State of California
AIR RESOURCES BOARD
Los Angeles Hilton
930 Wilshire Boulevard
Los Angeles, CA 90017
April 28, 1977
77-9-1 Minutes of the October 5, 1976 Board Meeting.
77-9-2 Continuation of Public Hearing on Proposed Changes 1
to Regulations Regarding Allowable Maintenance During
New Vehicle Certification of Light-Duty and Medium-Duty
77-9-3 Status Report on the Effects of MMT Fuel Additive. 52
77-9-4 Continuation of Public Hearing Regarding Adoption 133
of Regulations for ARB Administrative and Hearing
77-9-5 Other Business -
a. Executive Session - Personnel & Litigation
b. Research Proposals 173
ITEM NO.: 77-9-2
Public Hearing on Proposed Changes to Regulations Regarding
Allowable Maintenance During New Vehicle Certification of Light-Duty
and Medium-Duty Vehicles.
Adopt Resolution 77-16.
The views expressed by the automobile manufacturers who responded
to a staff questionnaire and participated in workshops with the
staff indicate that it is technologically feasible to build
vehicles requiring far less frequent emissions related
maintenance than is allowed under current regulations.
Information submitted by the manufacturers leads the staff to
conclude that with the exception of air filter and oxygen sensor
replacements at 30,000 miles, no other emissions-related
maintenance is necessary during the first 50,000 miles of vehicle
operation. For certain maintenance items, however, some
manufacturers strongly object to having their allowable
maintenance limited to the extent that other manufacturers claim
is technologically feasible.
The staff anticipates little opposition on technological grounds
to the imposition of the following maintenance limitations; (1)
adjustment of engine idle speed, engine bolt torque, and valve
lash once after break-in; (2) adjustment of engine valve lash at
15,000 mile intervals; and (3) choke lubrication, adjustment of
drive belts, tension and replacement of spark plugs, oxygen
sensors and air filters at 30,000 mile intervals.
With respect to the manufacturers' legal objections, the staff
believes that the Board clearly has the legal authority to adopt
the proposed maintenance regulations. The manufacturers appear
to have conceded that the Board has the authority to limit
allowable maintenance during the certification process.
ITEM NO.: 77-9-3
Status Report on the Effects of MMT Fuel Additive.
Board should request that the staff prepare regulations limiting
or eliminating the use of MMT in gasoline sold in California.
Lead phase-down regulations promulgated by the Air Resources
Board and the U.S. Environmental Protection Agency combines with
an increase in the portion of the vehicle population which
requires lead-free gasoline because of the use of catalytic
converters are resulting in rapidly increasing usage of the
octane improving fuel additive, methylcyclopentadienyl manganese
tricarbonyl (MMT). The use of .125 gram/gallon of manganese (as
MMT) in unleaded gasoline improves the fuel's research octane
number (RON) by approximately 2.0. Further refining gasoline to
provide the same increase in octane would be marginally more
expensive and could require approximately 1% additional crude
oil when and if all gasoline produced is unleaded. While the
average manganese content of all unleaded fuel sold in the United
States today is only .006 gram/gallon, Ethyl Corporation (the
sole manufacturer of the additive) and most oil companies expect
that .125 gram/gallon manganese will be used in essentially all
unleaded fuels in the next few years. The use of MMT currently
is limited by Ethyl's production capacity.
An increasing body of evidence indicates that the use of MMT in
unleaded gasoline causes 50-100% increases in hydrocarbon
emissions due to the formation of porous deposits on engine
combustion chamber surfaces. Ford has estimated that a 4-8% fuel
economy penalty will be associated with the engine calibration
changes necessary to counteract the effect of MMT when attempting
to certify at 0.41 gram/mile HC. It has also been determined
that MMT can cause plugging of both pellet and monolithic
catalytic converters under certain operating conditions.
Plugging is particularly severe for monolithic catalysts located
close to the engine. The staff expects the use of close-coupled
monoliths to increase in the future because of the rapid warm-up
characteristics of such a configuration. Close-coupled monoliths
could be of major significance in allowing manufacturers to
optimize fuel economy while meeting stringent emission standards.
The available data suggest that MMT also reduces spark plug life.
The effect of MMT on oxygen sensors is uncertain at this time
although tests run by GM showed increased O2 sensor degradation
when MMT was used.
When gasoline containing MMT is burned the manganese is converted
to manganese oxide, much of which is exhausted to the atmosphere.
It has been estimated that three month average manganese levels
could increase tenfold (from .05 g/m3) if all gasoline
eventually contains about .125 gram/gallon manganese.
The State Department of Health has advised the staff that the
increased use of manganese fuel additives represents a potential
health hazard. Available data suggests that increased ambient
manganese levels could result in increased accumulation of
manganese in the brain and liver. Sufficiently large exposures
are believed to cause neurologic disease. More data are
necessary to determine whether the expected increase in ambient
manganese levels will result in significant and direct effects.
There is evidence that increased ambient manganese levels will
catalyze the conversion of SO2 to more harmful sulfate compounds.
As much as a 10% increase in sulfate levels could be caused under
conditions of high humidity.
If MMT usage expands significantly in the future the staff
recommends additional study of potential health risks.
It appears that the continued use of MMT in unleaded fuel would
be a serious mistake, even in the absence of further data
regarding the direct health effects of the use of MMT. Catalyst
plugging problems experienced with close-coupled monolithic
converters indicate that the use of MMT will eliminate one of the
most promising catalyst configurations. The significant
hydrocarbon emission increases caused by MMT can be expected to
result in fuel economy penalties which exceed the energy benefit
of building octane with MMT instead of with further refining of
unleaded fuel. The increased use of fuel containing MMT by
vehicles previously manufactured will result in greater emissions
of hydrocarbons with the concomitant effect of increasing ambient
levels of oxidant.
ITEM NO.: 77-9-4
Continuation of Public Hearing Regarding Adoption of Regulations
for ARB Administrative and Hearing Procedures.
Adopt Resolution 77-14.
The regulations which are proposed for adoption at this public
hearing were first proposed at the March 25, 1977 Board meeting,
at which time the matter was continued to the Board's April
meeting. Some changes to the March 25 proposal have been made as
a result of early public comment and further analysis by the
These regulations would establish administrative procedures in
Title 17 of the California Administrative Code relating to
meetings of the Board and administrative hearings. In addition,
minor amendments have been proposed for the Emergency Meeting
procedures in Subchapter 7, and these provisions have been
relocated in a new Subchapter 1 which will contain all the
The new regulations provide procedures for implementing a 6-month
running calendar of future Board meetings, plus procedures for
giving notice of regular and special meetings, making staff
reports available to the public, and other related matters. In
addition, procedures are established for the conduct of
administrative hearings, including provisions relating to the
filing of petitions, selection of a presiding officer,
determination of whether an administrative hearing shall be held,
conduct of such a hearing, types of evidence which are
admissible, and the manner of issuing a decision.
These regulations will clarify and implement procedures for Board
meetings and establish an administrative hearing procedure for
matters where such a hearing is required by law or is otherwise
appropriate. The procedures are intended to provide for an
expedited resolution of disputes at the administrative level.
ATTACHMENTS: Resolution 77-14
Proposed ARB Regulations Regarding Administrative
Staff Report 77-9-4
Public Hearing Notice
Comments of Motor Vehicle Manufacturers