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.