PB-203 952


GOVERNMENTXL  APPROACHES  TO AUTOMOBILE AIR POLLUTION CONTROL

Donald  Infeld,  et al


Institute of  Public Administration
Washington,  D.  C.


1 August  1971
                                                          Distributed . . ,'to foster, serve and promote the
                                                                      nation's economic development
                                                                      and technological advancement.'
                 NATIONAL TECHNICAL INFORMATION SERVICE
                                                                   U.S. DEPARTMENT OF COMMERCE

-------
ly^ -•'  "'"i,. .-T:-*s"'^ ;•;.,..•;/^f^^r^^l^*?^^^^-5^^

                                 wnicn  is directed co tne definition and analyses  ot
 BIBLIOGRAPHIC DATA
 SHEET
|4. Tide and Subtitle
 Governmental  Approaches  Co Automobile Air Pollution
 Control
7. Author(s)
 Donald  Infeld and  Gregory Wllcox
19. Performing Orgaaizarion Name and AddreSa
 Institute of  Public  Administration
 1619 Massachusetts Avenue,  N.  W.
 Washington,  D.  C.   20036
    >onsoring Organization Same and Address
   -ice  of Trogram  Development
 Office  of Air  Programs
 Environmental  Protection  Agency
 Research Triangle  Park, North  Carolina 27711
                                                                 3. Recipient's Accession No.
                                                                 5. Report Date
                                                                  August  1,  1971
                                                                8. Performing Organization Kept.
                                                                  No.
                                                                 10. Project/Task/Work Unit No.
                                                                 11. Contract/Gram No.

                                                                 EHS  70-126
                                                                 13. Type of Report & Pericj
                                                                   Covered
   Supplementary Notes  DISCLAIMER  - This  repott was  furnished  to the  Office of  Air
   ograms  by  Institute of Public  Administration,  1619 Massachusetts Avenu
N.  W.,  Washington,  D. C. 20036 in fulfillment of  Contract EHS 70-126
                                ;e development of pollution control technology and  low
                                 . the range of policies available to induce the
                           control average emissions per mile are discussed  in Chapter 2.
automotive industries  to en<
pollution fuels.   Corres;
motorist to do his part __	„_	r~* --.»^ -»= u.-^uooou  iu ui«u.
Chapter 3 considers the measures available to reduce the aggregate amount of annual
automobile use.  Chapter 4  details what urban planners can do to reduce auto pollution
emissions in urban areas and facilitate dispersion of existing pollution.  The two
remaining chapters deal with the relations among these focal points.
 7. Key U'ords and Document Analysis.  17o. Descriptors
 National government
 Government  policies
 Exhaust emissions
 Vehicles
 Standards
 Litigation
 Industries
7b. Idemifiets/Open-Ended Terms
Air  pollution control
Mobile  sources
7e. COSATI Field/Group  13B" *
                                                Consumers
                                                Distance
                                                Highways
                                                Streets
                                                Traffic engineering
                                                Urban  planning  -
                                                Highway planning
                                                carbon monoxide
8. Availability Statement  Unlimited
                                                     19. Security Class (This
                                                       Report)
                                                       Page
                                                         L'XCl.AS

-------
                                                                INSTITUTE  OF  PUBLIC  ADMINISTRATION
                                                     C C. FITCH. PHItlDIM
GOVERNMENTAL APPROACHES TO
AUTOMOBILE AIR POLLUTION CONTROL
                                                                                                       August 1, 1971
This report was prepared by
DONALD INFELD AND GREGORY WILCOX
under the overall direction of
ROBERT WITHERSPOON,  IPA Project
Coordinator
August 1, 1971
Submitted to the
Office of Program Development,
Office of Air Programs,
Environmental Protection Agency
Contract Number EHS 70-126
Submitted by the
Institute of Public Administration
1619 Massachusetts Avenue,  N.W.
Washington, D.C.  20036      £

(202) 667-6551
Mr. Paul Gerhardt, Chief Economist
Office of Program Development
Office of Air Programs
Environmental Protection Agency
5600 Fisher's Lane
Rockville, Maryland  20850

Dear Mr. Gerhardt:

       I am pleased to transmit the attached report Governmental
Approaches to Automobile Air Pollution Control by the Institute
of Public Administration.  This report is the companion volume to
Governmental Approaches to Air Pollution Control:  A Draft Com-
dlum and Annotated Bibliography submitted to your office on July
15, 1971.  The subject of automobile air pollution is so important
and the scope of investigation so wide, that it was decided to
compile a separate study rather than attempt to include this
material in the final report.  In addition to bringing together in
one place the full range of governmental approaches for dealing
with automobile air pollution, we have attempted to place these
approaches in an analytic framework which facilitates both the
comparison of existing approaches and the discovery of new policy
possibilities.

       We should like to express our appreciation to those staff
members of the Office of Air Programs and the Bureau of Mobile
Sources who commented on the draft version of this volume in April.
Their suggestions have been incorporated in the appropriate sec-
tions.  In addition,  since events in this field are following upon
one another so rapidly, a section (Appendix C) has been added to
record the most recent developments of significance that have oc-
curred since the initial draft of this report was submitted on
March 1, 1971.
                                        Si
                                               Myers

-------
i   I
                                                                                                                                                 11
                                           TABLE OF CONTENTS
                 INTRODUCTION

                   Purpose

                   Organization


                 CHAPTER 1 — INDUSTRY CONTROL OF AVERAGE EMISSIONS PER MILE

                   Encouraging Control Technology
                      Pre-1968 Automobiles
                      New Internal  Combustion Engine Automobiles
                      Standards for New Vehicles
                         Standard setting
                         Rationale  for standards
                      Advantages of Standards
                      Problems with Standards
                         Feasibility
                         Arbitrariness
                         Uniformity
                      Enforcement of Standards
                         Organization
                         Testing procedure
                      Economic Incentives:   Emission Charges
                         Advantages
                         Problems
                      -Economic Incentives:   Research and  Development Grants
                      Legal Approaches
                         Conspiracy
                         Federal antitrust  litigation
                         State and  private  antitrust litigation
                         Restructuring the  auto industry
                         Research activities
                         Warranty
                         Citizen suits

                  Encouraging Development  of  Unconventional,  Low-Emission
                      Vehicles
                      Direct  Regulation
                         Standards
                         Ban  of  internal combustion  engine
                      Economic  Incentives
                        Research and  development grants
                         Prototype  Procurement
                        Distribution
Page



  2

  2


 1-1

 1-2
 1-2
 1-4
 1-5
 1-11
 1-12
 1-17


 1-20
 1-24
 1-25
1-36
1-37
1-39
                                                                   Page

  Encouraging Development of  Low  Pollution  Fuels                   1-43
     Oil Industry Research                                         1-43

  Direct Regulation                                                1-46
     Oil Industry Position                                         1-46
     Federal Position                                              1-47
     Legislative History                                           1-47
        Fuel registration
        Fuel regulation

  Economic Incentives                                              1-48
     Cost of Production                                            1-48
     Cost of Purchase                                              1-49
     Size of Market                                                1-49
CHAPTER 2 — CONSUMER CONTROL OF AVERAGE EMISSIONS  PER  MILE        2-1

  Direct Regulation                                                2-4
     Standards                                                     2-4
     Maintenance Requirement                                       2-5
     Mandatory Retrofit Requirement                                2-7

  Economic Incentives                                              2-9
     Proposed Legislation                                          2-9
        State level:  California
        Federal level
        Problems
        Estimation
        Economic considerations
        Political considerations

  State Emission Checking Programs                                 2-15
        Costs
        Benefits
        Current status
CHAPTER 3 -- CONTROL OF MILES DRIVEN PER YEAR                     3-1

  Vehicle Use Controls                                            3-3
     Direct Regulation                                            3-3
        Fuel and vehicle rationing
        Traffic bans
        Parking restrictions

-------
                                 ill
                                                                                                                                    iv
     Financial Incentives
        Direct usage tax
     Other Financial Incentives
        Parking taxes
        Commit at ion taxes
        Tax rebates

  Mass Transit
     Historical Federal Transportation Support
        Rail
        Bus
        New mass transit concepts
        Sumnary and conclusions
     Outlook for Mass Transit

        Planning

  Urban "De'siBii-
 Page

 3-6

 3-8
3-9
3-10
3-19
                                                                  3-22
CHAPTER 6 -- TOWARD A FEDERAL STRATEGY

  Uncertainty

  Projected Carbon Monoxide Levels

  Cost

  Considerations for a Balanced Strategy


APPENDIX A -- MAJOR FEDERAL AUTO AIR POLLUTION CONTROL  LEGISLATION

APPENDIX B -- EXHAUST EMISSION STANDARDS

APPENDIX C -- RECENT DEVELOPMENTS
Page

6-1

6-1

6-3

6-5

6-7
CHAPTER 4 -- LOCATION

  Emission Reduction
     Increasing Average Vehicle Speed
        Expressways
        Streets
        Staggering
     Traffic Bans

  Dispersion
     Urban and Transportation Planning
     Long Term Urban Design.
     Highway Design and Location
     Alteration of Traffic Patterns
                                                                  4-1
4-3
4-3
4-8

4-11
4-11
4-12
4-13
4-15
CHAPTER 5 — EMISSIONS CHARGE SYSTEMS

  Relating Emission Classes to Location
     Air Use Permits

  Relating Miles Driven to Location
     Fuel Tax Based on Location

  "Complete" Emission Charge System
     Without Sophisticated Monitoring Equipment
     With Sophisticated Monitoring Equipment

  Summary and Conclusions
        Advantages
        Problems
5-1

5-4
5-4

5-7
5-7

5-9
5-9
5-11


-------
                      INTRODUCTION


          This report, prepared under the direction of the Institute

for Public Adminstration (IPA) , contains findings of research carried

out for the Office of Air Programs (GAP) of the Environmental

Protection Agency under Contract No. EHS 70-126.  The general purpose

of this research, as described in the contract, is "to identify and

evaluate alternative Federal strategies to improve and develop induce-

ments for control of air pollution by the private sector."  The ini-

tial research under this agreement is now included in the IPA document

entitled, "Governmental Approaches to Air Pollution Control:  A Com-

pendium and Annotated Bibliography."  This work discusses mechanisms

of government control of air pollution from stationary sources only.

However, in view of the significant air pollution problem caused by

mobile sources, it was felt that additional research on mobile source

air pollution was worthwhile.  Furthermore, it was felt that limiting

the scope of this additional research to automobiles would permit

a more comprehensive analysis than would otherwise be possible under

the circumstances.  Since automobiles contribute nearly 90 percent

of the pollution (by weight) from all mobile sources, this focus would

direct the research efforts to what is clearly the most critical

area in the control of air pollution from mobile sources.  Accordingly.,.

this report is directed entirely to the definition and analyses of

governmental approaches to control air pollution from privately owned
            1
automobiles.
1.  Although most of the discussion in this report applies to commercially
owned and operated automobiles as well, such vehicles are not given ex-
plicit consideration.
                               - 2 -


                              Purpose

          The purpose of Governmental Approaches  to Automobile  Air  Pol-

 lution Control  is  (1) to bring together  in one  place  the  full range of

 policy approaches  affecting automobile pollution  control  and, (2) to

 place them  in an analytical framework which  facilitates both  the  compari-

 son  of existing policies and  the discovery of new policy  possibilities.

 Accordingly, this  report comprehends more than  a  discussion of  those

 policies now in practice or currently under  consideration in  govern-

 ment circles.  For example, policies are analyzed for which the neces-

 sary technology may not be immediately available  or for which rather

 complicated, expensive and intrusive administration would be  required

 (such as emission  charge systems using sophisticated monitoring equip-

 ment).  Though the report frequently.will indicate problem areas with

 individual  control approaches, there will be little attempt to  weigh

 the advantages and disadvantages of some policies against others.

 Finn conclusions can only be  reached by additional research to  determine

 the precise costs and air pollution reductions  possible using the ap-

 proaches detailed  in this report.


                           Organization

          The analytical framework created for  this report separates
                         1
 auto air pollution damage  into three  basic  components,  any of which

 are subject Co government action:
1.  "Damage" as used in this report,  refers in a general fashion to
the injury to people,  buildings,  vegetation,  etc.,  by air pollution.
Using this definition, the extent of auto-related air pollution
damage is a function both  of the magnitude of the emissions,  and the

-------
                                - 3 -


          1.  Average emission per vehicle per mile

          2.  Miles of use

          3.  Location of use

          Public policies which depend solely on control of any one

variable can, at best, achieve only partial success since the resulting

gain in air quality could be completely overwhelmed by changes in the

other two variables.  Hence, if public control policy is to guarantee a

reduction in the social cost of air pollution, it must manipulate or
                            1
control all three variables.

          The separation of pollution damage into the components out-

lined above, has many advantages.  Since the current federal strategy

has been centered largely around control of one of these components —

average emissions per vehicle per mile -- this framework will facilitate

the development of supplementary and complementary policies to insure

effective control of auto air pollution and to minimize the costs of

doing so.  This separation also will allow detailed analysis of the

broad range of possible actions on the basis of what action can best

influence each component, and who (manufacturers, consumers,  govern-

ment) can best perform the action.  Furthermore, this framework will

facilitate comparison of policy possibilities, since each policy can be

measured against the component of pollution damage that it is designed

to influence.  For example, both state emission checking programs and
1.  This assumes average emissions per mile from new motor vehicles    '
will not be reduced to a negligible amount, that is,  a nearly pol-
lution-free car will not be developed in the near future,  or such
complete control over the source would impose too great a  cost on
society.  These considerations will be discussed in detail in Chapter  6.
                                 -  4  -


mandatory purchase  of used  car  control  devices  are measures  which can

influence motorists' control of average emissions  per mile.   As indicated

below, a cost-benefit analysis  might conclude that only the  latter policy

is needed by most states  to secure effective control  over  this  component

of pollution damage.

          Since  the three components of auto pollution  damage will

prrvide the overall organization cf  this report,  it  is  useful to under-

stand some basic relations  among them.   First,  emission per  mile and

miles of use determine  the  aggregate magnitude  of  auto  air pollution,

while the location  — and thus  concentration — of this amount of pol-

lution is an essential  determinant of the actual damage produced.

Assuming an overall objective of reducing pollution  damage,  public

policy should be sensitive  to locational variables in addition  to

total emission variables.

          Second, some  components  are far more  susceptible to in-

fluence by a particular entity  than  others.  For example,  the individual

motorist can exert  considerable  influence over  the location  and miles

of use, but to a much smaller extent over the emissions  per  vehicle per

mile.  Though he can affect this variable through  selective  equip-

ment purchase and careful maintenance,  he depends  largely  on the tech-

nological alternatives placed upon the  markets by  automotive  Industries.

Similarly, automobile use is subject to the desires of  individual

motorists, but the  need for such transportation is determined largely

by the spatial relation of people  and activities.  Thus, urban  planners

to a greater extent  than motorists,  can influence  the number of  annual


-------
                                                         TABLE I
                                       CLASSIFICATION OF PUBLIC POLICY APPROACHES
                                      BY COMPONENTS OF AUTOMOTIVE POLLUTION DAMAGE
AVERAGE EMISSIONS PER VEHICLE PER MILE
Policies Aimed at Industry Policies Aimed at Motorists
1. Encouraging Development
of Control Technology
for pre-1968 Internal
Combustion Engine Cars

2. Encouraging Development
of Control Technology
for New Internal Combus-
tion Engine cars.
a) emission standards
b) emission charges
c) research and de-
velopment grants
d) litigation

3. Encouraging Development
of Unconventional
1. Mandatory maintenance
requirement

2. Mandatory retrofit
equipment installation
requirement

3. Used-car emission
standards

4. Discriminatory licens-
ing fee based on emis-
sions of vehicle

5. Discriminatory sales
tax based on emissions
of vehicle
MILES DRIVEN PER YEAR
1. Discouraging private
automobile use
a) fuel or mileage
rationing
b) parking restrictions
c) preferential lanes
d) tax on gasoline
e) parking taxes
f) commutation taxes
g) tax rebates

2. Total ban

3. Haas transit
a) rail
b) bus
c) new designs
LOCATION
1. Increase .average
vehicle speed
a) expressways
b) traffic control
c) separating rights
of-way
d) staggering work
e) traffic bans

2. Facilitate dispersal
a) alternate land
plans and urban
configurations
b) highway design &
location
c) alteration of
traffic patterns
4.
Vehicles
 a) emission standards
 b) ban on internal com-
    bustion engine
 c) research and develop-
    ment grants
 d) legislatively guaran-
    teed market

Encouraging Development
of Low Polluting Fuels  -
                                                               4.  Urban design
                                                                   a) reduce average trip
                                                                      length
                                                                   b) make economical, con-
                                                                      venient mass transit
                                                                      possible

(

* a)
to
to -O
01 to
U cd
3 g
O *•»
h
D. -0
at
•2 ti
cd at
» M.

•o to
at I
4J 5)
U to
SOD
O
•H to
t) a.

! 1
M
0° •
a. S
. 1
c 3
a) o
6 u
a! "2
> cd
O 3
00 O
4J

O *O >
<+4 Ol
CO U
4J 0>
at M
00 i-4
to -0
cd



U M
-H 00
*H 0
O to
a a

-o
01
jj g)
U J3
at w

Sffl
S.S2
<0 O IH
S « S





•O 0)
a) a) a
u H O
U U

M >
•H -H
0 c1
CO 0 CO
0) O 0)
U W i-*


cd co
>

CO |
0) *
•H U
• i-4 O
B rJ
01
m U-t CO
0 03
— t —1 4-1
2 § 2 °
B CO
O 4-1 O i-l
U O U 4J
« *




•H to a> co i
o o) i-( cd
to a -H u
US O
C CO -H
O B to 0)
CJ O Ot 1+4 CO
-H Ou OS
Oj CO 01 -H 4-1
§ -H <-4 CD O O
3 B U CO to
a at i-t 3 w B
B jC BO
O 4-1 0) 4-1 O ft
CJ O > O O *J
« *



•HMO)
O 0) -H
*•< Q> i-4
4J B

8-°, s.






B 4-4 0)
M 0 >



O
cd
at
•a
§
a)

I


g
•H
4J
•H
r-i
I
O
3
O
CO
4J
B
at
a
u

01
4-*

i

CO

-H

at



2
3
u ,
2
4J
to
i


4J
0)

at
•3S
•3

•H
a N
3 a
3,
M V-
0) O
1 45
•S
at w
H *J
"rt S
> X
cd 0)
2 co

M










cd

I
at
CO
0)
•H
*H
g,
CO

0
^H
9

a)
1
.
n
fr


CO

^
o

>,
'TJ
e

i
i-H
2
U
B
o
u

B
O
—*
o
4-1
O
u
B
at
B
1
0)

1

o
CJ
o
4J
CO
0)
K
3
T)
B
•H

•H
4J
O


4J
3
fl
ai'
•B



"S 2
4J
0) B
OP O
cd
^ o
u
at
54-1
to


*H CD
S S
-H

I J
a*
M n
O iH
0 s
4J
a i
1 Ji
(M *J
0 0
S 1
"o o
0. U
?v
^H
^ •§
t) H
S «
>> cd
00
O CO
-4 0)
O i-t

1 1
u a



s i
a. cd
cd
6 S
N 1
4J
cx at
6 "
at
B U
*d
•a ai
at M
CO
§o
4J
U
co a)
•H -(
at H
cd
* 5
0) M
^H 3
•H CO
01
o< a>

Sjj
o t-
•H 0)
CO -O
CO i-l
•H CO
e B
S o
CJ
01
5) H
10 rH
*"* T*
(fl CO

w
at
a B

6 5
3
S "°
o
-H O
W W
cd 3
a 4
0
^H CU
CJ
—1 3
cd -a
u at
-H to
4J
•H 0
^4 4J
U
O
5 *
>, S
,_j - w
•H £
U 01
at <-t
a.
s" s
9 JH
0) 3
iH
•H *J
43 OJ
1 i
0
4J H
3 a
w
tH a)
« -a

§ -H

" *
0 •*
B
o
•H
4J

•3
(X
2
•H
CO •
•H
x

o
B
o
•H

0)
a

at
,_i
VH
u
cd
M-t
•8
rt j
a
2 ,
cd
§'


M
3
-S t



o
•H
CO
1

1
CO

3 at o
3 CO 1-4
I to >
3 1 I
1 1
CO
CO tH


Ot
0) O

O B
" S
to 4J
•S «
•H W
So
o B
CJ H
O
t *H 4J
«H B
n ? o
J CJ
J J3
3. to U
S S 2
J §• *
S 6 S
•H "H
a o
H • ^)
fl a H
i u o
3 B 0.
U YH
O -
g a «
•H <-(
Cd 4J
u cd
O .£


at *

-------
                               - 7  -


 variables  through a price on emissions.  The final chapter, Chapter 6,

 will  analyze  some of the important  considerations related to combining

 the materials in the previous chapters into an effective federal strategy

 for the  control of auto-related air pollution.  In addition, Appendix

 A will give an overview of major federal legislation related to the

 auto  air pollution problem,  Appendix B will summarize federal emission

 standards, and Appendix C will highlight recent developments in the

 area  of  automobile air pollution control which have occurred since this

 report was originally submitted on  April 1, 1971.

          It  is important for those with a national policy orientation

 to realize that not all of the policy alternatives available in Chap-

 ters  2,  3, and A will necessarily be available at the federal level.

 For example,  discriminatory licensing taxes for automobiles with

 relatively high emissions per mile  (Chapter 2) will probably lie within

 the domain of  state authority.   However, policy alternatives at lower

 levels of government will often suggest federal counterparts (in this

 case,  federal  discriminatory excise taxes)  or suggest the desirability

of federal action to induce states or localities to take certain

actions.   In any event, the options open to state and local govern-

ments as well  as the aggressiveness with which they are exercised can

have strong bearing on the  nature of the federal role.   A comprehensive

and organized  review of policy  alternatives available at all levels

of government wl.ll also place the role of the Federal Government in

perspective.
                          CHAPTER  1


           INDUSTRY CONTROL OF AVERAGE EMISSIONS PER MILE


          Control over the emissions source,  the engine-fuel  systems,

is the most direct approach to reducing auto  air pollution.   It  la

the mainstay of current federal auto pollution control policy and,

if totally successful, could conceivably end  the automotive air  pol-

lution problem.  It is more likely, however,  that considerations of

cost and equity — as reflected in the range  of technological pos-

sibilities — will require control of the source be supplemented
                  1
by other policies.

          The focus of this chapter is on programs designed to

stimulate automobile manufacturers, fuel producers and other  related

industries to develop the technology necessary for effective  control

of pollutant emission per mile of automobile  usage.    More specifi-

cally this focus implies an evaluation of the relative costs  and

benefits of government action in three basic  areas:

          1)  Development of control technology for the internal

combustion engine.

          2)  Development of unconventional engines having low

pollution emission.

          3)  Development of low pollution fuels.

With respect to the first two areas, the chapter will evaluate the

role of direct regulation, economic incentives, and litigation.   In

-------
                                 1-2
 addition to  encouraging  development  of pollution control systems

 for new vehicles,  consideration will be  given to government's  role

 In the development of  new devices  for older  automobiles with no pol-
                       1
 lution control systems.   And,  since, control of  the  source  is  the

 major federal strategy,  current federal  programs will be discussed

 and some basic information necessary to  understand the auto air pol-

 lution problem will be briefly outlined.


                   Encouraging  Control Technology

 Pre-1968 Automobiles.

           Currently, approximately 70 percent of the nation's  auto-

 mobiles (pre-1968) do  not have any type  of pollution control device or

 system.  Depending upon  age and degree of maintenance, these vehicles

 emit anything from five  to one hundred times as  much pollution as new

 models.  These pre-controll.ed  vehicles-ara being phased out of use

 at a rate of approximately 10  percent per year,  which means they

-will contribute significantly  to automobile-caused pollution for  the

 next few years unless  control  devices are developed  and applied.

           Research efforts conducted by  the  auto manufacturers as

 well as several other  firms have resulted in a number of low cost
1.  Although development of new control technology, new engines and
new fuels can make the greatest impact on average emissions per mile,
there are other ways in which such control can be achieved.  Motorists,
for example, could keep their vehicles well maintained and purchase
existing control equipment if their vehicles do not have a con-
trol system.  In addition, measures designed to Increase average ve-
hicle speed will reduce emissions per mile.  However, these alternatives
relate to vehicle ownership and usage behavior.   Since this chap-
ter will be devoted to public policies aimed at  industry,  these
alternatives will be discussed 
-------
                                1-4
This measure was considered recently In proposed legislation.   How-

ever, such a policy would be extremely costly to the auto manufacturers

and apparently can be justified only as a punitive measure.  Relief

of this nature is being sought in numerous lav suits that are now

pending (see "Legal Approaches" below).

          Other measures would include direct regulation requiring

motorists with pre-1968 cars to purchase control devices or a financial

incentive.  These will be discussed in the following chapter insofar

as they relate to policy alternatives directed at individual motorists.

                                          2
New Internal Combustion Engine Automobiles

          Action by the Federal Government appears to be needed to

provide the incentives for development of auto pollution control tech-
                             3
nology by the private sector.   In a strictly commercial sense,
1.  See The National Air Quality Standards Act of 1970, Report of
the Committee on Public Works, United States Senate, Serial No.
91-1196 (September 17, 1970), p. 13.

 2.  Various  technological alternatives for controlling automotive
 emissions  are being  pursued.  "Add-on" devices include catalytic con-
 verters, manifold  reactors, and direct flame afterburners.  Other pos-
 sibilities include engine refinements and exhaust gas recirculation.  For
 a comprehensive review, including cost and performance estimates, see
 Control Techniques for Carbon Monoxide. Nitrogen Oxide, and Hydrocarbon
 Emissions  from Mobile Sources: National Air Pollution Control Administra-
 tion, March  1970.

 3.  For evidence of  the reluctance  of the auto industry to take  the
 initiative in developing pollution  control technology, see John C.
 Esposito,  Vanishing  Air (New York:  Grossman, 1970), Chapter 2.
                                1-5


the development of pollution control equipment  is  simply  not good

business:

          Control of air pollution does not make cars
          easier to sell, it does not make them cheaper
          to produce, and it does not reduce comebacks on
          the warranty.  To people interested in profits,
          expenses for the development and production of
          exhaust controls are liabilities.*

Manufacturers are particularly concerned about  the price  increase

that would result from the introduction of pollution control tech-

nology:

          ... a lot of our customers couldn't and
          wouldn't go along.  Some of them would have
          to buy down to less car than they really want.
          Some would have to do without or settle for
          used cars.  And recent experience indicates
          a lot of them would join the ranks of import
          buyers.

In the absence of Governmental pressure, these  considerations show

why it is unlikely that the auto industry would act to control air.

pollution.
Standards for New Vehicles '

          One way to control the source is to set maximum Units

on emissions from new motor vehicles; this has been the core of the
1.  S. Smith Griswold, cited in "The Way Detroit Wages War on Pol-
lution", by Coleman McCarthy, The Washington Post. January 26, 1970,
Smith Griswold has held executive positions with the California
Air Resources Board and more recently with the National Air Pollution
Control Administration.

2.  tee A. lococca, President of the Ford Motor Company cited in
"Environment Mortgaged to Buy Life's Frills" by Milton Viorst,
The Evening Star. November 10, 1970, p. A-21.  As Viorst pointed out,
lococca is really saying that the country will have to accept a
decline in its material standard of living if it is serious about
restoring the environment.  Unfortunately  for the automakers, car

-------
                                1-6
federal strategy to encourage auto manufacturers to develop and
                                    1
apply emission control technologies.   The summary of federal auto

air pollution legislation In Appendix A highlights the emphasis on

emission standards, and more generally, control of the source.
          Standard setting.  Under the authority granted in the
                                        2
Motor Vehicle Air Pollution Control Act,   the Secretary of the De-
                                          3
partment of Health, Education, and Welfare  may regulate the dis-
                                                 4
charge of any substances from new motor vehicles.   The federal

standards promulgated to date as well as the proposed HEW standards
1.  Unlike the Congressional legislation  concerning  stationary  source
air pollution (which places the responsibility on  the states),  the
authority for setting mobile source standards has  been pre-empted by
the Federal Government.  Nationwide standards for  automobiles are
considered vital since autos are designed, manufactured,  and dis-
tributed on a national basis and move frequently over state lines.
California, however, has been granted permission to  set standards
more stringent than national standards because of  the severe air pol-
lution problems in that state.  See Clean Air Act  Amendments of
1965, P.L. 89-272, Sec. 208.

2.  Title II of the Clean Air Act Amendments of 1965, P.L. 89-272.

3.  A recent reorganization of the federal pollution control efforts
places responsibility for air pollution control in the Office of Air
Programs  (OAP) of the newly-created Environmental  Protection Agency
(EPA).  Formerly, this responsibility was mandated to EPA's Air Pol-
lution Control Office  (APCO) and prior to that the National Air Pol-
lution Control Administration (NAPCA), an entity in the Department
of Health, Education, and Welfare (HEW).  Hence, although references
here to past legislation or historical events will often refer to
APCO, NAPCA or the Secretary of HEW, it should be  understood that
the responsibility for air pollution control now resides with OAP
and the Administrator of EPA.

4.  The primary pollutants emitted by the internal combustion engine
are carbon monoxide, hydrocarbons, nitrogen oxides, and lead.  In-
creased concern is currently being voiced over the emissions of  -
rubber and asbestos particles (from brake linings  and clutch facings)
but no federal regulatory action is currently programmed.
                                                                                                                              1-7
 are summarized  in Appendix B.  The  impact  of  present and future

 standards on automobile emission levels  is also shown.

           Congress has departed from  the previous  executive stan-

 dard setting procedure and written  explicit standards for 1975-76

 into federal law.  The new legislation,  1970  Amendments  to the Clean
          1
 Air Act,  provides for a 90 percent reduction in levels of automobile

 emissions as compared to the 1970 model year levels.  (See Appendix B

 for details.)

           The automobile industry strongly opposed Congressional

 standard setting:

           ... we believe it is completely unrealistic to
           freeze standards into the Statute.   By jloing so.,
           it deprives the Secretary /Administrator^/ of the
           opportunity to set standards based on the national
           air ambient quality standards which this bill di-
           rects him to promulgate.   With new data being ac-
           cumulated daily this can be accomplished by a
           responsive technical administrative agency and not
           frozen arbitrarily into  law with no scientific Justi-
           fication for the levels  of control  specified.   We
           submit that these laws must provide for some flexi-
           bility. Z

           The extensive  legislative  hearings  held by both Rouses of

 Congress  in  1970 highlighted  the urgency  of the auto air pollution

 problem.   Upon  learning  that  the level of ambient air quality neces-

 sary to protect  the public's health  would not  be reached before 1990
1.  The 1970 Amendments  to the Clean Air Act were  reported by  a
House-Senate Conference  Committee on December 16,  1970,  and signed
into law on December 31, 1970, P.L. 91-604.

2.  Information submitted to the Senate Subcommittee on Air and
Water Pollution by Ford Motor Company.   Reprinted in Hearings
before the Subcommittee on Air and Water Pollution, United States

-------
                              1-8


under the existing HEW standards schedule,  Congress felt such a

strong measure was warranted.   This conclusion was based on fed-

erally established air quality criteria and auto emission re-

search which together indicated that the 1980 research goals proposed

by HEW were vital for health reasons,  and an estimate of ten years  for

sufficient replacement of automobiles  with those having the emission

controls meeting 1980 standards.   The establishment of emission  stan-

dards on the sole basis of perceived public health and welfare needs

represents a substantial departure from previous legislation which  re-

quired "appropriate consideration of technological feasibility and

economic costs."


         Rationale for standards.  Prior to the establishment of  standards

on the basis of an investigation of air pollution effects (i.e.,  air

quality criteria documents), standards were (and to some extent still

are) essentially ultimatums designed to goad the auto industry into

commercial application of successively greater degrees of control tech-

nology at the earliest possible times.  Underlying the standards  ap-

proach have been two premises -- either the industry is deliberately

witholding available pollution controls, or a stringent set of stan-

dards can be the "mother of invention."  As will be discussed below,

the first premise seems unlikely but there is evidence which indicates

that the second may well be true.
 1.   For a brief  derivation of  the new  standards, see National Air Quality
 Standards Ace iOf  1970 /Senate  Version  of  Clean Air Act Amendments of
 1970/;  Report of  the Committee on Public  Works, United States Senate,
 Serial  So.  91-1196, September  17, 1970, pp.  25-27.

 2.   Air Quality Act of  1967, P.L. 90-148,  Sec. 202(a).
                                 1-9


           In support of the first premise, a number of law suits have been

 brought which allege that from the mid-1950's until fairly recently, the

 automakers have conspired to prevent the development and installation of

 anti-smog devices.   The Federal Government charged the auto companies with
                                                                 1
 such conspiracy and recently settled the case by consent decree.    A

 number of cities and states filed similar suits which are currently

 pending  in the  courts  (see "Legal Approaches" below).   Further sup-

 porting  this  view,  a former federal pollution abatement official

 stated in 1964  that  he  felt the  automobile manufacturers had deliberately

 withheld existing control technology.   "Everything that the industry

 has  disclosed that  it is  able  to do today in 1964 to control auto ex-

 haust, was possible  technically  ten years ago.   No new principles had

 to be developed, no  technological  advance was needed,  no scientific
                            2
breakthrough was required."

        Today, however, there can  be little  question that the  tech-

 nology to meet  the proposed standards does not  currently exist,  that

 the  accelerated demands for  cleaner engines  will require advances and

 technological breakthroughs.  The  guidelines agreed  to by the  auto

 industry  in settlement of  the Federal Government's  antitrust suit  and
1.  Although by entering the consent decree, the auto companies  do  not
admit guilt, one outspoken  critic of the industry believes  that the
Government's allegations "should stand as a reminder of the  vast
potential for nembers of this industry to agree to do nothing."   Ralph
Nader cited in Ideas (Washington, D.C.:  International Research  and
Technology, December 1969), p. 115.

2.  S. Smith Griswold cited in "The Way Detroit Wages War on Pollution"
by Coleman McCarthy, The Washington Post. January. 26, 1970.  The  con-
trols cited were required in California cars in 1964 and nationwide

-------
                                 1-10
 the increased scrutiny of the Industry by both government and the

 public also reduce the possibility that the automakers may be guilty

 of suppressing available technology.

           The other underlying premise of the standards approach is

 essentially that the Federal Government can "legislate technology."

 Although the behavior of the auto industry in the past would suggest

 a lack of serious commitment to pollution control, industry represen-

 tatives are increasingly vocal about their firms' commitxent to clean

 air.  They argue that immense resources are dedicated to controlling

 pollution and deny that any legislative pressure could result in
                                          1
-=p?edier compliance with clean air needs.

           However, such a message has an all-too-familiar ring to

 critics of the auto industry.  They point to 1964, when enforcement of

 the law in California threatened the auto industry it caused "re-

 markable "technological breakthroughs'":

            During the~early sixties,  California enacted
            a statute which .required that all  new cars  sold
            in that-s£a££~ would be equipped vith controls
            two years after state officials  certified  two
            workable  pollution-control devices.   In March
1.  A recent statement by the head of Ford Motor Company's automotive
emissions office is typical of the industry's position, "We've got more
than 200 engineers working three shifts a day, seven days a week on the
problem.  We just can't go any faster than that.  We're just as con-
cerned as anyone else."  "Automotive News", February 2, 1970.  Cited in Ideas
(Washington, D.C.:  International Research and Technology; March, 1970),
p. 29.  A somewhat stronger statement was made by Edward Cole, president
of General Motors" . . . pollution problems cannot be legislated out
of existence any more than the laws of nature can be overruled."  In
"Auto Industry Opens Counterattack on Environmental and Consumer Move-
ment" by Jerry M. Flint, The New York Times. November 18, 1970, p. C-29.
                                                                                                                                1-11
           of 1964,  the trade association which speaks for
           the American manufacturers forcefully reiterated
           its then  familiar litany that no controls would be
           possible  before the 1967 model year.  But three
           months later, the state certified four control
           devices,  all developed by outsiders.  The pros-
           pect of having to purchase equipment from out-
           side of the automotive establishment fired the
           industry's  creative  urge.   /Chrysler quickly de-
           veloped a "Clean  Air Package77 which  was  es-
           sentially copied  by  the  other  "Big Four" auto
           manufacturers^/   The California incident illus-
           trates graphically that  volunteerlsm will not
           work with the auto industry.   Only the threat
           of a hard and fast legal deadline succeeded.  .  .

           On the basis  of such evidence,  it does appear that stan-

dards through the establishment  of legal  deadlines can substantially

motivate the industry.
Advantages of Standards

          Standards for new cars can yield significant reductions  in

average emissions per mile in a short time.  Since the establishment

of the first set of standards in 1968,  69  percent control over

hydrocarbon emissions and 60  percent control over carbon monoxide
                            2
emissions have been achieved.   This is not to say further reductions

will be possible with the same speed (see "Feasibility" below), but

rather that standards by explicit threat can motivate rapid compliance.

          Standards are relatively easy and inexpensive to enforce.

As discussed below, the national enforcement program need only sample
                                                                                                1.   ".  .  . And a Rebuttal  on Three Essential Points J_to  a_statement
                                                                                                made by L. A. lococca, president of the Ford Motor Company/  "  by
                                                                                                John C. Esposito, The Washington Post. November 23, 1970, p. A-16.

                                                                                                2.   Source:  APCO.  Cited  in Environmental Quality. First Annual Report
                                                                                                of  the  Council on Environmental Quality; transmitted to  Congress August

-------
                                1-12


a fraction of the auto industry's output to get a reliable measure of

conformance.  The small number of auto manufacturers also facilitates

administration.


Problems with Standards

          Feasibility.  As discussed above, the Clean Air Act Amend-

ments of 1970 establish a new criterion for standard setting — the

degree of control required for public health and welfare.  However,

a later amendment giving an additional year to automakers to meet the

nitrogen oxide standards, as well as a provision for a one-year waiver

of the standards upon demonstration of technological difficulties,  in-

dicate the Congress is still very much concerned about the ability of

the automakers to develop the technology in the time allowed.

          This highlights a basic' difficulty with the standards ap-

proach:  there can be no advance assurance that any  particular set of

standards can be met in the time required by the implementation

schedule, even if automakers were totally committed  to the development

of pollution control technology.  Neither the "ultimate"  limits of

the internal combustion engine nor the technologies  needed to achieve

it are currently known.   Thus, contentions by the auto industry that

they will be unable to meet the proposed standards are extremely  dif-

ficult to evaluate, let alone challenge, especially  since the industry
                                                                                                                            1-13
 controls  the  dominant  share of the nation's automotive research and
                       1
 development resources.
         Arbitrariness.   Determining specific standards to be im-

plemented at  a  specific  time  is  a task fraught with great controversy.

The Air  Quality Act  of 1967 required the Secretary of HEW to determine

air quality criteria with respect to potentially dangerous pollutants.

Such research has been conducted for all automobile-related air  pol-

lutants.  Although these criteria have not  been universally accepted,

they were crucial inputs in the  recent Congressional decision to
                                 2
establish legislative standards.   Yet,  even  if the published air

quality  criteria were universally accepted, the implications of  such

ambient  air level criteria for auto  emission  control would be highly

disputable; the absence  of reliable  micro-meteorological  knowledge

about how pollutant  gases  combine and diffuse over time make it  im-

possible to relate accurately exhaust emission concentrations to
                           3
concentrations  in the air.
1.  To provide policy makers with an independent source of information,
the Clean Air Amendments of 1970 require the Environmental Protection
Agency to arrange for a comprehensive study on the technological feasi-
bility of meeting standards.  The National Academy of Sciences will
conduct this study.  P. L. 91-606, Sec. 202(c)(l).

2.  See National Air Quality Standards Act of 1970, Report of  the
Committee on Public Works, United States Senate, September 17, 1970, p.  25.

3.  The Automobile Manufacturers Association took strong  exception  to
the particular research document relied upon to relate air quality  cri-
teria to specific auto emission standards. . (D.S. Earth,  et  al.,
"Federal Motor Vehicle Emission Goals for CO, HC, and NO.  Based on
Desired Air Quality Levels", a NAPCA paper presented to the  annual

-------
                                  1-14
                                                                                                                         1-15
            The inability to rationalize standards on the basis on pre-

  cisely determined scientific evidence that would relate public health

  and welfare needs to auto emission levels has resulted in a long-

  standing dispute between Federal policy makers and  representatives of
                    1
  the auto industry.

            Lacking defensible grounds  for determination of auto

  emission levels, anything short  of reducing such emissions to zero can

  be considered an arbitrary compromise.   Henry Ford  II  recently criticized
  (continued  from previous  page)

 letter to the Secretary of HEW  (August 27, 1970), the AMA claimed,
 ."It wae--rade-manifestly clear in the paper that the measurements,
 math models, data analysis and  conclusions are of a developmental
 or a preliminary nature and not intended to be construed as final
 or adequate for establishing legal standards."  In reply, the Sec-
 retary contended that "It appears to me that the paper makes responsi-
 ble and constructive use of such data and methods as a means of
 determining what the Nation must do in order to reduce the threat of
 air pollution in years to come, particularly in view of the alternative
 which is to postpone making projections and decisions for several
 years in order  to produce more  definitive data from which more pre-
 cise conclusions could be drawn."  Letters reprinted in Senate Sub-
 committee on Air and Water Pollution Hearings. 91st Congress, Second
.Session, Appendix, pp. 1576', 1596..

 1.  The following comments by auto industry spokesmen are representative
 of the current  industry disagreement with both the air quality requirements
 and the technological capability implied in the proposed Congressional
 standards.  ". _._ . our citizens have been needlessly frightened /by
 pollution scares/ . . . frantic measures to overcontrol automotive
 emissions cannot be justified during most of this decade."  Charles
 Heinen, Chrysler Corporation's  chief emissions expert.  "We have an
 obligation to oppose technically unsound standards which impose
 unnecessary cost burdens on the public with no appreciable
 benefits in terms of air quality . . .  There are limits to
 what can be accomplished in terms of current technology and
 the practical realities of the mass production system."  Edward
 N. Cole, president of General Motors.  Both in "Auto Industry
 Opens Counter Attack on Environmental and Consumer Movement"
 by Jerry M. Flint, The New York Times. November 18, 1970, p. C-29.
 federal policy  makers  for using  a moralistic approach to the pollution

'issue:

              One of the  troubles  with  the moralistic
           approach  to  problems is  that  it doesn't  lend
           Itself to rational  solutions.  If  something is
           identified as a sin, like vehicle  air  pollution,
           then  obviously  It should be stopped 100  per
           cent  right now  ...   If you  have  to compromise
           with  sin, you might as well compromise on a
           nice  round number like 90 per cent on  some nice
           round date like January  1, 1975.  .  .  .   Arcer
           all,  if air  pollution  is a moral  issue,  not a
           practical one,  then there's no need to con-
           sider what's necessary,  what's possible, how
           soon  it's possible, or how the benefits  compare
           with  the  costs.  One arbitrary compromise is as
           good  as another.  .  .1  (emphasis supplied)

           Aggravating  the difficulty in setting  non-arbitrary stan-

 dards,  public pressure is making it increasingly difficult  for

 federal policy  makers  to  objectively evaluate the  available data.
 1.  Henry Ford II in "The Clean-cut  Issue of Clean Air",  The
 Washington Post. November 23,  1970,  p.  A-16.  Setting standards
 at  any level  above zero is not consistent with the traditional way
 our laws treat such noxious situations.  This is cleverly brought out
 by  Frotessor  Ernest Starkman,  an expert in automotive technology,
 "It's  like 'litter-bugging'1.   We don't  establish limits  permitting
 one to throw  three gum wrappers and  one pop bottle out the car
 window'per mile.  Instead, the edict is, 'Thou  shalt not litter.'"
 Address to California University Engineering Alumni Society,
 October 23,  1969,  cited in Ideas (Washington,  D.C.:   International

-------
                                1-16
The mounting public demand for clean air has essentially elevated
                                 1
the Issue to "motherhood status".
          Uniformity.  Uniform, "across-the board" standards are

the simplest  to administer, but may be substantially more costly to

society as a  whole, as well as inequitable to large numbers of rural

motorists.  All motorists, whether they drive one thousand or ten

thousand miles a year, or whether they drive primarily in rural areas

or urban areas, must purchase a car with expensive pollution control

equipment.  The cost to society will also include a decrease in the

kinds of vehicles  that can be offered for sale.  There is evidence

that many large, .high performance vehicles and many foreign isakes

will not be able to meet forthcoming standards.  With respect to

foreign cars, standards may essentially constitute a trade barrier
                                  2
over and above tariffs and quotas.
1.   As one  congressional  aide remarked recently, "Clean air is a
good, conservative, middle class issue and no one can afford to be
on  the wrong side these days."  Cited in "With Even the Silent Majority
Opposing Air Pollution, the Nixon Administration is Apt to Take a
Hard Line Against Detroit" by William Chapman, The Washington Post
April 5,  1970,  p. E-l.  A few weeks later, the Senate passed its
version of  the  stringent  1970 Amendments to the Clean Air Act
(S-4358) by a vote of 73-0.  This, however, cannot be taken as a
sign of the times.  Unanimous votes on Clean Air Amendments have
become a Senate tradition.  Though, one might have expected some
-dissent this year as the  bill contained highly controversial provisions.


 2.   The  unintentional  discrimination  against  foreign  cars may
 seriously affect the economy  of some  European countries.  For a  dis-
 cussion  of the difficulties  faced  by  foreign  car manufacturers in
 meeting  United States'  standards and  the possible  effects,  see "U.S.
 Auto Pollution Standards  and  Foreign  Cars", by  Claire Sterling,
 The Washington Post. November 9, 1970.
                                 1-17


Enforcement of Standards

          It  is not enough just  to  set  limits on maximum allowable

emissions; provision must be made to  ensure the promises of law are

translated into reality.


         Organization.  In establishing an enforcement program, a basic

policy consideration is how the responsibility is to be divided between

the Federal Government and the states.  The logical division of responsi-

bility coincides with  the characteristics of  automobile  manufacture

and use.  Since automobiles are marketed on a national basis,  the

Federal Government is  best suited to  determine whether new auto-

mobiles are conforming to standards.  The completely  decentralized

use of automobiles, however, makes  it far more efficient for states

or regions to monitor  the continued effectiveness of  the control

system in individual automobiles.   This general  division of responsi-

bility has been adopted, though as will be  seen  below, state emission
                                                  1
checking programs are  only in the planning  stage.


          Testing procedure.  Obtaining a reliable measure of  the

roughly eight million  passenger vehicles manufactured  each year is  a

complex undertaking.   It requires a comprehensive test cycle (idle,

acceleration, deceleration, etc.) if  results  are to be representative

of emissions during actual automobile usage.   Suitable procedures for
1.  Since federal enforcement is directed at manufacturer's compliance
and state enforcement is directed at individual motorists, the develop-
ment of state inspection programs will be discussed in the following

-------
                                1-18


determining durability must be developed in spite of the short time

allowed for testing.  Also, criteria must be developed for determining

how many vehicles to test and how ratings are to be evaluated.

          The federal program to test and certify whether new cars are

actually in conformance with the existing standards has been heavily

criticized.  Currently, tests are made on a sampling of prototype engines

— only 1,200 cars were tested last year.  Although the prototypes re-

ceived special handling and are not the ordinary assembly line product,

a certificate of conformity issued to a particular prototype extends

to every vehicle ". .  . which is in all material respects substantially
                              _       _                1
the same construction as the Certified/ test vehicle."   Government

ground rules permit special fine tuning before the prototypes* emissions

are measured (supposedly to correspond with dealer tunings prior to

sale), the "averaging" of high and low emitters (only the "average"

aust be in compliance with federal standards), and durability tests

with quick mileage accumulation (i.e., avoiding so far as possible

starting, stopping, foul weather,  corrosion and similar factors likely

to degrade the pollution control system.)

          Serious doubts were cast on the validity of this testing pro-

cedure by the results of a surveillance program instituted with the

aid of a rental car corporation.  The data, compiled by examining 1968

models driven by the public, revealed a startlingly high rate of control

system deterioration.   Slightly more than one-half of the cars tested

failed to meet either the hydrocarbon or the carbon monoxide standard.
1.  Air Quality Act of 1967, P.L. 90-148, Sec. 206(b).
                                                                                                                             1-19
 For more than one model, more than 80 percent of the cars tested
                         1
failed one or more tests.   Reports in 1970 show hydrocarbon emissions

higher than the standard by 25 percent and carbon monoxide  by about

10 percent — up from the 20 percent and 8 percent figures measured
                2
the year before.

          The failure of production line vehicles to perform as well

as their prototypes has serious implications for air quality.  Ap-

pendix B shows the estimated effect on projected air pollution levels

of this failure of production line vehicles to remain in compliance

with automotive emission standards.  The charts show quite clearly

that continued failure of production line vehicles to meet federal

standards will jeopardize long term air quality gains.  In addition,

such failure means that short of extensive maintenance programs, the

consumer expenditures (estimated at $15 billion since 1968) were

substantially worthless.

          New, more realistic test procedures, as well as more ac-

curate evaluative methods dnd measuring equipment were announced by

NAPCA on July 15, 1970.    These changes in the certification testing
1.  Source:  Interim Report — Rental Car Surveillance Program, March
1968 to November 1969, Division of Motor Vehicle Pollution Control,
Bureau of Abatement and Control, National Air Pollution Control Ad-
ministration.

2.  Environmental Quality.  The First Report of the Council on

-------
                                1-20


procedure are expected to close the "loopholes" that existed under the

old procedure.  The Clean Air Act Amendments of 1970 also make explicit

provisions for assembly-line testing of vehicles and give clear authority

to the Administrator of EPA to revoke certificates of conformance for

any vehicles not yet delivered by the manufacturer.  Also included in

the legislation is a warranty provision which will require develop-ent

of a aore durable emission control system (see p. 1-32).  The new legis-

lation also makes federal certification a legal requirement for the

sale of new vehicles.  Heretofore certification was voluntary, al-

though all auto manufacturers applied for the certificates for all of

their nodel lines.


Economic Incentives;  Emission Charges

          As a supplement to the prevailing federal approach of new car

emission standards, federal policy makers could levy a charge on auto

manufacturers directly proportional to the emissions from new motor vehicles.

Automakers would then have an Incentive to reduce pollution,  as to do so

would minimize their costs.  There has been only slight attention given

to such a policy; two bills were introduced in the House of Representa-

tives in the Ninety-first Congress seeking to make federal excise taxes
                                                        1
a function of engine horsepower and pollution emissions.   However,  the

announced intention of this legislation was to raise money for proto-

type development and,federal purchase of pollution'free automobiles,  not

to induce automakers to make lower pollution automobiles.
1.   H.R.  17202 (Farbstein);  H.R.  18980  (Ottinger).
                                                                                                                                    1-21
                                                                                                             A recent study to be published shortly by the National Academy

                                                                                                    of  Engineering outlines in detail the characteristics of an emissions
                                                                                                                                              1
                                                                                                    charge  scheme aimed at auto manufacturers.   Under the charge plan as-

                                                                                                    sumed in  that analysis, a fixed charge would be applied for each ton

                                                                                                    of  the  three gaseous pollutants emitted by automobiles at the time of

                                                                                                    manufacture and for as long as cars  of that model year were on the

                                                                                                    road.   The  annual  charge to the auto manufacturers would be a function of

                                                                                                    the number  of cars of a given  model  year and their emission levels at

                                                                                                    that time.   This could be determined inexpensively and reliably by a

                                                                                                    random  sampling of a small fraction  of the actual number of vehicles

                                                                                                    of any  model.   A charge system of  this nature,  it is  argued,  would give

                                                                                                    manufacturers the  incentive to develop pollution control technology

                                                                                                    and to  produce  control devices whose performance does  not  degrade

                                                                                                    over time.
                                                                                                             Advantages.   Charges can be adjusted so as to produce any
                                                                                                                              3
                                                                                                   desired level of emissions.   Thus the same reduction in emission

                                                                                                   levels can be reached as under the standards approach, but at a lower
                                                                                                   2.  For a more extended discussion of the advantages of emission
                                                                                                   charges, see Chapter 5, "Emission Charge Systems".

                                                                                                   3.  For example, applying a charge of S200 per tori' for Hydrocarbons,'
                                                                                                   $200 per ton for nitrogen oxides, and SlO per ton for carbon monoxide,
                                                                                                   it is contended, will be the equivalent of the new emission standards

-------
                                1-22
                                                                                                                                1-23
social cost.  The latter will be true since there will be no required

curtailment In production of any vehicle  (see "Uniformity" above),

but, Ideally, there will be a readjustment In the pollution levels of

vehicles and the quantities of different models produced as automobile

manufacturers seek to produce that "mix" of automobiles which will lower

costs as well as satisfy customer demands.

          A charge system of this type would reduce  the characteristic

government-Industry debate over technological feasibility and economic

cost which generally precedes the establishment of new sets of stan-

dards.  Once the charge is established (and admittedly there will be

a great debate at that time), technology and cost considerations will

be factors debated within the firm and not between the auto companies

and any government agency as is currently the case.


          Problems.  Auto firms need not necessarily consider the re-

curring maintenance and operating costs associated with various control

devices.  Thus, they could lower their costs under the charge scheme

at a substantial cost to consumers.

          At a more basic level, the auto industry might be sufficiently

oligopolistic to ignore the charges incentives if it should choose to

do so.  Even if one takes for granted that the auto firms will pass

the charge onto consumers, the possibility exists that they will raake
 little  effort  to  reduce  emissions.    However,  in such a case the careful

 scrutiny  applied  to the  behavior of the auto industry would almost cer-

 tainly  call  forth governmental action — either in the form of anti-

 trust suits, higher charge levels,  or new legislation.  Furthermore,

 such behavior  would be unlikely if  the charge system necessitated a

 large price  increase for new cars.

          While there would probably be few objections — beyond the

 resistance of  vested interests — to "small" or "moderate" charges,

 "steep" emission  charges  (or the outright ban  of higher  emitting  engines

 under a stringent standards  approach)  raise  significant  political questions.

          In the  Senate Hearings on air pollution, a  public witness

 strongly  advocated that  large horsepower engines should  be "outlawed out-

 right,  or taxed very heavily."  She saw "absolutely no reason  for any-

 thing over 200 hp" and suggested federal efforts "to  obtain equal time
                                       2
 to answer the  400 horsepower car ads."
 1.  The possibility under an emission charge approach that auto manu-
 facturers would make little effort to reduce emissions essentially means
 that such approaches must be coupled with direct regulation  (e.g., new
 car emission standards) if they are to be successful.

     One possible  factor motivating the auto industry to sabotage an
 emissions scheme would be that:  "By not responding any differently to
 the emission charges than they claim they would have responded to
 'reasonable' standards, the auto firms might hope to discredit the use
 of emission charges and return to 'voluntary compliance' and  'reasonable'
 deadlines."  Adrian J. B. Wood, J. Serge Taylor, Frederick R. Anderson,
 Laurence I. Moss,  Strategies for Pollution Abatement. Committee on
 Public Engineering Policy, National Academy of Engineering (Washington,
 D.C.:  January 22, 1971), pp.6-55 to 6-80.

2.  Dr. Ruth Weiner, President, Colorado Citizens for Clean Air.
Hearings before the Subcommittee on Air and Water Pollution of the Com-
mittee on Public Works, united States Senate,  91st Congress,  Second

-------
                                1-24
          In reply. SenatorMuskie placed this policy suggestion in

a larger context,  and in doing so, gave considerable insight  into

the problems of translating such good intentions into public  policy:

          You are talking about the size of an auto-
          mobile engine.  It goes much beyond that.
          . . .  How far do we go in actually limiting
          the kinds of products that can be produced,
          the kinds of consumer tastes to which private
          enterprise will be free to serve?  Just what
          limitations do we impose in a consumer-oriented
          society, that is also free in the kinds of
          products that we manufacture, the kinds of
          products that people can buy?

             It is relatively easy to say — the size
          of an automobile engine is an obvious one.
          But then you go beyond that, and we are
          going to have disagreement as to how big an
          automobile engine.  Then there are going to
          be those who say maybe we ought to go to
          something else . . . *
Economic Incentives:  Research and Development Grants

          The reduction of auto air pollution emissions requires that

research into pollution control techniques be accelerated.  The auto

industry, as discussed above, has indicated its determination to

clean-up the internal combustion engine and has indicated repeatedly
                                                             2
that such research efforts are not hampered by lack of funds.   Federal

support, however, could encourage research by non-industry firms who

operate with substantially smaller research and development budgets.
1.  Hearings before the Subcommittee on Air and Water Pollution of the
Committee on Public Works, United States Senate, 91st Congress, Second
Session, March 16, 1970, p. 77.

2.  The vice-president in charge of General Motors' Research Labora-
tories recently testified, "At no time since I have been associated
with the research laboratories have we really been limited by money or
facilities.  We are primarily limited by ideas. ..."  Paul F. Chenea,
Hearings before House Subcommittee on Public Health and Welfare, 91st
Congress, First Session, Serial No. 91-49, December 9, 1970, p. 114.
                               1-25


 the Federal Government has developed a plan designed to stimulate

 such research and development by private contractors.  The National

 Air Pollution Control Administration Motor Vehicle Research and De-

 velopment Plan is a six-year plan (Fiscal 1970-75) for federal research

 development relating to the prevention and control of motor vehicle
           1
 pollution.    In part it will provide funds over the next six years

 for the research and development of new, improved techniques for con-

 trolling emissions from gasoline-fueled engines.  As currently

 anticipated,  this money will be  used largely for contracts with

 private firms but also will permit  some in-house research.  It is

 not expected  that the plan  will  provide any significant  increases

 over the current level of funding for conventional engine  research

 and development  over the next  six years.   This  reflects  the federal

 position that private industry will  be committed to improving  the

 internal combustion  engine  and that  federal spending for research

 and development  should  be focused on  unconventional engines.         ~


 Legal Approaches

          Since both  the automobile and oil  industries are characterized

by  a close-knit group of large sellers, the application or modification

of  antitrust  laws is possibly  the major recourse  in  law  to control  auto
1.  A brief summary of this plan can be found in Hearings before the
Subcommittee on Air and Water Pollution, United States Senate, 91st

-------
                                 1-26


emissions.  Application of antitrust laws requires careful consideration

of two opposing factors.  On the one hand antitrust laws can be used to

prevent  conspiracy and promote competition in the development of pol-

lution control technology; on the other, stringent enforcement (or

realistic  threats of such enforcement) could essentially prevent

meaningful, cooperative research, especially inter-industry research.

In this  regard, antitrust laws might require modification to permit

specific activities which might  otherwise be unlawful.  These possi-

bilities concerning the use of antitrust laws will be discussed in

detail below.  This section will also discuss two other legal approaches:

(1) warranties as a means of stimulating the auto industry to develop

durable  pollution systems, and (2), legal remedies available to entities who

have reason to believe the EPA Administrator is derelict in performing

his statutory obligations to reduce auto air pollution.


          Conspiracy.  The inactivity of the automakers in developing

pollution control equipment, especially in the Fifties and early

Sixties, has resulted in a large number of court suits charging the

major auto manufacturers (and often several co-conspirators) with con-

spiracy  to delay development of automobile smog devices and conspiracy

to control the pace of installation of such devices.   If such an as-

sertion  could be proved,  it is conceivable the automakers could be re-

quired to establish a crash program for installation of pollution control

devices at no (or reduced)  cost for all motor vehicles produced during

the years in question (generally  1953-1970).   Complainants could  also

be awarded millions of dollars in treble damages.
                                1-27
          Federal antitrust litigation.  The Federal Government was
                                                                   1
the  first to allege such behavior in a suit filed  in January  1969,

This action was resolved in September 1969 by a consent  decree, in which

the automakers did not admit guilt, but agreed to  cease  and desist from

the alleged activities as well as accept certain behavioral guidelines
                                                       2
designed to insure compliance with the consent decree.   The  consent

decree offer of the Justice Department (a relatively favorable resolu-

tion for the automakers) and the court's acceptance were unpopular with
                                           3
environmentalists in and out of government.

          The following month, a L.S. District Court Judge rejected

the numerous petitions to intervene brought by a number  of city and

state governments as well as private individuals.  The court  held  that

they lacked standing to intervene but in an unusual action  the judge

ordered that the exhibits and Grand Jury testimony be  impounded and
                                   4
made available to future litigants.
1.  U.S. v. Automobile Manufacturers Association. Inc., 1969 Trade
Cases, paragraph 72,907, D.C.D., Calif.

2.  Civil Action No. 69-75-JWC.  D.C.D. Calif.

3.  One expert points to this case as an illustration of both the
attitude and the power of the automobile companies.  The consent decree
does not impose any penalty on the manufacturers and normally seals
the Grand Jury records, thus closing off information that might be
used in other damage suits.  In addition, he claims, the fact that the
suit was initiated only ten days before the Johnson Administration left
office "probably indicates the reluctance of the Administration to incur
the wrath of the auto companies."  J. Clarence Davies, III, The Politics
of Pollution (New York:  Pegasus; 1970), p. 94, p. 214 fn.

4.  For a discussion of standing in air pollution litigation, see
Governmental Approaches to Air Pollution Control:  A Compendium and An-
notated Bibliography, prepared for the National Air Pollution Control
Administration by the Institute of Public Administration, Contract No.

-------
                                1-28


          State and-private antitrust litigation.   The parties denied

standing to Intervene In the federal suit then brought Individual

(class action) suits.  These suits are based on the assertion that

anti-pollution devices would have been standard equipment on vehicles

now, but for the manufacturers' alleged agreement  not to compete in

developing them.  They claim damages to public buildings, greenery,

increased benefits to welfare clients suffering from pollution-related

diseases, and increased expenses to combat air pollution.

          On September It, 1970, a federal Court granted these litigants

the right to pursue their suits (which were consolidated for pre-trial

motions).  This is the first ruling to grant parties who were not

involved in a commercial relationship with the alleged conspirators

the right to recover under federal antitrust laws   for damages suf-

fered as a result of such conspiracy.  This decision cleared the way

for about twelve separate suits filed in courts throughout the nation.

The complainants will have to prove that a conspiracy existed and that
                               1
their damages resulted from it.

          The chances are slim that the complainants will receive the

kind of relief that can have a significant impact  on air quality.  The

cost to industry of a retrofit program would be enormous and it is not

likely that the courts will grant such relief.  It is more probable that

the significance of tile large number pf suits will be the message they


1.  Forty-seven of the fifty states are still capable of entering  i
such suits.  Michigan, Delaware and Wisconsin cannot do so because
they house the major automotive corporations and a state cannot sue
its own citizens.
                                 1-29


 carry to the auto industry — that the public and government are aroused

 and are subjecting industry's behavior to careful scrutiny.


          Restructuring  the  auto Industry.   Thus, the threat of future

 litigation will also be  an Important  consideration in the auto industry's

 decisions about pollution  control.  Of particular concern to the auto in-

 dustry  is the threat of  antitrust enforcement to restructure the industry.

 Ralph Nader, among others, believes vigorous technological competition

 can only be  guaranteed if  the Federal Government enforces existing anti-
                                                     1
 trust laws and restructures  the  automobile  industry.    A recent work by

 a colleague  of Nader's also  takes this position:

             The only way  to  deal with the  problem of corpo-
          rate gargantuism,  especially in the auto industry,
          is to dissolve the  major companies  and  to establish
          an optimal number  of smaller corporations.  .... a
          reduction in the size  of huge automobile corporations
          is the first step  towards creating  a balance of
          power between  the people and the  polluters.   True
          competition .  .  . would shift some  profit-making
          energies in the direction of  quality products  (in-
          cluding, of course, products  which  do not pollute).

But even this harsh critic of the auto  industry  realizes  the over-

whelming obstacles to implementing such a policy:

          Admittedly,  the rearrangement of  the largest manu-
          facturing industry  in  the world is  a formidable,
          perhaps unrealistic undertaking.  But we are dis-
          cussing solutions,  not political  expedients.
1.  Testimony before an ad hoc committee of New York Representatives
cited in Ideas (Washington, D.C.:  International Research  and Technology,
December 1969), p. 115.

2.  Jqhn C. Esposito, Vanishing Air (Grossman: New York, 1970),  p.  360.


-------
                               1-30


          Research activities.  Concern exists over whether the anti-

trust laws will permit information-sharing and joint research projects

of the sort that could substantially contribute to rapid development

of new emission control technology.  Critics of the automobile industry

claim that allowing close cooperation among members of that industry

will invariably lead to a conspiracy to restrain new developments.  And,

in fact, the consent decree which resolved the federal conspiracy case

prohibits a wide range of communications and cooperative endeavors

among members of the auto industry.

          The situation with respect to joint research efforts between

the automobile and oil industries is less clear.  A Commerce Department

panel concluded a few years ago, "The Federal Government should re-

cognize the need for meaningful joint research between industry- groups

and encourage these efforts by making reasonable allowances for ap-
                                                                1
propriate activities in the application of Federal regulations."   In

this regard, the Senate Subcommittee on Air and Water Pollution re-

cently considered an amendment to the Clean Air Act which would authorize

the automobile and petroleum industries to meet in a public forum under

federal supervision.  The Subcommittee's Chairman, Senator Edmund Muskie,

solicited the views of Senator Philip Hart, Chairman of the Subcommittee

on Antitrust and Monopoly.  In reply, Hart felt such an exemption from

antitrust laws was unnecessary for at least two reasons:
1.  The Automobile and Air Pollution, A Program for Progress, U.S.  De-
partment of Commerce (October 1967), p.  36.
                                                                                                                               1-31
           (1)  Government instigated and supervised  coopera-
           tion among  competitors  or between  industries  does
           not violate the antitrust laws;  and,

           (2)  Even if this kind  of conduct  raised an anti-
           trust  issue, its legality would  be measured by
           the rule of reason or clearance  for cooperation may
           be obtained from the Justice Department.^

But even  if further thought and examination  indicated that an  ex-

emption was necessary to permit such behavior, Hart  believes such

a statutory enactment would not be desirable;

           . . .Unless an exemption is absolutely  essential for
           the type of conduct the bill seeks to encourage, I
           would  be extremely reluctant to  raise the  issue in
           light  of these complicating factors   /j>ending_anti-
           trust  litigation involving automobile industry/.
           In addition,  most exemptions cover far  more ground
           than is necessary and often result in conduct which
           might  ultimately frustrate the very purpose of  the
           bill.  It seems justified to suggest that  the past
           record indicates a course of joint action  to sup-
           press  innovation in pollution control technology
           and that antitrust policy has been used to end  this
           type of conduct.  At this juncture it does not  seem
           wise to remove antitrust controls  to promote innova-
           tion,  since the ultimate result  may be  a repetition
           of what has apparently  occurred  in the  past.

               The spur of competition may well prove to  be
           the most reliable mechanism for  insuring the de-
           velopment of  technology to meet  the proposed bill's
           1975 standard.  It is my hunch that forced coopera-
           tion may result in both the petroleum and  auto  manu-
           facturing industries relaxing their research efforts.
           One may reasonably ask:  "Why expend great sums in
           research when we can get access  to everyone else's
           research?"  Absent the incentives  of competition,  I
           am not very  confident that the management  of any
1.  Letter from Senator Philip A. Hart to Senator Edmund S. Muskie.
Reprinted in Hearings before the Subcommittee on Air and Water

-------
                                1-32
          of Che firms Involved In these industries could
          justify the necessary Isrge research expenditures.
          If it is feared that one firm may corner the tech-
          nology through patents, trade secrets,  or know-
          how, your Committee may wish to consider the de-
          sirability of mandatory licensing at reasonable
          royalties of proprietary information which would
          assist in ultimately achieving the proposed Act's
          1975 emission standard.*

The Subcommittee accepted Senator Hart's suggestion and included

j-cvisior. for mandatory licensing in the new legislation.  This

provision establishes a procedure by which patents can be made

available to persons who could not otherwise meet the emission stan-

dards required by the Act.  If such need is established and it can

also be demonstrated to the satisfaction of a district court that the un-

availability of a patent may result in the lessening of competition,

the court may require the owner of the patent to license it on such
                                                        2
reasonable terms and conditions as the court determines.


          Warranty.  As a supplementary measure to the federal certi-

fication program, reliability and durability could be encouraged by

the use of warranties.  If pollution control devices are to have a

significant impact upon air quality, they must retain their
1.  Letter from Senator Philip A.  Hart to Senator Edmund S.  Muskie.
Reprinted in Hearings before the Subcommittee on Air and Water  Pol-
lution, United States Serate, 91st Congress (1970),  Part 5,  p.  1669.

2.  P. L.  91-604, Section 308.  This is a much "watered-down"  version
of the final Senate draft of the legislation.  In addition to patents,
the Senate bill would have included provision for mandatory  licensing
of trade secrets and know-how.  See National Air Quality Standards
Act of 1970.  Report of thi"Committee'on Public Works, United States
Senate, September 17, 1970 (S. 4358 Sec. 309).
                                                                                                                                    1-33
 effectiveness for many thousands of miles.   One type of warranty

 would require that automobile manufacturers (through their dealers)

 guarantee the continued effectiveness of pollution control systems.

 If a motorist could show his automobile was emitting pollution in

 excess of the standards, he would have legal standing to require the

 automobile dealer to repair or replace the control device at no

 cost.

           Performance warranties, however, suffer from one general

 deficiency which  is a particular problem with pollution control sys-

 tems.   Control systems require careful maintenance and periodic
                                                      2
 adjustment,if they are to retain their effectiveness.    Consequently,

 it is extremely difficult to distinguish between the manufacturer's

 liability and the consumer's misuse of the product.    The inability

 to determine  whether a vehicle has been "properly maintained,  ser-

 viced,  and operated"  may result in performance warranties being

 unenforceable.
1.  Lifetime performance, however,  is not an absolute necessity  at
the current time.   If present control systems could  remain  effective
for 5-6 years, they would make a  great impact  on air  quality
during  the critical period prior to the introduction of low emission
vehicles at mid-decade.

2.  The degree of maintenance and attention  required of motorists by
auto manufacturers  brings up a basic question — where  is the threshold
beyond which a control system should be declared to  require  "un-
reasonable" amounts of maintenance  and attention and should  not be
certified.  One estimate of the recurring costs for  maintaining existing
control devices and those proposed  is $6 billion annually.   Should
motorists be required to bear this burden or should  the auto manu-
facturers be required to build more foolproof systems as a requirement
for Federal certification?  (Source of estimate:  William H. Lear,
Joint Hearings on the Federal Low-Emission Vehicle Procurement Act,

-------
                                1-34


          The auto industry also believes It Is not reasonable and

may well be unconstitutional to require a manufacturer to warrant and

replace a system since he has no reliable basis for predicting the per-

formance of the new technology, and, thus, cannot include the warranty

cost in his prices.  In addition, the industry contends that the dif-

ference between the emission standards and the actual performance of

those vehicles with emissions in excess of the standard would probably

not be great enough to have any real effect on ambient air quality.

         For these reasons, the auto industry favors a much weaker

"defecfwarranty.  This is the standard type of warranty wherein the

manufacturer will replace or repair the system only if performance

is impaired as a result of a defective part or assembly..  The Clean

Air Act Amendments of 1970 .include  a defect warranty but also pro-

vide  that once local auto inspection stations are capable of checking

emissions, a five-year or 50,000-mile performance warranty will go
            1
into effect.


          Citizen suits.  The Clean Mr Act Amendments of 1970 also

authorize  citizens to bring suits to enforce any standard issued

under the Act or to compel the Administrator to perform any non-

discretionary duty created by the Act.  This provision was included

despite the strong objections of the automobile industry.  The in-

dustry contends that firm standards are needed two years in advance
1.  P.L. 91-604, Sec. 207.
                                                                                                                                      1-35
 of implementation,  and  If such standards can be placed in doubt by

 citizen suit against  the Administrator,  manufacturers will be left

 In doubt as  to what their course of  action should be.

           The Automobile Manufacturers  Association cites further

 problems with citizen suits.

           .  .  .  serious  problems are raised by the pos-
           sibility  of citizens suits to  punish or enjoin
           alleged violations  of existing standards.   In the
           administration of new,  highly  technical regulatory
           statutes, manufacturers must necessarily work out
           with the  agency technical  interpretations of what
           the applicable test and inspection procedures are
           to be.  If  manufacturers cannot rely on interpre-
           tations made and practices followed by the agency —
           if such reliance can be upset  after the fact by a
           citizens  enforcement suit,  effective day to day
           compliance  with the agency's regulations will be
           made infinitely more difficult.

              No  reason has been suggested why_,  in the abs_ence
           of  citizens suits,  the  Secretary /AdministratoT/
           would  fail  to  perform his  duties under the Act,  or
           why  in the  event of a violation the Secretary and
           attorney general would  fail  to  take the necessary
           enforcement measure.  Citizen  complaints  to the
           regulatory  authorities  may be helpful;   a  multitude
           of  citizens attorneys general  bringing enforcement
           suits in the courts  are more likely to be  harmful.
          No other federal regulatory  statute is enforced  in
           such a helter  skelter manner.  The  effective  regu-
          lation of air pollution is too critical  for such
          an expe
                 ot air pi
                 :riment. ^
1.  Letter to HEW Secretary Richardson from Thomas C. Mann, Presi-
dent of the Automobile Manufacturers Association, August 27, 1970.
Reprinted in Hearings before the Subcommittee on Air and Water Pol-
lution, United States Senate, 91st Congress, Second Session, Part 5,

-------
                                1-36


            Encouraging Development of Unconventional,
            	Low-Emission Vehicles.1	

          The uncertainty surrounding the speed with which the in-

ternal combustion engine can be cleaned up,  the costs of doing so,

and the ultimate limits that can be reached, require programs be

undertaken to develop an alternative power plant.   The major auto manu-

facturers, however, are committeed to improving the internal combustion

engine.  This commitment is based upon a combination of several fac-

tors (not necessarily in order of importance):

          1.  The belief that the Internal combustion engine

              can be cleaned up sooner and at lower cost than

              any other engine.

          2.  The large investment in physical  plant, parts, and

              technical know-how associated with the internal

              combustion engine.

          3.  Consumer acceptance and familiarity  with the con-

              ventional engine.

          4.  The threat to the strong alliance between the auto-

              mobile manufacturers and the oil  Industry.
1.  Among the most promising alternatives to the internal combustion
engine are the steam engine, gas turbine engine, and a hybrid engine
(a low-powered fuel burning engine with an array of electrical bat-
.teries).  For a comprehensive survey of unconventional power plants,
•see Report of the Ad Roc Panel on Unconventional Propulsion, Panel of
the Office of Science and Technology (Washington, D.C.:  February 16,
1970).
                                  1-37
 Although each of  the  "Big  Four"  automakers  has  ongoing programs to
                                               1
 develop unconventional  low emission vehicles,    the  industry's

 priorities are so heavily  oriented  to  the internal combustion engine

 that most non-industry  experts agree with the President's Air Quality

 Advisory Board which  concluded,

           •  • • /-£"£/ automobile industry lacks  sufficient
           motivation  to design unconventional powerplants
           and therefore it  seems clear that some govern-
           mental encouragement of non-auto  companies and
           additional  stimulation of  vehicle manufacturers
           is necessary.^

           Such governmental encouragement and stimulation can take

 several forms.
 Direct Regulation

           Standards.  The emission standards approach described above,

• will not provide the required motivation for accelerated develop-

 ment of an unconventional power plant.  The automakers are determined

 to meet the stringent standards by intensifying their efforts on

 the internal combustion engine.  However, insofar as standards are
 1.  The existence of such programs does not, in itself, imply a
 commitment to finding an alternative to the internal combustion
 engine.  One critic claims precisely the opposite is true, "auto-
 mobile industry research into alternative sources of propulsion has
 been directed not at finding solutions, but at discouraging further
 interest in alternatives."  Examples given include one auto company's
 manufacture of a steam propelled automobile using factory boiler
 specifications which resulted in the vehicle being overly large and
 cumbersome.  See John C. Esjosito, Vanishing Air (New York:  Grossman,
 1970), Chapter 2.

 2.  The Washington Post. December 18, 1970.  Cited in Ideas (Inter-

-------
                                1-38


an indication of the desire of the Government to control the source,

the current standards serve notice on manufacturers that the Govern-

ment will require a (nearly) pollution-free vehicle.  This may serve

to stimulate entrepreneurial activity on the part of those manufac-

turers who feel the internal combustion engine will not be able to

meet the standards or will not be competitive with a well designed,
                     1
low emission vehicle.
          Ban of internal combustion engine.  Each session several

bills are introduced into both houses of Congress seeking to ban the

sale of automobiles with internal combustion engines by a specific date
                                                          2
if such engines cannot meet certain low emission criteria.   The

intent of such legislation is to give automakers an ultimatum somewhat

stronger than under the standards approach.  However, there has never
1.  A letter by American Motors Corporation (the Big Four auto
company having the least stake in the existing market) to the
Senate Commerce Committee indicates that this might be the case.
" As you might imagine, American Motors is highly Interested in de-
veloping a low emission, mass-produced automobile.  Not only
would this have advantages from a social point of view, but we
look upon it as a rare opportunity for our company."  .(.January 24,
1969.)  Cited in The Search for a Low-Emission Vehicle, Senate Com-
merce Committee Staff Report, 1969, p. 29.

     This report argues that American Motors was the only one of the
"Big Four" auto manufacturers to express a serious commitment to work
on an unconventional engine such as the Rankine cycle (steam), as
opposed to the gas turbine .which is relatively similar to the present
internal combustion engine.

2.  For example, see S. 3276 (90th Congress, 1969) — a bill sponsored
by Senator Gaylord Nelson to ban the internal combustion engine if it
could not meet low emission standards by 1978.  At least nine states intro-
duced such bills into their legislatures in 1969-70. but only in Cali-
fornia did the bill have any success — it passed the California Senate
but died in the Assembly Transportation Committee.
                                 1-39


 been any action taken with regard to such bills at the federal level.

 Most policy makers are reluctant to ban the internal combustion engine

 before it is clear an unconventional vehicle could be marketed in its

 place.  Also,  the uncertainty surrounding the pollution control potential

 of the internal combustion engine makes it unfairly discriminatory to

 outlaw that engine when many interests (including some with substantial

 investments at stake)  contend it offers the best potential to meet

 clean air needs.


 Economic Incentives

           The  research,  development, and production costs of uncon-

 ventional vehicles will  be enormous.  The auto industry takes the posi-

 tion —  as  it does with  respect  to conventional  engine  research —  that

 no outside support could serve any useful purpose in hastening develop-
                                                          1
 ment  of  an alternative to the internal combustion engine.

          Independent developers are  in a  completely different situa-

 tion.  Beside working with a  substantially smaller research  and de-

velopment budget,  these  firms  face the huge costs of acquiring facili-

 ties and  tooling up for production.   The cost of this activity, including

 the funds needed for working  capital  to begin production,  is estimated
1.  In a letter to a Senate Subcommittee investigating various
financial incentives for development of a low emission vehicle, J. M.
Roche, President of General Motors, typified the industry position,
"_._ . . We at General Motors need no incentive^ such as your bill
/federal procurement of low emission vehicles^/ would provide.  However,
your  bill could induce others to seek a solution to the problem  . . .  .
Joint Hearings on the Federal Low Emission Vehicle Procurement Act,

-------
                                1-40
to be $275 million.   Independent manufacturers will also face a huge

marketing cost; the price of direct entry into the passenger vehicle
                                                  2
market has been estimated to be $300-$400 million.   This includes

the money necessary to set up nationwide dealerships as well as the

money required to sustain a fairly high rate of production in order to

produce the vehicle at a cost competitive with the internal combustion

engine.  The possibility exists that independents could reduce such

costs by either selling engines to existing auto manufacturers or by

buying incomplete vehicles (lacking engines and transmissions) from

them.  However, there are serious questions as to whether the auto-

mobile industry would agree to such arrangements on principle, or even
                                                              3
if such arrangements are economically and legally practicable.
1.  William H. Lear, President of Lear Motor Company, Testimony at
Joint gearings on the Federal Low-Emission Vehicle Procurement Act,
Serial Nol 91-51, January 29, 1970, p. 132.

2.  "The Search for a Low Emission Vehicle", Staff Report prepared
for the Committee on Commerce, United States Senate, 1969, p.  23.

3.  Even if auto manufacturers were to agree in principle to purchase "
unconventional powerplants from non-industry sources, there would be
a very serious split liability and warranty problem.  The possibility
of purchasing incomplete vehicles at wholesale prices raises the same
legal problems.  Furthermore, such purchases would create unbalanced
production, procurement, and inventory problems on the part of the
conventional auto manufacturers.  For a more complete discussion of  the
problems facing independent manufacturers, see testimony of William
H. Lear, President of Lear Motor Corporation, Joint Hearings on the
Federal Low-Emission Vehicle Procurement Act, Serial No.  91-51, January
29, 1970, p. 130-32.  Mr. Lear is currently involved in Rankine cycle
(steam car) development.
                                1-41


         .  Research and development funds.   In view of the previous

 discussion, one economic approach  to  stimulate development of Inherently
                            ^.
 low  polluting vehicles is to  provide Independent  contractors with

 research and development funds for the purpose of  allowing them  to meet

 the costs of prototype development.   The National  Air Pollution  Con-

 trol Administration's six-year research and development plan will  pro-

 vide substantial funds for unconventional vehicle  research and de-

 velopment .


           Prototype procurement.  As a further incentive to stimulate

 development of an unconventional vehicle, government at all levels

 could purchase prototype vehicles.   Such a policy would underwrite some

 of the costs of unconventional vehicle development as well  as encourage

 mass  production.   It  also would provide controlled conditions for field

 testing of new concepts  In  automotive  propulsion.

           The  recently announced Federal  Clean Car Incentive  Program

 will provide for purchase of prototypes that meet  performance,  safety,

 durability,  and other requirements  as  well as  low emissions criteria.

 The program  is designed in  three  phases intended to provide graduated

 financial incentives  to private developers.  The Federal Government

will examine data and possibly  test a  few vehicles  in  the prototype

phase, purchase ten vehicles in the demonstration phase, and some 100


-------
                                 1-42
           Distribution.   Direct federal support for the marketing of

 specific  consumer  products by  a segment of  private  Industry  raises

 questions of political acceptability.   An Indirect  subsidy in  the form

 of  a legislatively guaranteed  market provides  a sound alternative;

 it  can substantially  lower marketing and production costs of private
                                                             1
 developers as well as reduce pollution  from federal property.   A

 guaranteed market  will allow a reasonable rate  of initial production

 (the Federal Government purchases 60,000 cars per year), and thus

 initial costs of low-emission  vehicles  can  be made  competitive with

 existing  vehicles.  Also, large  capital  outlays  for nationwide dealer-

 ships  and servicing centers would be unnecessary as  sales and servicing

 can  be provided centrally for  federal agencies.  Procurement legis-

 lation, in addition,  could create a consumer demand  for low emission

 vehicles  which in  turn might stimulate the  conventional auto manufac-
                                 2
 turers to redirect their efforts.

          The cost to government of a guaranteed market plan depends

 upon  the  premium paid for low emission vehicles.  In California,  the
1.  Executive Order No. 11507 (February 4, 1970) to reduce the pol-
lution from federal facilities was recently amended to include vehicles.

2.  A statement made by the Ford Motor Company substantiates this
possibility, ". .  . it is often assumed that our industry would
resist any radical change in automotive power systems because of our
tremendous investment in existing production facilities.  On the
contrary, one of the reasons we are continually examining new power
sources is that we must periodically update our designs, plants, and
equipment to meet the ever changing demands of our customers."
(emphasis supplied)  Cited in  The Search for a Low Emission Vehicle.
Staff Report for the Senate Commerce Committee, 1969.
                                1-43


low emission procurement plan allows the price of an unconventional

vehicle to be double that of a comparable conventional vehicle.  A

recent Senate bill favored a 25 percent differential for improved

conventional vehicles and 50 percent for those with inherently low

polluting engines.  The 1970 Amendments to the Clean Air Act provide

for a 50 percent premium for the improved conventional vehicle and,

like California, permit a 100 premium to be paid for an inherently

low polluting vehicle.  Five million dollars is authorized  for
                                                                 1
Fiscal 1971 and $25 million for each of the two succeeding years.


          Encouraging Development of Low Pollution Fuels

          Since air pollution is the byproduct of the combustion, of fuels,

the development of low pollution fuels should be an important component

of the federal strategy to curb auto air pollution.  The necessity  of

continuous fuel purchase, as opposed to the option of purchasing an emission

control device, reinforces the benefits that would accrue fron  the  avail-

ability of cleaner burning fuels for all cars.


Oil Industry Research

          Current petroleum industry research programs  to develop  low

polluting automotive fuels are directed to three basic  areas:

          1)  Reducing the volatility of gasoline.  This aspect  of  the

auto air pollution problem will be less and less important  as automobiles

-------
                                1-44


with the 1971 evaporative controls are phased Into the vehicle population.

Although auch fuel reformulation would be redundant for automobile*,

hydrocarbon evaporations would be reduced from refineries,  tank farms

tanker trucks and service stations.

          2)  Reducing smog-producing character of gasoline hydrocarbons.

The smog potential of auto emissions could be reduced by replacing the

olefins (photochemically reactive hydrocarbons) in gasoline with less

reactive substitutes.  As above, the fuel marketing chain would also

benefit from this modification.

          3)  Reducing the amount of lead compounds in gasoline.  Lead

compounds are added to gasoline as the cheapest way of raising the octane

rating of gasoline.  A high-octane rated ("premium") fuel is needed by

high compression engines to eliminate engine knock.  The case for the

reduction or elimination of lead in automotive fuels is based on

several factors:

          a)  Health.  Although not conclusively established as a

          hazard to health, consideration of the available  evidence

          along with the associated risks dictate programs  be under-

          taken to reduce or eliminate lead from gasolines.

          b)  Deactivization of catalysts which may be necessary to

          reduce the emission of other pollutants.   The automobile in-

          dustry claims it may not be able to meet future emission

          standards without use of a catalytic type muffler which

          would reduce hydrocarbon and carbon monoxide emissions to
                                 1-45


          harmless carbon dioxide  and water.    Lead  emissions

          rapidly coat  currently known  catalysts  and eventually

          render catalytic devices inoperative.

          c)  Increased emission levels of other  exhaust  pol-

          lutants.  Leaded fuels result in a higher  rate  of

          hydrocarbon emission than non-leaded  fuels.

          The petroleum Industry is committed,  in principle,  to re-

search and development  of low polluting fuels.  The  industry  has much

to gain from the automobile industry's ability  to meet emission standards

with the internal combustion engine.  Although  almost all prospective

vehicle power sources will require  petroleum-based fuel of some sort,

the cost of refinery conversion  from high-octane  petroleum  to,  say

kerosene (steam engine  requirement) would be huge.   It would  necessitate

phaseout of existing refinery facilities and cause major  disruptions  in

a large and established industry.

          Despite the oil industry's desire to see the internal com-,

bustion engine meet future standards, the industry showed initial re-

luctance to remove lead from gasoline.  Estimates of the  total  refinery

conversion costs in order to produce lead-free gasoline range from
                  1
$4.2 - $6 billion.    Marketing an additional fuel would also be costly.
1. Donald D. Kummerfeld, Gregory Wilcox, "Federal Policy on Auto Air
Pollution Control", Research Report  (Washington, D.C.:  Center  for

-------
 1
J

J
                                1-46


Furthermore,  the Industry felt  that,  In view of  the uncertainties sur-

rounding new  automotive  technologies  and the health effects of  lead,

the Administration and auto industry  demands fc?r lead removal were unwar-

ranted.  However, with the auto Industry's announcement that the majority

of 1971 model cars would be designed  to use lower octane unleaded fuels,

and under the threat of legislation which might  ban the use of  lead, all

major gasoline producers have marketed, or will  soon market, lead-free

blends.


                         Direct Regulation

          Although 'Voluntary compliance" has been successful in the de-

velopment and marketing of low-polluting fuels, federal policy makers

have fought for and won the authority to regulate fuels.  The need for

such legislation has been denied strenuously by  oil industry represen-

tatives .


Oil Industry Position

          The oil industry argues that auto air pollution control can

be achieved more effectively by establishing proper emission standards

rather than by imposing marketing and fuel restraints.   The industry

feels that on the basis of its past behavior,  competition within the

industry — as well as between the oil, auto,  and chemical industries —

could be relied upon to achieve reductions in auto pollution.   Not only

does the industry feel that control legislation is unnecessary,  they

argue that regulation of the means by which these industries strive to
                                                                                                                                              1-47
                                                                                                              achieve emission reduction goals will be dangerous to the attainment of
                                                                                                                                   1
                                                                                                              the goals themselves.
                                                                                                              Federal Position

                                                                                                                        Federal officials concerned with auto pollution abatement

                                                                                                              believe that the authority to regulate the composition of fuels Is an

                                                                                                              important safeguard to insure that all promising approaches are pur-

                                                                                                              sued.  This authority could prevent the oil industry from delaying the

                                                                                                              removal of lead or substituting other, possibly dangerous, additives

                                                                                                              in its place.  Also, such authority may allow the Federal Government

                                                                                                              to play an important third party catalyst role in combining the efforts

                                                                                                              of the auto and oil industries to reduce auto air pollution.



                                                                                                              Legislative History.

                                                                                                                        Fuel registration.  The Air Quslity Act of 1967 prohibited the

                                                                                                              introduction into interstate commerce of any fuels designated by the

                                                                                                              Secretary of Health, Education and Welfare unless additives contained
                                                                                                                                                          2
                                                                                                              in such fuels have been registered with HEW.   The purpose of this

                                                                                                              legislation was to permit thorough study of additives to determine pos-

                                                                                                              sible adverse health effects when they or their combustion products

                                                                                                              are emitted into the air.  On June 13, 1970, the Secretary of HEW
1.  See, for example, testimony of Robert C. Gunness, President, Standard
Oil Company of Indiana, Hearings before the House Subcommittee on
Health and Welfare, 91st Congress, Serial No. 91-49, March 5, 1970,
pp. 243-262.


-------
                                1-48


designated motor gasoline as the first fuel requiring registration of

additives.  Information that must be submitted Includes:  the names of

additives, concentration, purpose of each additive and summaries of

Information previously developed on the characteristics and effects of

each additive (see Appendix C for recent related information).  The

Clean Air Act Amendments of 1970 also require the manufacturer, at the

discretion of the Administrator of the Environmental Protection Agency,

to conduct tests into the health effects of fuels or fuel additives.
          Fuel regulation.  The Clean Air Act Amendments of 1970 provide

the authority for federal control over fuel composition.   However,  the

legislation stipulates fh^t no fuel or fuel additive can be controlled

or prohibited unless:

          . . . emission products of such fuel or fuel ad-
          ditive will endanger the public health or welfare
          . . . [or] will Impair to a significant degree
          the performance of any emission control device
          or system which is in general use, or which the
          Administrator finds has been developed to a point
          where in a reasonable time it would be in general
          use were such regulation to be promulgated.1

The legislation also requires consideration of other technologically or

economically feasible means of achieving emission standards before any
                                             2
action is taken to regulate fuel composition.


                       Economic Incentives

Cost of Production

          The Federal Government could subsidize some of the cost of

new refining equipment needed to produce low polluting fuels by  allowing
1.  P.L. 91-604,  Section 211(c).

2.  On January 30,  1970, the EPA Administrator published his  intent  to
regulate the lead content of motor fuels.   See Appendix C for details.
                                                                                                                                   1-49
for accelerated  depreciation of  such investments or by other partial

cost subsidies.  These  are discussed in detail in the accompanying re-
                                     1
port on stationary source pollution.
Cost of Purchase

          In order to provide  Incentives  for  the  purchase of clean

burning fuels, a system might  be devised  that combined both taxes and

tax reductions.  In other words, the more a fuel  pollutes the higher

the tax imposed upon it; conversely, the  lower the  emission potential,

the greater the tax reduction.  The administrative  difficulties of this

type of approach, however, would probably prove too cumbersome for

the scheme to warrant serious  consideration.

          The recent federal attempt to place a $4.25  tax on each pound

of lead additive blended into gasoline is an  example of a discriminatory

tax designed to shift consumer demand to  the  low-polluting fuels.   The

lead tax would, in effect, remove the price differential between leaded

and lead-free gas by adding about 2.3 cents to the  price of leaded
         2
gasoline.
Size of Market

          The greater the market for low-lead fuels,  the greater will

be the motivation of the oil industry to produce low-lead fuels.  As
1.  Governmental Approaches to Air Pollution Control:  A Compendium and
Annotated Bibliography, submitted to the National Air Pollution Control
Administration by the Institute of Public Administration.  Chapter 6,
"Partial Cost Subsidies".

2.  For a more comprehensive discussion of the lead tax, see Ibid.,

-------
                               1-50


mentioned above, the recent decision of the automakers to reduce the

compression ratio of most 1971 model cars so that they could run on

lead—free fuel was an important factor in convincing the oil industry

to market low-lead fuels.  By imposing a discriminatory tax, the Federal

Government could possibly reduce the supply of high compression cars

(see pp. 1-20 through 1-24), or decrease the demand for such cars (see

pp. 2-8 through 2-14 and Chapter 5).  The Federal Government could also

increase market size by requiring government vehicles to use lead-free

gas.  This policy has been adopted.
                         CHAPTER  2


           CONSUMER CONTROL OF AVERAGE EMISSIONS PER MILE


          In Chapter 1, discussion focused on policies aimed at  in-

dustry to reduce average emissions per mile.  In this chapter we

shall consider the consumer, who also has an important role to play

in this regard.  The -.aimer in which he exercises his options to buy

automotive equipment and fuels, and the degree to which he keeps his

car maintained, can significantly affect the quantity of emissions
                1
per mile driven.   As we have already noted, it is more efficient to

monitor individual automobiles on a state or regional rather than on

a national basis.  Consequently, most of the policies discussed  in  this

chapter have been envisaged  for consideration at  the state  level.

          The concept of an "emissions class" will be useful, both

in this and subsequent chapters, as a means of summarizing the extent

to which a motorist exercises his options to control pollution.  The

number of emissions classes represents the range of potential auto-

mobile emission levels — from a nearly pollution-free vehicle to an

almost completely inefficient and ill-maintained "smoke belcher".

These classes could run from one (lowest pollution) to five (highest

pollution),  or even more.  Thus, policy can be conceived as attempting

to influence consumer behavior so that greater numbers of vehicles
                                                                                          1.  Emissions per mile can also be reduced by shutting off engines when
                                                                                          waiting at the curbside for longer than three minutes, maintaining a
                                                                                          constant speed and avoiding stops and starts so far as possible.  However,
                                                                                          the ability to drive in this manner depends largely on the design of the

-------
                                2-2


 are in lower emissions classes.  This can be accomplished by Inducing

 motorists to do any of three things:   purchase a new automobile;  pur-

 chase a "used car" control device; pursue a regular maintenance schedule.

           1.  Purchase a new automobile.   Motorists owning precontrolled

 (pre-1968) cars,  or cars with less sophisticated control  systems  than

 available, could  significantly reduce the pollution associated  with
                                                      1
 their automobile  use by purchase  of a new automobile.   In addition,

 selective choice  of a new vehicle using emissions as an important  com-

 ponent of vehicle choice will make a  substantial difference,  as cur-

 rently there is a wide range in emissions among  new cars  although  all

 have  similar control equipment.   Automobiles with large displacement

 engines,  eight  cylinders and an automatic transmission, for example,

 now emit  more pollution than a comparable vehicle equipped with a
                                                                      2
 small displacement engine, six cylinders, and a  standard  transmission.

           2.  Purchase  a "used  car" control device.  Those motorists

 owning pre-controlled cars could  purchase and have  installed one of

 the several  control  devices  currently on  the market.  As explained in

 Chapter 1  (p. 1-3),  these devices are both relatively Inexpensive  (ap-

 proximately  $50 with Installation) and reportedly highly effective
1.  It should be borne in mind that this strategy probably will not pro-
duce an immediate marked improvement in air quality since many persons
buy used cars, and, furthermore, only a certain potential volume of new
cars is available annually.  All this is to say that there will be only
a gradual phasing out of the older, high-emitting car population —
probably at a rate of 10-12 percent per year.

2.  These differences In emissions associated viith various car character-
istics are only temporary.   Effective with the 1970 models,  an attempt
was made to put all cars on an equitable basis,  irrespective of car size,
engine size, transmission type.  Such equitability will become a reality
in 1972 when a true mass emission measurement procedure is Implemented.
                                  2-3
   (reducing hydrocarbon emissions  by approximately one half and carbon  '
                                                              I
  monoxide and nitrogen oxides emissions  by about one third).

            3.  Maintenance.  All  cars, especially older ones,  could bene-

  fit significantly from an annual tune-up.  One  study conducted recently

  showed that careful tuning of 43 cars resulted  in a  reduction of hydro-

  carbon and carbon monoxide emissions by over SO percent at idle, an
                                          2
  important consideration  in city driving.  Periodic maintenance is also
                                                                     3
  essential to keep pollution control systems operating  efficiently.

            Policies to  induce a  shift in emissions classes can take two

  basic  forms  —  either policy makers can directly regulate the number

  of vehicles  in  different emissions  classes,  for example by. requiring all

  automobiles  to undergo an annual  tune-up,  or  they can apply a discrimina-

  tory tax as  an incentive for motorists  to  move  to a  lower emissions class.

  Some policies of each type will require  the establishment of  state  pro-

 grams to test emission levels while others will  not.   The question  of

 whether to establish a state inspection program  for auto emissions is a

 central decision facing policy makers and will be examined in  detail below.


 1.  Preliminary  evidence  from APCO-conducted tests indicate that used
 car  control devices are not truly as effective as indicated by their
 manufacturers.   Thus,  the material in this section regarding the retro-
 fit  strategy should be  subject to review after true mass experimental
 data become available.

 2.  Although  a complete test  cycle was not investigated, the researchers
 felt a  less  drastic, though significant  improvement would have been ob-
 served.  Cited in  "The Implications  of Lead Removal from Automotive
 Fuel,"  an  Interim  Report of the Commerce  Technical Advisory Board Panel
 on Automotive Fuels and Air Pollution  (June 1970),  p.  15.

3.' Use of low polluting fuels was not included as a  means of  shifting
 from a higher to a lower emission  class.   It is almost impossible to
 devise an integrated policy which  can induce motorists both to re-
duce the pollution potential of their vehicles and  also  to  use clean
burning fuels.  As two distinct policy tacks will be necessary, the
emissions class concept will be used for  classifying policies which  can
accomplish the former while an incentive mechanism will  be  described

-------
J
                                              2-4
                                       Direct Regulation


              Standards

                        As  noted In Chapter 1, the Federal Government has pre-

              empted the right to set emission standards for new motor vehicles

              prior to initial sale.  After transfer of ownership, however, states

              have the right to establish programs regarding emission levels of

            —vehicles registered in the state.  A typical program would involve

              establishing  a set of standards and some sort of required (generally

              annual) emissions test.  On the basis of the measured amount of pol-

              lutant 'OsisEiJms, the vehicle would either be in conformance with the

              standards  or  rejected and required to return after remedial action.

              The precise levels at which the standards are set will determine the

              steps most motorists will have to take to be in compliance.  Strin-

              gent standards, for example, will require drivers of older, pre-

              controlled cars to get a tune-up and probably also purchase retrofit

              equipment. Since It will certainly be Impossible to bring all older cars

              into compliance with the standards,  some will be rejected and perhaps
                                    1
              banned from the roads.   In this way,  a stringent standards approach
              1.   The problem of what to do about cars  that cannot  be brought  into
              compliance with emission standards  is  largely unresolved.   One source
              dismisses it as "one of the many 'sticky'  operational problems that all
              states will face in developing inspection programs."
                      This problem arises only if the standards  (on *ur*i**m allowable
              emissions) approach  is used.   If, as described on page 2-5,  the  standard
              of acceptability  is  defined as the lowest  level of  emissions attainable
              by a  specific car, the problem is avoided  (though at a cost  in air
              quality).  Similarly, a discriminatory tax approach would never  face
              the prospect of banning cars from the road, but would simply charge the
              owner a  large sum for the privilege of disproportionately contaminating
              the air.
                                  2-5


 could have the effect of manipulating all  three components of  emissions

 class shifts — new car purchase, retrofit equipment purchase, and'

 maintenance.  Probably, however, standards will have to be set at a

 fairly low level (see page 2-18) and for most cars will amount essen-

 tially to maintenance requirements, although some pre-1968 models

 may have need of a control device.


 Maintenance Requirement

           A more direct approach to require maintenance of all cars

 would be to establish  "the absence of engine faults that cause un-

 necessarily high emissions" as the standard of acceptability, rather

 than a certain  level of  emissions.  As  the  developers  of this new in-

 spection logic  claim,  "when no pertinent faults exist,  each engine

 is  as good as repairing  agencies can  keep it  and should be regarded
                1
 as  acceptable."   The  test  cycle developed  to determine engine  faults

 provides  valuable diagnostic information for  repair purposes.   This

 approach  is ideal for exploiting the potential of controlled  engines

 and  thus  should become increasingly important in the future when  a

 greater proportion of lower emitting engines are in use.

          In the absence of periodic emission checking, policy makers

 could require motorists to have  their automobiles tuned once a
1.  E. L. Cline and Lee Tinkham, "A Realistic Vehicle Emission In-
spection System" reprinted in The Search for a Low-Emission Vehicle,
United States Senate Commerce Committee Staff Report (Washington, D.C.:

-------
                                 2-6

      1
 year.   As proof, a certificate of compliance could be Issued by the

 servicing facility, and this would be required for annual registration.

 Most authorities agree, however, that mandatory maintenance require-

 ments would severely overburden the servicing facilities of any state,

 and might even lead to a rapid growth in the numbers of inept service

 stations.  The difficulty in providing emissions control maintenance

 for large numbers of cars will be aggravated if ongoing research in-

 dicates that mechanics not specifically trained in emissions reduction

 techniques are Inadequate and training programs have to be intro-

 duced.

           In order to reduce the burden on servicing facilities,

 measures are needed that will choose a certain proportion of .cars

 for annual maintenance.  One approach would be to base maintenance

 requirements on age of vehicle, while another would be to require

 maintenance whenever a car changes  hands.

           The aggregate reduction in automobile emissions resulting

 from general maintenance policies will not be as great as the  reduc-

 tion resulting from a selective maintenance requirement based  on
 1.  One study shows that In the absence  of governmental action only
 about one-third of all motorists normally  get  an  annual tune-up.
 Look magazine survey reported in Ernst and Ernst,  "A  Study of Selected
• Hydrocarbon Emission Controls."  U.S. Department  of Health, Education
 and Welfare,  July 1969.

 2.  One objective of a federally funded  demonstration project under way
 in New Jersey is to determine the degree to which mechanics need be
 trained specifically for pollution control.  New  Jersey Motor Vehicle
 Emission Inspection Project,  December 6, 1966,  to June 30, 1970.  De-
 scribed in Hearings of the Senate Subcommittee on Air and Water Pol-
 lution, 91st Congress, Second Session, Part 1,  pp. 379-380.
                                 2-7

                   1
direct inspection.   However,  the costs of administering any type of

mandatory maintenance  programs would probably be negligible compared

to  the cost of establishing  emission checking programs.
Mandatory Retrofit Requirement

          As discussed  in Chapter  1,  anti-pollution kits are cur-

rently available for  retrofit  on most pre-1968 cars.   Despite the

low cost of these kits  (from $20-$50, Including installation) and

their advertised ability to cut  pollution levels (up to SO percent),

initial evidence shows  that motorists are reluctant to purchase this
          2
equipment.   Consumer demand might be stimulated if the Federal

Government were to certify the effectiveness  of retrofit devices

(see p. 1-3).  Partial  cost subsidies in the  form of an income
                                         3
tax deduction might also increase  sales.   The establishment of na-

tional used car standards would  effect the application of control

devices and was recently considered by the Senate Subcommittee on
1.  The choice of those vehicles with highest emissions as  candidates
for a tune-up is, of course, the special virtue of an emissions
checking program.

2.  An intensely promoted two-month marketing test recently conducted
in Phoenix by a major auto manufacturer revealed that only  528 of a
possible 334,000 owners of pre-1968 cars chose to purchase  the kit
($20), a ratio  of less than 1 in 600.  Cited in Ideas  (Washington,
D.C.:  International Research and Technology, August 1970),  p. 67.

3.  The actual tax saving, however, would probably be negligible.  For
a discussion of this point, see Institute of Public Administration,
"Governmental Approaches to Air Pollution Control:  A Compendium and.
Annotated Bibliography," A Report to the Office of Program Development,
Office of Air Programs, Environmental Protection Agency, Washington,

-------
                               2-9


                       Economic Incentives

           In addition to direct regulation, economic Incentives may

also be used to Induce consumers to shift toward use of vehicles

In lower emissions classes.  Using economic Incentives, two major

policy approaches are available:  registration fees and new car sales

taxes.  A registration fee, for example, might be based on the emissions

class of the vehicle and could be established either to supplement or
                                                        1
to replace standards and/or other regulatory approaches.  In the ab-

sence of a state emission checking program, a new car sales tax could

be imposed.  Presumably it .would be based upon the new car emissions

data available from the Federal Government.
Proposed Legislation

          State level:  California.  The California legislature has

two bills pending which attempt to discourage the purchase of high

emission vehicles through differential taxation.   One bill applies

higher annual registration fees to vehicles with  larger engines;

this assumes that emissions per mile "have a simple relationship

to engine sice as measured by cubic inch displacement.   Table 2-1

shows the graduated taxation  levels as a function  of cubic inch dis-

placement provided in the bill.
 1.   Currently most  states have  discriminatory  registration fees based
 on  vehicle weight,  a vehicle  characteristic  associated with degree of
 potential road "damage".  However, such  fees are  not designed to
 change  consumer preferences,  but  to  raise  revenue for building and
 maintaining  roads.

 2.   State of California Legislature.  Assembly Bill No.  1, 1970,  Re-
 gular Session, January  6, 1970.
                                                                                                                           2-8
 Air and Hater Pollution.   However, ultimately, the Subcommittee

 stated that they "were unable to develop a feasible national system"

 for controlling emissions from used vehicles — It is "a class of

 vehicles for which the regions and states have better opportunities
             2
 to control."

           Precedent for state retrofit requirements can be found in

 California.  The Air Resources Board of that state requires instal-

 lation of used car control devices if they (1) meet certain emission

 reduction criteria, (2) are compatible with at least 75 percent of

 used cars In the State, and (3) cost less than $65.  The cost to

 motorists of installing retrofit emission control devices on all

 pre-1968 model year vehicles (in 1973) is estimated to be SI.6
         3
 billion.   However, in view of the disproportionate share of the

 pollution attributable to pre-1968 vehicles — in 1973 they will

 constitute 40 percent of the automobile population but will con-

 tribute 60 percent of total vehicle emissions — this cost may be

 justified by the increase in air quality.
1.  Committee Print No. 1, August 25, 1970, Section 211,  reprinted
in Hearings before the Subcommittee on Air and Hater Pollution,
United States Senate,  91st Congress, Second Session, Part 5.

2.  National Air Quality Standards Act of 1970, Report of the Com-
mittee on Public Works, United States Senate, September 17, 1970,
p. 13.

3.  At the present time,  however,  the law applies  only  to  crankcase

-------
                                 2-10
                               Table 2-1
               CUBIC INCH DISPLACEMENT AND ANNUAL AMOUNT
                 OF REGISTRATION FEE OF MOTOR VEHICLES
                      (1971 OR LATER YEAR MODEL)
Cubic Inch
Displacement
0-199
200-249
250-299
300-349
350-374
375-399
400-424
425-449
450-
Annual
Licensing Fee
? 30
40
50
70
90
110
140
180
250
           A  second California bill seeks to Influence vehicle choice

 by using discriminatory taxation.1  Specifically, the sales tax

 payable on a particular make and model would be determined by com-

 paring its estimated average emissions of hydrocarbons, carbon

 monoxide, and oxides of nitrogen to the maximum limits for each of

 these pollutants under California law.  The smallest, i.e., worst,
1.  State of California Legislature.   Assembly Bill No.  2035,  1970
Regular Session, April 2,  1970.
                                   2-11


  of the three differences of estimated  emissions  to maximum standards

  would determine the amount of emissions sales  tax.  The  tax levels

  provided In the bill are contained in  Table 2-2.


                               Table 2-2


     AMOUNT OF NEW CAR SALES TAX ON EACH MAKE AND MODEL OF VEHICLE
          BASED ON AVERAGE PERCENTAGES OF EMISSIONS STANDARDS
                                                                                                     Estimated Emissions as a
                                                                                                  Percentage of Maximum Standards
                                                Tax on the Sale of
                                                Sew Motor Vehicles
                                                                                                         Less than 501

                                                                                                            50-60Z

                                                                                                            60-70Z

                                                                                                            70-80*

                                                                                                            80-90Z

                                                                                                            90-100*
                                                      No Tax

                                                       $ 40

                                                         90

                                                        150

                                                        220

                                                       300
           Federal  level.   At the federal level,  there has been little

consideration  given  to  similar  measures.  There  have been two bills

introduced in  the House of Representatives seeking  to make federal

excise taxes a function of engine horsepower  and pollution (see  p.

1-18).  Such taxes, although levied on manufacturers,  will probably

reduce the demand for larger cars (rather  than the  supply)  because


-------
J
                                              2-12


                        The most significant  automobile-related  federal legisla-

              tion attempting  to use a discriminatory  taxing mechanism was  the recent

              Administration .proposal to put  a  tax of  $4.25 on each  pound of  lead

              additive  that   Is blended Into gasoline.  The main purpose of  this

              tax was not revenue, but the creation of an inducement that would

              speed the process toward low-lead or lead-free fuel by making such
                                                                       1
              fuels competitive with the less expensive, leaded  fuels.


                        Problems.  A serious  shortcoming in some of  the legislation

              above is the lack of precision  with which vehicles were1 placed  in

              emissions classes.  In the first  piece of legislation  described,

              registration fees were based on cubic Inch displacement as the  sole

              index of pollution potential.   However,  many other vehicle charac-

              teristics sucn as maintenance,  horsepower, number  of cylinders  and

              type of transmission also determine the  quantity of contaminants

              emitted.  The use of engine size  (or horsepower in the case of  the

              federal legislation mentioned), although a strong  indicator of  re-
                                                                                2
              lative emission  levels, represents a drastic over-simplification.
1.  See also p. 1-31.  An extensive discussion of the lead tax (as an
economic Incentive) may be found in Institute of Public Administration,
"Governmental Approaches to Air Pollution Control:  A Compendium and
Annotated Bibliography," A Report to the Office of Program Development,
Office of Air Programs, Environmental Protection Agency, Washington,
D.C., 1971, pp. 7-20 to 7-24.

2.  One disadvantage is that it provides no information about some
important pollutants for In-service vehicles.  "... cubic inch displace-
ment and several other engine characteristics are not significantly re-
lated to exhaust emissions of oxides of nitrogen or hydrocarbons."  Ralph
d'Arge, Truman Clark, Osman Bublk. Auto Exhaust Emissions Taxes:  Method-
ology mid Sflgtft PrBH**?T>j>iry Tests. Project Clean Air, Research Project
S-12 (University of California:  September 1, 1970), p. 19.
                                 2-13


           This defect could be remedied by placing vehicles In

 emissions classes on the bases of actual measurement, rather than by

 use of non-representative surrogates.  Alternatively, If estimation

 techniques could be perfected, automobiles could be placed in emis-

 sion classes  on the basis of vehicle characteristics.


           Estimation.   A group of California economists recently

 attempted to  identify  and weigh the vehicle characteristics that

 would predict the observed variation in vehicle emissions.  Although

 they statistically examined a large number of vehicle characteristics

 (e.g.,  weight,  average fuel consumption,  engine size and/or horse-

 power), which appear to be highly correlated with average emission

 rates,  they were unable to arrive at equations which would explain
                                                                1
 much of the variation  in observed emission rates among vehicles.


           Economic considerations.   In  both of the California bills,

 the specific  tax schedules provided are quite arbitrary;  no attempt

 was made  to relate the fees for specific  emission classes to the

 proportional  share of  pollution caused  by that class.   Since

 estimates  of  pollution damage  are subject to controversy,  different

 but Internally  consistent  tax  schedules could be developed depending

 upon the  particular  dollar  value  of damages  estimated  for  each ton

 of  automotive emission:
1.  Ralph d'Arge, Truman Clark, Osman Bublk, Auto Exhaust Emissions
Taxes;  Methodology and Some Preliminary Tests, Project Clean Air, Re-

-------
                                2-14
           .  .  .if a ton of gaseous residuals Is assumed to
           cause $1.00 or $10.00 In social damages,  the-
           absolute magnitude of tax by vehicle type will
           change, but the degree of proportional discrimi-
           nation will not change.  Motor vehicles with
           higher amounts of "potential" emissions will be
           taxed at higher rates, but the relative differen-
           tials between high and low polluting vehicles
           will remain constant regardless of the dollar
           amount of damages per ton of pollutants that Is
           assumed.

Although an Improvement over arbitrary tax schedules, such a schedule

would be equitable only If automobile usage (e.g., miles driven per

year) and location of predominant use (e.g., urban driving),  the

other key components In determining pollution damage, vary approxi-

mately the same within each class.  But these assumptions appear un-

realistic.  A certain class of vehicles, for example, may be driven

primarily for excursions In the  country, in which case the tax as-

sociated with its  class would overstate the class's proportional

contribution to air pollution damage and hence overcharge  the owner.

Consequently, in  the absence of  any hard data  to the contrary, the

assumption that usage and  location vary equally for each class of
                                  2	
vehicles appears  to be  untenable. - Similarly,  there are equity problems

for individual motorists whose  usage habits  differ  from "average" habits.
 1.   Ralph d'Arge, Truman Clark, Osman Bubik, Auto Exhaust Emissions
 Taxes;  Methodology  and Some Preliminary Tests.  Project Clean Air,
 Research Project S-12  (University of California:  September 1, 1970), p. 11.

 2.   It  could be argued, of  course,  that the average payment for each
 class of vehicles would probably be equitable.  However, although each
 class as a  group would probably pay its proper  share, almost certainly
 most individual owners would not.   For instance, car owners using
 their vehicles exclusively  in  the country  or well ventilated areas
 would be overpaying  as would "weekend" drivers.  In short, equitable
 treatment will not be  accorded to those whose automobile usage habits
 vary significantly from "average" habits.
                                  2-15


           These Inequities might be alleviated  by  developing  tax schemes

 which relate emission classes  to location  of  emissions or  to  intensity

 of automobile usage, or preferably, to both.  Such schemes are dis-

 cussed in detail in Chapter 5, "Emission Charge Systems".


           Political considerations.  A difficult political choice will

 be posed if discriminatory registration fees are to be applied Co the

 registration of all cars.  To the extent that older, high  pollution

 emitting cars are  generally owned by poorer Individuals,  such a tax

 would tend to be regressive.   This impact could be mitigated by ad-

 justing  the tax schedule for  age of vehicle — a two-year old auto-

 mobile In a certain emissions class would pay a larger tax than a

 four-year old vehicle with Identical emissions.   At the same time, of

 course,  adjustments of  this sort will  reduce the incentive  to dis-

 pose  of  older cars  and purchase a new  car  or retrofit equipment.


                 State Emission Checking Programs

          Up  to  this point, the  approaches  to  auto.air pollution  con-

 trol  have been discussed without  regard to  the desirability of estab-

 lishing a state auto inspection program for auto emissions. This  sec-

 tion will describe  some of the basic considerations surrounding a

 state's decision to introduce such a program.

          Ideally,   the decision to establish a costly  emission checking

program would be based on projections of the needed reduction  in ag-

gregate emissions in a particular state to maintain healthful  air


-------
                                2-17


result In a larger aggregate amount of reduction although the coat

per unit weight will be higher than with the retrofit device approach.

Policy makers should attempt to make precisely such comparisons for

policies and combinations of policies available both with and without

Inspection programs before embarking upon such a costly course of

action as establishing a state-wide system for auto emission Inspec-

tions.  This will not be an easy task for the costs and benefits of

emission checking programs are highly uncertain.


          Costs.  The cost of establishing an emissions checking

program (including equipment) for the entire United States is

estimated to be more than $100 million.   The cost would vary from

state to state depending upon whether or not the emissions program

will be added to an existing safety inspection program, or be the
                                  1
focus of an entirely new program.   The cost will also depend upon

the way in which the program is administered — at state-operated

facilities, at state-appointed service stations, or by random spot
       2
checks.   The latter will be the least costly of programs, but will
 1.   Currently 31  states  (sod  the District of Columbia) have periodic
 motor vehicle safety inspection programs, and seven states have some
 form of random spot  Inspection.

 2.   Of the 32 jurisdictions that have periodic inspection programs,
 29  operate under  a state-appointed  system.  Only three jurisdictions
 have central,  state-operated  inspection  facilities.
                                 2-16


 compare cost* and benefits of policies available with an Inspection

 program and policies available without such a program.  Table 2-3

 summarizes the major policy alternatives aimed at consumer control

 of average emissions per mile which are available both with and

 without an emission checking program.   In general, policies aimed

 at regulating emission classes require knowledge of emission ratings,

 while measures directed at specific components of emissions classes

 do not.


                             Table 2-3


  POLICIES AIMED AT CONSUMERS TO CONTROL AVERAGE EMISSIONS  PER MILE
  With Emission  Checking
  	Programs	
     With or Without Emission
        Checking Programs	
  1.  Standards

  2.  Selective Maintenance

  3.  Discriminatory Registration
     Fee
1.  Mandatory Maintenance Re-
    quirement

2.  Mandatory Purchase of
    Retrofit Equipment

3.  Discriminatory New Car
    Sales Tax
           This  categorization  facilitates systematic  comparison  of

policy alternatives.  For example, making one comparison, it is quite

possible that requiring the purchase of retrofit equipment — if such

devices actually meet manufacturers' claims  (see fn. 1, p. 2-3} —

may be more cost effective than establishing a state-wide emissions


-------
                               2-18


result in the smallest decrease In aggregate emissions,  as this

criterion is directly related to the proportion of vehicles tested.

The organization of the program will determine to & large extent

which of several possible types of test equipment and evaluative

routines can be efficiently employed.

          Federal funds are available to states under the Air

Quality Act of 1967 for partial support of almost all phases of

establishing and operating an emission checking program:  program

development (two-thirds grants, Section 209); training and demonstra-

tions (Section 103(a)(2)> and  (b)(3)); instrumentation  (Section
                                                 1
10A(b)(l)); program maintenance (Section 105(a)).
          J^iXcfits.  The amount of reduction in emissions will be

determined by the accuracy of the test procedure and the level at

which the rejection rate can be set (assuming a standards approach

will be used).  Evidence indicates rejection rates will have to be
                     2                      3
lower than 20 percent  or perhaps 40 percent  in order to prevent

a critical overload of commercial repair facilities and eliminate
1.  The Clean Air Act Amendments of 1970 renumbers as well as makes
minor modifications in some of these provisions.

2.  Ernst and Ernst, "A Study of Selected Hydrocarbon Emission Con-
trols", U.S. Department of Health, Education and  Welfare,  July 1969.

3.  Marian F. Chew, "Auto Smog at Idle Only," Society of  Automotive
Engineers, No. 690505, May 1969.
                                 2-19


the heavy burden on  the  Inspection system that would occur in the

way of demands for a retest.  Also making accurate estimation of  bene-

fits difficult, there is great uncertainty concerning the  amount  of

emission reduction possible from post-1970 model vehicles. However

one fact is clear:   the cost per ton of reduction for composite emis-

sions Increases with time.  This occurs because cost* are  increasing

while potential emission reductions are decreasing.   Costs will Increase

simply because vehicle population increases and more  tests and repairs

are therefore required.  Potential emissions reductions will  decrease

because the federal  standards strategy (as outlined in Chapter 1) will

drive down the base  levels of emissions.

          Another uncertainty about benefits is the extent to which

motorists will deliberately alter the emission levels of their cars.

If checking is done  on a scheduled basis,  some motorists might not

scruple to have their engines fine-tuned  in order to  pass  the test,

and then have them retuned for maximum performance regardless of

the accompanying Increase in pollution.   Furthermore,  since pol-

lution control systems would probably be  external to  the engine,

it would be a simple matter to disconnect  the  system  after passing
         1
the test.   Less extensive engine readjustments (e.g., manipulation of

the fuel-air mixture) could also have a major  impact  on the engine's

emissions.  Although an emissions checking program would probably
1.  The Federal Government and the State of California have laws
prohibiting manipulations of pollution control systems that render
such systems less effective.  However, the effects, if any, of this

-------
                                2-20


curb many such abuses, deliberate avoidance of proper classification

on the part of those determined to do so could not easily be pre-

vented until a better monitoring system becomes available than Is now

In existence.  Under present conditions, the appeal of deceptive prac-

tices could be reduced by sealing the carburetor at the time of In-

spection, Instituting random spot checks, or Imposing fines where the

results of spot checks revealed a significant increase above a pre-

viously recorded emissions level.

          To sum up, the attempt to obtain an accurate estimate of

the aggregate pollution reduction resulting from the creation of a

statewide emission checking program is a highly uncertain process —

it Involves forecasting the nature and cost feasibility of future

monitoring technology, future automobile emission characteristics

and the behavior of motorists.


          Current status.  Although a careful evaluation of the need

for establishing formal emission inspection programs on a state by

state basis is lacking, there is strong Congressional pressure for

states, especially those with severe air pollution problems, to estab-

lish such programs.  At the present time, however, no state has ap-

plied for the two-thirds grant for developing emission inspection

programs, largely because of problems with measurement technology.

Seeking to eliminate this roadblock, the Federal Government made

a grant to the State of New Jersey to support the development of
                                 2-21

                                                 1
 emissions testing procedures for state programs.   A "quick" cycle

 emission testing procedure was developed during the course of this

 demonstration project.   Although this test procedure Is rapid (90

 seconds) and inexpensive,  doubts may be expressed about its ac-
        2
 curacy.    Accelerated federal-supported research will probably soon

 result in the development  of a quick, reliable,  and cheap test.

 Then federal and public  pressure will probably  cause most states  with

 air  pollution problems to  incorporate emissions  testing into their
                                     3
 periodic safety  inspection programs,  or,  alternatively,  to establish
                               4
 independent  emission  programs.
1.  New Jersey Motor Vehicle Emission Inspection Project, December
6, 1966-June 30, 1970.  Described In Hearings of the Senate Sub-
committee on Air and Water Pollution, 91st Congress, Second Session.
Part 1, pp. 379-380

2.  In general, most "quick" cycles rely on the unproven correlation
between the results of tests on a few modes of engine operation and
the results of tests on the full seven-mode Federal cycle.  Although
"average correlation" may be excellent, there is significant doubt
about vehicle by vehicle correlation.

3.  All states currently have plans for periodic state Inspections in
order to quality for federal highway construction aid.

4.  The Clean Air Act Amendments of 1970 require that states include
in their air quality Implementation plans provision for periodic
emission checking of motor vehicles "to the extent necessary and

-------
                         CHAPTER   3


                 CONTROL OF MILES DRIVEN PER TEAR


        In the preceding two chapters, discussion focused on govern-

 mental approaches to reduce average automobile emissions per mile of

 use.  This chapter will consider policies which can limit the number

 of miles of private automobile use.  This will be especially Important

 since automobile usage Is expected to grow rapidly for the remainder

 of this century.  According to APCO estimates, annual  automobile miles

 will Increase from 838 billion in 1970  to 989 billion  in 1975.    If

 this 3 percent annual rise continues, automobile  usage will increase

 by billions  of miles  in the near future.  As  a result,  the  aggregate

 number of miles  driven  per year will assume an increasingly Important

 role as a producer of auto air  pollution.

       A significant reduction  in annual miles driven essentially im-

 plies moving away  from  an  automobile-centered  society.  This, of course,

 raises difficult cultural  questions as well as  political and economic

 ones.  With regard to the  latter, a significantly reduced  dependence

 on  the private automobile  is likely to have major economic repercussions.
1
1.  The manufacture of motor vehicles and parts Is the largest  industry
in America — first in sales, first in employment and first  in  payrolls.
Automobile manufacturing and distribution and automotive transporta-
tion provide some IS million jobs (28 percent of private non-farm em-
ployment).  Furthermore, each car and truck manufactured and sold in the
United States generates $1,200 in taxes,  and these taxes provide  5 percent

                   .     •  •,      ,                (continued  on  next page)
                                  3-2


   Consequently, attention here will be  on the possibility of making

   "modest" inroads in reducing automobile use or, perhaps,  reducing

   the rate of increase of automobile use.  Achieving either  of these

   goals could result in noticeable air quality gains in the next few

   years because of the high proportion of pre-controlled and partially

   controlled  cars  that will  be on the  roads.   Furthermore, small re-

   ductions  in automobile  use In  specific urban locations could greatly

   mitigate pollution damage.

         It should be realized that  fundamental changes  in the way

  private transportation needs are being met are being sought  for many

  other reasons besides air pollution considerations.  The quality of

  transportation affects  the economic efficiency of cities and the life

  style of  city dwellers  as  do few other  services.   The fact is,  how-

  ever,  that certain groups  (the young, the old,  the  poor,  the incapaci-

  tated) are not well served  by automobile-centered transportation

 systems.  Furthermore, automobiles  co-opt huge amounts  of valuable

 urban space, especially in high density business areas with large

 concentrations of high rise buildings.  The omnipresent congestion  .

 in such areas (as well as others) causes huge losses in time for mil-

 lions of people dally, not  to mention  the accompanying fatigue and


 (continued from previous  page)

of the  total  tax revenue  of  all units of  government.
Source:  Statement by L. A.  lacocca, Ford  Motor Company, September 9,
1970.  Reprinted in Hearings before  the Subcommittee on Air  and Water
Pollution,  United States Senate, 91st Congress, Second Session, Part 5,

-------
             •     • •           3-3       -


nervous strain.  Thai, decisions on measures to limit automobile uae

presumably would Include evaluation of a broad spectrum of cost and

benefits — air pollution being only one consideration, albeit a high

priority one.  Although reference will occasionally be made to the

broad Implications of various policy approaches, this chapter will

devote almost exclusive attention to the air pollution aspects of

limiting automobile use.

          Direct approaches to reduce miles driven can be classified into

two basic categories:  direct controls over vehicle use and imposition

of a tax or other price control related to vehicle use.  Within these

general categories, consideration will focus both on measures to reduce

aggregate miles driven and measures which can reduce automobile use

specifically in congested urban areas.                               __

          Mass transit — to the extent that it may have potential to

displace automobile use — will also be discussed as an indirect ap-

proach to reducing miles driven.  In addition, consideration will be

given to enlightened urban design, which through alteration of the basic

spatial relationships between people and activities, can possibly re-

duce average trip length and also make economical mass transit systems

possible.


                        Vehicle Use Controls

Direct Regulation

          Direct control over the aggregate number of miles per year

motorists drive generally implies some sort of rationing — most likely
                               3-*


fuel rationing.  To limit automobile use  In congested urban area*,

rationing road use, parking spaces and  rights of way (to high occupancy

vehicles) could discourage private automobile use  In these critical

areas.


       Fuel and vehicle rationing.  Controlling the consumption of

automobile fuel via a rationing mechanism could result in a rapid de-

crease In automobile use.  However, in  the absence of widespread health

disasters attributable to pollutants from automobiles, It is highly

unlikely that such a large intrusion of government into the private

sector would be deemed politically feasible or desirable.  The severe

economic repercussions caused by rationing, the difficulty in providing

equity, and the enormous cost of enforcement also  mitigate against

adoption of such a policy.  Instead, for  cases of  prolonged catastrophe

or in order to prevent localized emergencies from  spreading,  direct

restrictions on the location of automobile use will generally provide

a more desirable alternative.
                                                                      1
          In view of the increasing trend toward multi-car households,

limiting the number of automobile registrations per household provides
1.  Twenty-nine percent of all U.S. households in 1969 owned two or
more cars, an increase of 10 percent from 1961.  When compared to car-
owning households, the number of multi-car households is considerably
larger — 36.5 percent.
Source:  Estimated by Automobile Manufacturers Association from U.S. De-
partment of Commerce, Bureau of the Census, Population Characterlaties
(Series P-20) and Consumer Buying Indicators (Series P-65).  Cited in
1970 "Automobile Facts and Figures", Automobile Manufacturers Associa-

-------
                                3-5
another alternative to reducing miles driven.  Although probably easier
                                                                     1
to enforce than fuel rationing, It has the same serious shortcomings.
          Traffic ban*.  Direct restrictions on location of permissible

vehicle operation could discourage automobile use if such restrictions

were sufficiently extensive to make driving inconvenient (or impos-

sible).  Small scale traffic bans may very well serve only to alter

traffic patterns rather than reduce vehicle use.  Since bans must be

viewed as an approach to control the location of vehicle use, this

concept will be discussed at length in Chapter 4.
          Parking restrictions.   Limitations of on-street parking when

paired with strict enforcement ran discourage motorists  from  taking

their cars into the downtown area.  In New York uity,  each week some

1,000 motorists have their Illegally parked vehicles  towed away, re-
                     2
suiting in a $75 fine.    Allocating the existing parking spaces to city

residents would make parking increasingly  difficult for  those living in
1.  The New Jersey Clean Air Council recently considered this measure but
had doubts about the "fairness or even the constitutionality of such con-
trol."  See "The Report of the New Jersey Clean Air Council on the Status
of Air Pollution from Mobile Sources" (July 1970), p. 31.

          With the risk of pushing an analogy too far, it would seem that
steps should be taken with respect to automobile ownership similar to
those used to instruct the public in the virtue of limiting the size of
families.  Partially as a result of widespread publicity, it is widely
felt that more than two children adds to the overpopulation problem,  but
seldom Is any consideration given to the environmental consequence of
owning two or three cars.'

2.  J'The Baa-the-Car Movement.". In Newmreak (January It,  1971),  p.  42.
                                                                                                                                 3-6
outlying districts.  Boston, for example, now  limits  all nighttime street

parking to city residents who display a special sticker  on their windshield.


          Preferential lanes.  Separate lanes  for buses  (see below)  and

cars with more than one occupant could Increase average  trip speed and

thus provide Impetus for mass transit ridershlp and car  pool formation.
Financial Incentives

          Cost per mile is a factor which undoubtedly  can influence motor

vehicle use.  However, in comparison to the large sunk cost  involved  in

automobile ownership, operating costs generally  tend to be small  and  are

thus often overlooked by automobile owners.  But if the cost per  mile of

driving were.to increase substantially, motorists would probably  attempt

to use each mile of driving more efficiently by  such practices as the

formation of car pools, less frequent shopping or short pleasure  excursions,
                  2              3
using mass transit  and the like.
1.  "The Ban-the-Car Movement," in Newsweek  (January  4,  1971),  p.  42.

2.  Researchers have found,  however,  that price differentials may have
only a limited effect.   "The point of equilibrium between automobiles
and mass transit does not seem  to be  the  economists'  dollar point, but
the perception of  that  point by the individual user through the values
he has acquired by using the automobile,  the way it has affected his
experience, his range of choices and  preferences."  Ibrahim M. Janmal
"Vehicular Air Pollution:  Variables  Influencing the Urban Transporta-
tion System" in Air Quality  Standards,  Arthur Atkisson and Richard S.
Galnes, Ed. (Columbus,  Ohio:  Charles E.  Merril, 1970),  p. 131.

 1.  The  major benefits  of  applying price controls to vehicle use may
be longer term.   As noted  above,  the additional costs of use will
probably be small relative to the purchase price of the car, and,
hence, may, not have short  run impact.  However, such controls (with
suitable mass transit available)  may mitigate the increasing trend
toward multi-vehicle ownership as the cost  of having a second (or
third) car increase significantly.   Although, on average, a one-car
 family will make more Intensive use of the family automobile,  the
aaount  of miles driven will generally be considerably less  than the

-------
                                3-7
          Direct usage tax.  In the absence of sophisticated monitoring

devices to measure Individual automobile use reliably and Inexpensively,
                                              1
a surrogate for miles driven must be employed.   Since there is a di-

rect correlation between number of miles driven and fuel consumption,

taxes on fuel sales would appear to be one of the most efficient means

of inducing a reduction in the aggregate number of miles driven.  The

degree to which a tax on fuel can reduce automobile usage Is related to

the sice of the tax and the sensitivity of consumer demand to price
          2
increases.

          A tax on fuel for this purpose, however, has certain problems.

First, since taxes on fuel account for approximately 30 percent of the

CO»L uf -fuel, the reaction to additional taxes by both the petroleum

interests and the motoring public would probably be particularly negative.

Second, a tax on fuel would not be an efficient or equitable approach

to reduce pollution damage (as distinct from pollution magnitude).  A

simple fuel tax implemented to reduce air pollution essentially represents

the air polltuion damage from driving an "average" automobile in an

"average" location.  However, since it does not discriminate on the

basis of the vehicle for which the fuel was purchased, such a fuel tax

would neither charge the owner of a high (or low) emission vehicle for

his disparate share of the pollution, nor would it provide any in-

centive to drive lower emitting vehicles.  In addition, and more important
1.  The possibility of direct monitoring of vehicle use will be dis-
cussed in Chapter 5.

2.  One study has found consumer demand for automobile fuel to be re-
latively inelastic, that is, generally Insensitive to Increases in
price, especially in the short run.  B. S. Houtthaker, L.' D. Taylor,
Consumer Demand in the United States. 1929-1970 (Cambridge, Mass:
Harvard University Press, 1966).
                               3-8


 for  the  discussion here,  a simple fuel tax,  by not discriminating on

 the  basis  of  location of  use,  will tend to reduce automobile usage

 uniformly  in  all  areas.   The cost to  society of a given quantity of

 automobile emissions,  however, is directly related to  the location In

 which  the  vehicle is  operated  —  in general,  the greater the existing

 level  of pollution, the greater the damage that will be caused by an

 incremental amount.  Thus,  a more efficient  and equitable policy would

 discriminate  on the basis of location of miles driven  and assess charges

 to individual motorists according to  the estimated air pollution damage
                                                  1
 of a trip  of  given length in a specific location.


 Other  Financial Incentives

           Various other financial incentives are available to dis-

 courage  private automobile use, especially for transportation in down-

 town areas.   These incentives  include parking taxes, connutation taxes,

 and  tax  rebates for car pool drivers.


           Parking taxes.   Heavy parking taxes could discourage auto-

 mobile use in congested areas.  San Francisco,  for example,  has Imposed

 a 25 percent  tax  on parking fees  in private  garages.   Similar in result

 to parking taxes,  the  reduction or  elimination  of  the  generally heavy

 indirect subsidy  to motorists who park  in major  urban  areas would doubt-

 less result in  a  large increase in  parking costs.   Such policies,  however,
1.  An ideal policy would discriminate on magnitude of emissions in a
given location.  Miles driven is only one component of emission magni-
tude — the other being the emission characteristics of the source
(emission class).  This concept will be treated in greater detail in

-------
                               3-9


 tend to penalize local traffic for using downtown road space, while

 exempting through traffic from this financial burden.  These policies

 also require that transportation alternatives be provided concurrently,

 or else parking becomes a rich man's luxury.


           Commutation taxes.  Cities with limited access routes such

 as New York  could impose heavy tolls at bridges, tunnels,  and highways

 leading into the city.  This toll could be based on vehicle occupancy

 In order to promote car pools.  Clearly, however, this measure cannot

 be used where access to an urban area is not confined to bridges and

 tunnels.  And even in New York, the implementation of this  meausre

 would require installation of expensive toll collection stations at

 each point of entry.


           Tax rebates.  As a stimulus to car pool formation,  a number

 of proposals have been made in state legislatures (noticeably Cali-

 fornia)  to forego gasoline taxes  and taxes on parking fees  for car-

 pool drivers.   The administrative feasibility of  tax rebates  or exemp-

 tions is questionable, as  it  is not clear  how car-pool ridership could

 be validated for  such purposes.


                           Mass Transit 1

           Perhaps  the most profound reduction in  automobile miles

 driven could be achieved by fundamental  changes in  the way private

 transportation needs  are met.  At present,  urban  transporation  systems
1.  The authors wish to express their appreciation and thanks to Sumner
Myers and Joseph Revis of the Institute of Public Administration for
their.insights on the interface between air pollution control and trans-
portation policy.
                                 3-10


                                                                1
   in most U.S. cities rely primarily on the private automobile.   Mass

   transit, however,  offers the possibility that automobile usage could

   be reduced,  especially for commutation to work which accounts for ap-

   proximately  SO percent of  all automobile trips.


   Historical Federal Transportation Support


            Heretofore,  the strategy for meeting the nation's  transporta-

  tion needs has been dominated by new highway construction.  The state

  and local commitment to highways is  attributable, in large measure,

  to  the  lucrative  federal aid for highway  construction — the Federal

  Government furnishes  90 percent  of the  money  to build the money  to

 build the Interstate  Highway System, the  states only  10  percent.  The

 huge sums of interstate money, as well as the 50-50 matching  funds  of

 other federal-aid highway programs, have lured — if not  forced —

 cities and states into emphasizing highways over mass transit.

           The  Highway Trust  Fund,  created  by Congress in 1956, was

 originally established to build the interstate system,  but it is  now

 also  the source of all federal  funds for federal-aid primary  and



 1.  On a national basis,  for example, 82 percent of commuting workers
use automobiles as a means of transport while only 14 percent use
public transportation.   U.S. Department of Commerce, Bureau of  the
Census, "Home to Work  Travel Survey", reprinted in 1970 Automobile

-------
                                3-11
                                                                          1
  secondary  roads.   Although the Fund has a huge annual influx of revenue,

  and contains most  of  the  federal money available for transportation of
                                                           2
  any kind,  it is dedicated solely to highway  construction.    Consequently,

  federal support for mass  transit (approximately $600 million between

  1964 and 1970) has been meager  in comparison to the  annual federal  out-

 lay for highway construction (approximately  $4  billion annually).

           Increased highway construction, in conjunction with  the ap-

 parent public preference for the speed, comfort, and  convenience of the

 private automobile has generated additional  traffic which  in turn has

 led to a need for more highways. As a result,  urban mass  transit is

 caught in a cycle of  increasing costs and fares, and decreasing quality,
                      3
 traffic,  and profits.    Recent  legislation, however,  as.well as legis-

 lative proposals  and statements of government officials  indicate the

 tide is turning toward drastically increased  federal  support for


 1.   The Fund currently has a claim  on about 71  percent of all federal
 excise taxes related  to highway use, including  the AC per gallon motor
 fuel tax.   Revenues to the Fund in  Fiscal 1969  totaled $4.7 billion.
 An  increase in this amount to some  $5.4 billion is expected in 1971
 as  tax revenues rise.   Data cited in  Conservation Foundation Letter
 (Washington, D.C:   June 1970),  p. 3.  Legislation also has been intro-
 duced  to increase the  revenue flowing into the  Fund.   One bill intro-
 duced  in a  recent session  of Congress would have turned  over to the Fund
 all revenues from the  7 percent excise tax on automobiles (approxi-
 mately $1.9 billion annually).   H.R.  16604 (Findley), 91st Congress.

 2.  Recent  legislation has  "opened"  the Fund  slightly to  permit funding
 of  certain  highway  related  projects  other  than  construction.   There  is
 increasing  pressure for legislation  to permit the Fund to be used for
 general transportation purposes.  See  pp.  3-19  to 3-21.

 3.  Passenger volume on mass transit systems  fell by some 54  percent
between 1950 and 1969,  while it  is estimated  that mass transit  systems
lost nearly $300 million over the last  five years.
                                 3-12


   construction, improvement, and possibly even subsidy of mass  transit

   system operating costs.


            Before examining the current outlook for federal support of

   mass transit systems,  it will be meaningful to examine the potential

   of mass  transit  systems to displace automobile use.   Since present

   concepts offer the most immediate payoff,  new  construction of  rail sys-

   tems and improvements  to  existing rail and bus systems will be considered
        1

   first.   Discussion will  then  turn  to several radically new mass  transit

   concepts (e.g., dial-a-bus systems) which will be made possible by

  breakthroughs in urban transportation technology.


            Rail.   Although rail systems have demonstrated a capacity
                                                        .        2
  to effect  a shift in  the transportation mode from automobiles,    this

  form  of mass transit  appears to have only slight promise for air

  quality improvements  on a national basis.   At present,  fewer than two


  1.  One expert feels  too much  effort is being concentrated  on futuristic
  schemes with  a concomitant neglect of  the short range potential that
  can be realized within  three to five years  by focusing on existing con-
  cepts with existing technology.  See Sunnier Myers, "Technology  and
  Drban transit", Business Horizons  (Spring 1967).

 2.  A high speed rail project instituted a few years ago from the
 village of Skokle to downtown Chicago resulted in shifting approxi-
 mately 2,000 daily auto trips to mass transit facilities.   The auto-
 mobile and  Air Pollution, A Program for Progress (U.S.  Department of
 Commerce: October  1967), p. 33.
          More  recently,  the New Jersey State Department of Environ-
          tection  reports  that  the  'Mi-am.*-'-  '	
mental Protection repots that the'-drL^f6/6"3"1116" °f Envlro
the PATCO lines between Linden W»L £!^l.??r~y_1? '"«-"P
            	  »^,Ui.i.i>  i-nat  cne  "dramatic  increase  in ridership on
the PATCO lines between Linden Wald  (New Jersey) and Philadelphia  has
shown quite clearly that passeneer r-ar /.™™..-	     •
                	u.*uucu «aj.a mew Jersey) and Philadelphia he
shown quite clearly that passenger car commuters can be attracted by
rapid, convenient, economical, and r^™*"*-*--1-1-    '•
              	, —..uu.i^oj., ana comfortable rapid transit systems.
Report of the Mew Jersey Clean Air Council on the Status of Pollution

-------
                               3-13


 dozen cities have the kind of high density channel demand effectively
                1
 served by rail.   In the overwhelming majority of cities, the spatial

 arrangement of activities Is such that most potential riders would be

 going where the rail system would not.  This is especially true of

 the potential of rail systems "in the other direction",  i.e.,  carrying

 center city residents to suburban jobs.   Surveys Indicate that neither

 the new rail system planned for Washington, nor the new  San Francisco

 system (see below)  will effectively accomodate the transportation needs

 of inner city residents who work in outlying areas.   Nor do rail systems

 linking suburbs and central cities provide for non-radial trip needs

 from suburban areas where population and employment are  growing most

 rapidly.

           What is more, rail transit may actually alter  the spatial

 arrangement of activities in the urban environment to the detriment of

 pollution control.   There is evidence that rail improvements accelerate

 decentralizaton of  urban areas,  and consequently increase average trip

 length and the need for automobile use to serve low-density, non-radial

 trip demands.   Also,  the lessened congestion in downtown areas associated

 with rail improvements may be short lived.   Areas surrounding  the terminal

 are quickly developed and,  attracted by  lessened congestion, automobile

 use in the area may actually increase.    Hence the net gain in downtown

 air quality from rail improvements may be eliminated.
. 1.  Currently only New York,  Chicago,  Philadelphia,  Boston,  and Cleve-
 land have rail transit.  New  rail transit systems are being  built in
 San Francisco and Washington, D.C.
                              3-14


          In sum, although rapid rail systems are often  advocated  as

a means of easing congestion and reducing air pollution,  there  appears

to be little evidence to support either of these contentions.   For this

reason, careful attention will be focused on San Francisco's Bay Area

Rapid Transit (BART) system which is the epitome of a modern rapid rail

system.  If BART's patronage, revenues, and earnings measure up to

expectations when it begins service later this year, it  probably will

serve as Impetus for Increased federal funding of rail systems.  With

substantial federal support, approximately six cities (Seattle, Balti-

more, Los Angeles, Atlanta, St. Louis and Pittsburgh) could be  ex-

pected to get new systems under way.  Before such evidence Is gathered,

new rail systems probably should be viewed as a long term, high-cost

(first-stage BART will cost about $1 billion), high risk approach.


          Bus.  In contrast to rail, bus and other mass  transit designs

capable of economically serving a relatively low channel density have more

recognizable potential in most cities to "shift transportation demand
                                 1
away from the private automobile.   The primary reasons  buses have not

realized more of this potential is related to three factors:

          1.  The vehicle itself is frequently unpleasant and un-

          comfortable.
1.  In some cities, however, origins and destinations will be so
scattered that fixed route bus systems will not be .economical since
buses require fairly high average occupancy because' of  the high labor

-------
3
                                               3-15


                           2.   Routes  and schedules  often are poorly adapted to

                           changing travel demands as well as insufficiently

                           publicized.

                           3.   Buses (as they are now operated)  are hapless  victims

                           of  urban congestion.

                 The first factor can be remedied rather easily  by vehicle redesign and

                 the second by well-established analytical techniques and publicity

                 campaigns. However,  remedial action with respect to the third factor

                 is much more  difficult; a minimum requirement is  that buses be given

                 .priority over private cars in entering and using  highway and street

                 systems.  This Implies the creation of exclusive  "bus lanes",  the

                 organization  of reserved loading and unloading  zones and a  priority

                 system for buses at Intersections.   The provision of exclusive lanes

                 on highways has proved successful in reducing1 trip times and in in-
                                    1
                 creasing ridership,  but it may prove extremely costly and  politically

                 difficult to  establish priorities for buses in  city areas.   In this

                 case,  the most effective way of increasing bus  ridership will be to

                 get all traffic to flow faster.  Since increasing average speed will

                 also reduce source emissions, this  result would have a two-fold

                 benefit.
                 1.   In an ongoing experiment,  one line of Shirley Highway into Washing-
                 ton from suburban Virginia has been reserved for buses.   Initial data
                 show  that commuting  time has  been cut 30 minutes from outlying dis-
                 tricts and ridership  has  increased 19 percent.
                 Source:   "The Agony of  the Commuter", Hewsweek  (January  18,  1971),
                 p.  48.
                               3-16

                                                             1
           As Information in the following chapter Indicates,  the ap-

 plication of planning techniques and flow control technology will

 probably be able to greatly Increase average speed.  If such is Indeed

 the case, and priority treatment Is given to buses so that they main-

 tain a relative advantage over automobiles, bus ridership will probably

 increase with a concomitant decrease in automobile miles driven.

                                     2
           New mass transit concepts.   Several technological Innovations

 designed to meet specific transportation needs hold out promise to re-

 duce the dependence on the private automobile.  For example, the taxi-

 bus (sometimes called "dlal-a-bus") system, can service the demand for

 non-radial, low density traffic which at present can only be met economi-

 cally by the automobile.   This is a computerized mini-bus system which

 utilizes sophisticated monitoring and dispatching technology.   Con-

 sequently,  in theory,  door, to-door service can be provided in a multi-
                                                                       3
 passenger vehicle at a cost considerably lower than the standard taxi.

 This  taxi bus concept  will be  field tested this year in Rochester,  N.Y.,

 and Haddonfield,  N.J.
1.  Since increasing average speed is an Important policy consideration
in urban areas, it will be discussed In the following chapter,  of par-
ticular relevance to the discussion here, is the consideration given to
coupling flow control technology and bus priorities.  See pp. 4-5, 4-6.

2.  This section will only briefly consider a few new mass transit con-
cepts that have potential to reduce automobile use.  For a comprehensive
look at  the shape of mass transit in the future, see Tomorrow's Trans-
portation (Washington, B.C.:  U.S. Department of Housing and Urban
Development, Hay 1968).

3.  The fare for a given trip, however,  may actually be greater than
the operating cost of automobile use because of the high labor cost

-------
                               3-17


           "People movers", a term generally applied to smaller than

 streetcar vehicles that can carry people around small cities,  large

 airports, and peripheral parking areas,  are anot'ntr promising  Innovation.

 These vehicles are usually computer programmed to conform to the traffic

 flow.  This  feature highlights the major problem with people-movers

 (beyond the  opposition of bus  and cab  companies):   it is  extremely  dif-

 ficult to program the  special  demands  of individual users into the

 general traffic flow.   This, of course,  is  a necessity if people are  to

 be persuaded to abandon their  private  cars.   The Urban Mass  Transit Ad-

 ministration Is currently funding a full-scale  test  of a  people-mover

 system at Morgantown, West Virginia.

           In addition  to  cleaner  air resulting  from  a  reduction  in auto-

 mobile usage,  there  is  the likelihood  mass  transit systems will be

 moved by  Inherently  low polluting power plants.  Design requirements for

 unconventional mass  transit power plants are often far easier  to meet

 technically  than they are for  private  automobiles.   In contrast to the

 state of  low emission automobile  technology, the development of low pol-
                                                1
 luting mass  transit  technology is well advanced.   Gas  turbines, for ex-

 ample,  are being field tested for installation on buses, although preltmi-
                                                                         2
 nary  evidence indicates their potential for  passenger cars may  be limited.


          Summary and conclusions.  Although in most cities buses have

 relatively more potential than rapid rail system to reduce automobile
1.  The Urban Mass Transportation Administration (DOT)  has begun a  series of
research projects aided at exploring the potential  of unconventional,  low
pollution systems.  One ongoing demonstration project,  for example,  is  in-
vestigating the feasibility and desirability of steam buses.

2.  See Report of the Ad Hoc Panel on Unconventional Vehicle Propulsion.
Office of Science and Technology (Washington,  D.C.:  March 19,  1971), p. 3.
                                                                                                                                3-18
use, it remains an open question as  to how much Impact such mass transit

modes can have.  On the basis of past  experience,  many experts believe

that new and improved bus and rail systems can induce only a minimal

shift away from the private automobile.  A recent  study concluded that

alternatives to the car usually  do not help:  "Rather, the inevitable

Increase in traffic seems to halt only when It is  discouraged by con-
         1
gestion."   However, as mass transit gets  revitalized by substantial

funding, "puts on its fancy clothes" and provides  quicker and more com-

fortable service, this conclusion may  be subject to modification.   In

addition, mass transit may be in for a sizable boost  as more and more

localities apply financial incentives  and  vehicle  use controls to  dis-

courage private automobile use (see  above).   Furthermore,  new mass

transit concepts appear likely to fill Important gaps in existing  mass

transit capabilities.

          As indicated earlier,  mass transit  must  be  judged in a broader

context than as a partial solution to  the  auto air pollution problem.

The introduction of mass transit would constitute  a disturbance in an

existing "ecological system" with highly uncertain ramifications:

          Many considerations are involved such as
          costs and benefits at  the  local  and national
          levels ensuing from economic readjustment to
          new movement systems,  questions  of  value pre-
          references of people and styles  of  life, economic
          adaptability of investments  in existing  environ-
          ments which are automobile oriented,  as  well as
          political overtones reflecting anticipated
          economic and labor adjustment (not  to say ob-
          solesence).2
1.  Setting National Priorities.(Washington, D.C.:  The Brooklngs In-
stitution) cited in "Conservation Foundation Letter" (June 1970), p. 5.

2.  Ibrahim M. Jamnal, Vehicular Air Pollution:  Variables Influencing
the Urban Transportation System In Air Quality Standards. Arthur Atkisson

-------
                               3-19


Outlook for Mass Transit

           Funding.  Although there has been Increasing Interest over

the past several years In "balanced" transportation systems, federal

aid, as Indicated above, has been Inadequate to finance significant

mass transit Improvements, let alone major new construction.  However,

two pieces of legislation recently signed into law Indicate a trend is

developing toward substantially Increased federal support of nass transit

systems.  In the Urban Mass Transportation Assistance Act of 1970,

Congress pledged $10 billion over a twelve-year period for mass transit

purposes.  After state and local governments contribute their share, this

figure may well rise to about $30 billion.  Most of the funds available

for the next five years ($3.1 billion) is expected to go- for new buses,

subway cars, and equipment.

          In a more subtle fashion, The Federal Highway Act of 1970

represents a change in federal policy that may be indicative of dramati-

cally increased support for mass transit in the future.  This legislation

— for the basic purpose of extending the Highway Trust Fund — was sur-

rounded by heated debate.  Conservationists, environmentalists, and urban

planners argued that the Highway Trust Fund must be made available to

finance a variety of approaches to combat urban congestion and vehicular air

pollution.  Backers of the Fund (including Members of Congress, highway

builders, the petroleum and trucking industries, and state highway of-

ficials) steadfastly opposed diversion of the Fund from what they claimed

is its only purpose — highway construction.  As enacted,  the legisla-

tion represents a compromise between these opposing forces in two ways,
                                                                                                                               3-20
both particularly favorable from the standpoint of mass transit.  First

there Is a shorter than usual commitment to federal aid for highways

and, second, the Highway Trust Fund may now be used for construction of

preferential bus lanes, bus passenger loading areas, and fringe and

transportation corridor parking facilities.

          In addition to this legislation, several other bills seeking

to use the monies in the Highway Trust Fund for broader purposes were

introduced into the Ninety-first Congress.  Although none was enacted,

they serve to indicate the displeasure with which many members of Con-
                                                         1
gress regard the limited goals of the Highway Trust Fund.   At the state
1.  Some of the major proposals to tap the Highway Trust Fund during
the 91st Congress include:

             Long sought legislation would authorize use of Trust
          Fund revenues to aid urban mass transportation systems,
          both bus and rail.  For example, some pending bills
          would authorize the appropriation of Fund monies to the
          Secretary of Housing and Urban Development, who could
          in turn use them to make grants to states for mass
          transit.  The governors of the states would choose how
          much of their federal-air highway apportionments would
          go to HUD for such purposes.

             More restrictive legislation would permit Fund monies
          to be used for the operation — but not construction —
          of public transportation systems.  For example, Senator
          Randolph has introduced S. 3293, which stipulates that
          whenever the Secretary of Transportation "determines that
          the highway needs of any urban area of more than 50,000
          population can be significantly reduced by applying
          federal-aid highway funds ... to the operation of public
          transportation facilities (including rail mass transit),
          he may, on the affirmative recommendation of the governor
          of the state involved, approve the use of such highway
          funds" for this purpose.   The governor, in turn, can act
          only after a local government recommendation.


-------
                               3-21
level, Maryland,  Virginia and Illinois have authorized the  use of  some

•tat* highway user taxes to support mass transit,  and similar  moves
                                          1
are being considered by five other states.

          Planning.  In addition to augmented funding, however, new

planning mechanisms will have to be created if mass transportation sys-

tems are to have major Impact on reducing private  automobile use.  Steps

aust be taken, for example, to ensure all modes of transportation  are

considered in a systems context before large commitments  to new projects

are made.  As Carlos Vlllareal, Administrator of the Urban  Mass Trans-

portation recently stated:

          The important concept now in transportation is
          intermodal . . . bringing all of the means of
          transportation together into an interrelated,
          complementary system. ...  It is not enough
          for us to build expressways, airports, highways,
          port facilities, fringe parking and commuter
          rail lines, one without regard to the other.

          The development of intermodal plans suggests the  need for  a

general transportation trust fund which could be used to  allocate  funds
(continued from previous  page)

             H.R. 14759,  introduced by Congressman Leonard  Farbstein
          of New York, would permit a governor to use his state's
          federal-aid highway funds to make grants for improving mass
          transit bus service — including "the acquisition of  buses
          and other operating equipment,  the reimbursement  of operating
          expenses, and the financing of  terminal and other facilities
          provided for the comfort and convenience of the bus-riding
          public."  Conservation Foundation Letter, June 1970,  pp. 4-5.

1. The new Maryland law created a Transportation Trust Fund and allocated
to it nestcf the highway user revenues previously earmarked for highway
uses only.

2.  Conservation Foundation Letter. June  1970, p. 8.
                                3-22


 among all modes of transportation.  This concept has been proposed

 in past legislation and strongly opposed by pro-highway forces.  Yet

 there can be little doubt that the creation of a general transporta-

 tion fund combined with the establishment of Intermodal planning mech-

 anisms will help to improve mass transit systems and thus help to re-

 duce the public's dependence on the private automobile.


                            Urban Design

        Thus far this chapter has examined vehicle use controls, finan-

 cial incentives, and mass transit as approaches to reduce automobile

 miles driven.   Such approaches essentially represent attempts to meet

 given trip demands by non-automotive means.  Another approach to reduce

 automobile miles driven would be to decrease trip demand or alterna-

 tively to reduce average trip length.

        This will generally require a basic reconstituting of land use

 patterns since  the type,  pattern,  and magnitude of vehicular movement

 closely reflects the spatial  interaction between people and the activi-

 ties  In which they engage.  For example, if cities could be compacted,

 houses,  factories,  stores,  and  offices would be closer  together and  the

 need  for transportation  (trip length) would be  reduced.   Greater den-

 sities would also allow transportation needs to be met  economically  by

 mass  transit, in  contrast to  low density cities (such as those  in South-

 west) which oust  rely heavily on the private automobile.

       Since the  auto air pollution problem is  largest  in major  cities

where huge private  investments have been  sunk in existing conditions,


-------
                               3-23


by major changes  In  the urban configuration.1  However,  land use

planning should play a significant role  in  future  "planned" cities

and  in  guiding urban growth  in existing  cities.  With regard to the

latter, the design of new urban development could  possibly eliminate

urban sprawl which is characterized by Inefficient spatial relation-

ships between people and activities.

        To aid urban  planners in evaluating  the air pollution eonse-
                                                   \
quence  of alternate  land plans and urban configurations, AFCO has

programned research  In this  area  into  their six-year research  plan.

Among other objectives, this research  will  seek  to determine how  alter-

native  distributions of urban activities can affect air  quality by

allowing transportation demands to be  met by different highway systems

and  transportation modes.  The results of such analysis  will  be  incor-

porated in guideline documents for planners.
 1.  This does not mean, however,  that  established  cities  are  incapable
 of moderately altering spatial relationships  to reduce  trip demand.
 For example, two alternatives are available to reduce the common  separa-
 tion of inner city  residents from suburban located jobs that  such
 Individuals might fill; It may be practicable either to locate  low-
 income housing closer to employment centers or to  train ghetto  residents
 for center city employment.

2.  One'major research project  In this  area  is scheduled for completion
next month.  See the forthcoming report:  "A Five-Year Program to In-
corporate Air Pollution Considerations  in Urban and Transportation
Planning," Alan M.  Voorhees & Associates, and  Ryckman,  Edgerley,
Tomlinson & Associates.
                          CHAPTER  4


                              LOCATION


          The  trend  toward  living  in urban areas  Is growing  rapidly;

by  1980  over 59 percent of  the population will be living  in  major

metropolitan areas while  75 percent will  be living in all urban areas.

In  the year 2000, these statistics are  expected to jump to nearly 66
                                     1
percent  and 85 percent, respectively.   This trend in urbanization  is

not limited to people  —  the car population in cities is  Increasing
                                            2
even more rapidly than the  human population.   Thus, since major metro-

politan  urban  areas  represent only about  1.5 percent of the  total area

of  the country, the  prospect Is that more and more vehicular contami-

nants will be  concentrated  in a very small proportion of -the atmosphere.

          The  strategy to combat the increased concentration of auto

air pollution  in urban areas consists of two basic tactics:  (1) reduce

pollutant emissions  in urban areas; (2) modify the urban -environment

so as to increase assimilative capacity and the separation of people from

high pollution concentrations.

          All measures which can control the number of miles driven in

urban areas will reduce the emissions in these critical locations.   In

this regard, Chapter 3 discussed the advantages of improving mass transit
                                                                                              1.  Source:  Jerome P. Pickard, "Metropolization of the United States",
                                                                                              Urban Land Institute, Washington, D.C., 1959.  U.S. Department of Com-
                                                                                              merce, Bureau of the Census data.  Cited in The Automobile and Air Pol-
                                                                                              lution:  A Program for Progress (Washington, D.C.:  U.S. Department of
                                                                                              Commerce; October 1967), p. 33.
                                                                                              2.  See A. M. Voorhees Tables in Air Quality Standards,  Arthur Atklsson

-------
                                4-2


and encouraging car pools, as well as discouraging automobile use via

vehicle use control* and price incentives.  Chapter 5 will explore the

possibility of putting an actual price on urban driving as a means of

securing better air quality.  By reducing the number of vehicles In

urbsn areas, these measures will also Increase the average speed of the

remaining vehicles on the road.  As discussed below, this Increase in
                                                    1
speed will result in a further decrease in emissions.

          This chapter shall consider other, more direct, means of in-

creasing average vehicle speed (such as by the use of traffic flow con-

trol technology) and the implications of banning traffic to a greater or

lesser degree in specific urban locations.

          Pollution becomes a serious problem in direct relation to the

capacity of the air to disperse pollutants.  So in addition co a reduc-

tion in the aggregate level of pollution in urban areas, measures designed

to reduce localized concentrations of pollutants will mitigate the

damages that otherwise would result from a given amount of emissions.

An obvious measure along these lines would be to reduce vehicle con-

gestion.  As indicated above, this would reduce vehicle emissions by

increasing average speed, but would also result in a "wider" distribution

of the pollutants that are emitted.  This chapter will discuss other

steps that can be taken to influence the dispersion of pollutants and

to reduce the exposure of people to air pollution.  These Include
1.  The increase in average speed is premised, on urban officials taking
suitable action to prevent potential users from switching to automobile
use because of the lessened congestion.  Congestion, as indicated
earlier, is often thought to be the greatest single factor discouraging
autonobile use in downtown areas.  The absence of congestion, such as
occur* initially after new highway construction, has in the past Invari-
ably attracted new users until average speed drops to some equilibrium
point.  Measures to discourage new automobile use, such as taxes on
parking fees, were discussed in Chapter 3.
                                4-3
alternate land use plans and urban configurations, the design and  loca-

tion of highways, and the alteration of traffic patterns.



                        Emission Reduction

Increasing Average Vehicle Speed

          As table 4-1 indicates, the largest amount of contaminants

from the automobile is emitted during the phases of acceleration and

deceleration.  Such phases increase with the stop-and-go  conditions

in congested urban locations.


                              Table 4-1
              PERCENTAGE OF CONTAMINANT EMITTED PER MILE,
                   IN EACH MODE OF I.C.E. OPERATION!

Idle
Cruise
Acceleration
Deceleration
Gross
Hydrocarbons
5.91
14. 1Z
56. 2%
23. 7Z
Carbon
Monoxide
7.5Z
14. 3Z
62. 2Z
16.1%
Oxide of
Nitrogen
0.031
21.401
78.50Z
0.17Z
           These  data suggest  that  one way  to  reduce automobile  emissions

 is  to  increase uninterrupted  vehicular  flows.  Average vehicle  speed has
 1.   Source:   A.  M.  Voorhees,  "Variables  Affecting Traffic and  Vehicular
 Operating  Conditions  in Urban Areas"  in  Air Quality Standards, Arthur

-------
                                4-4


been found to be a good index of  the extent of acceleration, decelera-

tion and Idle driving on a given  route.  Consequently, measures which

Increase average vehicle speed can reduce  the total  amount  of pollutants
                  1
per mile traveled.   The potential of such measures  should  not be under-

estimated; although vehicular traffic Is almost evenly divided between

urban and rural areas, the slower traffic  in urban areas accounts for

70 percent of total vehicle emissions for  carbon monoxide (with hydro-

carbons and oxides of nitrogen somewhat lower).


          Expressways.  If properly designed (see below), high speed

expressways can reduce the total amount of pollutants emitted from ve-

hicles per mile traveled.  They allow vehicles to run without Interruption

and at efficient cruise speeds — ideally  about 55 miles per hour for most

vehicles.   Also, because superhighways let motorists reach their

destinations faster, drivers and occupants in these vehicles are ex-

posed to the remaining concentrations of pollution for far  shorter

periods of time.

          The application of flow control  technology on expressways

could, in many cases, significantly increase average vehicle speed.
1.  This reduction in pollution, however, does not.apply across the board.
Hydrocarbon and carbon monoxide emissions decrease, while nitrogen oxides
and lead emissions increase in concentration with higher, hotter engine
speeds.  An analysis of emissions at different speeds can be found In
John T. Mlddleton and Wayne Ott, "Air Pollution and Transportation",
Traffic Quarterly. April 1968, pp. 175-189.

2.  Maryland State Roads Commission, Bureau of Highway Information,  cited
In Prince George's County News. April 9, 1970.     •     .,,....
                                4-5


For example, "metering" of traffic through control of volume of traffic

allowed to enter at selected access ramps at peak travel periods can

substantially increase peak hour travel speeds by preventing overloads,

while maintaining the same volume of traffic using the freeways during

peak hours.  The increased average vehicle speed will reduce auto

emissions as well as provide the basis for a high speed bus service if

buses are  given priority at access ramps.  Experiments are now under

way in a number of large cities to give buses such preferential access

and thereby achieve an express transit operation at a minimum road
     1
cost.

          Programming for higher speeds, rather than higher volumes

(as is generally the motivation for installing such expensive systems)

may severely diminish the capability of <.he area road network to satisfy

transportation needs.  Yet, even If metered freeways could Initially

increase average speed without critically undermining capacity, this

accomplishment may be only temporary.   If the total demand is allowed

to expand  freely, aa In the past, metered freeways would attract more

vehicles to them than the system would  allow on the freeways In a

given period of time.  Consequently, long queues would form on the

approach ramps.  Unless a decision were taken to limit the aggregate

demand by  pricing, It would be difficult to prevent this situation from

occurring.  Such a decision, however, would usually be politically
1.  For a discussion of highway flow controls and mass transit, see
Sumner Myers, "Technology and Urban Transit" in Business Horizon!
(Summer 1967), pp. 68-69.  See also "Busway-Freeway Rapid Transit",

-------
                                4-6


unfeasible.  Thu», the major benefit of a flow control system might

well be the opportunity It provides for a rapid bus transit system

since buses, given priority, would not be affected by ramp congestion.

It Is for this reason that the recently enacted Federal Highway Act of

1970 permits the Highway Trust Fund to be used to support the Implemen-

tation of highway flow control systems.  One consequence may be a rapid

Increase In the number of metered highways.


          Streets.  Street systems In major urban areas (especially

older cities) generally were not designed to handle the volume of traffic

they are now called upon to bear.  Consequently, driving on city streets

Is often characterized by low vehicle speed and frequent stop and go

operations.  Average vehicle speed and uninterrupted travel can be

Increased on city streets by efficient design of the traffic control net-

work.  Many cities, for example, are experimenting with computer simula-

tion of traffic flows to achieve optimal sequencing of traffic signals.

As an added measure, "metering" vehicles Into downtown areas at peak

hours could prevent serious congestion.

          However, modifications to the existing traffic control network

are probably a more practical scheme In most cities.  It Is now tech-

nically feasible to build "closed loop" traffic systems, that Is, systems

responsive to changes In traffic conditions.  Furthermore, such systems

could be designed to sense the approach-of a bus ..In the .traffic stream,

and thus could be made responsive to moving people and not simply vehicles.

Giving buses priority on time-shared city streets, as discussed In

Chapter 3, Is a crucial factor In stimulating bus rldershlp.
                                                                                                                                 4-7
           As • long-tern operation, stop and go traffic can be minimized

 by aeparatlng rights of way at Intersections.  Separate pedestrian

 routes csn often be created by building either elevated or underground

 passageways and traversing the upper stories of buildings.  Similarly,

 overpasses, underpasses and multi-level networks are very helpful In

 separating traffic flows in different directions,  but they are extremely

 costly.1
           Staggering.   Congestion might also be decreased by staggering

 work hours to reduce the peak hour loading of vehicles that Is so often

 a major cause of traffic delays in urban areas.  One elaborate study

 showed rush hour crowding could be reduced by 25 percent in Manhattan just
                                                                  2
 by staggering working hours in the largest offices and factories.   But

 since the  direct imposition of any such scheme would represent a  large

 intrusion  of  government  into the  private sector,  it  Is often politically

 difficult  to  Implement effective  staggering.3   However,  It  should be  noted

 that a  degree of staggering already exists  in  many urban areas where

 substantial numbers  of workers  arrange  to travel  earlier or later than

 the  standard  hours in order to  avoid the rush  hour peaks.  Another point
1.  For a discussion of the urban and cost considerations in reducing
the number of Intersections per mile of street network, see Ibrahim M.
Jammal, "Vehicular Air Pollution:  Variables Influencing the Urban Trans-
portation System" in Air Quality Standards. Arthur Atklsson and Richard -.
S. Galnes, Ed. (Columbus, Ohio:  Charles E. Merrll, 1970), p. 159.

2.  Finding of six-year study directed by Lawrence B.  Cohen of the
Department of Industrial Engineering of Columbia University, 1965.
Cited In Edward Banfleld, The Unheavenly City (Boston:  Little, Brown
and Company, 1968) p. 8.

3.  For an indication of the political difficulties associated with

-------
                                  4-8


 to be borne in mind la the changing nature of business being carried

 on In downtown areas.   The high cost of space Is tending to restrict

 the business population to those firms requiring constant public

 contact.  It follows that the employees of such firms are obliged

 to work "normal" hours and thus staggering would provide an unaccept-

 able solution.


 Traffic Bans
                                        i
           Restricting the use of automobiles In certain major urban

 areas may be necessary to avoid high concentrations of pollution.  One

 source estimates that as ouch as 75 percent of the traffic may have to

 be restricted In certain large metropolitan areas If health standards

 are to be achieved.

           The most stringent measure In this regard would be an our-

 rlght ban of the automobile from Inner city areas.  Although this Is

 strongly advocated by environmentalists,  such proposals have received

 little serious consideration.  The California legislature, however,

 did discuss — and reject — one bill during the past session that

 would have banned cars from the core areas of 19 major California

 cities.

           Such legislation can only be a possibility where the local

 mass transit systems are capable of handling the commuter population.

 But even If mass transit Is available, such as in New York where

 80 percent of the people who cone to work in the central business

 district use public transport, banning cars from large cities may

 radically alter the whole complexion of the urban areas:
 1.   National Air Quality  Standards Act of  1970, Report of  the Committee
 on  Public Works, United States Senate, Report No. 91-1196  (September 17.
..men.  n_  2.'
                                                                                                                                     4-9
             The solution to the auto-transit problem in-
          volves the delicate balance between technology
          and humanity that creates a living city.  If
          New York goes too far in preventing use of auto-
          mobiles and banning them from the city, it is
          feared the city will die as those who live there
          move out — except for the rich and the poor
          (a trend already well established).  In effect,
          . . . the city would be re-establishing medieval
          walls, erasing the mobility of modern urban
          civilization while creating bastions for commerce
          only.  One thinks of the empty caverns of Wall
          Street on Sunday afternoon to illustrate the
          potential future of a city without people.

          A less stringent measure than the total ban is the selective

ban — the diversion of traffic flow away from major business and

shopping areas.  Tokyo is now banning all cars from 122 of its busiest

streets on Sundays, the busiest shopping day in Japan.   The elimination

of automobiles in one normally congested area caused the downtown pol-
                                                2
lution level to fall to half its normal reading.   Following this ex-

ample, one-mile stretches of three major New York throughfares were

declared off limits for automobiles on weekends and week nights during

parts of the summer, fall, and Christmas shopping season.  The carbon

monoxide level  on some auto-less streets was reported to have fallen
                         3
by as much as 90 percent.

          In addition to reducing auto air pollution,  the Tokyo and

New York experiences bear out two important lessons.   First,  and
1.  The Washington Post (August 23, 1970),  p.  D-l

2.  "Clean Air and Automobility", The Washington Post (August 5,  1970),
p. A-18.


-------
                                4-10
contrary to merchants' expectations, sales did not suffer.   Secondly,

through careful planning, traffic can be re-routed successfully in two

of the world's most crowded cities.  Conceivably, urban transportation

planners could relate the magnitude of automotive emissions to the re-

quired air quality criteria and determine the optimal re-routing plan

in terms of the degree of control required.  This will allow traffic

restrictions to be only as extensive as air quality needs require,

and thus the disruption of "normal" activities will be minimized.

          One expert on urban planning offers guidance on the  develop-

ment of programs for restricting traffic:

             For each city,  the Immediate  planning question is
          what reduction in automobile traffic is feasible,
          given the presently available alternative modes of
          transportation.  Such a reduction might be phase 1
          of a long-run program.  The answer will depend on
          the particular city.  It will be necessary to ex-
          amine a broad spectrum of proposed restrictions, in-
          cluding variations in area coverages;  times of the day;
          types of vehicles; trip purposes;  number of passengers
          per vehicle; etc.   Sucb a study  would determine what
          is immediately feasible, or — through application
          of criteria — which of the things which are feasible
          are most economical or efficient.

             It is entirely possible that  the most feasible
          program would not be a complete  ban on automobiles.
          Another possibility is that the  feasible reduction in
          automobiles which could be Implemented would not be
          sufficient to meet air quality criteria entirely but
          only to move in that direction.   If this were so,
          further steps would need to be taken.   If the imme-
          diately feasible were implemented as phase I,  phase
          II might incorporate an expansion of public
1.  Sales in Tokyo actually ran 50 percent above the usual figure.
Other areas where shopping streets have been established have found
the, arrangement draws^ large crowds^.  "Clean Air and Automobility",
The Washington Post Post (August 5; 1970), p. A-18.  However, the
inability to carry certain types of merchandise long distances could
alter thennature of retail business activity in auto-less business
districts.
                                                                                                                             4-11
            transportation  facilities,  some advance in the
            technology of public  transportation,  or improve-
            ment  in  the control of vehicular emissions.1
                               Dispersion

 Urban and Transportation Planning

           Where pollutants can be rapidly  dispersed,  higher emissions

 can be  tolerated and, conversely, where local  air  is  stagnant  so

 that pollutants collect, only very low  emissions can  be  tolerated.

 Urban planners with a basic understanding  of mlcrometeorology,  the

 process involved in small scale atmospheric convection and  diffusion,

 can adopt measures to influence the dispersion of  air pollutants.

 Of particular importance, this knowledge will  permit  planners  to

 take effective action to separate people and the source  of  emissions

 through alternate land plans  and urban  configurations.   Unfortunately,

 however, the state of the art in environmental planning  is  in  its

 infancy; methods have not yet been devised for determining  the

 potential air quality associated with a  particular plan  or  design.

 Although there have been many attempts,  for example,  to  develop

 accurate mathematical models of the dispersion of  pollutants from

 sources such as freeways, these models frequently  underestimate

 the concentrations at given distances from the pollution source

 being measured.  This is primarily due to the  difficulty in
 1.  Guy Black, The Downtown Ban on Automobiles (Washington, D. C.
 George Washington University, mimeo, August 7, 1970), p. 6.  The
 author also points out the importance of technological forecasting in
'developing traffic restriction programs and the need far studying

-------
                                4-12
accounting for other nearby sources of pollution and-the wide variations
                   1
In urban landscape.

          Recognizing the need for fundamental research, APCO has pro-

grammed extensive studies of environmental planning Into their six-year re-
                            2
search and development plan.  This plan highlights the two major areas for

abatement of air pollution by influencing dispersion:  long term urban

design and highway design and location.
Long Term Urban Design

          The spatial distribution of urban activities affects the dis-

tribution of vehicular emissions and the resultant ambient air concentra-

tions.  Methodologies are needed to evaluate selected land plans, to

estimate the pollution potential of alternate land designs, and to relate

air pollution concentrations to the size and location of parks, open
                       3
spaces and green belts.
1.  One source notes that diffusion models usually predict carbon
monoxide concentrations one-half to one tenth of those actually
measured.  See "Air Quality Criteria for Carbon Monoxide", (National
Air Pollution Control Administration Publication No. AP-62 U.S.
Department of Health, Education, and Welfare; March 1970), pp. 6-26,
6-27.  See also "Workbook of Atmospheric Dispersion Estimates"
(Public Health Service Publication No. 999-AP-26, 1967).

2.  See discussion on p. 3-23  for details of  this plan as it  relates  to
reducing emissions by altering the spatial arrangements  of people and
activities.  Discussion here will be devoted  to aspects  of the plan
relating to pollution concentration.

3.  For an analysis of land use planning as it relates to mobile source air
pollution control, see Salvatore J. Be Homo, "Ways to Reduce Air Pollution
through Planning Design and Operations," prepared for presentation at the
50th Annual Meeting, Highway Research Board (Washington,  D.C.: January 1971).
However, In contrast to the body of research done to relate the location of
stationary sources of pollution to meteorological conditions,  very little
is known about locating major  traffic flows to air current patterns.  See
Ibrahim M. Janutl, "Vehicular Air Pollution:  Variables Influencing the
Urban Transportation System" In Air Quality Standards. Arthur  Atklsson and
Richard S. Galnes, Ed.  (Columbus, Ohio:   Charles .E.  Merril,  1970).
                                                                                                                             4-13
          On a smaller scale, investigation is needed into the potential

of various building patterns to abate pollution concentration.  High and

low rise buildings when alternated, for example, can create favorable

air turbulence.  Similarly, laying streets along breeze lines can cause

contaminants to disperse more rapidly.


Highway Design and Location.

          Certain highway designs and locations may lead to greater con-

centrations of pollution either on the highway or the areas immediately

adjacent to it.  An analysis of the proposed Lower Manhattan Expressway

undertaken by the New York City Department of Air Resources revealed such

construction would result in dangerously high carbon monoxide levels.
                                                                          1
Among other reasons, the proposal was rejected on the basis of this study.

Another New York study documents the potential air pollution damages of

poor highway location to the surrounding area.  This analysis revealed that

the carbon monoxide levels measured at the top floors of buildings located

above an interstate highway were as high as the hazardous rush hour levels
                                   2
in downtown Manhattan street level.

          The Federal Highway Administration has issued guidelines which

require state highway departments to consider the impact on the environment
1.  "An Estimate of Vehicular Air Pollution Potential of the Proposed
Lower Manhattan Expressway in New York City," New York City, Department of
Air Resources, November 1965.

2.  Cited in "Statement of the Metropolitan Washington Coalition for Clean
Air," July 15, 1970, p. 4.  To preclude the possibility of such health
hazards occurring, this organization has formally demanded the sus-
pension of the proposed District freeway system pending a comprehensive

-------
                                4-14


of proposed new highway construction.   Among other factors,  these guide-

lines specify air pollution as an environmental effect to be weighed.

However, nowhere are minimum standards prescribed for the information

needed to support required considerations of environmental effects.  Con-

sequently, air pollution (as well as other environmental  considerations

such as noise pollution) is usually given short shrift in planning new
         1
highways.

          Methodologies are needed to translate traffic estimates into

expected pollution concentrations at various distances from the  road.

Also needed are guideline documents to provide transportation planning

agencies with criteria relating air quality to various highway design

configurations.  Presumably such guidelines would give concentrations  as
                                                                      2
a function of traffic mixes and flows  and as a function of lane  width.

          Proper highway design would  include provision for  the  maxi-

mum possible distance between vehicle  routes and adjacent dwelling places,

maximum distance between traffic lanes and sidewalks, and maximum width

of traffic lanes and median strips.  It is especially helpful to have

landscaping alongside of highways with the landscape belt as wide as

possible.  Such provisions allow for the greatest dilution of emissions
1.  To remedy this situation,  a three-day environmental workshop was
held (July 7-9, 1971) in Washington,  D.C.,  by the  Highway Research Board
of the National Academy of Sciences.   One sub-panel  devoted  its efforts
to modifying a draft set of air pollution guidelines.  The final product
is expected to be published shortly.

2.  General Electric Company,  "Final Report on Study of Air Pollution
Aspects of Various Roadway Configurations," submitted to the New York
City Department of Air Resources, June 6, 1971.
                               4-15
 before they can reach smog-causing concentrations and before they
                                           1
 filtrate residential and pedestrian areas.
 Alteration of Traffic Patterns

           As indicated above in the discussion of traffic bans, certain

 selective bans may have the primary effect of rerouting traffic rather

 than discouraging automobile use.  Altering traffic patterns could be

 an important tool in redistributing emissions in a more regionally favorable

 manner .

           A recent experiment undertaken in Gothenburg, Sweden, indicates

 the potential of innovative transportation planning to re-route traffic

 so as  to avoid high center  city pollution concentrations.   By constructing

 actual barriers,  urban planners divided the city into five sections;  through

 traffic  from one  section  to another (with the exception of emergency

 vehicles) was made impossible.   Intracity driving required exiting from a

 particular  section,  driving on  a  "ring" road,  and then entering the de-

 sired  section.  Initial information indicates  this approach  is  highly

 successful  in lowering air  pollution concentrations  in the center  city
     2
1.  For a comprehensive discussion of highway design for air pollution
control see John T. Middleton and Wayne Ott, "Air Pollution and Trans-
portation," Traffic Quarterly. April 1969.  See also M. G. Schneiderman,
C. K. Cohn, and G. Paulson, "Air Pollution and Urban Freeways:  Making a
Record on Hazards to Health and Property," The Catholic University Law
Review. Fall 1970.

2.  Organisation for Economic Co-operation and Development, "The Gothenburg

-------
                          CHAPTERS        -..;•/. ••';'-'^..

                                              I
                      EMISSIONS CHAfiCE SYSTEMS


          From an economist's point of view, an Ideal method of en-

suring socially desirable automobile ownership and usage patterns

would be to measure the precise emissions from a given vehicle in

a given location and impose a charge related to the social cost of
                                          2
that amount of pollution In that location.   This would make the

previously hidden cost of pollution a real dollar cost to motorists.

Supply and demand forces would then function in a market context to

allocate vehicle ownership and usage patterns in a socially tolerable

manner.  Such an emissions system would give each motorist both the

information (dollar costs of his pollution) and the incentives

(desire to minimize costs) to reduce his contribution to the auto
1.  For a comprehensive discussion of emission charges in air pol-
lution control, see Governmental Approaches to Air Pollution Control:  A
Compendium and Annotated Bibliography, prepared by the Institute of Public
Administration for the National Air Pollution Control Administration, 1970,
Chapter 8.  Except for different considerations related to monitoring
and administering an emission charge system for automobiles, that dis-
cussion applies in total.  Hence, the discussion here will highlight
only those aspects that are of particular relevance to the automobile
problem.

2.  The concept of securing rational allocation of a scarce resource
by assessing a charge related to the cost to society of specific auto-
mobile use is not new.  Much research has dealt with the possibility of
congestion pricing, that is, charging motorists a price reflecting the
increase in congestion resulting from their decision to drive in specific
locations.  Although the damage in these studies is increased travel time,
there is no reason why environmental costs could not be included.  Studies
on congestion pricing thus yield considerable insight into developing
emission charge_schemes.  See Road Pricing:  The Economic and Technical
Possibilities /the "Smeed Committee" Report/ (London, England:  HUSO,
June 1964).  More recently, see Gabriel J. Roth, "Traffic Congestion as
a Source of Revenue," Traffic Quarterly (April 1970), p.  175.
 .;•'            " "•              -  5-2-                         -    V''^
 •;,vv               -x                                               •• -\

 pollution problem.   This motorists can do, aa Indicated  throughout,

 In three basic wasy:  1) shift to a lower  emissions  class;  2)  reduce

 automobile usage, and 3) avoid driving in  highly polluted areas.

           Measures to control the level of the first two  variables

 via a price mechanism were discussed in Chapter  2 and Chapter  3, re-

 spectively.   Chapter 2 Included discussion of discriminatory  taxes

 as a means of shifting motorists'  preference to lower emission classes

 and Chapter 3 included discussion of a direct usage tax (via a tax on

 gasoline)  as a means of reducing  miles driven.  It was mentioned in

 each of these chapters that the significant disparity in ownership

 and usage  habits  among motorists will  most  likely result in large in-

 efficiencies and  inequities if policy  makers impose tax systems based

 upon only  one of  the  three  variables.  Charges based  upon the emissions

 class of a  vehicle,  for  example, could result  in  large expenditures for

 control equipment  by  those  who use their automobiles  infrequently or

 primarily in  rural areas.   Alternatively (assuming a  simple  fuel  tax

 is Imposed),  those motorists with virtually pollution-free cars will be

 assessed approximately the  same charge for  driving a hundred miles  as
1.  An emission charge system aimed at_automobile manufacturers was
discussed in Chapter  1  (see pp. 1-20  to  1-24).  This  chapter will be
devoted to discussion of emission charge systems directed at individual
motorists.

2.  A price could be applied to the third variable (location) in  the
form of a congestion charge.   Since the concept involved in  congestion
pricing is identical to that being developed here, it was omitted

-------
                                   5-3

                                   1
    those driving  "smoke belchers."   In  addition  to  these  considerations,

   charge systems based upon a single variable cannot guarantee a reduction

   in pollution damage since changes in the levels of the other two

   variables may overwhelm the effects of any reduction in the variable

   being controlled.

             Theoretically,  an ideal  emission charge  system would  provide

   control over  all  three  variables' simultaneously.   Specifically,  It

   would apply a charge based  upon  the number of miles a vehicle in a
                                                               2
   specific  emissions  class  is driven  in  a particular location.   As will

   be discussed  below, the technical feasibility of such a "complete"

   emissions charge scheme will depend upon the development of sophisti-

   cated monitoring technology.  In the absence of such technology, or if

  a "complete" scheme were too costly or too instrusive to administer,

  two "incomplete" emissions charge systems could  be  considered.   These

  measures  apply a charge  related to  the  levels  of two variables :

            air  use,permits         gasoline  tax ba^ed on  location
           ^           \
      location    emissions  class
                                                   miles "driven
  1.  Any  difference in charge will  be  related  to a difference in fuel
  consumption.  Since higher emitting cars generally consume more fuel,
  a simple fuel tax will discriminate,  to some  degree, on the emissions
  characteristics of the automobile.

  2.  Theoretically, the term "emission charge system" should be applied
  only to  those measures which simultaneously control all three components
  of pollution damage.   However, measures which impose charges related to
  emissions class or miles driven can also be considered to place a  price
  on emissions insofar  as those variables are correlated with the magnitude
•  of emissions.  For the punoses.of differentiating among possible  emission-;'
  related chdrge systems,  measures which apply a charge based tfn  consideration
 of all three components  of pollution damage will be  called a "complete"
 emission charge  system,  while measures which apply a  charge related  to the
 levels of one or two  of  the  components will be called "incomplete".
                                     5-6


              These approaches will be considered and then followed by  an

    attempt to combine them Into a "complete" emissions charge system.

    Following that,  the chapter will consider the implications of sophisti-

    cated monitoring  technology for the  development of a "complete" system,


                   Relating Emission Classes  to  Location
                  1
   Air Use Permits


             Given the emission class of a particular vehicle (see Chap-

   ter 2)  and with the assumption that the vehicle is used an average

   amount,  the environmental  cost of automobile use will depend largely

   on  the location in  which the automobile is  operated.   To  relate usage

  of a certain type of vehicle to  location of  use,  the  country  could

  be divided into zones on the basis of the social  costs of emitting  an
                                                    2
  additional quantity of pollution in that vicinity.   The zones  could

  be numbered say,  from "0" (low population areas with high ventilation)

  to "3"  (inner-city  areas  or  other areas  where pollution levels are

  chronically high).   A charge would be  assessed  in the  form of  required

 purchase of an air use permit.  The cost  of  the permit would be  related

 to the emissions class of the car and the highest  pollution zone in


 1.  This section as well as  many of the insights in this chapter are
 attributable to  Anthony B.  Low-Beer, "The Use of Effluent Charges to
 Control  Air Pollution and  Induce an Efficient Allocation of Resources",
 Columbia University,  1970  (unpublished Ph.D.  thesis).

 2.  The social cost of an  incremental  amount  of  pollution is generally
 regarded as  directly  related  to  the  existing  amount of  pollution in the
 location of  vehicle use.  This assumption is  employed here.  However, it
 should be emphasized  that many individuals may feel-additional  pollution
 1* a relatively pbllution-free area  is," indeed a cofetly degradation of
 the environment equal in social  cost (if not greater) to emissions of

-------
                                 5-5


which  Che  automobile  is  to be operated.  For example,  the  price of

a yearly zone  "3" permit for an  automobile  in  emissions  class  "4"

would  equal  the  expected social  cost of  the emitted  air  contaminants

using  the  assumption  that the automobile will  be  used  an average
        1
amount.

           Physically  the air use permits could take  the  form of a

windshield sticker  conveying the following  information (perhaps by

geometrical  shape,  color, size):   (1) emissions class  of vehicle;

(2) highest  zone for  which use is permitted, and;  (3)  date of  ex-

piration.

           The  operation  of an air use permit scheme  would  appear to

be well within the  range of administrative  feasibility.  Permits could

be sold in gasoline stations and in parkway toll  booths.   Since the

cost of administering such a system in "0"  areas  would probably out-

weigh  the  benefits  to be obtained, permits  would  probably  not  be re-

quired  in  these  zones.  Conceptually,  enforcement, which  includes  traffic

surveillance and punishment of violators, does not seem to  present  any

major difficulties  either -- traveling without an air use license  or  with

a permit for a lower  emissions class vehicle,  or operating  zone would
1.  Air use permits need not only be sold on an annual basis; permits
could be sold for time periods as short as one day or even less.
Such flexibility would allow tourists or transients to purchase per-
mits for only their period of automobile use in a zone for which they
do not have a permit.  As permit costs are based on expected usage,
charges for short duration would be proportionately greater than for
annual permits — a permit issued for a single day could be expected
to be used on that day, while yearly permits assume only "average"
use.  The enforcement of short duration permits might be difficult,
but the issuance of "self-cancelling" stickers could resolve this
problem.  After activation (rubbing or peeling off top surface),
these stickers would change color upon expiration.
                                 5-6


 constitute a violation.   Similarly, the sale of a permit of lower than

 rated emission category (which would be found on the vehicle's regis-

 tration)  could subject the seller to a fine.

           Some difficulty may arise if all vehicles do not have emission

 ratings,  as might  be the  case for vehicles predominantly used in zones

 not requiring a permit.   A mechanism for testing or estimating the

 vehicle's emission class  would have to be established prior to a permit
              1
 being issued.

           Interzone transfers would not constitute a problem unless  some

 individuals found  that many of their trips required only minimal entrance

 into a high pollution zone, and thus felt purchase of the high zone permit

 was an unjustifiable expense.   These individuals,  as well as others,

 might decide to risk penalty  rather than make  a costly  purchase while

 travelling only a  short distance  in a  high pollution zone.   However,

 the majority of such motorists would probably  find it most  advantageous

 to  purchase a  zone "3" (maximum zone permit) on an annual basis.

           The expected benefit of such a system then, would not be In

 altering  the location of  predominant automotive use, but primarily In

 influencing the motorist's  choice of vehicle and maintenance habits.

A low  emissions  class  rating  under an  air use permit  system  would mean

sharply reduced  operating costs, especially in highly polluted  areas.

One study  estimated  that an air use permit scheme  in New York City
The feasibility of air use permits is dependent upon the establishment
of state emission checking programs in areas where permits would be
used.  Emissions need not be actually checked, however, if accurate

-------
                                5-7
related to pollution damage would cost a relatively pollution-free

automobile $80-$90 annually, while a relatively uncontrolled emitter
                                         1
might face fees up to $800-S900, or more.

          The air use permit system would  not preclude the ownership

of high emission cars (as very strict standards might) for those who

use cars primarily for low zone driving or for those who value the per-

formance of such cars above the considerable annual cost of the re-

quired permits.


                 Relating Miles Driven to  Location

Fuel Tax Based on Location

          The air use permit system represents the marginal social

air pollution costs of automobile ownership, given that the vehicle

is used in average fashion.  Such a system, however, cannot represent

the cost of driving an additional mile once the permit has been pur-

chased.  In the absence of monitoring equipment which could precisely

determine vehicle usage, a tax on gasoline consumption could be im-

posed as a charge representative of the air pollution cost of vehicle

usage in a particular location.  For example, the additional tax on

gasoline in a relatively pollution-free area might be $0.05 per gallon

whereas it night be $0.20 per gallon in an area with considerably
1.  Anthony B. Low-Beer, "The Use of Effluent Charges to Control Air
Pollution and Induce an Efficient Allocation of Resources",  Columbia
University, 1970 .(unpublished Ph.D. thesis).   This estimate  assumes  "
auto-related damages in New York City amount to $800 million annually,
and that the highest emissions class emits approximately ten times
as much pollution as the lowest class.
                                 5-8


 greater pollution.  Such a fuel tax would represent the marginal social

 coat of burning a gallon of gasoline in the area where the gas is pur-

 chased by an "average" automobile.

           The implementation of a fuel tax based on location will re-

 quire careful administration and enforcement.  Since the tax on a gallon
                                                        1
 of gasoline will be very high in highly polluted areas,  some motorists

 would be motivated to drive to low pollution areas to purchase gasoline.

 Such behavior would not only result In massive evasions of the emissions

 charge,  but would also result in socially wasteful driving by causing

 additional congestion and pollution.   This sort of behavior could be

 curtailed by basing fuel tax sales on an average,  or perhaps a weighted

 average  social cost of burning fuel within a one-half  gas tank radius

 (approximately 125-150 miles).   This  would reduce  the  charge differen-

 tial between high and  low pollution zones  and make it  less profitable

 to  travel a great distance to  buy  lower priced fuel.  Of  course,  suitable

 restrictions would have to  be  imposed,  similar to  the restrictions on

 Interstate transportation of liquor,  to prevent unscrupulous  individuals

 from "bootlegging" gasoline purchased in low pollution  zones.

           A fuel  tax based on  location  would provide the  incentive for

motorists  to reduce automobile use  in those areas where pollution

 levels are chronically  high.  As discussed in  Chapter 4,  this will
1.  One source estimates the tax in New Tork City representative of
the social cost of burning a gallon of gasoline there would be ap-
proximately $0.80 per gal'lon.  Anthony B. tow-Beer, "The Use of Ef-
fluent Charges to Control Air Pollution and Induce an Efficient
Allocation of Resources", Columbia University, 1970, Chapter 5,

-------
                                5-9


also result In a beneficial Increase In average vehicle speed In urban

areas.  However, by Itself it will provide no Incentive for motorists

to shift  to lower emission classes through purchase of new vehicles,

purchase  of additional control equipment, or through better vehicle

maintenance.


                 "Complete" Emission Charge System

Without Sophisticated Monitoring Equipment

          Since the gasoline tax fails to represent variations in

emission-per-mile ratings (emission classes), and the use of air per-

mits does not account for the marginal pollution cost per mile of use,

an ideal  system would involve a combined air use permit/fuel tax

scheuie.  These two systems could be combined by issuing an automobile

owner a ration card stating the vehicle's emissions class which would

entitle him to purchase fuel according to specified fuel tax schedules

related to the emissions class of the vehicle and the location of gaso-

line purchase.  Alternatively, one economist suggests motorists could

get a gasoline tax rebate on the basis the emissions class of their

automobile and a record of the location and amount of gasoline purchases

substantiated by means of tear-off vouchers,  "trading stamps",  or a
                      1
log book of some kind.
1.  William Vickrey, "Theoretical and Practical Possibilities and
Limitations of a Market Mechanism Approach to Air Pollution Control",
Air Pollution Control Association Meetings, Cleveland, June 11, 1967,
p. 8.
                                5-10


          Although the former approach Is preferable  to  the  latter

since It would avoid the necessity of establishing a  complicated

mechanism for refunding gasoline taxes, two substantial  defects must

be noted.

          First, it would be extremely difficult, if  not impossible,

to ensure that gasoline purchasers paid the full tax.  A compliance

program would have to be established, probably consisting of government

Inspectors making random fuel purchases.

          Second, the charge rate might vary from $2.00  per gallon

for poorly controlled cars in high pollution areas to $0.20 per gallon

for low emission vehicles in rural areas.  Obviously, there would

be a temptation to purchase gasoline from rural stations .in special

low emission vehicles with large gas tanks and then siphon it off

for use in higher emitting vehicles or for sale on the "black market".

In view of these considerations, it Is highly unlikely that a combined

fuel-tax /air-permit system of this sort could be made evasion—free at

reasonble cost.

          To overcome some of the difficulties in combining the two

systems, another economist suggests that it might be  desirable to separate

the two systems and to assume that each will account  for one-half of auto-

mobile operating costs.  However, unless an "average" automobile is

used an "average" amount, this approach will not result in the proper


-------
                                 5-11
defect,  In  conjunction with others, requires that the modified approach
                     1
be  rejected as well.
With Sophisticated Monitoring Equipment

          The difficulties with the "complete" emission charge

systems discussed above are attributable to the fact that actual vehicle

emissions are not measured directly but are inferred from surrogates;

emission class  represents pollution potential, gasoline consumption re-

presents miles  driven, and an air use permit represents location.  If

actual automobile emissions in a given location could be monitored di-
                                                              2
rectly, all of  the difficulties cited above could be overcome.

          One method for monitoring vehicle use was described in the-
                                                                      X
Smeed Report and is now being studied by the British Road Research
             3
Laboratories.   A meter would be mounted in each vehicle that would be

actuated by electric pulses emitted from induction loops imbedded in

the roadway.  As a means of discriminating between locations, the

density of the  loops could be proportioned to the average pollution
1.  For the analysis leading to this conclusion see Anthony B. Low-Beer,
"The Use of Effluent Charges to Control Air Pollution and Induce an
Efficient Allocation of Resources", Columbia Univeristy, 1970, Chapter
5, (unpublished Ph.D. thesis).

2.  It will not be necessary to measure directly exhaust emissions from
individual vehicles, for example, by putting a meter on the tailpipe.
If miles driven in a given location by a specific automobile are known
with accuracy, this statistic could be combined with emissions class for
a reliable estimate of "actual" emissions.

3.  See Road Pricing;  The Economic and Technical Possibilities (London:
HMSO, June J964).
                                5-12


level in the area.  Periodically  the meter would be  read and a charge

imposed corresponding to the estimated social  cost of  a vehicle of  that

emission class driving the metered number of units.

          The development of Automatic Vehicle Monitoring (AVM)  systems

off ere the possibility of both more accurate monitoring of vehicle  use

and the automation of billing procedures.  Using a simple AVM system,

response blocks would be mounted  on cars permitting  scanners located at

various points along the road to  identify the  cars as  they pass.  The

records made by individual cars could be processed by  a central  com-

puter and a monthly bill sent to  individual motorists.   A more sophisti-

cated AVM system would permit the continuous monitoring of the location

of any vehicle within an accuracy of 100 feet  in a metropolitan  area 50

miles in diameter.  A central transmitter would broadcast repetitive

signals — each signal addressing one particular vehicle whose equip-

ment recognizes its own coded signal among all the others.   On re-

ceiving the coded signal, the addressed vehicle activates -a  keyed

transmitter which produces a respond-acknowledge (R-A)  signal.  At  least

three roadside receivers, perhaps on towers, pick up this R-A signal

and relay it to the central computer.  The vehicle's location is then

computed by triangulation using the differences in arrival times of  the

R-A signal at the three roadside receivers.  As above,  charge computa-
                                                        1
tion and billing could be done efficiently by  computer.
1.  For a comprehensive discussion of AVM systems, see An Analytic
and Experimental Evaluation of Alternative Methods for Automatic

-------
                                                                                                                              5-14
                                5-13


                     Summary and Conclusions

          Advantages.   A "complete" emission charge system would allow

each motorist to adjust his automobile ownership and usage behavior in

a manner consistent with his personal value preferences.  The attempt

by motorists, as an aggregate body, to lower transportation costs will

insure a desired air quality level can be met, without resorting to direct

regulation.  This will result, as indicated previously, in increased ef-

ficiency of  resource allocation, and more equitable assessments for

pollution damage.

          The establishment of an emission charge system would probably

alter presently observed consumer automobile purchasing behavior in a

significant  way.  Rather than the present emphasis on performance and

styling, emissions characteristics would play an important role in the

vehicle choice process.  What is more, the explicit desire of motorists

to own low polluting vehicles may furnish the automakers with increased

motivation to produce  low emission vehicles.   And as such time as un-

-conventional vehicles  become available, an emission charge system will
                      1
 speed the transition.
 1.  "In the absence of an effluent charge of some sort, it is difficult
 to see how adequate incentives can be offered for the switch to electric
 /or other unconventiona^/ cars, unless indeed the latter are subsidized
 in some way.  A subsidy, indeed, would have the double disadvantage of
 requiring added taxes usually of a distorting nature, for the financing
 of the subsidy and of increasing the distortions already existing in the
 large hidden subsidies fron which users of private automobiles for com-
 muting in congested areas already benefit; moreover commuters are, as

                                               (continued on next page)
           Problems.  Although the state of the art of monitoring tech-

 nology is well advanced, It is uncertain at the current time whether

 it would be possible to implement emission charges on a large scale;

 neither has sufficient research been done to determine the costs of

 establishing and administering such a charge system, nor to determine

 whether the equipment can be made sufficiently foolproof to serve as

 a basis for revenue collection.   With regard to costs, one source con-

 tends that, at least for the foreseeable future,  pollution costs would

 be insignificant in magnitude to support such an elaborate system of
            1
 collection.

           But even if the mechanics of monitoring and revenue col-

 lection could be resolved at reasonable cost,  there would-be two sig-

 nificant drawbacks to impiementing an emissions charge system.

           First, political feasibility.   A  substantial possibility

 exists that the public will resent the imposition of "taxes on  i riving".
 (continued from previous page)

 a whole, probably better off on the average than those who would
 probably be required  to bear tire burden of the tax as a practical
 matter.  With effluent /emission/ charges in effect, adequate in-
 centives can be provided for the change, and the change can be
 made gradually with the change being made first where the difficulties
 are least and the benefits greatest.  An attempt to promote electric
 vehicles by fiat, as by banning all but electric vehicles and vehicles
 with special licenses from certain areas is likely to produce so many
 cases of throwing the baby out with the bathwater as to encounter
 serious opposition and at best the transition will be made in an
 arbitrary and inefficient manner."  William Vickrey, "Theoretical
 and Practical Possibilities and Limitations of a Market Mechanism Ap-
 proach to Air Pollution Control," Air Pollution Control Association
Meetings, Cleveland, June 11, 1967, p. 8.

 2.  However,  Vickrey further contends an emissions charge system might
be cost efficient if made part  of a system of  collecting congestion

-------
                                5-15


as an unwarranted Intrustion of government into the private sector.

In fact, the invasion of privacy issue will  probably  be  sufficient to  reject

the implementation of an AVM system which would enable the government to

monitor individual automobile use.

          Second, communicability. .Motorists must clearly understand

how the system works if it is to be effective in curbing auto pollution.

Although the concept is relatively simple, complexity will increase as

the system becomes operational.  It is not clear at present how govern-

ment could secure universal understanding of the details of an emission

charge system.

          To sum up, the "complete" emission charge system does not ap-

pear to be a feasible alternative at present.  Of the two. "incomplete"

systems discussed in this chapter, air use permits would be administra-

tively easier to establish and maintain as well as result in greater

air quality benefits; given a choice, Individuals would probably pur-

chase different equipment in reaction to financial penalty, rather than

restrict, their automobile use.

          Subject to the criticisms discussed in Chapter 2 and Chapter 3,

both the tax on emission class and the simple gasoline tax appear to be

administratively feasible and capable of reducing auto pollutant emissions.

With respect to choosing among various emission charge systems, it is

worth remembering that "the real question is not which system is theoreti-

cally perfect but which is actually capable of achieving the'highest de-
                                     1
gree of compliance most efficiently."
1. ' J. Clarence Davies, III, The Politics of Pollution (New York:  Pegasus,
1970), p. 179.
                           CHAPTER  6


                      TOWARD A FEDERAL STRATEGY


          The underlying premise of this  document  is  that  unless

virtually pollution-free automobiles can  be produced  on a  large scale,

federal policies aimed at  control of the  source must  be supplemented

by measures which control  the  other components  of  pollution  damage —

miles driven and location  of use.   Certainly if near-complete control

over the source could be achieved,  the auto air pollution  problem

would cease to exist as soon as enough pollution-free cars were pur-

chased to replace existing vehicles.   However,  three  factors mili-

tate against a highly exclusive emphasis  on control of the source,

(1) the uncertainty surrounding how soon  the automotive industries  can

achieve the stringent control  required; (2) the fact  that  even if the

automotive industries, succeed  in meeting  the 1975-76  emission stan-

dards, the carbon monoxide levels in some cities will still  be in

excess of the 1975 ambient air quality standards; and (3)  the cost

to society of attaining the required degree of  control will  be enormous

These three considerations require  investigation of a "balanced"

federal strategy and will  be discussed, in turn, below.


                             Uncertainty

         Even if one assumes the automobile manufacturers and  other


-------
 j
                                               6-2
                                                                                                                                        6-3
                 automobile,   there  can be no assurance that  they will  succeed  In

                 this  task  In  the near future.  As indicated  In Chapter 1, neither

                 the ultimate  limits of the internal combustion engine,  nor  the

                 necessary  technologies to achieve it are known.  In comparison with

                 the research  experience associated with the  internal combustion

                 engine,  the state of the art in unconventional engine  development  Is
                                                                                        2
                 far less advanced  (though the problems may be less difficult to solve).
                 1.  Congressional displeasure with the progress of  the automobile com-
                 panies  In  controlling pollution, the large body of  pending  litigation,
                 the threat of antitrust action  to restructure  the industry,  along with
                 the mounting public concern over clean air. have probably resulted In
                 an increased commitment on the  part of the automobile Industry to de-
                 velop a pollution-free industry.  Dr. A. J. Haagen-Smlt, one of the
                 nation's foremost authorities on air pollution control, believes that
                 this may be the case.  In a recent interview,  he stated that he is con-
                 vinced  that the auto manufacturers are working hard to perfect anti-
                 emission systems and that "We're so far over the hump [in controlling
                 the internal combustion] that I'm beginning to lost interest."  Cited
                 in "Pollutant Fight in Autos Hailed," The New  York  Times. January 12,
                 1971, p. 17.

                          A similar conclusion Is suggested by  a source generally
                 critical of the auto Industry:

                          ... by emphasizing that the way to  clean air is
                          through a clean internal combustion engine, they
                          [the auto Industry] may feel they have little to
                          lose In supporting auto pollution abatement.  As
                          with auto safety, it was only after repeated at-
                          tacks. . . that safety measures were  taken. . .
                          most of which are now  a cost to the consumer and a
                          profit to the industry.  History may  repeat itself
                          if pollution control devices become a costly "add-on"
                          requiring constant adjustment and replacement.
                 Ideas (Washington, D. C.:  International Research and Technology, February
                 1970),  p.  10

                 2.  Unconventional vehicles also face uncertain consumer acceptance
                 unless  they are clearly superior to conventional vehicles In the cri-
                 teria used  by motorists for vehicle selection.
 What is more,  automakers will not be seeking simply to develop ef-

 fective technology --In view of the increasing cost of vehicles due

 to safety and  anti-pollution requirements,  they will also be trying

 to develop low-cost systems.    Compounding the difficulties, it will

 not be enough,  of course,  to develop prototypes with pollution-free

 characteristics;  if such vehicles are to have a significant impact on

 air quality,  they oust be durable and suitable for mass production.

 With regard to manufacture,  the lead time  from prototype development

 to mass production will  be at least  one  year and probably many more.

          These uncertainties about how much control can be achieved in
                2
 how long a time  suggests that there is  not,  and cannot be,  one and

 only one "solution" to motor vehicle air pollution.   To deal effectively

 with uncertainties,  several  simultaneous supplementary and comple-

 mentary approaches should be followed.   This  rill allow several paths

 to be pursued  in  parallel, and hence preservation of as many degrees

 of freedom as possible until more certain information is available.


                   Protected Carbon Monoxide Levels

          Even If  Inspection of relevant  data  revealed without reserva-

 tion that a pollution-free vehicle could be developed by mid-decade,

 evidence  exists to  indicate that  the carbon monoxide  level in major
1.  It is probably true, as many argue, that the technology could be de-
veloped quickly If cost were not a factor.  Clearly, however, the cost
of the system to the purchaser is a major factor to auto manufacturers..
See  p. 1-5.

2.  As recently as May 1971, during extensive hearings on the progress
being made to curb auto emissions, automakers expressed serious re-
servation about the technological feasibility of meeting the standards
in the required time.  (See Appendix C.)

-------
                              6-4


cities will be In excess of the ambient air quality standard which

becomes effective In 1975.

         According to William Ruckelshaus, Environmental Protection

Agency Administrator, of the seven major metropolitan areas for

which EPA has adequate data, only Cincinnati will come close to

achieving the carbon monoxide standard by 1977.  Ibis news was re-

leased at a briefing at which EPA promulgated its final national
                                                         1
ambient air standards .for the six most common pollutants.   The Ad-

ministrator said that Chicago, Denver, Los Angeles, New York, Phila-

delphia and Washington won't be able to get their carbon monoxide

levels down to acceptable levels before the 1980's without taking ad-

ditional transportation controls.

         "This will mean they will have to make some rather drastic

changes in their commuting habits," Mr. Ruckelshaus warned.  He listed

several alternatives, including outright bans on vehicles during

certain peak hours, coupled with increased emphasis on mass transporta-

tion and car pools and regulations requiring more frequent motor tune-

ups.  These additional measures, he emphasized, would be required even

if auto manufacturers meet their 1975 deadline for carbon monoxide

reductions.
1.  On April 30, 1971, pursuant to Section 109 of the Clean Air Act
as amended, the EPA Administrator promulgated national ambient air
standards for sulfur oxides, particulate matter, carbon monoxide,
photochemical oxldents, hydrocarbons and nitrogen oxides.  Within nine
months thereafter, each state la required by Section 110 of the Act
to adopt and submit to the Administrator a plan which provides for
the Implementation, maintenance and enforcement of these standards
within each region (or portion thereof) within the state.
                               6-5

                                              1
         The  air  quality implementation plans  for these areas, by

 law, must provide for transportation controls including, but not limited

 to  the  following:   emission limitations necessitating installation of

 emission control  (retrofit) devices,  emission limitation necessitating

 conversion of motor vehicle fleets  to low emission fuels or engines,

measures to reduce motor vehicle  traffic (e.g.,  the techniques dis-

 cussed  in Chapter  3 — commuter taxes,  parking limitations, staggered

working hours), expansion or promotion of the use of mass transporta-

 tion facilities, and, at such  time  as determined by the EPA Adminis-

 trator, programs for  periodic  inspection and  testing of motor vehicle
                          2
emission control systems.


                               Cost

         The  actual dollar  cost to motorists  of controlling the source

will be enormous.   As with  most phenomena of  this nature,  great progress

can be made easily and inexpensively  at the outset.   Developing the

technology to "squeeze out" the last  few percentage points of control,

however, will be technically difficult  and costly.   With regard to the

latter, the cost of control devices to  meet Increasingly stringent

federal emission standards  is  rising  rapidly.   For 1968 and 1969 models

the amount was $18-$19 per  car; for 1970,  $36  per car;  and for 1971 it
                             3
Is estimated at $49 per  car.   In  1971 alone,  motorists will pay
1.  Clean Air Act Amendments of 1970.  P.L. No. 91-604, Sec.  110(2)(B).

2.  Federal Register. Vol. 36, No. 67 (April 7, 1971), p. 6683.

3.  Environmental Quality. First Report of the Council on Environmental

-------
                                                6-6
                                                                                                                                             6-7
                 approximately $100 million for auto pollution control equipment.    The

                 application of more stringent standards  will  increase these costs

                 sharply,  especially considering that standards at mid-decade will  be

                 ten times tougher than the 1971 standards  and will  also require control

                 of an additional pollutant,  nitrogen oxides.   One recently published

                 EPA study estimates the initial cost to  motorists of pollution control

                 systems needed to meet the 1975-76  standards  will be $240.   However,

                 in a recent government-industry meeting  (see  Appendix C),  automotive

                 industry  estimates ranged  from $80  to $600 per car  to meet the 1975

                 standards.

                           In addition to the actual dollar cost of  pollution control

                 equipment,  control of the  source under the prevailing standards ap-

                 proach sill result in large  inefficiencies and inequities.   All pur-

                 chasers of new vehicles will have to buy sophisticated control equip-

                 ment regardless of the intensity of their  automotive use or the lo-

                 cation in which they predominantly  drive.   Uniform  standards will  also

                 curtail the range of automobile makes and  models that can  be offered

                 for sale.   Consequently, while across-the-board emission standards may

                 be tiie simplest to administer,  they are  probably not the least cost

                 solution.
1

1
                 1.  Environmental Quality. First Report of  the Council on Environmental
                 Quality; transmitted to the Congress, August 1970, p. 73.

                 2.  "The Economics of Clean Air," Report of the Administrator of the
                 Environmental Protection Agency (Washington, D.C.:  March 1971), Table
                 3-4, p. 3-16.

                          Neither this cost estimate, nor the other cost data cited above,
                 include the additional cost of maintaining such systems, and the in-
                 creased operating cost (fuel penalty cost).  The above cites source
                 estimates these costs to be $20.70 per year.
                 Considerations  for  a  Balanced Strategy

          The central question for the development of  a  balanced federal

strategy to control auto air pollution is  the following:   "What  is  the

optimal allocation of federal effort among controlling the source,  con-

trolling ownership and usage behavior, and controlling the environment,

to achieve some desired level of pollution-free air?"  Ideally,  to  ac-

count for uncertainty, measures  should be  evaluated so as  to  balance

the costs of action against the  risks  and  costs of inaction.   This  will

require knowledge of probabilities —  especially  the probabilities  of

various degrees of control of the source being achieved  at various

points in time.

          It will also require knowledge of the costs  and  benefits  of

the policy approaches detailed in this report, and an  understanding of

the interrelationships between components  of the  system  in which the

automobile is imbedded.  More precisely, questions such  as the following

will have to be answered:

          1.  How significant an impact can new mass transit
          systems have on displacing automobile usage?   What
          Impact can exclusive lanes have  on mass transit
          ridership and car-pool formation?

          2.  If retrofit of control devices on pre-1968 cars
          were immediately required,  would a pollution-free
          vehicle be needed in the near future in most states?
          Would most states need costly emission checking programs?

          3.   To what extent can urban design and traffic  flow
          control technology increase average speed?  Will  in-
          creases in average speed quickly be offset by greater
          automotive use?

          4.   Would it be more efficient to place a charge on

-------
                            APPENDIX
                                                                                                                                         APPENDIX A
                                                                                                                                         Page 2 of 2
          MAJOR FEDERAL AUTO AIR POLLUTION CONTROL LEGISLATION
                                                                                          Date
                                                                                                           Title*
                                                                                                                                      Major Provisions
Date
                  Title
                                                 Major Provisions
                                                                                          1967
1955
I960
1963
Air Pollution Control
Act of 1955
  (P.L. 84-159^

Schenk Act
  (P.L. 86-493)
            Clean Air Act
              (P.L. 88-206)
1964
1965
            No title
              (P.L. 88-115)
            Motor Vehicle Air
            Pollution Control Act
              (P.L. 89-272;.
                                                                                                       Air Quality Act
                                                                                                         (P.L. 90-148)
Temporary authority for research Into
all forms of air pollution and possible
control methods.

Directed Surgeon General to make a
two-year study of the effect of vehicle
emissions on public health.  (This
was made a permanent responsibility of
the Surgeon General in 1962, P.L. 87-761.)

Replaced the 1955 Act and provided for
grants (1964-1967) to state and local
governments for the establishment and
development of air pollution control
programs.

Directed HEW to develop devices and
procedures for motor vehicle pollution
control in concert with automotive and
fuel industries and other interested
parties.

HEW was also required to report to
Congress semi-annually on progress in
abating auto emissions.

Required the General Services Administra-
tion to set vehicle emission standards
similar to the California standards set
In 1964, for vehicles it purchased for
Federal use.

Authority for HEW to set standards on
new motor vehicles.  Sample vehicles
could be submitted to HEW by manufacturers
on a voluntary basis for testing and
certification.
                                                                                          1970
                                                                                                  Clean Air Act Amend-
                                                                                                  ments of 1970
                                                                                                  (P.L. 91-604)
Specific authority  for  research  and
development on  fuels and vehicles
(Section 104).

Authority  for HEW registration of  fuel
additives.

Exception  of California from National
auto emissions  standards so  the  state
could enforce more  stringent standards.

Federal grants  to states for auto  emis-
sion inspection systems.

Establishment of a  Presidential  Air
Quality Advisory Board.

Establishes standards for new motor
vehicle emissions for 1975-76.

Makes certification of new cars  a  re-
quirement for sale.   Also provides
authority for revocation of  certificates
of conformity and assembly line  testing
of vehicles.

Authority to regulate fuel additives.

Authority for increased expenditures for
Federal purchase of low emission vehicles.

Requires manufacturers to warranty pol-
lution control systems.
                                                                               1.   For a detailed year by year history of federal automobile air pollution
                                                                               policy, see Donald D.  Kummerfeld and Gregory Uilcox,  "Federal Policy
                                                                               on Auto. Air Pollution Control", Center for Political  Research Report.
                                                                               April 13, 1970,  Appendix A.

                                                                               2.   Despite differing titles, all legislation after 1963 constituted
                                                                               amendments to the Clean Air Act.

                                                                               3.   The Motor Vehicle Act was Title II of P.L.  89-272.   Title I consisted

-------
                                              6-8
J

j
           stimulate the auto manufacturers  to produce pre-
           dominantly  low-emission vehicles?  Or stimulate
          motorists to maintain their vehicles better or
           drive  less, especially in critical locations?

           In  sum, this report should be viewed as a  first step in the

development of a balanced  strategy; it sets forth the range of policy

approaches in a  meaningful analytic framework.  Additional research  is

needed at  this time to obtain precise estimates of the costs and bene-

fits of  supplementing existing governmental policy with the measures

detailed in the  foregoing  chapters.  Particularly important would be

an investigation of the political, legal, and administrative difficulties

of implementing  such measures.  For example:

           1.  What political obstacles are paramount (e.g.,
           strong resistance to work staggering plans on the
           part of powerful business interests)?

           2.  What legal authority (e.g., to require retrofit
           devices or  to establish emission checking  programs)
           is  required in addition to existing laws,  regula-
           tions, licensing systems and so forth?

           3.  What administrative difficulties can be identi-
           fied (e.g., Impracticable vehicle inspection programs)?

          Information as to Che air quality improvements realizable under

each technique,  and their associated costs and implementation difficulties,

will be vital for the development and selection of a "preferred" strategy

package.   Research data and collection must begin shortly if supplementary

policies are to be developed soon enough to reduce the costs of clean air,

or,  perhaps more importantly,  to provide a "fail-safe" system to insure

that Che quality of our air at mid-decade will be in compliance with the

standards established to protect public health.
                                                                                                                                         APPENDIX  B

                                                                                                                                                              1
                                                                                                                                    EXHAUST EMISSION STANDARDS


                                                                                                                           Following the lead of California, where standards were estab-

                                                                                                                 lished for carbon monoxide and hydrocarbon emissions in 1964, the Federal

                                                                                                                 Government established emission standards for these two pollutants for

                                                                                                                 all automobiles sold after January 1,  1968.  The standards were tightened

                                                                                                                 for 1970-71 models with the intention of achieving an 80 percent hydro-
                                                                                                                                                                                          2
                                                                                                                 carbon reduction and a 69 percent reduction in carbon monoxide emissions.

                                                                                                                 These reductions have been realized when exhaust emissions are measured

                                                                                                                 by the current test procedures.  However, in July 1970 the existing pro-

                                                                                                                 cedures were revised.   Using the newly-developed test procedure,  the achieved

                                                                                                                 degree of control was considerably lower than expected —  a 69 percent

                                                                                                                 reduction in hydrocarbons,  and a 60 percent reduction in carbon monoxide

                                                                                                                 emissions were actually realized.   The 1970-71 standards were modified

                                                                                                                 to provide the intended degree of control,  and these revised sCandards

                                                                                                                 will have CO be met by 1972 model cars.
1.  Exhaust emissions account for approximately  100 percent of the
nitrogen oxide  emissions, 100 percent of  the partlculate emission,  and
55 percent of the hydrocarbon emissions.   The uncontrolled internal  com-
bustion engine also emits contaminants from  two  other  locations — fuel
tank and carburetor evaporation  (20 percent  hydrocarbons),  and crankcase
blowby (25 percent hydrocarbons).  However,  complete control over the
latter has been achieved and the evaporative losses have  been reduced to
negligible amounts.  Thus the task of the  present air  pollution policy
(as far as the internal combustion engine  is concerned) is  almost ex-
clusively to reduce exhaust emissions.

2.  Reductions are measured relative to uncontrolled (pre-1968)  vehicles.
               1.  The Institute of Public Administration and TRW, Inc., have recently
               comenced (August 1, 1971) a six-month project designed to investigage
               precisely the sorts of questions raised above for the six cities with
               the nose severe carbon monoxide problems.  This study is being done for

-------
                                    B-2
                                   Table A
                 EXHAUST EMISSION STANDARDS AND UNCONTROLLED
                           VEHICLE EMISSION LEVELS

                            Former Test Procedure
Baseline (uncontrolled ve-
hicle)*
Present standards .(in-
tended degree of control)*
Hydrocarbons
G./mi.
11.2
2.2
cent
Carbon
Monoxide
G./mi.
73.0
80 23.0
Per-
cent
Oxides of
Nitrogen
G./mi.
69 ! N.A.3
Per-
cent
N.A.
A
Revised Test Procedures
Baseline (uncontrolled ve-
hicle)*
Equivalent present stan-
dards (achieved degree
of control)*
1972 Standards (control)*
1973 Standards (control)**
1975 Standards (control)**
1976 Standards (control)**
14.6
4.6
2.9
.41
.41
69
80
---
!
116.3
47.0
37.0
60
69
3.4 —
3.4 |-
6.0
3.0
3.0
.40
50
 1.  Grams per mile emitted.
 2.  Percentage reduction from uncontrolled vehicle.
 3.  No standards applicable.
 4.  Final regulations have been promulgated for the  measurement of hydro-
 carbons and carbon monoxide in 1975 and nitrogen oxides in 1976.   These
 procedures are being proposed as the procedures to be used for 1973 model
• year vehicles.

 * *Source:  APCO*  Cited in Environmental Quality. First Annual Report of
 the Council on Environmental Quality;' transmitted to the Congress August
 1970, p. 77.
 **  Source:  Federal Register.  July 2,  1971.
                                B-3


           In addition,  in February 1970 the Secretary of HEW proposed

 standards to limit for  the first  time emissions of nitrogen oxides be-

 ginning with 1973 models and  emissions of particulate matter beginning

 with  1975 models.   In an unprecedented move,  however,  Congress established

 new car exhaust  emission standards for 1975-76  into federal law.   These

 standards, embodied in the Clean Air Act Amendments of 1970,  will  re-

 quire a 90 percent reduction  in emissions  as  compared to 1971 model
          1                                                    '—~~
 vehicles.    Table  A summarizes both the current and the  recently  finalized

 exhaust emission standards.

           The air  quality implications of  the current  federal exhaust

 emission standards   and the  effects  of non-compliance of the production

 fleet are summarized  in  information provided  to the Senate Subcommittee

 on Air  and Water Pollution by the National Air  Pollution Control  Ad-

ministration:

                Given a knowledge of  the emission  rates  for un-
           controlled  vehicles and  for the controlled prototype
           fleets,  plus the predicted  growth in  number  of vehicles,
          it becomes  possible to project the  effects of  the Federal
          mobile emission standard program on total  national  ex-
          haust emissions of hydrocarbons and carbon monoxide.  Air
          quality  is  a complex function of total emissions; there-
          fore, changes in total emission values may be  assumed to
          be representative of the changes in air  quality in  large
          metropolitan regions.

                The effect of each phase of the Federal mobile
          emission control program is illustrated by the  curves
          labeled A in the accompanying figures.  Three  cases are
          considered.   Figures I and  II represent  the projected
          effect of imposition of the 1968 and  1970  exhaust
          emission standards ....  The curves labeled  "A" thus
          represent the relative changes in expected air  quality,
          as projected from present and proposed Federal emission
          standards for exhaust emissions of carbon monoxide and
          hydrocarbons and from test data on prototype vehicles ....

-------
                                     B-4
                     For some  time, it has  been apparent  that a
             discrepancy exists between  the average emission
             rates of the prototype fleet  and the average emis-
             sion  rates of the  production  fleet in the hands of
             the public,  [see  pp. 1-17  to 1-20]  ....   The
             differences between curves A  and B represent the effect
             of noncompliance of the production fleet.  The produc-
             tion  fleet  data indicate that air quality in 1985
             will  be  25 percent  higher in  hydrocarbons and 13 per-
             cent  higher in carbon monoxide than it would  have
             been  if  there were no discrepancy  in emission rates
             .  .  .  the  oxidant levels  in 1985 will  also be ap-
             proximately 25 percent higher.  This analysis is
             based on data gathered from 1968 and 1969 model
             year cars.   To the extent  that production fleet
             performance can be made to  approximate prototype emis-
             sions  more  closely, in 1970 and later  model years,
             the  discrepancies in  the projected curves can be
             reduced.1
                                                                                                                    Hjm I. Project*) effects of 1961 M.) 1970 Federal t.ti»lo
-------
                     B-6
                                                                                    B-7
       The air quality Implications of the present and future stan-

dards for the three most significant automobile generated air pol-
                               1
lutants are depicted in the following diagrams.
EMISSIONS
TONS PER YEAR)
   HYDROCARBON EMISSIONS FROM
   MOTOR VEHICLES IN THE UNITED STATES

                                       1965-1990
1.  Source:  Annual Report of the Environmental Protection Agency to
the Congress of the United States in compliance with Section 202(b)(4)
Public Law 90-1,48, pp. 6-8, 6-9, 6-10.
                                                           g§   8.0
                                                           O  =J
                                                                   4.0


1965
                                                                            1970
                                                                                                           1990
      1975    1980    1985
        MODEL  YEAR
PROJECTIONS BASED ON ACHIEVING

-------
             B-9
                                                               B-8
   OXIDES OF NITROGEN EMISSIONS FROM
   MOTOR VEHICLES IN THE UNITED STATES
                              1965-1990
   %
Q
in
 00 S
=> 0 0 0 g


^ 	 >





N
s





\
\




\

V
1965-1990




*• — —





                                                    1965
                                                                1970
                                                   1990
     1975    1980    1985
      MODEL YEAR
PROJECTIONS BASED ON ACHIEVING

-------
                          APPENDIX  C


                          RECENT DEVELOPMENTS


          Since the initial draft of this document was submitted to the

Office of Air Programs on March 1, 1971, a number of significant de-

velopments have occurred pertinent to automobile air pollution control.

Those relating to the establishment of new exhaust emission standards

are incorporated in Appendix B.  The following discussion extends the

main body of the report from March 1, 1971, through August 1, 1971.
                  Compliance with Emission Standards
                              1
Emission Control Hearings Held
          On May 6 and 7, 1971, the Environmental Protection Agency held

bearings in Washington to help Administrator Ruckelshaus judge whether

automobile manufacturers are making a "good faith" effort to meet motor

vehicle standards for 1975 and 1976 models.  Under the Clean Air Amend-

ments of 1970, the-Administrator may grant a one-year extension of the

emission reduction standards if he finds that the manufacturer has made

adequate efforts to meet the standards but is still unable to do so.

Twenty-one representatives of domestic and foreign automobile manu-

facturers, related industries, professors, scientists, state govern-

ments and public interest groups, along with Administrator Ruckelshaus,

testified at the two-day hearings.
1.  This section draws heavily upon the coverage of  this event which
appears in CPR Research, Current Actions in Air Pollution Policy.
May 1-June 1, 1971.
                                C-2


           Probably the most significant testimony came from Mr.

 Ruckelshaus.   He stated  that the 1970 Act  "does not permit traditional

 concepts of satisfactory vehicle driving performance to stand in the

 way  of whatever  changes  in  vehicle design  and  power system are needed

 to control emissions."  He  went on to state  that "the same is true

 with regard to vehicle cost."  Consequently, the price that must be

 paid for preserving a  healthy environment  may  be a  more expensive car

 that cannot deliver the  road performance of  today's high-emission

 vehicles.

           More important was the EPA  policy  toward  suspension of the

 effective date of reduced standards.   Ruckelshaus said that it was his

 present  judgment  that  if even one manufacturer was  able to comply with

 the  standards  by  the deadline date, then no others  would be issued ex-

 tensions.   This hard-line stance is indicative of the EPA  assessment

 that uncontrolled automobile emissions  are a major  threat  to the public

health and that,  of the  six pollutants  for which ambient standards have

been set  (hydrocarbons,  photochemical oxideants,  sulfur oxides,  oxides

of nitrogen, particulate matter and carbon monoxide),  only sulfur oxides

and  particulate matter can be effectively  controlled without  auto-emission

reductions.

           The  testimony  from the  automobile industry ranged  from extreme

pessimism  about reaching the reduction deadline  expressed  by  American

Motors ("there is virtually no  possibility") to more optimistic  state-

ments made by Ford and other manufacturers.  For the most  part,  chances

of meeting the hydrocarbon and  carbon monoxide standards in time were

considered possible, while oxides of nitrogen requirements  seem  un-


-------
                     :"         C-3_


          In the annual report to the Congress required by  the  Clean
                           1
Air Act Amendments of 1970,  the Environmental Protection Agency noted

the concern of the manufacturers, but stated  It was "moderately opti-

mistic" the standards could be met.


Exchange of Technical Information

          As discussed in Chapter 1  (see pp.  1-30 to  1-32),  there has

been a continuing debate over the amount and  kind of  information ex-

change desirable to  foster progress  in the development of new tech-

nology -- and that amount which might serve to lessen competition.  In

the past several months, various representatives of the auto industry

(including organized labor) and some federal  legislators have repeated

their contentions that progress in emission control technology  is best

achieved through unrestricted information sharing.  However, in the

recently released report to the Congress mentioned above, the Environ-

mental Protection Agency announced that it agrees, in general,  with the

Department of Justice, that progress in automobile emission  control is

best assured through primary reliance on competition  and independence

in research and development efforts conducted by manufacturers.


Incentives to Low-Emission Vehicle Development

          Federal Clean Car Incentive Program.  This  program is designed

to foster private development of new types of low emission  vehicles re-

lated to the 1975 and 1976 emission standards (see p. 1-41).
1.  P.L. 90-148, Section 202(b)(4).

                                   ••-•  .   -•'.••-.£.'..<   .  ; •        s,«4-  t:
                                                   -"•" , '  .              "  i""ir
           Since Its inception in January 1971, with approximately 20

 initial proposals from industry,  ten different vehicle systems have

 been accepted into the program for further consideration.  In May

 1971,  three contracts were approved to provide prototype cars for

 testing.   The Incentive Program is expected to provide valuable In-

 formation about the feasibility of reaching the 1975-76 emission

 standards.


 Low-Emission Vehicles Purchase Program

           Section 212 of the  Clean Air Act provides for the creation

 of  a Low-Emission Vehicle Certification Board (See pp.  1-42,  1-43).

 EPA initially certifies vehicles  which discharge significantly less

 pollutants  than required by current federal regulations.   The Board

 identifies  the class  of vehicle for which the selected  cars are

 considered  suitable substitutes taking into .consideration factors such

 as  performance and cost of maintenance.   Certified vehicles may be

 purchased for use in  government fleets at premiums of up  to 100 percent

 over the prices normally paid  by  the government  for equivalent vehicles.

 The  non- statutory members  of the  Board have been named  by the President

 and  its first meeting was  held  on June 18,  1971.   At that time the

board adopted  initial procedural  regulations.


                              Fuel  Policy

Regulation of Lead Additives

          The major tactic in the federal  strategy  to control  atmos-

pheric lead levels will be the regulation of the  lead content  of motor


-------
                               C-5


of the broadest possible range of control technology -- since some

premising enission control devices (e.g., catalytic mufflers) can be

deactivated to great extent by use of a leaded gasoline.

          In the January 30, 1971, Federal Register, the EPA Adminis-

trator published his intent to promulgate regulations to control lead

additives to motor fuels.  The Office of Air Programs intends to re-

quire the general availability by July 1974 of lead-free gasoline of

an octane quality suitable for 1975 and subsequent model year auto-

mobiles..  OAF also announced it is in the process of developing a

schedule to reduce the lead content of current "regular"  and "premium"

grades of gasoline from present levels.of approximately 2.5 grams per

gallon to no more than 0.5 grams per gallon.  It is intended that the

schedule now under development require lead additives to gasoline be

phased out as quickly as is technologically possible.

          EPA is now considering the (statutorily required) available

scientific, medical and economic data prior to publishing proposed

regulations on lead additives.


Lead Additive Tax

          In February 1971, the Administration announced its Intention

to submit again legislation calling for a tax on lead additives in

gasoline.  A bill with this intent was killed in Committee during the

91st Congress (see p. 1-49):  On the basis of the old legislation,  the

Treasury Department In cooperation with EPA Is writing a new bill In-

corporating the findings of new studies and conferences  with affected

Industries.  The legislation is expected to be submitted during the

next cession of Congress.
                               C-6


                       Transportation Controls

          .As detailed in Chanter 6,  there  has .been increasing concern

with the development of transportation  control techniques (e.g.,  car

pool incentives, work staggering) to supplement ongoing efforts to re-

duce emissions by technological redesign of the source (engine-fuel

system).  Transportation control plans  are,  of course, required to be

part of the air quality Implementation  plans which states must submit

to EPA by January 30, 1972.                                          .

          It is clear that EPA expects  localities  with severe air

pollution problems to incorporate stringent  transportation controls

In their implementation plans.  An example is  the  suggestion of Dr.

John T. Middleton that Los Angeles might Include staggered work hours,

provision for a four-day work week,  abolition  of gasoline as a fuel,
                                                            1
and a mandatory requirement  for mass transit in some areas.   He also

said that the Federal Government would  write an air pollution control

plan for California if state and local  governments fail to plan to

meet national air quality standards.
1.  John T. Hiddleton, Address to Los Angeles County  Environmental

-------