EPA 230/3-74-013
Report  to Congress


    The Clean Air Act, as amended in 1970, initiated a coordinated

national effort toward reducing air pollution through research,

regulations,  enforcement, and related programs.

    Section 202(b)(4) of the Clean Air Act  requires the Administrator to

report yearly on measures taken in relation to motor vehicle emission

control.   Section 202(b)(4) reads as follows:

     "On July 1,  1971, and of each year thereafter, the Administrator
     shall report to the Congress with respect to the development of
     systems necessary to implement the emission standards
     established pursuant to this section.  Such reports shall include
     information regarding the continuing effects of such air pollutants
     subject to standards under this section on the public health and
     welfare, the extent and progress of efforts being made to develop
     the necessary systems, the costs associated with development
     and application of such systems,  and following such hearings
     as he may deem advisable, any recommendations for addi-
     tional Congressional action necessary to  achieve the purposes
     of this Act.  In gathering information for the  purposes  of this
     paragraph and in connection with any hearing, the provisions
     of Section 307(a) (relating to subpoenas) shall apply. "

     This report covers the period July 1, 1973 through June 30,  1974.

                          Table of Contents


L	Introduction and Summary	  I. 1

II.  EPA Actions	II- 1

      A.  1976 NOx Emission Standard Decision	II-1

      B.  Motor Vehicle Regulations	II- 4

          1. Regulations for Light-Duty Diesel Passenger
               Vehicles	  II- 4
          2.  Regulations for Light-Duty Gasoline Trucks	II- 4
          3.  Regulations for Light-Duty Diesel Trucks	II- 5
          4.  Motorcycle Regulations	  II- 5
          5.  Non Methane Hydrocarbon Exhaust Emission
               Standards	  II- 7
          6.  Regulations for Motor Vehicle Certification	  II- 7
          7.  Regulations Defining Certificate of Conformity..,	  II- 8
          8.  Regulations for Certification at High Altitudes	II- 9
          9.  Regulations for Certification of Low Emission
                Vehicles	11-10
          10.  Regulations Defining Exclusions and Exemptions	11-11
          11.   Recall Regulations	11-11
          12.  Regulations for Importation of Catalyst-Equipped
                 Vehicles		  11-12

      C.  Fuel Regulations	  11-13

          1.  Fuel Regulations for Lead-Free Gasoline	  11-13
          2.  Fuel Regulations for Low Lead Gasoline	   11-14
          3.  Regulations for Registration of Fuels and
                Fuel Additives	   11-14

III.  Progress in Emission Reduction Technology	   Ill-  1

      A.  Alternative Automotive Power Systems Program	  Ill-  1

          1.  Conventional and Stratified Charge Engine	  Ill-  1
          2.  Gas Turbine	  Ill-  4
          3.  Rankine Cycle Engine	  Ill-  8
          4.  Demonstration Vehicles	 Ill-  9

      B.  Federal Clean Car Incentive Program	Ill-10


      C.    Low-Emission Vehicle Purchase Program	111-12

      D.    Feasibility of Alternative Fuels	Ill-13

      E.    Assessment of Progress	 Ill-14

          1.  EPA Assessment	111-14

          2.  National Academy of Sciences	 Ill-16

IV.   Costs and Benefits of Meeting Emission Standards	IV-  1

      A.    Cost of Meeting Emission Standards	  IV- 1

          1.  Light-Duty Vehicles	  IV- 1
          2.  Heavy-Duty Vehicles	  IV- 8
          3.   Lead-Free Fuel  Regulations	  IV-12
      B.    Benefits of Meeting Emission Standards	  IV-12

          1.  Effect of Mobile Source Pollutants	  IV-12
          2.  Improvement of Air Quality	 IV-26

V.    Related EPA Programs	   V- 1

      A.    Certification Program for New Motor Vehicles	   V- 1

          1. Certification Determination	   V- 1
          2. Inspections and Investigations Program	   V- 6
          3. Exclusions and Exemptions Program	   V- 6

       B.     Selective Enforcement Auditing Program for
             Production Vehicles	   V- 8

       C.    Enforcement Activities for Vehicles  In Use
             And Fuel Standards.	   V- 9

           1.  Antitampering Program	   V- 9
           2.  Recall Program	   V-10
           3. Warranties Program	   V-12
          4. Aftermarket Parts	   V-12
           5.  Imports Program	   V-13
           6.  Fuels Program	   V-14

       D.    Other Emissions Inventory Programs	   V-15

           1.  Light-Duty Vehicle	   V-15
           2.  Heavy-Duty Vehicles	   V-15

       E.    Supporting Emissions Characterization Program	   V-16

           1.  Emissions at Nonstandard Temperatures	   V-16
           2.  Currently Unregulated  Emissions	   V-17
           3.  Sulfate Emissions	   V-18

F.  Transportation Control Plans	    V-19

    1.  Transportation Control Plan Measures	    V-20
    2.  Implementation and Cost	    V-27
    3.  Other Studies	    V-28

    FOOTNOTES	     V-30

                           List of Tables
1.1   Existing Emissions Standards	    1-4

I. 2   Emissions Standards for Heavy-Duty Gasoline and Diesel
       Engines	    I- 5

I. 3   Major Regulations Proposed/Promulgated During 1973/1974.. .    1-6

IV. 1  Emission Control Equipment Costs, 1974-1977 Model Year
       Light-Duty Vehicles	   IV- 2

IV. 2  Emission Control Equipment Costs for 1978 Model Year
        Light-Duty Vehicles	  IV- 4

IV. 3  Estimated Incremental Maintenance Costs for Emission
        Control Systems of Light-Duty Vehicles	   IV- 6

IV-4  Effect of Emission Controls on Fuel Economy of
       Light-Duty Vehicles	   IV- 7

IV. 5  Estimated National Costs for Emission Controls
       for Light-Duty Vehicles	   IV- 9

IV. 6  Estimated National Costs for Emission Controls
        for Heavy-Duty Gasoline Engines	   IV-11

IV. 7  Adverse Health Consequences of Motor Vehicle Pollutants	   IV-15

IV. 8  Possible Adverse Health Effects Which Might Logically
        Follow Exposure to Carbon Monoxide	   IV-17

IV. 9  Adverse Health Effects  Which Might Be Attributed to
        Photochemical Oxidant  Exposures	   IV-18

IV- 10 Adverse Health Effects Which Might be Attributed to
        Nitrogen Dioxide	   IV-20

V. 1  Gas Mileage for 1974 Automobiles	    V- 7

V. 2  States with Transportation Control Plans	    V-21

                      List of Figures
III.     1.       Internal Combustion Engine	  III.2
III.     2.   "    Stratified Charge Engine System	  Ill-3
III.     3.       Gas Turbine Engine	   Ill-5
 V.     4.       Steps in Certification Process	   V-2

EPA's effort in reducing mobile source emissions includes the setting
of standards, the promulgation of regulations, program development,
and research.



    The period for this  report (July 1,  1973 - June 30,  1974) saw substantial

development of EPA activities to control motor vehicle emissions.

    The Clean Air Act allows the EPA Administrator to suspend for 1

year the statutory 1975  model year emission standards for hydrocarbons

(HC) and carbon monoxide (CO) and the statutory 1976  model year

emission standards for nitrogen oxides (NOx).  In 1973, the EPA

Administrator did suspend the statutory standards and set interim

standards for HC, CO,  and NOx. The  suspension of statutory 1975

model year emissions standards was covered in the 1973 report to

Congress.  Suspension of the statutory 1976 model year emissions

standards and setting of interim standards is discussed in Chapter II

of this report.

    In June  1974, the Energy Supply and Environmental Coordination Act

changed the status of the interim standards and enacted new deadlines for

emissions standards. According to the new Act, the Clean Air Act statutory

standards for HC and CO  (originally to be met by the 1975 model year)  are

now to be met by 1977 model year with the possibility of an additional one

year extension.  The Clean Air Act statutory standards for NOx (originally

to be met by the 1976 model year)are now to be met by 1978 model year.

Current standards reflecting the Energy Act provisions and EPA promul-

gations are  summarized in Tables 1.1  and I. 2.

    Currently, Legislative proposals  revising  standards  are being consi-

dered. EPA in submitting legislative proposals to amend  the CAA of 1970 on

March 22,  1974,  transmitted the Presidents proposals which would

1) extend the Federal auto emission  standards applicable  to the 1975 model


year for carbon monixide, hydrocarbons and nitrogen oxides through the

1976 and 1977 model years,  2) provide for review of regulations

applicable to emissions of oxides of nitrogen from light duty vehicles

and engines manufactured during or after the 1978 model year.

    In addition to the suspension of emission standards,  EPA proposed

or promulgated standards setting emission levels in different vehicle

categories and proposed regulations to ensure that motor vehicles meet

emission standards (e.g., Regulations defining Certificate of Conformity,

Recall Regulations, etc.  see Table I. 3).

    The  past year saw developments in a number of other areas as  EPA:

    o developed fuel regulations requiring marketing of lead free fuels,
       established a schedule for phasing down lead content in fuels
       and proposed regulations for registration of fuels and fuel

    o continued its Alternative  Power Systems program which
      evaluates and develops alternative power systems to
      conventional internal combustion engines.

    o initiated contractor studies to assess the technical and
      economic feasibility of alternative fuels.

    o continued to support research by the National Academy of
      Sciences focusing on the technological feasibility and cost
      of meeting various  NOx Standards.

    o continued research in assessing the costs and benefits
      of motor vehicle emission control.

    o continued its certification testing  program, which tests
      prototype vehicles representing all new motor vehicles
      sold in the U. S.   In  the past year,  completed certification
      of 1974 model year light-duty gasoline and diesel engines.

    o published fuel consumption results on 1974 model year
      vehicles in the Federal Register and as a booklet for
      consumer use.

    o expanded the surveillance and inspection of manufacturing
      facilities in order to ensure that certification procedures
      are observed. In the past year, conducted  24 in-depth
      inspections  of domestic and foreign facilities.


o developed a Selective Enforcement Auditing program in order
  to test new motor vehicles or new motor engines being
  manufactured in assembly line production.

o undertook an investigation of 20 potential violations of
  tampering with emissions controls; referred five cases to
  the Justice Department.  An EPA survey in Washington,
  D.  C.  found components of emission control  systems had
  been removed in 15 percent of vehicles.

o under the Recall Program,  tested vehicles in use.  EPA announced
  June 25, 1974 that four manufacturers of certain 1972 vehicles
  appeared to be in violation of Federal air pollution emission
  standards.  One earlier investigation under this program led to a
  recall of 826, 000 Chrysler vehicles. Thirty percent of the
  recalled vehicles have been remedied.

o under the Imports Program, monitored approximately 3 million

o established a regional field sampling inspection system under the
  fuels program to assure availability of lead-free gasoline.

o completed a report on emission testing of light-duty vehicles
  entitled "Automobile Exhaust Emission Surveillance--Analysis
  of FY 1972 Program. "

                                                                      TABLE I.I

                                                             EXISTING EMISSIONS  STANDARDS

1 HC CO NOx 1


j HC

NOx 1


                                                          (emissions  expressed  as  grams per mile)
Light duty gasoline
passenger vehicle
Light duty diesel
passenger vehicle
Light duty gasoline
Light duty diesel
truck (proposed)







0.41 3.4 2.0

0.41 3.4 2.0

2.0 20 . 3.1

2.0 20 3.1

0.41 3.4 0.4

0.41 3.4 0.4

NOTE:   The 1977 emission standards for hydrocarbons and carbon monoxide  are  listed  in  this  table.
        The guidelines for determination of a 1  year suspension of  HC and CO  are  found  in  House  Reoort  93-1013  (pages  23-25).
        On March 22, 1974, EPA in submitting legislative proposals  to amend the Clean Air  Act  of 1970,  transmitted0
        the President's proposals which would;  I) extend the Federal  auto emission standards applicable to  the  1975
        model  year for carbon monixide, hydrocarbons and nitrogen oxides  through  the 1976  and  1977 model years,
        2) provide for review of regulations applicable to emissions  of oxides of nitrogen from  light duty  vehicles
        and engines manufactured during or after the 1978 model year.

                             TABLE I. 2
                     EMISSIONS STANDARDS FOR
Type of Engine
                                  1975 and 1976 Model years
                                  (grams/brake horespower/hour)
HC and NOx
Gasoline engine
Diesel engine
a) Standards for 1977 and 1978 have not been set.

b) Standards apply to the combined emission of hydrocarbon and
   nitrogen oxides.

                                           Table  1.3

                                   MAJOR REGULATIONS  PROPOSED/
                                   PROMULGATED DURING FY 1974


Jan. 10 ,1973	General Availability of Unleaded  Gasoline	Promulgated

Jan. 10,1973	Reduction of Lead in Gasoline	Promulgated
[amended Nov.  28,  1973)

                    Interim Emissions standards for 1975  model year
July 2,1973	Light Duty Passenger Vehicles	Promulgated

Julyl3,1973	Low Emission Vehicle Certification Regulations	Proposed

Aug.  7,1973	Regulations for Light Duty Diesel Passenger Vehicle	Promulgated

Aug.  7,1973. .,	Regulations for Light-Duty Gasoline  Trucks	Promulgated

                    Interim Emissions standards for 1976  model year                                H
Aug.  21,1973	Light Duty Passenger Vehicles	Promulgated       i
Oct.  12,1973	Regulations for Certification at  High Altidues	Proposed

Jan.  17,1974	Motorcycle	Advance Notice

Jan.  25,1974	Regulations for Light-Duty diesel Trucks	Proposed

March 7,1974	Registration of Fuels	Proposed

March 21,1974	Exemptions and Exclusions  Regulations	Proposed

March 25 ,1974	Recall Regulations	Proposed

May 7,1974	Amendment to Jncrease General Availability of
                    Unleaded Gas in Rural Counties	Proposed

May 7,1974	Extensions and Exemptions  from Unleaded  Gasoline
                    Regulations	Promulgated

 July 3, 1974	Supplemental Notice  of Proposed Rulemaking to Advance
                   the  Jan.1,1975 Compliance  date for retail  outlets  for
                   unleaded gas in rural counties to Oct.1,1974	Proposed

 May  10,1974	Conversion to Non-Methane  Hydrocarbon Standards	Advance Notios

                       CHAPTER II.   EPA ACTIONS
EPA has been active in promulgating regulations for heavy-duty truck
engines as well promulgating regulations for passenger vehicles.Fed-
eral standards through 1970-73 for heavy-duty truck diesel engines
covered smoke emissions only.  For the 1974 model year, the standards
were revised to include HC, NOx. and CO emissions.


                    CHAPTER II.  EPA ACTIONS


     On July 20, 1973 the Acting EPA Administrator, granted the

request of Ford Motor Company, General  Motors Corporation, and

Chrysler  Corporation for a 1 year  suspension of the 1976 motor vehicle

emissions standards.  The 1976 standards are applicable to light-duty

vehicles and engines manufactured during  or after model year 1976.

Section 202(b) of the Clean Air Act requires that 1976 and later model

year vehicles and engines achieve a 90 percent reduction in nitrogen
oxides over 1971 model year vehicles.  The Administrator's decision

to grant the request was made on the basis of four criteria specified

in Section 202(b)(5) of the Clean Air Act.   The Act states that The

Administrator has the authority to  suspend for 1 year, the  effective date

of the 1976 NOx standard only if he determines that:

     o  the applicants have established that effective control technology
        is not available to achieve  compliance prior to the  effective
        date of the standards.

     o  the study of the National Academy of Sciences (conducted
        pursuant  to the Act) and other  available information does
        not indicate that  the technology is available to meet the

     o  the applicants have made all good faith efforts to meet
        the standards.

     o  the suspension is essential to the public interst or the
        public health and welfare of the United States.

    On the basis of these criteria, and the information submitted by

applicants and other witnesses during 2 weeks of hearings held by  EPA,

The Administrator decided to suspend for 1 year the effective date of the

1976 standards.  The Act also directs that if a suspension is granted,


then EPA must set interim standards representing the best available

technology.  The EPA Administrator set an interim standard of 2. 0

grams per mile of NOx for the 1976 model year vehicles.

     On the basis of information submitted during the course of the

hearing by the applicants, other foreign and domestic automobile manu-

facturers, and catalyst and substrate suppliers, EPA determined that the

technology was not available for compliance with  the 1976 standards.  The

hearing record indicated that the control of nitrogen oxides for the 1976

model year would involve a reducing catalyst.  However, the technical

problems associated with reducing catalysts, and the  greater complexity

of the NOx control system over the oxidation catalyst  system used to control

HC and CO indicated that the state-of-the-art would not permit meeting

standards by the 1976 model year.  Reducing catalysts required more

precise air/fuel  ratios than  did oxidation catalysts, they suffered from

durability problems, and the integration of the NOx emission control

system was more difficult than was obtaining a workable HC and CO

emission control system. Although evidence presented by the manu-

facturers established that progress had been made in  developing catalyst

sensors at the bench test level, insufficient data existed in the  record

to support a prediction that the basic technical problems of durability

and  system integration could be overcome by the  1976 model year.

     Evidence was also presented at the hearing indicating that  the Honda

and CVCC engine could achieve the statutory 0.4  NOx level on light-weight

cars.  However,  the CVCC engine had  not demonstrated its capability

to control NOx emissions on heavier cars, and insufficient lead-time

existed to convert a significant fraction of the engine production lines

to CVCC technology by the 1976 model year.


    The National Academy of Sciences (NAS) also confirmed that the tech-

nology was not available to reasonably predict success in meeting the

0.4 NOx standard on 1976 model year vehicles.  The NAS report conducted

under the Clean Air Act, concluded that no vehicle equipped with a dual

catalyst system (oxidation and reducing catalyst)'had exhibited the necessary

durability to meet the 1976 standard, and that there was no certainty that

such technical problems could be solved by the manufacturer in time for the

1976 model year.

    With respect to the good faith requirements of the Act, EPA determined

that the manufacturers had made "good faith" efforts toward achieving

the 1976 standard although the record indicated that there did appear to be

a lack of cooperation between manufacturers and suppliers.  Each appli-

cant for a suspension request was determined to have spent extensive funds

on research and development of NOx control technology.  This factor,

coupled with the fact that the manufacturers were progressing toward

meeting the 1976 standard at the same rate they had been progressing

toward meeting the 1975 HC and CO standards, enabled EPA to find that the

manufacturers had met the good faith requirements of the Act.

    EPA also determined that granting a suspension for 1  year of the effective

date of the 1976 motor vehicle emission  standards would be essential to the

public interest.   EPA had determined that the technology was not available

to enable compliance with the 1976 standards by the 1976 model year.  Con-

sequently,  granting a 1  year's suspension would be in the public interest

since without  available technology, the auto industry would be  forced to

shutdown if a  suspension were denied, and the technology was  not available.

Evidence was  also presented indicating that the  sale of 1 year's vehicles

meeting the interim standard set by EPA would not significantly increase


NOx emissions, or significantly impact air quality levels. Although two other

factors touching on the public interest issue were  surfaced at the hearing,

insufficient evidence existed to make a conclusive finding or to enable these

factors to weigh heavily on the public interest decision.  Information

received in the hearing record indicated the possibility that reduction

catalysts might impose significant fuel economy penalties, and that HC and

CO emissions due to reduction catalysts might increase.


     A number of EPA regulations proposed and  promulgated during the

year will also help reduce air pollution from motor vehicles.

          1.  Regulations for Light-Duty Diesel Passenger Vehicles

     Regulations for the control of exhaust pollutants from diesel-powered

light-duty  passenger vehicles to be effective with the  1975 model year

were promulgated on August 7, 1973 (38 F.R. 21348).  Currently,  about

8, 000 of the approximately 10 million light-duty  vehicles sold in the United

States are diesel-powered.  Due to the ease with which these vehicles

can be made to meet emission standards and their inherently excellent fuel

economy,  the proportion of diesel-powered light-duty vehicles is expected

to increase. These vehicles will nowbe required to meet the same emission

standards  that are applicable to gasoline-fueled  light-duty vehicles.

           2.  Regulations for Light-Duty Gasoline Trucks

    Regulations for control of emissions from light-duty gasoline fueled

trucks, effective with  the 1975 model year,  were promulgated on

August 7,  1973 (38 F.R.  21363).  (A light-duty truck is defined as  any

motor vehicle weighing 6, 000 pounds or less, which is designed primarily

for transporting property or is a derivative of such a vehicle, or has


special features enablng off-street operation.)  This action was in

response to the U. S.  Court of Appeals decision regarding emission standards

for 1975 model year light-duty vehicles (International Harvester Company vs.

Ruckelshaus,  D. C. Cir No. 72-1517, Feb.  10,  1973) in which the Court

ordered EPA to remove light-duty trucks from the light-duty vehicle category.

The new emission standards for light-duty trucks are significantly more

stringent than the 1974 standards, but are slightly less stringent than the

interim 1975 standards for light-duty vehicles.

          3.  Regulations for Light-Duty Diesel Trucks

     Regulations for  the control of diesel-powered light-duty trucks were

proposed on January  25, 1974 (39 F. R.  3276).   Currently, no such vehicles

are known to be marketed in the United States.  However, prior to this

proposal, at least one manufacturer notified EPA of plans to market  a

light-duty dies el truck.

     The standards contained in the proposal are the same as those promul-

gated for light-duty gasoline-fueled trucks and are expected to be met

through application of existing technology.  The standards would be appli-

cable beginning in the 1976 model year.

         4.  Motorcycle Regulations

     An Advance Notice of Proposed Rulemaking to control emissions from

new motorcycles was published on January 17,  1974 (39 F. R.  2108).  The

need for control of motorcycle emissions stems from the increasing

number  of  motorcycles in the urban  environment and their relatively high

emission levels  compared  to new cars.   The Advance Notice of  Proposed

Rulemaking communicates to motorcycle manufacturers the course of

action EPA  is considering  regarding the stringency and timing of motor-


cycle regulations, thus providing them with the maximum possible lead time,

and also seeks comments on technical aspects of the regulations.

     Many factors--for example, increased personal income, increased

leisure time,  improved products and greater general public acceptance--

have caused the motorcycle population to expand sharply over the past few

years.  EPA estimates that 2. 3 million motorcycles will be offered for

sale in 1976,  compared with a projected 12 million automobiles.  On the

average,  an uncontrolled motorcycle emits 20 times more hydrocarbons

per vehicle mile than an automobile controlled to the 1977  standards.

The average motorcycle however,  annually travels only one-third the miles

of the average automobile.  Based on these data, the new motorcycles sold

in 1976 and thereafter will, if left  uncontrolled,  add a greater hydrocarbon

burden to the atmosphere than all new automobiles sold in  each  of those


    In addition, the proposed rulemaking for the Approval and Promulgation

of Implementation Plans (40 CFR Part 52) for the  States of Arizona,  California,

and New Jersey includes certain limitations on the registration  and operation

of motorcycles.  These limitations are necessary to reduce total hydrocarbons

and carbon monoxide levels in those  regions and to prevent a counterproductive

shift from automobiles to motorcycles as a result of other elements of the

control strategy.  The proposed rulemaking states,  "in an attempt to remove

the ceiling on motorcycle registration,  the Agency will evaluate the feasibility

of establishing emission standards for new motr   -vcles and will evaluate the

"availability of motorcycle emission control tec., ^xogy for  meeting emission

standards for retrofit. " In comments  submitted to EPA in response to this

proposed rulemaking, the motorcycle industry stated that technology is


available and can be implemented with reasonable production lead time.

       5.  Non-Methane Hydrocarbon Exhaust Emission Standards

    On May 10, 1974, an Advance Notice of Proposed Rule Making was

published for conversion of current standards for motor vehicle hydro-

carbon exhaust emissions to a nonmethane basis (39 F. R.  16904).  This action

was in response to a formal petition by Ford Motor Company for such an


    The rationale set forth in Ford's petition may be summarized as follows:

(1) Methane is a photochemically non-reactive hydrocarbon;  (2) Catalyst-

equipped vehicles  are likely to have a greater proportion of methane in their

exhaust than current vehicles;  (3) Current standards limit emissions of all

hydrocarbons including methane, thereby penalizing catalyst-equipped vehicles;

and (4) this penalty creates a hardship by making it more difficult to control

NOx and causing fuel economy  to suffer.

    Ford did not provide any evidence to support its contention of hardship

and informal contacts with other manufacturers indicated a difference  of

opinion on the need to adopt a non-methane based standard.  Therefore,

EPA's position is  that additional information justifying the need for the

change is required before it can embark on a program to develop regulations.

The Advance Notice of Proposed Rulemaking is aimed at obtaining the  comments

of other manufacturers and interested parties so as to allow EPA to base its

decision on the merits of the issue.

       6,  Revision of Motor Vehicle Cerification  Regulations	

       On  February 27, 1974,  the Agency promulgated regulations

designed to accomplish three main purposes: (1) to clarify certain re-

quirements pertaining to vehicle emissions certification and provide

that certification may be denied (or revoked) on account of a failure


to comply with such requirements (principally, the requirements

provide for the right of entry into manufacturers' facilities for EPA

personnel in order to perform inspections); (2) to clarify that the

Administrator will not certify any vehicles employing Auxiliary

Emission Control Devices which have been determined by the Admini-

strator to be "defeat devices", and (3) to provide that once the regula-

tions are in effect production vehicles which do not conform in all

material respects to the same design specifications that applied to a

certification vehicle will not be  covered by the certificate of conformity.

        The regulations spell out in much greater detail than previously

the kinds of records a manufacturer  of motor vehicles or engines must

compile and keep, and the kinds  of inspections it must consent to in

connection with certification and production facilities.   They also state

 explicitly that failure to comply with any of these requirements may

 result in a denial or revocation  of certification for vehicles affected

by the failure.  Finally, they provide that all these record-keeping and

inspection  requirements apply to facilities and manufacturers located

 overseas just as much as those  located in this country.

        7.   Regulations Defining Certificate of Conformity

        The Certificate of Conformity is issued by the EPA Administrator

to manufacturers of motor vehicles upon completion of emission and

durability testing of prototype vehicles.   Every automobile sold in the

United States must have a valid  certificate stating that the motor vehicle

complies with all applicable Federal motor vehicle emission standards

in effect at the time.  EPA will  propose regulations to define the

degree of similarity required between prototype vehicles and their pro-

duction counterparts.  This regulation is a clarification of the language


of the Motor Vehicle Certification Regulations of Feb 27,  1974 (#6 above),

and will allow EPA to more closely control changes to production vehicles

that manufacturers may make. Manufacturers in turn will be able to

make changes with more confidence that the validity of the Certificate

of Conformity will not be affected.  The regulations include a list of

"critical vehicle configuration parameters" which if changed, would

affect exhaust emission levels.

       8.  Regulations for Certification at High Altitudes

       On Oct 12,  1973, EPA published a Notice of Proposed Rule-

Making which would require that new motor vehicles offered for sale

in high altitude regions of the Nation,  be certified for compliance with

Federal emission standards at high altitudes (38 FR 28302).  Under

the current certification process, vehicles are tested in Ann Arbor,

Mich., at essentially sea level conditions; those complying with the

standards may be sold anywhere in the Nation, including areas at high

altitudes.  The Clean Air Act requires that all new vehicles,

wherever sold or operated, meet Section 202 emission standards.

EPA has proposed these regulations because its  studies of comparative

emission levels of various United States cities show that vehicles at

high altitude have higher emissions  than those same vehicles at low al-

titude.  For 1968 through 1971 vehicles tested in Denver,  carbon

monoxide and hydrocarbon levels were 60 percent and 50 percent res-

pectively, above the national average.  Three air quality control regions

at high altitudes--Denver, the Wasatch Front (Salt Lake City,

Odgen, and Provo, Utah),  and El Paso, Texas/Las Cruces Alamo-

gordo, New Mexico--have ambient air levels high enough  to require

transportation controls. Substantial improvements in ambient air


quality in these regions are expected to come from the new Federal

emission standards for autos if new autos are equipped to meet the

emission standards at high altitude.

      The additional cost to the automobile manufacturer for each vehicle

sold at high altitude is estimated at a maximum of $14 to $19.  This

includes: 1) an estimate by EPA of $4 per vehicle for additional certi-

fication costs and 2) estimates by an automobile manufacturer and the

National Academy of Sciences which gave a range of $10 to $15 for the

cost of a device which would automatically adjust the engine for correct

operation at any altitude up to about 6, 000 ft.  Such automatic  altitude

sensing and adjustment devices, however, are not required.  If the

vehicle is only made to meet the standards at high altitudes the addi-

tional cost per vehicle of these  regulations beyond the $4. 00 per vehi-

cle additional certification costs is expected to be negligible.

             9.   Regulations for Certification of Low-Emission Vehicles

      The purpose of regulations for certification of low emission

vehicles is to encourage development of vehicles with significantly

lower emission levels than vehicles certified to meet Federal  emission

standards.  Vehicles so certified are then eligible for purchase by

the Federal Government at premium prices.  The present vehicle

certification regulations are applicable to 1973 and 1974 model year

light-duty vehicles.   On July 13, 1973, EPA proposed regulations ex-

tending the provisions to 1975 and later model year light-duty  and heavy-

duty vehicles (38 F.R.  18686).  Comments received in response to

these proposed regulations have raised serious difficulties in promul-

gating certification regulations  for low emission heavy-duty vehicles.

The primary difficulty is the lack of appropriate test procedures


and test instrumentation for certification.  Resolution of the

technical difficulties is expected shortly.

           10.  Regulations Defining Exclusions and Exemptions

      On March 21,  1974 EPA proposed regulations defining which motor

vehicles are subject to the requirements of the Clean Air Act.  (See

also Chapter V).

Essentially the regulations  provide:

      o criteria to be used in interpretation of the term
         "motor vehicle" as defined in Section 213(2) of the
         Clean Air Act.

      o  types of exemptions allowed under Section 203(b)  and
         203(c) of the Act.

      o  procedures by which EPA will administer the granting
         of such exemptions.

These regulations will save the manufacturer costs of installing

certified engines in vehicles which are excluded or exempted from

the Clean Air Act requirements.

            11. Recall  Regulations

      Recall regulations were proposed for comment on March 25,  1974.

They are designed to provide for procedures to implement  the recall

provisions in Section 207(c)(l) and (2) of the Clean Air Act. The Act

requires that when a vehicle or engine manufacturer is notified that a

recall order has been lodged against him, he submit a plan to remedy

the emissions problem. This plan includes notification of  owners that

their vehicles (or engines) should be brought to  repair facilities and

that the vehicle (or engine), if properly maintained and used, will be

serviced at no expense to the owner.  The manufacturer may request

a hearing to contest the recall decision.  The  recall regulations imple-

ment these statutory requirements by describing the content of the  re-


medial plan and owner notification letters.  Furthermore, the regula-

tions describe the reports that a manufacturer must submit to allow

the Administrator to evaluate the effectiveness of the  recall campaign.

Finally,  formal hearing procedures are included in the regulations to

provide the manufacturer a public forum in which to contest a recall

decision.  (For additional information on the recall program see

Chapter  V).

           12.  Regulations for Importation of Catalyst-Equipped Vehicles

      EPA plans to amend current regulations governing the importation

of motor vehicles and motor vehicle engines.  (Subpart P, Part 85  of

Title 40  of the  Code of Federal Regulations).  The purpose of the amend-

ment is  to assure that vehicles equipped with catalyst converters and

imported into the United States after having been driven abroad on

leaded gasoline are brought into conformity with U. S. emission

standards.  This is necessary because lead in gasoline deteriorates

the catalyst.

      EPA proposes to deny entry to catalyst-equipped motor vehicles

which have been operated in countries where unleaded fuel is not

available.   Conditions of exception to this denial of entry are:

      1)  An Internal Control Program by the Vehicle  Manufacturer which

      must be approved by EPA.  This program will insure that a catalyst

      is  initially installed or replaced upon importation of vehicles sold

      under this control program.  The cost to the manufacturer has not

      been assigned any dollar estimates but involves costs to the manufac-

      turer of developing and administering the internal control program;

      2)  An Internal Control Program developed and  administered by

      the State  Department and the Department of Defense for their


     own personnel;

     3)  Posting of a Bond by the Individual Importer. (Generally an

     individual consumer)  This involves posting of a temporary bond

     by the importer equal to the value of the vehicle plus duty.  The

     bond is released once a new catalyst is installed or a contaminated

     one  replaced.

     C.  Fuel Regulations

          1.  Fuel Regulations for Lead-Free Gasoline

     Fuel Regulations were promulgated January 10, 1973 to insure

that lead-free gasoline would be available to owners of automobiles

equipped with catalytic converters.  Availability of lead-free gasoline

(gasoline in which the amount of lead does not exceed . 05 grams of lead

per gallon) is necessary because lead in gasoline deteriorates the

catalytic converter components.

     The regulations require that all gasoline stations selling more

that 200, 000  gallons annually offer unleaded gas for sale at at least

one pump by  July 1, 1974.  On May 7- EPA issued a Notice of

Proposed Rulemaking to increase the general availability of unleaded

gasoline in rural counties.  This required that gasoline stations selling

over 150, 000 gallons annually and located in counties having a popu-

lation density of less than 50 people per square mile, offer unleaded

gasoline for  sale.  A Supplemental Notice of Proposed Rulemaking was

published July  3, 1974 which proposed to advance the January 1, 1975

compliance date for rural counties to October 1, 1974.

     There is a small additional cost to the manufacturer of 0. 1 cent

per gallon above the combined  cost producing regular and premium gaso-


line.  There is an additional cost of 0. 5 cent per gallon to the industry

for distribution and marketing of lead free gasoline.

            2.  Fuel Regulations for Low-Lead Gasoline

      On January 10, 1973 EPA promulgated regulations  requiring the

amount of lead in gasoline to be reduced to an average of 1. 25 grams

per gallon by January 1, 1978.  On November 28, 1973, EPA

announced that revised lead regulations had been promulgated which

provided for a phased reduction in the average lead content of all

grades of gasoline produced by any refinery over a 4 year period.

Refineries are restricted to 1. 7 grams per gallon beginning

January 1,  1975, with annual reductions to 0. 5 grams per gallon by

January 1,  1979.  The incremental gasoline production costs vary from

zero in the  first several years to a maximum of 0. 1 cents per gallon

of gasoline  in 1979.   Reporting requirements necessitated by these

lead phase down regulations impose a minimal additional cost to re-

finer or lead additive manufacturer.

          3.  Regulations  for Registration of Fuels and Additives

      On March 7,  1974,  EPA proposed additional regulations to

establish procedures to obtain basic information about fuel and fuel

additives. Such information is needed to determine the effects which

additives or their combustion products may have on emission control

devices (particularly catalytic converters) or on the public health or


      The proposed regulations prohibit the sale,  or introduction into

commerce,  of fuels or fuel additives designated by the EPA Admini-

strator after specified dates, unless such fuels or fuel additives have

been registered with EPA.


      To register fuels or fuel additives, the manufacturers must submit

information as specified in the proposed regulations, and, in some cases,

perform tests to determine potential public health effects of the fuels

or additives in accordance with protocols and procedures to be

established by EPA.  For additives, such information includes their

chemical composition.  For fuels, it includes the commercial name

and manufacturer of any additive contained in the fuel, the range of

concentration of any additive in the fuel, and the purpose-in-use of any

such additive.  Other information, such as chemical and physical

properties of a fuel, is also to be furnished.

      The cost to the fuels manufacturer in conforming with these regula-

tions  is estimated as the  cost of submitting initial information and quarterly

updating information.  The cost of initial notification is estimated as $150, 000

and annual updating costs are estimated at $350, 000. The cost  to the fuels

additive manufacturer is  the initial reporting cost estimated at $25, 000-

30,000 and the cost for reporting new additives estimated at $2,000  per year.

During the 1973/74 fuels shortage, mobile source emissions were
reduced and air quality improved in some localities as motorists
cut down on highway driving.  EPA is currently exploring alternative
power systems and fuels to alleviate the problem of relying predom-
inately on gasoline.  DOCUMERICA-Bob W. Smith


Chapter III.  Progress in Emissions Reduction Technology

   A.  Alternative Automotive Power Systems Program

   During the past year,  EPA continued its program to evaluate  and

develop alternative automotive power systems (AAPS) to the conventional

internal combustion engine.  The evaluations of alternatives coming from

this program are expected to provide factual information to Federal

policy makers, Congress, and the American public on what can and

cannot be accomplished in automobiles with respect to achievement of low

emissions, good fuel  economy, and satisfactory road performance.

   The program began in July 1970 with preliminary technical eval-

uations of known power systems. These initial evaluations resulted

in a ranking of the systems primarily on the basis of their potential

(if developed) for achieving what are now the statutory 1978 Federal

emission standards. This ranking was followed by preliminary design

studies on the highest ranked systems. In 1971 further evaluations

of all the designs provided added confidence that the three highest ranked

systems should proceed into hardware development.

   The three types of systems being developed were the internal com-

bustion engine employing  the stratified charge combustion process,  the

gas turbine engine, and the Rankine cycle engine.

   1.  Conventional and Stratified Charge Engine

   The gases emitted by  automobile exhaust are the waste products of

combustion.  In a typical automobile,  gasoline (a hydrocarbon fuel)

is fed from a tank to a carburetor where it is mixed with air. This

mixture is then drawn into the cylinder, where it is compressed and

ignited by the spark plug (Figure III. 1), the resulting explosion forces

the piston down the cylinder.  This is the power stroke which is

transmitted through various shafts and gears to drive the car. When

the piston is at the bottom of its down stroke,  the cylinder  is  full

of hot gases--unburned hydrocarbons,  carbon monoxide, nitrogen

oxides,  and carbon dioxide--water, particles of lead, and  other  com-

pounds.   Then the piston rises to  expel the  remaining gases through

an exhaust valve,  and the cycle is repeated.  This action is repeated

in each of the engine's cylinders.
                           Figure III-l
                     Internal Combustion Engine
                              Four-Stroke Cycle
                      2. COMPRESSION        3. POWER
                                                        4. EXHAUST
                          Front cutaway of V-engine

                          MIXTURE*  \ SPARK
                                6V0  \ PLUG


                       Illustrations in this section are highly
                       simplified schematics  to  show only
                       pertinent functions.

    The stratified charge engine is a refinement of the conventional

engine that features a more efficient combustion process.  This engine

is spark ignited, gasoline fueled, and uses much of the hardware of the

conventional engine,  with the difference that a "layered"  or "stratified"

fuel mixture is used in the  combustion chamber.  The central idea

is to supply a rich mixture of fuel near the point of ignition inside the

cylinder, but keep the rest of the mixture lean.

    One type of stratified charge engine that has been developed uses a

small precombustion chamber in the cylinder head (Figure III. 2).  The

small chamber which contains the spark plug, is supplied a rich air

fuel mixture by one carburetor through the third valve.  A lean air

mixture is supplied by the other carburetor to the normal chamber

through the normal intakes.  The rich mixture in the small chamber

provides good ignition, and the flame spreads to the lean mixture.

Burning the cylinder is slower  and more efficient than in conventional

engines and by prolonging the combustion,  most exhaust pollutants are

burned up inside the cylinder.

                              Figure III. 2

                    Stratified Charge Engine System

                ' LEAN
                '. FUEL-AIR
                       2. COMPRESSION
                                         3. POWER
                                                       4. EXHAUST


    The stratified charge engine is no longer a part of the AAPS pro-

gram.   In 1973  the technologies associated with this process had pro-

gressed to.an advanced phase of development beyond the scope of the

AAPS program.  The original AAPS work on the  stratified charge

process was in direct support of an ongoing U.S. Department of the

Army program aimed at applying this combustion process to Jeep

engines. The Army has continued with the development of the  stratified

charge  process to the point where engines are being "soft tooled" for

limited production, test, and evaluation.  In addition,  one manufacturer

plans to market 1975 model year automobiles equipped with stratified

charge  engines.  This same manufacturer is the  only manufacturer

who did not apply for suspension of the  1975 statutory  standards.

     2.  Gas Turbine Engine

     In  conventional engines, the basic combustion process of com-

pression, heating, and expansion occur successively in the same

component--that is, one cylinder.  In the gas turbine engine,  on the

other hand, the processes  occur simultaneously and .continually in

different components—that is compressor,  combustor, and turbine.

Air is taken in by the compressor, compressed to a higher pressure

and then delivered to the combustion chamber where it is mixed with

fuel and burned.  The  resulting high-temperature, high-pressure gas

runs the turbine  (Figure III. 3).  Part of the shaft power developed

by the turbine is  used to drive the compressor; the remainder is the

output used to drive  the vehicle and the accessories.

    An advantage of the turbine is that  combustion can be adjusted

for very efficient burning of the fuels,  thus  minimizing pollutants

in the exhaust.

                     Figure  III.3
                  Gas Turbine Engine
 AIR __»
                           GAS TURBINE

                                                 1 «
                                       FINAL DRIVE GEARS


   Gas turbine development research has progressed well over

the past year.  Significant work is underway at solving three current

problems: relatively high emissions of NOx, poor fuel economy, and

high manufacturing cost.

    During the past year,  seven engines have been built, and three

installed in automobiles.  The  engines have been run on engine

dynamometers by contractors and by the NASA Lewis Research Center

in Cleveland,  Ohio.  Complete engine performance curves

(e.g., plotting horsepower versus revolutions per minute) have been

obtained from this testing.  Vehicle performance also has been docu-

mented from road and chassis  dynamometer testing.   These data

have provided a baseline on which improvements are being made in

the three problem areas.

    The development of a  low emission combustor (means  by which

energy is added to the system) continued.  The new hardware has

evolved from test equipment used earlier in lab tests.  These  tests

proved that the combustion concept, which uses a variable geometry

combustor with pre-vaporization and pre-mixing of the fuel and air,

can  achieve emission levels  (NOx included) lower than the statutory

levels.  The  test combustor  has been successfully run when installed

in the  complete engine mockup and is being shipped to the  contractor

for further tests  in the vehicle.  The combustor is large,  and  size

reduction will be emphasized in future development work.

    Work to improve fuel  economy is progressing in many areas.

For example, the new and improved designs have been completed for

all aerodynamic components.  Tests have been conducted to verify the

use of water injection  as a means of boosting power and permitting use


of a smaller basic engine size.  The new designs for variable inlet

guidevanes also have been completed.  Work is continuing on finding

ways to reduce and to recover heat losses occurring within the turbine.

In total,  the  effects of these changes when implemented with hardware

could mean a 50 percent improvement over fuel economy of current

gas turbines which would bring fuel economy of gas turbines in line

with that of conventional engines.

    In addition to working on these methods within the engine  for im-

proving fuel  economy, work was initiated on another important area

outside of the engine itself.  This new work is focusing on the develop-

ment of a continously variable transmission.  If successful, this type

of transmission could improve the vehicle fuel economy as much as

30 percent over the already improved gas turbine.

    Manufacturing costs will be reduced both from use of ceramic material

and advanced casting techniques for making rotating components.   With

the assistance of the Department of Defense and the National  Aeronautics

and Space Administration, all ceramic work else'v^iere in the United

States is under review; promising materials will be made available to

the EPA program as soon as possible.   Development work sponsored

by the program  on ceramic heat exchangers continued during the past

year, with a  new project to test and evaluate all known ceramic heat

exchangers planned to begin in the Fall of 1974.

    The project  to develop new and low cost casting techniques also

continued during the past year.  In areas relating to new materials and

manufacturing techniques, progress  has been typical of this type of

work--steady but slow.

    The upgraded version of the engine embodying all of the improve-


merits noted here will be used to determine the overall improve-

ment in emissions, fuel economy, and manufacturing costs.  A

potential health problem of nickel  oxide emissions from  gas turbine

engines equipped with nickel oxide rubbing seals has been identified.

Efforts have been initiated to develop   alternative seal materials.

    3.   Rankine Cycle Engine

    The Rankine cycle system is an external,  continuous combustion

engine in which high pressure steam or other working fluid vapor is

expanded in either a turbine or a piston-type expander to produce work.

A pump draws liquid from a condenser and forces it under high

pressure into the vapor generator> where it is competed  to superheated

vapor by the heat from combustion in the burner.  The hot, high-

pressure vapor is then metered into the  expander where it produces

usable power.  The vapor expands to a low pressure and is then

cooled and converted back to a liquid in the condenser.  The resulting

low-pressure liquid is then returned to the vapor generator by the pump

to repeat the cycle.

    During FY 1973, four versions of the Rankins cycle were under

pre-prototype system development and were  in competition for selec-

tion as the prime system and the backup system to be developed in the

prototype phase.  These four versions covered use of organic materials

and water as working fluids and reciprocators and turbines as the ex-

panders.  Since fuel economy is an imporant factor in any change in

engines to be produced for the consumer,  strong emphasis was placed

on improving this characteristic.

    Three of the four  systems were tested  on engine dynamometers and the


test data evaluated.  In particular, the various versions of Rankine cycle

were compared on the basis of their emissions and fuel economy for the pre-

prototype  version and on the projected weight, volume,  size, and

complexity for the prototype version of each.

   All of the engine versions displayed very low emissions, as

expected from the basic Rankine cycle combustion process (atmos-

pheric pressure and temperature).  The fuel economy of both turbine

versions was relatively low becasue of inefficiencies at low loads.

The organic turbine was considerably larger than the water turbine,

mainly because of the size of  the heat exchangers.  These evaluations

led to the selection of the water reciprocating (steam) system as the

prime system and the organic reciprocating system as the backup.

   The work on the steam engine will continue on the engine dynamo-

meter,  with emphasis on developing the control system and on further

improving fuel economy. Current plans call for a  complete engine  system

to be installed in a vehicle with the purpose  of completing of deve-

lopment of the control system.  The vehicle, a full sized car, will

be tested  on a chassis dynamometer late in 1974.  In addition to vehicle

oriented work, component development is proceeding in the areas of freeze

protection and in the overall reduction and recovery of waste heat.  The

work on the back up system will be limited to engine dynamometer testing

to further develop the control system  and to improve fuel economy.

   4.  Demonstration Vehicles

   By the Fall of 1972 development of the gas turbine and Rankine

cycle systems had progressed to the point where laboratory tests showed


that what are now the 1978 model year statutory levels had been met.

EPA felt that continued refinement of the concepts demonstrated that

stringent emissions would be met when combustor hardware appeared in

demonstration vehicles.  As a  result, program development activities focused

on fuel economy.  The 1970 plans originally called for complete system

testing and demonstration in automobiles by 1975,  followed by final

evaluations.  These demonstrations were to be made in full size automo-

biles of about 4, 500 pound test weight, the size most often purchased.

    In 1973, to further emphasize the importance  of fuel economy and

to encourage greater use of smaller  automobiles, the demonstration

size vehicles were changed to compact size  (3, 500 pounds maximum).

Work is now proceeding on the smaller engines required.  As a

result of this change, system demonstrations have been moved back

approximately  6 months with demonstrations planned in FY 1976.

B.  Federal Clean  Car Incentive Program

    The Federal Clean Car Incentive Program (FCCIP) is designed to

promote private development of new  types low-emission vehicles capable

of meeting what are now the 1978 model year emisssion standards.  The

program offered financial assistance to private manufacturers engaged in

developing low-emission prototype vehicles.  The first phase of the

program consists of a developer leasing to the Federal government a

candidate prototype vehicle which is  subjected to rigorous evaluation

by EPA.  After a prototype successfully passes the stringent emissions

and performance testing, EPA may purchase 10 more prototype cars for

more comprehensive testing.   The Government may later buy up to 500

vehicles  for further evaluation and limited fleet use.


    The program began in January 1971 with 20 initial proposals from

industry.  Seven different vehicle systems were accepted into the

program. Four withdrew prior to FY 1974; one more entry withdrew

during the past year because of failure to achieve the required emission

levels coupled, with lack of corporate finances to continue the develop-

ment.  Thus far two types  of prototype vehicles have been delivered

and tested.

    One vehicle tested was in internal combustion engine car with

catalytic exhaust treatment and exhaust gas recirculation (EGR).

The emissions often met the 1978 model year standards but were not

consistent.   Durability was not acceptable, and several catalytic

converter replacements and catalyst additions were required during

testing.  This car was not accepted for the second phase of the program.

    The second prototype car delivered and tested was  a hybrid heat

engine/battery car using a Wankel engine with thermal reactor and

exhaust gas recirculation and an array of lead-acid batteries. Emission

levels in test samples were sometimes quite low, but were not consistent.

This inconsistency was at least partially due to the relatively undeveloped

carburetion controls used in the prototype vehicle.  Fuel economy on the

city driving cycle used in certification testing was similar to other 1974

vehicles at the same inertia test weight.  Some relative improvement in

fuel economy was indicated in several highway mode tests.  The complete

test results for this system are under evaluation.  Additional tests appear

to be needed before completing the evaluation and making recommendations

for or against continuing this vehicle in the FCCIP.


     Much has been learned from formulating and implementing this

program.  Specifically, EPA has found that it is extremely difficult

to provide adequate financial incentive to independent developers of

new engine systems under conditions where the  Federal Government

would purchase, test  and  evaluate only the end product of a developer's

efforts.  Considerable monies (amounting to several millions of dollars)

must be available to the developer during development of the hardware,

rather than after development is completed.  Currently, EPA is  aware of

no mechanism in the Federal Government  to support this type of work other

than by normal Federal R&D contract procedures.  In this case,  the

development would  be part of a Federal program and not a privately

sponsored program, as was the original intention of the FCCIP.  Thus,

FCCIP cannot provide enough financial incentive to compensate independent

developers for the financial risks they must  take. As a result, the program

will be terminated after evaluations are completed and recommendations

made on the  one remaining car.

C. Low-Emission  Vehicle Purchase Program

     Section 212 of the Clean Air Act provides for the creation of a Low

Emission Vehicle Certification Board.  Upon submission of an application,

the EPA Administrator must determine whether or not a vehicle  qualifies

as having emissions substantially lower than standard levels.  The Board

then has  the  responsibility for certifying whether a vehicle is suitable for

use as a substitute  for any class of vehicle then in use by the Federal

Government.  Certified vehicles may be purchased for use in Government

fleets at  premiums  ranging up to 100 percent over prices normally paid

by the Government  for equivalent vehicles.


    Three applications have been received for certification under Section

212, all covering electrically powered vehicles.  The EPA Administrator

has determined that the vehicles described in these applications are powered

by inherently low-polluting propulsion systems.  The LEVCB has met

twice during this past year and has rejected the first two applications on the

basis that the vehicles covered are not suitable substitutes for any existing

class of vehicles currently procured for use by Federal agencies.  The third

application is being reviewed.

D.  Feasibility of Alternative Fuels

    The energy crisis brought with it an awareness of the need to reduce

consumption of petroleum fuels.  In addition,  most automotive emission

pollution stems from the chemical make-up of petroleum fuel.  Recognizing

this,  EPA initiated contract studies in July 1973 to assess the technical

and economic feasibility of alternative fuels that were compatible with

objectives of reduced automotive emissions and improved automotive fuel

economy.  As used here,  "alternative fuel" applies to fuels derived from

nonpetroleum resources in abundant supply in the United States.

    The studies have shown that the most  promising alternative automotive

fuels are synthetic gasoline and distillates derived from coal.  Hydrogen

fuel may be possible by the year 2000.

    Based on these findings, further work has been initiated to fill identified

reaseach and data gaps for the  leading synthetic fuels.  Under EPA funding,

the Bureau of Mines began testing of engine combustion characteristics

using alternative fuels in April 1974.  Other studies recently initiated include

combustion testing of a more fundamental nature through university grants,

 and studies  to assess the impact of United States production, distribution

and utilization of the alternative fuels.


E. Assessment of Progress

    1.  EPA Assessment

    More than 70 percent of all 1975 model cars are expected to be equipped

with catalysts, a considerably larger number than EPA's earlier

expectations.  The 49 State interim standards for the 1975 model year

(excluding California) permit manufacturers to choose between catalyst

and noncatalyst systems. The greater than expected use of catalysts for

the 1975 model year is  due  to the fuel economy advantage they offer.

    The sales-weighted fuel economy of the 1975 model year fleet,

assuming the same model mix in 1974 and 1975,will be at least 8 percent

better than the 1974 fleet (in addition to catalysts, changes in carburetion,

lower  axle  ratios, and electronic ignition systems will contribute to

improved fuel economy),  according to estimates made by major automobile

manufacturers at hearings Nov.  6, 1973 before the Environmental

Subcommittee of the Senate Committee on Public Works. Not all

manufacturers will achieve gains,  and in some cases there will be fuel

economy loss.

    In  meeting past emission standards, most manufacturers used the  same

basic approach of engine modification (i. e., spark retard, intake manifold

preheating and faster acting chokes) and exhaust gas recirculation.

The 1975 models will utilize a greater variety of control approaches. Saab,

for example, will use fuel injection and no catalyst to meet both the Federal

and California interim standards.  Honda will use its compound vortex

controlled  combustion (CVCC) stratified charge engine. Mazda will use a

thermal reactor.

    Some companies—Mercedes-Benz, for example--may use two different

approaches to emission control on the same model.  Mercedes plans to

equip some vehicles with catalyst and other with thermal reactors.


Thermal reactors may be used because a substantial number of Mercedes sold

to U.S. customers are initially purchased and driven in Europe where unleaded

gasoline is not generally available.  The thermal reactor is not adversely

affected by the lead in the gas and will pass U. S. emission standards.

    EPA's technical staff have analyzed  extensive information provided

by automobile manufacturers under the provisions of Section 202(b)(4)

concerning their progress toward meeting the Federal emission standards.

The paragraphs which follow represent  the collective judgement of EPA

engineers directly responsible for the interpretation and analysis of the


    The probability is very high that manufacturers  will be able to certify

most of the line of vehicles in the 1974 model year at the 0.41 grams/

mile HC,  3.4 grams/mile CO,  and 2.0 grams/mile NOx levels required

by Congress for the 1977 model year. Fuel economy at these levels will

depend heavily on the advances made beyond the  systems designed to meet

the 1975 California interim standards.   If manufacturers do nothing but  add

spark retard to their California systems,  there will be some losses of fuel

economy on 1977 models relative to 1975 models. If manufacturers are

 willing to increase the costs of emission  control systems, such techniques

as improved catalyst formulation and configuration,  improved quick-heat

manifolds, and improved exhaust gas recirculation  can be used to make

the average fuel economy of 1977 models as good as or better than that

of 1975 models.

    Automobile industry research to  meet the Clean Air Act statutory

levels was drastically reduced during 1973 due to the uncertainty of

the necessity of meeting a 0.40 grams/mile NOx standard.  The primary

obstacle to meeting the standard with reducing catalysts or single bed


oxidation-reduction catalysts appears to be the lack of an advanced fuel

metering system.  The use of an oxidation catalyst in front of the

reduction catalyst shows promise of avoiding sudden increases  in oxygen

concentration caused by the lack of precise fuel metering for dual

catalyst systems.  In general,  a 0.40 NOx standard, the present

legislative  target for light duty passenger vehicles,  would be expected

to solidify the use of catalytic technology.

    The only manufacturer that has demonstrated the capability to  certify

at the 1978 standards is Honda with its CVCC engine.

    2.  National Academy of Sciences Study

    The Clean Air Act provided for the National Academy of Sciences to

study various aspects of emission control.  The Academy's first study

reported on the technological feasibility, initial costs, and operating

costs of emission  control systems designed to operate at the 1975

statutory levels.  The findings were summarized in last year1 s report.

    EPA signed a contract in December 1973 for a second study focusing

on the technological feasibility and cost of meeting various NOx emission

standards.   Other related parameters such as fuel economy, and the

relationships between vehicle weight, engine type, and NOx control,  are

also being investigated.

    The final report is due in October 1974.

Visible pollution increases during rush hour traffic in many
urban areas.  The top picture shows Portland ,Oregon at 9:30
in the morning; the picture below shows Portland at 2:30 in
the afternoon.  State of Oregon Sanitary Authority


                        EMISSION STANDARDS

A.  Costs of Meeting Emission Standards

    1.  Light Duty Vehicles

       a.  Emission Control Equipment--1975-1977 Model Years

    The new national Federal standards for HC and CO for the years 1975

and 1976 enacted with the passage of the Energy Supply and Environmental

Coordination Act will not necessarily require catalyst equipment to control

emissions of light-duty vehicles. The 1975 California standards, however,

will require almost all automobiles sold in California to have catalysts.

An estimated 70 percent  of all 1975 model year cars  sold in the United States

(including California) will have catalysts.  Costs of emission  control equip-

ment for  1975-1977 are estimated in Table IV. 1.  If 1977 model year

standards for HC  and CO are not suspended, catalysts will be required

on most 1977 model year cars.

       b.  Emission Control Equipment for 1978 Model Year

           Light-Duty Vehicles

    The capability of many different systems to achieve the statutory

1978 model year standards for NOx has been investigated. At this time,

 the dual  catalyst system has received the most attention because it is

compatible with the oxidation catalyst system many manufacturers will use

to meet the 1975 California interim  standards.  No drastic modifications

need to be made to the 1975 type system other than installation  of the

reduction catalyst upstream from the oxidation catalyst.  Minor changes

include recalibration of the carburetion and different plumbing of the air

injection  system.


                             TABLE IV. 1

               1974-1977 MODEL YEAR LIGHT DUTY VEHICLES
Cumulative costs through 1974
54. 53
     Quick heat manifold             5.00      4.75      	
     High energy ignition           15.00      12.35      	
     Advanced  carburetor         15.00      14.25      	
     Proportional exhaust gas       20.00      30.00(e)   	
     Air injection                  40.00      43.32(f)   	
     Subtotal for noncatalytic       	     	
        systems                    95.00     104.67       75-120
     Oxidation catalytic (in
       eludes long-life exhaust
     Cooling system changes
     Body revisions and
       material changes
     Assembly line changes
       and testing
     Cumulative costs through



65. 10
                                           $268.00   $234.30    $233-313
(a)   List price includes both dealer and manufacturer profits.
(b)   Economics of Clean Air; Annual Report to Congress,  EPA,  March 1972.
(c)   National Academy of Sciences.  Report by the Committee on Motor
      Vehicle Emissions.  February 12,  1973.
(d)    Estimated ranges, from domestic manufacturers.
(e)   1974 through 1975 model years.
(f)   1973 through 1975 model years


    The estimated costs of emission control equipment for the 1978 model

year based on use of a dual catalyst are shown in Table IV. 2.  EPA estimates

an incremental cost of $80. 00 for addition of a reducing catalyst.  Thus,

the estimated cumulative  cost of equipment per car to meet the 1978  standards

is $348.00

    The per-vehicle costs for emission control for light-duty trucks can be

considered equivalent to that for passenger cars through 1974, since both

types of vehicles are covered by the same standards and the power-plants

used are basically the same.  With light-duty trucks covered by separate

and less stringent standards beginning in the 1975 model year, per-vehicle

control costs for light trucks will become somewhat less than for passenger


    For this  report, it is  assumed that costs associated with emission

control for light-duty trucks of model years 1975-79 will be  the same

as  costs associated with noncatalytic 1975 passenger-car emission control


           c. Maintenance

    Maintenance costs for emission control systems are expected to rise

somewhat due to the increased complexity of emission control systems

and the addition of oxidation catalysts.   However, these costs will^pe more

than offset by the  addition of new electronic ignition components that do not

need to be changed and by the increase in the life of exhaust system and emission

equipment that will result fron use of lead-free gasoline.


                                TABLE IV. 2

                 for 1978 MODEL YEAR LIGHT DUTY VEHICLES
(b) (c)

Cumulative costs through      268.00    224.30      273-313
Reduction catalyst             80(e)      74.10       50-90
Electronic control            	       47.50       15.25
Sensors                      ~^^_       5.70      	

Subtotal                       80.00     127.80       65-115
               Cumulative costs through
                            $348.00    $351.60    $388-428
(a)   List price include both dealer and manufacturer profits.
(b)   Economics of Clean Air.  Annual Report to Congress,  EPA, March 1972.
(c)   National Academy of Sciences.  Report by the Comittee on Motor
      Vehicle Emission. February 12,  1973.
(d)   Estimated Industry ranges.
(e)   Revised EPA estimate, April 1973.


    The major component of any change in maintenance costs is the possible

requirement to change oxidation catalysts in order to maintain acceptable

exhaust emission levels.  Federal regulations allow one catalyst change after

25,000 miles, but do not require further  changes.  However, all three major

domestic manufacturers have stated that  their oxidation catalysts will last the

50, 000 mile design life of the car specified by the Clean Air Act.    This

is a substantial improvement in durability over the early catalysts.  As the

automobile and catalyst manufacturers have refined their designs, both

catalyst efficiency and durability have made significant gains. ( Table IV. 3).

           d.  Fuel Consumption Penalties

In 1973, EPA published the results of an  extensive study of passenger-car

fuel economy involving tests of nearly 4,000 vehicles ranging from 1957

production models to 1975 prototypes.

    EPA data from over 4, 000 tests on cars from the 1957 model year

through the 1973 model year show that there has been a drop  in fuel economy
                                                     (Table IV. 4)
due to emission controls in 1968-1974 cars of about 10% on the average

compared to uncontrolled (pre-1968) cars. In 1975, new cars are expected

to have a substantial increase in fuel economy; we estimate a 7-8% improve-

ment  over  1973/74 cars.  This is principally due to the installation of

catalysts to lower emissions, which allows the engine to be recalibrated

to improve fuel economy.

    In addition, installation of electronic  ignition systems and the use of

lower axle ratios and radial tires help to improve fuel economy.  Chrysler,

for instance claims fuel economic gains for 1975 model cars  of from 3-17%

over  comparable 1974 models.

    Similarly, General Motors has now claimed  a 15% overall improvement

for its 1975 models compared with 1974.

                            TABLE IV. 3

                                  ANNUAL MAINTENANCE COST
1975 -76
- 6.00
- 4.00
+ 4.00
SOURCE: EPA Memorandum:  "Analysis of estimated maintenance
          costs for emission control systems meeting 1975/1976
          federal standards, and progress reports on emission con-
          trol development submitted by Chrysler, Ford and
          General Motors, November 1973.
(a)   Incremental Costs over uncontrolled  vehicles.
(b)   Based on assumption that 75 percent  of 1975
      vehicles sold will employ catalystic emission -
      control systems.
(c)   Based on the use of dual-catalyst.


                       TABLE IV. 4

         MODEL YEAR

     1957-67 (uncontrolled)








     1975 (a)

     1976 (a)

     1977 (a)

     1978 (a)&(b)
      and subsequent years












SOURCE:  U.S. Environmental Protection Agency

(a)   Less certain than previous years since no
     firm basis is presently available for

(b)   Based on use of a dual-catalyst system with an
     advanced fuel-metering system or 3 way catalyst
     with feed-back control.


   If the statutory standards for hydrocarbons (HC), carbon monoxide

(CO), and more stringent interim standards for oxides of nitrogen (NOx)

are imposed in 1977,  then fuel economy may drop again, perhaps as

much as 3% from 1975 cars,  or a net drop of about 6% over uncontrolled

cars.  However,  this will still be a gain of about 4% over current models.

Estimates of the fuel  economy impact resulting from imposing the statu-

tory NOx deadlines on 1978 cars range from a  slight improvement over

1974 cars to a 9% penalty relative to 1974, depending on the emission

control system utilized.

        e.   Aggregated Costs

    The annual total cost is the sum of the pollution control equipment

costs on all new cars in that year, the cumulative maintenace costs for

all cars sold since  1968,  and additional fuel consumed (over uncontrolled

cars) by cars with emission controls (Table IV. 5).

    2.   Heavy-Duty Vehicles

    Separate emission control regulations have been in effect since

1970 for new heavy-duty gasoline and diesel truck engines  manufactured

for use in over-the-highway trucks and buses of over 6, 000 Ib. gross

vehicle weight (GVW). Trucks under 6, 000 Ib.  GVW are considered to be

light-duty and have been dealt with in a previous  section.

        a.   Gasoline Engines

    The emission control technology used for heavy-duty gasoline engines

through 1973  is similar to that employed for light-duty trucks and passenger

cars through the  1972  model year. In fact, many heavy-duty gasoline

engines are derivatives of passenger-car engines. For  1974, the NOx

control standards are generally attainable without the use  of exhaust  gas

recirculation (EGR).  However, some EGR engines were certified in the

                                                 TABLE IV.5

                                        ESTIMATED NATIONAL  COSTS FOR
                                  EMISSION CONTROLS FOR LIGHT-DUTY VEHICLES

Fuel -consumption
Fuel price

Annual National Cost $ billions
1968 (b)
























(a)  Vehicles less than 6,000 Ib. GVW including light-duty trucks.

(b)  No costs incurred nationally prior to 1968.

(c)  Fuel prices assumed:  $0.36/gal, 1968/71;  $0.40/gal,  1972; $ 0.45/gal, 1973;  $0.50 gal, 1974-79.
     Note that the fuel price figures are low and will affect the estimates.

(d)  The annual national costs estimates do not reflect negative maintenance costs  for  years 1975,  1976,
     1977.  That means that these figures are higher than  they should be.


previous year to meet California standards for 1973, which were at the

same level as Federal standards for 1974.

    EPA has made no equipment-cost estimates for emission controls for

heavy-duty gasoline truck engines.  In the absence of such estimates, it is

assumed for purposes of this report that the per-vehicle cost increment of

1970-1973 engines is  equivalent to that for 1970 model year passenger-car

engines less the cost  of fuel evaporation controls,  or $21. 50.  It is further

assumed that the 1974 and following-year control equipment  costs will be

equivalent to that for  a 1973 passenger car engine, less the cost of EGR and

evaporative controls,  or $45. 50.

    Incremental annual maintenance costs for heavy-duty gasoline truck

controls for all years are assumed to be the same  as passenger-car costs,

or $16.

    Fuel consumption penalties are estimated to be 3 percent for 1970 and

5 percent for  1974 and beyond.

    Aggregated costs  are summarized in Table IV- 6.  The annual total

cost is the sum of the pollution control equipment costs on all new engines

sold in that year, the cumulative maintenance costs for all engines sold

since 1970, and additional fuel consumed (over uncontrolled  engines) by

engines with emission controls.

        b.  Diesel Engines

    Through 1970-1973, Federal standards for heavy-duty diesel truck

engines covered smoke emissions only.  In 1974,  the standards were

revised to include HC, NOx, and CO, emissions as well as more stringent

smoke emissions.  The permissible gaseous-emissions levels are the same

as for heavy-duty gasoline engines for 1974, but the test procedure is


                                        TABLE IV.6

Incremental Cost for Cklendar Year, $ millions
Fuel -consumption
Annual total



    Both smoke and gaseous standards,  including those for 1974,  have been

attainable largely through fuel-injection system modifications.  (NOx and smoke

are the more difficult emissions to control; even uncontrolled  diesels are

usually well within CO standards).  Equipment cost penalties are considered

nominal; further,  it is estimated that no fuel consumption penalties have been

incurred.  Accordingly, no national cost penalty is attributed to diesel-truck

engine emission controls.

    3.   Lead-free Fuel Regulations

    On January 10, 1973  EPA promulgated regulations requiring that gasoline

stations make lead-free gasoline available for use in vehicles equipped with

lead-sensitive catalyst systems.  EPA's analysis shows that lead-free

regulations will cost the consumer  approximately $2. 6  billion from 1974 to 1979.

However, there will be  a $2.0 billion saving between 1975-1979 due to re-

duced maintenance cost from the extended lifetime of exhaust components

and spark plugs.  This $2.0 billion figure assumes that all new cars, both

catalytic and non-catalytic,  and no  old cars will use lead-free gasoline over

the 1975-79 period.  Computation is based on a 0. 095 cents saving per

vehicle mile using lead-free gasoline.


    1.  Effects-of Mobile Source Pollutants

    The effects of atmospheric  pollution are pervasive, complex, and

difficult to quantify in nonlaborabory situations.  A number of sources

and pollutants are usually involved, and there are significant problems

in attempting to isolate  specific cause and effect relationships.   The develop-

ment of more reliable techniques for relating sources to receptors is one major

objective of EPA's Regional Air Pollution Study (RAPS).   Mathematical models


of air pollution mechanisms, including those related to mobile source

pollutants, will be developed for St. Louis, Mo.  Such models will permit

in-depth examination of such questions as the relative importance of mobile

and stationary sources of CO, HC,  and NOx.  EPA is also supporting work

by emissions data specialists, meteorologists, physical chemists, biologists,

plant scientists,  medical researchers, materials engineers,  and economists

in attempts to provide a quantitative analysis of the  effects of mobile source

pollutants and the benefits of controlling automobile emissions.

    There are a number of ways of  estimating the benefits of emission

reductions.  The most common has been to translate the physical and bio-

logical damages into economic terms. Another method is the analysis of

consumer behavior in the marketplace--for example, a study of property

value changes relating to levels  of pollution.  Opinion surveys can also

indicate what people perceive as environmental stresses and what they are

willing to pay to alleviate them.  But assigning dollar values to the complex

and far-reaching  effects of air pollution is not easy  even when those effects

can be accurately quantified.  This difficulty is particularly apparent in the

case of health effects where costs are often defined  in terms of reduced


    A study by the California Air Resources Board is using another

approach,  the Delphi Method. In this application of the Delphi Method,  the

pooled scientific judgment of a panel of experts in the health field will enable

estimation of "rough order" health  dose-response relationships  (damage

functions) for the mobile source air pollutants for which EPA has promulgated

ambient air quality standards.  These damage functions can be used  to esti-

mate health benefits.  Where the health benefits  are in the form of fewer

days lost,  fewer doctor visits, or the like, the physical health benefits can be


translated into economic benefits.  With this kind of information,  EPA can

better evaluate the tradeoffs of alternative strategies of abating mobile source


    It is impossible to place an exact dollar figure on the total value of benefits

to be realized by abating air pollution much less that contributed by auto-

mobiles since many market as well as extra-market effects have not been

adequately quanitifed. Research  continues in attempts to better  specify

dose-response relationships for  the different receptor effects as well as

to better understand the incremental impact of air pollution on human wants

and behavior.

       a.  Health Effects

    Our knowledge of the adverse effects of motor vehicle emissions is

limited by a lack of systematic biological studies.   However,  information

from epidemiological, clinical, and toxicological studies indicates that a

number of health hazards are associated with motor vehicle emissions.  Of

the pollutants emitted by motor vehicles,  the ones of principal concern to

human health that are covered in this report are carbon monoxide, hydro-

carbons,  (as precursors of photochemical oxidants) and nitrogen oxides.

    A variety of health consequences may be related to components of motor

vehicle emissions (Table IV. 7).  These consequences include aggravation of

pre-existing disease,  impairment of resistance to common respiratory

infections,  animal tissue changes similar to those of chronic  respiratory

disease in humans, and increases in body burdens.  At the present time, we

lack quantitative information on the significance of automotive pollutants

relative to other enviromental and genetic factors that figure  in the health

problems of the general population.


    CO                    Impaired Cardiac Function
                           Increase in Blood Carboxy Hemoglobin

   NOx                    Acute Respiratory Defenses
                           Chronic Respiratory Disease

   OXIDANTS              Irritation of Mucous Membranes
                           Acute Respiratory Defenses

   LEAD                  Increased Body Burden (Accumulation)
                           Increased Risk of Childhood  Poisoning


       Carbon Monoxide.  Carbon Monoxide (CO) is 200 times more

reactive than ambient oxygen with the blood's oxygen-carrying

hemoglobin (HB).  Carbon monoxide forms carboxy-hemoglobin

COHb) imparing the body's oxygen-transport system (Table

IV. 8).

   Persons with pre-existing coronary diseases (estimated as 5 percent

of adults) are especially  susceptible to the effects of CO.  With small

increases of COHb, these persons experience significant electrocar-

diographic changes, increased severity of angina pain and decreased

tolerance to exercise.

Short-term exposure of humans to CO has also produced effects on the

central nervous system. These effects may relate to problems such as

impaired driving performance  and resultant increases in accidents.
       Photochemical Oxidants.  Except for limited damage to vegetation,

there are few effects related to ambient concentrations of

hydrocarbons.  The threat of HC to human health is based on its

role as a precursor of photochemical oxidants formed in

polluted atmospheres containing nitrogen oxides  and unsaturated

hydrocarbons.  The basic effects of photochemical oxidants on

man involve eye mucus  membrane or lung irritation, increased

aging of red blood cells, visual disturbances, and impaired delivery of

oxygen to tissues (Table IV. 9).

   The exact dose-response relationships are uncertain,  but concentrations

of 0.2 to 0.25 parts per million (ppm) of photochemical_pxidants have

consistently produced adverse  health effects in man and animals. Effects

are observable at lower concentrations as well.  Eye irritation is associated

with concentrations above 0. lOppm,  and impairment of athletic performance

               CARBON MONOXIDE
                        EPIDEMIOLOGY  STUDIES
 Diminished Tolerance
  to Exercise

 Decreased Activity

 Aggravation of Heart

 Increased Risk of
  Heart Disease

 Impaired Fetal
No Data
No Data
Three Studies
Studies of

Studies of


No Data
            No Data
            Limited Studies
            No Data

           Limited Studies

No Data     Limited Studies-
Source:  Finklea, John F. ,  "Conceptual Basis for Establishing
         Standards",  Paper in Proceedings of the  Conference
         on Health Effects of Air Pollutants,  October 3-5,  1973.
         Printed by Senate Committee on Public Works
         November 1973 (# 93-15).

                       OXIDANT EXPOSURES
                                  RESEARCH APPROACH
Aggravation of asthma
Aggravation of chronic
destructive lung disease
Aggravation of heart
Aggravation of
Single study
Three early
Three early
No data
No data
Two early
No data
Single study
No data
No data
No data
No data

Accelerated aging

Irritation of eyes
and respiratory tract
'in healty subjects

Decreased cardio-
pulmonary reserve
in healthy subjects

Increased suscepti-
bility to acute
respiratory disease

Increased risk of
chronic lung


embryotoxicity, and
  No data

  Two studies

  Single study

  Single study

  Single study

  No data
No data

No data
No data
No data
No data

Two studies    No data
Single study     Two studies
Single study
 Two studies
    Source:  Finklea, John F. "Conceptual Basis for Establishing
             Standards", Paper in Proceedings of the Conference on
             Health Effects of Air Pollutants, October 3-5, 1973.
             Printed by Senate Committee on Public Works
             November  1973 (# 93-15).


 has occurred at 0.12ppm.  Longer term exposure to 0.13ppm increases

 frequency of attacks among 5 percent of asthma patients studied.  The

 primary oxidant,  ozone, in concentrations of 0. 3 ppm produces nasal and

 throat irritation.  At 0. 6 to 1.0 ppm,  ozone significantly impairs pulmonary

 function.   Concentrations of 1. 0 and 3.0 ppm are intolerable to some

 subjects; a 9.0 ppm concentration leads to severe illness.

    EPA is currently engaged in community epidemiogical studies in

 Southern  California to better understand the impact of photochemical

 oxidants on respiratory diseases.  Other studies are examining the  toxi-

 cological effects of photochemical products found in exhausts from fuels

 with new  additives.

         Nitrogen Dioxide. The nitrogen oxide of concern is nitrogen

 dioxide (NO2), which has toxic effects primarily involving the lungs

 (Table IV. 10). At concentrations greater than 100 ppm, NO2 is lethal

 to most species. Man smells it at levels of 0.12 ppm, and short-term

 exposure to  concentrations of 5 ppm causes a transient increase in airway

 resistance.  Long-term exposures  (6 months) to concentrations of 0.062

 to 0.109 ppm brought an increased  incidence of acute respiratory disease

 in some families.  At concentrations of 0.063 to 0. 083 over a 6-month

 span, an increased frequency of acute bronchitis was found among

 infants and school children.  EPA is engaged in community epidemiological

 studies designed to define better the effects of nitrogen oxides on

 human health.

Other Health Studies

    A program has been initiated to study the creation and content of aerosols

 (liquid or solid suspensions in air) produced photochemically from auto

                         MIGHT BE ATTRIBUTED TO NITROGEN
                          __^	TOXICOLOGY
                  Clinical    At Low Exposure Levels
                  Studies	(  9000ug/m3)	
Increased susceptibility
to Acute Respiratory

Increased Severity of
Acute Respiratory

Increased Risk of
Chronic Respiratory
Aggravation of
Aggravation of
Heart and Lung


Fetotoxicity or
 Three replicated  No data
 Two replicated
 Two studies
 showing reduced
 function in

 One study

 No data
   No data
 No data
              Replicated rodent
Two studies with
 Four studies in
  No data      No data
 No data
No data

No data
No data      No data

No data       No data
    Source:  Finklea, John F, ,  "Conceptual Basis for Establishing
             Standards", Paper in Proceedings of the Conference
             on Health Effects of Air Pollutants,  October 3-5,  1973.
             Printed by Senate Committee on Public Works
             November 1973 (# 93-15).


exhaust, and to study the effect of these aerosols on animal physiology.

The use of catalytic converter systems on automobiles may also increase

sulfur dioxide and suspended sulfate levels in the immediate vicinity of

roadways.  The adverse health effects of these pollutants have been well

    Use of certain catalysts may cause large numbers of very fine particles

of metal compounds to be emitted into the air. However, the total

amount of metal emitted into the air from automobiles should be

substantially reduced when lead is removed from gasoline.  Tests are

being conducted in EPA laboratories to determine the general and specific

toxicity of any catalyst metals entering the atmosphere.

    Specific toxicity studies involve irritation of the eyes, bronchospasm

induction,  carcinogenesis,  embryotoxicity,  and resistance to respiratory


        b.  Effects  on Materials

                Effects of NOx and Ozone.  One of the significant materials

costs attributable tp  ozone  is that to elastomers  --primarily rubber.

Ozone oxidizes and thus produces cracking of rubber  surfaces that are

under stress.  The costs attributed to preventive measures and pre-

mature failure of rubber products  due to ozone is estimated at
approximately $500 million annually.  This estimate neglects secondary

costs associated with possible safety  aspects such as the effects of

premature parts failure on frequency of auto accidents.

    NOx and ozone cause fading of textile dyes.  To combat this problem,

dye manufacturers have incurred the  extra expense of adding antioxidant

compounds to their dyes.  Excessive  fading results also in decreased

product life.  One investigator has estimated that costs of avoiding

dye-fading amount to approximately $200 million annually.

                Total Materials Costs.  Recent estimates for

the year 1970 place the total materials costs associated with air

pollution in the range  of $1. 3 to $3.1 billion, with a "best" estimate

of $2. 2 billion.  Of this $2. 2 billion, $0. 7 billion is associated with

the complex of air pollutants identified as oxidants.  Ozone and

NOx, the primary auto-related pollutants that affect materials, are
assumed to be major components of the oxidants category.

   No effects of CO and HC on materials have been recorded.  It is not

known to what extent auto sulfate emissions will impact on general

atmospheric sulfate levels, nor what impact these levels will have  on

general deterioration  of materials. Also,  it is  not known to what extent

NOx plays  a role in the corrosion of metals, or what effects ozone  and

NOx have on other processes that deteriorate statuary and other

works of art.

                Current Studies.  Data from laboratory experiments

in controlled environments are being analyzed to determine the direct

and synergistic effects of ozone and NO  with SO and  relative humidity

on a variety of economically important materials.

        c.  Effects of Vegetation

                Hydrocarbons.  Among the many hydrocarbons emitted

by motor vehicles, ethylene causes significant damage to vegetation.

Concentrations ranging from  0. 001 to 0. 6 ppm ethylene for 8 to 24 hours

can cause significant effects on plant growth, yield, flower and leaf

retention,  and leaf orientation.  Ethylene concentrations of 0. 001 ppm


for 20 hours cause blight on African marigolds.  The flowers of orchids,

snapdragons, and carnations have been damaged at concentrations between

0. 01 and 0. 5 ppm.  Flower buds of tomato and pepper plants have dropped

at 0.1 ppm within 8 hours.  Economic losses have caused many commercial

flower growers to relocate to areas free of excessive ethylene pollution.

In spite of these significant direct effects, the major problem with ethylene

and other hydrcarbons is their contribution to the formation of photo-

chemical oxidants.

                Nitrogen Dioxide.  The exposure of many plant species

to more than 1 ppm NO2 for one or two days will result in necrotic leaf

lesions.   These lesions can be associated with reduced growth which detract

from the value of crops such as radish and  spinach where external appear-

ance is important.  Exposures of plants to more common ambient levels of

 0. 25 to  0.4 ppm NO2throughout the growing season, reduced crop yield

tomatoes by 22 percent. Cropyields of naval  oranges have also been

reduced.  Recent reports show that concentrations of NO2 and SO2

mixtures containing from 0.1 to 0. 25 ppm of both acted synergistically

in reducing  photosynthesis. Like hydrocarbons, NO2 and other oxides  of

nitrogen are most significantly linked to the formation of photochemical


                Photochemical Oxidants.  Photochemical precursors and

associated levels of atmospheric oxidants originate  in urban and industrial

areas, but they  can be dispersed and expose vast rural areas.


   While measurable success has been made in associating plant damage

to photochemical oxidants, it is still difficult to separate the affects of

individual pollutants. In terms of  occurrence and damage to vegetation,

ozone and peroxyacetylnitrate (PAN) are the most important photochemical

oxidants.  PAN has been identified as a problem in the Los Angeles

Basin of Southern California and other metropolitan areas.

   A recent study by the Stanford Research Institute  estimates that direct

oxidant damage to commercial crops and ornamental  plants amounts to about

$120 million.  The total value of plant destruction,  resulting from automotive
sources alone, is between $36 million and $72 million.

   Controlled laboratory exposures have demonstrated that most sensitive

plant species respond to oxidant concentrations as low as 0.05 ppm.  (Natural

background levels of ozone have been calculated at  0 to 0. 03 ppm.)  Both

exposure  duration and pollutant concentration are important variables

in determining the type and magnitude of plant response to photochemical

oxidants.   Generally, plant reponse can be categorized as chronic or acute.

Acute plant responses result from relatively high oxidant concentrations and

short exposure periods, resulting in rather distinct foliar injury.  In

contrast,  chronic responses are generally  nondistinct chlorotic or pig-

mented changes in foliage resulting from relatively low oxidant concen-

trations and long exposure periods.


                Current Studies and Programs.  Greenhouse and laboratory

studies are being conducted to define the dose-response relationships for

gas mixtures (03 and SO 2 ; NO 2  and SO2 ) including the influence of

natural environmental conditions on the response of plants to these gas

mixtures.  Efforts are underway to standardize the methodology of plant

assessment,  which requires correlation of foliar injury with reduced growth

and yield.  The effects of ozone on plant quality components such as protein,

amino acids, and carbohydrates are being studied and the relation is

being determined between these quality  components and plant vigor. The

alteration of basic physiological processes in test plants  exposed to

chronic low levels of ozone can be monitored.  Preliminary results

indicate that ozone reduces levels of carbohydrates and leads to

accumulations  of toxic phenol metabolites reflecting adversely on yield

and quality of crops.

    A 5-year field ecosystems study is currently in progress in the San

Bernardino Forest of Southern California to identify the response of a mixed

conifer forest ecosystem to ambient levels of photochemical oxidants

resulting from automobile emissions in the Los Angeles basin.

       d.  Other Aspects of Controlling Mobile Source Emissions

               Aesthetic Effects of NO?  and Oxidants. Research has  shown

that NO2»  and  particulate aerosols including lead particles can cause

the visibility reducing brown haze that characterizes many metropolitan

areas. Some have reasoned that reduced visibility results in aesthetic

losses and psychic costs and, in general, contribute to a degradation in

the urban environment and quality of life.


                Social Aspects.  People living in the inner city,  where CO,

NOx,  and oxidant levels are typically high,  may be particularly susceptible to

adverse health effects because of age or inadequate health care.

                Effect of Vehicle-Free Zones on Downtown Areas.  Partial

bans on central business district traffic have been attempted in many European

and some American cities.  In addition to reducing noise and pedestrian

inconvenience, the bans caused a drastic drop in carbon monoxide air

pollution levels. CO levels in New York's Madison Avenue dropped from

30 to  5 ppm with the traffic ban. Merchants and shoppers have reacted

favorably to traffic bans,  but the relative effects of noise abatement,

decreased pedestrian inconvenience,  and reductions in air pollution

are impossible to  isolate. Vienna, Austria, is creating a large

environmental oasis in its downtown section, and it is clear that  air

pollution abatement will be one of its attractions.

    2.  Improvement of Air Quality

    Availability of data limits analysis of trends for CO to Los Angeles,

California, and Newark, New Jersey.   In Los Angeles, trends of ambient

CO concentrations are predominantly downward.  The greatest improvement

has been in reduction of the annual percentage of excursions  above the eight hour

average.  Evidence of this reduction in downtown Los Angeles  is demonstrated
by a decrease in the 1 hour maximum concentration from 48  mgm/m  in 1963
to 39 mgm/m  in  1972.

    Ambient Air Quality data are available from certain  other cities during

the fuel shortage of 1973-1974.  Analysis of this data indicates that ambient

CO levels decreased in New York City, N. Y., Portland, Ore.,   and

Richmond, Va.', but increased in Mamaroneck,  N.  Y.,  Providence, R.  I.,

and Boston, Mass.


The higher readings in Mamaroneck are suspect, since the sampler was

located adjacent to a road where motor vehicle operators idled their engines

while waiting for gasoline pump service.

    Data  for analysis of trends of oxidant concentrations are available only

from  Los Angeles and Newark.  In Los Angeles, the general trend has been

downward since the late 1960's.  In downtown Los Angeles, the 1-hour

oxidant standard was exceeded 921 times in 1963 and 516 times in 1972.

In Newark, the maximum 1 -hour oxidant concentration was reduced from
           3                      3
411 ugm/m  in 1969 to  200 ugm/m in 1972. The extent of the decline

is more  apparent in the number of times the national oxidant standard

was exceeded.  In 1969,  the standard was exceeded in 50 out of 6, 963

readings (0. 7 percent) while in 1972 only 16 of 7, 756 readings

(0.2 percent) exceeded standards.

Buslanes are being tried in several urban areas to reduce vehicle
miles traveled. DOCUMERICA- Yoichi Okamoto


A.  Certification Program for New Motor Vehicles
    1.  Certification Determination
    Certification of new passenger cars for compliance with Federal emission
standards began with the 1968 model year. The program includes testing
of prototype vehicles that represent all new motor vehicles sold in the United
States.  The manufacturer is required to submit data showing that prototypes
conform to Federal exhaust,  crankcase and fuel evaporative emission
     The certification process begins when the manufacturer submits  an
application to participate in the program.  This is a Part I Application
(Figure V. 1)  and its purpose is to:
         o give notice to EPA of the manufacturer's intent to sell
         o provide information to determine whether the test equipment,
           test fuel,  and mileage accumulation procedure proposed by the
           manufacturer conforms to the regulations.
         o provide necessary description of the proposed product line
           including  projected sales data which allows EPA  to  select the test
     There are two different test fleets: an emission data fleet and a
durability data fleet.  The emission data fleet consists of a number
of vehicles tested at  4, 000 miles to establish the emission level  of a
vehicle close to its "break-in" point.  The durability fleet consists of
 a smaller number of vehicles tested at 4, 000 mile intervals to 48, 000
miles and at 50,000 to determine the deterioration of the vehicles'
emission control systems.

     Figure V.I
Certification Process


    The vehicle selection process starts by dividing the manufacturer's

product line into groupings of vehicles called  "engine families".  The

engine family is the fundamental unit in the  certification process in that

ultimate compliance is determined on an engine family basis.  Once the

product line is divided into engine families, up to eight emission data

vehicles are chosen to represent each  engine family.  Selection of

durability data vehicles for each engine family is on an "engine-system

combination"  basis.  An "engine-system combination" is a unique

combination of engine family,  exhaust  emission control system and

evaporative emission  control system.

    After the manufacturer receives notification that his proposed pro-

cedures  and equipment  are acceptable and has been notified of the required

test fleets,  mileage accumulation and emission testing at the manu-

facturer's facility can be initiated.  At any test point,  EPA can require

that the vehicle be brought to the EPA  laboratory in Ann Arbor, Michigan,

to confirm the manufacturers testing results.   Currently, confirmatory

tests  are routinely required for all emission data vehicles at the 4, 000

mile test point, and for most durability vehicles at the 50, 000 mile test

point  (some durability vehicles are tested at intermediate mileage points).

    After completion  of all tests on all emission data  and durability

data vehicles  in an engine family, 'the manufacturer submits a request

for issuance of a Certificate of Conformity  (called a Part II Application).

The request contains a compilation of all test data and a full description of

all maintenance performed. Based on the durability vehicle test data, a

deterioration factor (ratio of exhaust emissions at 50, 000 miles to the

exhaust emissions at 4, 000 miles) is established for each exhaust

pollutant for each engine-system combination. The exhaust emission test


results of each emission data vehicle in the engine family are then

multiplied by the appropriate deterioration factors.  If the emissions

of every emission data vehicle in the engine family, as adjusted by the

appropriate deterioration factors, meet all the applicable standards, the

manufacturer is issed a certificate of conformity for that engine family.

The certificate is effective for one year, or until the end of the model

year; whichever comes first.  If any of the vehicles do not meet

applicable standards,  the manufacturer is so notified.  If he does not

request a hearing within 30 days or if the hearing affirms the finding of

nonconformity, the manufacturer has two options:

The first alternative is to delete from the application for  certification

the vehicles  represented by the failing test vehicle.  Then EPA may select

in place of the failing vehicle an alternate vehicle chosen in accordance

with the selection criteria employed in selecting the vehicle that failed.

The second alternative is to modify the test vehicle and demonstrate by

testing that it meets applicable standards.  Another vehicle identical

to the first vehicle, as modified,  must then be operated in accordance

with applicable test procedures.  If the manufacturer fails to follow either

alternative,  certification of the affected engine family is denied.

    During the past year, certification of 1974 model year light-duty vehicles

and heavy-duty engines was completed, and certification of 1975 models is

now well underway. The certification program for the 1975 model year  involves

monitoring the test programs of approximately 60 manufacturers and review-

ing durability data from approximately 450 vehicles and engines and emission

data from 650 vehicles and engines.   This effort represents about a 100  per-

cent increase in durability vehicles and a 40 percent increase in emission data

vehicles over the previous model year and requires that  EPA conduct approxi-


imately 2,500 planned emission tests.  This increase is primarily a result

of the creation of a separate set of Federal emission standards for California.

    As a result of the unauthorized and unreported maintenance  practices

 by Ford Motor Company concerning 1973 certification vehicles,  EPA has

expanded its certification program to increase surveillance of domestic

manufacturers' testing programs, to perform periodic inspection of

manufacturers' facilities and records,  and  to investigate reports of possible

violations of regulations.

    Several trips each week are made to domestic manufactuers to observe

scheduled and unscheduled maintenance and mileage accumulation, and to

insure that  established test procedures are followed. In-depth inspections

of major manufacturers' programs are made annually.

    In addition to the requirements for certification of motor vehicles prior

to mass production, EPA has regulations governing changes to vehicles

during mass production and introduction of new models.  Approximately

800 requests for such  changes during this past year were reviewed and

more than  200 tests were conducted to determine compliance with standards.

    Certificates of conformity are also issued to cover heavy-duty gasoline

and diesel  engines.  This year, EPA monitored  the test programs of

approximately 15 manufacturers and, following  the completion of emission

testing, issued approximately 100 certificates of conformity with emission

standards.  In addition, over 200 requests were processed to make changes

during mass production and to introduce new engines.

    Since the 1971 model year, emission test results have been published

in the Federal Register.   Beginning with the 1973 model year, the fuel

consumption during  the emission test has also been determined and published

in the Federal Register as well as in a booklet for consumer use.

(Table V. 11). Fuel economy information was also presented by

participating manufacturers to car buyers in a format as presented

in Table V. 1. The driving cycle used in that emission test

is representative of typical city driving common to urban commuting.

To provide the consumer with additional fuel economy information,

a highway fuel economy test procedure was developed early this yeaar

and is being used to test 1975 model year vehicles. Thus, emission

test  results and a broad picture of fuel economy tests results  will be

available to consumers increasingly concerned with both air quality

and conservation of natural resources.

    2.  Inspections/Investigation Program

    EPA conducts periodic, scheduled audits of vehicle manufacturer certifi-

cation procedures and inspections of facilities to ensure that certification

procedures are being observed.   In the past year, EPA has conducted 24 of

these in-depth vehicle manufacturer inspections.   EPA's inspection team

inspected 12  foreign manufacturers and 12 domestic manufacturers.

    During the past year, EPA also initiated 17 investigations of potential

manufacturer violations of the Clean Air Act and made three referrals  to

the Justice Department.  A complaint against Volkswagen AG  and

Volkswagen of America for the existence of unreported defeat devices

on certain 1973  Volkswagens was  settled by stipulation in the

amount of $120,«000.

   3. Exclusion and Exemption Program

   EPA may  individually exclude  certain types of vehicles from, being

subject to the Clean Air Act if it meets one of the following  criteria:


                          TABLE V. 1

VEHICLE TEST              RANGE           AVERAGE
WEIGHT  (Ibs.)            (miles/gallon)       (miles/gallon)

      2,000                  22 - 29              24

      2,250                  19 - 25              21. 5

      2,500                  17 - 22.5            18.5

      2,750                10. 5-24.5            17. 5

      3,000                  9-20              15

      3,500                10. 5-20              13.5

      4,000                 6. 5 - 19              10.5

      4,500                 7.5-14               9.5

      5,000                   7-11               9

      5,500                   7 - 10. 5             8


(a)  Using a test procedure which simulates commuter-type driving.
    Results are not indicative of high-way-type driving.


   o  Inability to maintain a maximum speed fo 20 miles per hour.

   o  Lack of certain features customarily associated with safe
      and practical highway use, such as reverse gear,
      differential, or safety features required by State of
      Federal law.

   o  Possession of certain features that render its use
      on the street or highway unsafe, impractical, or
      highly unlikely, such as tracks, an inordinate size,
      or features ordinarily associated with military
      combat or tactical vehicles.

   EPA grants 3 types of exemptions from emission standards to manu-

facturers for both new and in-use vehicles and engines:

   o  Testing Exemptions   - given if the manufacturer indicates
a valid test purpose, a reasonable  scope, a necessity for the
exemption, and a significant degree of control over the exempt
vehicles or engines.

   o  National security exemptions - granted of endorsed by a
Federal agency charged with national defense.

   o  Export exemptions - given automatically without request for
vehicles or engines intended solely for export to a country with emission
standards not identical to EPA standards; vehicles or engines must be
labelled accordingly.



   Selective Enforcement Auditing is a program in which EPA will test new

motor vehicles or new motor vehicle engines being manufactured in

actual assembly line production. The purpose of the program is  to

determine whether assembly line vehicles or engines  do  in fact conform

with regulations with respect to which the certificate of conformity was


   The procedure EPA folows is to issue an administrative order to

the manufacturere to select certain production vehicles for testing.  If

EPA finds that the test results do not conform with the regulations

under which the Certificate of Conformity was issued, EPA may  revoke the




    EPA,  in addition to ensuring that new vehicles meet Federal Emission

Standards, also directs enforcement efforts at ensuring that vehicles continue

to meet standards throughout their useful lives.   EPA is also responsible

for enforcing fuel regulations and availability of regulated fuels.

    EPA is encouraging states to assume a greater role in various mobile

Source Enforcement activities. Primary emphasis is being directed at

the tampering, TCP's and fuels areas.

    1.  Anti-Tampering Program

    Section 203(a)(3) of the Clean Air Act prohibits any manufacturer

or dealer knowingly to remove or render inoperative a vehicle's

emission  control system after sale of the vehicle to the ultimate

purchaser.  During the past year,  20 investigations of potential violations

of the tampering prohibitions of the Clean Air Act have been conducted.

Five cases were referred to the  Justice Department for action  resulting in

prosecution of one dealership for removal of emission control systems;

a $500 fine was secured.  EPA is conducting surveys to determine whether

tampering is a significant problem in the Nation. Conducted by State motor

vehicle departments,  these surveys consist of a visual check of the

emission  control systems of  2, 000 vehicles as they pass through annual

inspection.  The Washington,  D. C.  survey, revealed that major com-

ponents of the emission control system had been removed in 15 percent

of the vehicles inspected.

    The most effective enforcement against tampering lies at the State level.

EPA is encouraging States to establish anti-tampering programs as part


of their inspection/maintenance plans.  Several States have adopted

anti-tampering prohibitions which apply to everyone after sale of the

vehicle,  rather than just dealers  and manufacturers.  EPA is conducting

a survey to determine exactly which States do have anti-tampering

prohibitions.  To aid in the effective enforcement of antitampering

laws, EPA has printed an inspector's guidebook depicting all emission

control systems  of 1973 foreign and domestic vehicles.

    2.  Recall Program

    Section 207(c) of the Clean air Act requires the EPA Administrator

to notify a manufacturer to recall and repair vehicles of a given type

when  the Administrator determines that a substantial number of them do

not conform to applicable emission standards during their useful  lives.

The objective is  to provide incentives to manufacturers to build vehicles

in all material respects like the prototype vehicle used for Certificate of

Conformity testing.  The Recall program consists of surveillance and

investigation, recall order implementation and public reporting.

    Surveillance  presently consists of the in-use compliance program,

defects reporting from government and  commercial fleets, obtaining

data from State and local inspection/maintenance centers, emission test

results and consumer and other complaints.   The in-use compliance

program was  initiated with the 1972 model year, the first year for which

Section 207(c) was applicable. EPA tested emissions of 24 engine classes

of 1972 model year vehicles.  In  aggregate the 24 represented about 70

percent of all 1972 vehicles sold  in the United States. Tfest vehicles were

selected statistically to asssure the sample accurately represented each

of the engine classes. Additionally, vehicles showing any sign of abuse  or


abnormal operation were rejected, and all test vehicles were put into an

optimum state of tune-up prior to testing. On the basis of these results,

EPA announced on June  25, 1974 that four major automobile manufacturers

had been notified that some of their 1972 model year vehicles appeared to

be in violation of Federal air pollution emission standards. As many as

1.4 million automobiles may be involved and thus subject to recall.  The

companies were given ten days from the June 25 notice date to provide

additional information they might have relevant to emission performance of

the vehicles involved.  After  consideration of this additional information,

EPA will decide whether to issue recall orders to these manufacturers.

    In a second series of surveillance tests begun early this year,  1973

model year vehicles (100 from each of 31  engine classes) are being evaluated.

Vehicles for these tests were again selected statistically.  The testing  under

this program is being  conducted in various U. S. locations and is expected

to be completed in early 1975.

    Currently, 12 other  investigations are in progress.  One earlier

investigation yielded a major EPA recall. Chrysler Corporation was

required to correct a defect in the emission control system designed to

reduce nitrogen oxide  emissions; 825,000 cars and 1,000 1974 trucks were

involved.  Of this recall, 30 percent have been remedied.  Regulations

were proposed March  25,  1974 to establish procedures for implementation

of recall orders.  These regulations contain requirements for remedial

plan contents,  recall campaign  reporting, and hearing procedures.

    Public reporting involves the plan to publish periodic information on

recall activities.  EPA expects to publish the first  report early in 1975.


    3.  Warranties Program

    Section 207(a) of the Clean Air Act provides for a defects warranty

starting with the 1972 model year.   EPA has concluded that consumers

do not understand what is covered by this warranty,  which is contained

in all owner's manuals, and therefore,   few claims are being made under

it.  To overcome this difficulty,  EPA intends to publish--or require the

vehicle manufacturers to publish--lists  of those defects covered by 207(a).

Defects on this list would be presumed to cause emission  standards to be

exceeded.  EPA also intends to institute a program to monitor the vehicle

manufacturer's effort under the warranty.

    The 207(b) performance warranty of the Clean air Act cannot be

implemented until EPA develops  a short test which reasonably correlates

with the sophisticated Federal test procedure used on prototypes of new

vehicles.   Technical problems centering on achieving satisfactory cor-

 relation for future model year vehicles have delayed implementation

of this provision.  However, EPA is making a renewed effort to develop

a short test, with the 1976 model year as a target date.  After a short

test is developed, EPA will  encourage States to select this short test for

inspection-maintenance programs as a part of their transportation control

plans that they prepare under Section 110 of the Act.

    4. Aftermarket Parts Program

    EPA intends to pursue a program of voluntary self-certification for

manufacturers of certain categories of automotive aftermarket parts,

"Aftermarket parts" are  those parts which are not "original equipment, "

that is, they are not produced by or for  the vehicle  or engine manufacturer.

The aftermarket parts program will attempt to identify the parts and

components important to  emissions performance and develop standards for


such parts.  This will enable after-market parts manufacturers to have

the option of designing and building their parts in conformity with the

standards and advertise them as being on a par with the original equipment

they replace. The program is intended to help alleviate any potentially

adverse competitive impact of the  emission control warranty by providing

an objective basis for ensuring that aftermarket parts do not degrade

emissions performance. EPA will support industry effort to develop

acceptable test procedures and the program will be announced in the Federal


    5.   Imports Program

    In conjunction with the U. S.  Customs Service,  EPA monitors imported

vehicles to ensure that they conform with U. S. emission standards. Those

not conforming may be imported under a U. S.  Customs bond pending modi-

fication of the vehicle to meet U.S. emission standards.  Vehicles that

cannot be modified to conform must be exported or destroyed.

    EPA periodically visits Customs  ports in the United States to inspect

imported vehicles, and to meet with  customs officials concerning enforcement

of the joint EPA-Customs regulations.  During the past year, EPA made visits

to 32 various ports of entry in the  United States.  EPA monitored approxi-

mately  3 million  commercial and privately-owned vehicles, issued 250 notices

to modify noncomplying vehicles, and issued 75 administrative orders to

export vehicles that could not be brought into conformity.

    EPA also initiated 26 investigations of potential violations of the import

provisions of the Act.  One of these investigations resulted in a prosecution

of one dealership for illegally importing 14 motor vehicles into the U. S.   The

corporation was assessed a civil penalty of $25, 000 and a  criminal

penalty of $30, 000 (reduced to $4, 500).


    6.  Fuels Program

    EPA has established a field sampling inspection system to assure the

general availability of lead-free fuel at the retail outlet.  Each Region

will inspect approximately 2, 000 retail outlets per year.  Each of EPA's

10 Regional offices will have a mobile fuels test laboratory and two per-

sonnel (one fuels inspector and one legal,  administrative and laboratory

back-up). The  fuel inspector will sample and test lead-free gasoline at

the retail outlets to ensure that the gasoline meets standards for lead-free

fuels.  Fuels inspectors will perform  on-site field tests and issue notices of

contamination to any retail outlet having contaminated gasoline. All tests

indicating contaminated gasolines will be sent to the laboratory for confir-

mation.  In addition,  EPA will send approximately 10% of all field samples

meeting standards to the laboratory for confirmation.

    EPA is currently developing a quality control program to monitor the

results of the Regional program.

    With regard to fuels enforcement, state departments such as the

Department of Weights and Measures are being encouraged to conduct lead-

free gasoline sampling. States are also being  encouraged to  adopt lead-free

gasoline regulations  identical to EPA, although EPA has no authority to re-

quire the states to do either.  Experience to date indicates that States are

reluctant to adopt lead-free  gasoline regulations identical to EPA unless

EPA provides these states with substantial financial assistance either in the

form of state grants  or personnel.



    1.  Light-Duty Vehicles

    As often as practical, EPA develops current data on emissions of in-use

light-duty vehicles so that State and local agencies, Federal Air pollution

officials, automobile manufacturers, and concerned citizens can estimate the

impact of emissions from light-duty vehicles on air quality. Under EPA

contract 1, 020 1966 through 1972 model year light-duty vehicles were

tested. The testing, conducted in Los Angeles,  Calif., Denver, Colo.,

Houston, Texas, St.  Louis,  Mo., Chicago, 111., and Washington, D. C.,

involved both hot and cold engine starts.  In addition,  total evaporative

emissions were determined using an improved technique whereby vehicles

were placed in a sealed enclosure.

Contractors to EPA are now working on a follow-up study  to determine

exhaust and evaporative emission factors for 1967  through 1974 model year

light-duty vehicles. Final reports are due in the next few months.

    A report entitled "Automobile Exhaust Emission Modal Analysis

Model" has  been completed  for  EPA.    This  report describes a

mathematical model and allied computer programs for calculating the

emissions of groups of vehicles over any specified driving sequence which

will be used in air  quality impact analysis.

    2. Heavy-Duty Vehicles

Contractors are also monitoring exhaust emissions from heavy-duty

gasoline-powered vehicles to compare emissions from 1970 and 1971

in-service vehicles with the applicable Federal standards. This work

involves simulating the 1970 Federal test procedure through use of a

chassis dynamometer. To produce  emission data more directly useful for

air quality impact estimates, test results will be expressed in terms  of


weight of the pollutants emitted per vehicle mile (i.e.,  gram per mile)

in addition to concentration of the pollutants of the tail pipe (e. g. , parts

per million) by which the 1970-73 standards were expressed.

    Another contract has been completed covering emission

surveillance of heavy-duty vehicles powered by diesel engines.  The purpose

was to determine the  effectiveness of the Federal exhaust smoke regulation

on heavy-duty diesel-powered vehicles operating in the Southwestern United

States.  A fleet of 64  test vehicles, representative of the vehicle population,

was used.

    At present, contracts are underway to  measure exhaust emissions from

diesel-powered and precontrolled gasoline -powered vehicles during actual

operation over a road route.   This will supplement the work completed

on controlled gasoline -powered trucks.


    1.  Emissions  at Nonstandard Temperatures
                                      o      o
    Ambient temperatures  outside the 68   to 86  F ranges specified in
the Federal procedure for emission testing of light-duty vehicles

studied in a program conducted by the U. S. Bureau of Mines.  The vehicles

tested included precontrol (1967) models, production cars from model

years 1969 through 1974, several developmental cars equipped with

advanced emission control systems  (including catalytic converters), and a

diesel and a stratified charge powered car.  The test temperature ranged
        o      o
from 20  to 110  F.  Cars equipped  with air conditioners were also tested
at 110  F with the air conditioner in operation.  The tests show that exhaust

emissions are adversely affected by deviations from  the standard test
temperature of 75  F and by air conditioner operation.  Fuel economy is
adversely affected by temperatures  lower that 75 F and by air conditioner


operation.  Emissions of hydrocarbons and carbon monoxide are more

sensitive to ambient temperature changes than emissions of nitrogen

oxides. In general, as the absolute level of emissions in the newer

and developmental cars drops, the sensitivity to change in temperature

becomes greater.   Of all 26 cars tested, the diesel and stratified charge

cars are lowest in emissions, highest in fuel economy,  and least sensitive

to ambient temperature.

    2.  Currently Unregulated Emissions

    In prior years,  studies on unregulated emissions from motor vehicles

have concentrated on characterization of reactive hydrocarbons, aldehydes,

polycyclic organic matter (POM) and  particulate emissions.  More  recently,

other unregulated pollutants have been identified and are being thoroughly

investigated by EPA.   These new compounds include sulfates, platinum and

other noble metal emission from catalysts, and miscellaneous compounds

such as nickel,  hydrogen sulfide and others.

    EPA's Office of Research and Development has recommended classifying

all hydrocarbons as reactive except for five compounds (one of which

is methane) which are  generally considered totally non-reactive

photochemically. Instrumentation for measuring reactive hydrocarbons

has been developed at EPA's National Environmental Research Center in

Research Triangle  Park, North Carolina.  The Motor Vehicle Emissions

Laboratory in Ann Arbor is setting up this instrumentation to measure

reactive hydrocarbons by this reactivity scale.  However, EPA  is also

investigating the feasibility of having  a non-methane emission standard,

which would be inherently simpler than the reactivity approach.  Thus,

lower priority has been given this area of investigation.

    While aldehyde  compounds are a distinct chemical class from hydro-


 carbons,  they are considered in conjunction with reactive hydrocarbons since

 both are photochemically reactive.  Routine measurement of aldehyde

 emissions is  conducted on advance prototype vehicles sent to EPA for testing.

 Although  isolated points show high .aldehyde levels, this work continues to show

 that aldehydes generally amount to  only about 10 percent of the total hydro-

 carbon emissions.

    Since previous work showed that properly functioning advanced light-duty

 vehicles  (including those equipped with catalytic converters) emit insignifi-

cantly small amounts of POM, little has been done in this area the past

 year.   However, investigations of POM emissions from light and

 heavy-duty diesel vehicles  are currently being conducted.

    Under EPA contract, higher particulate emissions from catalyst-

 equipped  vehicles were measured in 1972.  During this work,  the con-

 tractor discovered that these cars also emit higher levels of sulfates. EPA

 then began intensive research in the sulfate area.   Contract work was re-

 cently completed to measure total particulate emissions from advanced pro-

 totype vehicles. Also,  EPA has acquired the in-house ability to measure

 particulate emissions from light-duty vehicles.  The total level and compo-

 sition of  these emissions are being assessed.

    3.  Sulfate Emissions

    Since the discovery of sulfate emissions, more extensive charac-

 terization of  sulfate emissions has been done by various groups, including

 EPA's Office of Mobile Source Air Pollution Control  and Office of  Research

 and Development.

    EPA has measured sulfate emissions on a number of different

 catalyst,  noncatalyst, and alternative engine automobiles.  Measurements

 were made by a variety of methods  under various  steady state  cruise condi-


tions and on the LA-4 driving cycle used in certifying light-duty vehicles.

The  lack of a standard measurement procedure has hindered the comparison

of data and to some extent,  impeded further research.

   Results to date on the sulfate question point to the following conclusions:

   o Noncatalyst cars with conventional internal combustion
      engines emit very low levels of sulfates.  Data from
      EPA-ORD, GM, Ford, and  Exxon show sulfate
      emissions to be about 0. 001 grams per mile or  less
      than  1 percent of the fuel sulfur with the remainder being
      SC>2 .  Chrysler data indicates that sulfate emissions
      from noncatalyst cars are lower for leaded than non-
      leaded fuel.

   o Catalyst-equipped cars emit more sulfates than non-
      catalyst cars.

   o Pelleted catalysts emit substantially lower levels of
      sulfates than monolith catalysts in the EPA Test
      Procedure.  At higher speeds, the emission levels of
      the two types of catalysts appear to be similar.  The
      difference may be due to sulfate storage on the
      pellated catalysts at low speeds.

     This information further details the conclusions presented to the

Senate Public Works  Committee Nov. 6, 1973.  These conclusions,

however, are still tentative.  EPA plans to obtain additional

characterization data, develop more reliable measurement methods

and assess the technology for control of sulfate emissions.

F.  Transportation Control Plans

   The Clean Air Act requires States to prepare  and  submit to EPA

State Implementation Plans for implementing the National Ambient Air

Quality Standards (NAAQS)  in each Air Quality Control Region.  Trans-

portation Control Plans must be included in State  Implementation Plans

when both stationary  source emission controls and the Federal new car

emission controls cannot attain the NAAQS (Table  V. 2).  Some States

prepared plans that were totally or partially approved by EPA.  In  cases


where the State did not prepare an approvable plan, EPA promulgated

the Transportation Control Plan.

    States have responsibility to develop and enforce TCP's and EPA

is encouraging States to assume a greater degree or enforcement.  Ex-

perience to date,;however,    indicates that no State intends to enforce all

of its TCP measures and Federal responsibility for enforcement is

anticipated to be substantial in FY 1976.

    1.  Transportation Control Plan Measures

        Carbon monoxide and hydrocarbon levels are to be  reduced through

the implementation of Transportation Control  Plans incorporating a

combination of the following measures: additional stationary source

controls, reduction in vehicle miles travelled, inspection and maintenance,

mechanical retrofit, and gasoline supply restrictions.

        a.  Additional Stationary Source Controls

    Additional controls will be imposed on a variety of stationary sources

to reduce hydrocarbon emissions.  These measures are not transportation

control measures as such, but they are measures by the State and EPA to

help reduce the hydrocarbon levels required in the  Transportation Control

Plans. The measures include:  vapor recovery at service stations, conditions

for loading and unloading barges,  conditions for solvent and degreasing

operations, conditions for architectural coating operations, and  controlling

emissions at dry cleaning establishments.


                           TABLE V- 2
Air Quality Control Region


 Los Angeles
 San Diego
 San Francisco
 San Joaquin Valley
 Southeast Desert

National Capital
 Washington,  D. C. and
  parts of (Md.  & Va.)
      Control Measures
VMT, I/M, Air Bleed,
VMT, I/M, Air Bleed, Catalyst,
VMT, I/M,  VSAD,  Catalyst
Service Station,  Additional
Stationary Control

VMT, I/M,  VSAD,  Catalyst,
Service Station,  Additional
Sationary Control

VMT, I/M,  VSAD,  Catalyst,
Service Station,  Additional
Stationary Control

VMT, I/M,  VSAD,  Catalyst
Additional Stationary Control

VMT, I/M,  VSAD,  Catalyst,
Service Station,  Additional
Stationary Control
VMT,  I/M, Air Bleed,  High
Alt. Mod. ,  Service Station
VMT,  I/M, VSAD, Catalyst,
Air Bleed, Air Craft Control












 Minneapolis-St. Paul

 New Jersey
New York
 Metro-New York City
I/M, Service Station
VMT, I/M,  VSAD, Air Fuel,
Catalyst,  Service  Station,
Gasolina Limitations
VMT, I/M,  VSAD Air Bleed,
Catalyst,  Service Station

VMT, I/M,  E.G. R., Catalyst,
Service Station, Additional
Stationary Controls

VMT, I/M,  E.G.R. , Catalyst,
Service Station, Additional
Stationary Controls
VMT, I/M,  Heavy Duty Truck
Retrofit, Taxi Controls












 Corpus Christi

 Dallas-Ft. Worth

 El Paso

 Houston-Gal veston

 San Antonio


 Wasatch Front

 Salt Lake  City





VMT, I/M, Air Bleed
VMT, I/M, Air Bleed,
Service Station

Being revised per court order


VMT, Service Station

VMT, Service Station

VMT, VSAD, Service Station,
"Ship & Barge loading/un-
loading facilities vapor control11

VMT, I/M, Service Station
VMT (Salt Lake City), I/M,
High Alt. Mod.
VMT, I/M, Air Bleed, E.G.R.

VMT, I/M, Air Bleed, E.G.R.

                 FOOTNOTES  TO TABLE V-2
(a)    Certain states examined data and redid their emission inventory.
      They determined that standards could be achieved without trans-
      portation control plans.  The cities include: Baton Rouge, La.,
      Birmingham, Ala., Mobile, Ala., Syracuse, New York.,
      Kansas City, Kansas, Toledo, Ohio.

(b)    "VMT" - Measures to reduce vehicles miles traveled
      "Service Station"  Gasoline vapor control at service  stations
      "I/M" - Inspection and maintenance of motor vehicles
      "VSAD" - Vacuum spark advance disconnect retrofit
      "Catalyst" - Catalyst retrofit
      "Air Bleed"  - Air Bleed retrofit
      "High Alt. Mod. " - High Altitude Modification
      "EGR"  - Exhaust  Gas Recirculation retrofit
      "Air Fuel" - Air Fuel Control retrofit

(c)    No plan yet becasue major source of pollution is Los Angeles

           b.  Reduction in Vehicle Miles Travelled

    Several different activities aim to reduce vehicle miles travelled.

              Parking Regulations include both parking management

programs (off-street parking facilities) and on-street parking limitations.

These activities aim to discourage the use of automobiles,  primarily

in the urban centers. Restrictions in the central business district can

significantly reduce the carbon monoxide level, and on-street parking

regulations can decrease congestion and reduce emissions due to improved

traffic flows.

    Section 510 of the Agriculture-Environmental and Consumer Protec-

tion Bill prohibits EPA from using FY 1975 funds to -- "administer

any program to tax, limit or otherwise regulate parking facilities".

              Regulatory fees or surcharges for mass transit augmentation

were  initially promulgated, but subsequently revoked by Amendments of

the Clean Air Act. These amendments authorized EPA to approve fees  or

surcharges only if submitted by the States.

              Computerized carpool matching measures promulgated by

EPA provide for  formation of carpools, and preferential treatment

programs provide incentives (such as free parking for carpooling groups)

to encourage these carpools.  Under measures included in some plans,

disincentives  (such as parking space reduction) are included to  discourage

single occupancy of automobiles during commuter trips.

              Bus priority treatment consists of allocating highway

facilities in a preferential manner to buses in order to improve the quality

of bus service. Priority treatment includes reserved lanes for  buses, pre-

ferential access for buses at freeway  ramps, and certain traffic

engineering improvements.


           Traffic free zones were primarily promulgated to control local

carbon monoxide problems.  The zones are restricted in size,  generally about

110 city blocks or less in order to provide pedestrian access to consumer

and work areas.

           Heavy duty vehicle delivery restrictions during the morning hours

were promulgated for the Newark,  N. J.  area.  These were subsequently

revoked when further analysis indicated that the restrictions would only

shift the peak oxidant value rather than reduce it. '

           Bike trails have been included in a few Transportation Control

Plans to help reduce vehicle miles travelled.

       c.   Inspection and Maintenance Measures (I/M)

    Two different types of inspection programs  have been promulgated:

    o an "idle test:  program that measures emissions while the vehicle is
       running in neutral.

    o a "loaded test" program that measures emissions while the
      vehicle is running in gear on a treadmill-like device called a
      dynamometer.  The effectiveness of these programs depends
      on the  number in the vehicle population that are forced to
      obtain  corrective maintenance  and the failure rate limits

    EPA is sponsoring evaluation of two early inspection/maintenance

programs.  These will provide those States which require I/M under

Transportation Control Plans with guidance in selecting and implementing

their own I/M plans.  EPA will evaluate a "loaded test" program in Arizona

and a city  "idle test" in  Chicago.  The evaluation emphasizes early

dissemination of data to the States.

       d.  Mechanical Retrofit

    A retrofit measure is the addition of any device, system, modification,

or adjustment made on a motor vehicle after its initial manufacture to


achieve a reduction in emissions.  The retrofit packages include:  vacuum

spark advance disconnect with lean idle,  air bleed to the intake system,

exhaust gas recirculation and oxidation catalyst for both medium-  and .

heavy-duty vehicles.

    On March 27,  1974 (39 F. R.  § 11334) EPA proposed a centralized

retrofit evaluation program.  This program will provide those States

which have motor vehicle emission retrofit strategies included in their

Transportation Control Plans with data which will allow them to decide

which specific retrofit device to approve for installation. The concept

 of this voluntary program is to establish a set of agreed-upon testing

procedures.   Once procedures are established, retrofit developers will

arrange for testing of their devices by independent labs in accordance with

the procedures, and EPA will provide the results to the States.  EPA's

continuing role in the program will be in monitoring the test programs,

evaluating, and verifying the test results.

    2.  Implementation and Cost

    It is the intent of the Clean Air Act and the desire of EPA that  the

plans approved/promulgated to achieve and maintain NAAQS be carried

out by State and local jurisdictions.  Generally, the States have been slow

in submitting initial compliance schedules.  This is due to lack of

sufficient personnel and understanding of requirements of the plans.

Many of these initial problems are being resolved through close

coordination between EPA regional offices and the States.  Several

court suits have been filed by States  and  other interested parties against

EPA in regard to Transportation Control Plans which has also delayed

implementation of plans.


    Total costs for state imposed transportation controls are indefinite

at this time, however,  more than 20 million vehicles are affected and an

estimated 2 billion may be required for implementation through 1979.

About half of this will be to retrofit equipment and half will be  accumula-

ted costs of inspection  and maintenance (I/M) programs  and service

station vapor controls.  This total will, of course,  be larger when

additional state implementation plans are analysed  to determine their


    3.  Other TCP  Studies

               Study of Alternatives of Gas Rationing in the Los Angeles


    This study was started in the late Spring '74 and the  purpose of it is to

identify and analyze alternative tax policies for reducing auto vehicle miles

travelled  (VMT) and concomitant emissions to a level consistent with

controls on emissions from non-auto sources and specified ambient oxidant

levels. Specific measures to be considered are taxes on auto emissions,

gasoline,  and parking.  The required improvement or increase in public

transportation service  will be determined and estimates made  of the costs

and related impact associated with each of the tax strategies.  Particular

attention will be paid to the effect on fuel consumption.  The effect of these

taxes on factors having a longer-run influence on vehicle use and emissions

will also be considered; auto occupancy, shifts in the size and  age distribution

of autos,  and changes in business and residential location patterns.

    The need for this study was strongly re-enforced by the recent submission

of State air quality implementation plans.  Most of these implementation plans

the use of the following strategies: restrictions on  auto usage, mandatory

inspection of vehicles,  traffic controls, increased use of transit, retrofiting


old cars, and parking restrictions.  EPA's alternative plans for meeting the

standards for some metropolitan areas involved considerable dislocation

of transportation activity and were criticized as imposing unacceptable hard-


    It is hoped that this study will expand the range  of alternatives presently

being considered to deal with problems related to achieving desirable levels

of air quality.  Such alternative  strategies might include tax incentives

or disincentives  and might use the available information on the behavior

of travellers to estimate effects and  impacts of different strategies,  rather

than waiting for the States to acquire  actual experience by implementing

control plans.  To the extent that the use of behavioral data and models is

successful in analyzing policy alternatives,  much potential but unnecessary

dislocations and distruptions, may be avoided.

         b.  Improving the Integration of Air Quality Considerations
             in Transportation Planning and Decision-making

    In 1974, M. I. T. undertook research to identify means for improving

the Transportation Control planning process.  This research, which

is still underway, has identified a  number of actions EPA could under-

take to improve this process.  EPA and M.I. T. are now discussing

possible  approaches to implementing the recommendations resulting

from M. I. T. 's work  thus far.


(1)    These deadlines have been changed by the Energy Supply and
      Environmental Coordination Act of 1974.

(2)    The 2. 0 gram std.for the 1976 was changed to 1977 through
      enactment of the Energy Supply and Environmental Coordination
      Act of 1974.

(3)    Statements based on data in  "Automobile Exhaust Emissions
      Surveillance-. A Summary - EPA Report ATTD-1544,
      March  1973.

(4)    These statements are based on data from "Emissions from a
      Gould Catalyst Vehicle with 25, 000 accumulated miles. "
      Report # 75-5, July 1974.  Report of the Technoligy Assess-
      ment and Evaluation Branch Emission Control Technology
      Division, Mobile Source Air Pollution Control, Ann Arbor,

(5)    The Cost of Clean Air - Annual Report of Administrator.
      EPA, April 1974.

(6)    Air Quality Criteria for Carbon Monixide -U.S. Department
      of Health, Education and Welfare. March 1970

(7)    Shy, CarlM., "Transportation and Health"  Presented at
      Connecticut Conference on Transportation.  Hartford,  Conn.
      May 16,  1973

(8)    Knelson, John H. , "Carbobn Monoxide and Cardiac Health"
      Presented at American Health Association - Nov. 4-8, 1973.

(9)    Air Quality Criteria for Hydrocarbons  -  U.S.  Department of
      Health,  Education and Welfare, March, 1970

(10)   Air Quality Criteria for Photochemical Oxidents -U.S. Depart-
      ment of Health, Education, and Welfare.  March 1970

(11)   Air Quality Criteria for Nitrogen Oxides -U.S.  Environmental
      Protection Agency.  Jan 1971

(12)   Summary Report on Suspended Sulfates and Sulfuric Acid
      Aerosis -U.S.  Environmental Protection Agency,  Research
      Triangle Park,  N. C.  October 1973


      (13)   Health Consequence of Sulfur Oxides - A Report from
            Chess, 1970-1971 -U.S. Environmental Protection Agency,
            Research Triangle Park, N.C.  May 1974

      (14)   Mueller,  W. J. and Stickney,  P.B., "A survey and Economic
            Assessment of the Effects of  Air Pollution  on Elastomers".
            Final  report on Contract CPA 22-69-146 from Battelle
            Memorial Institute, Columbus, Ohio,  to the National Air
            Pollution Control Administration, DHEW, Raleigh, N.C.
            June 1970.

      (15)   Salyin, V. S. Survey and Economic Assessment of the Effect
            of Air Pollution on Textile Fibers and  Dyes Final report on
            Contract PH 22-68-2 to the National Air Pollution Control
            Administration,  DHEW, Raleigh, N.C.  June 1970

      (16)   Waddell,  T.E.,  The Economics of Damages of Air Pollution -
            EPA,  OR&D Socioeconomic Environmental Studies series,
            EPA-600/5-74-012.  May 1974

      (17)   Benedict, H. M. ,  Miller, C.J., and Olson.  R. E., Economic
            Impact of Air Pollution on Plant in the United States Final
            report on Contract CRC-APRAC CAPA-2-68 (1-70) from
            Stanford Research Institute to CRC and EPA.  November 1971

      (18)   An Engine Class is comprised of all cars produced by a
            single manufacturer,  which have the same  tupe and about
            the same size engine.