authorities that a comprehensive and orderly program of this sort, plus the tooling that would be required, would be applied to about 175 engine-transmission combinations in vehicles produced by the various companies.

However, California urged that an attempt be made to comply on all 1966 models instead of the 1967 models. Such a foreshortened schedule could be met only by a substantial variation from normal development, testing, and tooling efforts. To make this feasible the total task was measurably reduced, when the California officials granted an exception to meeting the standards for every 1966 model. Each of the companies was given an opportunity to file a list of exemptions, particularly relating to models which are distributed in California in limited volume. In addition, testing procedures were changed to utilize industry facilities, and trucks above one-half ton rating were excluded, pending more research and development.

CALIFORNIA REGULATORY PROBLEMS STILL BEING SOLVED

This change in the size and detail of the task led the companies to announce that they would meet the California exhaust standards on over 95 percent of 1966 passenger car models and light trucks. The programs to do that are just now at peak intensity. California officials are now driving and evaluating many of the vehicles to confirm our tests of compliance. Accelerated programs such as these have presented engineering and production problems which are being solved as they appear. However, the legislative problem of mandatory maintenance and inspection have not been solved in schedule, and this factor jeopardizes orderly regulation of controls in that State. Thus California air pollution control officials are still without the detailed and specific legislative backing on mandatory maintenance and inspection requirements to be able to set up their own program in detail.

Also, in trying to meet the California schedule the vehicle manufacturers have of necessity concentrated on the evaluations that relate primarily to California operating conditions; they obviously have not had sufficient time to acquire field experience with productionbuilt vehicles on the wide variety of climatic conditions that exist throughout the country.

QUESTIONS AND PROBLEMS IN CALIFORNIA

Meanwhile, administrative officials and legislators in California have been dealing with many other questions raised by the public in that State, as motorists have attempted to accommodate themselves to the present laws. The most serious problem has been that of gaining public acceptance of mandatory installation of even the relatively simple crankcase blowby emissions control systems on used cars. Difficulties are also being encountered in attempts to establish an annual mandatory maintenance program for exhaust control systems and a program for State inspection of crankcase emissions control devices on both new and older cars. At the present time, major revisions of the existing California smog laws and regulations are being debated in California in an attempt to cope with these questions.

Currently, also, scientists in California are reviewing many technical aspects of that State's requirements. While more stringent exhaust standards are being planned for 1970 application, they are trying to determine which hydrocarbons are really the most reactive ones in the atmosphere and most in need of control, and whether control of oxides of nitrogen will improve or worsen the smog situation, because controversy has arisen in this point.

HEAVIER TRUCKS NOT YET INCLUDED IN CALIFORNIA ENFORCEMENT

With respects to trucks, attempts to apply the California standards to trucks above one-half ton rated capacity are presently in early exploratory stages. Tentative test procedures have been written, and initial evaluations of the test procedures are underway. It is recog nized that heavier trucks must be dealt with separately, because many differences are involved in truck operation, including high-load factors, requirements for very long life and durability, and the fact that truck and passenger car operations do not follow the same cycles of operation. At this point, test methods, basic knowledge for development programs, and hardware to apply to trucks in the heavier categories are not available to implement standards.

The economic aspects of control of vehicle emissions have become more clear as California has reached the point of approving specific methods of control. It appears, for example, that the total cost of original equipment and subsequent maintenance for exhaust emissions control on millions of individual motor vehicles is very high in comparison with the cost of controlling air pollution from some larger stationary sources such as chimneys and stacks. Unfortunately, no exact comparisons can be made, but it is evident that installation of technically sophisticated control equipment and periodic maintenance on the many millions of individually owned motor vehicles-as compared with the control of emissions from a much smaller number of industrial and utility plants-results in an escalation of cost, in addition to multiplication of the individual problems to be handled.

ECONOMIC FACTORS OF MAJOR CONCERN TO INDIVIDUAL CITIZENS

The figures that are pertinent, and can be submitted for your general information, are the estimates made last year by the California State Motor Vehicle Pollution Control Board on exhaust control devices. They related to the installation, inspection, and maintenance of the three catalytic mufflers and one exhaust afterburner which the board had tested and approved to activate the legal requirements in that State.

The minimum price and installation estimate on any one of the four units was $50, with a range up to $95.

The minimum average annual gross cost for maintenance was estimated at $49.63. Multiplied by annual new-car and truck registration (875,000 in California) the indicated annual cost of this equipment for new vehicles would be more than $43 million. If the total of 9,500,000 vehicles which are registered in California was equipped with these devices the annual maintenance costs would be more than $450 million. The indicated costs to individual vehicle owners are

high and a pressing need must be established to justify the expense of such control programs in the public mind.

Although the automobile manufacturers have now developed new systems, the initial costs and maintenance will still be quite expensive.

EXPERIENCE AVAILABLE

The California accumulation of experience with its control program indicates the level of complexity and costs of vehicle emissions control, and provides the only experience available to evaluate other proposals to regulate motor vehicle emissions.

The motor vehicle industry has cooperated closely in the California program from the beginning. It has loaned scientists and engineers to help implement the program, and has been an active participant in the technical studies and development of test procedures, in attempts to avoid regulatory pitfalls. California has experienced many legislative and administrative problems in carrying out its program, especially in regard to public acceptance. At the present time major revisions in the California program are underway which concern equipment to be made available on our vehicles this fall.

RECOMMENDED FUNDAMENTAL STEPS

If Congress is to determine whether automotive emissions contribute significantly enough to air pollution all over the Nation, so that national control measures should be initiated like those in California: It would appear first to require that Federal ambient air quality standards be established, a basic requirement already recognized in section 3(c) (1) (2) (3) of the Clean Air Act, but not implemented by the Department of Health, Education, and Welfare. This is a starting point for the evaluation of any emission sources. Then the objectives in controlling vehicle emissions would become definitive and measurable. The ambient air quality standards should be realistic and acceptable to the States and communities where they would be employed. This would help to put the vehicle in perspective, along with other sources of emissions, and would supply meaningful interpretation of the contaminant effects of fossil-fuel burning, beyond the bare fact that motor vehicles consume currently about 16 percent of the total fuel of this type.

A Federal exhaust emission standard evolved to apply to motor vehicles would need to be acceptable to the individual States. Otherwise, variation deemed essential by local authorities may result in a condition that cannot be met by the manufacturers with a uniform product. Proposed legislation does not insure that a uniform national standard will actually result from a Federal standard. Our industry's experience is that States retain their regulations even in cases where Federal action has occurred, as in the application of regulations of the Interstate Commerce Commission pertaining to truck equipment.

Successful procedures exist which utilize voluntary standards developed in national engineering societies, with cooperation and coordination of the States and the Uniform Vehicle Code, to achieve nationally a high degree of uniformity on many aspects of vehicle regulation. Automobile lighting, turn signal indicators, and many

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other items have been developed by this method, which has proved effective through the years. More recently, authority granted by Congress to the States in the Beamer resolution, to form compacts, has been implemented by the States, affording them an opportunity to improve and accelerate their mutual action on safety equipment through the Vehicle Equipment Safety Commission. Such interstate compacts are parallel in many ways to the approaches being used to deal with interstate air pollution problems of a general, or nonautomotive type, also under authorization by Congress.

Technical details of exhaust-emission standards should not be written into law; rapid evolution in air pollution technology particularly indicates this. This concerns research in basic air pollution chemistry and engineering developments to facilitate vehicle emission test methods. Our industry is continuing its extensive studies in these areas, in addition to engineering developments to improve the emission control systems on our vehicles.

Any timetable established should be thoroughly realistic and should not impose unreasonable risks in an attempt to meet target dates without adequate preparation. If the automobile manufacturers were to be involved on a nationwide basis, sound experience dictates that it would require at least 2 model years for passenger car and light truck compliance with exhaust control provisions. This time is needed for further development of the California exhaust systems for wider application, for climatic experience and reliability testing, and to gain production experience. Also many months would be required to complete tooling for the greatly expanded volume. This means that the industry should be advised of requirements to be met 2 full years prior to the start of the model year in which control systems are to be provided.

Trucks are special: Since there is no truck experience as yet with control systems on vehicles above half-ton ratings, and no systems available, it is not feasible now to set any timetable limit which could predictably be met on the larger trucks or the many special purpose vehicles built by truck manufacturers.

Diesel engines: The situation with regard to diesel vehicles is less well established than it is with gasoline-engine-powered trucks. Diesel smoke can and should be controlled by proper maintenance procedures and fuel selection. Control of diesel odor, however, is beyond present technical capabilities despite extensive research efforts in this area. Certainly every effort will be made to learn more about the diesel-odor phenomenon, and to explore all possible methods of control.

Air pollution control legislation to require control systems on vehicles will not be effective unless periodic inspection is provided to be certain the emission control systems continue to function properly as new cars accumulate mileage and become older cars. Without inspection and maintenance, costly investments in emissions control equipment on vehicles will be wasted. Adequate inspection will require action and cooperation of the States to initiate programs and integrate inspection of emission control systems into inspection of safety features of cars; as in existing State inspection programs, it should be coordinated directly with State registration and enforcement programs. Of course, any such inspection must be done locally where

the vehicles are being used and where inspection facilities and knowhow exist.

Further, with respect to practical State inspection programs, the States must justify the added cost to their motorists during the years. that will intervene before the systems will have been included on enough cars to effect a noticeable improvement in the atmosphere. Unless the States are willing to accept this responsibility, and enforce it, the failure of the vehicle owner to maintain the emissions control system will render the entire program useless and wasteful, even though every new car is properly equipped when it leaves the factory. Since Congress authorized the interstate safety compact for the express purpose of dealing with this type of situation, the Vehicle Equipment Safety Commission should be used for this purpose. The interstate safety compact is designed to obtain State cooperation and interest in the application and enforcement of uniform safety features on cars. If Congress acts on bills now under consideration, a resolution of Congress, or suitable language in pertinent legislation, should commend to the Vehicle Equipment Safety Commission, and to the States, that they concurrently implement inspection programs to insure continued effectiveness of installed air pollution control equipment.

It is our view that information for administrative officials, and education for the motoring public as to the need for emission control measures, will be most important parts of any national program that is attempted. The public must understand that intent and purpose, and be confident that decisions made by regulatory bodies are sound, to insure their support and cooperation. If this is accomplished, the need for the initial investment cost, mandatory inspection, and good vehicle maintenance practices will be more acceptable to the owners of vehicles.

As indicated earlier in this testimony, it is our desire now to comment on some specific provisions of bills which are now getting consideration, in particular H.R. 7429, H.R. 8398, and S. 306.

COMMENTS ON H.R. 7429

This bill to amend the Clean Air Act would require federally purchased vehicles to be equipped with exhaust control measures. It is therefore comparable with the proposed standards of the General Services Administration. The effective date, October 1, 1966, could be achieved on the volume of vehicles which would be purchased at the Federal level.

However, as written the bill does not recognize that diesel vehicles are not a part of this problem, and need to be treated separately from gasoline-powered vehicles. Also, it does not recognize the fact that control equipment has not been developed or tested for application to trucks above half-ton rating and that no hardware is available for such application. The GSA standards do recognize this fact, as do the California laws and regulations.

In addition, H.R. 7429 does not provide for appropriate maintenance and inspection measures. We regard this matter of maintenance and inspection as a vital requirement if air pollution control results are to be achieved.