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
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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
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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
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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
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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
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- 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
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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
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- 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
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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
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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.
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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.
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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
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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
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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
leadfree 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
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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
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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.
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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
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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 evasionfree 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
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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
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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
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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
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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 ....
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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
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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
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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
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