-------
     Administrator, U.S. Environmental Protection Agency by
     Emission Control Technology Division, January 1975.

12.  A Report on Automotive Fuel Economy, U. s. Environmental
     Protection Agency, October 1973.

13.  Automobile Gasoline Mileage Test Results, 1974 Cars and
     Light-Duty Trucks, U.S. Environmental Protection
     Agency, September 18, 1973.

14.  Potential for Motor Vehicle Fuel Economy Improvement,
     Report to the congress by U.S. Environmental Protection
     Agency, October 24, 1974.

15.  EPA Analysis of FEO Review of Lead Phase-Down
     Regulation, U.S. Environmental Protection Agency, April
     9, 1974.

16-  Automotive News 4973 Almanac, April 30, 1973.

17.  Long Term Forecastf Chase Econometric Associates,
     December 2, 1974.

18.  "Forecast of Motor Vehicle Distribution, Production,
     and Scrappage, 1971-1990," U.S. Department of
     Transportation, Federal Highway Administration, October
     1971.

19«  1973/74 Automobile Facts and Figures, Published by
     Motor Vehicle Manufacturers Association, Detroit,
     Michigan.

20.  Tingley, D.S., and Johnson, J.H., "Emissions and Fuel
     Usage by the U.S. Truck and Bus Population and
     Strategies for Achieving Reduction," SAE Paper No.
     740537, June 1974.

21.  "Control of Air Pollution From Aircraft and Aircraft
     Engines, Emission Standards and Test Procedures for
     Aircraft," Federal Register, Vol. 38, No. 136, Tuesday,
     July 17, 1973.

22.  Aircraft Emissions;  Impact on Air Quality and
     Feasibility of Control, U.S. Environmental Protection
     Agency.

23.  Cost estimates provided by R. Sampson, U.S.
     Environmental Protection Agency, Ann Arbor, Michigan.
                           2-270

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24.  EPA Memorandum:  "Analysis of Estimated Maintenance
     Costs for Emission control Systems Meeting the 1975/76
     Federal Standards."

25.  Hare, C.T., Springer, K.J., Oliver, W.R., Houtman,
     W.H., and Huls, T.A., "Motor Cycle Emissions, Their
     Impact, and Possible Control Techniques", SAE Paper No.
     7i»0627, Presented at SAE West Coast Meeting, August
     1974.

26.  Hare, C.T., Springer, K.J., Oliver, W.R., and Houtman,
     W.H., "Small Engine Emissions and Their Impact", SAE
     Paper No. 730859, Presented at SAE National FCIM and FL
     Meeting, September 1973.

27.  Hare, C.T.f Springer, K.J., and Huls, T.A., "Exhaust
     Emissions From Two-Stroke Outboard Motors and Their
     Impact", SAE Paper No. 740737, Presented at SAE
     National FCIM and FL Meeting, September 1974.

28.  Hare, C.T., Springer, K.J., and Huls, T.A., "Snowmobile
     Engine Emissions and Their Impact", SAE Paper No.
     740735, Presented at SAE National FCIM and FL Meeting,
     September 1974.

29«  Nationwide Inventory of Air Pollutant Emissions—1968*
     U.S. Department of Health, Education, and welfare.
     Public Health Service, Environmental Health Service,
     National Air Pollution Control Administration,
     Publication No. AP-73, August 1970.
                           2-271

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              2.  TRANSPORTATION CONTROL PLANS
Summary
When new-vehicle emission standards and stationary-source
control are fully implemented, twenty-seven Air Quality
Control Regions (AQCR) are still expected to exceed the
oxidant and carbon monoxide air quality standards of 1975.
To meet the air quality standards, these AQCR's will be
required to implement Transportation Control Plans  (TCP).
The aim of the TCP's is to reduce total emissions of in-use
vehicles by implementing either or both of the following
strategies to control total emissions from in-use vehicles:

  •  Measures that reduce emissions per vehicle mile of
     travel

  •  Measures that reduce total vehicle miles travelled
      (VMT).

The first strategy includes the application of retrofit
control systems, inspection and maintenance of vehicles, and
service station vapor controls.  The second strategy
contains mass transit improvements, carpool programs, and
other methods that will reduce the use of low-occupancy
automobiles.

A detailed discussion of measures contained in the TCPfs is
given in the following paragraphs.  Costs for implementing
the inspection and maintenance programs, installation of
retrofit devices, and service station vapor control systems
are estimated for each AQCR for the period 1976 to  1985
inclusive.  The costs to the vehicle owners of implementing
these measures are estimated to be $344 million in  1976,
$441 million in 1977, and thereafter remaining relatively
constant through 1985.  However, a net benefit results by
taking into account the fuel savings that are expected to
result from tune-ups required by the inspection and
maintenance strategies.  Hence, the cumulative benefit for
the period 1976-85 is estimated to be about $540 million
(see Table 2-13).  Approximately $664 million will be spent
for capital investment' over the decade and a little over $3
billion will go to operation and maintenance of the program
(see Table 2-14).  To maintain maximum clarity and
usability, it was decided not to convert the U.S. units of
measure contained in this section to metric equivalents.
                           2-272

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Introduction

The Clean Air Act Amendments of 1970 (hereafter referred to
as the Act) directed EPA to set national primary and
secondary ambient air quality standards.  The primary
standards must be established so that their attainment and
maintenance will protect the public health with an adequate
margin of safety.  The secondary standards will protect the
public welfare from any known or anticipated adverse effects
associated with the presence of air pollutants.  In 1971,
national ambient air quality standards were established for
six pollutants, including the four primary pollutants
associated with motor vehicles: carbon monoxide, nitrogen
dioxide, photochemical oxidant, and hydrocarbons.
Hydrocarbons are reactants in the formation of oxidants, and
they have no known health effects at ambient concentrations.
The primary and secondary standards for these pollutants are
identical and are shown in Table 2-1.
                         Table 2-1.
         National primary and Secondary Ambient Air
                     Quality Standards

                          Air Quality
Pollutant                 Standard1 (ppm)    Averaging Time

Hydrocarbons              0.24              3 hours
                          or                or
                          9.00              8 hours

Carbon Monoxide          35.00              1 hour

Nitrogen Dioxide          0.05              Annual

Photochemical Oxidant     0.08              1 hour

* Primary and secondary standards for these pollutants are
  identical.  Standards are not to be exceeded more than
  once a year.

Source: Reference 1.
The standards for the motor-vehicle-related pollutants have
been exceeded in a number of major urban areas.  From the
State Implementation Plans (SIP)  submitted to EPA by the
states in February 1972, it was found that of the 247 AQCR's
in the United States, 54 regions exceeded the air quality
standard for oxidants, 29 exceeded the carbon monoxide
                           2-273

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standard, and 2 exceeded the nitrogen dioxide standard.  In
total, sixty-six AQCR's, representing roughly 60 percent of
the nation's population, exceeded one or more of these
standards.

The Act established three principal approaches to achieving
the air quality standards:

  •  Emissions standards for new automobiles

  •  Emissions standards for stationary sources  (power
     plants, industrial sources, and general area sources)

  •  In-use vehicle controls.

EPA is authorized to promulgate and enforce emissions
standards for new automobiles, trucks, and motorcycles.  EPA
has used this authority to establish increasingly stringent
emissions standards for cars and initial standards for
trucks.  More stringent truck standards as well as
motorcycle emissions standards are now under development.2
The Energy Supply and Environmental Coordination Act of 1974
extended the 1975 and 1976 deadlines of the Act for two
years.

Reductions in pollutant concentrations resulting from the
implementation of new-vehicle emissions standards and
stationary-source controls were projected to significantly
reduce the number of AQCR's exceeding the oxidant or carbon
monoxide air quality standards.  These include approximately
i>0 percent of the nation's population.  Table 2-2 presents a
list of these AQCR's together with the ambient
concentrations for carbon monoxide and photochemical
oxidants measured through 1972.  Having controlled the
emissions from stationary sources and new vehicles to the
extent possible, those states containing the AQCR's that are
still projected to exceed the air quality standards will be
required to implement transportation control plans, i.e.,
control of in-use vehicles, to meet the requirements of the
Act.  This section describes the TCP's to be implemented in
those states containing the AQCR's listed in Table 2-2, and
it includes the estimated costs to the nation.
                           2-27tt

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Overall Strategies

TCP's make use of either or both of the following strategies
to control total emissions from in-use vehicles:

  •  Measures that reduce emissions per vehicle mile of
     travel

  •  Measures that reduce total vehicle miles travelled
     (VMT) .

The first strategy includes the inspection and maintenance
of vehicles in use and the application of retrofit control
systems.  The second strategy includes mass transit
improvements, carpool programs, and other methods that will
reduce the total use of automobiles.  TCP's mainly pursue
the above strategies with respect to automobile travel.  The
goals are to reduce emissions per vehicle mile and/or to
reduce VMT for automobiles.  Although motor vehicles are not
the only source of hydrocarbons, carbon monoxide and
nitrogen oxide emissions, Table 2-3 clearly indicates the
significance of automotive emissions.
                         Table 2-3.
       Mix of Emission Sources in Urban Areas - 1971

                             Percent of Total Emissions
                                         Trucks,
                                         Buses &
                                         Motor-   Stationary
                                         cycles   Sources
Pollutants

Carbon Monoxide
Hydrocarbons
Nitrogen Oxides
Automobiles
                          77-87          8-10      3-15
                          50-65          5-10     25-45
                          40-50          8-13     37-52
Source:  Reference 3, p. 111-23.
Measures that Reduce Emissions
Per Vehicle Miles

INSPECTION AND MAINTENANCE PROGRAMS

The term "inspection and maintenance" covers a variety of
strategies for reducing air pollutant emissions from light-
duty motor vehicles that are currently in use by
establishing procedures that will ensure proper maintenance
                           2-276

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of vehicles.  Emissions from most vehicles tend to increase
with use until the vehicle on the road is properly tuned.
Thus, most vehicles on the road are emitting more than they
were designed to emit or more than they would be emitting
after a tune-up.  The inspection and maintenance programs
will systematically reduce the emissions from an automobile
population.

Most of the inspection and maintenance programs have two
distinct phases:

  •  An inspection phase, in which motorists are required to
     periodically present their vehicles for examination

  •  A maintenance phase, in which vehicles that fail the
     examination must be tuned up to bring them into
     compliance.

Three classifications cover the major alternative approaches
in an inspection and maintenance program*.

  •  Exhaust emissions inspection
  •  Engine parameter inspection
  •  Mandatory maintenance.

The exhaust emissions inspection will be the only one
discussed because it is the only approach that is being used
at present in those states that have initiated the program.

Exhaust Emissions Inspection. This inspection technique
involves sampling the exhaust gases from the examined
vehicle and passing the samples through suitable analytical
instrumentation to measure the quantities of air polluting
compounds they contain.  If the concentration of each
compound falls below the applicable emissions standards, the
venicle passes the examination.  If the concentration of any
pollutant is above the standard, the vehicle fails.  If a
vehicle fails the test, it must then be adjusted or repaired
to bring the emissions into compliance.  Following the
maintenance, the vehicle would normally be resubmitted for
an emission test to ensure that it is in compliance.

There are two types of vehicle operating modes that can be
used in an emissions inspection test.  In an idle mode test,
emissions from the vehicle are measured using a tail-pipe
concentration while the vehicle is running in neutral.  In a
loaded mode test, the emissions are measured while the
vehicle is running in gear on a treadmill-like device called
a dynamometer.  When operating in this test mode, the
vehicle can be drive in several conditions, such as
acceleration, cruise, deceleration, and idle.  A driving


                           2-277

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cycle composed of a series of different driving modes can
more accurately represent actual driving conditions.  Thus,
emissions measurements taken in a loaded mode test are
usually more representative of actual driving emissions than
the measurements taken in an idle test5.  However, due to
its more sophisticated equipment, the need for larger
testing and facility areas, and a longer testing time per
vehicle, the cost of a loaded mode program is higher than
the cost of an idle mode program for a given vehicle
population.

The choice of which inspection and maintenance program to
implement is a function of several factors, including the
desired emissions reduction, ownership and operation of the
inspection stations (public or private), and the
relationship of the inspection and maintenance program with
existing vehicle safety inspection programs.

In general, it is desirable to incorporate the inspection
and maintenance program with a vehicle safety inspection
program when one exists.  If this approach is taken, the
manner in which the safety program is operated will have an
effect on the type of inspection and maintenance program
that is chosen.  Of the thirty-two states, including the
District of Columbia, which have safety programs, only three
states have publicly owned and operated stations.  Safety
programs in the remaining states are operated through
private garages and service stations.  Loaded mode
inspection and maintenance programs could be incorporated
into a state-owned safety program, but it would be difficult
to incorporate a loaded mode test program into a state-
licensed safety program because of the high cost of the test
equipment.  Therefore, in most cases idle mode tests could
be incorporated with state-licensed stations and loaded mode
tests with state-owned safety inspection stations.  If a
loaded mode test is required in a state with a state-
licensed safety inspection program, it is most likely that a
separate state-operated emission test program would hav« to
be started.

Twenty-four areas are required to have some form of
inspection and maintenance program within the next two years
under the TCP»s which have been approved or promulgated.
There are mandatory safety inspections in 13 of these TCP
areas.  The plans specifically call for 20 idle mode and 7
loaded mode programs.  The number of plans do not add to 2*»
because some AQCR's will include both idle mode and a loaded
mode or privately and publicly owned inspection facilities
as shown in Table 2-7.
                           2-278

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The expected emission reductions from an inspection and
maintenance program are a function of the mode type, the
frequency of the inspection, and the percentage of the
vehicle population that fail the inspection.  In general,
inspection programs will be conducted on an annual cycle.
Reductions in hydrocarbons and carbon monoxide emissions,
but not nitrogen oxide emissions, can be expected.
Table 2-4 provides expected emission reductions for the idle
and loaded mode programs for various failure rates.
                         Table 2-4.
Inspection and Maintenance Emission Reduction Effectiveness

              Hydrocarbon Emission Reductions
    (Percentage of Emissions from All Vehicles Inspected)

                        Failure Rate

              (Percentage of Vehicles Tested)

Mode Type        10       20       30       40       50
  Idle            6        8       10       11       11
  Loaded          8       11       13       14       15


            Carbon Monoxide Emission Reductions
    (Percentage of Emissions from All Vehicles Inspected)

                        Failure Rate

              (Percentage of Vehicles Tested)

Mode Type        10       20       30       40       50
  Idle            3        6        8        9       10
  Loaded          4        7        9       11       12
The failure rate is only a convenient shorthand way of
referring to the stringency of the emission standards.
Actually, the state will adopt specific emission standards
which each vehicle will be required to meet.  When the
emission standards are compared to the distribution of
emissions for the total vehicle population, the percentage
of vehicles that are above the emission standard can be
determined.  The resultant percentage represents those
vehicles that will fail the inspection and is termed the
failure rate.  Thus, the more stringent the standard, the
higher the failure rate.  Since the emissions distribution
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for the vehicle population can change from year to year, the
failure rate would also vary accordingly.

Costs will vary positively with the failure rate.  Vehicles
that fail the test must receive corrective maintenance and
be retested.  Program capacity must therefore be based not
only on the projected failure rate, but also on the rate of
retesting.  Increased vehicle capacity must be met by adding
additional testing facilities and/or increasing the hours of
operation.
RETROFIT CONTROL PROGRAMS

A retrofit approach can be defined as the addition of any
device or system and/or any modification or adjustment on a
motor vehicle after its initial manufacture to achieve a
reduction in emissions6.  Retrofit programs go beyond the
attempt made by inspection and maintenance programs to keep
in-use vehicles at minimum emission levels consistent with
their type and original design.  The only way to reduce the
rate of emissions from vehicles in-use further than the
level attained through inspection and maintenance is to
require retrofits.  The objective of a retrofit program is
to reduce the emission levels of an in-use vehicle below its
•'well-maintained" levels through the addition of a device or
system and/or a modification or adjustment after its initial
manufacture.

Normally, a retrofit program will not be planned unless
additional stationary-source controls, inspection and
maintenance, and some modest VMT reduction measures are also
implemented because retrofit devices alone are not enough to
meet the national air quality standards.  This is
principally because of the high cost of retrofit devices and
the relatively short life-span of their effectiveness, i.e.,
as older vehicles leave the population, so do the retrofit
devices, and the effect of the low emitting new vehicles
becomes more predominant.  All retrofit programs must embody
several important factors to be effective.  These factors
include:

  1. Choosing retrofit system that is most closely matched
     to the particular pollutant problem in the area, since
     different retrofit systems provide different emission
     reductions for the three pollutants;

  2. Assuring that a sufficient number of devices and
     trained installation personnel will be available;
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  3. Incorporating a testing requirement at the time of
     installation; and

  ft. Providing for annual inspection and maintenance of
     retrofitted vehicles to assure proper operation in
     subsequent years.

The two retrofit programs currently under consideration for
wide-spread implementation are:

  •  Vacuum Spark Advance Disconnect (VSAD)

  •  Air Bleed to Intake Manifold

In addition, a high altitude modification to the air bleed
retrofits has been under consideration for Denver and Salt
Lake City.  This modification involves timing and carburetor
changes on the air bleed.  Preliminary test runs in Denver
by EPA showed that the high altitude modification would not
significantly reduce emission levels.  Instead, an air bleed
system with exhaust gas recirculation appears to be more
desirable.

The characteristics of the two main types of retrofit
systems, including a description of the system, its
applicability, the expected emission reductions from its
implementation, and other considerations are discussed
below.

Vacuum Spark Advance Disconnect (VSAD). Two basic engine
modifications employed by motor vehicle manufacturers in
meeting Federal exhaust emission standards have been the
leaning of air/fuel ratios and the modification of
ignition(spark) timing.  The modification of these
parameters in precontrolled (pre-1968)  vehicles will reduce
carbon monoxide emissions by 9 percent, hydrocarbon
emissions by 25 percent, and nitrogen oxide emissions by 23
percent, resulting in a fuel penalty of up to 2 percent*.
Durability data developed by General Motors over 25,000
miles without maintenance show no deterioration in the
reduction of hydrocarbons and nitrogen oxides over time, but
do show approximately a 20 percent deterioration for carbon
monoxide.   Because the 1968 model and newer vehicles have
utilized these modifications to some extent to meet Federal
emission standards, this retrofit technique is considered to
be applicable primarily to precontrolled vehicles, but not
to approximately 10 percent of those precontrolled vehicles
which do not employ vacuum spark advance.

Air Bleed to Intake Manifold.  Many devices have been
designed to introduce excess air in the fuel mixture prior


                           2-281

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to combustion by one means or another.  The effect reduces
hydrocarbon and carbon monoxide with possibly some small
increase in nitrogen oxide emissions.  The reductions
achieved vary directly with the amount of air allowed into
the intake system.  This technique is applicable to some
extent to all light-duty vehicles through the 1971 model
year, but because of the relatively lean air/fuel ratios on
most controlled vehicles, the technique is primarily
applicable to precontrolled vehicles  (pre-1968).

Tests conducted on this system for EPA indicate an expected
reduction of 23 percent for hydrocarbons and 50 percent for
carbon monoxide emissions with a fuel benefit up to 4
percent7.  No significant effect on nitrogen oxide emissions
has been observed.  Durability data on the system are not
adequate for judging the performance of this control
technique over an extended time frame.
SERVICE STATION VAPOR CONTROLS

Although the hydrocarbon vapors emitted to the atmosphere
from service stations cannot be considered in-use vehicle
exhaust emissions, the relationship between these vapor
losses and vehicle use is so directly related that their
control can legitimately be thought of as a transportation
control.

Gasoline is a volatile liquid that tends to evaporate at
ordinary ambient temperatures.  The vapors thus created
become a significant source of hydrocarbon emissions and,
consequently, of photochemical oxidants.  In some
metropolitan areas these vapors contribute as much as 15
percent of the total hydrocarbon emissions8.  Gasoline may
evaporate at any of the points at which it is stored or
handled and enter the atmosphere either through "breathing"
from vents in the storage tanks (at the bulk terminal, in
tanker trucks, at the service station, or in the automobile
tank) or during the process of transferring from or
refilling of each of these tanks.

The California Air Resources Board estimates that 23 pounds
of hydrocarbons are emitted for each thousand gallons of
motor fuel sold at stations in an uncontrolled situation; 11
pounds from transferring fuel from transport to station
storage; 11 pounds in moving fuel from storage to a car
tank; and 1 pound in "breathing" losses from underground
storage.  A study by the Standard Oil of California reports
similar results9.  The average service station sells
approximately 25,000 gallons of gasoline per month which
results in hydrocarbon emissions of 575 pounds per month.
                           2-282

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EPA estimates such emissions to be around 400 pounds per
station per month*,*«,»*.  By 1975, uncontrolled vapor
losses of this magnitude will make the service station as
significant a source of hydrocarbon emissions as some of the
vehicles it serves.  When translated into grams per mile,
the hydrocarbon emissions from service stations exceed the
1977 new car hydrocarbon standards2.

Vapor Control Stages and Techniques. Service station vapor
losses result primarily from tank truck unloading (Stage I)
and vehicle fueling (Stage II).  The basic measures to
reduce either the evaporation or subsequent emission of
vapors to the atmosphere in Stage I include the following:

  1. Floating roofs on large storage tanks.  These devices
     reduce the airspace above the liquid where evaporation
     may occur.

  2. Submerged filling of tanks.  This allows new gasoline
     to flow into the liquid already in the tank,
     eliminating splashing which would otherwise increase
     the amount of vapor.

  3. Restrictions on vent pipes on the stationary storage
     tanks.  This technique limits the amount of "breathing"
     which occurs through the vents.

  *». Use of vapor return lines.  This method allows vapors
     in the tank being filled to be transferred back into
     the tank from which the gasoline is being taken.

  5. Secondary recovery systems.  Carbon absorption or
     refrigeration-condensation systems are used to
     neutralize or reprocess the vapors that otherwise might
     be emitted.

Of these control techniques, submerged tank fill is required
for any new station storage container  (in most regions) with
a capacity greater than 250 gallons, and any existing
container over 2,000 gallons.  In addition, displaced vapors
must be either transferred back to the delivery vessel
through a vapor-tight return line, or they must be processed
on the location by a refrigeration-condensation system or
other appropriate system designed to recover or eliminate at
least 90 percent (by weight) of the organic compounds in the
displaced vapors.  If the vapors are transferred to the
delivery vessel, such as a tanker truck, the tanker must be
refilled at facilities equipped with processing systems
(such as refrigeration-condensation, carbon absorption,
etc.)   which can recover at least 90 percent of the organic
compounds in the vapors.
                           2-283

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On February 8, 1974, sources were required to submit control
plans to EPA for Stage I vapor recovery by June 1, 1974»2.
EPA has been unable to approve many control plans submitted
because sources failed to include sufficient information or
technical justification.  Guidelines for Stage I vapor
recovery are being prepared by EPA and will be made
available to sources in the very near future.  Therefore,
EPA postponed the date for sources to enter and sign
contracts for control systems and the date for sources to
initiate on-site construction or installation of control
equipment.

Stage II controls (recovery of vapors displaced during
refueling of automobiles) could theoretically make use of
any of the Stage I control techniques described above.
However, submerged fill, collapsible bladders (the small
scale equivalent of a floating roof), and carbon canisters
to absorb all vapors during fueling would require redesign
of present automobiles and are not being considered by EPA
for Stage II controls.  Restrictions on vent pipes  (often
including small carbon canisters on the vehicles) were
introduced to comply with the Federal Motor Vehicle Control
Program in the 1970 model year, although pre-1970 vehicles
have vent pipes open to the atmosphere.  The remaining
control technique is the collection of vapors displaced
during fueling, and the subsequent processing of the vapors
through a vapor return line to the service station storage
tank.

Essentially two techniques have been developed for the
collection of vapors displaced from automobile tanks through
vapor return lines: simple displacement or "balance" and
vacuum-assist.  After the vapors are collected, they can be
recovered or reprocessed either at the service station or at
the bulk terminal.  Thus, recovery systems, such as carbon
absorption, refrigeration-condensation, or incineration, can
be installed either at the service station or at the bulk
terminal.  A substantial controversy has recently arisen
over the effectiveness of simple displacement systems and
the reliability of vacuum-assist systems.  Comment period on
the regulations was reopened, and EPA has postponed the
requirement for submiss ion of control plans from June 1,
1974, to December 1, 1976, with the final compliance to be
achieved no later than May 31, 1977.
                           2-284

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Measures that Reduce Total
Vehicle Miles Travelled

THE NEED FOR VMT REDUCTIONS

In the previous section, three measures to reduce emissions
per vehicle mile (in-use controls) were described.  In this
section, a brief description of measures which reduce VMT is
presented.

The potential air quality benefits of in-use vehicle
controls is shown in Table 2-5.  The table shows that if in-
use vehicle and stationary-source controls are fully
implemented by 1977, at least eight regions in 1980 and five
regions in 1985 are expected to fail to comply with oxidant
and/or carbon monoxide standards.  Therefore, if further
control of motor vehicle emissions is necessary, reductions
in automobile use are required to comply with the air
quality standards.
                         Table 2-5.
   Number of AQCR's Failing to Comply with Oxidant and/or
        Carbon Monoxide Standard in Indicated Year1
Conditions

Without In-use
  Vehicle Controlsa

With In-use
  Vehicle Controls'
                                   Calendar Year
1977        1980        1985
21-24       12-U       9-10
12-17        8-10       5-10
1 Ranges reflect uncertainty in degree of stationary-source
  control that will be achieved.  Air quality projections
  are based on linear rollback for carbon monoxide and
  Reference 13 for oxidant.  Analysis excludes New York,
  Denver, and Fairbanks.

z Control strategy consists of stationary-source controls
  and Federal Motor Vehicle Emission Control Plan  (FMVECP).

3 Control strategy consists of stationary-source controls,
  FMVECP, inspection and maintenance, retrofit (including
  catalyst retrofit) , and vapor controls.

Source:  Reference 2.
                           2-285

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In any particular AQCR, the adequacy of transportation
emission control strategies for achieving the national
ambient air quality standards will depend on the severity of
the air pollution problem within the region, the relative
contribution of mobile and stationary emission sources, and
the relative growth rates of these sources.

Thus, the extent of automobile use reductions will vary
substantially among the AQCR's in which they are needed.
Table 2-6 displays the distribution of automobile use
reductions  (measured as vehicle miles of travel) necessary
to achieve nationwide compliance with the ambient air
quality standards in 1977 and 1985; the projected VMT
reductions needed in 1985 and beyond are highly uncertain.
This is due to their extreme sensitivity to a number of
parameters used in the projection calculation; namely, the
relative contributions of different emission sources, the
growth rates of these sources, and the extent of stationary-
source control achievable.  Accordingly, a broad range of
the number of cities in each of two categories is shown; one
category shows the number of cities needing between zero and
25 percent VMT reductions, the other shows the number of
cities requiring VMT reductions greater than 25 percent.
The actual reductions needed by the cities in this latter
category will depend primarily upon the degree of
stationary-source control that can be achieved in 1985.
                           2-286

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                         Table 2-6.
  Number of AQCR's Requiring Automobile Use Reduction to
           Achieve Compliance with Oxidant and/or
                 Carbon Monoxide Standards1
                  Automobile Use Reduction
Calendar
Year

1977

19852
Less than 10%

      8

   0-25*
   6-8
10%-30%
30%-50%  50% or more
25% or more
   a-6
» The VMT reductions estimated for each AQCR are based on
  the additional control of motor vehicle emissions
  required, assuming the regional I/M and retrofit programs
  for in-use vehicles are fully implemented by 1977.   Air
  quality projections are based on linear rollback for
  carbon monoxide and Reference 13 for oxidant.  The number
  of AQCR's whose current transportation control plans
  include auto use reductions exceeds the number used here
  because some plans have substituted VMT reduction for
  retrofit.  Auto use reductions are expressed as perce it
  reductions in VMT.

2 Ranges reflect uncertainty in the degree of stationary-
  source control that will be achieved and the future growth
  in automobile use.

Source:  Reference 2.
The automobile use projections, upon which the analyses
presented in Table 2-6 are based, reflect trends as of 1973.
Thus, nationwide automobile use  (VMT) is projected to be
about 55 percent greater in 1985 than in 1972.  This
projection assumes an increasing number of vehicles per
person and an increasing annual mileage per vehicle.  If the
recent downward trend in automobile sales per person
continues for a number of years so that the number of
vehicles per person and the annual mileage per vehicle
remains constant through 1985, automobile use would be only
about 18 percent above current levels.  This represents a
VMT reduction of 25 percent from the projected baseline
assumed for Table 2-6 which reduces significantly the number
of AQCR's requiring VMT reductions to achieve compliance
with the standards.
                           2-287

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STRATEGIES TO REDUCE VMT

There are generally two strategies to achieve VMT
reductions:

  •  Improvements in transit systems to encourage automobile
     drivers to reduce trips.

  •  Incentives to increase the number of passengers per
     automobile.

Transit Improvements. To attract significant numbers of
automobile drivers out of their cars, a transit system must
at least satisfy three conditions:

  •  It must have enough vehicles to carry the new riders.

  •  It must provide service whose quality is comparable or
     superior to that of the automobile.  The most important
     component of service quality is travel time.

  •  Its cost to the rider must be attractive relative to
     the cost of operating an automobile.

An example of the relationship between travel time, cost,
and transit ridership for work trips is illustrated in
Figure 2-1, which is based upon the results of a study of
travel behavior in Pittsburgh, Pennsylvania**.  The
variables included in the figure are the time required to
walk to and from the transit stop, the difference between
automobile and transit travel times, the difference between
automobile and transit costs, and the percentage of work
trips taking place by transit.  The importance of the time
and cost variables in determining transit ridership can be
illustrated by considering the case where transit and
automobile travel times and costs are equal  (Point A of
Figure 2-1).  The figures indicate that 66 percent of work
trips would take place by transit.  In constrast, average
work-trip transit ridership in the United States is
currently less than 15 percent.
                           2-288

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                            Figure 2-1.
Dependence  of Work-Trip  Transit Ridership  on Service Quality
     160
                                                              WALK TIME =5 WIN.
                                                              WALK TIME =10 WIN.
     -10
 LEGEND:
                                                             WALK TIME =0





                                                             WALK TIME =5 WIN.

                                                             WALK TIME =10 WIN
        O        5       10       15

   TRANSIT TIME -AUTOMOBILE (MINUTES)



AUTO COST = TRANSIT FARE

AUTO COST = TRANS IT FARE +$2.00
                                                          20
                             2-289

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In practice, it is unlikely that a transit system can offer
widespread service which is as fast as that of the
automobile.  A more realistic example of a high-quality
transit system is illustrated by Point B of Figure 2-1.
Here, the walk time is five minutes, transit travel time
exceeds automobile travel time by 10 minutes, and the
transit fare and automobile cost are equal; transit
ridership is 21 percent.  If the walk and travel times
remain unchanged and the automobile costs $2.00 per work
trip more than transit owing to free transit, parking
charges, or other reasons, transit ridership for work trips
increases to about 90 percent (Point c).

The reductions in the combined emissions of automobiles and
transit vehicles thus achieved depend on the kinds of
transit vehicles used, and the design and operation of the
transit system.  For example, if diesel buses meeting the
California 1975 heavy-duty diesel emission standards are
used and these buses carry an average load of 20 passengers,
the reductions in combined bus and automobile emissions are
roughly 30 percent for carbon monoxide and hydrocarbons and
15 percent for nitrogen oxides in 1977.  In 1985, when
automobile emissions will be less than in 1977, the carbon
monoxide and hydrocarbon reductions are 20 percent and 25
percent, respectively.  However, nitrogen oxide emissions
increase by about 20 percent; this increase would be
eliminated if an average bus occupancy of 30 passengers were
achieved.

These quantitative results are approximate because of their
reliance on a single behavioral study and rather crude
measures of trip characteristics.  However, the conclusion
that a high-quality transit system can attract high levels
of ridership is also supported by the experience of existing
high-quality transit operations, such as the Shirley Highway
Express in the Washington, D.C.  area15.

Most transit systems in the United States do not provide the
high-quality service needed to attract high ridership.  For
example, nearly 50 percent of urban area residences are
located three or more blocks from the nearest transit stop.
Transit routes are heavily downtown-oriented, but only about
10 percent of the trips go downtown.  Transit trips take
nearly twice as long as automobile trips.  Moreover,
subsidized free or reduced rate parking confers a cost
advantage on the automobile.  Transit service of this
quality is illustrated by Point D of Figure 2-1, indicating
a ridership of 4 percent.

Carpools. Average automobile occupancy in the United States
is about two persons per car.  Average occupancy for work
                           2-290

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trips is about 1.4 persons per car16.  Since most cars are
capable of carrying at least four persons, there is
considerable room for reducing automobile use and emissions
through carpooling.  The principal obstacle to carpooling is
that carpools are highly restrictive in terms of the service
offered.  Carpoolers must have trip origins and destinations
that are close to one another, must travel at the same time,
and, to minimize the problems of locating carpool partners,
must make trips that are repetitive from day-to-day.  As a
result, the greatest potential for increased carpool use is
in connection with peak-period work trips.  These trips are
responsible for about 25 percent of urban area automobile
emissions*f.

The present automobile low occupancy rates for work trips
indicate that substantial carpooling will not take place
unless certain measures are implemented to encourage it.
The limited experience to date with carpool programs has
provided indications of the effectiveness of two possible
approaches to encouraging carpools:

  •  Preferential treatment for carpools on streets and
     freeways.

  •  Parking restrictions combined with locator systems.

Preferential treatment for carpools has been observed to
increase peak-period automobile occupancies by 10 to 30
percent*».  Locator systems combined with parking
restrictions appear capable of doubling occupancies for
downtown peak-period work trips to suburban locations19.  If
these preliminary indications are confirmed by future
experience, programs to encourage carpooling should be
capable of reducing total urban area automobile emissions by
5 to 10 percent.

Carpooling and transit systems appear to be competitive, not
complementary, approaches to reducing automobile use.  Both
approaches operate most easily in connection with peak-
period work trips to high density areas, and transit system
improvements tend to attract passengers from their carpools.
It is therefore unlikely that the effects of high-quality
transit systems and carpooling on automobile use will be
additive.  For example, if transit system improvements alone
can achieve a 15 percent reduction in automobile use and
carpooling alone can achieve a 10 percent reduction, the
automobile use reduction obtained from implementing both
approaches together is likely to be greater than 15 percent
but less than 25 percent.
                           2-291

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TRANSPORTATION CONTROL MEASURES
TO REDUCE VMT

In this section, specific VMT reduction measures considered
by the states, localities, and EPA in developing TCP»s will
be briefly explained.

Bus and Carpool Priority Treatment. Priority treatment for
buses and carpools consists of allocating highway facilities
preferentially to these vehicles for the purpose of
increasing their average speeds.  The usefulness of bus
priority treatment in attracting automobile drivers to use
the transit is dependent on the quality of the transit
system or subsystem that uses priority treatment.  Hence, in
areas where bus priority treatment is included in a TCP, the
measure is a part of an integrated transit improvement
program.  For example, in the Washington, D.C. area,
priority treatment is used in combination with bus fleet
expansion, the addition of new transit routes, and improved
bus scheduling.

  Carpooling Programs. Many TCP's include measures that
provide computerized carpool matching programs and
preferential carpool treatment programs.  The matching
programs provide for the formation of carpools, and the
preferential treatment programs provide incentives, such as
free parking, to encourage carpools.

Computerized carpool locator programs have been established
in cities such as Washington, B.C., Boston, Massachusetts,
Knoxville, Tennesse, and Omaha, Nebraska.

Employer Transit Incentive Regulations. Employer incentive
regulations applicable in several metropolitan areas require
major employers to implement measures that encourage the use
of carpools and mass transit, while at the same time
discouraging the use of single-passenger automobiles for
work-related commuting.  Under this approach, the employer
has the flexibility to develop his own plan to minimize the
impact of his facility on the area1s VMT.  The concept is
based on already existing programs that have been developed
by employers to discourage energy-inefficient commuting
habits.  In addition, many employers have voluntarily
started such programs to avoid the acquisition of land for
additional parking facilities.  Companies, such as Minnesota
Mining and Manufacturing and Aerospace Corporation of El
Segundo, California, have already illustrated the
effectiveness of this approach in reducing commuter
automobile usage.
                           2-292

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Parking Programs. Parking management programs are used in
several TCP's to complement the improvement of mass
transportation and carpooling alternatives.  The
transportation plans include two general types of parking
regulations:  on-street parking controls and parking
management programs.  The on-street parking controls are
similar to common regulations in various cities to prevent
congestion and to discourage commuter parking on public
streets.

The States are encouraged to develop their own area-wide
parking facility plans.  These plans should focus on the
interrelationship of transportation alternatives and new
parking facilities.  The plans should set forth the manner
in which the location, operation, and increase in the number
of parking-related facilities would be kept consistent with
the air quality needs throughout the area.  The plans could
also ensure that the new facilities complemented rather than
competed with existing and developing transit facilities.
Several areas, such as San Diego, Los Angeles, Portland, and
Seattle, have begun such plans for parking restrictions as a
traffic control approach.

Transit Expansion and Development. The improvement and
expansion of mass transit facilities is one of the key
elements for the success of transportation plans.  Bus fleet
expansion will allow service to be upgraded in several major
respects:

  •  Existing routes can offer more frequent service.

  •  New routes can be established to allow more people the
     opportunity of transit.

  •  Older, uncomfortable vehicles can be replaced with
     smoother riding, air-conditioned vehicles.

Within the last two years, many areas have established
programs to improve and upgrade existing transit systems,
Therefore, in the near future many areas will begin to offer
the type of alternative transit that is required to help
achieve the required VMT reductions.  An example of the type
of improvement which can effect a reduction in VMT is the
Seattle "Magic carpet" program.  City-wide fare reductions
along with free fares within the CBD were associated with a
fleet expansion and exclusive bus lanes.  The increased
ridership will help Seattle achieve the VMT reductions
necessary to meet the National Ambient Air Quality
Standards.
                           2-293

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Sufficient Federal funding is necessary if areas are to
expand transit systems to the level necessary to provide
assistance in achieving the VMT reduction goals contained in
the plans.  EPA has been working with DOT to assure the
availability of such funding.  In addition, states and
localities must be willing to increase their support for
mass transit.  Ideas such as using sales tax revenues for
capital and operating expenses and therefore stabilizing
fares have been successfully implemented in Atlanta,
Georgia.  Other areas must continue to provide the necessary
local commitment if expanded mass transit is to become a
reality.

Parking Surcharge and Parking Fees. The use of surcharges on
commercial rates for parking both discourages non-carpool
commuting and provides a source of financing for transit
improvements.  The measure can help bring about a
significant change in urban driving habits with a minimum of
social disruption if the fees are properly formulated and
integrated with transit improvements.  The program offers a
wide latitude of individual choice to the driver.  Those
whose needs or preferences are strongly in favor of using
the single passenger automobile may continue to do so,
although at a somewhat higher cost; those who can easily
adapt to other modes of transit or a carpool will have the
incentive to take such action.  The Energy Supply and
Environmental Control Coordination Act of June 1974  (P.L.
93-319) forbids the EPA from promulgating surcharges.

Gasoline Supply Limitations. Gasoline supply limitations
are, at least in theory, one of the most effective methods
of reducing VMT.  At the time the TCP's were first proposed,
gasoline supply limitations were considered to be included
in several plans.  Two types of regulations were proposed:

  1. A gasoline supply lid would have become effective
     during 1974 or 1975, which would have limited the
     quantity of gasoline sold in an area to fiscal  1973
     levels.

  2. A regulation, which would be implemented on May 31,
     1977, would reduce an area's gasoline supply and thus
     VMT to the extent necessary to achieve the ambient air
     quality standards.

The gasoline supply lid was dropped as a primary control
measure by EPA at the time the plans were finally
promulgated.  The determination not to include gasoline
supply lids as a "reasonably attainable" alternative was
based upon the comments received during the public hearings
held on each plan and the Agency's evaluation of the
                           2-294

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feasibility of implementing and administering an effective
program.  Moreover, possibilities of evasion, the likelihood
of noncompliance, and the difficulty of enforcement appeared
too great to make this measure praticable.

However, the gasoline supply reduction to be implemented on
May 31, 1977, has been retained in plans for several areas.
In these areas, this measure was included as a final resort
measure to fulfill the statutory requirement that a plan
must achieve the ambient air quality standards by 1977.  in
each of these areas, even with additional stationary-source
controls, inspection and maintenance programs, reasonable
VMT control measures, and retrofit strategies, additional
VMT reductions were necessary to demonstrate attainment of
the standards.  As the EPA Administrator has stated on
several occasions, this measure has been included in these
plans to meet the technical requirements of the law, and the
EPA does not intend to implement this measure unless it is
leagally required to do so.  EPA has submitted a proposed
amendment to the Clean Air Act which would allow additional
flexibility in these heavily impacted areas.
ADDITIONAL VMT REDUCTION MEASURES

several other measures were considered and accepted or
rejected for use in TCP's.  Measures used by the states or
EPA to a limited extent include bicycle lane programs,
vehicle-free zones, selective vehicle exclusion strategies,
and gasoline truck delivery bans,  of these, the first two
measures are being implemented on a limited basis, such as
the bicycle lane program now underway in Denver, Colorado,
and the vehicle-free zones in Springfield, Massachusetts,
the Camden-Trenton area of New Jersey, and Salt Lake city,
Utah.  The last two measures {selective vehicle exclusion
and gasoline truck delivery bans) were considered for
implementation but were rejected.


Costs of Transportation
Control Plans

This section estimates the aggregate costs to the motor
vehicle owners of implementing TCP's.  In order to estimate
aggregate costs for the period 1976-85, costs of
implementing various transportation control measures at each
AQCR have been computed.  Table 2-7 presents the list of
AQCR»s which will implement specific measures that will
reduce emissions per VMT; the table also describes the
geographic and model year coverage of each measure.
                           2-295

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                              Table  2-7.
     List  of  AQCR's  Which Will Implement  Measures to
        Reduce Emissions  Per Vehicle Mile  of Travel
AQCR
Boston
Springfield

NY-NJ-Conn.


Philadelphia




Southwest
Penn.
Baltimore
Natl. Capitol




Chicago


Indianapolis

Cincinnati

San Antonio

Houston -
Galveston
Denver
Phoenix -
Tucson


Wasatch
Front


Los Angeles
San
Francisco
San Diego
I/M
Test
Type
Idle
Idle

Idle

Loaded
Idle


Idle

Idle

Idle
Idle

Idle


Idle


Idle

bile
-„
Idle


Idle
Idle

Loaded



Idle


Loaded

Loaded
Loaded
Ownership
Private
Public

Public

Public
Private


Public

Private

Private
Public

Private


Public


Private

Public

Private


Private
Public

Public



Public


Public

Public
Public
Area
Covered
AQCR
Springfield
SMSA
N. J. part
of AQCR
N. Y. SMSA
Penn. part
of AQCR

N.J. part
of AQCR
AQCR

AQCR
Va. part of
AQCR
D. C. & MD
part of
AQCR
Cook Cty.
inc.
Chicago
Marion Co.

Hamilton
County
Note 1


AQCR
AQCR

AQCR



Note 2


AQCR

AQCR
AQCR
Retrofit
VSAD
Vehicle
Year
Pre-68












Pre-68
Pre-68







Pre-68






Pre-68









1955-65

1955-65
1955-65
Area
Covered
AQCR












AQCR
AQCR














AQCR









AQCR

AQCR
AQCR
Air Bleed
Vehicle
Year
1968-71


Pre-71


Pre-68


Pre-71



1968-71








Marion
Co.






Pre-68

Pre-68



Pre-68






Area
Covered
AQCR


N. J. part of
AQCR

Penn. part
of Phila.
SMSA
N. J. part of
AQCR


AQCR










.





AQCR

Phoenix &
Tucson
SMSA's

AQCR
excluding
Tooele Co.




-ssvc
Stages
I &n


i&n





I &II

I

i&n
i &n







i



i&n


i&n
i&n








i&n

i&n
i&n
Area
Covered
AQCR


N. J. part of
AQCR




N. J. part of
AQCR
Allegheny
County
AQCR
AQCR







Marion
County


San Antonio
County

AQCR
AQCR








AQCR

AQCR
AQCR
NOTES: 1 San Antonio SMSA and Kendall, Medina, Wilson, Atascosa, Comal Counties.
       2 Ogden, Salt Lake City, Provo- Orem SMSA's.
       3 Boston and Houston - Galveston AQCR's have recently cancelled retrofit programs. Also, the
         EPA is presently considering the promulgation of I/M measures for Dallas-Fort Worth.

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             Table 2-7. (Continued)
List of AQCR's Which Will Implement Measures to
  Reduce Emissions Per Vehicle Mile of Travel
AQCR
Sacramento
San Joaquin
Puget
Portland

East Wash-
ington,
Idaho

Northern
Alaska




Austin-
Waco
Dallas - Ft.
Worth
El Paso




I/M
Test
Type
Loaded
Loaded
Idle
Idle



Idle


Idle













Ownership
Public
Public
Private
Public



Private


Public










0


Area
Covered
AQCR
AQCR
AQCR
Portland
SMSA


Spokane
SMSA

City of
Fairbanks
& North
Star
Borough









Retrofit
VSAD
Vehicle
Year
1955-65
1955-65






















Area
Covered
AQCR
AQCR






















Air Bleed
Vehicle
Year


Pre-68
Pre-68



Pre-68


Pre-68













Area
Covered


AQCR
Oregon part
of AQCR


Spokane
SMSA

AQCR













-SSVC
Stages
i&n
i &n














i

i &n
i &n




Area
Covered
AQCR
AQCR









„




AQCR

AQCR
El Paso
SMSA &
Texas
Counties
of AQCH
                     2-297

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INSPECTION AND MAINTENANCE PROGRAMS

Analysis of the inspection and maintenance program costs has
been limited to the programs operating in Chicago and New
Jersey.  In both instances, the programs make use of idle
mode tests, and the inspection stations are state owned and
operated.  Reference 11 presents a description of these
inspection programs as well as estimated fixed and operating
costs for a publicly owned and operated emissions inspection
program.  A brief description of the assumptions used in
estimating costs of inspection and maintenance programs
follows.  Cost elements have been computed by the EPA Office
of Land use and Transportation Policy, based on data
provided by Northrop/Olsen Corporation", The City of
Chicago24, and the State of Arizona22.  It is assumed that
the inspection facilities would be either publicly or
privately owned and operated with the needed maintenance of
rejected automobiles performed at privately owned garages or
repair facilities.  The number of inspection lanes required
is computed from the projected light-duty vehicle population
for that area for the year of program implementation and the
following standard lane capacities:

  •  Idle Mode - 32,000 vehicles per lane per year

  •  Loaded Mode - 25,000 vehicles per lane per year.

These capacities assume an 8-hour working day for 250 days
per year with an average of 10 percent idle time.  Since
vehicles are not expected to arrive at inspection stations
at a uniform rate, some idle time is inevitable.  However,
the extent of this idle time largely depends on the
inspection schedule and other measures in an area that would
affect the distribution of vehicle arrivals.  The success of
each area in achieving greater uniformity in arrival rates
cannot be estimated at this time; therefore, HO percent idle
facility time has been assumed.  It should be recognized
that as areas become experienced in administering inspection
and maintenance programs, the idle facility time is expected
to be significantly lower than 40 percent.  In this sense,
the cost estimates appear to be overstated for the later
years of the 10-year period.  The number of stations
required was computed assuming that all stations have two
lanes.

The total annual cost of an inspection station is assumed to
range from $106,077 to $130,97*, depending on the following
factors:

  •  Ownership (private versus public)
                           2-298

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  •  Test type (loaded versus idle)

  •  Geographic location which determines the total site
     cost.

Table 2-9 presents the summary of costs assumed per two-lane
station.  Reference 11 gives the detailed breakdown of the
cost estimate.  The second cost area in the program is the
maintenance of failed vehicles.  An average tune-up cost of
$30 per failed vehicle, of which $15 is assumed to be
attributable to the inspection and maintenance measure, is
considered.  Vehicles that fail the emissions inspection and
subsequently are tuned are expected to incur fuel savings.
The extent of annual fuel savings from the program is
dependent on the failure rate among other things.  EPA*s
Office of Transportation and Land Use Policy estimates that
on the basis of recent data the following relationship
exists between the failure rate and annual fuel savings for
serviced vehicles: Y = 31.5X~°.51*, where X=percent failure
rate and Y=annual fuel savings, expressed in percents, for
serviced vehicles.  Fleet-wide dollar savings are computed
for each AQCR by computing the fuel saving rate from the
above equation and assuming an annual vehicle use of 10,000
miles, a fuel consumption rate of 13.58 miles per gallon,
and a price of gasoline of $0.75 per gallon.

Based on the inspection cost estimates given in Table 2-8
and the maintenance cost and fuel savings assumptions
outlined above, the annual inspection and maintenance fixed
and operating costs for each AQCR have been computed for the
years 1976-85.  The summary annual costs for the United
States are presented in Table 2-9.  As shown in the table,
the fuel savings more than offset the costs of the
inspection and maintenance program, and in fact, result in
an overall net benefit, even after considering all TCP
costs.
                           2-299

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                                 Table  2-8.
  Fixed and Operating Cost  of  a  Two-Lane Inspection Station
Cost Category

Capital  Costs
  Equipment
  -  Instrumentation
     Automated System
     Dynamometer
  Installation Costs
  Site costs
  Construction Costs
Administration and Miscellaneous
  Contingencies

Total Capital Costs

Annual Costs:
  Annual Capital  Costs
  Operating Costs
  -  Salaries
     Supplies
  -  Administrative Support  and Overhead

Total Annual Costs
                                                         Public
     Loaded
  ( In 1975  Dollars)

                         Private
     Idle                 Idle
    $11 .870
     14.850
      6.400
      5,000
  14.000-140.000
     35,000
      3,000
   4.500-10.800

 $94.620-226,920


 $17.054-30.974

     64,000
      2.940
     33,060

$117.064-130,974
     $11.870              $11,870
      14.850                    0
           0                    0
       3.000                6,000
  14.000-140,000                0
      35.000                    0
       3.000                3,000
   4,090-7,000              1,040

 $85,810-214.720           21.910


 $15.630-28,907            $8,077

      64.000               64,000
       2.940                2,940
      33.060               33,0.60

$115,630-128.907         $106,077
  Administrative and miscellaneous costs are assumed to be $3,000 per station  for  the.first year-

  Unforeseen contingency costs  are calculated as 5 percent of the total  cost for equipment, instal-
  lation, land, construction, and administration.

  14.000 Square feet at $1.00 to $10.00 per square foot.

  2.500 Square feet at $14.00 per square foot.  For private stations i.t  is assumed that present
  facilities will be adequate to house the small amount of equipment needed for inspection.

  Assuming an economic life of  40 years for land and 10 years for other  capital  costs at  10
  percent annual interest and with zero scrap value.  The administrative and miscellaneous costs
  which are incurred for the first year only are assumed to be non-depreciable.

  One supervisor at $16.000 and 5  inspectors at $9.600. each per year.
                                   2-300

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                                   Table 2-9.
     Aggregate Cost (Benefit)  of Inspection  and Maintenance Programs,  1976-85
Year

1976
1977
1973
1979
1980
1961
1982
1983
1984
1935

Totals
Capi ta1
Investment
(1)
141.9
3.4
3.3
3.7
3.8
2.6
3.2
3.0
3.4
3.0
171.3
Annual i zed
Capi tal
Costs (2)
13.4
13.3
19.2
19.7
20.2
20.6
21 .0
21.4
21 .3
22.2
203.3 1

Stat ii
Costs
104.4
103.8
106.4
109.1
111.9
114.0
116.4
118.6
121. 1
123.4
.129.1
        (In Millions of  1975 Dollars)

        Operating & Maintenance (0/M)
                Costs

           Owners'
Station 0/M Maintenance Savings
           Cost (4)

           186.0
           190.8
           195.5
        -  - 200.3
           205.2
           209.6
           214.2
           218.7
           223.4
           22S.1
Fuel
Savi ngs
(5)
385.9
395.7
405.5
415.5
425.6
434.7
444.0
453.3
462.9
472.5
Net 0/M
(6)
(3+4-5)
(95.5)
(101.1)
(103.6)
(106.1 )
(108.5)
(111.1)
(113.4)
(116.0)
(118.4)
(121.0)
Annual
Costs (7)
(2+6)
(77.1)
(82.3)
(84.4)
(86.4)
(88.3)
(90.5)
(92.4)
(94.6)
(96.6)
(98.8)

Cumulative
(8)
(77.1)
(159.4)
(243.8)
(330.2)
(418.5)
(509.0)
(601 .4)
(696.0)
(792.6)
(891.4)
         2,071.8
                                                      4.295.6
(1 ,094.7)
(891.4)
                                    2-301

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RETROFIT PROGRAMS

Vacuum Spark Advance Disconnect (VSAD). VSAD retrofits are
mainly applicable to pre-1967 vehicles as shown in
Table 2-7.  It is assumed that the installation cost of a
VSAD retrofit would be approximately $20.00 per vehicle, and
it is estimated that the annual maintenance cost would be
approximately $5.00 per vehicle.  VSAD retrofits are
expected to increase fuel use from 0 to 2 percent, which
translates to a maximum annual fuel penalty of $11.25 per
vehicle, assuming a fuel consumption rate of 750 gallons at
$0.75 per gallon.

Air Bleed. The 11 AQCR's that will be implementing air-bleed
retrofit programs are listed in Table 2-7.  Air bleed
devices are primarily applicable to pre-1968 vehicles
although some areas, such as Baltimore and Boston, extend
the applicability to 1971 model year vehicles.  The
installation cost of an air bleed retrofit is assumed to be
$10 per vehicle for simple air bleed devices and $55 per
vehicle for air bleed devices with exhaust gas recirculation
(EGR).  It is further assumed that the life of the devices
is 5 years, necessitating replacement of the equipment after
that period at the same cost.  However, air bleed devices
are expected to increase the fuel economy by approximately 4
percent.  This fuel economy benefit translates to $22.50 per
year per vehicle.  Therefore, the net benefit over the 5
year life of the units would be $72.00 per vehicle with a
simple air bleed device and $57.50 per vehicle with an air
bleed/EGR device.

Summary Costs of Retrofits. The summary aggregate costs of
the retrofit programs for 1976 through 1985 are presented in
Table 2-10.
                            2-302

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                                  Table 2-10.
              summary Costs  of Retrofit Programs,  1976-85
Retrofit Program
1976
        1977
1978
1979
                                              (In Millions of 1975 Dollars)
                1980
                                         1931
1982
                                 1983
1984
1985
VSAD
Cumul at i ve
Air Bleed
Cumulative
Totals
Cumul at i ve
34.5
34.5
34.5
34.5
27.0
61.4
69.2
69.2
96.2
130.7
13.9
75.4
(46.4)
22.8
(32.5)
98.2
10.2
85.6
03.4)
(10.6)
(23.2)
75.0
7.8
93.4
(23.5)
(34.1)
(1S.7)
59.3
6.6
100.0
(16.1)
(50. 2)
(9.5)
49.8
6.3
106.3
12.1
(38.1)
18.4
68.2
6.3
112.6
(8.1)
(46.2)
(1.8)
66.4
6.3
118.9
(7.1)
(53.3)
(0.8)
65.6
6.3
125.2
<6.S)
(59.8)
(0.2)
65.4
  Only California AQCR's Mill  implement VSAD  in 1976.
                                    •f

  Numbers in parentheses indicate negative value. I.e.

  these retrofi ts.
                                 economies gained by  implementation of
                                       2-303

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SERVICE STATION VAPOR CONTROLS

The recent controversy about the Stage II Vapor Control
Systems (simple balance and vacuum-assist) creates
uncertainty as to the type of system which will be
implemented.  The installation cost of a vacuum-assist
system is significantly higher than the simple displacement
system.  Using the simple balance method, costs per station
may run between $2,000  (for a new station) and $5,000  (for
existing stations) for the required equipment labor.
Vacuum-assist equipment costs anywhere from one and a half
to two times as much.  For a 75,000 gallon per month service
station, the University of California, San Diego, estimates
the investment costs at $6,727 and $14,681 for simple
balance and vacuum-assist systems, respectively.23

In estimating the investment and operating cost of service
station vapor control systems, it is assumed that for Stage
II controls, one-third of the systems implemented will be
simple balance and two-thirds will be vacuum-assist.  Based
on EPA*s most recent data, the investment and operating
costs of the systems are assumed to be as follows:
Investment
  Service station component
      (Stage II)
  Support facilities component
      (Stage I)

Total per station

Operating costs per station
  per year
                                      Blower-  Simple
                                      Assist   Displacement
$12,000  $8,000

  1,300   1,300

$13,300  $9,300


$   556  $  556
For Stage I systems, a fuel savings benefit of $594 would
result, assuming 90 percent efficiency in recovering 880
gallons per station at $0-75 per gallon.  For Stage II, the
fuel savings benefit would be $495 for simple balance
systems, assuming 75 percent recovery, and $627 for vacuum-
assist systems, assuming 95 percent recovery.  Table 2-11
presents the summary costs of service station vapor controls
for the 10-year period.
                           2-30U

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                        Table 2-11.
      Aggregate Costs of Service Station Vapor control
                     Programs, 1976-85

         Annual Costs  (In Millions of 1975 Dollars)

Year       Fixed    Operating      Total    Cumulative

1977      $46.4    $(14.2)        $32.2      32.2
1978       46.4     (14.2)         32.2      64.4
1979       46.4     (14.2)         32.2      96.6
1980       46.4     (14.2)         32.2     128.8
1981       46.4     (14.2)         32.2     161.0
1982       46.4     (1^.2)         32.2     193.2
1983       46.4     (14.2)         32.2     225.4
1984       46.4     (14.2)         32.2     257.6
1985       46.4     (14.2)         32.2     289.8
SUMMARY COSTS

Table 2-12 shows the summary costs associated with measures
that will reduce emissions per vehicle mile.  Table 2-13
shows the breakdown between capital costs and operating and
maintenance costs for each control program for the period
from 1976 to 1985.

Approximately 90 percent of the total cost for reducing
emissions per vehicle mile is attributable to the inspection
and maintenance programs.  Several factors account for the
large costs of inspection and maintenance relative to
retrofit and service station vapor controls.  Perhaps the
most significant is the annual operating cost, which is
estimated to be $100,000 per station.  Furthermore, because
of the random vehicle arrivals for inspection, it is assumed
that the stations will be idle 40 percent of the time and
therefore they will not operate at optimum capacity.  This
idle factor obviously offers some potential for economy and
reduction of overall costs; however, the amount of idle time
that could be utilized is indeterminable at this time.

A second factor that contributes to the large cost of
inspection and maintenance programs is that essentially
every vehicle in the control area must submit to the
inspection, and those that fail will require maintenance and
reinspection, whereas retrofit systems usually apply only to
a small portion of the total number of vehicles.  Finally,
retrofit and service station vapor control cost estimates
include some partially compensatory economies, whereas no
                           2-305

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fuel economies are considered for inspection and maintenance
programs.
                           2-306