DRAFT
Regulatory Support Document
Revised Gaseous Emission Regulations
For 1984 and Later Model Year
Light-Duty Trucks and heavy-Duty Engines
September 1981
Prepared. By
Office of Mobile Source Air Pollution Control
Emission Control Technology Division
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DRAFT
Regulatory Support Document
Revised Gaseous Emission Regulations
For 1984 and Later Model Year
Light-Duty Trucks and Heavy-Duty Engines
September 1981
Prepared. By
Office of Mobile Source Air Pollution Control
Emission Control Technology Division
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Tab 1 e of Conte_nt_s_
Page
1. Introduction/Summary 1
A. Introduction 1
B. Summary 2
1. Technological Feasibility 2
2. Environmental Impact 3
3. Economic Impact 4
II. Technological Feasibility 5
A. Introduction . . . 5
B. Current HC and CO Emission Rates 5
1. Overview: The Transient Test 5
2. Current Technology Engines 6
3. The 9- Mode Test 8
4. Full Power Operation 9
5. Transient Operation/All Speeds and Loads ... 17
6. Cold Engine Operation 18
C. Available Control Techniques 18
1. Overview 18
2. Improvements to Fuel Metering 18
3. Improved Mixture Distribution 19
4. Other Physical Modifications 19
5. Other Calibration Optimizations 21
6. Improved Warm-up Characteristics 21
7. Summary of Possible Control Techniques .... 22
8. Tradeoffs 25
D. Attainable Reductions/Proposed Emission Standards. . 25
E. Idle Emission Standard 29
III. Environmental Impact 32
A. Introduction . 32
B. Changes in the Per Vehicle Emission Rates 32
1. Introduction 32
2. Hydrocarbons 33
3. Carbon Monoxide 36
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Table of Contents (cont'd)
C. Ambient Air Quality Impact: Carbon Monoxide .... 39
1. Introduction 39
2. Scenarios Analyzed . • 39
3. Results and Discussion 42
4. Conclusions . . 42
D. Other Environmental Impacts 46
1. Lead 46
2. Sulfuric Acid . 46
3. Misfueling 46
IV. Economic Impact 49
A. Introduction 49
B. Cost Implications of the Proposed Revisions .... .49
1. Revision of the HDE Gaseous
Emission Standards 49
2. Revisions to the LDT/EDE
Enforcement Provisions 65
C. Total Economic Impact of the Proposed
Revisions 73
1. Light-Duty Trucks 73
2. Heavy-Duty Gasoline Engines 73
3. Heavy-Duty Diesel Engines 79
4. Aggregate Savings 79
II
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Chapter I
INTRODUCTION/SUMMARY
A. Introduction
In December of 1979, EPA promulgated gaseous emission regula-
tions for 1984 and later model year heavy-duty engines (HDE). A
similar rulemaking affecting 1984 'and later model year light-duty
trucks (LOT) was promulgated in September of 1980. Although the
primary function of these actions was to implement the statutory
HC and CO emission standards, these rulemakings implemented
several other provisions also to be effective for the same model
year. The major provisions common to both rulemakings included:
1. The statutory HC and CO emission standards,
2. Revised useful life definition,
3. Revised certification requirements with respect to dur-
ability testing and allowable maintenance,
4. An idle test and an idle emission standard for gaso-
line-powered light-duty trucks and heavy-duty gasoline-fueled
(HDG) engines, and,
5. The implementation of a 10 percent Acceptable Quality
Level,\(AQL) for Selective Enforcement Audit (SEA) testing.
The HDE final rulemaking also included a new emission test
procedure and implemented the basic SEA program for HDEs.
This large number of new and revised requirements was promul-
gated simultaneously, effective for the same model year, to avoid
the procedural disruption and waste associated with frequent
changes in emission regulations. This comprehensive approach
allows manufacturers to deal with the impact of several regula-
tions at once, thus avoiding repeated financial outlays for re-
search and development, tooling changes, and recertification.
In the economic analysis supporting the 1984 HDE final rule-
making, EPA made the finding that "[m]ost engine manufacturers
should have little difficulty financing the required investment,
barring. a. .post-1980. rece.ssi.pn" (emphasis added). When the eco-
nomic impact of the final rule was being analyzed the industry had
just finished a year of record sales (1978), and sales into 1979
continued strong. However, in late 1979 and into 1980 when the
general economic downturn became more severe, LOT and HDE sales
dropped dramatically. Over the past five to six financial report-
ing periods (quarters) since late 1979, most companies in the LDT
and HDE markets have reported substantial operating losses. In
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general,. 1980 was a year of record losses in the motor vehicle in-
dustry.
In response to this economic crisis in the industry, and the
need for short-term cash flow improvements, the Administration has
announced a number of regulatory relief initiatives. Preliminary
analyses indicated that several provisions of the 1984 LDT/HDE
final rulemakings which required substantial capital investment
could be relaxed without causing a large loss in the emission re-
ductions and air quality improvements expected from the final
rulemakings. The three major provisions are: 1) a three-year re-
vision of the HDE gaseous emission standards to levels which
heavy-duty gasoline-fueled engines (EDGE) could achieve without
catalytic converter technology, 2) deferral of the implementation
of the HDE SEA program from the 1984 model year to the 1986 model
year, and 3) a relaxation of the AQL required during formal SEA
testing of LDTs and HDEs.
Even though this rulemaking will establish no additional re-
quirements and will actually provide cost savings for both the
regulated industry and the consumer, EPA has decided to prepare
this Rulemaking Support Document to address the issues which will
arise in this action. In Chapter II, Technological Feasibility,
we address the level of the "non-catalyst" HDE emission stan-
dards. Chapter III examines the air quality impacts of the in-
creased emission levels resulting from the revised HDE CO emission
standard and the relaxations in the enforcement provisions. Chap-
ter IV estimates the total cash expenditure and cash flow savings
which would result if the proposed actions are implemented. The
results of these analyses are summarized below.
B. Summary
1. Te cjmolo^ica_l. Fe,asi.bility
The level of attainable emission standards for HDG engines is
influenced by several factors. First, is the limitation to non-
catalyst technology. Second, given the nature of this action, the
technology used should be less expensive to develop and purchase
than a catalyst system. Third, because of the limited time avail-
able for development, tooling, and certification, the technology
used should not require substantial leadtime. Finally, impacts on
fuel economy, driveability, and power must also be considered.
Given these constraints, the available technology to gain greater
emission reductions becomes limited to the conventional approaches
that have been used in the LDV and LDT fleets for several years.
The results of.the analysis in Chapter II indicate that the
HDE HC, NOx, and idle CO standards in place for 1984 are feasible
even under the constraints discussed above. However, the HDE CO
Z
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emission standard will have to be revised up from the statutory
standard to 35 g/BHP-hr.
EPA expects that HDG engines can comply with the HC standard
through the use of modifications, components, and recalibrations
•aimed at reducing cold operation emissions and providing more ef-
ficient air-fuel (A/F) mixtures during all operating modes. Com-
pliance with the revised HDE CO standard will be achieved pri-
marily through carburetor recalibrations and components which will
reduce cold operation CO, provide leaner A/F mixtures in all ope-
rating modes, a.nd increase the amount and efficiency of the air
injection system. Emission levels of 35 g/BHP-hr for CO and 1.3
g/BHP-hr for HC have alrady been achieved on current technology
engines. Based on the emission levels of current technology en-
gines the idle CO and NOx standards should be achieveable with
little difficulty.
Since only the 1984 HDE CO emission standard is proposed for
revision, and HDD engine CO emission levels are below even the
statutory level, there will be no substantial impact on the tech-
nological feasibility for HDD engines.
2. Eny.vrpnmenXa.l. .Impact
Implementation of the proposed relaxations and revisions
would result in greater per vehicle emission rates than would oc-
cur if the 1984 LDT and HDE gaseous emission regulations remained
in effect. These greater emission rates, primarily in HC and CO,
would result from all three of the major provisions being con-
sidered for change.
The adoption of non-catalyst technology will have two effects
on the HC and CO emission rates of HDG vehicles. First, the re-
striction to non-catalyst technology will force the revision of
the HDE CO emission standard. This will have no real effect on
heavy-duty diesel (HDD) vehicles, but will cause an increase in CO
emissions from HDG vehicles. Second, the low mileage emission
levels of HDG vehicles for both HC and CO will increase as a re-
sult of the smaller deterioration factors associated with non-
catalyst technology.
The two-year deferral of the HDE SEA program could also lead
to an increase in the HC emissions from all heavy-duty vehicles
(HDV) and the CO emissions from HDG vehicles. When no SEA program
is in effect manufacturers do not have to account for emissions
variability in their production engines. As a result, the average
emission level for any pollutant would be somewhat higher without
an SEA program. However, EPA expects some HDE manufacturers will
certify in 1984 accounting for the impacts of the 1986 SEA pro-
gram, thus eliminating the potential need for recertification in
1986 and at the same time minimizing the increase in HC and CO
emissions.
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The proposed relaxation in the AQL applicable to LDT and HDE
SEA will also lead to slight increases in emission levels. Relax-
ing the AQL from .10 to 40 percent allows a higher degree of non-
compliance during any given audit. Under a 40 percent AQL totally
accounting for emissions variability is less important than under
a 10 percent AQL. Most manufacturers account for emissions vari-
ability by lower target emission levels. Thus, the relaxation of
the AQL will likely lead to higher target emission levels and
overall higher per vehicle emission rates.
As is discussed in the Environmental Impact Chapter, EPA ex-
pects that if the proposed changes are implemented, an ozone and
CO air quality loss of 1-3 percent will occur as compared to the
base case (the 1984 LDT and HDE regulations as promulgated).
3. Economic. .Imp,act
EPA expects that the proposed relaxations and revisions will
provide the regulated industry with substantial cash flow and cash
expenditure savings. In 1981 dollars, discounted to January 1984,
the cash expenditure savings sum to $102.7 million dollars and the
cash flow savings sum to $43.2 million dollars. Of the $102.7
million dollars in cash expenditure savings, $72.8 million is pre-
1984 capital investment. Virtually all of the cash flow savings
is capital investment deferred from 1982-83 to 1984-85.
Over the 5-year period 1984-88, the aggregate savings to the
nation sum to over $449 million dollars. Most of this savings is
attributable to lower purchase and operating costs for HDG ve-
hicles. :
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CHAPTER II
TECHNOLOGICAL FEASIBILITY/
ATTAINABLE NON-CATALYST STANDARDS
A. Introduction
In this chapter, EPA analyzes available technologies and pro-
jects what levels of HC and CO emissions for heavy-duty gasoline
(HDG) engines are attainable for 1984, assuming that oxidation
catalysts are not employed.
B. Current HC and CO Emission Rates
To properly evaluate potential non-catalyst emission reduc-
tions from HDG engines, current emission rates must be reviewed.
Because absolute emission levels are inherently affected by the
test procedure over which they are measured, a review of the tran-
sient emission test is appropriate.
1. Overview: The Transient Test
The transient test is performed on a computer-controlled en-
gine dynamometer. During the test, the engine is driven through
continuously-varying speeds and loads according to prescribed cy-
cles. These speed and load cycles were developed from in vehicle
performance data taken from 57 urban HDG trucks: 30 in the joint
industry/EPA CAPE-21 study in New York City, and 27 in the EPA-
conducted Los Angeles CAPE-21 study. These trucks were actual
commercial vehicles operated by their own drivers; the performance
data was taken in the course of their daily business. These data
were then used to generate driving cycles representative of the
input data.
There are several key aspects of the transient test:
a. It is engine specific,
b. It is composed of subcycles, each of which retains the
characteristic driving patterns of specific urban localities, and,
c. It is performed on a "cold" engine, and then repeated
with the engine in a warmed-up state.
Each of the above characteristics is critical in evaluating cur-
rent and future emission trends.
Engine specific means that the cycles are defined in terms of
percent speed and percent load, i.e., any two engines are required
to deliver identical percent powers -throughout the cycle even
though their absolute power levels may be different. This, and
the fact tha.t emissions are expressed as mass per output work
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(work is simply power multiplied by the time at that power), make
emission results between engines comparable, regardless of their
Specific rated power and varying performance characteristics.
Secondly, the cycle is actually four subcycles joined end to
end, each one characteristic of a particular geographic area and
type of driving:
Duration
Subcycle (sec) Charac^tejcistic^s
1. New York Non-Freeway (NYNF) 272 low power; stop-and-
go; 45% idle;
avg. spd. 7.8 mph
2. Los Angeles Non-Freeway (LANF) 309 moderate power, tran-
sient; 26% idle;
avg. spd. 15.1 mph
3. Los Angeles Freeway (LAF) 316 high-speed, high-
power cruising;
avg. spd. 45.54 mph
4. New York Non-Freeway (NYNF) 272 repeat of 1.
Each subcycle demands different performance from the engine, and
produces different absolute emission levels. These performance
demands can be isolated .and their emissions impact reasonably
estimated.
Thirdly, the heavy-duty engine dynamometer test is similar to
the light-duty vehicle test in that the total emission results are
derived from a weighted average of a "cold" engine cycle and a hot
engine cycle. For the heavy-duty test, the cold start emission
cycle consists of the above four subcycles (NYNF, LANF, LAF,
NYNF), and is weighted 1/7 of the total; the hot start cycle is
identical to the cold, begins 20 minutes after shut down of the
engine from the cold start, and is weighted 6/7 of the total.
These weighting factors were derived from the observed in-use
ratio of cold starts to hot starts in the CAPE-21 survey.. Since a
cold engine characteristically emits higher amounts of HC and CO,
the cold start cycle is significant when discussing current and
future emission levels.
2. Current Technology Engines
Table 11-1 presents a list of 1979 MY -HDG engines tested by
EPA on the transient cycle. Table II-2 presents subcycle by sub-
cycle HC emission breakdowns for each engine, along with a percent
contribution of' each subcycle to the total emission results.
Table II-3 presents the same data for CO.
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Table II-l
1979 HDG Current Technology Baseline
Engine
Family
Ford 400
Chrysler 440
Ford 370
IHC 446
GM 350
Chrysler 360
GM 350
IHC 345
GM 454
GM 366
GM 292
GM 454
6.6L "E"
RBM
6.1L "E"
MV8
113
LAI
113
V345
114
114
.112
115
HC*
(g/BHP-hr)
2.
2.
2,
2.
4.89
3.83
3.51
3.27
3.14
67
48
44
30
2.16
2.12
1.31
(H)**
(H)
(H)
(H)
(M)
(M)
(M)
(M)
(M)
(L)
(L)
(L)
CO*
(g/BHP-hr)
112.4 (H)
112.4 (H)
47.8 (L)
90.4 (H)
118,
96,
(H)
(H)
64.8 (M)
34.4 (L)
51.6 (L)
43.4 (L)
55.0 (L)
78.5 (M)
* Average of several tests.
** Engines are classified as high (H), moderate (M), or lower (L)
emitters of a given pollutant. Note that a high HC engine is also
usually a high CO engine, but not in every case.
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Immediately noticeable in Table II-l are the high levels of
HC and CO emissions. Note that the engines were certified for
1979 at 1.5 g/BHP-hr HC and 25 g/BHP-hr CO, but on the 9-mode
steady-state test procedure. In complying with any motor vehicle
emission standard, the design approach is to match the engine cal-
ibration and. emission control system to the test procedure it-
self. This is the case in light-duty (see Reference 2), and in-
deed in heavy-duty. Table II-4 presents comparative HC and CO
emission data for both transient and 9-mode test procedures for
the current technology (1979) engine baseline. The large dif-
ferences in measured emissions are explainable by the readily
identifiable differences in required engine performance under each
test.
3. The 9-Mode Test
The 9-mode test procedure consists of nine steady state en-
gine operating modes which are weighted into a composite emission
number:
Mode Speed (RPM) % Power Weighting Factor
1 Idle 0 .232
2 2000 25 .007
-3 2000 55 .147
'4 2000 25 .077
5 2000 10 .057
6 2000 25 .077
7 . 2000 90 .113
8 2000 25 .007
9 2000 Closed Throttle .143
The 9-mode is performed with the engine in a warmed-up state, at
only one engine speed (except idle). To date, it can be firmly
stated that on all current production engines all efforts at emis-
sion control on HDG engines have been directed primarily at these
modes.
There are three major areas of engine operation which the
transient test contains, but not the 9-mode:
a. Full power operation;
b. Transient operation, at al^ speeds and loads;
c. Cold engine operation.
These areas give rise to the measurable emission differences, and
reflect where control technology will need to be directed for
1984. In this analysis we will show that full power (power en-
riched) LA Freeway modes are the major source of CO emissions in
current technology engines, and also a significant source of HC on
the higher emitting engines. Secondly, the major source of HC on
the lower HC emitting engines will be shown to be the cold engine
8
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operation. Finally, on the lower-emitting engines, it will be
shown that non-cold start HC and the remaining CO emissions are
not as attributable to any one mode or source, and are primarily
relatable to inadequately controlled mixture calibration as the
engine undergoes transients at all speeds and loads throughout the
entire test cycle.
4. Full Power Operation •
Under wide open throttle (WOT) conditions, additional fuel is
added to the combustion mixture. This power enrichment causes
richer than stoichiometric mixtures, thereby promoting power and
driveability, but drastically increasing unburned fuel (HC) and
partially oxidized fuel (CO) emissions due to lack of oxygen.
Present day engines certified to the 9-mode were emission con-
trolled primarily up to 90 percent power (at only a single speed);
note that current technology engine power valves are calibrated to
cause power enrichment above 90 percent power. Thus, full power
emissions on current technology engines are uncontrolled.
This observation is demonstrated by the data presented in
Tables II-2 and II-3. In both tables, data from all twelve cur-
rent technology engines tested at EPA are presented. In addition,
the engines are also grouped into three categories: high, medium,
and low emitters of a given pollutant. Note mode 7, the LA Free-
way (LAP) in the hot-start portion of the test: 29.6 to 65.7 per-
cent of brake specific CO (BSCO) emissions are attributable to
this high-power segment. More interesting are the trends observed
in segment percentage contributions from the highto the low-
emitting engines. As the average composite BSCO emissions go from
105.5 g/BHP-hr (higher emitters) to 46.1 (lower emitters), i.e., a
2.3 fold decrease, all other subcycle model percentages increase
by approximately two-fold except for the LAF mode, which decreases
in contributing percentage from 56.3 to 36.7 percent (i.e., a
lower percentage of a lower composite number). Had all modes de-
creased proportionally, the model percentages should remain con-
stant. Clearly the major difference between high and lower CO en-
gines is the amount of CO generated during the LAF segment. This
is primarily a result of power enrichment in the carburetor during
the LAF's characteristic high speed, high power operation. (Per-
haps most indicative is the actual mass of CO generated during the
LAF segment. Note in Table II-3 that total grams of CO generated
in the LAF segment are 50-650 percent higher than those of the
next highest hot start segment.)
The data for HC (Table II-2) is less dramatic with regards to
LAF dominance, but the trends are nevertheless the same. Every
high CO engine, (i.e, those with LAF dominance of CO emissions)
also has dominant LAF HC emissions (ranging from 23.7 to 36.0 per-
cent total contribution). This is logical since in this opera-
tional mode both emissions arise primarily from inadequate oxygen
for total combustion in the fuel-enriched mixture. Again, the
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Table 11-2
Engine by Engine Transient HC Emission Breakdown
Cold Start
o
IIIC 446
1IIC 345
CM 366
CM 350
F 400
F 370
lln)
2|b)
3[c]
4|d|
1.
2.
3.
4.
I.
2.
3.
4.
1.
2.
3.
4.
1.
2.
3.
4.
1.
2.
3.
4.
I
NYNF
24.73
23.26
.289
8.7X
25.50
64.84
.40
17. OX
47.86
94.7
."64
28. 8*
61.49
95.0
.86
33.5%
32.91
46.77
' .56
11.77.
20.11
52.25
.36
10.9%
2
LANF
17.11
6.97
.188
5.6*
9.09
5.51
.13
5.52
12.73
6.24
.16
7.22
12.57
6.30
.17
6.6%
16.16
9.66
.26
5.4%
8.13
5.29
.14
4.2X
3
LAP
15.10
1.81
.166
5.0%
4.93
0.78
.07
3.0%
5.95
0.81
. .08
3.6%
6.42
.92
.08
3.1%
14.67
2.60
.24
5.0%
7.39
1.35
.13
3.9%
4
NYNF
5.55
5.23
.061
1.8%
3.80
5.20
.06
2.6%
2.61
2.69
.03
1.4%
2.81
3.06
.04
1.6%
6.68
9.38
.11
2.3%
1.71
2.47
.03
.9%
20 .
Minute
Pause
Hot Start
5
NYNF
9.66
10.65
.677
20.4%
4.82
7.14
.44
18.7%
4.96
5.69
.39
17.6%
4.71
5.56
.37
14.4%
8.62
12.10
.87
18.1%
8.05
13.37
.85
25. U
6
LANF
11.14
4.61
.736
22.2%
6.29
3.40
.54
23.0%
4. By
2.28
.36
16.2%
6.50
3.16
.49
19.1%
10.11
5.77
.96
20-. 0%
7.65
A. 78
.76
23.0%
7
LAF
12.53
1.50
.831)
25. OX
4.84
0.75
.42
17.9X
5.07
0.69
.37
16.7%
4.5b
.65
.35
13.6%
13.17
2.33
1.25
26.0%
6.96
1.26
.69
20.8%
8
NYHF
5.71
5.36
.373
11.2%
3.40
4.38
.29
12.3%
2.62
2.74
.19
8.6%
2.74
2.95
.21
.8.2%
5.69
8.02
.55
11.5%
3.4b
5.02
.35
10. 6X
Composite
le s t
Result
3.32
3.3i!
10U<
2.35
2.3i
100X
2.22
2.22
10UX
2.57
2.57
100X
4.80
3.31
3.31
1UOX
Me'liuiu, or
Low Kin i 11 c r | e. I
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Table H-2 Uont'd)
Cold Start
Engine by Engine Transient HC Emission Breakdown
Hot Start
C 360
C '.'.0
CM 454
CM 292
CM 454
1.
2.
3.
4.
1.
2.
3.
4.
1.
2.
3.
4.
1.
2.
3.
4.
1.
2.
3.
4.
1
NYNF
8.56
13.11
.11
4.5*
17.38
20. 12
.19
5. OX
16.38
19.06
.20
15.5%
47.31
65.65
.80
37. Ti
44.54
62.38
.44
17.9%
2
LANF
7.18
3.42
.09
3.6%
10.57
4. 10
.11
2.9*
3.88
1.74
.05
3.9%
4.33
2.62
.07
3.3Z
15.43
5.75
.15
6.U
3
LAF
8.22
1.08
.10
4.0%
24.67
2.78
.26
6.8%
5.34
,63
.06
4.7%
2.08
0.39
.03
1.4%
6.80
0.68
.06
2.4%
4
NYNF
3.63
3.96
.05
2.0%
7.76
7.41
.08
2.1%
1.68
1.83
.02
1.6%
1.64
2.08
.03
1.4%
6.43
5.83
.06
2.4%
5
NYNF
10.23
13.54
.80
32.7%
10.25
11.32
.67
17.62
4.94
5.82
.35
27.1%
4.12
6.17
.43
20.3%
11.85
11.24
.70
28.5%
6
LANF
6.41
2.99
.47
19.2%
9.32
3.65
.57 .
15.0%
2.39
1.07
.17
13.2%
3.71
2.20
.37
17.5%
6.97
2.52
.39
15.9%
7
LAF
7.87
1.04
.58
23. 7i
22.22
2.40
1.37
" 36. OX
4.95
0.60
.33
25.6%
1.95
0.37
.20
9.4%
5.65
0.57
.33
13.4%
8
NYNF
3.52
3.77
.28
10.2%
9.10
11.69
.56
14.7%
1.57
1.72
.11
8.5*
1.83
2.33
.19
9.0%
5.80
5.25
.33
13.4%
Composite
Test
Result
2.45
2.45
I DUX
3.bl
3.bl
lOUi
1.29
1.29
100X
2.12
2.12
100%
2.46
2.46
100%
High
Medium, or
Low hinittcr
-------
Table U-2 (cont'd)
Engine -by -Engine _T ran8ie_nt_ _HC Ernie s ion B^rea kdown
1.
CM 350 2.
3.
4.
Av«.Tnv.<-' :
All' 4.
K UK inn 9
Avcrac.i: :
ilif.h IIC 4.
Engines
Average :
M..-il. IIC 4.
Engines
Low (1C 4.
Kii)'inc;8
I
NYNF
21.04
31.48
.34
12.8*
17.0%
9.1%
17.1%
27.3%
Cold Start
2 3
LANF LAF
6.13 10.39
3.53 1.71
.09 .16
3.4% 6.0%
4.8% 4.1%
4.5% 5.2%
5.0% 3.7%
4.«% 3.2X
4
NYNF
3.69
5.34
.06
2.3%
1.9%
1.8%
2.2%
1.5%
20-
Minute 5
Pause NYNF
3.66
5.18
.34
12.8%
21.1%
20.5%
21. 4X
21. 7X
Hot Start
6 78
LANF LAF NYNF
5.01 9.51 3.71
2.93 1.57 4.51
.46 .87 .34
17.3% 32. 7X 12.8%
18.4% 21.7% 11.0%
20.1% 27.0% 12.0%
18.9% 20.3% 11.4%
15. 6X 17.2% 8.7X
Total High
Test Medium, or
Composite Low Emit tor
2. bo H
2.66
lOOi
Emission l.evul
100% (12 engines) 2.1b
100% II (.4 engines) J.bi
100% M (5 engines) 2.5U
100% L O engines) l.bB
|a| Total grams per subcycle.
|bl Cromn per brake-horscpower-hour per subcycle.
|cl Subcycle contribution, in effectively-weighted grams per brake-horsepower-hour, to the composite test result. Iwuen
mldcifl together, all subcycle contributions add up to the composite test result). For methodology, see Kelerence 1,
pp. 4-5.
ld| Kclnnivc percentage o£ subcycle contribution (3) to the total composite test result.
|e) In grams per brake-horsepower-hour: High (H)/ 3.3
3.3^ medium (M)"/ 2.3
Low (L)<2.2
-------
Table 11-3
Engine-by-Engine Transient CO Emission Breakdown
I Hi: 446
IIIC 345
CM 366
CM 350
F 400
F 370
1
NYHF
lla]
2|b|
3|c|
4 Id)
I.
2.
3.
4.
\.
2.
3.
4.
1.
2.
3.
A.
1.
2.
3.
4.
1.
2.
3.
A.
236.
222.
2.
3.
90.
2^9.
1.
4.
143.
284.
1.
it.
171.
264.
2.
3.
222.
316.
3.
3.
85.
221.
1.
3.
,4
4
79
0%
3
6
40
32
7
3
9
5%
2
5
4
5%
9
7
8
4%
2
5
5
32
Cold
2
LANK
245.2
99. 9
2.73
2.9%
84.7
51.4
1.24
3.8%
140.7
69.1
1.8
4.3%
155.2
77.7
2.1
3.1%
162.4
97.0
2.6
2.3%
106.6
69.4
1.8
4.0%
Start
3
LAF
774.8
93.0
8.63
9.3%
153.2
24.2
2.24
6.82
187.7
25.5
2.4
5.7%
404.5
57.8
5.3
7.8%
620.6
109.9
10.0
8.8%
230.7
42.1
3.9
8.7%
20-
4 Minute
NYNF Pause
127
119
I
1
60
79
2
86
88
1
2
102
116
1
2
130
183
2
1
21
30
.2
.9
.42
.5*
.0
.2
.88
.rx.
.1
.8
.1
.6%
.6
.6
.4
.1%
.6
.5
.1
.9%
.4
.9
.4
.9%
Hot Start
5
NYNF
123.3
135.9
8.73
9.4%
39.7
58.9
3.70
11.3%
88.0
100.8
6.9
16.52
111.6
131.9
9.3
13.7%
103.5
145.4
10.6
9.4%
38.8
64.4
4.2
9.3%
6
. LANF
200.0
82.7
13.3
14.3%
60.2
32.5
5 . 29
16.1%
113.3
52.9
8.7
20.8%
130.2
63.4
10.1
14.9%
161.6
92.2
15.6
13.8%
80.1
50.0
8.1
18. 0%
7
LAP
708.1
84.7
47.1
50.7%
150.6
23.2
13.11
40.02
167.0
22.8
12.5
29.8%
376.6
53.9
29.7
43.8%
582.3
103.0
56.2
49.6%
206.7
37.4
21.0
46. .72
8
NYNF
122.7
115.1
8.20
8.82
56.1
72.3
4.94
15.12
B8.2
92.1
6.6
15.82
95.3
102.5
7.4
10.9%
127.3
179.6
12.3
10.9%
40.3
58.4
4.1
9.12
Composite Hi^li
'I'est Medium, or
Kesult Low him i 1. er tc 1
.
92. b8 "li
92. b8
1002
-
32.8 L
3/.0
1002
_
41.9 L
41.9
1002
_
67. B M
67.8
1002
_
113.2 ii
113.2
1002
_
45.0 L
45.0
100*
-------
Table 11-3 (cont'd)
Engine~by-Engine Transient CO Emission Breakdown
C 360
C WO
<;M A 5 A
(Short
Block)
CM 292
CM A 54
I Tall
Block)
1.
2.
3.
4.
I.
2.
3.
4.
1.
2.
3.
It.
1.
2.
3.
A.
1.
2.
3.
A.
1
NYNF
107.5
164.7
l.A
1.5%
228.3
26A.3
2.5
2.2%
250.3
291.3
3.1
3.8%
315.0
A37.1
5.6
10.2%
204.8
286.9
2.1
3.8%
Cold
2
LANF
1AA.7
68.8
1.8
2.0%
203.6
78.9
2.1
1.8%
86.2
38.7
1.0
1.2%
115.7
69.9
2.0
3.6%
175.6
65.5
1.7
3.0%
Start
3
LAF
868.6
113.8
10.8
11.7%
1262.0
1A2.1
13.1
11.3%
769.6
91.3
9.0
11.0%
159. A
30.2
2.7
4.9%
376.1
37.9
3.6
6.4%
A
20-
Minute
NYNF Pause
61
66
100
96
1
65
71
1
6A
81
1
2
144
131
I
2
.2
.7
.8
.9%
•&
.0
.0
.9%
.2
.1
.8
.OX
.7
.9
.1
.0%
.6
.1
.A
.5%
Hot Start
5
NYNF
56.6
76.3
4.6
5.0%
.75.2
83.0
5.0
4.3%
86.9
102. A
6. A
7.8%
89. A
133.7
9.6
17.5%
153.9
146.1
9.3
16.7%
6
LANF
127.9
59.5
9.6
10. A%
161.1
63.0
10. 0
8.7%
102.8
45.8
7.2
8.81
111.0
65.9
11.2
20. AX
157.1
56.7
9.0
16.1%
7
LAF
783.0
103.3
58.6
63.7%
1217.2
131.7
75.9
65. 7X
71A.1
87.2
A9. 5
60. AX
161.5
30.5
16.3
29.6%
366.2
36.9
.20.9
37. 4X
8
NYNF
58.5
62.6
A. A
A. 8%
9A.I
89.9
5.9
5.1%
69.7
76.2
A.y
6.0Z
70.0
89.1
. 7.1
12.9%
138.2
124.9
7.9
14. 1%
Composite High
Test Medium, or
Result Low fciuicter
_
92.0 H
92.0
100*
_
115.6 li
115.6
-
_
81.9 H
81.9
loox
-
55.0 L
55.0
100X
_
55.9 L
55.9
100%
-------
Table U-3 (cont*d)
• Engine~by~Ensine Transient CO Emission breakdown
1
NYHF
1. 196.1
r,M 350 2. 293.3
3. 3.2
4. 3.2%
Avt: rnt;e
All 4. 3.9Z
1C UK incs
Average
H i nil CO 4 . 2.6%
Engines
Aver.ige
Mo.l CO 4. 3.7X
f-nj; incs
A v c r n y, e
Low CO 4. 5.2Z
KM,; i IK'S
Cold
2
LANF
108.9
62.6
1.7
1.7%
2.8%
2.1%
2.2Z
3.7%
Start 20-
3 4 Minute.
LAF NYNF Pause
805.5 68.1
132.21 98.6
12.1 1.1
11.8% 1.1%
9.5% 1.7%
12.6% 1.2%
9.4% 1.6%
6.5% 2.1%
Hot Start
5 6 7
NYNF LANF LAF
92.1 104.8 640.8
130.1 61.4 106.0
8.5 9.7 59.2
8.4% 9.6% 58.3%
10.7% 14. 2X 47. 9X
7.1% 11.1% 56.3%
10.8% 11.9% 52. U
14.3% 18.3% 36.7%
8
NYNF
64. B
78.8
6.0
5.9%
9.9X
7.0%
8.5%
13. 4Z
Total liiy,h
Test Mertiuu, or
Composite Low bmittur
101.5 H
101.5
100%
A v t; r a , , <_• 1 1 C
hju i s y i on Li: vi
10UX . (12 engines) 7b. 7
100% (5 engines) lO'j.'j
100% (2 enyinus) 7't.y
100% (5 engines) 40. I
In I Total . c.rninB pnr subcyclc.
|b] Urams PIT brnko-horscpowcr-hour per subcycle.
(c| Siibcycle contribution, in effectively-weighted grams per brake-horsepower-hour, to the composite test result. (wiu:n
iirlilcd t..j|;ei.lier, all subcycle contributions arid up to the composite test result). For methodology, see Kulurcncu 1.
pp. 4-i.
| (I) Uelntive percentage of subcycle contribution (3) to the total composite test result.
[c| In grnniR per brnkc-hurecpowcr-hour: Hie'' (H)/90
90 > medium (M5"> 60
Low
-------
Table'II-4
Engine
9-Mode Versus Transient Emissions
Current Technology Engines[1][2]
BSHC
9-Mode
1979 GM 292
1979 GM 454
1979 GM 350
1979 IHC 446
1979 GM 366
1979 IHC 345
1979 GM 350
1979 Ford 400
1979 Ford 370
1979 Chrysler 360
1979 Chrysler 440
1979 GM 454
0.42
0.39
0.79
0.42
0.50
2.73
0.59
2.15
1.20
1.18
0.83
0.47
Transient
2,
2.
4.
3,
2.12
2.30
3.14
3.27
2.16
44
48
89
51
2.67
3.83
1.31
BSCO
9-Mode
26.86
17.33
14.62
24.28
17.40
17.68
20.40
53.16
37.12
21.38
10.47
20.11
Transien.^
54.98
51.55
118.07
90.40
43.43
34.44
64.76
112.43
47.75
98.14
112.38
78.49
f'lj Engines were tested as received from the manufacturers.
[2] All levels are undeteriorated.
•w_ ) f"fr~r* i.
M- 17
-------
lower the total HC emissions are, the lesser the percent contribu-
tion of the LAP segment to that total.
In summary, power enrichment occurs at the high power points
throughout the entire transient test cycle, but the majority of
this high power operation is found in the LA Freeway segment.
Emissions performance over this segment is the major differenti-
ating factor between lower and 'higher emitting engines. Control
of power enrichment is the first and most effective step in re-
ducing CO emissions with or without a catalyst. This will be dis-
cussed further below.
5. Transient Operation/All Speeds and Loads
As the LAP emissions contribution drops when going from the
higher to lower emitting engines, the contribution from other seg-
ments tend to increase until no single segment is dominant. (The
obvious exception to this is cold start HC, which is discussed be-
low.) Aside from certain physical factors,* these emissions arise
from less than accurate fuel metering and mixing as the engine
drives over the entire test cycle. If the fuel flow does not pre-
cisely match the engine inlet air flow at any instant in time,
then too lean or too rich mixture conditions prevail, along with
ensuing lean misfire (high HC) or incomplete combustion (high HC
and CO). This matching is complicated by the inevitable need to
closely match the fuel and air flows at continually varying speeds
and loads while also maintaining power and driveability. All cur-
rent technology engines were emission optimized at idle, and at
eight different steady-state power modes at 2000 RPM. This repre-
sented a reasonably simple design/calibration problem, as evi-
denced by the engines' emission performance over the 9-mode test.
Once outside that limited regime of emission-optimized modes, how-
ever, such as on the road or on the transient test, emissions re-
main virtually uncontrolled. Little design attention with respect
to emissions has been given to the majority of the engines' opera-
ting ranges.
Precise matching of fuel and air flows under varying condi-
tions, including transient enrichment by the accelerator pump for
driveability, is a major emission-related problem of mixture con-
trol. Another is the problem of achieving as homogeneous (per-
fectly mixed) a fuel/air (F/A) mixture as possible. Incomplete
mixing (including liquid fuel deposition on the manifold or com-
bustion chamber walls) produces localized pockets of rich and lean
mixtures, resulting in an overall increase in HC and CO emis-
sions. Complete mixing is also critical to achieving uniform A/F
ratios from cylinder to cylinder, again to optimize overall emis-
sion performance.
* Combustion chamber design affects wall quenching. Inlet
manifold design affects mixture distribution between cylinders,
fuel deposition in the manifold, and heat exchange charac-
teristics. All of these in turn affect HC and CO emissions.
I 7
-------
The above, problems are not new, are well recognized, and have
already been addressed in the light-duty passenger car fleet. Ex-
perience with the light-duty fleet has indicated, however, that
there exists a definite limit to the amount of HC and CO emission
reductions achieveable through recalibration before power, drive-
ability, and/or fuel economy become unacceptable. For this rea-
son, catalysts become inevitable at lower emission standards, both
for their effectivenss and the flexibility in engine calibration
their effectiveness permits.
6. Cold Engine Operation
Cold s.tart emissions are substantially higher than those of a
fully warmed-up engine, and usually require separate attention
during control system design. Again referring to Tables II-2 and
II-3, we note that cold start HC contributions are high, and be-
come dominant at lower overall levels of HC emissions. Cold start
CO on the other hand has a relatively minor effect on an overall
basis. This phenomenon! is typical, though perhaps exaggerated by
the lack of design control in the past, and is attributable to the
fact that a very rich mixture is needed for starting and drive-
ability in a cold engine, to compensate for dieposition of a large
part of the fuel on cold manifold walls. This rich mixture is
provided by the choke mechanism, either manual or automatic.
Emissions arise both from this overall rich mixture, misfire, and
from the eventual evaporation of the condensed fuel. Emissions
have not been a design constraint in the past for cold starting,
only startability, driveability, and power. The transient test
procedure itself is demanding, requiring both emission control and
high power driveability early in the cold start cycle.
C. Available Control Techniques
1. Overview
Widespread introduction of new non-catalyst technologies is
assumed to be an unrealistic scenario for the 1984 model year.
This is a function of the remaining leadtime, and cost - the in-
tent of this rulemaking is to ease the capital expenditure burden
on the.industry. Technologies which EPA expects to be implemented
for 1984 will not be new, but rather will represent refinements,
^calibrations, and optimizations of current technologies.
2. Im)rovemerits to Fuel Metering
By and large, fuel metering improvements will be the single
most effective strategy for reducing overall HC and CO emissions
in 1984 engines, especially when optimized for the transient
test. These improvements include modifications to carburetors to
achieve more precise F/A ratio control, and recalibration to lean-
er F/A ratios on an overall basis, and especially under transient
conditions and WOT.
18
-------
Figure II-l presents the CO emission distribution of the 1979
baseline engines. Note that two mutually exclusive sets of car-
buretors are found above and below 70 grams/BHP-hr, representing
higher and lower emitting engines. Some carburetors (those below
70 g/BHP-hr) meter fuel more accurately under transient conditions
even though also optimized for the 9-mode. Power enrichment,
sometimes observed at 4-6 percent CO (40,000 to 60,000 ppm in the
raw exhaust) contributes substantially to these CO levels, as
shown above in Table 11-3. At any rate, we infer from Figure II-l
that since two groups of carburetors produce two radically dif-
ferent emission rates on a test procedure for which neither was
optimized, the higher emitting group is unrepresentative of cur-
rent technology and should not be considered a realistic starting
point when extrapolating achieveable emission reductions. They
represent excessive power enrichment/inaccurate fuel metering pro-
ducing twice the CO emissions of other engines of equivalent power
and displacement. The realistic current technology CO baseline
is, therefore, presumed to be in the range of 40-60 g/BHP-hr. It
is from this range downward in which development work will be con-
centrated.
The prime result of recalibration will need to be leaner mix-
ture calibration, and leaner WOT and transient enrichment, thereby
reducing both HC and CO emissions.
3. Improved Mixture Distribution
As overall calibrations get leaner, it becomes more important
from a power., driveability, and emissions standpoint that the F/A
mixture be as homogeneously mixed as possible and the mixture dis-
tribution to each cylinder is uniform. Localized rich or lean
"pockets" in the mixture should be eliminated by the time it en-
ters the cylinder. Assuring uniform F/A mixture distribution to
each cylinder is also important. Too lean a mixture in one or
more cylinders will force recalibration to a richer operating
point to accommodate the needs in that cylinder, which will in
turn cause too rich a mixture in other cylinders.
This is essentially a problem of improving the mixing of air
and fuel in the manifold prior to cylinder induction. The liquid
fuel must be vaporized and then mixed, requiring heat energy and
substantial turbulence. Deferring the problem of cold starting
until later, heat energy arises from the air itself and from the
warm manifold. Improvements would come from redesign of the mani-
fold to increase turbulent mixing, and to increase heat transfer
(perhaps by heating intake air by drawing it across the exhaust
manifold) to the intake air or air/fuel mixture.
4. Other Physical Modifications
Other physical changes to the engine have been proven to re-
duce unburned fuel emissions, such as decreasing surface-to-volume
ratio of the combustion chamber to minimize wall quenching, reduc-
tions in cylinder "dead" volume, etc. Although these may be per
-------
4 -i
Figure II-l
CO Distribution of 1979 Baseline Engines
3-
Number of
Engines
ro
o
H
IHC
V-345
(Mo1ley
2bbl)
CM 366
(Holley
4 bbl)'
Ford 370
(Holley
4 bbl)
CM 292
(Roch.
1 bbl)
GM 454
(Holley
4 bbl)
GM 350
(Roch.
2 bbl)
GM 454
(Roch.
4 bbl)
IHC 446
(Carter
4 bbl)
Ihrysler 360
(Carter
4 bbl)
Ford 400
(Motorcraft
2 bbl)
Chrysler 44(
(Carter
4 bbl)
CM 350
(Roch.
4 bbl)
30-40
.40-50
50-60 60-70 70-80
CO (grams/BHP-hr)
80-90
90-100
100-120
-------
formed on some engine families, we do not consider fleetwide phy-
sical redesign of engine combustion chambers for all families to
be realistic or necessary for 1984.
5. Other Calibration Optimizations
As mixture calibration optimization reaches its limit with
respect to attainable reductions, other calibrations - notably
spark timing - can be utilized to further reduce HC and CO. Iron-
ically, these reductions are made possible by the other 1984 MY
emission standard for heavy-duty engines: the NOx standard of
10.7 grams/BHP-hr. NOx emissions at this level are relatively
uncontrolled, and will allow ignition timing calibration to be set
near MET* - the most efficient calibrations. The higher NOx
standard permits both lean mixtures and optimum timing advance -
both of which increase NOx but decrease HC and CO emissions and
fuel consumption.
Furthermore, spark timing can also be optimized for the cold
start portion transient test procedure. The light duty fleet cur-
rently uses electronically-controlled spark timing to optimize ig-
nition under all engine operating conditions in the Federal Test
Cycle to minimize emissions and maximize fuel economy. The
methodology and technology is entirely applicable, if necessary,
to HDG engines on the transient test.
6. Improved Warm-up Characteristics
As emission levels decrease with mixture and ignition timing
optimizations,; the limiting factor for HC reductions is clearly
the engine's performance on the cold start portion of the tran-
sient test. As Table II-2 above indicated, cold start HC emis-
sions are the dominant fraction of engine-out HC.
Two strategies exist for reducing cold start emissions: re-
strict the amount of cold mixture enrichment, and increase the
warm-up rate of the engine. The former is straightforward, and
limited by the amount of leaning a cold engine can withstand and
still maintain the high driveability and performance both the road
and the transient test require. This is done by choke recali-
bration. Increasing the warm-up rate of the engine can be ac-
complished in primarily two ways: decrease the efficiency of the
overall combustion cycle, and use exhaust gas heat to rapidly warm
the intake manifold and/or intake air. Cycle efficiency reduc-
tions are best achieved by changing spark timing as a function of
engine temperature: less efficient spark timing calibrations re-
duce engine efficiency, and increase the amount of waste heat re-
jected to the combustion products and thereby conducted to the en-
gine itself. The result is a faster warm-up; less time spent in a
cold state reduces cold emissions.
* "MET" denotes the minimum timing retard (i.e. maximum timing
advance) at which maximum power is obtained without inducing knock
reactions.
21
-------
Cold start HC emissions, as elaborated above, are presently
uncontrolled, and generally dominate at lower overall HC emission
levels. .Table II-5 lists current technology engines, and the per-
cent increase in composite total transient test HC and CO emis-
sions attributable to the cold start cycle. (The cold start cycle
is identical in every way to the hot cycle, with the sole excep-
tion of engine temperature.) From this we can infer the amount of
emissions generated by the "cold"* 'engine temperature. Figure
II-2 graphically portrays the percentage attributable to cold en-
gine temperature versus the total composite test result, and il-
lustrates the general trend of increasing impact of cold HC emis-
sions with lower overall HC emission rates. (Note that there are.
exceptions to the trend). All of the 1979 baseline engines tested
by EPA were equipped with automatic chokes; the high degree of
scatter in the Table II-5 data indicates that varying choke cali-
brations are possible. Since the varying engine calibrations were
not optimized for either a transient test or a cold start, the
available data does not lend itself to determining the exact con-
tribution of the cold start to overall test results at any given
emission level. The data do indicate, however, that it can be
significant ( probably 10-40 percent). The real question is to
what degree cold start HC emissions can be reduced by choke recal-
ibration/improved warm-up. Experience tells us that significant
reductions are achievable from uncontrolled engines.
7. Summary of Possible Control Technique's
Based on the discussion above EPA has identified a number of
potential means of reducing HC and CO emissions from HDG engines.
These are summarized below.
a. Carburetion - modifications and improvements to the
power enrichment, accelerator pump, and general fuel metering sys-
tems.
b. Calibrations - spark timing, A/F ratio, and EGR flow
rate calibrations.
c. Manifold/Combustion Chamber Redesign - intake manifolds
could be redesigned to improve the homogeneity of the F/A ratio.
Combustion chamber surface-to-volume ratio could be decreased and
cylinder dead volume minimized to lessen fuel quenching on
cylinder walls.
d. Air Inj ec t ion System - Increased air injection to the
exhaust manifolds will increase the HC and CO oxidation. This
system could be further improved by an air -modulation system and
possible recalibrations of the pressure relief and diverter
valves. Some exhaust manifold modifications may also aid. the
efficiency of the air injection system.
* "Cold," for laboratory test procedure purposes, is a tempera-
ture between 68° and 8fa°F.
Z2L
-------
Table II-5
Cold Start Contribution to Conposite Emission Results
HC
CO
Engine
Ford 400
Chrysler
Ford 370
1HC 446
GM 350
Chrysler
GM 350
IHC 345
GM 454
GM 366
GM 292
GM 454
Composite
HS
4.26
440 3.70
3.10
3.06
1.71
360 2.46
2.36
1.98
1.14 •
1.55
1.38
2.04
HC Averages:
Composite
Total Test
4.80(H)
3.81(H)
3.31(H)
3.32(M)
2.57(M)
2.45(M)
2.66(M)
2.35(M)
1.29(L)
2.22(L)
2.12(L)
2.46(M)
High (H):
Med. (M):
Low (L):
% Due
To CS
11.3%
2.9%
6.3%
7.8%
33.5%
neg.
11.3%
15.7%
11.6%
30.2%
34.9%
17.1%
6.3%
14.2%
25.6%
Composite
HS
110.4
112.5
43.5
90.5
66.0
90.0
97.2
31.3
79.8
40.4
51.2
54.8
Composite
Total Test
113.2
115.6
45.0
92.9
67.8
92.0
101.5
32.8
81.9
41.9
55.0 .
55.9
% Due
To CS
2.5%
2.7%
3.3%
2.6%
2.7%
2.2%
4.2%
4.6%
2.6%
3.6%
6.9%
2.0%
Grams/BHP-hr, results of individual tests, unweighted.
-------
Figure 11-2
•Cold Start Contribution to Total Test
HC Emissions as a Function of Total Test Emissions
H : Average, All higher emitting engines.
M : Average, All moderate .emitting engines.
L : Average, All lower emitting engines;
40-
35 .
30-
% Due.to
Cold Start 25 -
20-
15 -
10-
5 -
©
5.0
4.0 3.0 2.0 1.0
Total Test HC (grams/BHP-hr)
0.0
-------
e. Automatic Choke - the use of a properly calibrated
automatic choke would decrease cold start HC and CO emissions and
improve warm-up time.
f. Early Fuel Evaporation (EFE) - this system involves the
use of exhaust gases to warm the air-fuel mixture by directing
some of the exhaust gases through a passage below the carburetor.
A warmer A/F mixture improves the fuel distribution to the cyl-
inders and results in lower emission levels and shorter warm-up
periods.
g. Heated Air Intake - heated air intake or a modulated
air cleaner system uses exhaust gases to warm the intake air to
the carburetor. This improves engine warm-up time and reduces
emissions by allowing leaner carburetor calibrations.
h. Exhaust Gas Recirculation _(EGR^ - EGR primarily used
for NOx control, can also be beneficial with regards to HC con-
trol. Besides its overall leaning effect on the mixture, it also
permits recombustion of a percentage of the exhaust gases. Sim-
ilarily, increased valve overlap works as a form of "internal
EGR."
The effectiveness of modifications and hardware of this type
has been demonstrated in the light-duty vehicle and light-duty
truck fleets for several years. These control strategies should
be available for the 1984 model year HDG engines and should pro-
vide substantial HC and CO reductions over current levels.
8. Tradeoffs
The emission control strategies discussed above have trade-
offs with respect to fuel economy, power, and driveability. Lean-
er mixtures, less power enrichment, and quicker engine warm-up all
improve fuel economy, but when carried to excessive degree could
impair power and driveability. An increase in air injection would
also cause a small fuel economy loss. EPA now believes that the
fuel economy impacts of these regulations will be basically neu-
tral. The limits to emission reduction will be determined equally
by power requirements and driveability needs in addition to any
fuel economy concerns.
D. Attainable Reductions/Proposed Emission Standards
As described above, several relatively simple and effective
means of emission control are available. At this time, EPA has
limited data as to the absolute effectiveness of a given technique
on heavy-duty gasoline engines. For example, no testing has been
performed to date on a current engine where mixtures were leaned
out, spark timing curves optimized, power enrichment limited, and
fast warm-ups or fast opening chokes were initiated. It is dif-
ficult to quantitatively predict attainable emission reductions
without results of such testing.
-------
One approach to deriving achievable standards would be to use
an engineering 'estimate of the efficiencies of the previously des-
cribed reduction techniques. -These efficiency estimates could
then be applied to the current baseline emissions data to calcu-
late what emission levels could be reached. Lacking any other
substantive data or technique at 'this time this methodology will
be used.
The emission reduction efficiencies used in this analysis are
those expected from the lower emitting engines in the current
technology baseline (see Tables II-2 and II-3) so the average HC
and CO emission rates from the low emitting engines will serve as •
the baseline levels. One might question the use of the lower
emission levels as not being representative of the average emis-
sion levels. However for the higher emitting engines the effic-
iency estimates would in turn be substantially larger. We have
chosen to use the lower emitting engines because they already re-
flect what could easily be achieved on other current technology
engines with even minor calibration changes.
Tables II-2 and II-3 clearly indicate that the HC and CO
emission levels in certain modes are so large that they require
specific attention in this analysis. HC emissions could be di-
vided into "cold/warm start" and "other." CO emissions could be
divided into "LAP" and "other." Table II-6 lists the emission, re-
duction techniques together with the modes in which they will be
effective in. gaining emission reductions. This information will
serve as a background for the discussion which follows.
1. Hydrpearbons [3]
As shown in Table II-2 cold/warm start emissions account for
49 percent of the HC emissions. Thus, the remaining 51 percent
comes from the "other" six portions of the test. In terms of the
average of the low emitting engines from Table Il-fi the "cold/warm
start" portions account for 0.92 g/BHP-hr and the/"other" portions
account for 0.96 g/BHP-hr. ;
With the emission control strategies shown in Table II-6 we
believe that substantial reductions in HC emission levels are
easily achievable. Our current belief is that reductions of 50-60
percent are possible in the "cold/warm start" portions of the test
through the means shown in Table II-6. For all practical purposes
"start" emissions are uncontrolled on the current test procedure.
EPA also believes that reductions of 30-40 percent are also avail-
able on the other portions of the test procedure. Assuming the
ranges of engineering estimates of reduction efficiencies . given
above, achievable emission levels can be calculated.
a. Cold/Warm Start Reductions
High Estimate: (0.92 g/BHP-hr)(60%) = 0.55 g/BHP-hr
-------
Table II-6
Test Port^ons/Emij^ion Reduc^^on Technologies
KG CO
Cold/Warm Start[1] Other[2] LAF[3] Other[4]
Carburetion X XXX
Calibrations X XXX
Manifold/Combustion X XXX
Chamber
Air Injection X ' X X
Automatic Choke X X
EFE X X
Heated Air Intake X X
EGR X
Sample Bags 1 & 5
12] Sample Bags 2, 3, 4, 6, 7, 8
[3j Sample Bags 3 & Xt 7
[4] Sample Bags 1, 2, 4, 5, 6, 8
27
-------
Low Estimate: (0.92 g/BHP-hr)(50%) = 0.46 g/BHP-hr
New.Range: 0.37 - 0.46 g/BHP-hr
b. Reductions in Other Portions
High Estimate: (0.96 g/BhP-hr)(40%) = 0.38 g/BHP-hr
Low Estimate: (0.96 g/BHP-hr)(30%) = 0.29 g/BHP-hr
New Range: 0.58 - 0.67 g/BHP-hr
c. Achievable Emission Levels
Using "High Estimate": 1.88 - 0.55 - 0.38 = 0.95 g/BHP-hr
Using "Low Estimate": 1.88 - 0.46 - 0.29 = 1.13 g/BHP-hr
Emission levels in the 0.95 - 1.13 g/BHP-hr range would support an
HC emission standard of 1.3 g/BHP-hr.
Using a full life multiplicative deterioration factor of 1.2
and an HC variability of 10 percent, the expected target HC levels
are 1.1 g/BHP-hr for 1984 (no SEA) and 1.0 g/BHP-hr when SEA be-
gins in 1986. The range of achievable emission levels shown above
supports the feasibility of these targets and thus the 1.3 g/BHP-
hr standard.
2. Carbon Monoxide
As shown in Table II-3 the "LAF" (LA Freeway) CO emissions
account for 43.2 percent of the total. Thus the remaining 56.8
percent arises from the "other" portions of the test. When these
percentages are applied to the average low CO engines of Table
11-3, the "LAF" accounts for 19.9 g/BHP-hr and the other portion
accounts for 26.2 g/BHP-hr.
With the emission control strategies shown in Table II-6 sub-
stantial reductions in CO emission levels are easily achievable.
Reductions of 40-50 percent are possible in the "LAF" portion of
the test through the means in Table II-6. Emissions under the
high-speed, high-power operation characteristic of the LAF portion
are relatively uncontrolled because of the limited power demands
of the 9-mode test procedure. Reductions of 30-40 percent are al-
so possible from the "other" portions of the test procedure.
Given the engineering estimates of reduction efficiencies shown
above, achievable emission levels can be calculated.
a. LAF Reductions
High Estimate: (19.9 g/BHP-hr)(50%) = 10 g/BHP-hr
28
-------
Low Estimate: (19.9 g/BHP-hr) (40%) = 8 g/BHP-hr
New Range: 9.9 - 11.9 g/BHP-hr
b. Reeducations in Other^ Porti-ons^
High Estimate: (26.2 g/BHP-hr)(40%) = 10.5 g/BHP-hr
Low Estimate: (26.2 g/BHP-hr)(30%) = 7.9 g/BHP-hr
New Range: 15.7 - 18.3 g/BHP-hr
c . Achievable Emission Levels
Using "High Estimate": 46.1 - 10 - 10.5 = 25.6 g/BHP-hr
Using "Low Estimate": 46.1 - 8 - 7.9 = 30.2 g/BHP-hr
Emission levels in the 25.6 - 30.2 g/BHP-hr range would support a
CO emission standard of about 35 g/BHP-hr. Using a full life mul-
tiplicative deterioration factor of 1.1 and a CO variability of 20
percent, the expected target CO levels are 31.8 g/BHP-hr for 1984
(no SEA) and 25.5 g/BHP-hr when SEA begins in 1986. The range of
achievable emission levels shown above supports the feasibility of
these targets and thus the 35 g/BHP-hr standard proposed here.
Considering all of the factors bearing on this analysis
(cost, fuel economy, leadtime, power, and driveability), EPA be-
lieves that the standards herein discussed are achievable for all
HDG engines for the 1984 model year. However if during the com-
ment period further data and information would prove the standards
to be infeasible the option for further relaxation for final rule-
making exists..
E. Idle Emission Standard
For heavy-duty gasoline engines, the 1984 idle CO standard is
0.47 percent (raw exhaust composition). Table II-7 presents the
current technology idle CO baseline. Note that five of twelve en-
gines already comply. Given the fact that substantial leaning of
mixtures will be performed to meet the transient standards, there
is no reason to believe the idle circuits of the remaining engines
cannot be improved. EPA judges compliance with the idle standard
to be relatively straightforward and will pose no problems to
manufacturers even considering any small deterioration factor
which may need to be included.
-------
Table II-7
Idle CO Current Technology Baseline _EmiLssions
Complies with
Engine Idle CO (•%) 1984 standard?
IHC 446 .299 yes
1HC 345 .402 yes
GM 366 .913 no
GH 350 1.158 no
Ford 400 . 1.853 no
Ford 370 .515 . no
Chrysler 360 .226 yes
Chysler 440 1.279 no
GM 454 .596 no
GM 292 .308 yes
GM 454 . .888 no
GM 350 .242 ' yes
-------
Ref^ejre rices
1. Cox, Timothy P., "Heavy-Duty Gasoline Engine Emission
Sensitivity to Variations in the 1984 Federal Test Cycle," SAE No.
801370.
2. Auiler, J., et. al., "Optimization of Automotive Engine
Calibration for Better Fuel Economy-Methods and Applications,"
SAE Paper No. 770076.
3. Here we are addressing total hydrocarbon emissions and
a total hydrocarbon emission standard. EPA intends to propose an
optional non-methane hydrocarbon standard for HDEs in a future
rulemaking.
4. The terms "High Estimate" and "Low Estimate" refer to
the range of reduction efficiencies. The percent figures shown
are the actual efficiencies.
31
-------
CHAPTER III
ENVIRONMENTAL IMPACT
A. I n t r o d u c t i o n
The ly84 light-duty truck (LOT) and heavy-duty engine (HDE)
final rulemakings (FRM) as promulgated were expected to provide
significant lifetime per vehicle emission reductions and improve
overall air quality. This analysis will examine the impact of the
proposed revisions and relaxations of the 1984 FRMs, with the goal
of determining the loss in lifetime emission reductions and air
quality improvement which could occur if they are adopted.
The base case for our emission reduction and air quality
analysis is the 1984 final regulations. In the base case we will
determine the per vehicle emission rates and air quality improve-
ments which would be expected. In the comparison case we will in-
corporate the proposed revisions and relaxations to determine
their impact on both the per vehicle emission rates and overall
air quality.
It should be noted that this analysis will not include a
major review of the health and welfare aspects of HC (ozone) and
CO, nor will it include a major discussion of the national HC and
CO emission inventories. These reviews can be found in other doc-
uments, and are beyond the needs of this analysis.[1][2]
B. Changes in the Per Vehicle Emission Rates
1. Introduction
Perhaps the figure which best expresses the potential envi-
ronmental impact of a proposed regulatory action is the change in
the per vehicle emission rate and lifetime emissions which the ac-
tion would bring about. In this section of the analysis we will
examine the changes in the .per vehicle emission rates to determine
the loss in HC and CO reductions which would occur under the pro-
posed revisions and relaxations.
Before beginning this analysis a few additional explanatory
remarks are necessary. Lifetime per vehicle emission rates are
determined using calculated target emission levels. In turn,
these target emission levels are calculated using the expected
deterioration factor and production line variability. The deter-
ioration factors and variabilities used are the anticipated
industry-wide averages. For any one manufacturer the deter-
ioration factor and/or the variability could be significantly dif-
ferent, such that the target emission levels and per vehicle emis-
sion rates could also differ. Our analysis is intended only to
reflect the expected average deterioration factors and variability
and thus cannot be assumed to implicitly apply to a given engine
family.[6]
-------
Secondly, .as was discussed previously, this action proposes
several relaxations to the LDT and HDE SEA programs. These in-
clude implementation of a 40 percent AQL for ,LDTs and HDEs begin-
ning in 1984.. Also, the HDE SEA program will : be delayed from 1984
to 1986.
As part of this action, EPA is announcing a 2-year deferral
period (the 1984 and 1985 model years-) for HDE SEA. Since no SEA
program will be in place until 1986, manufacturers certifying in
1984 and 1985 will have to account only for the deterioration fac-
tor in computing their target emission levels. However, we expect
that the manufacturers will begin planning for the impact of SEA
before 1986, specifically during 1984 model year certification,
and thus will design the engine and emission control systems with
the 1986 SEA requirements (40 percent AQL) in mind.
Therefore, we expect that to some degree the 1984 and 1985
model year HDE emission rates will reflect the impact of the SEA
requirements. In our previous analyses we anticipated the manu-
facturers' reactions to SEA would include self-audit testing, in-
creased quality control, and in some cases additional engine mod-
ifications and hardware. Although we do not expect the self-audit
testing and increased quality control to begin until necessary,
the additional modifications and hardware will probably be used
when possible beginning in 1984. Therefore, we expect that 1984
and 1985 model year HDEs will have per vehicle emission rates
slightly lower than if they accounted only for deterioration, but
greater than in 1986 when the SEA requirements must be met. Our
air quality analyses of the emission rates of 1984-85 heavy-duty
vehicles will not inherently include this impact, so the per ve-
hicle emission rate increases shown for 1984 and 1985 HDEs may be
slightly higher than that which will actually occur.
2. Hydrocarbons
The proposed relaxation to the SEA provisions will affect the
HC emission rates of both LDTs and HDEs. For LDTs the relaxation
of the AQL is; the only factor to be considered, but for HDE's both
the relaxation of the AQL and the deferral of SEA will have an im-
pact.
a. Light-Duty Trucks
As described in the regulatory analysis supporting the 1984
FRM, the 10 percent AQL caused the HC target emission level to
drop from 0.53 g/mile to 0.49 g/mile. Relaxation of the AQL back
to the 40 percent level would increase the target to 0.53 g/mile.
Over the LDT lifetime this means an increase of about 0.006 tons
(12 pounds) in additional HC emissions.[3]
b. HDG Engines
-------
Both the deferral of the HDE SEA program and the relaxation
of the AQL would affect HDG engine emission rates. In 1984-85 the
engines will not be subject to any SEA, so the only factor manu-
facturers would have to account for is the expected deter-
ioration. In the 1986-88 period manufacturers would have to ac-
count for both deterioration and SEA at a 40 percent AQL.
The changes from catalyst to non-catalyst control technology
and the resultant decrease in the deterioration factor will also
cause an increase in the total lifetime HC emissions. This will
begin in 1984 and continue through the period.•
(1) 1984-1985 Model Years
In the 1984 and 1985 model years manufacturers will have to
deal only with deterioration. Based on a non-catalyst control
strategy, a full life multiplicative deterioration factor of 1.2
is consistent with past analyses.[4] This would give a target
emission level of about 1.1 g/BHP-hr.
Assuming a brake specific fuel consumption of 0.7 and a fuel
economy of 5 miles/gallon these emission levels are 1.9 g/mile for
the target level and yield a deterioration factor of .031 g/mile/
10,000 miles.
(2) 1986 and Later Model Years
The only change in the 1986 and later model years is that
manufacturers will have to deal with SEA at a 40 percent AQL. The
impact of this is to slightly lower the target emission level.
Using an HC variability of 10 percent, the new target level be-
comes 0.97 g/BHP-hr. In terms of g/mile this figure is 1.69
g/mile.[4]
We do not expect the implementation of the SEA program in
1986 will cause any new hardware or engine modifications. There-
fore, the deterioration rate should be the same as that of the
1984-85 model years.
Table III-A compares the emission rates of the 1984-85 and
1986 and later model year HDG engines (non-catalyst) to the emis-
sion rates expected from the original 1984 final rulemaking. The
per vehicle lifetime increases in the 1984 and 1985 model years
shown are probably larger than will occur because some manufac-
turers will opt to comply with the R&D/hardware needs of SEA and
the 40 percent AQL beginning in 1984, to avoid replicate efforts
in 1986.
c. Heavy-Duty Diesel Engines
(1) 1984-1985 Model Years
-------
In the 1984-85 model years no SEA program will be in effect,
so the manufacturers would have to account for only deterioration
over the. lifetime. Based on past analysis this factor is 1.05
(multiplicative) for a target level of about 1.24 g/BHP-hr.[4]
Assuming a brake specific fuel consumption of 0.43 and a fuel
economy of 5.8 miles/gallon these figures become 3.53 g/mile for
the target level and .007 g/mile/10,000 miles for the deteriora-
tion factor.[4]
(2 ) 1986 and La ter Model Years
In the 1986 and later model years, the manufacturers will
have to deal with SEA at a 40 percent AQL as well as lifetime
deterioration. The major impact of the SEA program is to slight-
ly lower the target emission levels, but since no major hardware
related changes are expected, the deterioration factor should re-
main unchanged. Using an HC variability of 16 percent the new
target emission level for HC is 1.05 g/BHP-hr or about 3.00
g/mile.[4j The deterioration rate will remain unchanged.
The data shown in Table III-B compares .the lifetime emission
rates for the three cases being considered in the heavy-duty die-
sel engine analysis. As before with the HDG engines, EPA does not
expect that the actual increase in the per engine HC lifetime
emissions will be as large as shown for the 1984-85 model year HDD
engines. We expect that most manufacturers will design their en-
gines for 1984 certification to be consistent with the demands of
the 1986 and later model year SEA program.
d. Summary and Discussion
Especially for LDTs and HDG engines, the long term increases
in lifetime HC emissions as a result of the proposed action are
not large. The HDD engine HC emission rates are higher than the
others because of the higher variability, lower deterioration fac-
tor, and longer average lifetime. Clearly, the expected increase
in HC emissions from these vehicles will result in less of an
ozone air quality improvement than was expected in the original
1984 final rulemakings. However, it is our inital judgment that
the expected losses are not adequate to warrant a complete ozone
air quality impact analysis for this proposal. Depending upon ad-
ditional information uncovered in the formal public comment period
the ozone air quality analysis may be included in the final rule-
making analysis.
3. Carbon Monoxide
All aspects of the proposed relaxations and revisions will
affect the CO emission rates from LDTs and HDG engines. The pro-
posed relaxations to the AQL will effect both LDTs and HDG en-
-------
Table III-B
HDD Jfogin_e H(^ Emi s sion Ra^tes
Lifetime
Low Mileage[1] Deterioration Factor[2 ] Emissions Increase
g/BHP-hr g/mile g/BHP-hr g/mile/10,000 mi Tons[3] Tons
1984 FRM 0.89 2.53 1.05 .007 1.368
(SEA at 10% AQL)
1984-83 1.24 3.53 1.05 .007 1.891 .523
(No SEA)
1986+ 1.05 . 3.00 1.05 .007 1.614 .246
(SEA at 40% AQL)
[Ij Target level.
[2j Multiplicative; 250,000 miles to rebuild.
[3J 475,000 miles.
-------
gines. The two year deferral of the HDE SEA program and the pro-
posal to relax the HDE CO emission standard emission rates to
non-catalyst levels will also effect HDG engines.
As is generally known, CO emission levels from diesel engines
are well below even the statutory HDE emission standards, so the
proposed relaxations and revisions will have no impact. Therefore
no further analysis of HDD CO emissions will be included.
a. Light-Duty Trucks
The major impact on the LDT CO emission rates is caused by
the relaxation of the AQL. As was described in the regulatory
analysis supporting the 1984 LDT final rulemaking the expected CO
target level would rise from 5.5 g/mile to 6.4 g/mile if the AQL
were relaxed from 10 percent to 40 percent. Assuming the same
basic control technology with either AQL, the per LDT increase
amounts to 0.2 tons of CO.[3]
b. HDG _Eng_ine_s_
HDG engines are affected by all three of the proposed relax-
ations and revisions. HDG engine emission rates will be affected
by the proposed revision to the CO emission standard and the smal-
ler deterioration factor associated with non-catalyst control
technology. In addition, the deferral of the HDE SEA program and
the relaxation of the AQL will also cause increased emission
rates. These will be addressed below for the appropriate years.
(1) 1984-1985 Model Years
With no SEA program in effect for these years, the manufac-
turers will only have to deal with the emission standards and
deterioration. HDG CO lifetime emission rate increases will be
large because the proposed standard is more than twice the stat-
utory level and the non-catalyst deterioration factor is substan-
tially less than the catalyst based factor.
Based on data gathered for the 1984 FRM analysis, the target
level for a 35 g/BHP-hr CO standard is 31.8 g/BHP-hr. .This as-
sumes a multiplicative full life deterioration factor of 1.1.[4]
In g/mile these figures are 55.42 for the target level and .418
g/mile/10,000 miles for the deterioration factor.
(2) 1986 and Later Model Years
In 1986, manufacturers will also have to consider the impact
of SEA at a 40 percent AQL. Since we would expect no fundamental
hardware changes, the deterioration factor would change little.
Therefore, the major impact would be a lower target emission
level. Using a CO variability of 20 percent, the new target emis-
sion level is 25.1 g/BHP-hr or about 43.81 g/mile.
-------
Table 1II-C compares the emission rates of the 1984-85 and
and later model year HDG engines (non-catalyst) to the rates
expected from the original 1984 final rulemaking (catalyst-
based). As before with HC, the per vehicle lifetime emission rate
increase shown for 1984-85 are likely larger than will occur. We
expect that in as much as is possible manufacturers will produce
their engines to comply with the SEA requirements beginning in
1984, so that the 1986-88 emission rate could be a more represen-
tative rate.
c. Summary and Discussion
Even though the proposed relaxations and revisions affect
only 2 of the 3 vehicle/engine groups, the absolute magnitude of
the increases in lifetime CO emission rates is substantially
larger for CO than for HC. This is especially true for HDG engine
CO. Therefore, we have included a formal CO air quality analysis
to measure the loss in the air quality improvements which could
occur if the proposed relaxations and revisions are implemented.
C. Ambient Air Quality Impact: Carbon Monoxide
1. Introduction
This section will address the CO air quality improvement
losses which could occur if the proposed relaxations and revisions
are adopted. The basic approach used here will be similar to that
used for the emission rates, in that the focus will be on the
losses in air quality improvements and not on absolute air quality
levels.
A CO air quality analysis was conducted using the Modified
Rollback method. Separate analyses were conducted for both low
and high altitude regions. The low altitude analysis covered 102
counties and the high altitude analysis covered 17 counties.[2]
In preparing the air quality projections, baseline emission rates
for various ssource categories were taken from the National Emis-
sions Data System (NEDS) and projections for future control stra-
tegies plus growth ratios were made. In combination with the
mobile source projections, the data allowed an evaluation of the
air quality losses to be expected.
2. Scenarios Analyzed ;
In total six scenarios have been analyzed, four low altitude
and two high altitude.[2] As shown in Table III-D, scenarios 1-4
are low altitude, 5 and 6 are high altitude. All scenarios in-
clude I/M for all LDVs and LDTs beginning in 1982.
Scenario 1 is the base case and represents the 1984 LOT and
HDE final rulemakings as promulgated. Scenario 2 is the prime
comparison case, as it incorporates the proposed relaxations in
the SEA programs and the revisions of the HDE CO emission standard.
-------
Table III-C
HDG Engine. C0 Emi_s_s^ion Rates
Lifetime
Low Mileage[1] Deterioration Factor[2] Emissions^ Increase
g/BhP-hr g/mile g/BHP-hr g/mile/10,000 mi Tons[3] Tons
1984 FRM 5.9 10.30 1.7 0.63 1.74
(catalyst)[4]
1984-8515] 31.8 55.42 1.1 0.418 7.26 5.52
(non-catalyst)
1986+ [6] 25.1 43.81 1.1 0.418 5.80 4.06
(non-catalyst)
[1] Target level,
[2] Full life - multiplicative,
[3j 114,000 miles;.
[4] SEA at a 10% AQL.
[5j No SEA.
[6j SEA at a 40% AQL.
-------
Scenario
1
2
3
4
5
6
Table II1-D
Air Quality Analysis Scenarios[1][2]
LDV
LDT
HDGE
CO Std/Life/S£A(AQL) C6~Std/LiTe/SEA(AQL) CO Std/Life/SEA(AQL)
3.A/ 1/2/40% -10/ 1 /10% 15.5/ 1 /10%
10/ 1 /40%
10/ 1 /10%
10/ 1 /40%
14/ 1 /10%
14/ 1 /40%
3.4/ 1/2/40%
7.0/ 1/2/40%
7.0/ 1/2/40%
prop./ 1/2/40%
prop./ 1/2/40%
35/1 /none: 40%
15.5/ 1 /10%
35 /I /none: 40%
15.5/ 1 /10%
35/1 /none: 40%
[1] All scenarios include I/M for all LDVs and LDTs.
[2j For more detail on each scenario referenced.
-------
Scenarios.3 and 4 are identical to 1 and 2 respectively, ex-
cept that both> 3 and 4 set the LDV CO emission standard at 7.0
g/raile instead of 3.4. This was done to gauge the sensitivity of
the air quality impact of the proposed changes to possible changes
in the level of the LDV CO emission standard.
Scenarios 5 and 6 apply to high altitude regions, and accom-
plish the same fundamental analysis at high altitude as scenarios
1 and 2 at low altitude. The LDV and LOT emission rates reflect
proportional CO standards at high altitude.
3. Results and Discussion ;
a. Average Percent Change in CO Air Quality
Table I1I-E presents the air quality improvement data for the
102 low altitude and 17 high altitude counties analyzed. Even
though the scenario by scenario results alone present some inter-
esting and useful information, the real impact of the proposed re-
visions and relaxations is found by comparing the results for the
different scenarios.
All three comparisons (scenario 1 vs. 2, 3 vs. 4 and 5 vs. 6)
show the same general trends. The proposed relaxations and revis-
ions would cause a 1-3 percent loss in the overall air quality
improvements which would occur with the base case. All of the
scenarios also show hints of air quality degradation beginning by
the year 2000. So at either low or high altitude, the average CO
air quality improvement is 1-3 percent less than would occur with
the base case.
b. Counties Above the Ambient Air CO Standard
Table III-F shows the data relative to the number of counties
projected to be above the standard. In this case, the impact of
the proposed changes is small. For both the low and high altitude
counties, all are in compliance by 1995. At low altitude the pro-
posed relaxations and revisions do seem to cause a delay in sev-
eral counties achieving the CO ambient air quality standard. At
high altitude there is no apparent impact.
c. Tot:ajl^ Number of Exceedance s^
The exceedances data in Table I1I-G basically shows the same
impact as the violations data of the previous table. Simply
stated, the proposed relaxations and revisions will allow several
more exceedances per year at low altitude during the 1985-1990
time period. At high altitude there is only a small impact for
the years studied. After 1995, no exceedances were computed at
low or high altitude.
4. Conclusions
-------
Table III-E
Average Percent.Change in CO Air
Low Altitude
Scenario
1
2
3
4
5
6
1985
-58
-58
0%
-58
-57 .
1%
-59
-58
1%
1988
-70
-68
2%
-68
-67
1%
High
-72
-70
2%
1990
-73
-71
2%
-72
-70
2%
Altitude
-77
-75
2%
1995
-77
-75
'. -74
-72
; 2%
-81
-79
2%
• 200°
-77
-74
3%
-74
-72
2%
-82
-80
2%
3% improvement
foregone
-------
Table III-F
Counties Exceeding the CO NAAQS
Low Altitude
Scenario
1
2
3
4
5
6
1985
6
6
0
6
6
0
2
2
0
1988
1
2
1
1
2
1
High
0
0
0
1990
0
0
0
0
1
1
Altitude
0
0
0
1995
0
0
0
0
0
0
0
o
cf
2000
0
0
0 violating
counties
0
0
0
0
o
0"
-------
Table III-G
Total Number of Exceedances
Low Altitude
Scenario
1
2
3
4
5
6
1985
25
31
6
28
32 .
4
' 4
5
1
1988
1
2
I
2
4
2
High
0
0
0
1990
0
0
0
0
1
I
Altitude
o.
0
0
1995
0
0
0
0
0
0
0
0
o"
2000
0
o
cf ,
(
0
0
0
0
0
0
exceedances
-------
A cursory review of the data shown in Table III-E, F, and G
would lead to -the conclusion that the proposed relaxations and
revisions would have a small negative impact in the mid and late
eighties, but none thereafter. This is essentially correct if the
accuracy of all of the assumptions and data that went into the
modified rollback could be guaranteed. Given that there are a
significant number of parameters needed by the model which must be
estimated by the user, it would be unwise to conclude that the re-
sults of the model are precisely accurate. However, the model
predicts trends quite well. For example, in Table III-F the num-
ber of counties exceeding the NAAQS could easily be off by one or
more in any year in the mid to late eighties. However it would be
correct to .say that the analysis clearly shows that the potential
negative impact is likely very small.
One other extremely important judgment that went into this
analysis should be highlighted. This analysis assumed that I/M
would be implemented where required, beginning in 1982, for all
LDVs and LDTs. If the I/M programs were delayed or scaled down in
geographical area or scope, the air quality analysis would likely
reflect less total improvement with time, as well as more exceed-
ances and more counties above the standard. The impact of .the
proposed relaxations and revisions would then probably be somewhat
larger. However, we expect that the overall impact of this pro-
posal would remain small, but would probably be noticeable into
the 1990's.
D. Other Environmental Impacts
1. Lead
The relaxation back to non-catalyst technology will also
cause the loss of the expected reductions in tailpipe lead emis-
sions from HDG vehicles. Assuming a lead content of 1.1 grams per
gallon in leaded fuel and a tailpipe out emission rate of 80 per-
cent, the benefit foregone amounts to approximately 22.3 Ibs. per
HDG vehicle over its lifetime.[5] This calculation assumes an
average HDG vehicle lifetime of 114,000 miles and an average
class-wide fuel economy of 9.9 miles/gallon.[4]
2. Sulfuric Acid
With the implementation of catalytic converter technology on
HDG engines, EPA expected a slight increase in the per HDG vehicle
sulfuric acid emission levels. With the move back to non-catalyst
technology this slight increase will no longer occur.
3. Misfueling
Since 1975 and 1976 respectively, most LDVs and LDTs have re-
quired the use of unleaded fuel. Given an average lifetime of 10
years for LDVs and 12 years for LDTs, EPA expects a substantial
-------
decrease in the demand for leaded fuel by 1984. We expected this
demand would be even less as a result of the new requirement for
unleaded fuel use in HDG engines. At some point in the mid-to-
late eighties demand for leaded fuel would have dropped to the
point that its production and distribution might have become cost
•prohibitive for some companies. A decrease in the available sup-
ply of leaded fuel would have led to a decrease in the misfueling
rate.
This move back to non-catalyst technology for 1984-1986 model
year HDG engines could extend by several years the general avail-
ability of leaded fuel in the marketplace. Unfortunately, as a
result the opportunity for misfueling would also be extended.
-------
References
1. . For a current review of this data, as well as citations
to other reports on health effects of HC and CO, see "Health Ef-
fects of Exposure to Low Levels of Regulated Air Pollutants - A
Critical Review," Benjamin A. Ferris, Jr., M.D., Journal of the
Air Pollution Control Association•, Vol. 28, no. 5, May 1978.
2. Air Quality Analysis for the Revised Gaseous Emission
Regulations for 1984 and Later Model Year Light-Duty Trucks and
Heavy-Duty Engines, September 1981.
3. "Regulatory Analysis and Environmental Impact of Final
Emission Regulations for 1984 and Later Model Year Light-Duty
Trucks," U.S. EPA, CMSAPC, May 1980..
4. "Regulatory Analysis and Environmental Impact of Final
Emission Regulations for 1984 and Later Model Year Heavy-Duty En-
gines, U.S..EPA," CMSAPC, December 1979.
5. The average lead content of leaded regular gasoline was
obtained from Robert Summmerhayes of EPA/FOSD, May 15, 1981.
6. This portion of the analysis uses certification-based
deterioration factor estimates, not in-use deterioration estimates
such as are used in MOBILE II emission factors.
-------
CHAPTER IV
ECONOMIC IMPACT
A. Introd uct i on
This chapter will examine the cost impacts of the proposed
changes to the 1984 LDT and HDE final ruleinakings previously
detailed in Chapter I. Rather than reexamining in detail the
entire cost analyses of both final rulemakings, this analysis will
evaluate only the cost impacts of the proposed changes. Of
necessity, much data from the previous analysis will be used to
develop the incremental cost savings.[1][2]
The areas to be evaluated are: the revised HDE CO emission
standard, relaxation of the AQL for LDT and HDE SEA, and the two
year delay of the implementation of SEA requirements for HDEs.
This analysis is divided into two main sections. In the
first section we will examine the cost implications of the pro-
posed revisions to identify and quantify the cash expenditure
savings and cash flow savings associated with each action. Cash
expenditure savings simply means that the need to spend that sum
will be eliminated; cash flow savings means that the need to spend
these funds will be deferred. After these savings have been iden-
tified and quantified in each category, they will be summarized
for each vehicle/engine grouping being considered.
In the second section we will identify in aggregate terms 1)
the net cash expenditure savings, 2) the net cash flow savings and
3) the net impact on both the first, price increase and the operat-
ing costs.
All cost figures used in this analysis are expressed in 1981
dollars unless otherwise noted. Costs carried over from the 1984
HDE final rulemaking (developed mid-late 1979) and the 1984 LDT
final rulemaking (developed early-mid 1980) will be inflated at 8
percent per annum. [3J The LDT and HDE sales projections used in
the 1984 final rulemakings will also be used in this analysis so
that valid per vehicle/engine cost comparisons can be made to
gauge the incremental impact of the proposed revisions (Table
IV-A). These projections reflect the significant increase in the
use of diesel engines which is expected in both LDTs and HDEs.
B. Cost Implications of the Proposed Revisions
1. Revision of the HDE Gaseous Emission Standards
a. Introduction
As has been described previously, the major thrust behind the
revisions to these rulemakings has been to provide short-term
economic relief to the automotive and related industries. Toward
-------
Table IV-A
LPT Sales Projections (millions) [1]
1984
1985
1986
1987
1988
1984
1985
1986
1987
1988
0-10,000
GVW
3.97
4.25
4.42
4.53 •
4.81
All States
0-8,500 Domestic
GVW LOT
3.45 2.69
3.70 2.82
3.85 2.84
3.99 2.83
4.18 2.81
Import/
Captive
LDT
0.43
0.46
0.48
0.50
0.52
49 States (Excludes California)
0-8,500
GVW
3.13
3.35
3.49
3.61
3.79.
I7.37r
Import/
Domestic Captive
LOT LDT
2.50 0.32
2.62 0.34
2.64 0.36
2.63 0.37
2.61 0.39
13.00 1.78
Heavy-Duty Engine Sales
1984-1988
Gasoline-
Year . Fueled
1984 366,991
1985 360,888
1986 354,287
1987 347,171
1988 339,547
LDDT
0.31
0.39
0.49
0.61
. 0.79
2TT9"
[2]
Diesel
266,161
284,255
302,854
321,966
341,583
LDDT
0.33
0.42
0.53
0.66
0.85
Total
1,768,884
1,516,819
[Ij Regulatory Analysis and Environmental Impact of Final
Emission Regulations for 1984 and Later Model Year Light-Duty
Trucks, U.S. EPA, OMSAPC, May 1980, pp. 31-33.
[2j Regulatory Analysis and Environmental Impact of Final
Emission Regulations for 1984 and Later Model Year Heavy-Duty
Engines, U.S. EPA, CMSAPC, December 1979, pp. 39-46.
50
-------
that end, preliminary analyses indicated that much of the capital
investment and R&D costs related to the 1984 HDE FRM were tied
directly to the implementation of catalytic converter technology
on HDG engines. As a result the decision was made to propose a
revised CO emission standard beginning in the 1984 model year,
which could be achieved without the use of catalytic converter
technology.
The technological feasibility discussion in Chapter II sup-
ports the proposed emission standards for HC (1.3 g/BHP-hr) and CO
(35 g/BHP-hr) assuming compliance with the 40 percent AQL beginn-
ing in 1986. These proposed revisions represent no relaxation in
the HC standard but do represent a 125 percent increase in the CO
standard. Beicause the relaxation of the CO standard will not af-
fect the expected .compliance strategies for HDD engines, their
compliance costs will basically require no further analysis over
what was contained in the regulatory analysis supporting the 1984
final rulemaking. Therefore this analysis of the costs of com-
pliance with the proposed emission standards will be limited only
to HDG engines.
b. Reviewjpf the 1984 Final Rulemaking Costs
(1) Aggregate and Per Engine Costs
In late 1979 EPA promulgated final rules implementing new
emission standards and compliance requirements for 1984 and later
model year heavy-duty engines. In support of this final rule, EPA
developed an economic analysis to determine the aggregate cost and
first price impact.
To determine the potential economic savings associated with
the proposed revisions it is necessary to review the final cost
estimates calculated in the past economic analysis. The figures
shown in Table IV-B give both the per engine and aggregate cost
estimates for the HDG engine portion of the analysis. The figures
are given in both 1979 and 1981 dollars and are discounted to
January 1984. These figures will be used later in this analysis
to determine the potential savings of the proposed revisions to
the HDE emission standards and regulations.
(2) Capital Cost Estimate for the 1984 Final Rule: HDG
Engines
At the time when the economic analysis supporting the 1984
final rule was conducted (mid-late 1979) the heavy-duty engine in-
dustry had just ended a year of record sales (1978). With one ex-
ception, there was little question that.the heavy-duty engine in-
dustry would be able to finance the required investment. As a re-
sult, less attention was given to determining the capital cost re-
quirements of the final regulations than might otherwise have
been under less favorable economic conditions.
SI
-------
The aggregate cost figures given in Table IV-B do include
some capital co'st estimates, as some of these investments would be
required . before production begins. These include certification
facilities, research and development, SEA facilities, and certifi-
cation testing. The area which did not receive explicit attention
is the tooling costs associated with the manufacturing of the
emission control hardware. Although these costs were stated in an
amortized manner as part of the manufacturing, cost, they were not
stated explicitly as capital investment costs. Identification of
these costs now is important, as they represent a major portion of
the potential savings associated with the proposal to revise the
HDE CO emission standard. Our initial estimate of the tooling
capital costs associated with the 1984 HDG final rule as
promulgated is shown in Table IV-C,[4] For future reference, the
R&D capital costs of the 1984 final rule are also included in
Table'IV-C.
Having now reviewed the 1984 final rule costs for HDG engines
and laid the proper background in relation to capital costs, we
can proceed with the analysis of the cost implications of the pro-
posed changes.
c. Non-catalyst Technology Compliance Costs
The technological feasibility discussion of Chapter II out-
lined the emission control techniques and strategies which are
most likely for HDG engines. Costs for achieving compliance with
the proposed emission standards would lie in three main .areas:
pre-production R&D, engine and component modifications, and new
emission control hardware.
(1) Pre-production R&D Costs
Phase I of each manufacturer's pre-production R&D program
would most likely be a complete characterization of the emission
characteristics of each family on the transient and idle tests.
This would include emissions characteristics at different cali-
brations as well as initial optimization of the engine's emissions
performance prior to any modifications or additions. This would
be accomplished using steady-state mapping techniques as well as
hot start and cold start tests. A more limited number of idle
tests would also be necessary. Given this test information, the
manufacturers would have the information necessary to make deci-
sions as to which modifications and emission control components
will be necessary to reach the target emission levels. Consi-
dering the leadtime plans submitted by the manufacturers in their
comments to the 1979 HDE proposal, we expect that some manu-
facturers have, already completed this phase.
With this initial data Phase II of the R&D program would be
the development and application of the emission control systems
and engine/component modifications. This task would fall on the
-------
Table IV-B
HDG Engine Compliance Costs: 1984 Final Rule [1]
3. SEA Facilities
4. Certificati
5. SEA Testing
6. SEA Self Au
7. Manufacturing
8. Quality
9. Overhea
TOTAL
Operating Costs
Unleaded Fuel [3]
Exhaust System and
Spark Plugs
Potential Fuel Savings [4]
ion Facilities
nd Development
ties
ion Testing
g
udits
ing
ntrol
nd Profit
Per
1979
£ 8.06
15.18
10.98
2.45
.81
5.06
253.00
10.00
88.61
Engine
1981 [2]
9.40
17.71
12.81
2.86
.94
5.90
295.10
11.66
103.35
Aggregat
1979
$11,918K
22,435K
16.228K
3.620K
1.196K
7.475K
373.924K
14,780K
130,957K
e
1981
$13,901K
•26.168K
18,928K
4,222K
1.395K
8,719K
436.145K
17,239K
152.748K
$394.15 $459.73
$582,533K &679,465K
$258.72 $258.72 $382,373K $382,373K
-$176.13 -$205.43 -$260,319K -$303,636K
$422.00 $540.00
[I] Regulatory Analysis and Environmental Impact of Final Emission
Regulations for 1984 and Later Model Year Heavy-Duty Engines, U.S. EPA,
aiSAPC, December 1979, pp. 133-34.
[2] Inflated at 8% per year for two years.
[3J Assumes 3 cent/gallon unleaded-leaded fuel price differential.
[4j Erroneously calculated in the original analysis.
53
-------
Table IV-C
HDG Emission Control Hardware Tooling Costs
1984 FRM (1981 Dollars) undiscounted [1]
Catalytic Converters . $ 7.0M
Larger Air Pumps 38.5M
Air Modulation System 1.6M
Chassis Heat Shields/ 1.5M
Stainless Steel Exhaust
Parameter Adjustment 2.2M
Deceleration Fuel Shut-off 6.5M
Engine Modifications ' 5Q._6M
Total $107.. 9M
R&D (Table IV-B, undiscounted) [2] 26.2M
Grand Total $13'4.1M
[1] See footnote 4 for more detail.
[2] Initially expected to be invested in 1981 and 1982.
5M
-------
four manufacturers of EDG engines and those companies which supply
the related components. Once the engine modifications have been
made and the necessary components added, the engines would have to
be recharacterized and reoptimized as was done in Phase I.
Costs for Phase I characterization and optimization can be
estimated by determining the number of transient tests necessary.
to adequately characterize an engine's emissions performance. A
liberal estimate of the level of effort required would be 40 tran-
sient tests per family. This would include two tests at each
calibration and a void rate of 10 percent. Each full emission
test (transient and idle) is estimated to cost $500, which yields
a total testing cost of about $20,000 per family. This methodo-
logy could overestimate the full cost because most manufacturers
would use hot starts and steady-state maps and would tend to keep
full transient tests to a minimum at this stage. As is shown in
Table IV-D when other fixed costs are included this cost becomes
$36K per family.
Costs for Phase II of the R&D process are more difficult to
estimate. This is primarily because this includes costs for
development of prototype emission control components and modifi-
cation of some other present features. Fortunately, virtually all
of the additions and modifications we anticipate will be employed
have been used in the LDV/LDT fleets for several years, and some
are already used in HDG engine families. As an initial estimate,
a figure of $15K per family will be used to estimate these com-
ponent and modification costs. Phase II will also require a re-
characterization and reoptimization after the modifications have
been made and the components added. This would add an additional
$20,000 per engine family bringing Phase II costs to $35K per
family, (Table IV-E).
Total Phase I and Phase II costs per family sum to $71K per
engine family and $1.136 million industry-wide. EPA anticipates
that this amount may overestimate the total cost impact of pre-
production R&D. This is due primarily to an anticipated decrease
in the number of HDG engine families over the next three years.
Preliminary 1982 certification data and informal conversations
with manufacturers indicate that the number of Federal HDG engine
families could drop from 16 to 11 or less by 1984 due to
decreasing market demand for HDG engines.
(2) Emission Control System
( a ) Modifications and Improvements
The emission-related modifications and improvements which
will be necessary to meet the 1984 emission standards will vary by
engine family primarily according to its emission
characteristics. The costs of control for each family will vary
according to the emission characteristics and the currently used
-------
Table IV-D
Pr e-Production R&D Testing Co^sts
Manufacturer
Chrysler
Ford
GM
1H
(a)
// Engine
Families [Ij
. 2
6
4
4
Phase 1
(b)
Fixed Costs
per Family [2]
$16K
$16K
$16K
$16K
(c)
Testing Costs
per Family
$2 OK
$20K
$20K
$20K
[Ij Based on 1981 Federal Certification Families.
[2j Engine: $2000, Break-in: $90.00, Engineering Overhead:
[3] 40 transient tests at $500 per test.
[4] (a) (b + c).
(d)
Phase 1
R&D Total [4]
$ 72K
$216K
$144K
$144K
$5000.
-------
Manufac_tur_er
Chrysler
Ford
GM
IH
Table IV-E
Pre-Production R&D Testing Costs
(a)
// Engine
Families
2
6
4
4
Phase II
(b) '
Fixed Costs
per Family [1]
jL_sr\.
$15K
4> J.3ix
j. _/r
-------
emission control hardware. Our analysis will assume that when
possible the manufacturers design and build their emission control
systems .to comply with the requirements of the 40 percent AQL
beginning in 1984, even though under the proposed revisions HDE
SEA would be delayed until 1986. This would allow the
manufacturers to avoid the replicate costs of repeated R&D,
retooling, arid recertification, and is thus the most efficient use
of resources.
EPA expects that the greatest emission reductions will be
gained in engine and component modifications. The cost of the
necessary modifications is difficult to estimate. Some are noth-
ing more than a recalibration, but others may require more ex-
tensive redesign and retooling.
The expected modifications are shown in Table IV-F. The
costs to implement new calibrations of spark timing, EGR, and A/F
ratio are negligible. Improvements to the air injection system
are primarily related to optimizing the diverter and pressure
relief valves to the demands of the transient test. The use of
air modulation would probably be beneficial.
Carburetion modifications present the largest potential im-
provements. The 'analysis in Chapter II described the need for the
improvements and recalibrations in general fuel metering, ac-
celerator pump operation, and power enrichment. In the long term
the price of the carburetor will probably remain relatively
unaffected, but manufacturers and vendors will have to recover
their costs for redesign and retooling. As an initial estimate, a
per engine cost of $10 is reasonable to amortize these costs over
a five-year production period. Using a 10 percent discount and
amortization rate beginning in 1984, this allows an investment of
about $11.6 million dollars if the investment is split evenly
between 1982 and 1983. This allows an investment of $725,000 per
engine family to cover costs for carburetor redesign,
optimization, and retooling if necessary. Finally, for the sake
of completeness, an additional $5 should be added to the initial
$10 figure. This covers the other carburetor related
modifications expected in the original 1984 final rulemaking
analysis such as parameter adjustment. ' .
There are other modifications which could be used to gain
further reductions. Both manifold configuration changes and com-
bustion chamber modifications would be effective. Changes to the
design of the intake manifold could improve air-fuel distribution
to the cylinders. Decreases in the combustion chamber surface-
to-volume ratio and dead volume would aid in reducing HC emis-
sions. Modifications of this type are not difficult or innova-
tive, but they are more leadtime intensive. Costs for modifi-
cations to manifolds or combustion chambers ' could run $20 per
engine in the short-term to recover design and retooling costs.
This would allow an average investment of $1.5 million dollars per
-------
Table IV-F
Emission Control Related Modifications/ Improvements
Carburetion $15
idle emission std
power enrichment
- accelerator pump
general fuel metering
other modifications
Manifold and/or Combustion Chamber Redesign $20
MiscejLlanepus
air injection system (diverter and -
pressure relief valves)
spark timing, A/F ratio, -
EGR recalibrations .
Sales-Weighted Cost:[l] $30
[Ij Based on estimated need for manifold/combustion chamber
redesign in 75 percent of the fleet..
-------
engine family.. However, it is unlikely that all engine families
will implement manifold and/or combustion chamber revisions. As a
conservative estimate we will .assume that 12 of the 16 engine
families do incorporate these modifications.
In summary, as an initial estimate we will use a per engine
modification/improvement cost of. &35 if all modifications are
implemented. This would cover the • recalibrations, carburetion
improvements and manifold/combustion chamber improvements. Al-
though we expect most families will require the carburetion im-
provements, it is unlikely that all will require manifold and/or
combustion chamber revisions. The actual per engine cost would be
$30 using our assumption that 75 percent of the families do use
these modifications.
(b) Emission Control Hardware
The emission control hardware anticipated for compliance with
the proposed standards is similar to that used in the LDV/LDT
fleets. Much of the technology and performance experience will be
readily transferable to HDG engines and has been in some
cases.[5j Table IV-G lists the hardware which we believe will, be
used, beginning in 1984.
The costs shown in Table IV-G have been taken from two
sources: manufacturers' comments to the 1979 HDE NPRM and' two
reports prepared by an EPA contractor.[6][7][8] In both cases the
costs reflect the economies of scale expected in HDG engine pro-
duction and have been inflated at 8 percent per annum to reflect
1981 dollars. [9] The hardware costs represent what EPA expects
for the average engine. In some cases these component costs may
be slightly greater, in other cases slightly less. At this point
in the analysis the component costs shown in Table IV-G do not
reflect an adjustment for the fact that some of these components
are already used on HDG engines.
If any engine family cannot meet the target emission levels
with the conventional modifications and hardware described above,
manufacturers may choose to incorporate less conventional control
technologies such as port liners or thermal reactors. These would
require more development and leadtime, as well as more expense to
both the manufacturers/vendors in short-term capital costs and the
consumers in first price increase. The use of these components is
not considered likely, but they are available if desired by the
manufacturers.
(3) Total Emission Control System Costs and Savings
Costs for compliance with the standards can be divided into
three main areas': pre-production R&D, engine and emission control
system modifications, and emission control hardware.
-------
Table IV-G
Emission Control Sy stem Hardware Costs [1]
Automatic Choke (electric) $ 4
Early Fuel Evaporation $18
Heated Air Intake $ 8
Increased Air Injection $39
EGR (light-load) $17
Air Modulation $ 8
$94
[1J See reference 10.
Gl
-------
Engine and emission control system modification costs and
emission control hardware costs shown in Tables IV-F and IV-G sum
to $124. Per engine pre-production R&D cost is estimated at $1.32
at the consumer level, bringing the total emission control system
cost to $125 per engine if all modifications and components are
incorporated.
Realistically, not all engine 'families will need to in-
corporate all of these components and modifications. Also, some
families already use items such as EGR, automatic chokes, and
heated air intake so these costs will not be incurred again. A
reasonable average per engine cost is probably in the $95-$105
range. This analysis will use the high end of this range ($105)
as the average per engine cost. This $105 includes all profit and
overhead and is in 1981 dollars.
On a per engine basis this figure should be compared against
EPA's anticipated costs for the 1984 Final Rulemaking (Table
IV-B). In the regulatory analysis we projected costs in 1979
dollars (including profit and overhead) of $20 for R&D and $326
for emission control hardware, for a total of $346. Inflated at 8
percent per annum this figure becomes $404. Compared against the
anticipated non-catalyst compliance costs, the savings is $299 per
engine for the emission control system portion of the first price
increase.
(4) Capital Costs of the Proposed Revisions to the HDG
Emission Standards
The proposed revision to the HDE CO emission standard and the
move to non-catalyst technology will still have capital cost re-
quirements. These are related to engine and component modifi-
cations, pre-production R&D, and tooling costs associated with
emission hardware.
As shown in Table IV-H these costs sum to $60.1 million dol-
lars. [4 J This includes $1.2 million for pre-production R&D, $29.6
million for carburetor and manifold/combustion chamber redesign,
and $42 million to cover costs to "tool-up" for the new emission
control hardware. EPA expects that many of the new emission con-
trol components can be obtained from currently, existing production
capacity thus eliminating the need for new tooling and equipment.
Since the amount of component carryacross' available could not be
precisely quantified the tooling costs estimates HDG engines have
not been adjusted downwards. It should be highlighted that many
of the emission control and engine components are built by vendors
and not the manufacturers themselves, so the capital costs are
spread over more than just the four major manufacturers. The move
to non-catalyst emission standards leads to a 46 percent decrease
in the capital costs (tooling/R&D) over that which was expected
with catalyst technology. Component carryacross will decrease
this amount even further. Given these facts, plus the number of
-------
Table IV-H
Capital Costs of the Proposed Revisions
to the HDE Emission Standards (1981 Dollars) [1]
Pre-production R&D $ 1.2M
Engine/Component Modifications $29.6M
Tooling
- Automatic Choke $ 3.5M
- Early Fuel Evaporation $ 2.1M
- Heated Air Intake $ .4M [2]
- Increase Air Injection $31.3M
- Air Modulation System $ 1.6M
- EGR (1 manufacturer) .9M
Parameter Adjustment ^ 2.2M
Total £72.8M
[lj See footnote 4 for more detail.
[2] No estimate available, but should be small, so we have
included 100K for each of the four manufacturers.
C'3
-------
manufacturers and vendors over which the costs are spread, EPA be-
lieves these capital costs are manageable for the industry.
(5 ) Operating and Maintenance Co^sts^
In the 1984 FRM EPA estimated that HDG vehicle operating
costs would rise about $83. This was comprised of $259 for un-
leaded fuel less $176 for improved exhaust system and spark plug
longevity. The $83 figure (1979 dollars) incorporates an
unleaded-leaded fuel differential of 3 cents per gallon, predicted
for the raid-eighties.
Assuming that the costs of spark plugs and exhaust systems
have increased at 8 percent per year, the savings associated with
these becomes $205, bringing the net cost increase to $54. The
accuracy of the $54 (1981 dollars) hinges on the prediction of the
3 cents per gallon unleaded-leaded price differential. If the
differential rises^ the operating cost increase would also rise.
The reverse is also true. For this analysis we will assume the 3
cents per gallon differential remains valid, and the net operating
cost increase is $54 dollars in 1981 dollars.
In the 1984 final rulemaking we also identified the potential
for a 4 percent fuel economy improvement for a lifetime savings of
$540 (1981 dollars and unleaded fuel cost).[11] The move to
non-catalyst control technology will eliminate this anticipated
improvement. EPA expects that the proposed emission standards
will have a neutral fuel economy effect on a fleetwide basis.
Many of the modifications and hardware additions expected should
have no fuel economy impact. The potential fuel consumption im-
pacts of increased air injection should be offset by improved fuel
distribution and improved engine warm-up time. EPA requests the
manufacturers' comments on the fuel economy impacts of the pro-
posed emission standards.
Finally, the fleetwide use of heated air intake and automatic
chokes will cause a small increase in lifetime maintenance costs.
These components usually require minor servicing (operational
checks and lubrication) in intervals of 12,000-24,000 miles. We
will include $20 to cover these costs over the vehicle life-
time. [12]
d. Idle Emission Standard
The idle emission standard should be feasible for no cost in-
crease over that discussed above. Costs for the idle standard are
included in the necessary carburetor modifications.
e. Cost Comparison: Catalyst vs. Non-Ca_talysjEL Systems
Having now reviewed and updated the costs associated with the
1984 FRM and identified and developed the costs associated with
-------
the proposed revisions to the 1984 HDE emission standards, the re-
maining task is- to compare the costs in the appropriate categories
to determine the savings. This will be done for capital costs,
first price increase, and operating/maintenance cost.
Comparing Tables IV-C and IV-H the capital cost savings of
the proposed changes to the HDE emission standards is $61.3
million dollars. As was expected, • the major portion of this
savings is due to the elimination of the use of catalytic con-
verter technology and the need to develop full life catalyst
systems.
As a result of the change in emission control strategies the
hardware portion of the first price increase will drop. The ex-
pected hardware/R&D portion of the first price increase will drop
from $404 (1981 dollars) for the 1984 FRM to $105 for the proposed
revisions, for a savings of $299 per HDG vehicle.
Operating and maintenance costs will not be affected as dra-
matically. Increased costs are expected to drop from $54 (1981
dollars) to $20, for a savings of $34 per vehicle. This assumes
the 3 cent per gallon unleaded-leaded fuel differential. If -the
potential fuel economy improvement impact is included the operat-
ing cost impact is substantial ($540 per HDG vehicle or its life-
time). These costs are summarized in Table IV-I.
2. Revisions to the LDT/HDE Enforcement Provisions
a. Relaxation of the Acceptable Qua_li_ty Level (AQL) during
Formal SEA Testing (10% to 40%)
Relaxation of the AQL has cost implications in four different
areas: self audit testing, quality control, formal SEA testing,
and compliance hardware. Relaxation of the AQL would decrease the
manufacturers' internal auditing levels and would thus provide a
savings. A 40 percent AQL would allow more production variability
(and noncompliance) than a 10 percent AQL, so quality control
procedures could be less stringent. The relaxation of the AQL
will actually lead to a slight increase in formal SEA testing
costs as the number of LDTs/HDEs required to reach a pass/fail
decision in formal SEA testing increases slightly. Finally, as
shown in Chapter III, the 40 percent AQL will allow higher target
emission levels than were demanded under the 10 percent AQL. This
will be reflected by potentially lower emission control system
costs. The cost impacts in these areas for LDTs, HDG engines, and
HDD engines are discussed below.
(1) Light-Duty Trucks
In the final rulemaking process implementing the 10 percent
AQL for LDTs it was difficult to identify specific costs asso-
ciated with the 10 percent AQL. An analysis of California audit
-------
Table IV-I
Cost Impact of the Proposed Revisions
to the HDE Gaseous Emission Standards
Capital Costs
(Tooling/R&D)
Emission Control
(Hardware/R&D)
Operating/
Maintenance
1984 FRM-
$121.4 M
$404
$ 54
Proposed
Revision
$ 60.1 M
(
$105
$ 20
Undiscounted
Savirigs_
$ 61.3 M
(industry-wide.)
$299
(per vehicle)
$ 34
(per vehicle)
-------
data indicated, that most manufacturers were already meeting the
more stringent AQL.[l3j When the manufacturers were queried as to
the cost, impacts of the 10 percent AQL little detailed response
was received.
Although most manufacturers routinely conduct some self audit
testing at the 40 percent AQL, only Chrysler responded that the 10
percent AQL might increase self auditing. They estimated addi-
tional equipment costs of $1.7 million dollars and annual manpower
costs of $300,000. Over a five year period this sums to $3.2 mil-
lion dollars.
Formal. SEA costs would increase slightly as a result of the
relaxation of the AQL. The number of LOT tests required to make a
pass/fail decision would rise from 13 to 16. This would lead to a
cost increase of about $1200 per audit or about $4800 per annum
assuming the current rate of about 4 audits per year (1980
dollars). Over a five year period this means a cost increase of
only $24,000 industry-wide.
Finally, because all emission target levels will rise, the
implementation of the 40 percent AQL will allow a reduction in the
costs of compliance related to emission control hardware. As was
shown in the economic analysis supporting the '1984 LDT FRM, these
costs were estimated at $3.40 per engine. The largest impact
fleetwide is the elimination of the need for anything but minor
reductions in NOx levels. The impact of the 10 percent AQL on the
NOx low mileage emission target was one of the reasons EPA con-
sidered an unsophisticated electronic control system as a likely
control strategy for 1984 LDTs. Even though the need for these
NOx reductions has been decreased, we continue to believe that
most manufacturers will choose some form of electronic controls
due to the need for reductions in cold start emissions and the
demands of the 1984 and 1985 LDT fuel economy standards.
(2) Heavy-Duty Gasoline Engines
In the regulatory analysis supporting the 1984 HDE final
rulemaking EPA identified costs in the areas mentioned in the
paragraphs introducing this section. These are discussed .below.
The 1984 analysis assumed that beginning in 1986 manu-
facturers would audit their production at an annual rate of 0.4
percent.[14] Using the sales data shown in Table IV-A this comes
to 4164 audit tests over the three years (1986-1988). In the cost
effectiveness portion of the 1984 HDE regulatory analysis, EPA
used an audit rate of 0.2 percent per annum or 2082 tests over the
three year period (1986-1988) under a 40 percent AQL. Over the
three year period the relaxation of the AQL would save .2082
audits. At $1072 per audit this savings is $2.23 million dollars
(1979 dollars). No additional testing facilities over that which
£.7
-------
was required for formal SEA testing were necessary under the 10
percent AQL, therefore no facility savings are included.
Quality control costs are likely to remain relatively un-
affected by a. change in the AQL. Going from no SEA program to
even a 40 percent AQL would require some tightening of internal
quality control procedures over the current levels. The pro-
duction of HDG engines has not been subject to SEA before, so some
quality control increases are likely.
As before with LDTs, increasing the AQL would result in an
increase in the number of HDG engines tested in each formal SEA.
An increase from 12 engines per audit to 15 would mean a per audit
cost increase of $5250, or $262,000 for the 50 audit tests
anticipated in the 1984 HDE regulatory analysis for the 1986-1988
time period of the original analysis.
Relaxing the .AQL under the catalyst-based emission control
approach would have allowed a cost savings. In the regulatory
analysis supporting the 1984 FRM we estimated an additional hard-
ware cost of $13 due to the effect of the 10 percent AQL. This
$13 is already reflected in the emission control hardware savings
described previously.
For the non-catalyst based emission control system being
assumed in this action, the standards setting approach being used
is different from that in the original rulemaking. In this action
we have proposed emission standards which we consider to be
achievable under a 40 percent AQL and the other technology and
lead time constraints. If the decision were made to maintain the
10 percent AQL under the same constraints, the approach used would
be to propose the emission standards at a level achievable at the
10 percent AQL. Under these constraints and this approach to
setting standards an incremental hardware cost attached to the 10
percent AQL has no definition.
(3 ) Heavy-Duty^ Di^ese 1 Engines
As before with HDG engines EPA has identified costs in all
areas mentioned in the introductory paragraphs. These are dis-
cussed below.
The 1984 final rulemaing analysis assumed that manufacturers
would audit their production at 0.4 percent per annum beginning in
1986.[15] Using the sales data of Table IV-A this comes to 3866
audit tests over the three year period being considered
(1986-1988). In the cost effectiveness chapter of the regulatory
analysis EPA assumed an audit rate of 0.2 percent per year or 1933
audit tests over the three year period if a 40 percent AQL were in
effect. Therefore, relaxation of the AQL would save 1933 audits.
At $1274 per audit this savings is $2.46 million dollars (1979
dollars) over the three year period. In the original 1984 FRM
-------
economic analysis no manufacturers of HDD engines needed addi-
tional facilities and equipment for self audit testing. Therefore
no savings in facility costs are included as a result of the AQL
relaxation.
As before with HDG engines, quality control costs are likely
to remain unaffected by the change in the AQL. The heavy-duty
diesel industry has little experience with the impacts of SEA on
its product lines and will probably choose to implement tighter
quality control procedures as part of its reaction to the new SEA
requirements.
Relaxing the AQL would mean that more engines would have to
be tested in formal EPA SEA to make a pass/fail decision. The
expected increase from 12 to 15 engines per audit would mean a per
audit cost increase of $5250, or $336,000 for the 64 audit tests
anticipated in the 1984 HDE regulatory analysis for the 1986-1988
model years (1979 dollars).
In the cost effectiveness analysis of the 1984 HDE regulatory
analysis the incremental emission control compliance costs for the
10 percent AQL were estimated on a family by family basis. This
was done by comparing the projected transient test hydrocarbon
emission levels of each engine family against the expected low
mileage emission targets of the 10 and 40 percent AQLs. Com-
pliance costs for each case were then estimated. The bottom line
of this analysis was that the average per engine emission con-
trol system cost of the 10 percent AQL was about $3 per engine
(1979 dollars). This is roughly the per engine savings which
could be expected from adoption of the 40 percent AQL.
(4) AQL Relaxation Cost Impact Summary
Table IV-J summarizes the potential cost savings in all areas
as a result of the AQL relaxation. As can be seen, the total
savings for the five year period 1984-1988 for LDTs and- HDEs is at
least $77.3 million dollars (undiscounted). Of this $77.3 mil-
lion, the short term capital cost savings to the manufacturers is
at least $8.2 million. This savings plus the emission control
system cost saving can be passed on to the consumers. These
represent real savings, and not just cash flow savings, since
these costs will not occur again, unless the 10 percent AQL were
reimplemented.
b. Delay Implementation of the SEA Program for HDEs
EPA has announced that implementation .of Selective Enforce-
ment Auditing (SEA) for HDEs will be delayed until the 1986' model
year. This will yield short-term (1984 and 1985) cost savings in
three areas and cash flow savings for two years. For the 1984 and
1985 model years no costs will be incurred in the areas of self
audit tests, formal EPA SEA tests, and increased quality control.
-------
Table IV-J
Cost Savings Due to the Relaxation of the AQL; Summary [1]
Light-Duty Truck (1984-1988); Heavy-Duty Engines (1986-1988)
Formal SEA
LOT
HDG
HDD
Total
Self Audit
Testing
$3.46M
$2.60M [2]
$2.87M [2]
$8.93M
Testing
Increases [3]
-$ 26K
-$306K
-£392k
-$724K
Emission Control
System: Costs [4] Total
$63.78M
- [5]
$ 5.39M
J69.17M
$67. 2M
$ 2.3M
$ 7.8M
• $77. 3M
[I] 1981 dollars, undiscounted.
[2.J Decrease in self audit rate.
[3] Shown as negative, because these costs will increase slightly
with the 40% AQL.
[4] Five year aggregate sales multiplied by the per
vehicle/engine savings.
[5] Not included as per discussion in text.
70
-------
Cash flow will.be improved by a two year delay in the purchase of
SEA related facilities and equipment. (Deferred cash investment
does in fact provide a small savings in the form of an opportunity
cost, but this will not be considered here.) No emission control
hardware cost: savings are expected, as EPA expects that when pos-
sible manufacturers will certify, their 1984 model year engines
with consideration to the impact of the 40 percent AQL and SEA on
the target emission levels. These cash expenditure and cash flow
savings are discussed below for HDG and HDD engines.
(1) Heavy-Duty Gasoline Engines
All 19.84 and 1985 model year costs related to self audits,
formal EPA SEA tests, and increased quality control will be
saved. As determined in the 1984 final rulemaking economic impact
analysis and shown in Table IV-K these savings come to $14.2 mil-
lion dollars (1981 dollars). In addition to this real cost sav-
ings, delaying the implemention of the EDE SEA program will im-
prove the manufacturers' cash flow requirements. For HDG engines
the cash flow savings is estimated at $16.4 million 1981 dollars,
delayed from 1982-83 to 1984-85. [16]
(2) He a_vy_- Dutj^ JDie s e 1 Eng i ne s
For the 1984 and 1985 model years, cost savings for the HDD
engine industry will occur in similar areas as for HDG engines.
In the economic impact analysis supporting the 1984 HDE final
rulemaking costs were determined in these areas. As shown in
Table IV-K the savings related to the two year elimination of self
audits, EPA formal SEA tests, and quality control come to $11.9
million 1981 dollars. In addition, the delay of the investment in
facilities and equipment for SEA will improve the major domestic
manufacturers' cash flow by $21.1 million 1981 dollars. The delay
will allow this investment in 1984 and 1985 instead of 1982 and
I.y83.[17j The original FRM analysis assumed that the smaller
domestic and foreign manufacturers would allow their certification
facilities to double as SEA facilities. Thus these manufacturers
will not incur the cash flow savings as their transient certi-
fication facilities must be prepared for 1985 model year certifi-
cation.
c. 'Summary of the Enforcement Related Cost Implications
(1) Li ght-Duty Trucks
The only part of the enforcement related proposals affecting
LDTs is the relaxation of the AQL. The self -audit testing cost of
Table IV-J, $3.43 million dollars, represents a cost expenditure
savings. The remaining $63.78 million dollars in emission control
system costs is 'primarily a consumer savings, although some small
manufacturer savings will occur as a result of the elimination of
-------
Table IV-K
Cost Savings from Delaying Implementation
of the Heavy-Duty Engine SEA Program [1][2]
Self Formal EPA Quality Facilities
Audits [3] SEA Tests [3] Control [3][4] & Equipment [5]
HDG Engines
HDD Engines
Total
$5010K
$4481K
$9.49M
$686K
$980K
$1.67M
$8490K
$6420K
$14.91M
$16.39M
$21.05M
$37.44M
[1J 1984 and 1985 model years.
[2] 1981 dollars, undiscounted.
[3] Cash expenditure savings.
[4] 1984 and 1985 sales multiplied times the per engine quality control
cost.
[5j Cash flow savings; deferred two years.
-------
the need for short term investment in the emission control system
components.
(2) Heavy-Duty Gasoline Engines
All enforcement related aspects of the proposal affect HDG
engines. Cash expenditure and cash flow savings will occur as a
result of the AQL relaxation and the 'delay of HDE SEA. These are
summarized by year and category in Table IV-L in 1981 dollars.
(3) Heayy-Duty Diesel Engines
The HDD engine industry is affected by all enforcement re-
lated proposed revisions. The relaxation of the AQL and the delay
of HDE SEA will provide both cash expenditure and cash flow
savings for the industry. The emission control hardware savings
associated with the AQL will primarily benefit the consumers, but
the manufacturers will also see a small savings as they will be
able to forego the short-term investment in emission control
systems and R&D. The expenditure and cash flow savings for the
proposed relaxation of the enforcement provisions are shown in
Table IV-M by year and category in 1981 dollars.
C. Total Economic Impact of the Proposed Revisions
Having now identifed the cost savings related to the proposed
changes to the HDE CO standard and the LDT/HDE enforcement pro-
visions, the remaining task, is to calculate the final cost savings
impacts of the entire proposal. This will be done for LDT, HDG
and HDD. In this analysis we will determine the cash expenditure
savings, the cash flow savings and the per vehicle/engine purchase
and operating cost impacts.
1. Light^-Duty Trucks
a. Cash Expenditure Savings
Since LDTs are affected only by the AQL relaxation portion of
the proposal the major savings will be in the area of self audit
testing. EPA estimates a cash expenditure savings of about $3.43
million dollars over the five year period.
b. Consumer Cost Savings
As a result of the relaxation of the AQL, EPA estimates a
consumer savings of about $3.87 per engine. Over the five year
period this sums to about $67.2 million dollars (undiscounted).
2. Heavy-Duty Gasoline Engines
73
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Table IV-L
Enforcement Related Cost Expenditure
and Cash Flow Savings: HDG Engines
1982
Self Audits [2]
Formal SEA
Testing [2]
Quality Control [2]
SEA Facilities $8194K
and Equipment [3]
Total $8194K
1983 1984
$2754K
$ 343K
$4281K
$8194K
$8194K fc7378K
1985
&2256K
$ 343K
$4209K
-
$6808K
1986 1987 1988
$886K $868K $849K
(-$ 86K) (-$ 80K) (-$ 80K)
- - -
_
$800K $788K $769K
Total
$ 7613K
$ 440K
$ 8490K
$16388K
Discounted
Total
$ 6769K
469K
8107K
18928K
[1] 1981 dollars, undiscounted
[2] Cash Expenditure Savings
[3j Cash Flow Savings.
> *
[4] Discounted at 10 percent to January, 1984
Total Cash Expenditure Savings: $15,345K [4]
Total Cash Flow Savings: $18,928K [4j
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Table IV-M
CA
Enforcement Related Cost Expenditure
and Cash Flow Savings: HDD Engines [I]
1982
Self Audits [2]
Formal SEA
Testing [2]
Quality Control [2]
SEA Facilities $10527K
and Equipment [3]
Total $10527K
1983 1984
J2367K
$ 490K
$3105K
$10527K
$10527K $5962K
1985 1986 1987 1988 Total
*2114K *900K *957K *1015K $ 7353K
$ 490K (-&129K) (-$129K) (-$135K) $ 587K
$3316K - $ 6421K
fc210b4K
J5920K $771K $828K $880K
Discounted
Total
$ 5445K
$ 640K
$ 6120K
$24317K
[1] 1981 dollars, undiscounted
[2] Cash Expenditure Savings.
[3] Cash Flow Savings.
[4] Discounted at 10 percent to January 1984.
Total Cash Expenditure Savings: $13205K
Total Cash Flow Savings: $24317K
-------
a. Cash Expenditure Savings
As a result of the proposed revisions, HDG engine manu-
facturers will accrue substantial cash expenditure savings. As
detailed in Table IV-N these savings come from decreased R&D/Tool-
ing costs, decreased costs associated with the AQL relaxation, and
costs eliminated as a result of the delay of the implementation of
the HD SEA program. Cash expenditure savings sum to $86.1 million
dollars (discounted).
b. Cash Flow Savings
The major cash flow savings are associated with the deferral
of the HD SEA program. As shown in Table IV-N this will allow a
two year deferral of the capital investment necessary to construct
the necessary SEA facilities. The total cash flow savings are
$18.9 million dollars (discounted).
c . Consumer Cost Savings
Purchasers of HDG vehicle will benefit from both lower first
price increases and lower operating costs.
(1) Fir st^ Price Increase _ Shavings :
The first price increase will vary in the analysis period.
Using the applicable data from Table IV-B (items: 1, 4, and por-
tion of 8) plus the $105 R&D/hardware cost discussed previously
the 1984-85 first price increase comes to $121. The savings is
$339 per engine.
When SEA begins in 1986 the first price increase savings will
drop to $302. The savings will decrease because of the need to
cover amortization of SEA facilites, self audit testing, quality
control, and formal EPA SEA testing. The savings in the 1987-88
time period depend upon the outcome of the revision process
applicable to the 1987 model year HDE emission standards. The
hardware savings could range from approximately the same as
expected in 1986 to virtually zero depending on the standard
promulgated for 1987. Since this decision has not been made, we
will conservatively assume no hardware savings in 1987 and 1988.
Thus the only savings in this year will be $3.50 related to the
AQL relaxation. The components of these savings for ' the
appropriate years are shown in Table IV-0.
( 2 ) Qj^ejr^ing/Maint^ajienac^e Coasts
Referring to the previous discussion, these costs would drop
by $34 per vehicle beginning in 1984 as a result of the proposed
revisions and the move to non-catalyst technology. As above we
will assume no savings in 1987 and 1988
-------
Table IV-N
->J
1982
R&D/Tooling [2] $30650K
SEA Facilities [3] $ 8194K
Self Audits [2]
SEA Testing [2] -
Quality Control [2]
Total Economic Savings to the
Industry of the Proposed Revisions: HDG Engines [1]
1983
$30650K
$ 8194K
1984
Total $38844K $38844K $7378K
Total Cash Expenditure Savings: $86,147K
Total Cash Flow Only Savings: $18,928K
1985
$2754K . $2256K
$ 343K $ 343K
$4281K $4209K
$6808K
1986
1987
1988
Total
$886K
$800K
$788K $769K
Discounted
Total [4j
-
-
$868K $849K
(-$80K) (-$80K)
-
$61,300K
$16,388K
$ 7.613K
$ 440K
$ 8,490K
$70802K
$18928K
$ b769K
$ 469K
$ 8107K
[1 ] 1981 dollars, undiscounted
[2] Cash Expenditure Savings
[4] Cash Flow Savings
(5] Discounted at 10 percent to January 1984.
-------
Table IV-0
HDG Engine First Price Cost Savings Components [1][2]
SEA Facilities
Self Audits
ies
[3]
l*J
trol
ntrol
1984-1985
$ 16.52
1.22
7.61
15.05
$299. 00
1986
$ 0
-.31
3.81
0
$299.00
1987-1988
$ 0
-0.31
3.81
0
0
Hardware/R&D
Total Savings: $339.40 $302.50 $3.50
[Ij Original costs were taken from Table V-LL of the "Regulatory
Analysis and Environmental Impact of Final Emission Regulations
for 1984 and Later Model Year Heavy-Duty Engines, December 1979,
U.S. EPA, OME1APC.
[2] Original costs were inflated at 8% per year to get 1981
dollars. These figures .also include overhead and profit.
[3] SEA testing costs go up slightly as a result of the 40% AQL.
[4] Average per engine costs will be reduced by about 50% over
the 10% AQL audit rate of 0.4%.
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3. Heavy-Du ty Pi ej>e 1 Engines
a. Cash Expenditure Savings
Heavy-duty diesel engine manufacturers should gain substan-
tial cash expenditure savings as a result of the proposed changes
to the enforcement provisions. As shown in Table IV-M these sav-
ings will occur in lower self audit costs and elimination of SEA
testing and quality control costs for two years.
b. Cash Flow Savings
The major cash flow savings occur as a result of the two year
delay of HD SEA. As shown in Table IV-M, this will allow delaying
this investment in SEA facilities to 1984-1985 from 1982-1983.
c. First Price Increase Savings
The first price increase will vary through the analysis
period. Beginning in 1984 the first price increase savings will
sum to about $64 per engine. The components of these savings are
taken from Table IV-P. Referring to the same table, beginning, in
1986 the per engine savings will drop to $7. This is a result of
the implementation of the SEA program for HDD engines.
4. Aggregate Savings
a. Cash Expenditure and Cash Flow Savings to the Industry
The aggregate savings to the manufacturers is comprised of
the cash expenditure and cash flow savings for each group of
vehicles/engines affected. These two types of savings are shown
in Table IV-Q by year for each vehicle/engine group. Both the
cash expenditure and cash flow savings are large. The un-
discounted totals are $95.6 million dollars and $37.4 million
dollars respectively. If these savings are discounted, their
present value in 1984 (the first model year of production affected
by these regulations) is $102.7 million dollars for the cash ex-
penditure savings and $43.2 for the cash flow savings.
b. Aggregate Savings to the Nation
The best means of determining the net impact on the consumers
and the economy as a whole is to express the aggregate cost as a
function of the total per vehicle lifetime savings. This allows
the inclusion of overhead and profit and hardware, as well as the
impact of the changes in operating costs. These per vehicle/ en-
gine impacts at the consumer level are shown in Table IV-&. If
the per vehicle engine savings are multiplied by the appropriate
sales the aggregate net impact on the economy is found. In this
case the net reduction for all three vehicle/engine groups sums to
$449.4 million dollars.
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Table IV-P
HDD Engine First Price Cost Savings Components [1J[2J
SEA Facilities
Self Audits
ies
13]
I*]
.trol
(AQL Relaxation)
1984-1985
$34.14
2.18
8.87
15.05 .
3.45
$63.69
1986+
$ 0
-.55
4.43
0
3.45
$7.33
[1] Original costs were taken from Table V-LL of the "Regulatory
Analysis and Environmental Impact of Final Emission Regulations
for 1984 and Later Model Year Heavy-Duty Engines, December 1979,
U.S. EPA, CMSAPC.
|2j Original costs were inflated at 8% per year to get 1981
dollars. These figures also include overhead and profit.
[3j SEA testing costs go up slightly as a result of the 40% AQL.
Average per engine costs will be reduced by about 50% over
the 10% AQL audit rate of 0.4%.
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Table IV-Q
Aggregate Savings to the Industry
Cash Expenditure Savings
LOT [2]
HDG [3 j
HDD [4J
HDG [5]
HDD [6]
1982 1983
$ 1.836K
$30,650K $30,650K
$30,650K $32,486K
1982 1983
$ 8.194K $ 8.194K
$10,527K $10,527K
$18,721K $18,721K
Undiscounted
1984 1985 1986 1987 1988 Total
319K
7,378K 6
5,962K 5
$13,659K $13
Undiscounted
Total
$16,388K
$21,054K
$37,442K
319K 319K 319K 319K $ 3.431K
,808K 800K 788K 769K $77,843K
,920K 771K 828K 880K $14,361K
,047K $1,890K $1,935K $1,968K $95,635K
Cash Flow Savings
Discounted
Total [1]
$18,928K
$24,317K
$43,245
Discounted
Total tij
$ 3-.350K .
$ 86.147K
$ 13.204K
S102.701K
[1] 10 percent discount to January 1984
[2J As per discussion in text
[3] All but SEA Facilities, Table IV-N
14] All but SEA Facilities, Table IV-M
15] SEA Facilities, Table IV-N
[6] SEA Facilities, Table IV-M
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Table IV-R
Aggregate Savings to the Nation: 1984-1988
Grou£
LOT
HDG
HDD
Years
1984-88
1984-85
1986
1987-88
1984-85
1986-88
Average Savings
Sales[lj (First Price)[2]
17.37M
727,879
354,287
686,718
550,416
996,403
$ • 3.87
$339.40
302.50
$3.50
$ 63.69
$ 7.33
Average Savings Discounted
( Operating/Maint) Total [3]
$ 55. 6M
$34 $259. 5M
$34 . $98. 5M
$1.7M
$ 33. 4M
$ 0.7M
$449.4M
[1] Table IV-A.
[2] Text and Tables IV-0, P.
[3] Discounted at 10 percent to January 1984.
82.
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Ref^erences
1. See. "Regulatory Analysis and Environmental Impact of Final
Emission Regulatons for 1984 and Later Model Year Light-Duty
Trucks," U.S. EPA, OMSAPC, May 1980.
2. See "Regulatory Analysis and Environmental Impact of Final
Emission Regulations for 1984 and Later Model Year Heavy-Duty
Engines," U.S. EPA, QMSAPC, December 1979.
3. Based on the new car CPI for 1979 and 1980, 7.4% and 8.0%
respectively.
4. EPA memo: Tooling Cost Calculations for HDG Engine Emission
Control Components.
5. Several HDG engine models use automatic chokes, EGR, EFE,
dual air pumps, etc.
6. See Public Docket OMSAPC 78-4.
7. Cost Estimations for Emission Control Related Compon-
ents/Systems and Cost Methodology Description, EPA-460/3-78-002,
March 1978.
8. Cost Estimations for Emission Control Related Components/
Systems and Cost Methodology Description: Heavy-Duty Trucks,
EPA-460/3-80-001, February.1980.
9. Cost figures from either the public comments or the contract
reports were inflated at 8% per year from the applicable base
years of 1979 and 1977 respectively.
10. EPA memo: Emission Control System Component Cost Calcula-
tions for HDG Engines.
11. In the economic analysis supporting the 1984 HDE FRM the per
engine potential fuel savings was erroneously calculated using the
5.4 mpg dynamometer figure instead of the 9.9 mpg average HDGE
road mileage figure. The unleaded fuel cost used here is $1.40/
gallon. See pages 125-127 of [2] above.
12. The labor anticipated over the vehicle lifetime is 1 hour or
less.
13. See Public Docket CMSAPC 79-2, Analysis of California Two
Percent Audit Data.
14. See Table V-AA of [2] above.
15. See Table V-BB of [2] above.
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References (cont'd)
16. See Table V-T of [2] above, and factor in inflation.
17. See Table V-U of [2] above, and factor in inflation.
SH
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