Analysis of Technical Issues Relating to: California's Request for Waiver of Federal Preemption with Respect to Optional 100,000-Mile Exhaust Emission Standards and Test Procedures for 1980 and Subsequent Model Year Light-Duty Vehicles and 1981 and Subsequent Model Year Light-Duty Trucks and Medium-Duty Vehicles

摘要

California has asked EPA for a waiver of Federal preemption concerning a number of changes to emission standards and test procedures applicable when a vehicle is certified for 100,000 miles. A separate set of emission standards are applicable when a vehicle is being certified for 50,000 miles, which is the Federal certification period. These 50,000 mile emission standards have already been granted a waiver by EPA under the requirements of the Clean Air Act and are not being revised. The changes to the 100,000 mile emission standards and test procedures constitute changes to an option and are not required to be met by all manufacturers. The 100,000 mile certification revisions are to take effect beginning with the 1980 model year for passenger cars and with the 1981 model year for light duty trucks and medium duty vehicles. This document shall concern itself with two criteria (1) that the state was not arbitrary and capricious in determining that the state standards will be at least as protection of public health and welfare as applicable Federal standards, and (2) that the state standards and accompanying test procedures are consistent.