COMPTROLLER GENERAL OF 

WASHINGTON. D.C. 20548 

B-166506 

jy 

p/k ’ Dear Mr, Chairman: 

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LM096536 

In response to your request of May 25, 1972 (enc, II), we are 

submitting a report (enc. I) on our review of (1) the adequacy of the 

_yIw.-.- motor vehicle. certification rCU--Y"-d,ICI" ‘.+..a...-A+*. groc&u,re..s~ -d...- of the Environment&l Protection I 

1 Agency (EPA),_ she capacity of EPA to oversee the auto companies' 2f 

/ preparat?&rof certification data, and (3) the procedures of the auto 

companies for developing the certification data. 

Following is a summary of the information we obtained relating to 

the points of interest specified in your letter, These matters are 

discussed in more detail in the enclosed report, 

On May 16, 1972, the Ford Motor Company withdrew the four applications it had made to EPA for certification of its 1973 vehicles, 

Ford officials withdrew their applications because they had discovered 

that Ford test personnel had performed unauthorized maintenance on prototype vehicles being tested for certification. The unauthorized maintenance had not been reported to EPA as performed, or included in the 

final applications, 

Ford officials have attributed the cause of the problem to a lack 

of proper management control over certification testing. Within Ford, 

the Engine and Foundry Division had the responsibility for building the 

certification vehicles, conducting the tests, and compiling the certification data. 

On May 23, 1972, Ford reorganized and transferred responsLSi1ity 

for prototype certification testing from its Engine and Foundry Division 

to the Environmental and Safety Engineering Staff, Ford officials told 

us that Ford would take a number of additional steps to improve management control over certification vehicles, 

Our discussions with officials of the General Motors Corporation, 

the Chrysler Corporation, and the American Motors Corporation disclosed 

that these companies do not have formal written certification test procedures. But officials from each of the companies stated that IL was 

unlikely that unauthorized maintenance would be performed on t'T.eir test 

fleet vehicles without the knowledge of upper management personnel. The 

officials told us that EPA personnel did not visit their plants to monitor their testing or to inspect their records, 
EPA officials told us that they have no basis for suspecting that 

unauthorized maintenance has been performed on the test ve:li.ctes of 

the above-mentioned three companies. However, in view of the limited 

EPA staff assigned to certification activities ;<nd the lack of E2A inplant monitoring of compliance with certification regulations, it is 

our opinion that EPA does not have reasonable assurance that the ccmpanies have complied with Federal regulations related to maintenance. 

Our review showed that the number of 1, assigned Lo 

certification activities had been insufficient to adesuateiy perform 

all activities necessary to ensure that auto companies complied with 

Federal certification regulations. Between June 1, 1971, and June 1, 

1972, personnel assigned to the Mobile Source Pollution Control Program 

(of which certification is a funct3XZT‘-increased from 112 to “i&6. nuring the same period personnel assigned to certification activities increased from nine to 19, Of the 19, only 10 were directly responsible 

for the certification of light-duty vehicles--primarily autos. No personnel had been assigned to specifically monitor activities at the test 

facilities of the auto companies. 

The certification staff spends a significant portion of its time 

explaining and interpreting Federal regulations for the auto companies, 

The staff normally spends the rest of its time reviewing and approving 

manufacturers' applications for certification; assisting auto company 

personnel in resolving day-to-day problems; monitoring vehicle tests at 

EPA's Ann Arbor, Michigan, laboratory; and reviewing test data submitted 

by the auto companies, The staff has not been availabie for monitoring 

the in-plant testing activities of the auto companies, 

Not only is the certification staff small but the recently hired 

staff members are relatively inexperienced, In addition, EPA has difficulty in hiring and retaining qualified staff members, primarily because --..-W.--.,,. of low entrance salar&+-for recent college graduates and noncompetitive 

salaries for engineers with automotive emissions experience, 

The effectiveness of EPA's certification program relies heavily on 

the integrity of the manufacturers to carry out the testing of prototypes 

in accordance with Federal regulations and to submit accurate and complete data on the tests and maintenance performed on each certification 

test vehicle. EPA generally has accepted at face value the information 

submitted by the auto companies. When prototype vehicles are delivered 

to EPA for testing, the EPA staff makes visual observations of the vehicles; however, EPA officials told us that there is no practical way to 

inspect the vehicles to determine whether unauthorized maintenance had 

been performed. The failure of EPA to monitor the testing activities of 

the manufacturers can be attributed primarily to the shortage of qualified personnel. 

-2- 
B-166506 

Because Ford is in the process of rerunning tests on its 

certification prototypes, EPA has instituted a number of procedural 

changes to coordinate, control, and accelerate the certification of 

Ford vehicles. EPA is documenting all communications with Ford, is 

inspecting test vehicles before testing begins, has notified Ford that 

it will make spot-check inspections of Ford's records and test facilities at any time that work is being performed on the prototypes, and 

has made arrangements to be responsive around the clock to special 

problems that Ford may encounter in testing its prototypes, The cost 

of these changes to the Government will be substantial, For example, 

the EPA staff has estimated that about 1,300 hours of overtime wil: be 

needed for certification activities related to Ford vehicles. 

EPA officials told us that EPA is presently considering several 

alternative procedures for ensuring the integrity of certification testing by the auto companies. They said that EPA might (1) make unannounced 

spot inspections of the auto companies' records and test facilities, 

(2) station inspectors at the auto companies' test facilities to provide 

continuous monitoring, or (3) assume responsibility for some or all testing and mileage accumulation of the companies' prototypes. 

The auto companies are primarily responsible for conducting tests 

and accumulating mileage on certification prototypes. EPA is responsible for ensuring that the vehicles it certifies do in fact meet-Fede.raJ,emission _I sjzancllrds. 

..,_ . . . To carry out this responsibility, EPA needs " 

to assure itself to a greater extent than at present that the %ests are 

conducted in accordance with Federal regulations. We believe, therefore, 

that, as a minimum, EPA needs to increase its certification staff to 

provide in-plant monitoring of the auto companies' test activities and 

records related to certification vehicles. 

Our review was conducted at EPA headquarters in Washington, D.C., 

and at the EPA Motor Vehicle Emissions Laboratory in Ann Arbor, We 

reviewed pertinent records, documents, and files and interviewed various 

officials of EPA, Ford Motor Company, Chrysler Corporation, General 

Motors Corporation, and American Motors Corporation. We also visited 

the testing facilities of some of the auto companies. 

The information contained in the enclosure to this letter has been 

discussed with officials of EPA, but formal written comments have not been 

obtained. We plan to make no further distribution of this report unless 

copies are specifically requested and then only after your agreement has 

-3- 
B-166506 

been obtained or public announcement has been made by you concerning 

the contents of the report, 

Sincerely yours, 

Comptroller General 

of the United States 

Enclosures- 2 

r t 4 lL 

5 

The Honorable Edmund S, Muskie, Chairman q 

Subcommittee on Air and Water Pollution ?J\' 

Committee on Public Works 0 _ 

United States Senate 

, 

-4- 
ENCLOSURE I 

GENERAL ACCOUNTING OFFICE 

EXAMINATION INTO 

al? AD- QF THE 

ENVIRONMENTAL PROTECTION AGENCY'S 

) 

CERTIFICATION PROCESS 

The Clean Air Act (42 U.S.C. 1857) provides that new motor vehicles 

cannot be sold, offered for sale, or introduced into commerce by a manufacturer unless the manufacturer receives from the Environmental Protection Agency (EPA) a written certificate that the vehicles conform to air 

pollution emiss.ion~.standards prescribed by regulation--a certificater- . . ‘.. ,._xi.lld * ._. 

conformity. The certificate of conformity is issued to the automobile 

manufacturer on the basis of emissions tests of selected vehicles deemed 

by EPA to be representative of the manufacturer's various combinations 

of engines and components,, Specifically, section 206 of the Clean Air 

Act states that: 

"The Administrator shall test, or require to be tested 

in such manner as he deems appropriate, any new motor 

vehicle or new motor vehicle engine submitted by a manufacturer to determine whether such vehicle or engine conforms with the regulations prescribed under section 202 of 

this Act. If such vehicle or engine conforms to such regulations, the Administrator shall issue a certificate of 

conformity upon such terms, and for such period (not in 

excess of one year), as he may prescribe." 

The certification process begins with the submission by the automobile manufacturer of a part I application for certification of proposed 

vehicles. The purposes of a part I application are to give notice to EPA 

of the manufacturer's intent to sell vehicles; to provide information sufficient to determine whether the test equipment, test fuel, and mileage 

accumulation procedure proposed to be used by the manufacturer conform to 

Federal regulations; and to provide the necessary description of the proposed product line, together with projected sales data, to allow EPA to 

select the vehicles it will require to be tested. 

EPA reviews the part I application to ensure its conformity with 

Federal regulations and to resolve any problems with the manufacturers. 

At the time EPA reviews the part I application, it selects the vehicles 

to be tested. In selecting test vehicles EPA designates two different 

test fleets: an emission data fleet and a durability data fleet. 

- l- 
The emission data fleet consists of a number of vehicles tested 

to 4,000 miles to establish the emission level of a vehicle after it 

has been broken in. The durability data fleet consists of a smaller 

number of vehicles tested to 50,000 miles to establish the rate of 

deterioration of a vehicle's emission control system over the useful 

life of the vehicle, 

The vehicle selection process begins by dividing the manufacturer's 

product line into groupings of vehicles called engine families. Each 

engine family consists of a group of vehicles whose engines could be expected to have similar emissions characteristics. Once the product line 

is divided into engine families, emission data and durability data vehicles are chosen. 

After the manufacturer receives written notification that its proposed test procedures and equipment are acceptable and has been notified 

of the required test fleet, it can begin the second phase of the certification process--mileage accumulation and conformance testing. The manufacturer must test both emission data and durability data vehicles, at 

the zero-mile stage (less than 50 miles) and must report the results to 

EPA, After emission data vehicles accumulate 4,000 miles, they are tested 

by the manufacturer and the results are reported to EPA. The manufacturer 

then submits the vehicles to EPA for testing at its laboratory in Ann Arbor, 

Michigan. The EPA test results are considered official. 

Durability data vehicles must be tested by the manufacturer at each 

4,000-mile interval from 4,000 miles to 48,000 miles and at 50,000 miles, 

EPA may perform the test in its Ann Arbor laboratory at each test point, 

EPA tests, however, are generally run on the durability data vehicles only 

at intervals of 12,000, 24,000, 36,000, and 50,000 mile points. 

When EPA conducts the test on a vehicle at a test point, EPAss test 

is used in determining conformity. When EPA does not conduct the test, the 

manufacturer's data is used, unless there is a lack of correlation between 

EPA's and the manufacturer's test equipment, in which case the manufacturer's 

data will not be accepted until the reasons for the lack of correlation 

are determined and the validity of the data is established by the manufacturer. 

Maintenance on the test fleets is allowed to be performed by the manufacturer in accordance with a prescribed schedule contained in the Federal 

regulations O Any other maintenance or repairs are allowed only with the 

advance approval of EPA. Requests to perform such unscheduled maintenance 

are frequently approved by EPA. 

-2- 
ENCLOSURE I 

After completion of all the required tests on each of the emission 

data and durability data vehicles in an engine family, the manufacturer 

submits a part II application for certification of that engine family. 

The part II application contains a compilation of all testdata (as a 

control measure, test data is also submitted to EPA as the tests are completed) on all vehicles tested and a full description of all maintenance 

performed. Compliance is determined by applying to the results of emission tests a deterioration factor determined from the durability tests 

and comparing the results with the applicable emission standards, 

FORD MOTOR COMPANY VIOLATED 

FEDERAL CERTIFICATION REGULATIONS 

In April and May 1972, the Ford Motor Company submitted to EPA four 

part II applications for certification of 1973 engine families. On 

May 16, 1972, Ford withdrew the applications because top management had 

become aware that unauthorized maintenance had been perfonned on the prototype vehicles tested for certification and that such maintenance had not 

been reported to EPA. The unauthorized maintenance invalidated the test 

results on the four engine families covered by the applications. Unauthorized maintenance was also performed on the eight other 1973 engine 

families for which Ford had almost completed certification testing, and 

therefore the results of the tests on those engines were also invalidated. 

This was the latest in a series of incidents involving the certification of Ford vehicles. In 1970 Ford experienced delays in testing 

prototypes of its 1971 heavy-duty gasoline engines and requested EPA to 

certify the engines on the condition that Ford would ensure the proper 

modification of any engines later determined by EPA to be ineligible for 

certification. On January 11, 1971, EPA granted Ford the conditional 

certification, but on January 22, 1971, EPA revoked certification for two 

of the 11 engine models because emission test results for those two engines 

exceeded Federal standards. About 500 engines had been produced for the 

two models whose conditional certificates were revoked, Ford modified the 

engines to the satisfaction of EPA and reapplied for certification of the 

models. Subsequently, all 11 models received certificates of conformity. 

In another incident Ford shipped about 200,000 1972-model vehicles to 

its dealers before the vehicles were certified by EPA. EPA considered the 

shipments illegal and requested the Department of Justice to pursue legal 

action against Ford. Ford signed a consent judgment and settled for $10,000 

(or about 5 cents per vehicle). 

Ford attributed the cause of the current incident to a lack of proper 

management control over certification testing. Within Ford, the Engine 

and Foundry Division (E&F) had the responsibility for building the certification vehicles, conducting the tests, and compiling the certification data. 

-3- 
ENCLOSURE I 

Ford officials told us that E&F thus had a vested interest in ensuring 

that the vehicles met Federal emission standards. They told us also that 

Ford did not have written procedures for testing vehicles for certification 

but that the Federal regulations and EPA advisory bulletins had been 

widely distributed to those having responsibility for certification testing,, 

Under the supervision of E&F, Ford's Car Product Development Group 

conducted the actual testing in its laboratory in Dearborn, Michigan, and 

drove the cars for mileage accumulation at three Ford, test tracks. E&F, 

through Ford's Automotive Emissions Office (a staff office organizationally 

independent of E&F but responsible for signing Ford's applications for cer-. 

tification), requested approval from EPA to perform some unscheduled maintenance on certification vehicles. The Automotive Emissions Office relayed 

E&F's requests to EPA and maintained documentation concerning EPA's approval 

of such maintenance. Ford officials told us, however, that the working 

level staff of E&F routinely performed unauthorized inspections, tests, and 

maintenance on the 1973 prototype vehicles without notifying the Automotive 

Emissions Office or EPA, All such maintenance, tests, and inspections were 

noted in the vehicle logs and were entered into Ford's computer system. 

As a result of E&F's complaints of inadequate support from Ford's 

Central Computer Group, the group prepared a complete report on all work 

done for E&F, including a printout of all maintenance performed on durability 

data vehicles. The printout contained data on two types of vehicle maintenance-- that reported to EPA and that not reported to EPA. The Central 

Computer Group advised the Ford vice president in charge of the Automotive 

Emissions Office of the printout on May 11, 1972, On May 16, 1972, Ford 

advised EPA of the unauthorized maintenance and withdrew its four applications for certification previously submitted on 1973-model engine families, 

Subsequent investigation by Ford disclosed that Ford personnel, in 

addition to performing unauthorized maintenance, had made unauthorized 

inspections and had conducted unauthorized diagnostic emissions tests. 

Ford identified 442 instances of unauthorized maintenance performed on 26 

test vehicles, 

Ford revised the application for one of its engine families to include 

the unauthorized and previously unreported maintenance items and resubmitted 

the application to EPA on May 19, 1972, The application contained 97 unreported maintenance items. EPA indicated that it would not have approved 

71 of these items. EPA rejected the application., 

On May 23, 1972, Ford reorganized and transferred responsibflity for 

prototype certification testing from E&F to the Environmental and Safety 

Engineering Staff, which included the Automotive Emissions Office, The 
ENCLOSURE I. 

vice president in charge of the Environmental and Safety Engineering 

Staff reports directly to the president of Ford. In a memorandum to 

Ford officials concerning the transfer of responsibility for certification testing, the chairman of the board stated: 

I'*** once a vehicle is transferred to the Environmental 

and Safety Engineering Staff for certification mileage 

accumulation and testing, neither the Engine and Foundry 

Division nor any other organization will touch the car or 

have access to it except as directed by the Environmental 

and Safety Engineering Staff." 

Ford also established an emissions certification organization under 

the Automotive Emissions Office. The emissions certification director Fs 

responsible for (1) controlling the entire certification process, (2) ensuring compliance with certification procedures, and (3) verifying the 

accuracy and completeness of certification applications. E&F continues to 

build the certification vehicles, and the Car Product Development Group 

continues to perform the actual testing and to drive the cars for accumulation of mileage. Ford officials told us that, in addition to the reorganization, the following actions would be taken to improve management control 

over certification vehicles: (1) all unscheduled maintenance which could 

affect emissions would require the advance approval of the 

Automotive Emissions Office, (2) the hoods of the vehicles would be locked 

to prevent tampering, (3) the vehicles would be stored in closely guarded 

storage areas during "soak" or cooling-down periods, (4) Ford would prepare a detailed manual fully describing the certification procedures, including the duties of drivers, mechanics, and engineers, and (5) when the 

manual was completed, Ford would institute internal reviews to ensure ccmpliance with the manual provisions. 

CERTIFICATION PEXXEDURES OF 

OTHER MAJOR DOMESTIC 

AUTO COMPANIES 

We visited the General Motors Corporation, the Chrysler Corporation, 

and the American Motors Corporation to obtain information on thei- certification test procedures. None of the companies had written procedures, 

but officials of each of the companies stated that it was unlikely that unauthorized maintenance would be performed on their test fleet vehicles without the knowledge of upper management personnel. 

The officials told us that EPA personnel did not monitor their companies' testing activities or their test records but that EPA personnel 

visited the companies8 facilities, when requested, to approve unscheduled 

maintenance or to resolve problems. The officials stated, however, that 

-5- 
they would have no objection to EPA's assigning inspectors to monitor 

testing activities. 

EPA officials told us that they had no basis for suspecting that 

unauthorized maintenance had been performed on the test vehicles of the 

three companies. In view of the limited EPA staff assigned to certification activities and the inadequacy of EPA certification procedures, as 

discussed below, it is our opinion that EPA does not have reasonable 

assurance that the companies have complied with Federal regulaticns related to maintenance. 

Specific information concerning the manufacturers' certification 

procedures follows. 

At the General Motors Corporation (GM), the Environmental Activities 

Staff is responsible for submitting certification and application 

data. The actual day-to-day test operations are performed under the direction of the Vehicle Emission Laboratory (VEL) at GM's proving ground 

garage. Engine design is the responsibility of auto divisions, such as 

Chevrolet and Buick, but testing is the responsibility of the proving 

grounds garage, which is organizationally independent of the auto divisions. 

The proving grounds garage is responsible for accumulating mileage on 

the test vehicles and VEL is responsible for conducting the tests, Garage 

personnel, such as driver foremen, drivers, and mechanics, are not given 

test results. There is no incentive, in the opinion of GM officials, for 

such personnel to perform unauthorized maintenance or to violate other Government test requirements, As a further check on drivers, test vehicles 

are equipped with tachographs which record speed and time on tapes. VEL 

analyzes the tapes for violations of driving instructions and for unexplained 

stops. Also mechanics must have VEL's authorization before performing 

maintenance, The mechanics are required to maintain logs of all maintenance 

performed, and the logs are forwarded to EPA weekly through the Environmental 

Activities Staff, 

The auto divisions are responsible for developing the prototypes to 

be tested. Occasionally, the proving grounds garage will require maintenance assistance from car division personnel, but in such instances the 

chief engineer of the proving grounds garage is present to ensure that 

emission control devices are not tampered with, 

GM does not have a set of operating manuals and procedural instructions 

relating solely to auto emission testing. Generally the testing of prototypes, as described in GM's part I application, is conducted under GM's 

-6- 
ENCLOSURE I 

normal corporate procedures, and the various organizational elements 

involved in emission testing are bound by these procedures. Furthermore 

GM supplements these procedures, when necessary, with special instructions. 

GM officials told us that EPA personnel did not monitor GM's in-plant 

testing and records and that most EPA staff visits were for resolving 

problems. The officials stated, however, that they would have no objection 

to onsite Government inspectors' monitoring their testing activities. They 

stated that, if EPA wanted to keep each test car under surveillance, it 

would require three men per car, because of their three-shift operation, 

or 78 men for the test fleet of 26 cars that were being tested at that time,, 

Chrysler Corporation engineering operations are centralized under the 

Division of Engineering and Research. Within the division, vehicle emission 

certification responsibility is assigned to Materials Engineering and is 

carried out by its Exhaust Emissions Section, Although Chrysler engineering is centralized, engine design and emission certification activities 

are separate operations. Chrysler officials expressed the belief that, because of this separation of duties, Chrysler personnel would not intentionally 

violate Federal certification regulations. 

The responsibility of the Exhaust Emissions Section begins with 

assembling input data for the part I application. These data are obtained 

from various corporate divisions. Once the data are assembled into the 

prescribed EPA format by the section, they are returned to the originating 

division for verification, prior to being submitted to EPA for approval, 

The Exhaust Emissions Section is responsible for scheduling and testing operations. To carry out this phase of the certification activity, 

the section has a staff of about 16 engineers assigned to the Chrysler 

proving grounds. Test results are verified by the engineers and forwarded, 

with supporting documentation, to the section's central office staff for 

review and reverification. Test results are assembled by the central 

office staff for inclusion in Chrysler's part II application. 

Chrysler has not developed written procedures for its vehicle certification activities. Chrysler officials told us, however, that several 

unwritten procedures had been established to maximize control over vehicles 

during the mileage accumulation and test periods. The most significant 

of these are listed below, 

--Drivers and maintenance personnel are assigned 

from a central pool at the proving grounds. 

-7- 
ENCLOSURE I 

They are not a part of the Exhaust Emissions 

Section. This is intended to relieve drivers 

and maintenance personnel of any vested interest 

in the certification program. 

--Test drivers receive driving instructions from the 

Exhaust Emissions Section. In addition, each driver 

must maintain a driving log during the mileage accumulation period. 

--Each test vehicle is equipped with a tachograph for 

recording time and speed during mileage accumulation, 

--Maintenance supervisors must prepare and sign stock 

order forms to obtain replacement parts from the 

stock crib. 

--Maintenance supervisors must prepare work orders 

for all vehicle maintenance. These must be approved 

by the Exhaust Emissions engineers assigned to the 

proving ground. 

--Copies of all work orders for vehicle maintenance must 

be forwarded from the proving grounds to the Exhaust 

Emissions staff for review. These orders are entered 

on the section's maintenance log, 

--Maintenance logs are forwarded periodically to EPA 

by the Exhaust Emissions Section. 

As a result of the recent disclosure of unauthorized maintenance on 

Ford Motor Company test vehicles, Chrysler initiated an internal audit of 

its certification procedures, Chrysl.er auditors advised us that no significant problems had been identified but that two recommendations were 

being considered for improving vehicle control. The first related to locking or sealing the hood of the car to prevent unauthorized tampering with 

the engine. The second related to the possible use of prenumbered work 

orders to ensure that the Exhaust Emissions Section receives all vehicle 

maintenance work orders, 

During our review we questioned Chrysler officials concerning the 

possibility of stationing Government personnel at the test facilities to 

monitor the test activities, Chrysler officials stated that they had no 

objection and that at least 12 persons would be required to adequately 

monitor Chrysler testing operations. The officials also told us that, at 

the request of Chrysler, EPA representatives had been at Chrysler's test 

facility about once a week to observe maintenance work. 

-8- 
ENCLOSURE I 

American Motors CoAmerican Motors Corporation (AMCI officials stated that AMC's 

comparatively small corporate size allowed close supervision at all 

levels. The vice president for engineering and research told us that 

he checked the testing and certification activities daily. He said that 

AMC's size and financial condition required that it not absorb any losses 

which might be incurred if certification of new model production cars 

were delayed. He said that the risk involved in tampering with certification regulations would be too great. 

AMC had no written procedures for development of certification data. 

On the basis of discussions and observations, we found that the following 

general procedures existed. 

--Necessary mileage is accumulated by the use of dynamometers 

or drivers on city streets. (No test track is used.) 

--Most drivers are hired through private employment agencies 

and do not have special technical skills. 

--Drivers maintain logs of their activities during their 

8-hour shifts, 

--Three shifts are employed 6 days a week until the 

necessary mileage is accumulated. 

--Test cars are monitored through the use of tachograph 

readings which are maintained in logs for each vehicle, 

--Emission-type maintenance can only be approved by the 

supervisor of exhaust emissions or by his assistant. 

--A detailed log on all maintenance, including such routine 

maintenance as oil changes, is maintained for each vehicle, 

The officials said that EPA representatives had mademanyvisits, 

especially during the beginning of the certification year--November and 

December--to explain the Federal regulations. The officials indicated 

that these visits were not specifically for monitoring testing. 

AMC officials stated that they would not object to onsite EPA 

inspectors' monitoring their certification testing activities. They expressed the belief, however, that unauthorized maintenance probably could 

be performed, if desired, even if Government monitoring were provided. 

-9- 
ENCLOSURE I 

EPA STAFF ASSIGNED TO CERTIFICATION ACTIVITIES 

IS INSUFFICIENT 

The number of persons assigned to test and certify automobile 

prototypes has generally been insufficient for adequately performing all 

activities necessary to reasonably ensure that automobile manufacturers 

comply with Federal certification regulations. The Director of EPA's 

Mobile Source Pollution Control Program told us that his initial program 

plan for fiscal year 1972 provided 237 authorized positions for his program, including 46 positions for the Division of Certification and Surveillance, The Director stated, however, that EPA officials had reduced the 

authorization for the Mobile Source Pollution Control Program to 161 positions, of which 32 were allocated to the Division of Certification and 

Surveillance. 

As of June 1, 1972, EPA had assigned 146 persons to the Mobile Source 

Pollution Control Program but only 19 were directly involved in the certification of prototypes and only 10 of those were directly involved in 

certifying light-duty vehicles--primarily autos. One year earlier, on 

June 1, 1971, only five persons were assigned to certify light-duty vehicles. In July 1970 only five positions had been authorized for the 

entire certification program for both light- and heavy-duty vehicles. 

EPA also has assigned to its emission-testing laboratory 32 technicians of whom seven perform the certification tests of light-duty 

vehicles. Thus the prototypes of all auto companies are tested and certified primarily through the combined direct effort of 17 EPA personnel. 

The 10 persons responsible for certifying light-duty vehicles are 

assigned among three teams, each team having responsibility for about 

one-third of the 52 auto companies seeking certification in model year 

1973. In addition to handling smaller companies, one team handles Chrysler 

and AMC, one team handles GM, and one team handles Ford. 

The staff spends a significant part of its time explaining and interpreting Federal regulations for the auto companies, either verbally or 

in writing. EPA officials told us that some provisions of the regulations 

were general in nature because they were intended to allow the flexibility 

needed in dealing with today's diverse vehicle product lines and continually 

developing technology. The remainder of the staff's time is normally spent 

reviewing and approving the auto companies" part I and part II applications 

for certification, assisting the auto companies in resolving day-to-day 

problems, monitoring vehicle tests in the EPA laboratory, and reviewing 

maintenance logs submitted by the auto companies as testing progresses. 

Staff has not been available for routine monitoring of the testing activities 

at the auto companies. 

- 10 - 
ENCLOSURE I

The Director, Division of Certification and Surveillance, told us 

that he had had considerable difficulty in hiring and retaining qualified people, He attributed this problem to (1) low entrance sa?aries-- 

(EPA hired college graduate engineers without experience at the GS-5 

level)--about $7,300 and (2) noncompetitive Federal salaries for engineers 

with automotive emissions experience. The certification staff recently 

lost two experienced engineers to the auto industry, but EPA had had difficulty attraceing such people from the auto industry, even at the GS-13 

level (about $18,700). 

Also we noted that, although the number on the light-duty certification staff had increased from five to 10 since June 1971, five of the 

10 staff members had worked for EPA Less than 5 months. Three of the 

five are recent college graduates, and the other two have a combined total 

of 11-l/2 years of automotive experience. The Director told us that a 

newly hired college-graduate engineer needed 12 to 18 months of experience 

in the certification process before he could make a meaningful contribution. 

The Director told us that the average grade level of his staff should be 

increased by fiscal year 1975, if the Government is to be competitive with 

industry. 

For 1973 models, EPA began testing durability prototypes at intermediate mileage points, in addition to the 50,000-mile point, which increased the total number of certification tests made in EPA laboratories 

by 50 percent over the previous year. EPA certification and laboratory 

officials told us that the number of laboratory technicians (seven) assigned to test light-duty vehicles was insufficient to effectively 

accomplish all required duties. 

During the first 5 months of 1972, the seven technicians assigned to 

test light-duty vehicles performed about 600 tests and were required to 

work 500 hours of overtime. EPA officials told us that about 350 additional 

tests would be required to complete the certification testing of 1973 prototypes. The supervisor of the laboratory test staff expressed the belief 

that, because of the certification workload, his present staff of seven 

should be doubled. 

EPA recently moved into its new $10 million emission-testing laboratory in Ann Arbor. The director of the laboratory said that it was not 

adequately staffed and that some equipment was being used only about onethird of the time. Another laboratory official said that, with adequate 

staffing, 30 tests could be run each day, compared with 10 with the preset 

staff. 

1t 

- 11 - 
ENCLOSURE I 

EPA PROCEDURES INADEQUATE FOR 

REASONABLY ENSURING THAT. AUTO COMPANIES 

CClMJ?JsY WITH FEDERAL CERTIFICATION REGULATIONS 

EPA has operated the certification program on the basic assumption 

that the auto companies will act in good faith, comply with EPA certification regulations, and submit complete and accurate data to EPA. On 

May 15, 1972, we issued to the Congress a report entitled "Cleaner 

Engines for Cleaner Air: Progress and Problems in Reducing Air Pollution 

from Automobiles, Office of Air Programs, Environmental Protection Agency" 

(B-1665061, which included a discussion of certain shortcomings in EPA's 

certification program. 

Our present review showed that EPA had not evaluated nor requested 

documentation on the practices and procedures followed by the auto companies in their testing process. Nor have EPA personnel made onsite, 

unannounced inspections for monitoring the auto companies' testing process 

and ensuring compliance with regulations. EPA visually inspects emissions 

data and durability data vehicles prior to testing the vehicles in its 

laboratory, but EPA officials told us that such inspections and tests 

generally could not be effective for detecting evidence of unauthorized 

maintenance or other irregularities., 

EPA's monitoring consists primarily of its reviews of part I and 

part 11 certification applications and periodic vehicle maintenance and 

test records submitted by the auto companies. Certification Branch personnel evaluate data contained in the applications for conformity with 

the regulations. Records of the mileage accumulated, maintenance performed, and tests run on the prototypes are submitted to EPA weekly by 

the auto companies and are reviewed and evaluated by EPA personnel. The 

Director of EPA's Division of Certification and Surveillance told us that 

EPA's practice of accepting manufacturers t data at face value obviously 

was inadequate for ensuring compliance with Federal regulations, 

Moreover EPA officials told us that, because of staffing limitations, 

EPA had not visited the manufacturers' plants to monitor the testing 

activities or to review the records. The visits that EPA personnel made 

to manufacturers' facilities usually were for resolving specific problems 

rather than for observing or monitoring testing practices or for spot 

checking records. The instances of unauthorized maintenance performed by 

Ford were recorded in Ford"s records. 

EPA's procedures have not been adequate for ensuring that manufacturers 

comply with Federal regulations. In addition, a lack of staff limits 

EPA's ability to adequately monitor the test activities of the manufacturers. 

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ENCLOSURE I 

Prose-r retesu 

Ford cars 

The process of rerunning durability tests on 39 Ford vehicles 

involving 12 engine families is scheduled to be completed by September 

1972 a To minimize delays in this testing process, EPA has established 

a task force to accelerate and coordinate certification of Ford vehicles. 

The task force is responsible for making decisions concerning the allowability of unscheduled maintenance, verifying driver's complaints, and 

inspecting failed components. Some of the actions EPA has taken to 

maintain control over the retesting of Ford vehicles include: 

--Installation of a tachograph in each vehicle to provide 

a continuous record of vehicle usage. (GM, Chrysler, 

and AMC have used tashographs in their test vehicles.) 

--Inspection by EPA of vehicles and components prior to 

the start of testing. 

--Documentation of all communications between Ford and 

EPA, including telephone conversations and meetings. 

--Tests by EPA of durability vehicles at applicable mileage 

points, A confirmatory test will not be run by Ford. 

--Spot inspections by EPA of Ford's test facilities during 

any time that work is being performed for making odd-hour . 

inspections to ensure Ford integrity for the duration of 

the certification test program. 

--Review and evaluation by EPA of Ford's inspection 

procedures. 

--Establishment by Ford of a system whereby EPA would be 

furnished with emission and maintenance data every 24 

hours, 

The Director of EPA's Mobile Source Pollution Control Program emphasized to us that, aLthough EPA would give Ford priority treatment in 

resolving problems, reviewing data, testing vehicles, and so forth, so 

that Ford vehicles could be certified as soon as possible if they met 

Federal emission standards, EPA would not waive any regulatory or sertification requirements. 

Although we did not estimate the additional costs that would be incurred by EPA in its program to accelerate certification of Ford vehicles, 

- 13 - 
. .’ 

ENCLOSURE I 

our review indicated that such costs would be substantial, For example, 

EPA estimates that about 1,300 hours of overtime work will be required. 

In addition, communication costs will increase as a result of the close 

monitoring; several EPA personnel will be assigned to monitor Ford certification activities; and a substantial amount of work will, in effect, 

be repeated because of the need to test an entire new fleet of prototype 

vehicles. 

wtive orocedures beinp considered bv EPA 

EPA officials recognize that something has to be done to obtain 

greater assurance that auto companies comply with all Federal certification regulations, especially with respect to unscheduled maintenance. 

Various plans for improved monitoring of the auto companies' certification practices are being considered by EPA, An EPA official said that 

EPA expected to develop a plan in the near future and that it would be 

applied initially to the domestic auto companies. According to EPA officials the following three alternative plans were being considered. 

1. The auto companies would continue to have responsibility 

for testing prototypes, but EPA would make unannounced 

inspections of the auto companies' testing facilities 

and records to ensure integrity of the testing. 

20 EPA would have inspectors stationed at the auto companies' 

test facilities to continually monitor the companies' 

testing activities. 

3. EPA would assume all responsibility for testing and mileage accumulation for some or all of the prototypes. If 

EPA were to assume all responsibility for testing some of 

the prototypes, the other prototypes would be subject to 

spot-check monitoring by EPA inspectors. 

Alternatives 2 and 3 would probably be very expensive. For example, 

GM officials told us that, if the Government wanted to keep each GM test 

vehicle under surveillance, it would require three inspectors per car 

(3 shifts) or 78 inspectors for the present test fleet. A Chrysler official stated that EPA would need 12 inspectors at Chrysler: two for each 

of three shifts, at two locations, 

With respect to alternative 3, Chrysler officials expressed the belief that EPA should not take on the responsibility for testing all prototypes, because EPA had neither the facilities nor the staff required. In 

addition, they said that EPA had problems with frequent staff turnover. 

Chrysler officials also indicated that Chrysler spent about $1 million 

annually on its emission certification program. 

- 14 - 
.* . 

ENCLOSURE I 

EPA's Director, Mobile Source Pollution Control Program, told us 

that he preferred alternative 1 and that he had requested additional 

resources to implement that alternative, He told us he did not believe 

the costs involved in alternative 2 could be justified at this time and 

that alternative 2 should be considered further only after experience 

had been gained with alternative 1. He also said that he believed that 

alternative 3 was unrealistic, not only because of the enormous costs 

involved but also because he deemed it inappropriate for the Government 

to assume responsibility for the testing of the vehicles. He said that 

under alternative 3, if a test vehicle failed for any reason, there would 

be endless quarreling between the EPA and the company about who caused it 

to fail and there would be no satisfactory way to resolve these disagreements. 

OONCLUSIONS 

We believe that the responsibility for accumulating mileage, testing vehicles, submitting data, and ensuring that Federal certification 

regulations are not violated properly should rest with the auto companies. 

EPA has responsibility for ensuring that (1) the auto companies comply with Federal regulations and (21 emissions from engines awarded certificates of conformity are within established standards. We believe that, 

to effectively fulfill these responsibilities, as a minimum, EPA needs 

additional personnel assigned to its certification activities and needs to 

significantly increase its surveillance and monitoring of the auto companies 

certification procedures, practices, and recordso 

EPA should require that the auto companies prepare and submit to EPA 

written procedures for their certification activities. Officials of the 

four auto companies told us that they would not object to EPA inspectors' 

monitoring their in-plant testing and reviewing plant records related to 

their certification activities. In this regard, EPA personnel should be 

able to enter auto company facilities, unannounced, any time of the day or 

night when mileage is being'accumulated or testing is being conducted on 

certification vehicles for the purpose of monitoring such activities. 

Requiring the auto companies to prepare written procedures and making 

in-plant inspections of the companies' tests and records will not provide 

EPA with &&& assurance that the auto companies are not violating Federal 

regulations, but it will provide significantly greater assurance than now 

exists. The procedures that would provide the greatest assurance are those 

under which EPA assumed responsibility for accumulating all mileage and 

conducting all tests on all emission data and durability data vehicles of 

all auto companies. These procedures would also be the most expensive to 

implement. 

- 15 - 
ENCLOSURE I 

Consideration should be given to the time and effort that would be 

required to obtain and train new staff. EPA has had problems in the 

past in hiring and retaining experienced staff. A sudden and extensive 

expansion of staff could be counterproductive because it would divert 

the time of the few experienced men from their certification duties to 

the training of newcomers. 

- 16 - 
ENCLOSURE II 

. 

COMMITTEE ON PUBLIC WORKS 

WASHINGTON. D.C. 20510 

Honorable Elmer B. Staats 

Comptroller General of the United States 

General Accounting Office 

441 G Street, N.W. 

Washington, D.C. 20548 

Dear Mr. Comptroller: 

On May 18, the Environmental Protection Agency announced 

that the Ford Motor Company was withdrawing the applications it had 

made to EPA for certification of its 1973 vehicles. According to the 

EPA announcement, Ford had discovered inaccuracies in its own test data, 

Subsequently, at a hearing before the Subcommittee on Air 

and Water Pbllution on May 22, William D. Puckelshaus, Administrator of 

the Environmental Protection Agency, testified that Ford test personnel 

had performed prohibited maintenance operations on prototype vehicles 

being tested for certification. 

Testimony at the May 22 hearing also indicated that EPA has 

no secure way to check data submitted by other auto companies to make 

sure that similar prohibited acts have not occurred in preparation of 

their data. Primary reliance for discovering such prohibited acts, EPA 

indicated, must come from disclosures of auto company employees. 

In light of these events, I ask your help in investigating 

the current capacity of EPA to oversee the auto companies' preparation 

of data for certification and the adequacy of EPA procedures to prevent 

similar circumstances in the future. Specifically, I would like to know: 

(a) The number of EPA personnel assigned to prototype 

certification activities; 

(b) The number of EPA personnel assigned to monitor the 

development of certification data by the auto industry -- 

including the number of personnel assigned to monitor 

activities at the test facilities of the respective auto 

makers; 

(c) The adequacy of EPA procedures to assure that regulations 

covering the certification tests are not violated in the 

testing process; and 

(d) The extent to which the data available to EPA enables the 

agency to independently evaluate the manufacturer procedures 

as required by section 208 of the Clean Air Act. 
ENCLOSURE 11 

Honorable Elmer B. Staats - Page 2 

Further, EPA has indicated to the Subcommittee on Air and 

Water Pollution that legislation may be needed to assist Ford Motor 

Company in solving the problems it faces now in developing new 

data for certification and in getting cars into production in time 

for the 1973 auto year. 

Before such legislation can be seriously considered, it is 

essential for the Subcommittee to know whether the Ford discovery of 

prohibited acts in the certification testing process represents an 

isolated incident or a more pervasive practice in the auto industry. 

For this reason, I ask you also to investigate the certification 

data submitted to the Environmental Protection Agency by the auto 

companies for their 1973 vehicles and the practices and procedures employed 

by the auto industry in developing this data to assure that these practices 

are consistent with the law and EPA regulations. 

As.we expect a request for action on legislation in a reasonably 

short time, a report is needed within 10 days. Prompt study of 

this matter is vital to assure fully informed Congressional consideration 

of measures to deal with this problem. 

Sincerely, 

EDMUND S. MUSKIE, U,S,S. 

rman, Subcommittee on 

r and Water Pollution 

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