*    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 v
                        WASHINGTON, D.C.  20460
              The Federal Automobile Emission Standards
                Their Purpose, Their Need, Their Impact

     Recently the Federal automotive emissions standards have come under
criticism from some quarters of the automotive and petroleum industries.
This paper attempts to present relevant facts on the issues raised.   ^

 I.  Emissions of Air Pollutants from Automobiles

    In U. S. cities the automobile is a major contributor to the man-made
emissions of carbon monoxide, hydrocarbons, and oxides of nitrogen.  It is
estimated that in cities motor vehicles will be responsible for the emission
of 50% to 90% of these pollutants in 1973.

Industry Statement—Drastic reductions have been made in automotive
emissions due to the Federal standards; a continuation of present
control measures is sufficient.

     EPA Position—It is true that, as a result of the promulgation of
     emission control standards, substantial progress has been made in
     reducing emissions from new vehicles.  However, even greater control
     is required if we are to clean up the air in our major cities to a
     degree which protects against the known adverse effects of air
     pollution on our health and property.

     National air quality standards for automotive pollutants were set
     to protect the public from the adverse health effects of these
     pollutants.  However, in order to achieve these standards over 26
     major metropolitan areas will require additional controls on motor
     vehicles above and beyond those imposed on new automobiles.  These
     transportation controls (which may include restriction of parking,
     vehicle inspection, mandatory maintenance, gas rationing, and
     conversion of vehicles to gaseous fuels) will be designed to control
     automobile air pollution.  All the help these cities can get through
     the achievement of the Federal new car emissions standards must be
     provided.

Industry Statement^--Natural processes emit quantities of air pollution
much larger than those emitted by the automobile.  Natural processes
also remove automotive pollutants from the air.

     EPA Position—It is misleading to base an argument against the
     control of emissions on estimates of worldwide emissions of
     pollutants produced by vegetation and other natural sources.

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 The  Federal  Automobile Emission  Standards—Their
 Purpose,  Their  Need,  Their  Impact  (cont'd)                        3/1/73


      Natural emissions occur in  a  widely diffuse fashion, and are
      distributed over the entire world.   Man,  on the other hand,
      concentrates his activities on a very small portion of the
      earth's surface.  With 75%  of all Americans living on only 1.5%
      of our  total land area, the emissions of  automobile pollutants
      are similarly concentrated.  This results in adverse levels of
      pollutants building up in all the major urban areas.  Natural
      removal processes do exist  for all the major air pollutants but
      these processes  are quite slow, and come  nowhere near to solving
      the problem of pollution accumulation in  urban areas.

 Industry Statement—Emissions from sources around the home (burning
. fireplace logs, fuel  oil furnaces, and the mere existence of backyard
 vegetation)  can be comparable to those resulting from using an auto
 meeting the  1976 Federal emission  standards.   Any one of these sources
 will use up  a person's "emission quota" for that day.

      EPA Position—The 90% reduction in automotive pollutants that was
      mandated by Congress in the Clean Air Act was designed specifically
      to remove the automobile from its role as the dominant source of
      air pollution in our urban  areas.  Comparing the emissions of a
      1976 automobile  to those of relatively less important sources of
      pollution simply points to  the success of the Clean Air Act in
     .achieving its goal.

      In direct reference to the  comparisons made between 1976 automobiles
      and burning logs, it should be pointed out that such a comparison
      can only have real significance if we assume that the fireplaces are
      used daily throughout the year, in every  household that owns a vehicle,
      and that these households can be as concentrated in downtown areas
      during  peak traffic periods as are automobiles.

      Comparisons of natural HC emissions from  a backyard and a 1976
      automobile evoke the same comments as above.  However, it should
      be pointed out that the research in this  area must be considered
      to be preliminary and that  the emissions  data available can be used
      to support a wide range of  estimates on HC emissions data per square
      foot of vegetation.  One interpretation of these data is that the
      1976 automobile  will emit only as much hydrocarbons as ,a vegetated
      five acre plot.   Clearly, in  major urban  areas, five acre plots
      of vegetated earth are far  outnumbered by our automobiles.

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The Federal Automobile Emission Standards—Their                  3/1/73
Purpose, Their Need, Their Impact (cbrit'd)


Industry's Statement—California, with the oldest and most severe
auto-related air pollution problems in the nation, does not support
the Federal new car standards for 1975 and 1976 and, in fact, has
established its own standards for 1975 which are much less stringent
than those required by the Federal government.

     EPA Position—The standards proposed by California for 1975 were
     formulated back in 1969 and were based on estimates by their
     engineers of available emission control technology-  The California
     standards do not take into account the rapid advances in emission
     control technology since 1969 and were never meant to provide the
     reductions needed to meet air quality standards within the timeframe
     specified by the Clean Air Act.  In  fact, even meeting the 1975-76
     Federal emission standards will not  achieve the air quality
     standards in parts of California without a major curtailment of
     vehicle use.  It is easy to agree with the industry that meeting
     the much less stringent proposed California standards would be
     easier and cheaper for the auto industry.  The point, however, is
     that  this would not meet the needs of the nation's cities for
     controlling automobile-caused air pollution.

II.  Health Effects of Automotive Pollutants

     Automobile emissions of hydrocarbons and nitrogen oxides react in
the atmosphere in the presence of sunlight to form  toxic photochemical
oxidants.  These oxidants have detrimental effects  on persons with respiratory
illnesses, cause eye irritation and watering, and have destructive effects
on rubber  products  and synthetic fabrics.  Nitrogen dioxide, one of the
nitrogen oxides, can as well cause adverse respiratory effects.

     The carbon monoxide  emitted by automobiles is  absorbed  through the
lungs  and  thereby reduces the oxygen carrying capacity of  the blood.  The
carbon monoxide in  the blood takes the form of carboxyhemoglobin  (COHb).
At levels  of  COHb just over 2% our visual and time  interval  discrimination
can be impaired.  Increased COHb levels have  also been  shown to have  adverse
effects on heart patients.

     The national air quality standards are designed  to  protect against
these  harmful effects/

Industry  Statement  -— The carbon monoxide emissions from  automobiles
are much  less toxic thain  stationary  source  related  pollutants;  in particular
sulfur oxides.  For this  reason  we  should turn  our  interests more towards
these  other  pollutants.

     EPA  Position —  This is not a  relevant  argument.   The goal of the
     Federal air pollution  control  program is to  eliminate all  air pollution
     problemsj not  eliminate  some  and  leave  others.  The Clean  Air Act
      requires control of  sulfur  oxides  to whatever  level is necessary, as
     well as control  of  carbon monoxide.

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The Federal Automobile Emission Standards—Their                 3/1/73
Purpose, Their Need, Their Impact  (cont'd)

Industry Statement—Average carbon monoxide blood levels of people
in major urban areas are below those levels related to effects on health.

     EPA Position—Examination of "average" concentrations of carbon
     monoxide in the blood of urban dwellers is a dangerous approach to
     determining the hazard to the population.  This type of data gives
     no indication of how many people have levels which exceed the
     acceptable health levels.  It is known that some people receive a
     greater exposure to high pollutant levels than others and that some
     are more strongly affected by a given level of pollutant concentrations.
     The Clean Air Act mandates the EPA's standards protect the health of
     not only the "average" man but also those subgroups more exposed or
     more vulnerable than the average man.

Industry Statement—Carbon monoxide blood levels of smokers are higher
than those for non-smokers.

     EPA Position—The carbon monoxide blood levels in smokers have little
     relevance to the stringency of automotive emission standards.   Smokers
     smoke by choice and know that it is harmful to-their health.   Non-smokers
     on the other hand, have the right to be adequately protected against
     CO even if smokers elect to pursue their habit.

Industry Statement—"Average" street level concentrations of automotive
emissions are low enough that they pose no threat to human health.

     EPA Position—EPA's air quality standards are based on known adverse
     health effects.  Air quality measurements show that these standards
     are being exceeded in many of our urban areas.   The use of a concept
     such as "average" concentrations is misleading because it ignores
     the adverse effects on specific individuals of exposures to
     pollutants for specific, times in specific places.

III.  Pollution Control and Fuel Consumption—

     The automobile is a major source of air pollution in the United States.
This is easier to understand when we realize that we Americans drive our
cars nearly 1 trillion miles a year and in the process consume nearly
70 billion gallons of gasoline.  This is the equivalent of 14% of  all the
energy resources consumed in the United States annually.   The pollution
abatement efforts of the automotive industry have increased the fuel
consumption of our automobiles but not by as much as some would have us
believe.

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The Federal Automobile Emission Standards—Their
Purpose, Their Need, Their Impact (cont'd)                      3/1/73

Industry Statement—The 1975-76 emissions standards have an adverse
effect on automotive fuel economy and may increase fuel consumption by as
much as 30%

     EPA Position—A recent study on automotive fuel consumption conducted
     by EPA shows that emissions controls do have an impact on fuel economy.
     This study estimates that the loss in fuel economy for 1973 model
     year vehicles over those with no emissions controls is in the range
     of 7% to 8%.  Data available from a major domestic manufacturer
     indicates that the fuel economy of 1975 vehicles with their
     additional controls should remain unchanged from 1973.  A fuel
     economy loss of this magnitude would increase the average drivers
     fuel bill by less than $25 a year.  EPA estimates the increased
     fuel consumption for 1976 model cars to be in the range of 10% to
     12%, again far below the 30% seen in many industry statements.

     To put the fuel penalty of emissions controls into proper perspective,
     EPA has also quantified the fuel penalty associated with consumer choices
     such as automotive air conditioning, automatic transmissions and
     increased vehicle weight.  That analysis shows an average fuel economy
     loss of 9% for air conditioners (installed on over 60% of new vehicles) ,
     and of 5% to 6% for automatic transmissions (installed on over 90% of
     new vehicles).  Differences in vehicle weight can account for as much
     as a 50% loss in fuel economy.

Industry Statement—Catalyst equipped cars will suffer fuel economy
penalties.

     EPA Position—The use of a catalytic converter as an integral part
     of emissions control systems does not of itself create a significant
     fuel economy loss.  These converters, which are attached to the
     exhaust system much like an  acoustical  muffler, by themselves create
     no more fuel economy loss than does today's standard exhaust muffler.

IV.  Cost of Emissions Control.

     The cost of owning and driving an automobile includes the initial
price, maintenance costs and operating costs.  The Department of Transportation
has estimated the,total cost to be approximately 11.9 cents per mile or
$11,900 over the 100,000 mile life of a vehicle.  Emission controls will
add to  the cost of owning a vehicle.  The increased operating cost due to a
reduction in fuel economy was estimated above.  The increased initial cost of

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 The Federal Automobile Emission Standards—Their               3/1/73
Purpose, Their Need,  Their  Impact  (cont'd)

a 1975 model year vehicle due to emissions controls should lie in the range
of $150 to $300 which is only 2 to 3 percent of the total.  The additional
equipment needed for 1976 to control oxides of nitrogen could raise the upper
limit of our cost estimate to approximately $350.

Industry Statement — Government studies say that 1975-76 standards could
raise the price of a new car by $500.

       EPA Position — Using acknowledged and informally obtained automotive
       industry data as a base, an Office of Science and Technology report
       published in 1972 did use a $500 initial cost figure.  However, cost
       data later obtained by EPA from industry sources at formal public
       proceedings, and more recently obtained in preparation for new
       proceedings indicates that cost will be lowered substantially below
       this level.

Industry Statement — Emissions control systems will require the use of
expensive and rare metals from outside the U.S.

       EPA Position — .Most American manufacturers intend to use precious
       metal catalysts as an integral part of the emissions control systems.
       Adequate supplies of the precious metals used in these systems can be
       imported at a cost of from $5 to $15 per car, depending on the con-
       figuration of the catalyst used.  It should also be noted that seve
       emissions control systems tested by EPA have met the 1975 standard
       without precious metal catalysts.  Neither the Clean Air Act nor EPA
       prescribe that specific technologies be adopted.  The Government sets
       the emissions standards; industry chooses the technology.

Industry Statement — Precious metal catalysts require the use of lead-free
fuels which cost more than the leaded grades.

       EPA Position — Catalytic systems are effectively deactivated by the
       anti-knock compounds of leaded gasoline.  The lead-free gasoline
       required for catalysts does cost more at the pump but a study conducted
       by EPA on the effects of lead additives shows that this cost will be
       offset by the increased life of spark plugs and mufflers resulting
       from the use of lead-free fuels.

Industry Statement — The costs of automotive pollution control exceed
the benefits.

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The Federal Automobile Emission Standards—Their                 3/1/73
Purpose, Their Need, Their Impact (cont'd)

      EPA Position — Reliable estimates of the benefits applicable to
      health and property have not, fbaen 4evelop,ed because of a lack of
      consistent data.  This does not imply that there are no health
      and property benefits from reducing automotive pollutants.  It
      simply means that these benefits have yet to be quantified, and
      translated into dollars.  The benefits cited by some sources in-
      clude only those which have been estimated for materials and
      vegetation.  In ignoring the benefits to health and property any
      comparison of automotive pollution control costs and benefits
      incomplete and misleading.
                                              March 1, 1973
                                    Office of Air and Water Programs

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