REDUCING AUTO EMISSIONS
SOME RELEVANT FACTS
An Address by
Robert L. Sansom
Assistant Administrator for
Air and Water Programs
U.S. ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C, 20460
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REDUCING AUTO EMISSIONS:
SOME RELEVANT FACTS
Robert L. Sansom
Assistant Administrator for Air and Water Programs
U. S. Environmental Protection Agency
This is an important conference. We are setting in place the last
part of the regulations and policy framework to clean up mobile sources
so that ambient air quality standards can be met in 1975 or 1977.
In our progress we have passed at least two major milestones:
--the Clean Air Act amendments of 1970; and
—the Administrator's decision last April not to extend
the 1975 deadline for the auto manufacturers.
Now we approach the third milestone--the implementation of
transportation controls—vehicle emissions inspection systems, vehicle
modifications, and mass transportation alternatives. These must be
implemented in 28 AQCR's in 18 States, by 1977 at the latest. Appro-
priately, the last part of the framework will be set in place by local
and state officials.
Before we embark on the discussions of the next three days, we
should take notice of criticisms of our past decisions, pf those who
question whether we are on the right path. Some of our major periodicals
PRESENTED AT THE NORTH AMERICAN CONFERENCE ON MOTOR VEHICLE EMISSION CONTROL,
ALBUQUERQUE, NEW MEXICO, NOVEMBER 13, 1972
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and almost every industry leader has, within the last few months
raised serious questions about whether our actions in carrying
out the mandates of the Clean Air Act amendments are correct.
There is no question that our actions have far-reaching implica-
tions, affecting in some form half of the American population who
drive the more than 80 million US vehicles. What is our response
to these criticisms?
The first issue is whether we have defined the problem correctly.
Is the automobile a major polluter?
It is estimated that on a nationwide basis, in 1970, gasoline
powered motor vehicles contributed 50% of the hydrocarbons (HC)
7Q% of the carbon monoxide (CO.,)--and 30% of the nitrogen oxide (NOX)
emitted to the air. In many individual cities, however, motor
vehicles contributed even more—in the 90% range in some cities.
In short, the automobile is the single most important source of these
air pollutants in this country. The .Clean Air Act of 1970» which
mandates that the automobile industry reduce these emissions by at
least BQ% by 1976 will go far in removing automobiles from the
pollution picture.
Some have criticized our goals by comparing the potential for
damage from automotive pollutants to potential damage from non-
automotive pollutants:
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-- one critic acknowledges that approximately 40% of man-made
pollutants by weight come from the auto but contends CO
is only l/30th to l/20th as harmful as other pollutants
such as SOX.
This type of statement assumes the quantification of all the effects
of air pollution on man. All of the harmful effects have yet to be
identified, let alone quantified. As for the comparison of CO and SOX,
it is true that, for example, calculations can lead one to the conclusion
that on a pound-for-pound basis SOX is potentially more dangerous than
CO. A crude way to obtain a relative index of toxicity is to compare
the primary standards for each. Although there is no one exposure time
common to both pollutants, such comparisons show that the toxicity ratio
might range from 8:1 to an upper limit of 30:1, but not above 30:1. But
this crude analysis is not sufficient, because until we know what the
dangers are beyond the concentrations level in the standard, we can't
say whether one pollutant will have a greater impact than another once the
standards are exceeded. It does not appear logical to control one pollutant
and not another just because the former might be more toxic. They both
should be controlled.
Another criticism we hear is that the carbon monoxide blood levels
of people in major cities across the country are well below the level
at which there is any health effect.
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We are presently co-funding a sampling program to determine the
carboxyehemoglobin (CQHb) levels of people in major cities throughout
the United States. Over 14,000 samples have been taken and the results
of the study are now being tabulated. One set of preliminary results
shows that the mean COHb level of non-smoking males, ages 39-49,
living in Chicago, is 3 percent. Because the carbon monoxide air
quality standards are designed to protect against levels In excess of
2 percent COHb> we must reject this criticism. [Incident!*ally, the
levels for smokers are substantially higher at 5 to 7 percent.]
Another criticism of the automobile standards is that natural
sources emit more pollutants than automobiles. It has been stated
that natural sources emit ten times as much CO worldwide as all
industrial and automotive sources combined.
Although this may well be true, it is irrelevant to the problem
at hind. Because man concentrates his emissions in metropolitan'
areas, he is exposed to pollutant concentrations far beyond natural
background levels. Because we recognize that natural removal
processes exist, our primary goal has not been to eliminate all
emissions, but to reduce the density of emissions in all regions to
levels such that natural dispersion and removal processes can prevent
the buildup of unnaturally high pollutant concentrations.
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Yet another type of criticism is to contrast the emissions from
the 1975/76 automobiles with emissions from man's other activities.
We examined these criticisms with the following results:
— We heard that the 1975 standards would result in an
automobile that emits as much HC as an average residential
yard. We checked this out, only to find that the appropriate
comparison would be to a forest {not a yard) at least three
orders of magnitude as large as a 40 sq. ft. yard. Again
critics have missed the key point: automobiles lead to
high contributions of pollution because thousands of them
concentrate in small areas, exceeding nature's dispersing
and absorptive capacities,
— Along this same line, I have heard that if we burn a log
in our fireplaces a day we will equal CO allotment for our
1975 car. True. But we could each have a roaring fire
all day with a pre-controlled car allotment, and if these
fires could be concentrated as automobiles can, we would
have a serious pollution problem.
— We are also told the 1976 standards are on a daily basis
equal in NOX terms to three gallons heating oil per person.
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Our analysis bears out this relationship, but it also shows that
the average person consumes a BTU equivalent load of 8 gallon per
day for all residential uses of fossil fuels. Thus, the 1S76 NOX
standards are equivalent to 2.5 times the NOX emissions from the
average person's daily BTLI consumption for non-transportation uses.
— These criticisms don't stand up to close scrutiny. The
automobile is a serious pollution problem.
Nevertheless, we know the automotive standards must stand up
to criticism. EPA is fully aware of this requirement. We are willing
to change our minds if an error is found. For instance, we found
our NO measurement techniques could have caused us to overestimate
ambient air concentrations and thereby overstate the degree or at
least the scope of applications geographically of automotive control
required to protect the public health and welfare. As we announced
in June, we have undertaken an extensive program using new measurement
techniques to either validate our requirements or change them.
This brings me to the second major milestone: the Administrator's
May decision to deny the auto manufacturers' extension request.
Thus, the question arises* even if these emission goals are
desirable is the technology available to achieve them in 1975 and
1976? One of the most important roles of EPA is to create the
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the regulatory and other incentives for industry to push technology
as fast as possible. This is a controversial role. But it is
vital. I was one of many economists who was very skeptical of the
Lrmits to Growth thesis. It is hardly reasonable to say bad
technology grows exponetially while good technology grows linearly.
But as critics of this thesis we must ask ourselves, what
incentives are there for clean growth? The 1975/76 auto standards
are such a regulatory incentive.
The Administrator's May, 1972, decision denying the auto
manufacturer's request for an extension was in my view an important
impetus to the development of a cleaner internal combustion engine
technology.
The rate of technological advance has risen sharply. I am
encouraged to see that industry is making progress. Some of the
data we have seen indicate that 1975 cars may meet the 1975 standards
and consume no more gasoline and be as driveable as cars currently
being sold.
We must not blindly pursue technology. We must determine if
it be acceptable in terms of cost and energy requirements. What
are the facts? Some manufacturers have consistently claimed that
the incremental cost of an automobile due to EPA's pollution control
efforts will exceed $600. Our estimates show that the increased
sticker price of an average US automobile in 1975 should be on the
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order of $150 to $300 over the price of a comparable 1968 car.
This estimate was confirmed by industry testimony before the EPA
public hearings in May of this year. It is also clear that the
cost will be even lower for cars with four and six cylinder engines.
We are confident that these cost increases can be further reduced
through continued development, engineering and optimization of the
basic systems, as well as through the development of new power systems
with inherently better emission characteristics. Even accepting
current costs one calculation I have seen that includes both
investment and maintenance cost yields a total cost to the consumer
in the range of about 40tf to $1 per week.
Energy consumption is another standard by which this technology
has to be judged. And, the question of fuel penalties from emission
control devices has also received considerable recent attention in
the press. Our research in this area does indicate that on the
average current model year vehicles show poorer fuel economy character-
istics than did vehicles manufactured before emission control devices
were required. Our figures indicate an overall fuel economy decrease
from pollution control devices of 7% in 1973 model year vehicles over
pre-1968 vehicles. But let's put this 7% into perspective. The
automotive industry has indicated that there is a 5-6% fuel penalty
associated with the introduction of automatic transmissions. There
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is an average of about 9% fuel penalty associated with an
automobile air conditioner, but this can range up to 20% in
urban driving on hot days. And, factory air conditioning is
installed on over 60% of all new cars on the market.
The type of engine used in the automobile is also a
significant variable in terms of fuel consumption. The available
data on diesel-powered automobiles show a 70% increase in fuel
economy over an automobile of the weight using the gasoline,
spark ignited, reciprocating engine which dominates the American
market. On the other hand, data available to EPA on the Wankel
shows a 351 decrease in fuel economy. The stratified charge engine
which is a prototype low emissions engine being developed jointly
under Army and EPA funding, shows a 121 increase in fuel economy over
the average 1973 vehicle of similar weight at a- significantly lower
emission level.
But the largest impact on fuel economy is associated with the
general industry trend toward heavier vehicles. The fuel economy
of the upper and lower bound of vehicle weights commonly found in
the US varies by 1501. The average current model 5S000 pound
vehicle achieves approximately 10 miles per gallon under simulated
urban driving conditions compared to 25 miles per gallon for 2,000
pound vehicles. Thus, the car buyer has a direct and effective method of
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achieving better fuel economy through his choice of the weight of the
vehicle he purchases.
In summary then, we have found some fuel penalty associated
with the introduction of pollution control devices. However, this
increase is relatively minor when viewed in the light of Detroit's and
the consumer's trend toward cars with increased weight, air condi-
tioning, power equipment, automatic transmissions and now the Wankel
engine.
With the energy crisis upon us, much can and must be done to
minimize energy consumption from mobile sources—sources using
about 40& of the petroleum resources in this country. The stratified
charge engine, or the diesel, or a shift to smaller cars—all these
measures—would have substantial fuel economy advantages. Surely,
these alternatives should be at the top of our list of measures to
save energy, and an easing of our emission goals at the bottom.
In sum, the evidence available to EPA indicates the technology to
meet the 1975 standards is available and can be had at a reasonable cost
to the consumer and with energy penalties much less severe than
those associated with a broad range of conveniences.
I have reviewed criticisms of the program to remind us as
we begin this conference that we must weigh the choices facing us in
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the area of transportation controls carefully. Our analysis must be
as precise as possible and we must weigh social and economic impacts.
During the next three days we will be considering three major
transportation control alternatives: Motor Vehicle Modifications,
Emissions Inspections, and Transportation System Controls.
Determining the proper mix of these options...Determining how
they would perform under varying conditions in the various localities...
Calculating the percent of relief we could expect from each and off-
setting beneficial effects against economic costs and social burdens...
These are the Conference objectives.
Let me briefly examine each option in turn. Vehicle modification
appears to be a feasible and readily available alternative open at
present.
Emission requirements could be extended to our pre-1968
vehicles and made more stringent on 1968 to 1974 models. Currently,
approximately 60% of the nation's automobiles—all those manufactured
prior to 1968--have no form of exhaust pollution control device.
The possibility of modifying or retrofitting older models has
strong appeal in light of the fact that, depending upon age and degree
of maintenance, they often emit many times more pollution than new
models, and that in the next few years they will continue to contribute
disproportionately to air degredation.
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Retrofit systems have been developed and generally follow a
similar approach of combining carbureator and distributor modifications
and adjustments, vacuum advance, and raising the engine operating
temperature. Catalytic retrofits are also available.
Certainly retrofitting could be an effective, short-term solution
even though -older vehicles are being phased out of use at a rate of
approximately 10% per year.
Emission Inspection systems are the second transportation control
alternative. Any mechanical device must be maintained. To assure
maintenance, as well as identify high emitters, periodic inspection
appears to be required. Sections 110 and 210 of the Clean Air Act
provide for such inspection if deemed necessary and practicable, and
EPA's recent decision on the allowable maintenance on 1975 and later
emission control systems assumed reliance on inspection systems.
Further progress toward creation of such a program depends upon
satisfactory resolution of such key issues as who will set up and
operate the required facilities; which test cycle would be the quickest,
cheapest and most accurate; and questions of relative costs, manpower
requirements, and implementation times.
Along with vehicle modifications and inspection the third option
of transportation systems controls has been advanced as a pollution
reduction approach with considerable, and as yet, largely unexplored
potential.
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Evaluating these claims is considerably more difficult than
evaluating modifications hardware, and our knowledge is correspondingly
less complete. At present we have a fairly good idea of what the
short-run alternatives are, some very gross estimates of their
likely effectiveness, a good deal of information on what some of
the key variables that influence effectiveness are, and a very poor
understanding of the monetary and social costs.
Furthermore, the improvements that can be achieved are likely to
vary considerably from city to city, depending on such things as
urban structure, the dispersion of origin and distination points,
the extent to which mass transit is already used, etc.
Most non-hardware transportation control alternatives—e.g.,
higher parking fees—require mass transit improvements because if
auto use is discouraged, alternative transportation will be needed.
Leaving aside for the moment coercive means of encouraging mass
transit use, the most important mass transit improvement that can
be made is to decrease door-to-door travel time. Travel time is a
more important determinant of transit ridership than cost. And
direct access time may be more important than linehaul time. This
means that transit improvement is likely to require not only the use
of express bus lanes and the like, but also improved collection and
distribution systems.
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It may be, however, that to be most effective in reducing emissions,
mass transit will have to be associated with vehicular restraints or
pricing policies designed to discourage automobile use. Without such
measures, it may be that no mass transit system can sufficiently attract
enough drivers from their cars to achieve the necessary reduction in
auto trips.
Answering questions such as those I have just raised is the
purpose of this conference. Local and State officials will labor hard
over these issues in the next few months. The public must be involved.
EPA has asked the States requiring transportation controls to
submit plans by February 15, 1973. In the next few weeks, we will be
issuing guidelines describing what constitutes an acceptable plan,
defining maximum feasible technology, and so forth.
While the measures discussed here are the last part of the
regulatory framework to be put in place, they are among the first
that will impact on the public. We must achieve our air pollution
goals. But, we must do so with minimum cost to society. The chief
value of this Conference will be in devising ways of accomplishing
these objectives.
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