[Recorded by Electronic Apparatus]
Tuesday, October 24, 1995
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[English]
The Chairman: Order.
Good afternoon, ladies and gentlemen. We welcome you in this room. This is quite an historical room, because it is a place where national caucuses meet. The seating arrangement is quite different - and the noise level.
The purpose this afternoon is to hear from the Association of International Automobile Manufacturers of Canada. It is my understanding that Adrian Bradford leads this delegation. He is their associate executive director.
We welcome you. Before you launch in your presentation would you be so kind as to introduce your colleagues.
Mr. Adrian Bradford (Associate Executive Director, Association of International Automobile Manufacturers of Canada): Thank you, Mr. Chairman. I am on staff with the Association of International Automobile Manufacturers of Canada. I have with me Ed Brune, general manager of emissions engineering with Toyota's technical centre in the United States; Glenn Bryksaw, responsible for emissions compliance with Honda Canada; and Eugene Dubecki, service engineer manager for Honda. Also present are other representatives of Toyota, who will assist in answering your questions.
I want to back up and give you a little bit of background about the Association of International Automobile Manufacturers of Canada. Thank you for this opportunity to make this presentation on Bill C-94.
The Association of International Automobile Manufacturers of Canada represents those companies selling passenger cars and light-duty trucks that are based outside North America and are not part of the 1965 Autopact. You'll see 16 companies listed in your hand-outs, many of whom have supplied innovative automobile technologies to the Canadian automotive market.
In 1991 the association changed its name from Automobile Importers of Canada to recognize the fact that several of its members are now building vehicles and components in Canada.
The association represents these Canadian distribution companies before federal and provincial governments, particularly Transport Canada, which is directly responsible for regulating the safety and emissions standards. However, the association also deals with a wide span of other subjects such as provincial standards for mobile air conditioners, fuel economy initiatives, and recycling of automotive parts.
Our presentation this afternoon will attempt not to repeat the information you heard earlier today, although we will be making several points in response to the assertions made by Ethyl representatives. MMT has long been a problem for AIMC members, although with the headroom that was permitted by emissions standards up until 1988, AIMC members could continue to meet emissions requirements. I'll get into a description of headroom a little later on.
The accumulation of manganese oxide in the exhaust system of vehicles usually would become severe after the vehicle went out of warranty coverage, and was viewed as a long-range service problem. This was in the 1980s. However, in the mid-1980s Honda had undertaken studies that found a degradation in emissions performance with respect to carbon monoxide and hydrocarbons, which was becoming more severe over the life of the engine where MMT was added to the gasoline.
About the same time, Mercedes Benz researchers undertook comparative bench studies in Germany, finding that a higher catalyst activation temperature was required for engines fueled with MMT in order to achieve the same conversion efficiency as would be achieved with an engine fueled with clear fuel.
Moreover, the accumulated mass of manganese oxides in the catalyst significantly reduced the catalyst's efficiency once temperatures exceeded 800 degrees Celsius in the engine.
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Mercedes Benz participated in the Canadian General Standards Board study in 1985 and 1986 that found an increase in hydrocarbon emissions in gasoline containing MMT relative to clear gasoline. At the same time the study of the Canadian General Standards Board confirmed that MMT tended to form manganese oxide deposits in exhaust systems and indicated that the deposits could impede the sensor's ability to function properly in controlling exhaust emissions.
The memorandum of understanding between vehicle manufacturers and the federal government for 1994 and 1995 model-year vehicles recognized the effects of what we called at that time ``Canadian fuel formulations'' in an addendum, which AIAMC members insisted on seeing in the memorandum of understanding because of the effects of MMT recognized in these early studies.
A further study was done by Toyota. While the Toyota study, which was done on a 1990 Toyota Camry, found a higher rate of hydrocarbon and carbon monoxide emissions on vehicles fuelled with MMT, this study has since been superseded by a more comprehensive study, which Mr. Brune is going to describe in his presentation.
With the passage of the U.S. Clean Air Act in 1990, Environment Canada began to look at means of upgrading Canadian emissions standards to ensure Canadians could receive the same advanced emissions technology available in the U.S.
- Transport Canada confirmed its intent to study the effects of MMT as opportunities to tighten
future emission standards are investigated.
- That is a direct quote from a letter.
The memorandum of understanding between the vehicle manufacturers and the federal government was written to recognize that the durability of certain emission control components could be adversely affected by what we call ``Canadian fuel composition''. This wording was intentional, because it recognized the disappearance of ``headroom'', the definition of head room being, ``the difference between design and mandated emission standards''. This headroom had allowed earlier model-year vehicles to tolerate MMT and still meet emission requirements.
Because of headroom -
The Chairman: Excuse me for interrupting you, Mr. Bradford. It would be nice if you were addressing a bunch of mechanical engineers, but unfortunately you are not. There are certain terms that escape our ability to capture them so quickly. For instance, headroom: when you come across terms like that, could you perhaps elaborate for a moment?
Mr. Bradford: Okay. I defined it somewhat quickly. I will probably defer to some of my engineering colleagues here, who can define it more exactly. It is essentially the difference between the mandated emission standard and the design standard, the one you design your vehicle to, in order to ensure you have enough room in between to meet the mandated standard.
Until the 1994 to 1996 standards, there was always sufficient headroom that vehicle manufacturers could meet those standards with some room to spare. But a lot of that room has disappeared now, with the much more stringent standards we are trying to meet in the 1994 to 1996 period.
Petroleum companies resisted the vehicle manufacturers' evidence of problems with manganese deposits, leading vehicle manufacturers into a lengthy debate over the definition of ``compatibility'': whether fuels must allow emission controls to operate at their optimum or merely allow the vehicle to operate. As vehicle manufacturers introduced improved technology to control emissions, the effectiveness of that technology is being compromised by currently available gasoline.
Between 1994 and 1996 vehicle manufacturers' emissions warranties became longer in order to keep them harmonized with U.S. requirements. They concurrently introduced advanced on-board diagnostic systems - the OBD-II systems you heard about earlier today; I won't try to explain those, because I assume those were well explained this morning - which are highly sensitive in detecting engine emissions deterioration relative to previous OBD technology. We had OBD-I and now we have OBD-II.
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International vehicle manufacturers began planning for a model year several years in advance, anticipating all foreseeable problems in certification and production. Over the last year they have fixed plans for the 1996 model-year vehicles in anticipation that MMT would be phased out by September 1995. Manufacturers still anticipate the phase-out of MMT by early 1996 so that damage to long-lasting catalytic converters and other emission components will be minimized.
For 1996 model-year vehicles, the OBD-II systems will operate as a lifetime vehicle inspection and maintenance system to immediately alert consumers to even minor increases in emissions. However, virtually no testing has been done, beyond that by vehicle manufacturers, on current-generation OBD-II systems, which we're seeing installed on the 1996 vehicles. I guess that's a reflection of how quickly the technology is evolving.
I'd like to briefly address the allegations of a nitrogen oxide benefit as a result of using MMT in fuel. Although this benefit has been broadly touted, we've yet to see an explanation of the mechanism by which manganese coating on engine and exhaust components causes NOx reduction.
I believe it's misleading to conclude that manganese coating on engine emission systems results in any consistent reduction of nitrogen oxides. The data clearly indicates that nitrogen oxide reductions in six out of eight models in the 1992-93 fleet study that was undertaken by Ethyl showed no statistically significant NOx reductions.
Two TLEVs - what we in the industry call transitional low-emission vehicles, and what are essentially new-technology vehicles - show no statistically significant differences in NOx emissions.
In summary, we believe the Ethyl presentation uses data to extrapolate emission levels beyond the useful range of the data.
The Chairman: Can you describe some examples of transitional low-emission vehicles that are on the market?
Mr. Bradford: Yes. There's currently at least one operating in California that one of our members introduced for the 1996 model year.
Maybe I could ask Glenn Bryksaw to address that, because he's directly familiar with the technology that went into it.
The Chairman: This is not a question period. I'm just asking you to expand where you can in your presentation. Some of these terms are completely new to the committee.
Mr. Bradford: Between 1992 and 1993 Honda introduced a Civic model in California that was certified to the standards of that time and is still called a transitional low-emission vehicle.
We've used the terms tier-1, TLEV, LEV, ULEV and ZEV quite regularly in the auto industry. I'll try to define all those, because they really give you an overall idea, without going into a lot of explanation of the acronyms.
The tier-1 vehicles are the 1994 to 1996 vehicles. The TLEV vehicles are transitional to the low-emission vehicles, which will be required in California starting in 1998.
Beyond that is another vehicle called the ULEV, or ultra low-emission vehicle. The ultra, ultra low-emission vehicle is the zero emissions vehicle, which for all practical purposes is an electric vehicle.
So it's really just a ratcheting down of the emissions standards represented by each of these. The TLEV is the first step beyond the tier-1 vehicle that we're living with in the 1994 to 1996 period.
I'll say a few words on the current situation in the United States following Friday's court decision favouring the registration of MMT.
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We do not expect MMT to make major inroads in the U.S. additive market due to its prohibition in California and its prohibition in areas that require reformulated fuels. In the areas that require reformulated fuels, which are areas with severe non-attainment problems and air quality problems, there are prohibitions on the use of heavy metals as additives. Also in the United States you have a large octane pool already in existence because of the current availability of other octane enhancers such as MTBE, ETBE, and ethanol.
I'll now turn the floor over to Mr. Brune, who's going to explain the research that was carried out by Toyota on MMT.
Mr. Edmond Brune (General Manager, Engine Engineering Department AA1, Toyota Technical Centre USA): I'm Ed Brune, and I'm with the Toyota Technical Centre USA. Thank you for the opportunity to address you on this topic today.
The results I'm going to present today are from a testing program that was conducted in Japan at the time that Ethyl Corporation initiated their last round of waiver requests at EPA, so they're several years old. We have presented this data to the EPA as part of the waiver request that Ethyl had presented. We have presented this data to Transport Canada in the past. However, we believe this data is current data. We think it is very much in agreement with past and current data that has been developed on the effects of MMT by the auto industry, so I'd just like to present it today for your consideration.
After we conducted this program, we had some rather serious concerns about MMT. One of the two major concerns is the effect of MMT on in-use reliability of our emission control systems, which can really affect the real world air quality, which could suffer from this. Of course, the second concern is that if it's affecting our emission control systems, we could be affected with higher warranty costs and customer dissatisfaction. These were issues we were quite concerned about.
The next slide basically gives a little outline of the investigation we conducted. We collected some parts in Canada that had been run on MMT-type fuel. We conducted an in-house durability test. We also collected some parts from the U.S. that had not been run on MMT fuel to compare with the Canadian components. Of course, we ran some emission tests on these components with and without MMT.
The next chart is a result of the program we ran in Japan. Basically, this is a car that's still fairly current technology for Toyota. It was a 1990 4-cylinder Camry, but this car has electronic fuel injection and a close-coupled catalyst to get the catalyst hot quickly. It has an under-floor catalyst and a dual 02 system with oxygen sensors, one in front of the car and one in the back, to get better fuel control. This is still pretty current technology for Toyota. We still basically use this technology.
As you can see on the graphs on the left, we ran a vehicle of this type for 30,000 miles with MMT, then we changed the components and ran it for 30,000 miles without MMT. As you can see in the top curve, we had a fairly significant increase in hydrocarbon emissions with MMT. On the middle graph you can see that we had some increase in carbon monoxide emissions with MMT.
On this particular car we did not really see any NOx as a result of MMT. Perhaps this is because with the dual oxygen system, we are compensating for the shift in the front oxygen sensor, which I think Glenn's going to talk about.
We were very concerned about the increases in hydrocarbon and carbon monoxide because we have to design our cars to meet those standards. We're worried about anything that will -
The Chairman: Mr. Brune, I hate to interrupt you, but not being in the position of having a PhD in mechanical engineering, I need your help. Perhaps I'm alone in this room in understanding the Toyota data on which you were elaborating a short while ago, entitled ``Mn Deposit Build-up on the Catalyst''. Can you explain the two vectors and go over it again? What does ``Sampling Position in Catalyst'' mean? I'm just trying to interpret the meaning of your charts.
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Mr. Brune: I was discussing this graph.
The Chairman: But a few minutes ago -
Mr. Brune: I'm really sorry; we must be out of order. I was discussing this graph.
The Chairman: But a few minutes ago you were presenting this chart.
Mr. Brune: No, I haven't gotten to that chart yet. In my package, that's two more charts back.
The Chairman: In your package, that chart is four pages after this.
Mr. Wappel (Scarborough West): Mr. Chairman, these fine gentlemen and ladies might all have degrees in mechanical engineering, but perhaps they should discuss numbering the pages with their secretaries.
Mr. Brune: We're sorry.
The Chairman: I'm sorry for the interruption. Go ahead.
Mr. Brune: Would you like me to start over on this one?
The Chairman: Yes, please.
Mr. Brune: This is a program that was run in Japan by the engineers there. This vehicle is a four-cylinder Camry. It was a 1990 two-litre car. This car has our latest type of technology. It has electronic fuel injection, a three-way under-floor catalyst and a close-coupled catalyst to get the quick light off and get cold-start emissions down. It also has a dual 02 sensor system. The rear 02 sensor trims the output from the front sensor to give you better air-fuel control.
We ran this car 30,000 miles with MMT and then changed the oxygen sensor and the catalyst and ran it 30,000 miles without MMT. The three charts on the left are the results of hydrocarbon, carbon monoxide and nitrogen oxides tests.
As you can see, on the hydrocarbon we had a significant increase in hydrocarbon emissions over the 30,000 miles. On the CO we also had some increase over the 30,000 miles. With the NOx we did not really see any effect with or without the MMT. We believe this may be a result of the dual 02 oxygen sensor system compensating for the rich-shift effect you've heard some people talking about today, which Glenn Bryksaw will discuss in a lot more detail.
Based on these results, we're really concerned about the effects of MMT on hydrocarbon and carbon monoxide. When we design our cars, we have to design them to meet these standards as well as an NOx standard. We have a difficult time accepting this kind of an increase in hydrocarbon and CO on our vehicles as a result of the MMT.
The larger graph on the right of the page is a graph of the catalyst light-off temperature. This basically is a graph that shows you how quickly the catalyst reaches operating efficiency versus temperature. Operating efficiency is 0 to 100 on the left of the scale, and the temperature runs across the bottom of the chart.
As you can see, with the MMT the catalyst does not warm up as quickly as it does without MMT. This is a real concern for us because nearly all the emissions that are left to control in the vehicle are cold-start emissions and we're working very hard on all kinds of things to try to reduce cold-start emissions because this is where the majority of the emissions to be controlled are present now.
We are really concerned about the effect that MMT has here by delaying the catalyst in reaching operating temperature. It goes counter to everything we're trying to do.
I would like to say that if MMT were a protective coating and a benefit on the catalyst, it certainly doesn't show up here. It's causing the catalyst to not reach its efficiency as quickly as we'd like it to.
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So we're very concerned about this. I think these data are basically in agreement with the Mercedes report Adrian spoke of earlier. It's really a major concern of ours.
Again, besides the catalyst light-up temperature, we're very concerned about engine-out emissions. On a cold start we're trying to reduce engine-out emissions as well as trying to get the catalyst hot as quickly as possible. We're doing all sorts of things in fuel control - intake manifold designs, combustion chamber designs, oil control - to try to reduce engine-out emissions. We're very concerned about any additive such that 80% of it stays in the engine and can be in the combustion chamber and perhaps give us difficulties in trying to reduce engine-out emissions. This additive can certainly have an adverse effect on engine-out emissions.
We could go on to the next chart, a comparison of emissions with and without MMT. These are the results we obtained from some components that were collected in the U.S. and in Canada. Of course the Canadian components had seen the effects of MMT and the American components had not been subjected to MMT. Again, these are four-cylinder Camry catalysts. In order for us to get some of this higher-mileage data, these are 1988 to 1990 Camrys.
This car has just an under-floor catalyst, so these are the results from an under-floor catalyst. As you can see, the three black dots are hydrocarbon with MMT and the -
The Chairman: Excuse me, Mr. Brune, you made reference to a type of catalyst. Can you repeat the term you used - ``under-floor'' - and what does it mean? Please, may I remind you again that we are politicians, underlined several times.
Mr. Brune: I'm sorry.
By ``under-floor'' we just mean the catalyst is located essentially under the front seat of the car, back away from the engine. Today we're talking about under-floor catalysts. A lot of the catalysts from before we had these really tight emissions standards would work effectively there, but now we're also looking at close-coupled catalysts, which are connected right up close to the engine so they'll warm up quickly. So we have the two terms: ``close-coupled'' and ``under-floor''. Some cars have both.
The Chairman: I see. Thank you.
Mr. Brune: As I said, you can see that at the higher mileages the MMT components, when tested on this car in Japan, showed higher hydrocarbon than the non-MMT components. In fact, we estimate the hydrocarbon to be about 37% higher on the MMT components than on the non-MMT components. Then on CO, which is the middle chart, again, at the higher mileages on the data points for the MMT we're seeing higher CO emissions. This correlates with the previous data. We estimated it to be about a 48% increase in CO with these components.
On this particular car, which is a single O2 system, under-floor catalyst, car, we did see that the NOx values were lower with MMT than without MMT. This may be because of the rich-shift phenomenon people have been discussing.
So again we're seeing increases in hydrocarbon, increases in CO, with components subjected to MMT. On this particular car we did see some decrease in NO2.
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This chart was prepared to just show how the manganese deposits accumulate in the catalyst. If you see the little cylindrical chart at the top - one, two, three, four - these are basically positions where we sectioned the catalyst, and with that, the deposits. The graph shows how those deposits accumulated in those various areas of the catalyst.
So this says that the manganese tends to start to develop in the front of the catalyst. As it goes back, it gradually gets less.
This data was from a 1988, two-litre, four-cylinder Camry. On this particular catalyst, on the front section of the catalyst, which would be the little number one up there in the cylinder, the weight of the catalyst increased about 3% as a result of the manganese. You can see how that weight trails off as you go back further into the catalyst.
We're trying to say, as people have said, that the manganese does deposit in the catalyst. It tends to deposit in the front of the catalyst first. It gradually builds up as mileage increases toward the back of the catalyst. In this case, near the front of the catalyst, we had about a 3% weight change in the catalyst at that area.
The little bottom graph is of a oxygen sensor that we analyzed the samples on. Of all the samples we took from this oxygen sensor, 28% of the deposits in that oxygen sensor were manganese.
The next chart, which is this coloured one, is just to show you a sample of a catalyst from a pick-up truck that we obtained in Canada. It shows that the manganese is building up in the cells of the catalyst. In the larger picture, you can see it's actually plugging up some of the cells in the catalyst.
This is a very large blow-up of that section of the catalyst. You can see some of the cells in the catalyst plugged up with manganese.
I would just like to summarize our results. From our testing we can see that manganese does deposit within the engine and emission control components. The components were indeed coated with manganese oxide. Our results showed that MMT increases hydrocarbon and CO tailpipe emissions. The hydrocarbon and CO emissions were higher with Canadian vehicle components that were subjected to MMT than with U.S. vehicles that were not subjected to MMT.
We're very concerned about MMT effects on new technology because of the low standards we have to meet in the future. We're also concerned about long-term warranty and reliability effects on some of our current systems as a result of this test program.
Thank you very much.
Mr. Bradford: I'll ask Glenn Bryksaw to present Honda's research.
Mr. Glenn Bryksaw (Auto Compliance Coordinator, Service Engineering, Parts and Service Division, Honda Canada Inc.): Good afternoon, Mr. Chairman, members of the committee. I'm Glenn Bryksaw, auto compliance coordinator from Honda Canada Inc. in Scarborough. I'd like to give you a little presentation on the Honda investigation into the effects of manganese on the emissions control systems of Honda automobiles.
I'm also going to try to do an ``Emissions 101'' course so that hopefully some of the things we've been talking about with regard to ``rich shift'' and those other areas are a little bit clearer.
I'll begin with the first slide after the title page. It says that in early 1994, Honda identified a high claim rate on oxygen sensors in Canada. Honda suspected MMT might have been the cause and began focusing on emission system problems in Canada. Sample part collection and analysis continued through the summer of 1994. In October 1994, Honda reported the findings to Transport Canada and Environment Canada.
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The Chairman: Can you refresh our memories as to what oxygen sensors are?
Mr. Bryksaw: I will. In fact I'm going to talk about that in a fair bit of detail.
The oxygen sensor is the feedback control system for the emission control system in the vehicle. It provides an understanding, on the part of the computer system within the car, of what the engine is doing in terms of whether the air-fuel mixture that's going in is rich or lean, and how to compensate for the various driving conditions, whether you're accelerating, decelerating or driving on the highway at a steady speed.
The current systems in 1996 require the use of two oxygen sensors. Previously we only used one. The first one is now used primarily to compensate for the various transient driving conditions. The second one is used as a monitor for the catalyst function, and that's where the OBD-II systems come into play. The previous system, OBD I, had a single oxygen sensor that was primarily used for adjusting the air-fuel ratio.
We began our warranty data comparison by comparing the provinces of Canada with the northern United States, with similar climates and vehicle populations. When I say similar, we compared about 250,000 vehicles in Canada with about 480,000 in the U.S., so we made sure the sales were, in this case, approximately two to one, but it was certainly not a small sample. We compared the number of oxygen sensor warranty claims versus the distance travelled, and we found that the oxygen sensor claim rate was significantly higher in Canada than in the northern United States.
Mr. Forseth (New Westminster - Burnaby): Excuse me. Are you referring to this graph as part of your presentation?
Mr. Bryksaw: Yes.
Mr. Forseth: Do you have any available numbers to attach to those two vectors?
Mr. Bryksaw: I'm sorry. This information is highly sensitive and competitive. The information has been provided to Transport Canada and Environment Canada in confidence. I would not be prepared to provide that information at this time.
Mr. Forseth: Okay, continue.
Mr. Bryksaw: In addition, we note that the claiming rate tends to increase in Canada, where it levels off in the United States. It appears that the beyond warranty experience that we don't know about is much more severe in Canada than it is in the U.S.
This data represents a high-volume model in Canada, and as you've noted, the Y axis on this chart represents the claim rate and the X axis the number of kilometres at the time of the warranty claim, or repair by the dealer.
We noted that while the actual data varies from model to model, the trends we experience on Canadian and northern U.S. states data seem to follow this sort of pattern.
Is everybody satisfied with the explanation of that chart?
The Chairman: Yes, go ahead.
Mr. Bryksaw: I'm going to attempt at this time to go into Emissions 101 to give you some understanding of the whole issue of rich shift. We did an analysis of non-failed oxygen sensors from Canadian and U.S. sample vehicles. We basically asked dealers to call their customers on a random basis, ask them to come in and make sure there were no reported problems with those vehicles in terms of either drivability or emissions performance. We asked them to replace the oxygen sensors on those vehicles. We did that in both Canada and the U.S. and then we sent those samples to Japan for testing.
Those tests came back with the results you see in the chart here; it's a performance comparison. On the Y axis we have a rich mixture at the bottom and a lean mixture at the top, and across the bottom is the number of kilometres on the car or the sample.
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The O's represent the data from the U.S. samples. The X's represent the Canadian data. We've put a best fit line through each of the data that indicates to us there is a significant difference between the two, which we are calling the rich shift.
I don't want to confuse you, but this rich shift represents what we call in the business ``lambda''. It is a numerical representation of the air-fuel ratio. The difference between those two best-fit lines from that data was 0.05. I would like you to remember this number, because later I'm going to refer to it with regard to why it is a problem for us.
Mr. Forseth: That's 0.05 of what?
Mr. Bryksaw: I will explain. It's 0.05 of the air-fuel ratio. With air-fuel ratio, 14.7:1 is the common optimum or stoichiometric air-fuel ratio, which means a perfect balance of fuel to air to get complete combustion. This 0.05 would be plus or minus that 14.7. It would cause a rich shift, which would increase the amount of fuel as opposed to air. It would actually drop that number, 14.7, down by a factor of 0.05.
Mr. Forseth: To 14.2.
Mr. Bryksaw: No, to 14.65. That is a significant change, and I will continue with my explanation to later on indicate why that is.
Is everybody clear that this is how we described a rich shift? The performance was measured on each of those samples.
Going over to the next page, I want to talk a little about Honda oxygen sensors. We have two styles of sensors or designs. One would be considered the conventional style and the other is a proprietary Honda product called the LAF sensor, or linear air fuel sensor. The left-hand curve in the graph you see here shows a typical oxygen sensor response curve with an abrupt drop in the output voltage at the optimum air-fuel ratio point.
As you can see, the voltage on the top at the rich - looking at the left curve now - drops very gradually in about the 0.8 to 0.7 volt range. At the point where the optimum mixture is obtained, that voltage drops rather dramatically down to 0.3 to 0.2 volts. This is how auto manufacturers control the air-fuel mixture. By having the engine switch back and forth by this abrupt change, we can then determine whether we are close to the optimum or stoichiometric air-fuel ratio.
If you can control that and have that oxygen sensor flip from 0.7 to 0.3 and back to 0.7 in a fairly tight timeframe you know you are just about on that optimum air-fuel ratio point.
Mr. Forseth: What does stoichiometric mean?
Mr. Bryksaw: Stoichiometric is the optimum. It is the point at which complete combustion occurs.
The right curve represents technology that Honda has designed. It's called a linear air-fuel sensor. It has a significantly different slope with two straight lines joined in about the middle. It allows us to fine-tune that air-fuel delivery. It's intended for our future technology as well. It allows us to take a smaller and smaller window and make that window tighter all the time. So we're not worried so much about the major flip from the top of the switching point at the optimum airfield ratio to the bottom. This allows us the flexibility to control the airfield ratio to an even tighter point.
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Mr. Forseth: So the first is almost operating like an on-off switch.
Mr. Bryksaw: That's correct.
Mr. Forseth: Can you describe what this is like? Is this like a probe?
Mr. Bryksaw: It's a zirconium oxide crystal. What it does is compare the oxygen in the exhaust gases on the one side versus the oxygen in the ambient air on the other side. This crystal generates a voltage. What I'm showing here on this curve is the voltage that is generated by this crystal when it reacts with the oxygen in the exhaust gas.
Mr. Forseth: Where is this sensor?
Mr. Bryksaw: It's located in slightly different places in different models. It is in the exhaust stream. It can be anywhere from being mounted right in the exhaust manifold, right at the point where the exhaust valve is, just a little bit downstream from there, or it may further down. In the case of an under-floor catalyst, it can be mounted just prior to that catalyst.
Secondarily, with the 1996 technology, the tier I technology, we have a second oxygen sensor that's mounted after the catalyst to monitor that catalyst's performance. So the location of that catalyst will determine where the oxygen sensor is located in the exhaust stream.
Mr. Forseth: Thank you.
Mr. Bryksaw: The next chart shows a three-way catalyst response curve. The bottom curve is carbon monoxide, CO. The middle curve, on the left, is the hydrocarbon curve, and the NOx curve is on the top of the graph.
I'll begin by saying that as emission control requirements ratchet ever tighter, precise control of the airfield ratio is required - an optimum airfield ratio window of 0.2 lambda. Now, remember that shift we were talking about before was 0.05. So 0.2, the window, is essentially that optimum airfield ratio window. That very thin window in the middle that says optimum airfield ratio basically represents the 0.2 lambda, and that's what we are targeting for.
Within that window, you will see that the balance of the three pollutants, the reduction done by the catalytic converter, is optimized. You have the top point of all three pollutants. This is the way the systems are designed. The optimum airfield ratio point allows for improved catalyst performance, and any shifting outside of that optimum window causes us great concern.
You will note, on the bottom curve here we've got rich versus lean, and you will see the relationship between the catalyst efficiency on the left scale versus the airfield ratio at the bottom. You can see that the carbon monoxide efficiency drops off very drastically when the system richens up, and it improves as the mixture leans out. You can see it's forever going up to the lean side there. The efficiency keeps going up.
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Parallel to that, the hydrocarbon curve doesn't quite drop off as much, but it also goes up and continues to extend out. You don't see it in the black and white chart, and I apologize for that. Those two lines are one on top of the other and they both go up and to the right once you get past the optimum airfield ratio window.
Mr. Forseth: As you move right, as you lean out, obviously the engine-out emissions are greatly improved. Obviously there is something else that happens to the engine as you lean out. How far can you go out before the engine stalls or really begins to run roughly?
Mr. Bryksaw: Drivability is another issue here. At or around the optimum airfield ratio point, drivability is just about as good as it can be.
What you'll find is that the trade-off here basically is against the other pollutant, which in this case is NOx. What happens is that as we go lean, the NOx goes up. The relationship basically boils down to combustion temperature.
If you increase the combustion temperature, there are a number of chemical reactions that occur during the combustion that create nitrogen oxides. If you richen up the mixture, the combustion temperature goes down, and fewer nitrogen oxides are produced, and that is a problem for us when we do our catalytic conversion further downstream.
The problem is a twofold one. There is a trade-off between the two emissions: hydrocarbons and CO on the one side, and the NOx on the other. They have almost mutually exclusive results. You can't do one without affecting the others.
The next slide talks specifically to the 0.2 air-fuel ratio. I'm using the arrow here to mark the optimum air-fuel ratio window that we had shown in the previous chart.
The left side of this chart represents time. The current technology is capable of keeping the air-fuel ratio in the optimum window for approximately 50% of the time. That's represented by that low, wide bell curve at the bottom there. It's current technology; this is what we've been using up until now. But we have a problem with the fact that the requirements on emission controls are ratcheting down so much that we have to control that even tighter.
Mr. Wappel: The optimum window is that target you've identified?
Mr. Bryksaw: Yes.
Mr. Wappel: You're saying that currently 50% of the time it's within that small space?
Mr. Bryksaw: Yes. The graph is intended to be a representation; it's not.... What I'm trying to tell you is that number is exact within that window.
Mr. Wappel: What I'm asking is, that bell curve doesn't look as though it's 48.9% of the time within that tiny space. It looks as though it's a tiny percentage of the time.
Mr. Bryksaw: Okay. Well, my guess is it's about 30%. I apologize for the misrepresentation of the curve shape, but the number is correct. All I'm trying to do here is to make a point about what we're doing, what the shape of the curve will look like and what we're doing with the numbers here.
Mr. Wappel: As I understand it, you're saying that at this stage you can get it in the optimum range 50% of the time, and what you'd like to do is get it into the 80% to 90% range. I presume the hammer comes that you can't do that if there is MMT in the gas.
Mr. Bryksaw: Yes. An excellent straight man.
.1630
Using the Honda linear air-fuel sensor, an optimum air-fuel ratio can be maintained for almost 85% of the time; we have 84.9%.
Now, here's where we have the problem. That window is 0.2 of an air-fuel lambda wide. Our shift is 0.05, so we've lost one-quarter of that window. What's happened is that with our test and within the parameters - and by the way, those samples we took were all within warranty - we already have a problem with time. That shift of the oxygen sensor, which we're relating to the manganese coating that was on those sensors, is a result of that manganese. This causes us a problem in targeting our future technology and in keeping it within that window in the future, the way we want to.
Basically we're throwing away one-quarter of that window. We're taking that part of it and saying that we can't deal with it because we don't necessarily know how much manganese coating there is going to be on each one. Our feedback from the operating conditions of the vehicle is therefore a problem, and we don't know how to adjust for that. As a result, we make an estimate at this point - and this is purely an estimate - that the amount of time we'd be able to operate within that window, using the 0.05 shift that we know about, is about 60% to 65% of the time. This is an estimate, but it is reasonable based on the size of the window and on where we're going. Even under optimum conditions, our future technology would not allow us to get that 85% window.
The Chairman: I'll ask you to conclude so that members can start asking questions.
Mr. Bryksaw: Okay, I'll just wrap it up.
The oxygen sensor replacement rate on identical hardware vehicles is significantly higher in Canada than it is in the northern United States. Canadian oxygen sensors are coated with manganese oxides and Canadian oxygen sensors exhibit a rich shift when compared with U.S. samples. Our concerns are that advanced sensor designs will allow for very precise control of air-fuel ratios. This precision is needed to meet the ever-tightening emission requirements, but a random coating of manganese oxides is intolerable with both current and foreseeable technology.
Thank you.
Mr. Bradford: Mr. Chairman, if I could just continue along the same vein, I'll try to keep this as straightforward as possible because I realize that what we've presented here is very technical. However, it was technical for a reason. We're trying to show that the studies we've undertaken have been more than merely anecdotal, as some may have referred to them. Indeed, if MMT did reduce emissions without adverse effects on emission control technology, then vehicle manufacturers would advocate its use in fuels worldwide.
It's hardly surprising in this light that an independent consultant hired first by the Canadian Petroleum Products Institute, and subsequently by Environment Canada, found that:
- ...the OEM's have substantiated the claim that MMT's use produces significantly different
emissions behaviour and long-term durability results than the clean fuels allowed in the U.S.
- I add to this that no manufacturer's study has indicated that there is a safe level of manganese for
use with advanced emission control technology.
With that, I'll conclude our presentation and await your questions.
The Chairman: The second page of your conclusions is incomplete. Is that by mistake or by oversight?
Mr. Bradford: Is that the last page?
The Chairman: Yes.
Mr. Bradford: You can strike that last page. Those are points I will address if we get into a discussion on them.
.1635
The Chairman: Well, as we do in this committee, we'll be glad to start with the opposition, with Mr. Forseth, followed by Mr. Bryden and Mr. Wappel.
Mr. Forseth: I'll have a go at the Honda Canada material. I find it interesting that with the warranty data on the Honda oxygen sensors you couldn't put any numbers on that graph. When there are no numbers or generalities, the graph becomes useless.
I'm looking at the second graph on performance comparison, where it shows the rich shift. One of the things we look at, of course, is consistency. If you are trying to look at a window, it looks like the data from the material that doesn't have MMT is all over the place, whereas it looks like MMT brings the operating range to a position that is more linear, more along the line. One might therefore be able to conclude that the MMT performance actually reduces the variability number. Certainly, that's something in theme with what you've been looking at.
You talked about the crystal that is in the sensor. What would be the normal life expectancy of these crystal sensors? In an exhaust system, these things are obviously not going to last forever. There must be some kind of replacement rate. What is the projected reliability of those, first of all?
Mr. Bryksaw: Under the current situation and up to this point, we have been providing warranties on our exhaust emission components basically for five years or 100,000 kilometres in Canada. With the enhancements in warranty, the U.S. EPA requirements are for eight years or 130,000 kilometres. That is what we are.... We definitely do not want to see a failure within that window because then obviously it's a customer dissatisfier. Actually, it is at any time.
There is no specific design lifetime on an oxygen sensor. All we're saying is that we look at what we consider to be a random failure rate of a certain percentage within the period of the warranty. What number we could live with is decided at Honda.
Mr. Forseth: Are these little sensors very expensive, or is it much like a PC valve?
Mr. Bryksaw: These are fairly expensive items, yes.
Mr. Forseth: You would think the recommended replacement would be 60,000, 70,000, 80,000, or 100,000 kilometres or whatever, and that you would then take it into the garage, pop the two out and put in two in five minutes.
Mr. Bryksaw: No, we do not recommend replacement. The on-board systems are capable of diagnosing whether or not there is a problem with these components. If there is no problem, the lifetime is indefinite.
Mr. Forseth: That's all for now.
The Chairman: Mr. Bryden.
Mr. Bryden (Hamilton - Wentworth): To follow up on my colleague's remarks, I would like to know how much it costs to replace these things when it's determined that they have failed.
Mr. Bryksaw: Right now, the average cost of a typical Honda oxygen sensor is in the range of approximately $250 on a retail basis. That is a ballpark number.
Mr. Bryden: What is the worst pollutant among the three: carbon monoxide, hydrocarbons, or nitrous or nitric oxides?
Mr. Bryksaw: I don't know that you can call one worse than another. The balance of nitrogen oxides and hydrocarbons was dealt with a fair bit this morning. I'm not an atmospheric chemist, so I can't tell you specifically what the ``worst'' would be. What I do know is the balance is critical in terms of the whole issue of smog and ground-level ozone. It's not appropriate to trade one off against the other. As manufacturers, the standards set by the government, which we must meet for compliance, require that we reduce all three. We can't do two and not the other one.
.1640
Mr. Bryden: I must admit I have been under the impression that the NOx pollutants are far more complex and have contributed more to pollution than the other two. I do point out that in the Toyota chart - this one has the three here - there is a significant improvement with respect to NOx when you use MMT as opposed to when you do not. I would like to have all three of you comment on that, because that argues....
When I look at that and compare it with the others, with the suggestion that nitrous oxide compounds are actually a worse pollutant than the other two, perhaps what I'm looking at here is the phenomenon that the presence of MMT is possibly better than its absence. Would you care to comment on that?
Mr. Brune: I don't think you can really draw that conclusion. If, indeed, the MMT additive is causing the oxygen sensors to shift to the rich side, as Glenn has discussed in his paper and as we believe happens in some of the studies we have done, clearly when the engine runs richer, the NOx goes down. When the engine runs richer, usually the hydrocarbon and CO go up.
So I can't say that adding this in here to take away from our normal controls, where we're trying to control all three.... Any one that goes in and causes disturbance is a problem for us.
Mr. Bryden: To me it is a moot point about richness or lean mixtures. What interests me is this chart that shows very clearly that Canadian cars using MMT have a significantly lower nitrous oxide emission than those in the United States that don't use MMT. I take it that chart is a general chart that involves cars using rich mixtures, lean mixtures and all of that. Is that not what I'm seeing in that chart? Am I not seeing an improvement with MMT as opposed to the opposite?
Mr. Brune: I think you're seeing a false improvement as a result of MMT.
Mr. Bryden: It's your chart.
Mr. Brune: That's what I'm saying. I think it's a false indication, because it's causing the car to run richer and it's causing problems with hydrocarbon and CO, when we have to meet all three standards.
Mr. Bryden: If that data is false, then surely the other data that show improvements in the emissions of hydrocarbons and COs and carbon monoxide, these two other charts, are then also suspect. What I'm trying to get at is, what does any of this data mean? If you say that one is false, are these two therefore right, or are they not all false?
Mr. Brune: It means that the MMT additive causes a phenomenon in the system due to this rich shift that causes hydrocarbon and CO to go up and NOx to perhaps go down, and that, on this particular set of data, is something that causes us a problem because it affects our emission control system in a way that we cannot -
Mr. Bryden: I understand.
A final comment, if I may, Mr. Chairman.
It really becomes a choice, a decision, as to whether we are better off keeping MMT and having lower nitrous oxide emissions and higher hydrocarbon and carbon monoxide emissions, or the reverse of that by getting rid of MMT and having higher nitrous oxide emissions and lower hydrocarbon and carbon monoxide. We have to make a choice between which are the more significant pollutants.
Mr. Bradford: If it were that straightforward, we would not have gone through the detailed presentation we made this morning on the OBD-II system.
Mr. Bryden: I'm just going on the results here.
Mr. Bradford: Well, this is the result of studies conducted in the early 1990s. They found this result.
.1645
As you're getting into advanced technology now, with the on-board II diagnostic systems, you're designing a vehicle to meet very stringent criteria in a very narrow band. You can't just modify your designs in order to accommodate one pollutant or another so that you can get the right mix of nitrogen oxides and hydrocarbons in the atmosphere.
Mr. Brune: I guess the point is that if, without MMT, we can control all three pollutants to the levels that -
Mr. Bryden: So this chart represents the past, not the future?
Mr. Brune: Yes.
Mr. Bradford: It represents the future in the sense that the problem is still there. But it's made even more complicated by the presence of the on-board II diagnostic system.
The Chairman: Thank you, Mr. Bryden.
Mr. Finlay.
Mr. Finlay (Oxford): Thank you, Mr. Chairman.
I apologize to the witnesses for not being here at the start. There were just too many other responsibilities today.
I'm also sorry that I wasn't here to ask Ethyl Corporation whether the plugging of the catalyst, which I saw with my own eyes - and I see there's a picture in here on the catalyst, also somewhat blocked by what is claimed to be manganese oxid...claims that's something other than manganese oxide.
I'm told by my colleagues that they didn't say that, but they did say that what I was seeing and what we all saw was not in effect a result of MMT. I find that a little desperate.
Catalysts must reach a certain temperature to operate efficiently, I believe. By using MMT, you find it takes longer to reach that temperature needed before the catalyst functions at a high level of efficiency. So the cold start time is longer, and that apparently is when the automobile engine runs the dirtiest.
Mr. Brune: That's correct.
Mr. Finlay: With respect to that testimony, can you tell me how much you think that delay in reaching the optimum temperate might increase the emissions? Is it significant?
Mr. Brune: I don't know if I can give you an exact percentage, but yes, it is significant. Probably 80% or maybe 90% of the pollutants now are really from the cold start of the car, so any time you deviate in warming up that catalyst quickly, you're having a major impact on the exhaust emissions of the vehicle.
I might add that we just showed a hydrocarbon curve here showing that the MMT had a negative effect on the light-off for NOx and carbon monoxide. We have curves like that, so it really affects all three pollutants as far as getting the catalyst at temperature and operating efficiently.
Mr. Finlay: Thank you.
On page 43 of the document we received from your group, the Association of International Automobile Manufacturers, there's a quote wherein Ethyl Corporation makes a number of claims regarding benefit to petroleum refiners with the use of MMT:
- MMT provides important environmental benefits. It helps fight urban smog by reducing
nitrogen oxides (NOx) and other automobile emissions. MMT enables refiners to use less
intensive refining, thereby decreasing refinery emissions of carbon dioxide (CO2), a
greenhouse gas, as well as NOx, carbon monoxide (CO) and sulphur dioxide (SO2). It also
enables refiners to reduce the aromatic content of gasoline which reduces emissions of benzene.
- The octane-enhancing qualities of MMT allow it to be used to replace benzene and other
aromatic carcinogens in gasoline and thereby reduce emissions of these substances according to
Ethyl.
How is that possible? On one hand you say using MMT reduces benzene and aromatics, and on the other hand, we use benzene and our gasoline is more aromatic.
.1650
Mr. Bradford: I guess this has a lot do with the improvement of fuels that took place in the United States in the early 1990s. This was required in order to meet more stringent standards. In 1995, I believe, the point was finally reached where reformulated fuels were required in the United States starting January 1.
In the meantime, Canadian fuels have not been keeping up with that rapid pace of technology.
Mr. Finlay: Perhaps allowing the use of MMT has delayed the reformulation of Canadian gasolines to get rid of some of these other things.
Mr. Bradford: You could say that.
The Chairman: Thank you, Mr. Finlay.
Mr. Waddell.
Mr. Wappel: Mr. Chairman, with great respect, I think Mr. Waddell was defeated in the last election.
Some hon. members: Oh, oh!
The Chairman: I mean Mr. Wappel - sorry.
Mr. Wappel: Mr. Chairman, I have questions for each of the three witnesses. I'd like to start with Mr. Bradford.
On page 1 of your material, you list all these wonderful companies. I'd love to own some of these cars. Parenthetically, you throw away a line that says ``also include three companies that manufacture cars and trucks for sale by the big three''. Who are they?
Mr. Bradford: Those are three companies to which we refer as captive imports. They're manufacturing vehicles for sale in Canada, but they're sold through the big three. I can tell you the names.
Mr. Wappel: Do that.
Mr. Bradford: They are Mitsubishi, Isuzu and Daewoo.
Mr. Wappel: Daewoo?
Mr. Bradford: Yes. I'm not even sure it's currently manufactured for General Motors, but they were making a model called the Pontiac LeMans up until recently.
Mr. Wappel: Are these people members of your association?
Mr. Bradford: Yes, that's correct.
Mr. Wappel: I guess they don't take part much if you had trouble remembering their names.
Mr. Bradford: Well, yes, they're members through their Korean company, and we don't make many trips to Korea.
Mr. Wappel: On the next page, we see MMT has been banned by name in California.Dr. Lynam, a vice-president at Ethyl, told us that was based on health concerns in 1978. Do you disagree with that?
Mr. Bradford: We haven't formed an opinion here on health concerns. Presumably -
Mr. Wappel: Do you disagree with the statement that the reason MMT was banned in California in 1978 was based on health concerns?
Mr. Bradford: I'm not familiar with the reasons why it was banned at that time.
Mr. Wappel: Yet you make a point of bringing it to our attention in your brief.
Mr. Bradford: Yes.
Mr. Wappel: Don't you know why it was banned?
Mr. Bradford: No. I know it was banned. That could be something we could very easily clarify.
Mr. Wappel: Well, I believe it was banned because it was thought to be a health hazard, which has subsequently been proven incorrect, at least so far as Environment Canada indicates.
There are fifty states in the union. How many of them have banned MMT by name, other than California?
Mr. Bradford: Only California, by name.
Mr. Wappel: In the bottom paragraph of that page, it's noted that manufacturers reserve the warranty coverage on 1994-95 cars where a problem was attributable to Canadian fuel formulation. This was demanded by manufacturers in recognition of the MMT problem. Demanded of whom by manufacturers?
Mr. Bradford: In the course of the negotiations for the memorandum of understanding, we demanded that the provision be in there because we felt that the problem of MMT had not been fully addressed in the Canadian General Standards Board study done in the late 1980s.
Mr. Wappel: So what does that little book in the glove compartment say? If I drive my Lamborghini tomorrow, what does it say in the little book in my glove compartment? Does it say that because I'm using Canadian fuel my warranty might be void?
Mr. Bradford: I'll ask some of these gentlemen to answer that, because that language is probably very specific to each company.
Mr. Wappel: Is anybody here from either Lamborghini or Bentley to answer my major concerns?
Mr. Bradford: No, I think Lamborghini sold about five cars in Canada last year, and then they didn't sell too many more, so I'm not sure we could get them up here for a meeting. Maybe I could ask some of my colleagues here if they are familiar with the exact car you want.
Mr. Wappel: Here's what I'm getting at. I asked Ethyl Corporation this question because, unfortunately, I missed the presentation by your brethren in the big three. Is there a proposal to exclude warranties if you're using a fuel that is legal in this country?
.1655
Mr. Bradford: The term we used was ``reserved warranty coverage'', because the obligation remained on us at that time to show the problem was attributable to MMT. There were individual manufacturers that could do that. In fact one company, Mercedes Benz, put that specific wording into their warranty coverage. Actually I have a copy of that here.
Mr. Wappel: It sounds like a great case for a consumer protection lawyer.
At any rate, under ``The Problem Today'', you say, ``Manufacturers fixed plans for 1996 model year vehicles in anticipation of MMT being phased out by September, 1995''.
You plan a number of years in advance, right?
Mr. Bradford: Yes.
Mr. Wappel: So a number of years ago you guys - and when I say ``you guys'' I mean the big auto manufacturers - simply decided there was going to be no MMT in gasoline in 1996 and made your plans accordingly. So you have proceeded with all of your technology, all of your experimentation and all of your data on the assumption that MMT was going to be gone. Now we find out it isn't gone in September and it isn't gone in October, but expeditious passage of this bill would be helpful to the environment.
It seems to me your position was fixed four or five years ago, when you decided MMT was not going to be a factor.
Mr. Bradford: We use the term ``fixed'' to refer to the last date when you actually fix the plans. Obviously we made our plans earlier.
I think it would be fair to say that most manufacturers fixed their plans earlier this year, when they anticipated MMT was going to be phased out. Ms Copps, the Minister of the Environment, made her initial announcement I believe in October of 1994 that she would phase out MMT. Manufacturers would have made their plans in anticipation that this would take effect by September 1995, because we anticipated a problem for our 1996 models with the move to the advanced emission control systems.
Mr. Wappel: In the last paragraph you say that virtually no testing was done, beyond that by vehicle manufacturers, on current-generation OBD-II systems. Is that unusual? Who else would be studying them?
Mr. Bradford: No, it's not unusual.
Mr. Wappel: Obviously the people who make them are going to be studying them. There would be no reason for anybody else to study them, unless it's Ethyl Corporation to try to dispute your claims that your OBD-IIs are going down the crapper, if that's a parliamentary word, because of their product.
Other than them - and there's only one of them in the entire world - the only people who would be studying these things would be you guys. So that's a statement of the obvious, wouldn't you agree?
Mr. Bradford: Yes, but as you say, Ethyl is the other company that would do studies on this. In 1994, as quickly as 1994 models were rolling off the assembly line, their on-board diagnostic system was being tested to determine if it was compatible with MMT.
Mr. Wappel: By the way, Mr. Chair, in view of your previous comments, I'll withdraw the word ``crapper'' and substitute ``porcelain facility''.
Your final conclusion is MMT is not expected to make major inroads in the U.S. market. Why? So what if it's prohibited in California? There are 49 other states, including New York.
Mr. Bradford: But it's also illegal in those areas that require reformulated fuels. I've heard a figure quoted that 30% of the U.S. market is represented by those areas where reformulated fuel is required.
Mr. Wappel: What do you mean by ``major''? Poor old Ethyl Corporation is knocking itself out in the courts in the United States. They're just going crazy trying to market this stuff. They must be insane if they're spending all these legal megadollars for a tiny market.
.1700
Mr. Bradford: A lot of U.S. refiners, we understand, are already committed to existing octane enhancers. Because of those commitments, a new company coming in is going to have to make its way through, first of all, those areas that are not subject to reformulated fuel requirements outside of California.
They'll have to start with companies that currently don't have a surplus of octane through other octane additives available. That type of market growth is going to take time.
Mr. Wappel: Mr. Chairman, might I turn to the next witness from Toyota? Just a couple of brief questions on the slides.
The Chairman: Yes, Mr. Wappel.
Mr. Wappel: Thank you.
Just a question on the graph. I'll describe it. The title says: ``Effect of MMT on exhaust emissions and catalyst''. On the graph on the right-hand side, which is the inlet temperature graph, what's the timeframe?
Mr. Brune: I'm not sure. I can't tell you.
Mr. Wappel: Minutes, seconds, microseconds?
Mr. Brune: I'm sure it's seconds.
Mr. Wappel: Seconds. So there would be milliseconds or seconds between the two fuels to increase the.... As I understand your evidence, the temperature heats up more rapidly. Am I right on that?
Mr. Brune: Yes.
Mr. Wappel: It heats up more rapidly without MMT than with MMT.
Mr. Brune: Yes, exactly.
Mr. Wappel: My question is, what is ``more rapidly''? Is it a matter of microseconds, milliseconds or regular seconds?
Mr. Brune: As for the light-off temperature, we try to get that as quickly as possible, because all the emissions now are in the cold-start emission. Anything that delays the catalyst light-off, we're extremely concerned about. Whether it's seconds, milliseconds, minutes, or whatever it is, it's a problem for us.
Mr. Wappel: I fully appreciate that. I just want to know if it's microseconds, milliseconds or minutes.
Mr. Brune: It's probably seconds to maybe a minute. It's somewhere in there. That depends on where the catalyst is located. If the catalyst is up near the manifold it's going to heat up quicker. If it's downstream, it's going to be longer.
Mr. Wappel: Take your graph on manganese deposit build-up on the catalyst. What sort of mileage are we talking about here?
Mr. Brune: This was a Camry that had high mileage on it. Some of the components, we collected from Canada. It probably was around 100,000 kilometres.
Mr. Wappel: Would the manganese deposit on section one, which is the largest deposit, have occurred over time, or would that have occurred initially?
Mr. Brune: We think it's a gradual build-up over time. It tends to start as more severe in the front of the catalyst. As the mileage goes up higher and higher, it probably migrates back through the catalyst.
Mr. Wappel: I'm not an engineer. I only go to Speedy Muffler once in a while. But when they replace your muffler, don't they replace your thing...? Is that something else again? What am I thinking of?
Mr. Brune: It's different.
Mr. Wappel: Is it a catalytic converter or something? There are two things under the floor, if I may use some term of art. One is the long thing, which is the tailpipe. I presume that's the muffler. The other's the short thing, which is closer up to the front and underneath. What's that called?
Mr. Brune: The resonator.
Mr. Wappel: The resonator. That's not any of these things.
Mr. Brune: No.
Mr. Wappel: How often would you normally replace a catalyst?
Mr. Brune: We would hope you'd never have to replace a catalyst.
Mr. Wappel: Excellent. I wouldn't even know -
The Chairman: Next time, ask the question and make sure you're satisfied when you go to a muffler shop. Is that the end of your questions?
Mr. Wappel: I have just one more question.
The Chairman: I will put you down on the second round.
Mr. Wappel: Fine, no problem.
The Chairman: Mr. Chatters, please.
Mr. Chatters (Athabasca): Thank you, Mr. Chairman.
I think I heard you - I heard Ford this morning - refer to the point that if we are to continue the tremendous strides we've made in the auto industry in the reduction of pollution and emissions from automobiles, that can only be achieved from here on in by a collaborative effort between automobile manufacturers and fuel manufacturers. What we're hearing here seems to indicate that this is so.
.1705
I would wonder why, in view of that, the auto manufacturers have chosen rather than a collaborative, cooperative effort with the fuel manufacturers to achieve this, why you've chosen instead to collaborate among yourselves, with your competitors, to apply the substantial political pressure you have to achieve the type of fuel you want. Why didn't you work with the fuel manufacturers to achieve the same thing? Because that's the only way we'll get to where we want to go in the interests of air pollution, your customers and everyone involved. It seems to me that would be the way to go. Why have you chosen to go this way instead?
Mr. Bradford: I guess this debate goes back several years. I referred to this in my documentation here. In 1991 we understood that Transport Canada was going to have another look at MMT, because it would be looking at making the emissions standards more stringent in the mid-1990s. This was probably to be in concert with the reduction in the U.S. emissions standards.
In 1993 the federal government created a joint industry-government working committee. It brought together these two interests: the oil industry and the vehicle manufacturers. We began discussing MMT. In fact, it was the first item on the agenda.
A year later, we had put together a document. I think it was read out this morning. It was a joint statement on harmonization. We believed this would be sufficient to have the oil companies recognize the effects of MMT.
It didn't happen. By 1995, we're faced with a situation of bringing in advanced technology vehicles with fuels that are not going to be compatible with them. So we really see no choice at this point but to ask the federal government to bring in controls on MMT.
I guess we've been negotiating this for so long now and reached the point at which those negotiations simply weren't going anywhere in the timeframe we had available to us.
Mr. Chatters: But I heard this morning, and before, a willingness on the part of the refiners and Ethyl Corporation to enter into joint and cooperative studies, and a willingness to accept the results of those studies. In their view, you have refused to do that. You have instead chosen to go the political route and seek legislation that would force the refiners to your position. That doesn't seem to bode well for future cooperation between the two industries.
Mr. Bradford: We've attempted to address this matter cooperatively through 1993 and 1994, but it simply didn't happen. So we're now up against the wall.
Mr. Chatters: From the evidence I've heard, I suggest that it hasn't happened because you haven't been willing to enter into those independent and cooperative studies. But I may be wrong.
I have another question before we're too far along with that one.
Mr. Bradford: We did our studies in the late 1980s as part of the Canadian General Standards Board process. Toyota continued to do studies in 1990. Honda did a study in 1994. We believe we have put forward enough information now to show that MMT has its effects on emission control systems. Any future studies, when you're trying to bring in more stringent emission standards, would be superfluous.
Mr. Chatters: Why didn't you make those studies joint studies, or cooperative studies, with the industry? Why did you choose to do them on your own and then present them as gospel, instead of choosing to do them cooperatively with the refining and additive industry?
Mr. Bradford: Because we believed this matter was going to be addressed by Environment Canada in due course.
Mr. Chatters: The political process.
Mr. Bradford: It was being addressed through a joint industry-government committee established for that purpose in 1993.
.1710
Mr. Chatters: Here's my other question. You referred several times to the availability of an octane pool in the U.S. as a reason that MMT would probably have difficulty breaking into that market in the U.S., yet we were told by the refinery people that the banning of MMT wouldn't mean the use of other octane enhancers. It would mean the use of a more stringent refining process to boost the octane of fuels, causing other problems.
Why in the U.S. have the refineries chosen to use these other additives rather than the process the Canadian refiners say they will choose to use if MMT is banned?
Mr. Bradford: I think the U.S. refiners are already doing that.
Mr. Chatters: Is that the option they're using now?
Mr. Bradford: That's one of the options they're using, but they have others. There are other additives available in the United States, such as MTBE -
Mr. Chatters: But they cost more than the further refining part. That was our understanding of it.
Mr. Brune: I don't think the price of reformulated gasoline has gone up more than one or two cents a gallon in the U.S. as a result of the reformulated gasoline requirements the EPA has initiated. I'm sure EPA's analysis showed that the clean air benefits that were obtained from reformulated gasoline far outweighed the small increase in the price of the reformulated fuel.
In the non-attainment areas in the U.S., you have to use reformulated gasoline and you can't use any heavy metals in that gasoline. Because these non-attainment areas are very high population-density areas where the pollution is, that's where there will be a lot of gasoline sold.
I think EPA's intention was to really sell a lot of reformulated gasoline that had the emission benefits and didn't have any heavy metals. It also has provisions in there for other non-attainment areas to opt in to use this fuel. I think it hoped other areas would also opt into using this fuel to gain the air quality benefits. I think in its analysis it really didn't believe there would be very much conventional fuel left. The conventional fuel is where MMT can now be put as a result of this waiver.
The clean air benefits to reformulated gasoline are -
Mr. Chatters: I don't dispute that. What I was getting at was if MMT is banned and refiners have to look at other options to reach the same octane level, they're going to choose the least expensive option above the others, unless there's legislation that says they can't do that. In Canada they tell us it's further refining, and you say some U.S. refiners are using that process as well. That was what I was trying to get at.
Mr. Bradford: But there are other options available -
Mr. Chatters: More expensive options, yes.
Mr. Bradford: I don't know if they're necessarily more expensive.
Mr. Chatters: The refinery people told us they were. I'm just going by what we heard.
The Chairman: Before concluding the first round I have a couple of questions. I'm intrigued by that lambda, the air-fuel ratio. Your chart indicates 0.2 lambda will be operative 84.9% of the time at a certain stage later on. When is that going to happen?
Mr. Bryksaw: The Honda Motor Company has announced it intends to introduce this technology we're talking about in the 1998 ultra-low emission vehicle, which is the Accord that will be sold in California. It uses this technology. It meets the ultra-low emission vehicle standards that are substantially below the current standards in Canada and the balance of the United States. This is our future technology. It is the first product announced that is gasoline-powered that will meet the ultra-low emission vehicle standards.
The Chairman: At that time will it be correct to say that lambda will be 0.2 100% of the time?
Mr. Bryksaw: We hope with that future technology we see now, it will be 85% and above.
The Chairman: As indicated in your chart?
Mr. Bryksaw: That's correct.
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The Chairman: The other question has to do with this general observation. As we pursue consistently, persistently, and continuously the technological fix, thus decreasing emissions of various gas components of this chemical soup that is produced by cars, the number of cars on the road increases every year. Population increases and so does the number of cars on the road.
Will there be a point in time, in your projection into the future, when the technological fix will be so advanced that the pollution factor will, despite the fact that the number of motor vehicles on the road is on the increase, indicate a sharp decline and eventually disappear?
Mr. Bryksaw: Is that directed to me?
The Chairman: It's to anyone. What are your long-term expectations?
Mr. Bradford: I guess if you're going well into the next century, we really can't comment on that because we don't have those types of figures. What we can tell you is we're looking ahead to the year 2001 as the likely date for the introduction of what are called low-emission vehicles. Those will be required in the United States by 2004, in any event. With low-emission vehicles you'll achieve a significant drop from the 1994 to 1996 vehicle standards.
As you may know, California has been more aggressive than the rest of the United States in going to vehicles that will meet not only low-emission vehicle standards but ultra low-emission vehicle standards and ultimately zero-emission vehicle standards.
The Chairman: So you are saying to us that despite the burning of fossil fuels, at a certain point technology can be developed to such a degree that pollution will be reduced to zero. Is that possible?
Mr. Bradford: We're obviously looking well into the middle of the next century. A lot of the manufacturers here develop prototype vehicles that will run on electricity. I believe Mazda has a vehicle that runs on hydrogen. But these things are still well short of the point of being commercialized.
The Chairman: So you're looking at other fuels? You will come up with fuels other than fossil fuels? Is that what you are saying?
Mr. Bradford: I think in the long term there will be a transition to other types of fuels, yes.
The Chairman: Fair enough. Thank you.
In the second round we have Mr. Forseth.
Mr. Forseth: I wanted some further explanation of this chart here. This is the 1-B Toyota data emission comparison without MMT. It has three scales on it. It's the one that has NOx on the bottom. I would like to know, who did it and with what kind of devices? Is this a measurement of what you refer to as engine-out emissions? I want the parameters of what these represent, how it was produced, and who did it.
Mr. Brune: Basically what was done is that TMC Japan, who currently really does the development and design of our emission control systems, was interested in seeing what effects MMT was having on our control systems. They asked the service personnel of TMS Canada and TMS U.S.A. to collect oxygen sensors in catalysts from the field at various mileages.
Those components were shipped to Japan and installed on the same type of vehicle in Japan that they were removed from in either the U.S. or Canada, the four-cylinder Camry. These parts were all tested on the same type pf car in Japan and these are the results that were obtained on that car with the different components that were collected in the U.S. and Canada.
Mr. Forseth: Do you know what the device was that was measuring the emissions?
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Mr. Brune: These were run on the standard EPA federal test procedure with the constant volume sampler and the normal certification test equipment. It's the LA 4 cycle.
Mr. Forseth: What is the measuring device itself?
Mr. Brune: It's NDIR for carbon monoxide, FID for hydrocarbon and chemiluminescence for NOx. It's the standard test set-up you use to certify your cars. You run the car on the Clayton dynamometer and -
Mr. Forseth: Okay.
Mr. Brune: It's the basic test everybody uses.
Mr. Forseth: Does the EPA in the U.S. regard this kind of data from Toyota and Honda to be conclusive?
Mr. Brune: As I said in the beginning, we presented this data to EPA. They expressed some concerns and we supplied this in the waiver hearing they had on Ethyl's initial waiver. I'm sure they deliberated on this data along with any other data in there, but obviously through the waiver process Ethyl has now been able to get it approved.
I can't reallly say how much weight this data had in terms of all the data that was supplied. We did submit it and discuss it with EPA. We told them our concerns.
Mr. Forseth: In evaluation, if the EPA and this whole core process couldn't validate or find this data impressive, then I guess we should also ask why we should.
Mr. Brune: I think the concern we have is that EPA got caught up in some rules and regulations that I think were rather antiquated in this waiver process. When the emission standards were relatively high and people wanted to put additives in the fuel, there wasn't a lot of concern about that additive increasing emissions because the standard was relatively high and it was an easy margin to meet.
As the standards get tighter, we have to design the car to be below the standard because we can't be right at the standard and take a chance. There's production variability. There are lots of things. Our safety margin is getting squeezed tighter all the time.
We're at the point where an additive that increases the emissions at the standards we're at now is very difficult for us because we're losing our safety margin. That's going to cause us problems in use.
I believe in their initial waiver EPA said that in order for the waiver to be denied the cars had to be above the standard with MMT. We're designing our cars to be half the standard without MMT, because we need a safety margin. The MMT clearly increases our emissions but we can't guarantee that all our cars are going to be above the standard with MMT.
EPA got into this position where the only way they could deny the waiver was to have every vehicle above the standards. I personally don't think that's a sound approach but that's the approach they took.
Mr. Forseth: It sounds as though you may be making a case to design an MMT collector.
Mr. Brune: I don't know how to do that. Well, I guess the catalyst is an MMT collector -
Some hon. members: Oh, oh.
Mr. Forseth: Or it should have a secondary catalyst converter, or a longer one, or whatever.
Mr. Bradford: This morning we heard a presentation on the fact that manganese in various forms goes right through the engine system. We simply can't design to accommodate manganese now when it goes through the engine and the exhaust system.
Mr. Forseth: We were told that 80% is being caught up in the system.
Mr. Bradford: That's the problem.
The Chairman: Mr. Finlay probably has a further question, followed by Mr. Wappel.
Mr. Finlay: My question, Mr. Chairman, concerns the relative percentage or quantity of CO2, CO, NOx and HC in the emissions of an efficiently running automobile.
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I understand that the amount of CO2 is the greatest, CO would be next, and NOx and hydrocarbons are about the same according to these graphs I'm reading here. But these graphs don't show me CO2 and CO. Am I right or wrong in that?
Mr. Bryksaw: In order to give you an understanding of the orders of magnitude involved here, the three major pollutants we're dealing with - hydrocarbon, CO and NOx - are all now regulated into the grams-per-mile and portions of a gram-per-mile requirement.
On the certification data we provide to the government, we also provide the data on CO2, and those numbers vary from car to car. They are of the orders of hundreds of grams per mile - 200 to 300 grams per mile.
Mr. Finlay: Of what?
Mr. Bryksaw: Of CO2. That gives you an idea.
Every vehicle is different, and I'm just giving you a ballpark range of what it is we're dealing with here.
Mr. Finlay: That's what I want.
Mr. Bryksaw: Okay. You asked about CO2. My guess is it's about 400 times the amount of the other pollutants combined. CO2 is the product of complete combustion.
Mr. Finlay: Exactly.
Mr. Bryksaw: That's what we are attempting to get when we burn a fossil fuel.
Mr. Finlay: Are the other three in the same range?
Mr. Bryksaw: No, they're all in the range of portions of a gram per mile. All vehicles have to meet similar standards, but every one differs depending upon the particular configuration of the vehicle, how much headroom there is and everything else.
The actual emissions of those three pollutants would all be in the order of certainly less than a gram per mile. Hydrocarbon is 0.41, ratcheting down to 0.25 grams per mile. NOx is slightly higher than that, but they're all less than a gram per mile.
Mr. Wappel: I have two questions for Mr. Bryksaw.
I liked this. It was a good presentation. It impressed me.
Mr. Bryksaw: Thank you.
Mr. Wappel: It doesn't mean much, though, unless we get to a really hard conclusion, so I'd like to ask you a question.
Before I get to that, on the slide ``Honda Oxygen Sensors'', of course you haven't, I presume for proprietary reasons, given any figures, but I note there are no Xs closer to the Y axis. Why?
Mr. Bryksaw: In the samples of vehicles we selected in Canada, there was a slightly larger sample chosen from the U.S. samples.
Our request to dealers was to provide us with what we would call random samples. We asked them to contact their customers and make sure there were no specific problems relating to the oxygen sensor that they were aware of, so they checked the on-board diagnostic systems to find out if there were any codes being set.
We asked them to replace those, but we allowed them to make the choice, and as it turned out, the samples we received from the U.S. started at a lower mileage than the samples from Canadian vehicles.
Mr. Wappel: Would you not have been curious to see if any of the Xs in Canadian vehicles would have been at around the U.S. line, closer to new mileage?
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Mr. Bryksaw: We were. I indicated to you that these results took a long time to put together. What we are providing to you at this time are the results of the study we did, which took very close to a period of about six months. The data collection, data analysis, is not a process that would allow us to do it in a shorter timeframe. We do have the problem of shipping the parts to Japan where some of the R and D facilities are. This is where the testing was done. So we had some time constraints in consideration that we wished to get this information to Transport Canada and Environment Canada in order for them to make their assessment of how valid the data was and go from there.
Mr. Wappel: And the slide ``Honda Conclusions''.
Mr. Bryksaw: Yes.
Mr. Wappel: With respect, I see three concerns. I see three identifiers but I don't see any conclusions, so let me ask you the questions.
The oxygen sensor replacement rate on identical hardware vehicles is significantly higher in Canada than in the northern U.S. states. In Honda's opinion, is that due solely to MMT in Canadian gas? Yes or no.
Mr. Bryksaw: We believe that MMT has a very significant effect on the oxygen sensor replacement rate, yes.
Mr. Wappel: Is your conclusion due to MMT in Canadian gas?
Mr. Bryksaw: We believe it is a contributing factor. It is not all of the factors, because obviously there is a replacement rate in the U.S. But the replacement rate in Canada is significantly higher and we believe -
Mr. Wappel: That's what I'm getting at. Is the significantly higher rate in Canada solely due to MMT?
Mr. Bryksaw: We believe it is.
Mr. Wappel: Okay. Canadian oxygen sensors are coated with manganese oxide. Is that solely due to MMT?
Mr. Bryksaw: That's correct. We know -
Mr. Wappel: Canadian oxygen sensors exhibit a rich shift when compared with U.S. samples. Is that solely due to MMT?
Mr. Bryksaw: We believe it is.
Mr. Wappel: All right. Those would be the conclusions that I would think you would put in as conclusions when we're talking about MMT.
Mr. Bryksaw: We're stating the facts here, and this is what we've concluded from our study.
Mr. Wappel: Thank you very much.
The Chairman: Thank you.
Mr. Chatters, please.
Mr. Chatters: You suggested that the reason you chose to go the political route, so to speak, rather than working with the refinery people to come to a conclusion, was because the minister made a public commitment in 1994 to remove MMT from gasolines. Had the minister not made that commitment, would you...? In view of the urgency to come to this agreement because of the OBD IIs, would you, in your view, have reached an agreement with the refinery people had the minister not made that commitment?
The Chairman: In the House of Commons that would have been classified as a hypothetical question and ruled out of order. However, we will see what our witnesses will say.
Mr. Bryksaw: As you say, this is a very hypothetical question. Let me assure you that we, in all good faith, went to the CPPI under the umbrella of the joint government-industry task force on vehicles and fuels to discuss and come to an agreement on what we believed was acceptable in terms of fuel formulations for future models. In those agreements that fell out of that particular task force there was a harmonization position that was stated, agreed and signed by the parties, CPPI, AIAMC, and the MVMA.
Our belief was that this harmonization agreement, which very specifically dealt with the issue of fuel quality and its effect on emission hardware and the fact that we are dealing with a systems approach, is very clearly stated in that document that CPPI agreed to. We have not, in the course of the dealings with the petroleum producers, come to an agreement with regard to what they would require as proof that MMT is a problem.
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To give a personal opinion, I don't particularly know what we could have said to them that would have convinced them that this was a problem. We felt we had the evidence; we discussed it with them; and even in light of one of their consultants who indicated that he believed our results, they chose to discount, if not ignore, that.
Mr. Chatters: It wasn't only the CPPI people you didn't convince; it was every outside body that got involved in the debate, including the U.S. courts that said you failed to show conclusively that MMT was detrimental to OBDs.
I can understand that because we saw some confusion on the other side about a false conclusion from one of your charts. We saw pictures of a spark plug this morning that was supposed to convince us that the manganese deposits on the spark plug caused problems, but the two photographs weren't even pictures of the same spark plug.
Laymen like ourselves raise serious doubts about your evidence, and certainly those doubts were reflected in the court decisions. So it's not only CPPI that you didn't convince; it's a number of other people as well.
Mr. Bryksaw: I personally can't comment on the U.S. situation. I would refer any of those questions to my U.S. colleagues.
We believe our evidence is convincing; we believe we have a solid case; we believe we understand what is happening; and we are very concerned about what's going to happen in the future. It's an honest and earnest concern. You can have your opinion on that, but that's our position.
Mr. Chatters: I accept that as an honest concern; I certainly do. The part I question is why you couldn't take that honest concern, get together with the refinery people and come to a conclusion without -
Mr. Bryksaw: We tried, but they didn't -
Mr. Chatters: They'd say you didn't.
Mr. Bradford: We attempted to do this in 1993, going back to 1990. As far as discussion is concerned, the paper that has flown back and forth between the two industries would fill this room. Unfortunately, we just haven't been able to bring the other party to the negotiating table.
We have gotten so far as a document - an understanding - on harmonization of standards, but there's never been the step beyond that to recognize that MMT is a problem.
Mr. Chatters: Something as simple as a joint and cooperative study, or an independent analysis by some group, I believe, would have gotten you to where you wanted to go.
Mr. Bradford: We wish we had done that in the early 1990s, and that would have resolved these problems more amicably than what's happening now.
Now in 1995, we're up against the introduction of on-board diagnostic II systems that only work well if they're allied with MMT-free fuel. We've talked a little bit about the OBD II systems this morning, but I would emphasize that they become an inspection and maintenance system as well that helps to address problems in future emissions.
Mr. Chairman, you spoke earlier of the long-range problems we are going to have, the long-range opportunities to address emission problems. Unfortunately, we have problems now with the emissions that are coming out of vehicles. With the OBD II system, it's going to be possible to diagnose those problems much earlier and address them before the vehicle becomes a serious polluting vehicle.
The Chairman: Thank you, Mr. Chatters.
We are about to conclude, but let me first ask you briefly what your understanding is of the OBD technology. Who requested the OBD technology, and by what date was it requested? In other words, is it correct to say that the OBD technology is required by January 1996?
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Mr. Bryksaw: That's correct. There's a phase-in program. It started basically with the 1994 models and was phased in through 1996. It's now at 100%.
The Chairman: You were driven, or the industry was driven, by that requirement. Would that be a correct assumption?
Mr. Bryksaw: That's correct.
The Chairman: Where did the requirement come from?
Mr. Bryksaw: Originally on-board diagnostic systems were developed to comply with California regulations. Those regulations then became the 49-state standard in the United States, and by our memorandum of understanding we have adopted the 49-state standard in Canada. So that's where it all comes from.
The Chairman: So this political conspiracy really boils down to a standards requirement by the U.S. authorities that OBD technology be in place by January 1996. Is that correct?
Mr. Bryksaw: On 1996 models, yes.
The Chairman: Would it be quite fair for any 1994 politician looking at the future - something that politicians are accused of not doing enough - to make a statement to the effect that in 1995, it would be possible and desirable in Canada to have MMT out of the way?
Mr. Bradford: You'd have to start it earlier than that, Mr. Chairman, in 1993, through the joint -
The Chairman: What happened in 1993?
Mr. Bradford: A joint industry-government committee to look at MMT among other fuel and vehicle technology issues was formed.
The Chairman: So it even goes back to the former government?
Mr. Bradford: Yes.
The Chairman: So there is continuity here.
Mr. Bradford: Yes, it started in the spring of 1993.
The Chairman: All right. Then Madam Copps was articulating something that she found when she was appointed to her position.
Mr. Bradford: Yes, I guess you could say that. She was moving forward with an initiative that had already started under the previous government.
The Chairman: What one can notice here is a constant progression. First it was lead. Oh, my God, I remember the hullabaloo on catalytic converters in the mid-1980s was tremendous. Then, more recently, it was benzenes, and now it's MMT. It's a constant removal of obstacles and a constant progression to keep up with technological change and requirements. Maybe the technology is much faster than the political speed. That's what we're witnessing here.
I wouldn't want to see Madam Copps blamed for making a statement in 1994 that was evidently based on knowledge of what had been announced before, and also on the knowledge of this January 1996 OBD technology deadline. I think she was putting the matter in the context of the inevitability of gradualness. Isn't that so?
Mr. Bradford: It sounds right to me.
Mr. Wappel: You'd better say yes.
Some hon. members: Oh, oh.
Mr. Bradford: Well, I think we'll say yes to that one.
The Chairman: We'll meet again - not in this room, but in another room - to do clause-by-clause analysis of this bill by way of an understanding that we have worked out, in cooperation with your position on Thursday morning.
On behalf of the members of this committee, we thank you for your presence, your input and your explanations.
This meeting is adjourned.