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
--

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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

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          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

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         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

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                    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

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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

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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.
                                    19

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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
                                    20

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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,
                                    21

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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.
                                    22

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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.
                                    24

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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
                                    25

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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.
                                    26

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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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