A PRESENTATION TO THE WASHINGTON OPERATION RESEARCH
       COUNCIL'S THIRD COST-EFFECTIVENESS SYMPOSIUM
                     "MARCH 18-19, 1974  —
               NATIONAL BUREAU OF STANDARDS
                  GAITHERSBURG, MARYLAND
       Analysis of Control  Strategies to Attain the
National Ambient Air Quality Standard for Nitrogen Dioxide
                       Presented by
               John Crenshaw, Allen Basal a
       Office of Air Quality Planning and  Standards
           U.S. Environmental Protection Agency
       Research Triangle Park, North Carolina  27711

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                                ABSTRACT

     This paper discusses the methodology and conclusions of an analysis
that evaluated alternative air pollution control strategies that achieve
the National Ambient Air Quality Standard (NAAQS)~for N02 (nitrogen
dioxide).  The analysis was undertaken by the Environmental Protection
Agency (EPA) in the summer of 1973 to determine the level of NO  (nitro-
                                                               X
gen oxides) emission control from mobile and stationary sources required
to achieve the standard.
     The primary objective of the analysis was to determine an efficient
air pollution control strategy that would attain and maintain the annual
N02 standard of 100 yg/m3 despite the rapid growth of NO  sources.   A
                                                        A
proportional model was used to simulate air quality data at five-year
intervals out to 1990.  The model used current air quality data, six
categories of NO  sources (light, medium, and heavy duty vehicles,  in-
                J\
dustrial processes, area sources, and power plants), five sets of
growth rates for each source category, two levels of stationary source
control, and four NO  automotive emission standards.  A proportional
                    /\                                  *
relationship was assumed between total annual NO  emissions and annual
                                                J\
average N02 concentrations. "Control costs were calculated for each
strategy.  Fuel penalty costs were calculated for each level of mobile
source control.
                *
     From the analysis, EPA concluded and recommended that the 1977
automotive standard of 0.4 grams/mile should be revised to 2.0 grams/
mile.  In addition, more stringent emission control should be placed
on new and existing stationary sources in regions with high N02 con-
centrations.  If adopted, this recommendation would change the national

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                                    2

N02 control strategy.  The recommendation was made after evaluating

projected air quality, control  costs, and fuel penalty costs.

BACKGROUND

     The Clean Air Act of 1970  requires that the Administrator of EPA

establish ambient air quality standards for any pollutant which,  in

his judgement, adversely effects the public health and welfare.   An

ambient air quality standard implies that at no location in the nation

may a parcel  of air contain more than a specified concentration of the

pollutant.  Air quality standards are expressed in micrograms  per cubic

meter (ug/m3) or parts per million by volume (ppm).  In addition  to

requiring air quality standards, Congress, through the Clean Air  Act,

set emission standards for new  automobiles.  Based on 1970 N02

measurements, Congress estimated that only through 90% control of NO l
                                                                    /\

emissions on new cars would the public be adequately protected from

the adverse health effects of N02.  Congress, therefore, wrote into

the Clean Air Act the requirement that automotive emissions of NO
                                                                 y\
                                                       •
be reduced by 90% by 1976.

     In 1971, EPA promulgated National Ambient Air Quality Standards

(NAAQS) for N02 and five other  pollutants.  The standard for N02  is
1  Nitrogen oxides are emitted into the air a nitric oxide (NO) and
   nitrogen dioxide (N02).  By far, NO is emitted in larger quantities.
   Once in the air, NO is converted to N02.  Therefore, to control
   N02 in the ambient air, emissions of N02 and its precursor, NO,
   must be controlled.  By convention, NOX represents the sum of NO
   and N02.  In this paper, NOX refers to the emissions of NO and N02.
   N02 refers to atmospheric concentrations of nitrogen dioxide.

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100 yg/m3 annual average.  The national control strategy for attaining

the NOz standard was to meet the mandated 90% control of NO  emissions
                                                           /\
from automobiles, to apply the available NO  control technology to
                                           /\
stationary sources, and then, if certain areas do not meet the standard,

to place further controls on transportation sources.  Transportation

controls include reducing vehicle miles traveled, retrofitting existing

automobiles, and restricting downtown parking.

     After the Clean Air Act was enacted, EPA discovered that the

analytical method that was being used to measure ambient N02 was over-

estimating NOz levels in many cases.  Using other analytical techniques,

EPA remeasured air quality in the 47 regions of the country where the

standards were suspected of being violated.  The results showed

that only 2-5 regions of the country were in violation of the standard.

Thus, the Administrator suspected and alerted Congress to the possibility

that our national control strategy for attaining the NOz standard might

be overly restrictive on the automobile.

     The Office of Air Quality Planning and Standards (OAQPS) was

asked to study the NOz problem and, if appropriate, to recommend a

new national control strategy for NOz based on the more recent air

quality measurements.  The problem was to determine the balance of NO
                                                                     /\
               »
emission control between mobile and stationary sources that would

achieve the NAAQS at the least cost to society.  The general approach

to the problem was to formulate a set of strategies, predict future air

quality for each strategy, associate a cost to each strategy, and then

recommend a control strategy based on future air quality, costs and

energy considerations (gasoline consumption).

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                                     4
AIR QUALITY SIMULATION
     The Modified Rollback Model was used to simulate N02 concentrations
in the future.  The model was developed by Roger-Morris and Noel  deNevers
of EPA.  The model will not be explained in detail because the model
per se is not the major subject of this paper.  The model assumes that
in a region air concentrations of a pollutant are proportional to the
emissions of that pollutant.  The basic equation from which the model
was derived is
                AQp       =     B  +  (AQQ - B)

where           AQp = Predicted pollutant concentration at a future date
                      (yg/m3)
                 B  = Natural background concentration (yg/m3)
                AQ  = Baseline pollutant concentration (yg/m3)
                 Ep = Total emissions (Tons/year) at a future date
                 EQ = Baseline emissions (Tons/year)
The equation states that (future concentrations of a pollutant) =
(background concentration) + (that portion of baseline air quality
contributed by man) x (the ratio of future emissions to baseline
emissions).
     The ratio
                   EpJ
is a summation of Ep and Ep for six categories
of NO  emission sources.  The calculation of I Ep and z  Ep begins with
the baseline emissions (Tons/year) from each source category.  The following
parameters were considered in the calculation,  (a)  Present and future
emission factors.  Emission factors represent the rate of emission into
the environment per a unit of production.  For example, an emission factor

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                                     5
for the automobile is expressed in grams/mile.  An industrial  boiler
would be expressed in pounds/106 BTU.  (b)  Weighting factors  represent
the percent contribution of NO  emissions from sub-categories  within
                              A
each emission category.  Since the combustion of different fuels releases
different amounts of NO  into the air, the power plant category was
                       A
divided into coal, oil and gas-fired units.  Industrial emissions were
divided into coal, oil, and gas-fired boilers, nitric acid plants, and
solid waste disposal,  (c)  Stack height factors considered the effect
of stack height on ground level N02 concentrations,   (d)  Growth rates
were derived for all six categories,  (e)  Speed factors adjusted emission
factors of mobile sources according to average vehicle speeds,  (f)
Deterioration factors accounted for the decrease in effectiveness of
control equipment (i.e. increased emissions) as vehicles grew  older.
(g)  Distribution factors were applied to consider the contribution
of emissions from each model year vehiclenduring a given calendar year.
Appendix A shows the expansion of the basic rollback equation  that con-
siders six emission source categories and breaks down emissions by new
and existing sources.
   .  Future air quality was simulated for the ten cities shown in Table 3.
These cities were selected because they represented a wide variety of
               *
N02 concentrations and NO  emission sources.
                         A
     Emissions data were taken from the National Emissions Data System
(NEDS) which is maintained by EPA with data provided by each state.
For the analysis, data were divided into the following six categorie^;--
light-duty vehicles, medium-duty vehicles, heavy-duty vehicles, power

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                                       6



  plants, industrial sources, and area sources (small emitting sources



  of less than 100 Tons/year each).  Air quality data were taken from the



  National Air Surveillance Network (NASN) which is -a network of air



  monitors operated by EPA.  Air quality was measured in the central



  business district of each city.  The baseline year for all data was 1972.



       Growth rates were derived for each source category.  For each



  category several sets of growth rates were derived using different



  economic indicators from the Department of Commerce.  The model was



  run with each set of growth rates to determine whether small variations



  in growth rates would significantly affect future air quality.  The



  variations were not significant (usually <4 yg/m3).  Therefore, the



  growth rates selected for the analysis were those derived from what



.  were felt to be the best economic indicators.



  STRATEGY FORMULATION



       The general approach to formulating strategies was to select



  various future automotive standards and test them at different levels of



  stationary source control.  The current NO  emission standard for light-
                                            /\


  duty vehicles is 0.4 grams/mile to be achieved in 1977.  The interim



  standards are 3.1 grams/mile in 1973 and 2.0 grams/mile in 1976.  EPA's



  Mobile Source Testing Lab recommended four emission levels that should



  be considered for future standards:  0.4, 1.0, 1.5, and 2.0 grams/mile.

                          CL*

  Each standard represents distinct level of technology and cost.  Each



  of these potential standards was assumed to be met in 1977 after the



  interim star.-dards were met in 1973 and 1976.  Standards for medium and



  heavy-duty vehicles were assumed .in 1980 at a level expected to represent

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                                    7
best available control  technology at that time.  These standards remained
constant throughout the simulations.  Each of the four automotive strategies
was simulated with two levels of stationary source,..control.   Both stationary
source strategies assign a level of control to new and existing emission
sources within each category and sub-category of NO  sources.
                                                   X
                  CSST -  Current stationary source technology represents
                          emission reductions that will occur as a result
                          of the current Federal and State air pollution
                          control regulations.
                  MSST -  Maximum stationary source technology represents
                          emission reductions that would be  feasible be-
                          ginning in 1980 if EPA pursues an  intensive re-
                          search and development program for the control
                          of N02.  The MSST strategy was derived from
                          emission estimates by EPA's Control Systems
                          Laboratory.
Figure 1 graphically represents the eight control strategies that were
considered.  For each strategy future air quality  concentrations were
simulated (on the Modified Rollback Model) for the years 1975, 1977,
1980, 1985, and 1990.
DEVELOPMENT OF COSTS
     For the purpose of recommending a control strategy, the air quality
simulations alone were not conclusive.  Several strategies appeared to attain
and maintain the air quality standard adequately.  Cost estimates would
provide a measure of the resource requirements for each strategy.  A
strategy could then be .selected which achieved and maintained the air

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                               Figure 1
                          SIMULATED STRATEGIES
1973
1976
1977
 CSST =  Current Stationary  Source Technology
 MSST =  Maximum Stationary  Source Technology

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                                    8
quality standard while efficiently utilizing             resources.
Therefore, costs were calculated for each of the eight simulated
strategies.
     No formal model  existed relating NO  emissions to air quality
                                        /\
and cost.  The relationship between emissions and air quality could be
simulated with the Modified Rollback Model.   But a method for linking
costs to emissions had to be developed.
     The following assumptions were employed in developing costs.
Co^ntant costs were assumed for each source affected by a simulated
regulation.  Economies and diseconomies  of scale were not considered.
In certain instances, cost was projected beyond the useful life of a
device.  This action implied replacement of the control device.  Costs
were presented in annualized form for each of the simulated time periods.
The annualized form was believed to be an adequate representation of
costs since the ordinal ranking of projected air quality and cost for
every strategy did not change over the time periods.
Cost Development.     in the   analysis, cost represented the annualized
control'cost required to achieve a strategy in a particular time period
and region.  For consistency, each strategy cost was developed with the same
emissions and growth rates used in the air quality simulations.
     Each strategy cost was developed in the following sequence.  The
affected sources were designated and categorized.  The control techniques
were determined,Model  plant costs were developed.  The number of affected
sources in each category was determined.  Finally, the model plant costs
and the numbers of affected sources were multiplied and their products

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                                      9
 summed to yield  the  total  strategy  cost.   Each  step  of  cost  development
 is  described in  more detail  below.
 Affected Sources^  The  affected  sources were  designated by comparing  the
 current and  projected emissions  inventory  with  the emission  reduction
 requirements for each strategy.   For  example, consider  a regulation
 applying to  NO   emissions  from stationary  source  coal combustion  under
              J\
 CSST.   A search  of the  current and  projected  emissions  inventory  found
 coal-fired boilers in the  industrial  category and in the power plant
 category.  The emission source categories  and the applicable affected
 sources  are displayed  in  Table  1.
 Control  Techniques.   After the affected sources were selected, the
 control  techniques that would achieve the  required emission  reductions
 were determined.   The criterion  for selection of  a control technique
 was least cost subject  to  demonstrated reliability or development
 potential.   Given  the affected sources, the required emission  reductions,
 and the criterion, the  applicable control  techniques were determined.
 Although appearing to be a large chore, this  task was relatively  easy,
 because NO  control  techniques for  stationary and mobile sources  are
           *v                  .»
 few.   The selected control techniques for  the mobile and stationary
.source categories  are given  in Table  2-1 and  Table 2-2, respectively.
 Model  Plant  Cost.  Given each affected source and the applicable  control
 technique, a model plant was specified.  A model  plant  is a  typical
 source within a  source  category.  For the  mobile  source category, the
 model  plant  was  defined by the affected source  designation.   In the
 industrial,  power  plant, and area source categories  a model  plant had

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                                 10
                     TABLE 1.   Affected Sources
 Emission
    Source
      Category
                Affected Sources
     CSST
        MSST
Area
Industrial
Power Plant



Light-duty vehicle

Medium-duty vehicle

Heavy-duty vehicle
None
New and existing
coal, oil, gas
fired boilers.
Existing nitric
acid plants.

New and existing
coal, oil, gas-
fired plants

New

New

New
New residential oil-
fired sources

New and existing coal ,
oil, gas fired boilers,
Coal, oil, gas-fired
plants
New

New

New

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                                   n
                               TABLE 2-1.
                  Control Techniques for Mobile'Sources
   Affected Sources
Emission Reduction
   Requirement
     Control Technique
Light-Duty Vehicle
Medium-Duty Vehicle


Heavy-Duty Vehicle
  gasoline
  diesel
  2.0 grams/mile
  1.5 grams/mile
  1.0 grams/mile
  0.4 grams/mile
  3.1 grams/mile
  2.0 grams/mile
  7.0 grams/mile
  7.0 grams/mile
Proportional Exhaust
Gas Recirculation (PEGR)
PEGR
PEGR + 3-way Catalyst
PEGR + 3-way Catalyst
Exhaust Gas Recirculation
Proportional Exhaust
Gas Recirculation

Exhaust gas recirculation
Engine Modification by
Redesign

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                                    12

                                TABLE 2-2.
                 Control Techniques for Stationary Sources
 Affected Sources
      Current Stationary
   Source Technology (CSST)
    Maximum Stationary
  Source Technology (MSST)
Power Plants
  coal-fired

  oil-fired

  gas-fired
Industrial  Sources
  coal-fired
  oil-fired
  gas-fired
  HN03 Plants
Area Sources
  Residential
  oil-fired
  heaters
Low Excess Air Firing plus
two stage firing
Low Excess Air Firing plus
two stage firing
Low Excess Air Firing plus
two stage firing
Low Excess Air Firing
Low Excess Air Firing
Low Excess Air Firing-
Catalytic Reduction
Not Applicable
Flue Gas Recirculation

Flue Gas Recirculation

Flue Gas Recirculation

Flue Gas Recirculation
Flue Gas Recirculation
Flue Gas Rhcirculation
Low Excess Air Firing
plus Flue Gas Recircu-
lation

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                                    13
to be specified.  The model plants in these instances were composite

plants whose characteristics were determined considering the current

and projected size distribution of the affected sources.

     Characteristics such as operating time, life of the control  device,

investment cost, interest, and maintenance cost were then calculated

for each model plant.  The validity of each characteristic was documented

by published cost/engineering studies and expert opinion.  Given  the

model plants, the characteristics, the required emission reductions,

and the control techniques, the annualized costs for each model plant

were developed.  Two examples, one from the industrial category and

one from the mobile source category are given below.  The examples

display the sequence of model plant cost development.
     1.  Source category
     2.  Regulatory strategy element
     3.  Affected Source

     4.  Control Technique

     5.  Model Plant
     6.  Characteristics:

          Vehicle Age and Annual
            Mileage
          Miles per gallon
          Fuel Cost
          Control Investment
          Depreciation period
          Interest
          Maintenance
          Fuel penalty factor
          Operating cost


            Annual fuel penalty cost
--  Mobile
--  2.0 grams NO  per mile
--  light-duty vehicles (less
    than 6000 pounds)
~ ^Proportional exhaust gas
    recirculation
—' light-duty vehicle
    4 years old; 11,400 miles
    13.5 mpg
    $.40/gal
    $32.00
    10 years
    8%
    $4.00/year
    6%
_ /"mi
   ilesVgall
^year J\  mi
$
ons.	
le A gallon
'fuel  penalty]
    factor    J
                                       =  (11,400) (.0741) ($.40) (.06)

                                 .         $20.27/year

     7.  Annualized Model Plant Cost   --  $29.00

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                                    14
     1.  Source Category
     2.  Regulatory Strategy Element
     3.  Affected Source
     4.  Control TUchnique
     5.  Model Plant

     6.  Characteristics:

           Fuel Consumption
           Operating Time
           Fuel Cost
           Combustion Efficiency
             Factor
           Excess Air, pre control
           Excess Air, past control
           Fuel Savings Factor
           Control Investment
           Depreciation Period
           Interest
           Maintenance
           Operating Costs
          —  Industrial
          —  MSST
          —  Coal Fuel Combustion
          —  Flue Gas Recirculation
          —  Boiler producing 190,000 pounds
              of steam'per hour
          5-100

          —\9 tons of coal per hour
          —  4566 hours per year
          —  $.18 per 106 BTU

          —  80 percent
          --  25 percent
               5 percent
               1 percent
          --  $141,000
          ~  10 years
          --  3 percent
          —  8.6 percent of investment
             Electricity and Labor   --  $700

             Fuel Savings  -  pounds steam X
                                                                   factor
                              fuel savings factor X  ins RTM  x operating time
=  190,000 X
                                             X  .01 X     X 5700
                           =  $2437

     7.  Annual ized Model Plant Cost —  $22,443

Affected Number of Sources.  The number of affected sources was calculated

in the following manner.  The annual emissions per model plant were determined.

NO  emissions for each of the affected sources were projected for each  region
  J\

.and time period.  Then, the projected annual emissions were divided by

annual model plant emissions to determine the affected number of sources.

An example  is given below.

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                                    15
     1.  Emissions per model  unit
         a.  Emission factor:  18 pounds  of NO  per ton  of coal  consumed
                                              A
         b.  Annual  Coal  consumption —          '  ^
            •hourly consumption x annual  operating  time
                               5700                 5
            •9 tons per hour  x 456'0 hours per year  = /TI300 tons  per year
         c.  Annual  unit NO  emissions --
                           A
            •emission factor  x annual  coal  consumption
            • 18 pounds of NO   per ton  of  coal  x 51300  coal tons  per year  =
                           /\
             923,400 pounds of NO  per year = 460 tons of NOV  per year
                                 X                          A
     2.  AQCR emission of NO   from new industrial -- coal  fuel combustion
                           A
         in the year 1980, regulation  effective in  1980
         a.  total 1980 emissions
             (1)  Base emissions; growth  rate; projection period given
             (2)  1980 total  emissions =  (1  + growth rate)10 x 1970 emissions
         b.  1980 new source  emissions
             (1)  1979 total  emissions
             (2)  1980 emissions = 1980 total  - 1979 total
     3.  Number of new industrial fuel combustion sources in 1980
         New sources in 1980  = 1980 emissions from  new sources divided
         by annual unit emissions
Total Strategy Cost.  Total strategy cost was developed  by multiplying
the number of affected sources by the  model  plant cost for a given source
for each time period and region.  An example of this product would be the
annualized cost for oil-fired power plants  to meet  the MSST requirements
in New York City in 1985.  The costs of each source were then  summed  to yield

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                                    16
the total strategy cost for a given time period and region.   An example
of the total strategy cost would be the cost for the 1.0 gram/mile
strategy with CSST for Chicago in 1980 (depicted'ir^ Table 4).
FACTORS INFLUENCING COST
     The relative magnitudes of strategy cost are not always apparent
from the regulatory aspects of a strategy.  Factors that influence the
magnitude of costs include growth rates of the affected sources, the
distribution of emissions among the various mobile and stationary source
categories, control techniques, age of the source, and phasing of
control.  Of course, there are other factors influencing cost.  For NO
                                                                      J\
control, one of the most important factors is the relationship of emission
reduction to fuel use.  This factor is unique in its affect  upon cost.
For some sources, there is an indirect relationship between  emission
reduction requirements and fuel use.  For other sources, there is a direct
relationship between fuel use and emission reduction requirements.
     For stationary fuel combustion, required emission reductions are
achieved by boiler modifications that reduce excess air during combustion.
This modification reduces waste heat losses to the stack and thus saves
fuel.  The fuel savings were considered in calculating the costs for both
the CSST and MSST strategies.                                 emission reductions
     For light, "medium, and heavy-duty gasoline propelled vehicles/down
to 1.5 grams/mile are achieved by lowering combustion temperatures through
exhaust gas recirculation (EGR).  Exhaust gas recirculation  suppresses NO
                                                                         }\
formation, but engine efficiency is also suppressed, resulting in the
expenditure of more fuel.  Emission reductions and fuel use  increase as

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                                    17
the flow rate through the EGR device is increased.  Emission reductions
below 1.5 grams/mile are achieved by also installing a catalytic muffler.
Fuel penalties, however, are still controlled by-the EGR specifications.
Fuel penalties increase as automotive emissions are reduced from 3.0 to 2.0
to 0.4 grams/mile.  In comparing strategies, the fuel penalty was found to
be the dominant factor influencing the relative magnitudes of cost.
Note in Table 4 that the cost of the 1.0 gram/mile strategies is less
than the cost of the 1.5 gram/mile strategies.  The explanation lies in the
fuel penalties associated with 1.0 and 1.5 gram/mile emissions.  Although
fuel penalties usually increase as NO  emissions are reduced, this is not the
                                     y\
case as. NO  emissions are reduced from 1.5 to 1.0 grams/mile.  A change
          A
in control techniques account for a decrease in fuel penalty between 1.5
and 1.0 grams/mile.  Emission reductions to 3.1, 2.0, and 1.5 grams/mile
are achieved by exhaust gas recirculation (EGR).  At 1.5 grams/mile, the
   device
EGR/is operating at its limit and the fuel penalty is severe.  Other
control methods could potentially achieve 1.5 gram/mile emissions, but
the exhaust gas recirculation device was selected because none of the
other methods had been demonstrated and the potential for development
was not considered adequate -within-^fehe required- -t4ffl€n  To reduce emissions
to 1.0 gram/mile exhaust gas recirculation has to be augmented with a
catalytic muffler.  At 1.0 gram/mile, the catalyst eases the emission
reduction burden on the EGR device so that the flow rate through the EGR
(which determines fuel penalties) can be reduced to the same level that
is required for an emissions reduction to 2.0 grams/mile.  Note in Table 5
that the fuel penalty for 1.0 gram/mile and 2.0 grams/mile is identical.

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                                    18
Thus, the fuel penalty associated with the 1.0 gram/mile standard is
far less than the fuel penalty associated with the 1.5 gram/mile standard
(Table 5).  The fuel penalty has such an overwhelming influence on cost
that the total cost of the 1.0 gram/mile strategies was less,  in all
cases than the total cost of the 1.5 gram/mile strategies.
RESULTS AND CONCLUSIONS
     The results of the air quality simulation are presented in Table  3.
For the analysis, the assumption was made that a city within _ 10 yg/m3
of the standard will marginally achieve the standard.  The  model was not
considered sufficiently precise to conclude that a city with a predicted
air quality of 104 ug/m3 in 1985 would, in fact, violate the standard  in
1985 or that a city with a predicted air quality of 98 yg/m3 would meet
the standard.  Table  3 shows that each strategy affected various cities
differently.  The cities fell into three classes:  (1)  cities (e.g.
Phoenix, San Francisco, Salt Lake City) that adequately maintain the
standard under any strategy;  (2) borderline cities (e.g. Chicago, Baltimore)
where the model cannot predict with confidence if the standard will be
met or fail to be met;  (3)  Los Angeles where only through maximum control
of both stationary and mobile sources will the standard be met.
     Although each city's air quality reacted differently to a given
strategy, one trend was apparent in all cases—that air quality was affected
more by stationary source control than by mobile source control.  For  example,
consider one of the borderline cities—Philadelphia.  Air quality (AQ) in
1972 was 83 yg/m3.  By 1985, if the interim 2.0 gram/mile standard is
retained, AQ = 106.  If the automotive standard is reduced  to 0.4 grams/mile

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                                      19
  in 1977,  AQ = 102 yg/m3  by  1985.   If the  2.0  gram/mile  is  retained  in  1977
  and more  control  is  placed  on  stationary  sources,  then  AQ  =  87  yg/m3 by  1985.
  The conclusion was drawn that  the  2.0 gram/mile  strategy with MSST  will
  give comparable or even  better air quality than  the  current  strategy of  0.4
.grams/mile with CSST.   Further, MSST may not be required except  in a few
  cities.   2.0 grams/mile  with CSST  may adequately maintain  the standard in
  all cities except Los  Angeles  and  Chicago.
       Table 4 presents  the cost of  each  strategy.  The data clearly  show
  that the  2.0 gram/mile strategy with MSST costs  less than  any strategy
  with CSST and more strict control  of the  automobile. The  main  reason  is
  because of the fuel  penalties  attributable to the  control  of NO from
                                                                 /\
  mobile sources.  Table6  shows the cost of extra gasoline  consumption
  that is associated with  each level  of automotive control.
       From this analysis, and after other  considerations, the Administrator
  of EPA has recommended that the 1977 NO   emission  standard for  automobiles
                                         X
  be changed from 0.4  gram/mile  to 2.0 grams/mile  and  that cities requiring
  more NO   control  to  maintain the standard achieve  that  control  through
        y\
  further emission reductions from stationary sources. Table  6 summarizes
  data from Tables 3,-4, and  5 for New York City for the  current  N02  strategy
  and the recommended  strategy.   The table  shows an  example  of how the
  recommended strategy results in better  air quality for  the city, costs the
  public less, and requires less gasoline consumption.

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                                    20
                              ACKNOWLEDGEMENT
     This analysis was presented by John Crenshaw and Allen Basala for
the U.S. Environmental Protection Agency at the WORC's Third Cost-  -
Effectiveness Symposium.  The entire analysis, documenting all methodology
and data in detail, will be published as an EPA technical document.  The
analysis was performed at the request of B.J. Steigerwald, Director of
the Office of Air Quality Planning and Standards.  The project was
managed by Michael Berry and John Crenshaw.  Allen Basala was responsible
for the economic portion of the analysis.  The authors greatfully
acknowledge the assistance of Frank Bunyard and Paul Boys in calculating
control costs; EriK, Finke, Warren Freas, and Dave Kircher in computer
modeling; and Pat Barber and Evelyn Barry in data handling and technical
research.

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                                                                Table 3
                                                       Projected Air Quality
                                                           For Various Standards
AQCR
         Standard
      2  g/m1
                  1.5  g/ml
                                     1  g/ml
                                                            .4  g/m1
                    1977
1. Phoenix
        1980
          61
1985
1977
1980
1985
1977
                                                                                     66
1980
                                                       60
1985
                                                                                                                  1977
                                                                                               fiS
                                                                                                       1980
                                                                          _5fl_
1985
2. Los Angeles
                                          1Q6
                                                                                   1U
                                                                                     117
                                                                                 120
                                                                                     log
                                                       102
                                                     107
                                                       116
                                                       97
3. San Francisco
                                                                                   71
                                                                            70
                                                                                                                              62
4. Denver
5. New York
                                                                                               90
                                                                                       74
6. Philadelphia
                                                                                              88
                                                                                       77
7. Washington, D.C.
                               87
                      97,
                       71
                                                                 87
                                                                 69
8. Chicago
                                                                                   11
                                                               119
                                                               112,
                                                                 98
                                                                                                      10
                                                                           97
                                                                                   111
                    101
9. Baltimore
101
                                                             101
                                             101
                                                                 101
                                                                 84
                                                                88
                                                                 78
0. Salt Lake City
                               59
                                             59
                                                                 59
                                                                 54

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                      Table  4
Annualized Costs  of  Projected Air Quality ($106)
CSST
  MSST

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             Table  5
Annualized Fuel Penalties ($106)
^0^ — • — Standard .
1. Phoenix i
t
2. Los Angeles
3. San Francisco
4. Denver
5. New York
6. Philadelphia
7. Washington D.C.
8. Chicago
9. Baltimore
10. Salt Lake City
2 g/mi
1977
7.9
52.5
23,1
6.8
60.5
24.5
12.8
31.3
11.0
4.6
1980
12.8
82.1
35.8
10.7
92.8
38.0
20.4
48.6
19.4.
7.5
1985
19.9
120.3
51.7
15.7
132.1
55.2
30.8
70.6
35.1
11.9
1.5 g/ml
1977
9.5
63.4
27.9
8.2
73.0
29.6
15.5
37.8
113.3
5.5
1980
22.9
147.2
64.1
19.1
166.5
68.2
36.6
87.2
34.8
13.4
1985
41.1
247.9
106.5
32.4
272.2
113,8
63.5
145.5
72.2
24.5
1 g/ml
1977
7.9
52.5
23.1
6.8
#
60.5
24,5
12.8
31.3
11.0
4.6
' 1980
12.8
82.1
35.8
10.7
92.8
38.0
20.4
48.6
19.4
7.5
1985
19.9
120.3
51.7
15.7
132.1
55,2
30.8
70.6
35.1
11.9
•4 g/ml
1977
8.8
58.8
25.8
7.6
67.6
27.4
14.4
35.0
12.3
5.1
1980
18.5
119.3
52.0
15.5
134.9
55,3
29.7
70.7
. 28.2
10.9
1985
32.0
193.2
83.0
25.3
212.2
88.7
49,5
113.4
56.3
19.1

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                                                      Table 6
                                          COMPARING NOX CONTROL STRATEGIES

                                                    (NEW YORK)
Strategy
    Annual
Air Quality
    Annual
Control Cost (10° $)
  Annual Fuel
Penalty  (10° $)
' J
Automoti ve s tandardjcf
.4 grams/mile
/ and
Moderate Stationary
Source Control .
Automotive standard of
2.0 grams/mile and
Maximum Stationary
Source Control.
\

1977



90

91




1980



90

78




1985



86

77




1990



96

87




1977



144.8

128.7




1980



276.0

194.7




1985



4'57.0

320.6




1990



510. -1

377.4
t



1977



67.6

60.5




1980



134.9

92.8




1985



212.2

132.1




1990



227.9

136.7




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          Appendix A:           MODEL  USED  FOR AIR QUALITY PREDICTIONS
                                 cmax-future  "
                                  max-base
                   (e •  gf •  ef)LDV  +  (e  •  gf  • ef)Mm/ +  (e  • gf  • ef)HDV
                        e)
                          LDv
[k •  e (efi  +(gf -I)ef2)]    + [k  .  e  (e^ +(gf  -I)ef2]j +  [k  • e  (e^ +(gf -l)ef2]A
+ (k -  e)                       + (k  .  e)j                   +  (k  . e).
          where         e   =  baseline  emissions  in Tons/year
                        k   =  emission  height  factor  (unitless)
                       efi   =  emission  factor  ratio for existing sources
                       ef2   =  emission  factor  ratio for new  sources
                       gf   =  growth  factor  (unitless)
                        c   =  air concentration  (yg/m3)
                        b   =  background  concentration (yg/m3)

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