic identify the
likely cause of malfunction. The staff is also recommending a
reduction in the frequency of maintenance allowed for oxygen
sensors during new vehicle certification. Oxygen sensors are
critical to the proper emissions performance of these advanced
systems, and reduced maintenance generally reduces emissions from
in-use vehicles.
DISCUSSION
a. Malfunction/Diagnostic System
Modern emission control systems utilize computers to "tune" the
engine while it is running for optimum performance and low
emissions. Unfortunately, malfunctions in these systems can
cause large increases in emissions without giving the vehicle
operator any indication that a problem exists. This is because
the computer can stop actively tuning the engine and shift to a
backup set of operating parameters when a malfunction occurs.
The backup parameters generally ensure adequate vehicle
drive ability and performance characteristics while sacrificing
emission control. Even if a malfunction is detected, the
complexity of these systems makes proper diagnosis and repair
very difficult when the vehicle is not equipped with a diagnostic
system.
This proposal would require a malfunction/diagnostic system which
would alert the vehicle operator when the emission control system
malfunctions, and require an on-board means to assist a mechanic
in diagnosing the likely area responsible for the malfunction.
Many owners are expected to seek immediate repairs in response to
the malfunction indication. Other owners would obtain repairs as
a result of the biennial smog check program, which "fails" cars
with illuminated warning lights. The on-board computer could be
accessed by mechanics or the vehicle owner. Such a system would
provide efficient problem diagnosis, thereby minimizing the
overall cost of repairs, and improving their effectiveness.
While the computer can easily screen incoming signals for a
possible malfunction, it is more costly for the computer to also
determine if the emission control device receiving an output
signal from the computer is operating properly. For this reason,
the staff proposal requires that only the fuel control solenoid
and exhaust gas recirculation valve, if so equipped, be monitored
by the computer for proper operation. Increasing the
repair ability of these two systems provides for a substantial
portion of the emission reduction that will be achieved by the
proposal.
Some flexibility in the compliance date for the regulation is
proposed to permit it to coincide with major emission control
system revisions, thereby minimizing manufacturer costs.
b. Oxygen Sensor Durability
The oxygen sensor is the most critical sensor in a modern
emission control system. It measures the exhaust gas composition
from the engine. This measurement in turn is used by the
computer to control the engine to minimize emissions.
The first oxygen sensors used in 1977 Volvos were replaced every
15,000 miles. Later their durability was extended to 30,000
miles, and now many cars require no sensor maintenance before
50,000 miles. The extension of sensor replacement intervals
resulted from improvements in the sensors and other related
emission-control components. Previous studies have shown that
extended emission control durability reduces in-use emissions.
This is because some vehicle owners do not perform the
maintenance recommended by the manufacturer and because extended
durability prolongs the time which their vehicles continue to
meet standards.
Under the proposed minimum 50,000-mile oxygen sensor replacement
interval, virtually all cars would have extended sensor
durability. For the very few manufacturers which indicated that
compliance would not be possible, an alternative would permit
more frequent maintenance if the manufacturer pays for the oxygen
sensor replacement and continues to provide a maintenance
reminder indicator.
SUMMARY AND IMPACTS OF PROPOSED REGULATORY CHANGES
The feasibility of equipping vehicles with malfunction/diagnostic
systems is well established. General Motors, Chrysler, and
Toyota presently have systems in production which have many of
the features of the proposed system. Similarly, more than half
the current vehicle models equipped with oxygen sensors have a
50,000 mile sensor maintenance interval.
The staff estimates that the statewide emission reductions which
would result ten years after adoption of its proposals are 19
tons/day hydrocarbons, 346 tons/day carbon monoxide, and 43
tons/day oxides of nitrogen. The staff estimates that costs
associated with the extended oxygen sensor durability proposal
are negligible. Most manufacturers will be able to incorporate
the malfunction/diagnostic system as part of planned emission
control system improvements at a cost of $25 to $30. The cost
effectiveness of the total proposal is: $.69 - $.83/lb.
hydrocarbons, $.04 - $.05/lb. carbon monoxide, and $.58 -
$.70/lb. oxides of nitrogen. These values compare very favorably
with other emission control strategies which have been adopted or
are under consideration.
The staff has had considerable interaction with vehicle
manufacturers since August, 1982 to ensure this proposal is
effective and manufacturers can comply. The staff conducted two
workshops, completed two mailouts soliciting comments from
manufacturers to resolve all issues which they raised prior to
the April Board Hearing. Ford Motor Company submitted written
comments contending that the Board lacks the authority to adopt
the malfunction and diagnostic system proposal. The Office of
Legal Affairs has concluded that the proposal falls within the
Board's legal authority and has responded to these issues.
ITEM NO.: 85-5-2
Public Hearing to Consider Amending Emission Control Warranty
Requirements for Fuel Injection Pumps on Light-Heavy-Duty Diesel
Engines.
RECOMMENDATION
The Staff has prepared two options in response to the direction
provided by the Air Resources Board (the "Board") regarding the
June 15, 1984, International Harvester (I.H.>) petition which was
considered at the Board's September 26, 1984 public meeting.
Both options address I.H.'s concern about the economic hardship
that it may face as a result of premature fuel injection pump
failures. The first option is a regulatory change that would
reduce, for a two model year period, the warranty mileage
applicable to fuel injection pumps on light-heavy-duty diesel
engines. The second option is an administrative alternative that
provides a similar result except that it would reduce warranty
only on those vehicles subject to severe duty applications which
exceed the manufacturers recommendations. No board action is
required to implement the administrative option. The staff
recommends the administrative option. The staff has prepared
regulatory changes should the Board choose to take that course of
action.
DISCUSSION
In its petition, I.H. requested a reduction in the warranty
mileage that applies to all emission-related parts on light-heavy-duty
diesel engines. I.H. petitioned the Board because it
had become increasingly concerned about the cost of warranty
claims for premature fuel injection pump failures on its 6.9
liter diesel engines. The failures seem to result when customers
modify Ford vehicles equipped with the I.H. 6.9 liter diesel
engine to pull large line-haul type trailers capable of carrying
loads in excess of those which are recommended. This application
can result in excessive engine and fuel injection pump loading.
After considering the petition and additional information
presented by I.H. at its September 26, 1984, public meeting the
Board directed the staff to develop a regulatory proposal which
would reduce the warranty mileage that applies to fuel injection
pumps on all light-heavy-duty diesel engines from 100,000 to
50,000 miles. The Board also directed the staff to propose
alternative (Administrative) methods of accomplishing the same
result. The administrative option would reduce the warranty
mileage on the fuel injection pump when a vehicle is modified to
haul excessively large line-haul type trailers. For both options
the Board stated that the reduced warranty should apply for a
maximum period of two years; 1985 and 1986.
The staff recommends that the Board choose the administrative
option since it would void warranty only on those vehicle subject
to severe duty applications which exceed manufacturer's
recommendation. A provision exists in regulation to accomplish
this, thus no Board action would be required.