* 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. ------- 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. ------- 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. ------- 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. ------- 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 ------- 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. ------- 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 ------- |