EPA 230/3-74-013
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY
Report to Congress
4TH & M STREET SOUTH WEST
WASHINGTON, D.C. 20460
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PREFACE
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.
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Table of Contents
Preface
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
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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
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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
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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
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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
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CHAPTER I. INTRODUCTION AND SUMMARY
EPA's effort in reducing mobile source emissions includes the setting
of standards, the promulgation of regulations, program development,
and research.
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1-1
CHAPTER I. INTRODUCTION AND SUMMARY
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
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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
additives.
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.
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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
vehicles.
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. "
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TABLE I.I
EXISTING EMISSIONS STANDARDS
TYPE OF
1975
VEHICLE 1
1 HC CO NOx 1
HC
1976
CO
NOx
j HC
1977^
CO
NOx 1
HC
1978
CO
NOx
(emissions expressed as grams per mile)
Light duty gasoline
passenger vehicle
Light duty diesel
passenger vehicle
Light duty gasoline
truck
Light duty diesel
truck (proposed)
(National)
(California)
(National)
(California)
(National)
(California)
(National)
1.5
.9
L.5
.9
2.0
>.0
15
9
15
9
20
20
3.1
2.0
3.1
2.0
3.1
2.0
1.5
.9
1.5
.9
2.0
.9
2.0
15
9
15
9
20
17
20
3.1
2.0
3.1
2.0
3.1
2.0
3.1
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.
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TABLE I. 2
EMISSIONS STANDARDS FOR
HEAVY-DUTY GASOLINE AND DIESEL ENGINES
Type of Engine
(a)
1975 and 1976 Model years
(grams/brake horespower/hour)
(b)
HC and NOx
CO
Heavy-duty
Gasoline engine
Heavy-duty
Diesel engine
(National)
(California)
(National)
(California)
16
10
16
10
40
30
40
30
a) Standards for 1977 and 1978 have not been set.
b) Standards apply to the combined emission of hydrocarbon and
nitrogen oxides.
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Table 1.3
MAJOR REGULATIONS PROPOSED/
PROMULGATED DURING FY 1974
..DATE DESCRIPTION STATUS
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
CTl
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
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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.
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CHAPTER II. EPA ACTIONS
A. SUSPENSION OF 1976 NOx EMISSIONS STANDARDS
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
i/
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
standards.
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,
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then EPA must set interim standards representing the best available
I/
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.
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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
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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.
B. MOTOR VEHICLE REGULATIONS
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
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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-
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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
years.
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
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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
amendment.
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
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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
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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
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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
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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-
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11-12
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
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11-13
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-
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11-14
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
welfare.
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.
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11-15
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.
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CHAPTER III. PROGRESS IN EMISSION REDUCTION TECHNOLOGY
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
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m-1
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
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Ill-2
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
V-TYFE INTERNAL COMBUSTION ENGINE
Four-Stroke Cycle
2. COMPRESSION 3. POWER
1. INTAKE
4. EXHAUST
Front cutaway of V-engine
VALVE
EXHAUST
GASES
FUEL-AIR
MIXTURE* \ SPARK
6V0 \ PLUG
PISTON
(EXHAUST
STROKE)
FLYWHEEL
CYLINDER
\
PISTON
(INTAKE
STROKE)
Illustrations in this section are highly
simplified schematics to show only
pertinent functions.
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Ill-3
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
RICH PRE-COMBUSTION
FUEL-AIR CHAMBER
MIXTURE
' LEAN
'. FUEL-AIR
MIXTURE
2. COMPRESSION
3. POWER
4. EXHAUST
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III-4
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.
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III-5
Figure III.3
Gas Turbine Engine
FUEL
AIR __»
INTAKE^ °'
GAS TURBINE
EXHAUST
1 «
FINAL DRIVE GEARS
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Ill-6
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
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Ill-7
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-
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m-8
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
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Ill-9
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
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Ill-10
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.
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m-11
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.
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Ill-12
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.
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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.
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m-14
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.
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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
information.
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
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m-16
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.
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CHAPTER IV. COSTS & BENEFITS OF MEETING EMISSION STANDARDS
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
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IV-1
CHAPTER IV. COSTS AND BENEFITS OF MEETING
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
I/
injection system.
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IV-2
TABLE IV. 1
EMISSION CONTROL EQUIPMENT COSTS,
1974-1977 MODEL YEAR LIGHT DUTY VEHICLES
YEAR
ITEM
(a)
LIST PRICE
(b)
EPA
(c)
NAS
(d)
INDUSTRY
1974
Cumulative costs through 1974
B3700
54. 53
83.00
SOME
1975/76
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)
recirculation
Air injection 40.00 43.32(f)
Subtotal for noncatalytic
systems 95.00 104.67 75-120
MOST
1975/76/77
Oxidation catalytic (in
eludes long-life exhaust
system)
Cooling system changes
Body revisions and
material changes
Assembly line changes
and testing
Subtotal
Cumulative costs through
1975/76/77
90.00
90.00
54.70
~I79~0
2.85
5.65
65. 10
75-110
$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
-------
IV-3
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
cars.
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
I/
systems.
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.
-------
IV-4
TABLE IV. 2
EMISSION CONTROL EQUIPMENT COSTS
for 1978 MODEL YEAR LIGHT DUTY VEHICLES
YEAR ITEM
(a)
LIST PRICE
(b) (c)
EPA NAS
(d)
INDUSTRY
1978
Cumulative costs through 268.00 224.30 273-313
1977
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
1978
$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.
-------
IV-5
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.
-------
IV-6
TABLE IV. 3
ESTIMATED INCREMENTAL MAINTENANCE COSTS for
EMISSION CONTROL SYSTEMS OF LIGHT-DUTY VEHICLES (a)
ANNUAL MAINTENANCE COST
MODEL YEAR INCREASE PER VEHICLE
1968-72
1973-74
(b)
1975 -76
1977
(c)
1978
$16.00
16.00
- 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.
-------
IV-7
TABLE IV. 4
EFFECT OF EMISSION CONTROL ON FUEL
ECONOMY OF LIGHT-DUTY VEHICLES
MODEL YEAR
1957-67 (uncontrolled)
1968
1969
1970
1971
1972
1973
1974
1975 (a)
1976 (a)
1977 (a)
1978 (a)&(b)
and subsequent years
FUEL ECONOMY
LOSS, PERCENT
Baseline
4.3
5.3
4.7
7.6
7.3
10.1
9
3
3
6
7
SOURCE: U.S. Environmental Protection Agency
(a) Less certain than previous years since no
firm basis is presently available for
estimating.
(b) Based on use of a dual-catalyst system with an
advanced fuel-metering system or 3 way catalyst
with feed-back control.
-------
IV-8
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
-------
IV-9
TABLE IV.5
ESTIMATED NATIONAL COSTS FOR
EMISSION CONTROLS FOR LIGHT-DUTY VEHICLES
ITEM
Equipment
(d)
Maintenance
Fuel -consumption
penalties
Fuel price
penalties
Annual National Cost $ billions
1968 (b)
0.05
0
0.11
0
0.16
1969
0.06
0.11
0.36
0
0.53
1970
0.19
0.28
0.50
0
0.97
1971
0.35
0.44
0.65
0
1.44
1972
0.40
0.58
1.12
0
2.10
1973
1.13
0.76
1.76
0
3.65
1974
1.01
0.96
2.30
0.35
4.62
1975
2.94
1.20
2.69
0.41
7.24
1976
3.26
1.31
2.89
0.43
7.89
1977
4.03
1.47
3.04
0.45
8.99
1978
4.10
1.69
3.29
0.47
9.55
1979
4.20
1.92
3.54
0.49
10.15
(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.
-------
IV-10
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
-------
IV-11
TABLE IV.6
ESTIMATED NATIONAL COSTS FOR EMISSION
CONTROL FOR HEAVY DUTY GASOLINE ENGINES
Incremental Cost for Cklendar Year, $ millions
Item
Equipment
Maintenance
Fuel -consumption
1970
14
0
8
1971
14
7
20
1972
17
18
37
1973
23
30
63
1974
39
46
92
1975
39
61
123
1976
39
74
154
1977
39
86
184
1978
39
98
212
1979
39
108
239
penalties
Annual total
22
41
72
116
117
223
267
309
349
386
-------
IV-12
different.
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.
B. BENEFITS
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
-------
IV-13
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
productivity.
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
-------
IV-14
translated into economic benefits. With this kind of information, EPA can
better evaluate the tradeoffs of alternative strategies of abating mobile source
emissions.
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.
-------
IV-15
TABLE IV. 7-ADVERSE HEALTH CONSEQUENCES
OF MOTOR VEHICLE POLLUTANTS
POLLUTANT HEALTH CONSEQUENCES
CO Impaired Cardiac Function
Increase in Blood Carboxy Hemoglobin
Levels
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
-------
IV-16
6,7,8/
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.
7.9,10/
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
-------
IV-17
TABLE IV. 8 - POSSIBLE ADVERSE HEALTH EFFECTS WHICH
MIGHT LOGICALLY FOLLOW EXPOSURE TO
CARBON MONOXIDE
EXPECTED
EFFECT
RESEARCH
APPROACH
CLINICAL
EPIDEMIOLOGY STUDIES
TOXICOLOGY
Diminished Tolerance
to Exercise
Decreased Activity
Mental
Aggravation of Heart
Disease
Increased Risk of
Heart Disease
Impaired Fetal
Development
No Data
No Data
Three Studies
Studies of
Smoking
Studies of
Smoking
Three
Studies
Multiple
Studies
Multiple
Studies
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).
-------
IV-18
TABLE IV. 9-ADVERSE HEALTH EFFECTS WHICH MIGHT
BE ATTRIBUTED TO PHOTOCHEMICAL
OXIDANT EXPOSURES
RESEARCH APPROACH
EXPECTED
EFFECT
CLINICAL
EPIDEMIOLOGY STUDIES
TOXICOLOGY
Aggravation of asthma
Aggravation of chronic
destructive lung disease
Aggravation of heart
disease
Aggravation of
Single study
Three early
studies
Three early
studies
No data
No data
Two early
studies
No data
Single study
No data
No data
No data
No data
hematopoietic
disease
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
disease
Respiratory
malignancies
Mutagenesis,
embryotoxicity, and
teratogenesis
No data
Multiple
studies
Two studies
Single study
Single study
Single study
No data
No data
Multiple
studies
No data
No data
No data
No data
Multiple
studies
Two studies No data
Multiple
studies
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).
-------
IV-19
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.
7.11/
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
-------
IV-20
TABLE IV. 10 - ADVERSE HEALTH EFFECTS WHICH
MIGHT BE ATTRIBUTED TO NITROGEN
DIOXIDE
EXPECTED
EFFECT
RESEARCH APPROACH
Epidenaology
__^ TOXICOLOGY
Clinical At Low Exposure Levels
Studies ( 9000ug/m3)
Increased susceptibility
to Acute Respiratory
Disease
Increased Severity of
Acute Respiratory
Disease
Increased Risk of
Chronic Respiratory
Disease
Aggravation of
Asthma
Aggravation of
Heart and Lung
Disease
Carcinogenesis
Fetotoxicity or
Mutagenesis
Three replicated No data
studies
Two replicated
studies
Two studies
showing reduced
ventilatory
function in
children
One study
suggesting
particulate
nitrates
aggravate
asthma
No data
No data
Anecdotal
case
reports
No data
Replicated rodent
studies
Two studies with
rodents
Four studies in
rodents
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).
-------
IV-21
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
12,131
documented.
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
infection.
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
14/
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
-------
IV-22
15_/
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
IjJ/
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
-------
IV-23
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
oxidants.
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.
-------
IV-24
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
17/
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.
-------
IV-25
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.
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IV-26
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
3
by a decrease in the 1 hour maximum concentration from 48 mgm/m in 1963
3
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.
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IV-27
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.
-------
CHAPTER V. RELATED EPA PROGRAMS
Buslanes are being tried in several urban areas to reduce vehicle
miles traveled. DOCUMERICA- Yoichi Okamoto
-------
V-l
CHAPTER V. RELATED EPA PROGRAMS
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
standards.
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
vehicles.
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
fleets.
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.
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V-2
Figure V.I
Certification Process
-------
V-3
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
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V-4
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-
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V-5
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
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V-6
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:
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V-7
TABLE V. 1
(a)
GAS MILEAGE FOR 1974 AUTOMOBILES
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
NOTE;
(a) Using a test procedure which simulates commuter-type driving.
Results are not indicative of high-way-type driving.
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V-8
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.
B. SELECTIVE ENFORCEMENT AUDITING PROGRAM FOR PRODUC-
TION VEHICLES
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
issued.
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
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V-9
Certificate.
C. ENFORCEMENT OF VEHICLES IN USE AND FUEL STANDARDS
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
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V-10
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
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V-ll
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.
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V-12
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
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V-13
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
Register.
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).
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V-14
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.
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V-15
D. OTHER EMISSIONS INVENTORY PROGRAMS
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
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V-16
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.
E. SUPPORTING EMISSIONS CHARACTERIZATION PROGRAM
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
o
at 110 F with the air conditioner in operation. The tests show that exhaust
emissions are adversely affected by deviations from the standard test
o
temperature of 75 F and by air conditioner operation. Fuel economy is
0
adversely affected by temperatures lower that 75 F and by air conditioner
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V-17
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-
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V-18
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-
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V-19
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
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V-20
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.
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V-21
TABLE V- 2
(a)
STATES WITH TRANSPORTATION CONTROL PLANS
Air Quality Control Region
or
(Portion)
Alaska
Fairbanks
Arizona
Phoenix-Tucson
California
Los Angeles
Sacramento
San Diego
San Francisco
San Joaquin Valley
(c)
Southeast Desert
Colorado
(HT
Denver
National Capital
Washington, D. C. and
parts of (Md. & Va.)
(b)
Control Measures
VMT, I/M, Air Bleed,
Catalyst
VMT, I/M, Air Bleed, Catalyst,
EGR
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
Program
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STATES WITH TRANSPORTATION CONTROL PLANS - CONT'D
Illinois
Chicago
Indiana
Indnanapolis
Maryland
Baltimore
Massachusetts
Boston
Springfield
Minnesota
Minneapolis-St. Paul
New Jersey
(e)
Trenton-Camden
(f)
Newark
New York
Metro-New York City
Rochester
VMT, I/M
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
VMT
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
(g)
Retrofit, Taxi Controls
I/M
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STATES WITH TRANSPORTATION CONTROL PLANS - CONT'D
Ohio
Cincinnati
Oregon
Portland
Pennsylvania
Philadelphia
Pittsburgh
Texas
Austin-Waco
Corpus Christi
Dallas-Ft. Worth
El Paso
Houston-Gal veston
San Antonio
Utah
Wasatch Front
Salt Lake City
Provo
Odgen
Washington
Seattle
Spokane
I/M
VMT, I/M, Air Bleed
VMT, I/M, Air Bleed,
Service Station
Being revised per court order
VMT
VMT
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,
VSAD
(d)
High Alt. Mod.
VMT, I/M, Air Bleed, E.G.R.
VMT, I/M, Air Bleed, E.G.R.
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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
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V-25
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.
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V-26
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
imposed.
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
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V-27
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.
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V-28
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
costs.
3. Other TCP Studies
Study of Alternatives of Gas Rationing in the Los Angeles
Area
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
ft
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
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V-29
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-
ships.
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.
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V-30
FOOTNOTES
(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,
Michigan.
(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
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V-31
(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.
AU.S. GOVERNMENT PRINTING OFFICE:1975 582-421/248 1-3
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