EPA-460/3-74-029-a
APRIL 1973
EXAMINATION OF ISSUES
RELATED TO TWO-CAR REGIONAL
EMISSION CONTROL STRATEGIES:
VOLUME I -
EXECUTIVE SUMMARY
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Mobile Source Air Pollution Control
Emission Control Technology Division
Ann Arbor, Michigan 48105
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EPA-460/3-74-029-a
EXAMINATION OF ISSUES
RELATED TO TWO-CAR REGIONAL
EMISSION CONTROL STRATEGIES:
VOLUME I -
EXECUTIVE SUMMARY
Prepared by
Merrill G. Hinton, Toru lura, and Joseph Meltzer
Aerospace Corporation
ElSegundo, California
Contract No. .68-01-0417
EPA Project Officer: F. Peter Hutchins
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Mobile Source Air Pollution Control
Emission Control Technology Division
Ann Arbor, Michigan 48105
April 1973
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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers. Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - as supplies permit - from the Air
Pollution Technical Information Center, Environmental Protection Agency,
Research Triangle Park, North Carolina 27711; or, for a fee, from the
National Technical Information Service, 5285 Port Royal Road, Springfield,
Virginia 22161.
This report was furnished to the Environmental Protection Agency by
Aerospace Corporation, El Segundo, California, in fulfillment
of Contract No. 68-01-0417. The contents of this report are reproduced
herein as received from Aerospace Corporation. The opinions, findings,
and conclusions expressed are those of the author and not necessarily
those of the Environmental Protection Agency. Mention of company
or product names is not to be considered as an endorsement by the
Environmental Protection Agency.
Publication No. EPA-460/3-74-029-a
11
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FOREWORD
This report, prepared by The Aerospace Corporation for the
Environmental Protection Agency, Division of Emission Control Technology,
presents the results of an examination of the issues related to two-car
regional emission control strategy implementation.
The comments and statements attributed herein to domestic
and foreign auto companies and state or city air quality control authorities
were expressed either during data acquisition visits or by letter or telephone
correspondence in the period 7 March 1973 through 30 March 1973.
The results of this study are presented in two volumes. Vol-
ume I, the Executive Summary, presents a brief, concise review of impor-
tant findings and conclusions in the Highlights and Executive Summary sec-
tions. Volume II, the Technical Discussion, provides a detailed discussion
of each study topic and is of interest primarily to the technical specialist.
In Volume II, passenger car population location, air quality effects, and car
movement and migration factors are delineated in Section 2. A summary of
potential two-car strategy compliance assurance measures, current and new
procedures, and associated problem areas is presented in Section 3. The
position of the auto manufacturers with regard to two-car strategy imple-
mentation, with particular emphasis on ability to produce, market, and
service two new car classes, is discussed in Section 4. The reactions of
*
potentially involved state or regional air quality control authorities with
regard to compliance assurance capability and air quality impact under a
two-car strategy are treated in Section 5. Possible effects of the two-car
strategy on the vehicle user are summarized in Section 6. Section 7 con-
tains a brief discussion of possible effects on the used-car arid replacement
parts industries. Appendix A, Section 8, contains a listing of the companies /
agencies contacted in the data acquisition activity. Appendixes B through O
contain backup information relative to the study.
111
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ACKNOWLEDGMENTS
Appreciation is acknowledged for the guidance and assistance
provided by Mr. F. P. Hutchins of the Environmental Protection Agency,
Division of Emission Control Technology, who served as EPA Project Offi-
cer for this study.
The following technical personnel of The Aerospace Corpora-
tion made valuable contributions to the examination performed under this
contract.
J. A. Drake
L. Forrest
B. Siegel
W. M. Smalley
C. Speisman
H. M. White
Merrill G. Hinton, Director
Office of MobLle Source Pollution
Approved by
Toru lura, Associate Group Director
Environmental Programs
Group Directorate
;ph tMeltzer, Gr^j/p Di recto£
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HIGHLIGHTS
An examination and summarization was made of available
information pertaining to issues relevant to potential implementation of a
one-year two-car regional emission control strategy for the 1975 model year.
Two different two-car strategy options were specified by EPA for examina-
tion. The first, or California-only strategy option, would require that new
cars sold in the State of California meet a low-emission standard such as the
1975 Federal emissions standards, while vehicles sold in all other states
would meet a higher-emission standard such as the 1973/74 Federal emis-
sions standards. The second, or California-plus strategy option, increases
the area of stricter control by adding up to 16 air quality control regions to
California as areas requiring the sale of low-emission 1975 model cars;
again, the rest of the United States would use higher-emission 1975 model
cars.
Assessment of the available data as of the time of data acqui-
sition visits and technical discussions (March 7 to March 30, 1973) resulted
in the following findings.
1 The California-only two-car strategy would require approximately 11
percent of the 1975 model year passenger cars sold in the United States
to meet the lower emission standards. Most of these cars would require
catalysts to do so. This would represent from 5 to 10 percent of the
United States new car sales of individual domestic auto manufacturers
and up to 30 percent of the United States new car sales of individual
foreign auto manufacturers.
2. The California-plus two-car strategy could require up to 33 percent of
the 1975 model year passenger cars sold in the United States to meet
the lower emission standards. This would represent from 24 to 33 per-
cent of the United States new car sales of individual domestic auto
manufacturers and up to 52 percent of the United States new car sales of
individual foreign car manufacturers.
3. Under either of these one-year control strategies there is no dramatic
improvement in air quality in the control regions with the lower
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emission cars. The regions would have an approximately 10 percent
(1-3 ppm) reduction in CO and an approximately 5 percent (0.001-0.02
ppm) reduction in oxidant level beyond the level that would result if only
1974 emission standards were in effect throughout the 1975 model year.
In terms of oxidant level reduction benefits resulting from compliance
with 1975 emissions standards, the State of California would appear
to benefit the most by being a control region. Four of the California
cities are among the seven cities exhibiting the greatest oxidant level
reduction, and three of these cities (Los Angeles, San Diego, and
San Francisco) are among the four cities with the greatest oxidant
reduction potential.
With the exception of Chrysler, which opposes any strategy requiring
the use of catalysts, the domestic auto manufacturers generally favor
the California-only two-car strategy. This strategy would only require
catalysts on from 5 to 10 percent of each manufacturer's new 1975 cars
for United States sales. The same companies are generally opposed to
the California-plus strategy, primarily on the basis of assembly, distri-
bution, and marketing difficulties. If the California-plus strategy were
implemented, however, the opinion of these companies is that any added
geographical areas should be as large as possible.
Foreign automakers generally oppose any mandatory two-car strategy;
they prefei optional phasing-in processes for catalysts. With regard
to the California-only strategy they feel that the percentage of their
United States car sales in California is much too large to represent a
reasonable test sample size (e.g., Nissan ~30%, Toyota ~24%,
Volkswagen ~17%). Their distribution and marketing problems would
further escalate under the California-plus strategy. However, their car
sales in California are a relatively small portion of their overall pas-
senger car output (e.g., Nissan ~5.01%, Toyota ~4.67%, Volkswagen
-5.38%).
Two classes of cars can be produced; however, there is an associated
degree of difficulty which varies inversely with the size of the auto
company (being more of a problem as the company gets smaller). The
California-only strategy, aside from any cataiyst-system-unique pro-
duction problems, is not unusual since the auto companies have produced
California-unique emission control systems since 1966. The California-
plus strategy would require that more vehicle assembly plants become
involved in the manufacture of catalyst-equipped cars and would entail
additional complexity. Additional assembly plants would have to be con-
verted; cross-shipping of cars might also be required (at additional
consumer expense).
VI
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8. Two classes of cars can be marketed and serviced; however, there is
a major impact on the ability to do so resulting from the number of
control regions involved. The California-only strategy, with the
exception of catalyst-system-unique parts storage and service require-
ments, has been in effect since 1966 with marketing and servicing
groups set up to handle the California region and, again, is not unus-
ual. The California-plus strategy may be highly disruptive of distri-
bution, sales, and service channels unless the additional areas are
sufficiently large. Although not an impossible task, it could be very
difficult to provide a full model mix of new cars and adequate service
to all cities potentially involved in such a strategy. The degree of
difficulty, of course, increases as control areas are added.
9. The car pricing policy under the two-car strategy has not as yet been
determined by the manufacturers (e.g., adding catalyst cost increase
to cars so equipped vs spreading cost increase over all cars). It has
been suggested by General Motors that the catalyst could best be handled
as a "mandatory option" as was done in California for other emission
control components. According to Ford, the warranty interpretation
under the two-car strategy would remain as is (replace defective
parts).
10. Benefits claimed for the California-only strategy by the auto industry
are primarily economic in nature (e.g., more learning time, less-
ened assembly-line impact, warranty-recall cost statistics accumu-
lated at limited risk, etc.). The companies also feel that service,
parts distribution, and training can be more thoroughly accomplished
and evaluated in a limited area.
11. Disadvantages attributed to the California-only strategy by the auto
industry include: the one-year time period may not permit enough
mileage accumulation on catalyst systems, and the California sales
percentage of some imports is much larger than that of domestic
automakers, thus posing a more severe burden on the foreign
automakers.
12. No benefits are claimed for the California-plus strategy by the auto
industry. The companies feel that this strategy has several inherent
disadvantages, including: it increases manufacturing and distribution
problems; it involves a complex and difficult enforcement system; it-
is very disruptive of normal channels of distribution, sales, service,
and enforcement; and any areas added to California would have to be
large geographically since the strategy gets less and less feasible as
the control regions get smaller.
vii
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13 The principal impact on the purchaser of a catalyst-equipped car in
the control region is economic in nature. In addition to the higher
purchase price (unless cost increases are spread over all cars), the
owner of a low-emission catalyst car is subject to the loss of the extra
cost of the catalyst system on resale if sold outside of the control
region. Also, if higher-emission non-catalyst 1975 cars were per-
mitted into control regions, as used cars without catalyst retrofit,
such cars could undersell the catalyst-equipped cars. This could
create a strong demand within the control region for higher-emission
1975 used cars from outside the region, and make the resale of
catalyst-equipped cars difficult.
14. Owners of low-emission cars may encounter difficulties in obtaining
replacement parts if problems develop on trips outside the control
region (24 hours delays are likely, in some cases), and service in
such areas from mechanics with little or no experience on the low-
emission system may be of poor quality.
15. Catalyst-equipped cars require unleaded gasoline to function properly
in reducing emissions and to prevent degradation with lifetime. In
recognition of this requirement, present Federal regulations call for
unleaded gasoline to be available throughout the nation by July 1974.
Supply of unleaded gasoline outside a control region was cited as an
item of major concern for users of catalyst-equipped low-emission
cars on trips outside a control region, since it will be difficult to
ensure that all stations stock a fuel for which there may be little
demand.
16. Any requirement to retrofit higher-emission 1975 model cars (non-
catalyst) with 1975 low-emission vehicle control systems (catalyst)
would be a severe one. It may be physically possible, but it would
be economically impractical unless both emission control systems
were essentially the same except for the catalytic converter. This
means that retrofit to factory-installed system features and perform-
ance levels has to be planned for in advance of 1975 model year'pro-
duction commencement.
17. Most states foresee many problems in administering the two-car strat-
egy, if it were based on regional control within a state; on that basis,
statewide control would be generally preferred. On the other hand,
since many of the air quality regions have their automotive pollution
problems concentrated in smaller central business district areas, the
states also foresee many objections to having stringent control imple-
mented outside of those areas. If price differences between low-
emission and higher-emission cars were large,, the problems associated
viii
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with a metropolitan area regional control strategy would be accentuated.
The general feeling was that it would not be worth the difficulty of setting
up complicated administrative procedures to assure compliance with
the short-lived, one-year, two-car strategy.
18. Most states or regions would favor the California-only two-car strat-
egy if their air quality implementation plans were also delayed for one
year (exceptions are New York City and the District of Columbia).
Although their air quality would be adversely affected, the impact is
considered small.
19. California has serious reservations about being the only state in the
nation with catalyst-equipped cars in 1975, unless such cars were to
be in general use in other states in the following year. If this were
done, California would accept the California-only strategy for just
one-year, but only if EPA enforced its mandate for a supply of
unleaded gasoline throughout the country.
20. California is the only state that has existing procedures for admin-
istering a car control program to standards other than Federal nation-
wide emission standards. California presently has an assembly-line
inspection program and requires a certificate of compliance with
California emission standards as a condition to sale and registration
of new cars sold in the state. Also, California's size, population dis-
tribution, and natural borders tend to enhance two-car strategy control
feasibility.
21. All states (including California) lack the ability to strictly enforce the
two-car strategy on a 100 percent compliance basis. There are numer-
ous loopholes in existing registration laws (lack of verification of vehicle
domicile, "used-car" provisions, etc.) as well as fleet-sale (sold in
one state, delivered and used in another) and border dealer problems.
The time required to pass the necessary laws to completely c$gjse
existing loopholes and to set up enforcement provisions is most likely
not compatible with the 1975 model year time frame.
Some statements made here and elsewhere throughout fhe
report may appear to endorse or disapprove of one facet or another of two-
car stragegy implementation. This is a result of attempting to make ^he
fullest possible identification and discussion of the pro's and con's of the
many issues potentially associated with the two-car strategy. Such discus-
sions naturally result in positive or negative statements when relating fact
ix
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or opinion from a given point of view, and the broadest possible spectrum of
affected parties was addressed in this study. Individually and in total, how-
ever, this study and its issue-oriented subparts do not in any way represent
an endorsement or lack thereof, or a recommendation for or against a two-
car strategy of any type.
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CONTENTS
FOREWORD iii
ACKNOWLEDGMENTS iv
HIGHLIGHTS v
EXECUTIVE SUMMARY 1
1. Introduction 1
2. Car Population Location and Effects 2
3. Potential Compliance Assurance Measures 10
4. Auto Industry Considerations 14
5. State or Regional Considerations 18
6. Vehicle User Effects 21
7. Corollary Issues 25
XI
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FIGURES
1. Air Quality Control Regions 2
2. Car Registrations by Control Region (Percent of
United States Passenger Car Population) 3
3. Car Registrations by Control Region (Percent of
State(s) Passenger Car Population) 4
4. Example of High CO Concentrations in Confined
Local Area (Denver) 9
TABLES
1. Car Registration Summary (by Air Quality Control
Region) 3
2. 1971 Car Registrations--Domestic Auto Manufacturers 5
3. 1971 Car Registrations — Foreign Auto Manufacturers 5
4. Air Quality Benefits--CO (by Air Quality Control
Region) 6
5. Air Quality Benefits--Oxidant (by Air Quality
Control Region) 7
6. Cities with Greatest Air Quality Improvement--
No Delay 8
7. Car Movement Summary 11
xii
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EXECUTIVE SUMMARY
1. INTRODUCTION
This report presents a summarization and examination of
available information pertaining to issues relevant to the potential imple-
mentation of a one-year, two-car regional emission control strategy for
the 1975 model year.
Two, two-car strategy options were specified by EPA for
examination:
a. "California-only" strategy: the use of low-emission cars
in the State of California; all other states use higher-emis-
sion cars (low-emission cars conform to 1975 Federal
emissions standards; higher-emission cars conform to
1973/74 Federal emissions standards).
b. "California-plus" strategy: the use of low-emission cars
in the State of California plus other selected areas and/or
basins; all other states and/or areas use higher-emission
cars.
Sixteen air quality control regions (in addition to California) were considered
for the California-plus strategy option; they are illustrated in Figure 1.
The principal topics covered in this report are the identification
and discussion of the pro's and con's of issues which may be basic to the
implementation of the two-car emission control strategy. Emphasis has
been directed toward the results of potential implementation of such a strat-
egy in the key areas of:
a. Possible administrative measures which might be used to
assure compliance with the strategy.
b. Resultant impact on the automobile industry, the govern-
ment, and the vehicle user.
c. Emission level trends to be expected in areas in which the
strategy is implemented.
No conclusions or recommendations as to the desirability of implementing
the two-car strategy were contemplated or made.
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SEATTLE
PORTLAND
MINN/ST.PAUL
CALIFORNIA
PHOENIX/ TUCSON
FAIRBANKS
PHILADELPHIA
\
BALTIMORE
WASH. D.C.
S. LOUSIANA/
S.E. TEXAS
HOUSTON/ GAL V.
Figure 1. Air Quality Control Regions
This volume (Volume I) summarizes the more pertinent
information from this examination of issues. Further details are given in
the main body of the report (Volume II).
2. CAR POPULATION LOCATION AND EFFECTS
Under the two-car strategy, the existing passenger car pop-
ulation (number and location) in the United States was examined to determine
its effect on potential 1975 new car sales distributions, metropolitan area
air quality, and car migration factors.
2. 1 PASSENGER CAR REGISTRATIONS
Table 1 lists the passenger car registrations (domestic,
foreign, and total) for the air quality control regions of Figure 1, based on
R. L. Polk and Company data as of July 1972. Also shown in the table arc
the individual percentages of the United States total registration in each
control region, and the cumulative percent registration of all 17 control
regions examined (approximately 33 percent). Figure 2 illustrates the
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Table 1. Car Registration Summary (by Air Quality
Control Region)
AIR QUALITY
CONTROL
REGION
IAQCRI
1 CALIFORNIA (entire ttote)
2 HOUSTON, TEX
3 PHOENIX/TUSCON, ARIZ
4 SOUTH LA 4 SOUTHEAST TEX
5 BOSTON, MASS
6 PHILADEPHIA, PA
7 PORTLAND, ORE
8 FAIRBANKS, ALASKA
9 BALTIMORE, MD
10 NEW YORK CITY/NEW JERSEY
11 SPOKANE, WASH
12 DENVER. COL
13 WASHINGTON, D.C.
14 PITTSBURGH, PA
15 SEATTLE, WASH.
16 MINNEAPOLIS/ST PAUL, MINN
17 SALT LAKE CITY, UTAH
AOCR TOTALS
U.S. TOTALS
AOCR, % U.S. TOTAL
PASSENGER CAR REGISTRATIONS
DOMESTIC
7,534,754
670,449
624,307
1,120,510
1.129,069
1,268,820
674,244
IT, 108
769,624
5r 944t 995
204.831
552,023
1,090,503
1,005,013
718,153
930,095
275,233
34,723,691
77,701,402
31.82
FOREIGN
1,809,696
86,742
90,542
W.740
140,617
153,737
132,684
2,800
91,155
772,376
27,406
101, reo
76,916
94,212
134,373
66,153
41.074
3,921,973
8,737,555
44.89
TOTAL
9,344,450
957,191
714,849
1,220,250
1,269,686
1,422,557
806,928
13,908
860,779
6,717,371
232,237
653,773
1,167,419
1,099,225
852,526
996,208
316,307
28,645,664
86,438,957
PERCENT OF U.S. TOTAL
INDIVIDUAL
10.81
1.11
0.83
1.41
J.47
1.65
0.93
0.02
1.00
7.77
0.27
0.76
1.35
1.27
0.99
1.15
0.37
33.14
CUMULATIVE
10.81
11.92
12.75
14.16
15.63
17.28
18.21
18.23
19.23
27.00
27.27
28.03
29.38
30.65
31.64
32.79
33.16
10.8
0.83
0.27 Q.37
0.76
1.2
1.5
x TOTAL % = 33.1
Figure 2. Car Registrations by Control Region (Percent
of United States Passenger Car Population)
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geographical distribution of car registrations by control region, as a
percent of the total United States passenger car population. As can be seen,
aside from the California (approximately 11 percent) and the New York City/
New Jersey regions (approximately 8 percent), the individual control regions
do not have a large car population (less than Z percent in every case).
Figure 3 presents similar data for each control region; how-
ever, in this case the percent of the states' passenger car registration
included in the region is depicted. Where a state has counties in more than
one air quality control region, the percent of the registrations resulting
from all control regions is also shown. (For example, 75.8 percent of the
passenger car registrations in the State of Washington are in the Seattle,
Portland, and Spokane control regions.)
Tables 2 and 3 list the percent of 1971 new car registrations for
selected domestic and foreign auto manufacturers as a function of total new
car sales in the air quality control region and of total new car sales of the
manufacturer. California sales of the domestic manufacturers range from
WASH.
75.8 12.7
IDAHO
PENN
53.7
OREGON
71.5
70.8
NJ= 100
NY= 55
100
31.9
13.7
Figure 3. Car Registrations by Control Region (Percent of
State(s) Passenger Car Population)
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Table 2. 1971 Car Registrations--Domestic Auto Manufacturers
AIR QUALITY
CONTROL
REGION
(AQCR)
CALIFORNIA
HOUSTON
PHOENIX/TUCSON
SO. LA/TEXAS
BOSTON
PHILADELPHIA
PORTLAND
FAIRBANKS
BALTIMORE
N.Y./N.J.
SPOKANE
DENVER
WASH. D.C.
PITTSBURGH
SEATTLE
MINNEAPOLIS
SALT LAKE CITY
GENERAL MOTORS
%
AQCR
26.78
42.94
33.09
41.22
38.35
40.97
25.44
25.08
44.89
41.41
30.80
28.99
36.20
37.74
26.72
40.68
30.50
35.38
GM
TOTAL
5.34
1.11
0.4»
1.20
1.37
1.40
0.41
0.008
1.14
7.27
0.11
0.42
1.30
1.09
0.38
0.91
0.19
24.14
CUM
GM
TOTAL
5.34
6.45
6.93
8.13
9.50
10.90
11.31
11.32
12.46
19.73
19.84
20.26
21.56
22.65
23.03
23.94
24.13
--
FORD
%
AQCR
24.34
25.61
25.76
26.31
24.12
21.82
22.39
23.46
29.84
19.99
22.75
25.07
25.09
23.50
25.11
26.82
26.82
23.56
FORD
TOTAL
9.32
1.27
0.71
1.47
1.65
1.44
0.70
0.015
1.46
6.74
0.16
0.70
1.73
1.30
0.69
1.15
0.33
30.84
CUM
FORD
TOTAL
9.32
10.59
11.30
12.77
14.42
15.86
16.56
16.58
18.04
24.78
24.94
25.64
27.37
28.67
29.36
30.51
30.84
--
CHRYSLER
%
AQCR
11.36
13.44
13.87
15.60
16.15
15.28
12.38
13.29
16.71
17.39
16.06
13.20
15.92
13.66
13.28
17.14
14.43
14.56
CHR
TOTAL
7.46
1.14
0.66
1.47
1.89
1.73
0.66
0.015
1.40
10.06
0.20
0.63
1.88
1.30
0.63
1.26
0.30
32.70
CUM
CHR
TOTAL
7.48
8.60
9.26
10.73
12.62
14.35
15.01
15.03
16.43
26.49
26.69
27.32
29.20
30.50
31.13
32.39
32.69
--
AMERICAN MOTORS
%
AOCR
2.04
1.44
3.16
1.16
1.22
3.24
3.21
4.67
2.66
1.99
3.31
2.86
1.89
3.41
2.02
3.73
2.43
2.19
AM
TOTAL
7.34
0.67
0.82
0.61
0.78
2.00
0.94
0.029
1.23
6.32
0.22
0.75
1.22
1.77
0.52
1.51
0.28
27.03
CUM
AM
TOTAL
7.34
8.01
8.83
9.44
10.22
12.22
13.16
13.19
14.42
20.74
20.96
21.71
22.93
24.70
25.22
26.73
27.01
--
Table 3. 1971 Car Registrations--Foreign Auto Manufacturers
AIR QUALITY
CONTROL
REGION
(AOCR)
CALIFORNIA
HOUSTON
PHOENIX/TUCSON
SO LA/TEXAS
BOSTON
PHILADAPHIA
PORTLAND
FAIRBANKS
BALTIMORE
N.Y./N.J.
SPOKANE
DENVER
WASH. D.C.
PITTSBURGH
SEATTLE
MINNEAPOLIS
SALT LAKE CITY
VOLKSWAGEN
%
AQCR
9.97
5.21
8.38
5.86
7.38
8.54
8.60
13.35
5.71
7.49
9.29
8.90
6.59
11.27
8.33
4.48
8.71
8.17
VW
TOTAL
17.15
1.16
1.04
1.47
2.27
2.53
1.21
0.04
1.26
11.35
0.30
1.12
2.04
2.80
1.03
0.86
0.48
48.09
CUM
VW
TOTAL
17.15
18.31
19.35
20.82
23.09
25.62
26.83
26.87
28.13
39.48
39.78
40.90
42.94
45.74
46.77
47.63
48.11
—
TOYOTA
%
ACQR
7.47
5.07
5.44
4.44
4.91
2.94
6.39
8.30
2.08
3.13
4.14
5.36
2.43
1.84
6.19
2.19
5.83
4.72
TOYOTA
TOTAL
24.19
2.13
1.28
2.10
2.84
1.64
1.69
0.047
0.86
8.93
0.25
1.27
1.42
0.86
1.44
0.79
0.60
52.32
CUM
VW
TOTAL
24.19
26.32
27.60
29.70
32.54
34.18
35.87
35.92
36.78
45.71
45.96
47.23
48.65
49.51
50.95
51,74
52.34
.—
DATSUN
%
AQCR
6.30
1.27
3.99
1.71
1.48
1.10
6.50
4.34
2.15
0.60
6.54
3.66
2.10
1.28
5.53
0.67
3.18
3.17
DATSUN
TOTAL
30.32
0.79
1.39
1.20
1.27
0.91
2.56
0.036
1.32
5.07
0.59
1.29
1.82
0.89
1.91
0.36
0.49
52.20
CUM
DATSUN
TOTAL
30.32
31.11
32.50
33.70
34.97
35.88
38.44
38.48
39.80
44.87
45.46
46.75
48.57
49.46
51.37
51.73
52.22
--
-------
5 to 10 percent of their total car sales, while the foreign manufacturers'
sales are in the 17 to 30 percent range. If all regions shown were to be
controlled, the domestic manufacturers would have from 24 to 33 percent
of their total car sales affected, while the foreign manufacturers would have
from 48 to 52 percent. Thus, either control strategy would have a greater
impact on foreign manufacturers in terms of the proportional number of
new cars involved in United States sales. However, it should be noted that
the United States sales of these companies are a relatively small portion
of their overall passenger car output (e.g., Nissan ~8. 62%, Toyota ~10.11%,
Volkswagen ~15.09%).
2.2
AIR QUALITY EFFECTS
The effects of delaying the Implementation of the 1975 Federal
auto emissions standards for one year on the air quality of 20 metropolitan
areas (at the end of 1975) are summarized in Tables 4, 5, and 6. The values
in these tables reflect consideration of the 1975 Federal auto emission stan-
dards only; no allowance is made for retrofit, transportation control
Table 4. Air Quality Benefits--CO (by Air Quality Control Region)
CITY
LOS ANGELES
SAN FRANCISCO
SAN DIEGO
SACRAMENTO
HOUSTON
PHOENIX/TUCSON
S. LA. AND SE TEXAS
BOSTON
PHILADELPHIA
PORTLAND
FAIRBANKS
BALTIMORE
N.Y.C. AREA
SPOKANE
DENVER
WASHINGTON, D.C.
PITTSBURGH
SEATTLE
MINNEAPOLIS/SI. PAUL
SALT LAKE CITY
1970 CO
ppm MAX*
41.0
13.0
16.0
22. 0
NO PROBLEM
39.0
NO PROBLEM
22.4
21.8
22.5
32.2
20.6
45. 0
19.4
11.0
23.5
24.2
20.0
20. 1
19.5
1975 CO
1-yr DELAY"
ppm'
31.0
9.8
12. 1
16.6
--
29.7
--
16.9
16.3
17.0
24.3
15.6
34.0
14.5
10.6
18.0
18.3
IS. 1
15.0
18. 2
1975 CO
NO DELAY
ppm'
28.1
8.9
11.0
15.1
—
27.0
--
15.3
14.6
15.4
22.1
14.1
30.8
13.2
8.8
16.4
16.6
13.7
13.6
15.3
CO
REDUCTION
NO DELAY ppm*
2.9
0.9
1.1
1.5
—
2.7 '
--
1.6
1.5
1.6
2.2
1.5
3.2
1.3
1.8
1.6
1.7
1.4
1.4
2.9
•All concentrations averaged over 8 hr
"Federal car program only. No retrofit, transportation strategies, etc,
and at end of 1975 production
-------
Table 5. Air Quality Benefits--Oxidant (by Air Quality
Control Region)
CITY
LOS ANGELES
SAN FRANCISCO
SAN DIEGO
SACRAMENTO
HOUSTON
PHOENIX/TUCSON
S. LA. AND SE TEXAS
BOSTON
PHILADELPHIA
PORTLAND
FAIRBANKS
BALTIMORE
N.Y.C. AREA
SPOKANE
DENVER
WASHINGTON, D.C.
PITTSBURGH
SEATTLE
MINNEAPOLIS/ST. PAUL
SALT LAKE CITY
1970 OX
ppm MAX*
0.67
0.30
0.40
0.24
0.324
0. 145
0.13
0.211
NO PROBLEM
0. 14
NO PROBLEM
0.26
0.18
NO PROBLEM
0.13
0. 16
0.17
NO PROBLEM
NO PROBLEM
NO PROBLEM
PERCENT
MOBILE HC"
71
59
64
60
22
60
24
44
--
66
--
64
69
--
66
68
77
--
_-
--
1975 OX
l-yr DELAY"*
ppm*
0.501
. 0.237
0.260
0.189
0.296
0. 114
0. 119
0. 176
—
0. 107
--
0.201
0.136
—
0. 113
0. 110
0.123
.-
__
--
1975 OX
. NO DELAY
Ppm*
0.479
0.229
0.265
0.182
0.292
0.110
0.118
0.171
._
0.103
—
0.193
0.130
._
0.106
0.103
0.117
—
--
OX
REDUCTION
NO DELAY ppm*
A. 022
0.008
0.015
0.007
0.004
0.004
0.001
0.005
0.004
—
0.008
0.006
._
0.007
0.007
0.006
—
--
•All concentrations averaged over 1 hr
"Includes heavy duty vehicles
•"Federal car program only. No retrofit, transportation strategies, etc,
and at end of 1975 production
strategies, etc. All CO concentrations are assumed to be due to mobile
sources and the oxidant concentrations are assumed to be directly proportional
to HC concentrations. Air quality data are based on ciither the state imple-
mentation plans or the TRW/GCA study of 14 metropolitan areas.
Table 4 indicates that the improvement (reduction) in CO
resulting from no delay in the standards is not large (1-3 ppm); approxi-
mately 10 percent in general. Similarly, as shown in Table 5, the Improve-
ment (reduction) in oxidant resulting from no delay in the standards is gen-
erally less than 5 percent (0.001-0.02 ppm). Therefore, there is no dra-
matic improvement in air quality in these metropolitan areas with or without
the two-car strategy.
Table 6 ranks the cities examined in order of greatest benefit
in air quality due to no delay in the standards. In the case of CO, attention
is drawn to the fact that high concentrations of CO occur in a confined local
-------
Table 6. Cities with Greatest Air Quality Improvement--
No Delay*
RANK
1
2
3
4
S
6
7
8
9
10
11
12
CITY
N.Y.C. AREA
LOS ANGELES
SALT LAKE CITY
PHOENIX/TUCSON
FAIRBANKS
DENVER
PITTSBURGH
BOSTON
PORTLAND
WASHINGTON, O.C.
SACRAMENTO
BALTIMORE
PHILADELPHIA
SEATTLE
MINNEAPOLIS/
ST. PAUL
SPOKANE
SAN DIEGO
SAN FRANCISCO
IMPROVEMENT
IN CO, ppni
1975 vs 1974 STD
3.2
2.9
2.9
2.7
2.2
1.8
1.7
.6
.6
.6
.5
.5
.5
.4
.4
1.3
1.1
0.9
RANK
1
2
3
4
5
6
7
S
CITY
LOS ANGELES
SAN DIEGO
SAN FRANCISCO
BALTIMORE
SACRAMENTO
DENVER
WASHINGTON, D.C.
N.Y.C. AREA
PITTSBURGH
BOSTON
HOUSTON
PHOENIX/TUCSON
PORTLAND :
S. LA. AND
SE TEXAS
IMPROVEMENT
IN OXIDANT, ppm
1975 vs 1974 STD
0. 022
0.015
0.008
0.008
0.007
0.007
0.007
0.006
0.006
0.005
0.004
0.004
0.004
0.001
•No delay In Implementing 1975 emittlon itandards
area, as illustrated in Figure 4 for the Denver area. Optimal control, then,
may not be the control of the entire air basin and, also, the improvements in
CO shown in Tables 4 and 6 may not be truly realizable in these local areas.
In terms of improvement in oxidant level, the State of
California would appear to benefit most by being a control region in that
four of its cities (Los Angeles, San Diego, San Francisco, and Sacramento)
are among the seven cities with the greatest improvement in oxidant level;
three of the California cities (Los Angeles, San Diego, and San Francisco)
are in the top four in terms of oxidant improvement potential produced by
compliance with 1975 emissions standards.
The results shown in Tables 4, S, and 6 should be evaluated
with due consideration to the quality of the measured CO and oxidant con-
centrations and the assumptions used in the projection methodology. Some
-------
~ BiQMi**"*" _*«wwi^->1 .
- JEFFERSON COUNTY "1
SHADED AREA UNITS ARE mg/fn3 « 103
EXCEEDS STANDARD FEDERAL STANDARD IS 10mg/m3
Figure 4. Example of High CO Concentrations in Confined
Local Area (Denver)
of the factors that affect the accuracy, or at least the significance, of the
measured data are the location and elevation of the surveillance equipment,
vagaries of weather, traffic flow, and congestion. A baseline year may not
be representative of average conditions.
Regarding the extrapolation calculations to 1975, several
inherent inaccuracies are apparent and their effects should be evaluated
when more complete data are available. For example, the emission fac-
tors are based on national averages for vehicle age distributions, miles
driven per year, etc. , and do not take into account local variations, Another
consideration is the assumption of a direct proportionality between HC emis-
sions and oxidant level. When data for the Houston area are compared to
;sponding HC-oxidant envelopes for Los Angeles, Denver, Cincinnati,
-------
Philadelphia, and Washington, it is clear that there is no simple universal
correlation of HC and oxidant concentrations. Since EPA does allow a sim-
ple proportional rollback of HC to reduce oxidant levels, the relationship is
used in this study for convenience.
Finally, a possible source of large error is the fact that CO
emissions of catalyst-equipped cars may be very high at low vehicle speeds
due to insufficient exhaust mass flow to keep the catalyst temperature up to
the value necessary for good efficiency. Actual New York City test data
indicate the CO emissions from catalyst-equipped cars rise sharply in the
idling and stop-and-go speed range. Maximum CO concentrations in urban
areas occur as a result of bad traffic congestion. These effects are not
accounted for in the methodology used'herein. Similar potential effects of
high altitude and low ambient temperature on catalysts are also not
accounted for.
2. 3 CAR MOVEMENT AND MIGRATION FACTORS
Daily car travel into and out of air quality control regions
and the annual migration of cars into such regions may both be important
factors to be considered in the two-car strategy. These factors are pre-
sented in Table 7 for each control region along with daily car miles per
capita. Daily car travel across the control region boundaries is shown
relative to all car trips within the region and is labeled "% Trips External."
As can be seen from the table, 90 percent or more of daily
car travel is within the control region, implying that the majority of vehicles
within a control region would tend to stay there most of the time. The per-
cent of cars migrating into a region from out of state is quite low (5 percent
or less), also emphasizing the degree of movement stability of cars within a
given region.
3. POTENTIAL COMPLIANCE ASSURANCE MEASURES
A number of approaches are possible to assure compliance
with the two-car strategy, including use of existing or modified car
10
-------
Table 1. Car Movement Summary
AIR QUALITY
CONTROL REGION
CALIFORNIA
SOUTH COAST (L.A.)
HOUSTON
PHOENIX-TUCSON
SO. LOUIS-TEXAS
SAN FRANCISCO
BOSTON
SAN DIEGO
PHILADELPHIA
PORTLAND
SACRAMENTO
FAIRBANKS
BALTIMORE
NEW YORK
SPOKANE
DENVER
WASHINGTON
PITTSBURGH
SEATTLE
M1NNEAPOLIS-ST. PAUL
SALT LAKE CITY
DAILY CAR
MILES PER CAPITA
17.1
15.0
16.5
13.5
6.1
13.8
H.I
13.8
8.2
8.2
15.1
..
9.5
7.4
12.0
11.3
12.0
8.8
13.5
M.O
15.8
% DAILY
TRIPS EXTERNAL
—
0.67
1.5
2.7
--
1.7
8.5
5.0
10.0
9.0
7.5
—
<10.0
5.0
<9.0
6.4
8.0
<9.0
7.0
3.8
8.5
% CAR _
IN MIGRATION*
2.2
' 2.5
3.7
5.1
2.7
3.0
2.3
5.0
1.5
4.0
3.2
—
2.7
2.5
5.4
4.0
2.3
1.6
5.0
2.4
5.1
"Out-of-stote registrations
registration procedures, direct control of car dealers, car inspection, and
required retrofit of higher emission cars operating in controlled regions.
However, implementation of these procedures will require additional state
legislation, new federal regulations, and expansion of state enforcement
agencies if 100 percent compliance is required.
3. 1
VEHICLE REGISTRATION
Since all states require annual registration of new and used
cars, a pre-registration requirement that purchasers of new cars which are
to be used in controlled regions show compliance appears relatively straight-
forward. Unfortunately, existing registration procedures in most states are
not capable of being used without modification. In particular:
v
a. Very little effort is made to ensure that all cars are in fact
registered, nor are penalties for late registration severe.
11
-------
Enforcement is primarily through normal police or highway
patrol traffic activities such as stopping cars for speeding
and reckless driving and reporting and investigating accidents.
b. Although all states require an address for car registration,
none are able to verify that such an address exists, and an
applicant's legal address is not required. For purposes of
car registration, a mailing address or post office box or
second home or business address is valid.
c. Only California requires that emission control compliance
(Equipment Installation Verification) be shown prior to regis-
tration. In general, compliance requirements for new cars
would be those specified by EPA for the region where the car
was sold. Unfortunately, once a new car is registered in
another state, it becomes a "used" car. Individuals may
therefore evade any new car pre-registration emission con-
trol regulations by registering a new car in a non-controlled
adjoining state and bringing the car into a controlled area for
permanent residence.
To use existing state car registration procedures for ensur-
ing compliance with a two-car strategy, expansion of state enforcement
capabilities would be required. In addition, new federal regulations would
be required to prevent out-of-state new car sales and registration.
3.2 DEALER CONTROL
In this approach new car dealers would be required to verify
that all new cars being sold are properly equipped for the region in which
they will operate and, in particular, that residents of controlled regions
are provided low-emission cars.
Dealers might determine which car to sell by confirming a
purchaser's legal address using such information as driver's license, place
of employment, or IRS address. If, in addition, dealers in controlled areas
were provided only with low-emission cars, this approach could make it dif-
ficult to evade the two-car strategy. At present, in California, all new cars
come equipped with the "California Package" and dealers are not permitted
to sell new cars unless this package of equipment is operating when sold.
12
-------
The difficulties with this approach are:
a. Most dealers are poorly equipped to determine their
customers' legal residence or the primary area in which
the car would be used.
b. New legislation with strong enforcement provisions would
be required to ensure dealer compliance.
c. Fleet car buyers who normally purchase and register in
one area for use in another might be required to purchase
and register locally.
3.3 VEHICLE INSPECTION
All new cars in a given controlled region might be inspected
periodically to ensure that they have proper emission control devices. Inspec
tion with certification could be required as a prerequisite for annual car
registration. Such an inspection program would require new legislation and
additional funding in all states except New Jersey. In addition, modifications
in registration procedures would be required.
3.4 VEHICLE RETROFIT
A program might be established to require that all 1975
higher-emission cars which enter a controlled region be retrofitted to meet
the region's emission standards prior to registration. New state legislation
would be required to make retrofit mandatory and a prerequisite for regis-
tration. The experience of California in setting standards, testing retrofit
devices, and obtaining legislative action indicates that it would take at least
two years after the introduction of 1975 cars to implement a retrofit program.
3.5 MEASURES REQUIRED OUTSIDE CONTROL REGION
There are strong indications that higher-emission 1975 cars
may cost significantly less than new cars required in controlled regions.
Higher car costs combined with the fact that many non-controlled regions
may have lower taxes or fees, and that new car dealers in controlled regions
can legally make agreements with their counterparts outside such regions to
13
-------
send customers in return for a "finder's fee," indicate that evasion of
two-car strategy restrictions may be widespread. For example, Oregon,
which borders California, provides incentives for out-of-state new car
buyers through having no state sales tax and low registration fees. A num-
ber of potential control regions are interstate, with each state having dif-
ferent sales and local taxes, all within easy driving distance of non-
controlled areas.
Therefore, if the two-car strategy is to be completely suc-
cessful, certain controls over car registration and sales outside these con-
trol regions are needed. In particular, non-residents of states outside con-
trolled regions should not be permitted to register higher-emission cars
unless they can show that the principal use of the car would be in that state,
and sales of such higher-emission cars should be prohibited to residents of
controlled regions.
In addition, catalyst-equipped low-emission cars will require
unleaded gasoline. Therefore, unleaded gasoline should be available both
within and outside of controlled regions if residents of these regions are to
be able to freely use their cars on trips to other parts of the country.
4. AUTO INDUSTRY CONSIDERATIONS
4. 1 GENERAL ATTITUDE TOWARD/ABOUT TWO-CAR
STRATEGIES
With the exception of Chrysler (which opposes any strategy
requiring the use of catalysts), the domestic auto manufacturers are gen-
erally in favor of the California-only two-car strategy. This strategy would
only impact from 5 to 10% of each manufacturer's production. The same
companies are generally opposed to any California-plus strategy, primarily
on the basis of assembly, distribution, and marketing difficulties. If the.
California-plus strategy were implemented, however, the opinion of these
companies is that any added geographical areas should be as large as possible,
On the other hand, the foreign automakers are generally
opposed to any mandatory two-car strategy; they prefer optional phasing-in
14
-------
processes for catalysts. With regard to the California-only strategy they
feel that the percentage of their U.S. car sales in California is much too
large to represent test case purposes (e.g. , Nissan ~30%, Toyota ~24%,
VW ~17%). Their distribution and marketing problems would further esca-
late under the California-plus strategy; Nissan states that such problems
would be "too big to imagine." However, their car sales in California are
a relatively small portion of their overall passenger car output (e.g., Nissan
~5.01%, Toyota ~4.67%, Volkswagen ~5. 38%).
4.2 ABILITY TO PRODUCE TWO CLASSES OF NEW CARS
There is generally no question but that two classes of cars can
be produced; however, there is an associated degree of difficulty which varies
with the size of the auto company. It is more of a problem as the company
gets smaller (Nissan feels that they might not have adequate lead time
to get two types of cars on the assembly line). The California-only strat-
egy, aside from catalyst-system-unique production problems, is not unusual
in this regard since the auto companies have worked with California-unique
emission control systems since 1966. The California-plus strategy would
involve more assembly plants for catalyst-equipped cars and entail addi-
tional complexity. Additional assembly plants would have to be converted
to two car lines; cross-shipping of cars may also be required (at additional
consumer expense).
4. 3 ABILITY TO MARKET AND SERVICE NEW CARS
As with the case of car production, again there is generally
no question but that two classes of new cars can be marketed and serviced.
There is, however, a major impact resulting from the number of control
regions involved in a two-car strategy. The California-only strategy, again
except for catalyst-system-unique parts and service requirements, has been
in effect since 1966 with marketing and service groups set up to handle the
California region effectively.
15
-------
The California-plus strategy may be highly disruptive of
distribution, sales, and service channels unless the additional areas are
sufficiently large. It is not an impossible task, but it may be very difficult
to provide a full model mix of new cars and adequate service to all cities
involved in such a strategy. The degree of difficulty, of course, would
increase with the increasing number of added control areas.
The car pricing policy.has not as yet been determined (e.g.,
low-emission car owners charged total cost versus spreading cost out over
all cars); it has been suggested by General Motors that the catalyst could
best be handled as a "mandatory option" as was done in California for other
emission control components.
According to Ford, the warranty interpretation under the two-
car strategy would remain as is (replace defective parts).
4.4 CALIFORNIA-ONLY STRATEGY COMMENTS
SUMMARY
Claimed benefits for the California-only strategy include:
a. It provides more learning about technical unknowns.
b. It is the logical next step to current developmental test
fleets.
c. It is the closest thing to the normal industry approach for
introducing new and unproven designs.
d. If problems develop only a limited percent of the total United
States car sales would be affected (5 to 10% for domestic
manufacturers; up to 30% for foreign manufacturers).
e. It lessens assembly-line impact.
f. Service parts distribution and training can be more thor-
oughly evaluated in a limited area.
g. In the event of a recall or modification, all vehicles would
be in one geographical area.
h. It has certain potential economic benefits, e.g. , it would
guard against the cataclysmic effects of failures across
the total production line; the knowledge «gained on initial
catalyst designs would allow revisions for lower cost pro-
duction; it would provide a statistical base for projected
16
-------
warranty-re call costs at limited risk (5-10% of sales in
California for major U.S. automakers).
i. It would be a continuation of a California-only two-car
strategy begun in 1966 which has been shown to be
workable.
Claimed disadvantages for the California-only strategy
include:
a. The one-year time period may not permit enough mileage
accumulation on catalyst systems.
b. California sales of some imports are much larger than
those of domestic automakers, thus posing a more severe
burden on foreign automakers (e. g. , 30% of Nissan's sales,
24% of Toyota's sales, and 17% of Volkswagens' sales are
in California). However, their California car sales are a
much smaller percentage of their overall passenger car output
(e.g., Nissan ~5. 01%, Toyota ~4. 67%, Volkswagen-5.38%).
4. 5 CALIFORNIA-PLUS STRATEGY COMMENTS
SUMMARY
No benefits are stated or claimed by the auto industry for the
California-plus strategy. Previous General Motors support for a California-
plus strategy was based on different 1975 emission standards which in all
likelihood would not have involved the use of catalysts.
Claimed disadvantages for the California-plus strategy
include:
a. It increases manufacturing and distribution problems.
b. It involves a complex and difficult enforcement systern.
c. It is very disruptive of normal channels of distribution,
sales, and enforcement.
d. Any areas added to California would have to be large geo-
graphical areas; the strategy gets less and less feasible
as control regions get smaller.
e. Nissan claims the problems of a California-plus strategy
are "too big to imagine, " from their point of view.
17
-------
5. STATE OR REGIONAL CONSIDERATIONS
The following paragraphs summarize the state or regional
issues concerning the two-car strategy options as they impact the various
jurisdictions that are candidates for control.
5. 1 REACTIONS TO TWO-CAR STRATEGY
The California-only strategy impacts the air quality imple-
mentation plans of other states. The impact varies in degree, depending
upon the contribution of vehicle sources to the degradation of air quality in
the candidate control regions. For example, the impact is more significant
in the New York Metropolitan area than in the Minneapolis/St Paul region.
The complications associated with the implementation and
administration of a regional control strategy for a one-year period are such
that many states would prefer the option of accepting 1974 automobile exhaust
emission levels for 1975 model year cars, provided that the schedule for
meeting national air quality goals were extended. For nearly all of the
candidate control regions, an additional year of new car emissions at the
1974 level would have a relatively small effect on air quality and therefore
would be acceptable.
Most states regard regional control within the state to be an
unmanageable proposition in at least two respects. One of these concerns
public reaction within and outside of the region selected for control; the other
concerns the lack of appropriate legislation and authority for implementing,
administering, and enforcing a local control program. Many states such as
New York, Texas, Massachusetts, and Utah feel that control of a metropoli-
tan region would not be acceptable unless all similarly affected metropolitan
areas within the state were also designated as control zones. Another com-
mon objection to the regional approach was the difficulty of maintaining the
integrity of zone .control in the face of a significant price difference betveen
the two classes of new cars. Arguments against a broad-based control
region were raised in those areas where auto pollution problems are
18
-------
concentrated in small central business districts. Most frequently, however,
uniform control throughout the state was preferred to the regional control
approach.
The majority of states or regions favored the California-only
strategy. An exception was New York City, where, in the Manhattan area,
new cars and taxis represent an exceptionally large fraction of the total
vehicle population. Washington, D.C. argued in favor of 1975 exhaust emis-
sion standards, but conceded that the administrative complications in setting
up a regional control program outweighed its value for a one-year application.
California would accept a statewide California-only strategy
for a one-year period provided that EPA mandates a supply of non-leaded
gasoline throughout the nation. However, the state had serious reservations
about being saddled with an emission control system which may ultimately
prove unsuitable. A regional control strategy within the state was rejected
as unworkable.
5.2 BACKGROUND/EXPERIENCE RELATED TO
VEHICLE CONTROL
Some degree of experience and background in vehicle control
and surveillance may be found in every state. However, California is uniquely
equipped in terms of experience and regulatory procedures for the adminis-
tration of a regional emission control program. For example, California
presently has both a regionally based and a statewide-based retrofit pro-
gram. Compliance with state emission laws is a requirement for vehicle
registration. A system of state-licensed garages capable of certifying
emission equipment on a functional basis has been established. An.or\"
highway emission inspection program is in the pilot stage of developriif-nt.
The state has established procedures and a current program for assembly
line inspection. Legislation for enforcement and penalties for violation of
emission laws have been enacted. However, with all of these experience
factors and existing capabilities, much new legislation would be required
to implement the proposed two-car strategy.
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Washington, D. C. , has a mandatory yearly inspection program
for B.C. government vehicles that is tied to the existing safety inspection
program required for all D.C. passenger cars; a pilot program for private
vehicles submitted on a voluntary basis is underway. New Jersey's emission
inspection program, also tied to safety inspection, becomes fully effective
commencing July 1, 1973. Regional emission inspection programs that are
tied to areas with severe automobile pollution problems are proposed in the
implementation plans of a number of states such as Oregon, Washington,
and Arizona. These programs, when linked with vehicle registration,
represent the means by which two-car strategy control may be implemented.
A number of states have a mandatory periodic safety inspec-
tion program. Few of these programs are tied to vehicle registration. How-
ever, those of New York and New Jersey are two exceptions.
No existing regulations require proof of residency for regis-
tration. A number of states do not identify the domicile of the vehicle by
county or other jurisdiction. Accordingly, new laws and procedures would
need to be developed in each of the areas proposed for control.
Nowhere are retrofit programs in force except in the State
of California. Regional retrofit programs have been proposed in some areas
including New York City and Washington, D. C. The possibility of imple-
menting these proposed retrofit programs by 1975 seems extremely remote.
5. 3 REGION-PECULIAR FACTORS
Region-peculiar factors include:
a. California's size, population distribution, and border situ-
ation "lends itself to two-car strategy control.
b. The proximity of population centers in a number of east
coast regions requires interstate control zones in order
to realize a beneficial effect on air quality.
c. Many of the air quality control regions considered for con-
trol are largely rural with only localized mobile source
pollution problems.
\
d. Unique situations exist in Alaska and Colorado. With
regard to Alaska, catalyst control systems may not be
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effective for the Alaska cold weather and CO and ice-fog
problems. Colorado and other high-altitude areas require
waivers to adjust emission control settings for high-altitude
effectivity and vehicle driveability.
6. VEHICLE USER EFFECTS
The low-emission and higher-emission 1975 new car classes
will differ in a number of characteristics including emission control equip-
ment, cost, and operations. Many of these differences are not yet known in
detail, primarily because they will be affected by policy decisions not as yet
made. The following sections discuss possible differences between the two
types of cars and their likely effects on the vehicle user. In general it
appears that users of low-emission 1975 cars will have higher initial and
operating costs and more difficulties in resale than owners of higher-
emission 1975 cars unless specific policies are implemented to ameliorate
these burdens. Policies that would lessen the initial cost difference between
the vehicles and a requirement to retrofit higher-emission cars that move
permanently into controlled regions would help the cost and resale problems
of low-emission cars.
6. 1 HARDWARE AND COST DIFFERENCES
If 1975 Federal standards are to be met in a controlled region,
the new 1975 low-emission car will require as a minimum some kind of cata-
lyst system to reduce CO and HC emissions. Depending upon the type and
performance of the catalyst system selected, such equipment as the intake
manifold, carburetor, and ignition system may be either physically different
or have different permanent settings or calibrations. The desirability of
retrofitting higher-emission 1975 cars that move permanently into controlled
regions will be greatly affected by the type of catalyst emission control sys-
tem selected. Conversely, a requirement that retrofit be technically and
economically feasible could affect catalyst emission control system selection.
For example, if both car classes had engine and emission control systems
\
that were identical in components except for the catalytic converter, per sc,
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and perhaps its air diversion control system, then not only would retrofit be
more feasible, but also the cost differences between the car classes would
be minimized.
Initial cost differences between the two car classes will
depend upon the hardware differences as noted above and also on the car
pricing policies followed by the auto companies. Several pricing policies
• '',!;V
are possible, including:
a. Low-emission car sold at full cost of emission control sys-
tem differences.
b. Cost increases distributed over all cars.
c. Catalyst control system treated as a "mandatory option" for
the low-emission car.
The actual cost differences between the cars will determine
the extent of likely evasion of the two-car strategy by 1975 model new car
buyers and therefore influence the cost of enforcement.
6.2 OPERATIONAL AND MAINTENANCE DIFFERENCES
Based on the ground rules of this study, both cars will have
the same NO level and therefore about the same fuel consumption charac-
Jv '*
teristics. Also, basic maintenance costs should be similar for both vehi-
cles, in terms of tuneups, etc. However, the reliability of catalyst systems
is of great concern and is one of the main reasons auto companies support
strategies that will permit a "pilot" program prior to nationwide use. While
consumers should be protected by the new car catalyst system warranty,-if
repairs under this warranty become significant, the auto companies will
undoubtedly pass this cost on to consumers through increased initial costs
and parts and labor prices. If serious warranty-recall problems did arise
the car dealers could get swamped and not be able to render effective ser-
vice and repair.
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6.3 ABILITY TO MOVE FROM AREA TO AREA WITH
GIVEN CAR
Depending upon the policy decisions made and the extent of
enforcement, owners of the higher-emission 1975 cars may find that if they
permanently move into a controlled region the retrofit or forced sale of
their car will be required. Whether this situation will, in fact, occur is
dependent upon the final regulations generated for controlling the area of
new car sales and on the regulations for used cars in the control region.
Since annual migration of cars into possible control regions is normally a
small fraction (<5%) of the total number of cars within the region, forced
sale or modification of the higher-emission cars may be an unreasonable
requirement.
6.4 RESALE CAPABILITIES
Since car migration is small relative to the total number of
cars in a region, most new 1975 cars will likely be sold in their area of
original purchase. Therefore, for most sales, there would be no loss in
value even for low-emission cars with catalyst systems. However, sales
of such cars outside of controlled regions would likely result in loss of the
extra cost of the catalyst system (e.g. , just as air conditioners lose value
in cold regions).
If higher-emission cars are permitted in controlled regions
as used cars without retrofit after the one-year, two-car strategy is com-
pleted, such cars could undersell the low-emission cars. This could create
a strong demand within the controlled region for higher-emission used cars
from outside the region, and make difficult the resale of low-emission cars.
Large fleets and leasing companies may experience some
financial difficulties because cars assigned to controlled regions would have
to be sold in these regions as used cars to prevent loss of value of the cata-
lyst system. Normally, fleet and lease cars are sold wherever there is a
market and many times are sold outside the area in which they initially
operated.
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6.5 IMPACT OF REGISTRATION REQUIREMENTS
Generally no impact of registration requirements is foreseen
unless inspection and/or maintenance or retrofit is required as a prerequi-
site to registration. However, if these requirements are not imposed, then
increased migration of higher-emission cars into controlled regions may
occur for economic reasons, as mentioned above.
In particular, if the initial price of the higher-emission car
is much less than that of the low-emission car, some owners may purchase,
register, and/or license higher-emission cars out of the state or out of the
control region and then bring such a car into the control region as a used car,
6.6 IMPACT OF RETROFIT REQUIREMENTS
If retrofit of higher-emission cars brought into a controlled
region on a permanent basis is required, various results are possible.
a. If the policy is not effectively enforced and the costs are
high, many owners would be encouraged to violate the laws
requiring retrofit.
b. If the cost of retrofit is high relative to the value of the car,
owners of higher-emission cars will likely sell them prior
to moving and purchase another car for use in the controlled
region. The replacement car could be new or might be a
pre-1971^ used car. Used cars might be particularly inter-
esting if they could be operated without installation of addi-
tional emission control devices.
c. If the ability to retrofit a higher-emission car is a require-
ment levied on the automakers, the initial cost of such cars*
might be increased to cover the costs of retrofit for those
cars potentially requiring it. This could result in both car
classes being nearly the same in emission control system
configuration, except for the catalytic converter.
6.7 ABILITY TO ACQUIRE REPLACEMENT PARTS
AND SERVICE
Difficulties in obtaining replacement parts (24-hour delays
likely) may be encountered by owners of low-emission cars in areas outside
the controlled region. In addition, service in such areas from mechanics
with little experience with catalyst systems may be of poor quality.
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6.8 ABILITY TO ACQUIRE UNLEADED GASOLINE ON
TRIPS OUTSIDE OF CONTROL REGION
Low-emission cars require unleaded gasoline for proper
operation of their "catalyst systems. Present Federal regulations call for
unleaded gasoline to be available throughout the nation by July 1974. How-
ever, if for any reason, such as the fact that it is uneconomic for stations
to stock a fuel for which there is little demand, unleaded gasoline is not gen-
erally available outside of controlled regions, then several approaches arc
possible.
a. The catalyst system could be designed with a bypass that
would be adjusted for use prior to a trip outside the con-
trolled region and closed upon return to the region. To
avoid widespread use of the bypass within the controlled
region, device adjustments and legal approvals by the state
or local region control authorities would likely be required.
b. For short periods of time, leaded gasoline may not per-
manently degrade catalyst materials; therefore, in emer-
gency situations its use may be allowed. However, the
extent of catalyst degradation would be unknown unless a
testing and inspection program was established.
c. For the few trips that most people would make outside of
controlled regions, the use of higher-emission rental cars
may be desirable, and perhaps should be encouraged. In
a number of situations, such rental cars could provide bet-
ter service at lower cost than the low-emission family car
with a catalyst that requires unleaded gasoline and special
parts and service.
7. COROLLARY ISSUES
7. 1 IMPACT ON USED CAR INDUSTRY
The impact on the used car industry will bo larj.L-ly determined
by the initial price differential between the low-emission and |-,igher-emiss ion
cars and whether retrofit would be required of higher-emission cars that
move permanently to controlled regions.
a. If the cost differences are large, and retrofit is required,
most new cars would be traded and sold in the region of
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initial purchase or traded between similar regions. There
would be little incentive for selling low-emission cars out-
side control regions because the extra initial cost of their
catalyst systems would be lost on such sales, while the
retrofit requirement would likely raise the cost of the initi-
ally lower priced, higher-emission cars to a level where
there would be no cost savings to the purchaser.
b. If cost differences are large, and retrofit is not required,
there would be a strong incentive to sell the lower cost,
higher-emission cars in controlled regions, and it may be
difficult to resell low-emission cars unless the extra cost
of their catalyst systems is absorbed as a loss.
c. If cost differences are small, and retrofit is required, the
higher-emission cars would be pretty much restricted to
sales outside of controlled regions. The cost of retrofit-
ting such cars for sale in controlled regions would make
them more costly than low-emission cars.
d. If cost differences are small, and retrofit is not required,
migration of the low-emission and higher-emission cars
would be pretty much as it is today for used cars, with cus-
tomer preference determining the movement of cars.
7.2 IMPACT ON REPLACEMENT PARTS INDUSTRY
* - '" ~ - J ~~"~ " -TIT-—.- - J_n . .__ i -
It is expected that initially there would be no impact, with
dealers providing parts from the automakers and original equipment sup-
pliers. However, if, over a period of time, low-emission cars require a
high volume of replacement parts to maintain proper operation, new sup-
pliers may enter the market.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA-460/3-74-029-a
4. TITLE AND SUBTITLE
Examination of Issues Related to Two-Car Region
Emission Control Strategies
Volume I - Executive Summary
7. AUTHOR(S)
M.G. Hinton, Toru lura, Jospeh Meltzer
9. PERFORMING ORGANIZATION NAME ANO ADDRESS
Aerospace Corp.
El Segundo, Calif.
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
Emission Control Technology Division
Ann Arbor, Michigan 48105
15. SUPPLEMENTARY NOTES
3. RECIPIENT'S ACCESSION-NO.
6. REPORT DATE
al April 1973
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
ATR-73(7324)-l
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-0417
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
16. ABSTRACT
An examination and summarization of data pertaining to the issues relating
to the implementation of a two-car regional emission control strategy.
17. KEY WORDS AND DOCUMENT
a. DESCRIPTORS b.lDENTI
Automobile
Emissions
Production
Vehicle Migration
18. DISTRIBUTION STATEMENT 19. SECU
Release Unlimited Uncl
20 SECU
UncL
ANALYSIS
FIERS/OPEN ENDED TERMS C. COSATI Held/Group
RITY CLASS (Thtt Report) 21. NO. OF PAGES
assified 39
any CLASS (This page) 22. PRICE
assified
EPA Form 2220-1 (9-73)
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