State of California
AIR RESOURCES BOARD
State Office Building
455 Golden Gate Avenue
Room 1194
San Francisco, CA
May 16, 1973
9:30 a.m.
AGENDA
73-10-1 Approval of Minutes of May 2, 1973 Meeting.
73-10-2 Consideration of STP's Application for Modification of
Its NOx Control Device.
73-10-3 Consideration of Contignitron's Application for
Modification of Its NOx Control Device.
73-10-4 Consideration of Request for Exemption of 1966-70
Vehicles Fitted With the Contignitron Ignition Device.
73-10-5 Report of Ad-Hoc Committee on Contignitron Company and
Clean Air Research Company Applications.
73-10-6 Consideration of Proposed Policy Concerning Aftermarket
Replacement Parts.
73-10-7 Report on Staff Surveillance of End of Assembly Line
Tests.
73-10-8 Other Business.
a. Consideration of Agricultural Burning
Implementation Plan for Kings County.
b. Report on Senate Transportation Committee Hearing
May 9, 1973.
c. Tentative Agenda for June 20 and 21 Meetings.
73-10-9 Remarks from Audience - End of Morning and Afternoon
Sessions.
ITEM NO.: 73-10-2
STP Corporation Application for Accreditation of a Modified NOx
Control Device for Certain 1966-1970 Model-Year Vehicles with
Engines in Class (a) and Classes (b) through (f).
RECOMMENDATION
Rescind Resolution 72-123-1 and adopt Resolution 72-123-2
accrediting a modified NOx control system for class (a) vehicles.
Rescind Resolution 72-123 and adopt Resolution 72-123-3
accrediting a modified NOx control system for classes (b) through
(f) vehicles.
SUMMARY
At it May 2, 1973 meeting, the Air Resources Board approved the
staff's recommendation for a modification of STP's NOx control
device for class (a) 1966-1970 model year vehicles. This
modification permits deletion of the air bleed for spark
modification on vehicles (Volkswagens) in this class that operate
with vacuum advance only distributors. Subsequent to the May 2,
1973 Air Resources Board meeting, STP requested approval of a
similar modification of its device for certain 1966-1970 model
year vehicles of engine classes (b) through (f); this
modification applies to vehicles equipped with centrifugal
advance only and vacuum advance only distributors. In the past,
many vehicles in this category have been exempted. The proposed
modification will permit NOx control by exhaust gas recirculation
(EGR). Although EGR will not accomplish the same degree of NOx
control as the approved system, data included in the attached
staff report for a revised test fleet show that the NOx reduction
standard for class (a) vehicles remains at 42%. This apparent
anomaly is the result of dripping two exempt test vehicles from
the prior fleet.
No additional tests were performed on vehicles in classes (b)
through (f), because the number of vehicles in this class would
not have a significant effect on the 54.6% reduction previously
accredited to the STP device.
ITEM NO.: 73-10-3
Consideration of Contignitron's Application for Modification of
Its NOx Control Device for 1966-1970 Model Vehicles.
RECOMMENDATION
Approve Contignitron Company's request to modify the Equalizer
Mod 4-8 Device.
SUMMARY
The Contrignitron Company has requested permission to modify its
conditionally accredited Equalizer Mod 4-8 device. The proposed
modifications are in electronic circuitry used to control the
ignition timing delay. The proposed modifications will result in
two variations of the device; one for 6 cylinder engines vehicles
and one for 8 cylinder engines vehicles. The manufacturer states
that the modification will advance the ignition timing at the
higher engine speeds and reduce the adverse temperature effects
of spark retardation.
Ignition timing curves and emission and thermal effects test data
were submitted by Contignitron to verify its claim that the
modification will reduce the adverse temperature effects without
reducing the device's exhaust emission control effectiveness.
Air Resources Board Laboratory test data are in agreement with
the manufacturer's claims.
ITEM NO.: 73-10-4
Consideration of Request for Exemption of 1966-70 Vehicles fitted
with the Contignitron Ignition Device.
RECOMMENDATION
Deny exemption unless Contignitron is willing to withdraw its
application for accreditation.
DISCUSSION
Attached is a letter from Contignitron requesting that vehicles
equipped with its Equalizer ignition system (the same device
which is conditionally accredited) be exempted from the
installation of a fully accredited NOx device.
Under Section 39177 of the Health and Safety Code, exemptions may
be granted when vehicles meet the NOx standard. The Board
determined that this system meets the emission standards when it
conditionally accredited Contignitron's device. Contignitron has
not been able to satisfy the Board as to the condition, viz.,
financial responsibility, and accordingly cannot yet market its
system as an accredited device. It now seeks to market it not as
an emission control device, but as an electronic ignition system
which when installed may be substituted for an accredited device.
Such a procedure was previously sanctioned by the Board when it
exempted vehicles with Air Quality Products' 1966-70 PURE POWER
high performance system. At that time (February 21, 1973), the
Staff Counsel reported that a "primary purpose" test could be
applied to determine whether the device is primarily an emission
control device or an ignition system. Applying that test here,
we find that the Equalizer is an electronic ignition system which
its developer claims extends breaker point and spark plug life
and improves engine performance. Also the device is being sold
in California now as an ignition system (the Board has issued
Contignitron a Resolution under Section 27156 of the Vehicle
Code; Section 27156 prohibits the alteration or modification of
emission control systems unless the Board issues a resolution
finding that emissions are not adversely affected). Thus, the
staff concludes that the device meets the primary purpose test
and may be granted an exemption under Section 39177 of the Health
and Safety Code.
Representatives from Contignitron have advised the staff that
they wish to sell their system, mainly to fleet owners, as an
exempt device until such time as they can meet the financial
responsibility requirements and sell the system as an accredited
device.
If the system is first given exempt status, and then full
accreditation, the vehicles on which "exempt" systems were
installed would have an exempt window sticker and vehicles with
the accredited system would show a compliance sticker. This
situation would cause the licensed installers and the public to
be confused. It may also mean that owners of vehicles with fully
accredited devices would receive benefits of financial backing
while owners of vehicles with the exempt system would not.
The Executive Interagency Enforcement Committee has considered
this possibility and has recommended that the ARB take steps to
prevent such confusion.
The ARB staff concurs in this view and proposes that Contignitron
elect whether to market the device as an exempt system or an
accredited device and when it so elects, it agrees to forego any
application for the other.
In conformance with this policy the staff recommends that the
Board instruct the Executive Officer to grant the device exempt
status only when Contignitron withdraws its application for
accreditation.
ITEM NO.: 73-10-5
Report of Ad Hoc Committee on Contignitron and Clean Air Research
Company Applications.
RECOMMENDATION
To Be Presented at Meeting.
SUMMARY
This is in response to the Board's request at the May 2 meeting
that the ad hoc committee (Mr. H. Sullivan and Mrs. G. Meade)
present a report on the status of the Contignitron Company's and
CARCO Company's application for accreditation. The requirements
of an acceptable financial arrangement for each of the two
companies were approved by the Board at the May 2 meeting.
ITEM NO.: 73-10-6
Proposed Policy Concerning Aftermarket Replacement Parts.
RECOMMENDED
Adopt proposed Policy.
DISCUSSION
At the April 18, 1973 meeting, the Air Resources Board received
and agreed in principle with a staff report concerning policy on
replacement parts. The proposed policy, a copy of which is
attached, was developed by the Executive Interagency Committee
which consists of representatives from the following departments:
Air Resources Board, California Highway Patrol, Department of
Motor Vehicles, Consumer Affairs. The Board instructed the staff
to obtain the official concurrence of the departments concerned
with the enforcement of this policy. Following the meeting, a
copy of the proposed policy was went to these departments for
their response. Each department concurs with the proposed
policy. Copies of their responses are attached.
ITEM NO.: 73-10-7
Report of Staff Surveillance of End of Assembly-Line Tests.
RECOMMENDATION
None. This is an informational item.
DISCUSSION
The ARB program of confirmatory testing of vehicles previously
tested at the end of assembly-line is increasing in activity.
During the period of September, 1972 through April, 1973, over
1,800 vehicles have been hot 7-mode tested. Parallel testing of
vehicles took place at three manufacturers' test facilities.
Comparison of the test results between the Air Resources Board
and manufacturers' laboratories was made on a pass-fail basis and
is summarized in Table I. Steady state testing was started with
the 1973 model year vehicles. Tables II, III and IV summarize
the results of these tests. Enforcement and surveillance testing
in accordance with the official approval test procedure (CVS) was
performed on forty-five randomly selected vehicles of fifteen
engine families. A summary of the results of these tests is
shown in Table V.
ITEM NO.: 73-10-8a
Consideration of Agricultural Burning Implementation Plan.
RECOMMENDATION
Adopt Resolution 73-1d thereby approving the Agricultural Burning
Implementation Plan of Kings County Air Pollution Control
District.
FACTS AND DISCUSSION
1. On June 21, 1972, the Board adopted Agricultural Burning
Guidelines for the entire state. The Guidelines required
all districts to adopt, by December 20, 1972, implementation
plans to regulate agricultural burning and to submit the
plans to the Board for approval within 10 days after
adoption. After public hearing, the Board is required by
the State Health and Safety Code to approve, modify, or
reject the plans. The Code also requires that if a plan is
rejected, or if no timely plan is submitted, or if the plan
is economically or technically not feasible, the Board after
hearings held in the basin affected, shall adopt an
alternative plan.
2. As of its May 2, 1973 meeting, the Agricultural Burning
Implementation Plans of 49 districts have been approved by
the Board.
3. Kings County Air Pollution Control District, the only
district remaining, adopted a plan by resolution on May 1,
1973 and submitted it on May 9, 1973.
4. The staff has reviewed the Kings County Air Pollution
Control District Agricultural Burning Implementation Plan,
and has found the plan to be consistent with the Board's
guidelines.