EPA-460/3-74-029-B
APRIL 1973
EXAMINATION OF ISSUES
RELATED TO TWO-CAR REGIONAL
EMISSION CONTROL STRATEGIES:
VOLUME II -
TECHNICAL DISCUSSION
ti.S. ENVIRONMENTAL PROTECTION ACENCY
Office of Air and Waste Management
Office of Mobile Source Air Pollution Control
KminMon Control Technology Division
Ann Arbor, Michigan 48105
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EPA-460/3-74-029-b
EXAMINATION OF ISSUES
RELATED TO TWO-CAR REGIONAL
EMISSION CONTROL STRATEGIES:
VOLUME II -
TECHNICAL DISCUSSION
Prepared by
Merrill G. Hinton, Toru lura, and Joseph Meltzer
Aerospace Corporation
El Segundo, 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-b
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, Executive Summary, presents a brief, concise review of important
findings and conclusions in the Highlights and Executive Summary sections.
Volume II, Technical Discussion, provides a detailed discussion of each study
topic and is of interest primarily to the technical specialist. In this volume,
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
automobile manufacturers with regard to two-car strategy implementation,
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 contains a brief discussion of
possible effects on the used-car and replacement parts industries. Appendix A
contains a listing of the companies and agencies contacted in the data acqui-
sition activity. Appendixes B through G 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 Officer
for this study.
The following technical personnel of The Aerospace Corporation
made valuable contributions to the examination performed under this contract.
J. A. Drake W. M. Smalley
L. Forrest C. Speisman
B. Siegel H. M. White
Merrill G. Hinton, Director
Office of Mobile Source Pollution
Approved by:
orul^ra, Associate Group Director
Environmental Programs
Group Directorate
Joseph Meltzer, Group Dh
Environmental Programs
Group Directorate
ctor
iv
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HIGHLIGHTS
An examination and summari..ation 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
car s.
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 1 0 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.
Z. 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 oxioant 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. Thir 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 prefer 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 ~Z4%,
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 catalyst-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.
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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 Lime required to pass the necessary laws to completely close
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 the
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 the
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
VOLUME II
FOREWORD iii
ACKNOWLEDGMENTS iv
HIGHLIGHTS v
1. INTRODUCTION 1-1
1. 1 Background, Objectives, and Scope 1-1
1. 2 Acquisition of Relevant Data 1-4
1. 3 Method of Reporting 1-5
2. CAR POPULATION LOCATION AND EFFECTS 2-1
2. 1 Vehicle Registration Data and Effects 2-1
2. 1. 1 Introduction 2-1
2.1.2 Vehicle Registrations 2-2
2.1.3 Vehicle Registrations by Manufacturer 2-5
2. 1.4 Foreign New Car Registrations 2-7
2. 2 Air Quality Data and Effects 2-13
2. 2. 1 Introduction 2-13
2.2.2 CO Calculations 2-14
2. 2. 3 Oxidant Calculations 2-18
2. 2.4 Significance of Results 2-21
2. 3 Auto Movement and Migration Factors 2-25
3. POTENTIAL COMPLIANCE ASSURANCE MEASURES 3-1
3. 1 Vehicle Registration 3-1
3. 2 Dealer Control 3-2
3.3 Vehicle Inspection 3-2
3.4 Vehicle Retrofit 3-3
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CONTENTS (Continued)
3.5 Measures Required Outside Control Region 3-3
3.6 Summary 3-4
4. AUTO INDUSTRY CONSIDERATIONS i . . . 4-1
4.1 General Discussion 4-1
4.1.1 General Attitude Toward/About Two-Car
Strategies . . . 4-2
4.1.2 Ability to Produce Two Classes of New
Cars 4-5
4.1. 3 Ability to Market New Cars 4-5
4. 1.4 Ability to Service Two Vehicle Classes 4-7
4.1.5 Vehicle Identification - By Control
System Type 4-7
4.1.6 Dealer Delivery Control 4-8
4.1.7 Requirement for Retrofit of Lesser-
Controlled Cars . . . 4-10
4. 1.8 Unleaded Gasoline Requirements - Non-
catalyst 1975 Models 4-10
4.2 Discussion by Domestic Auto Company 4-11
4.2.1 General Motors 4-11
4.2.2 Ford 4-16
4.2.3 American Motors '. 4-21
4.2.4 International Harvester 4-25
4. 3 Summary of Auto Industry Considerations 4-26
4.3.1 General Attitude Toward/About Two-Car
Strategies 4-26
4. 3.2 Ability to Produce Two Classes of
New Cars 4-27
4. 3. 3 Ability to Market New Cars 4-27
4.3.4 California-only Strategy Comments
Summary 4-28
4. 3.5 California-plus Strategy Comments
Summary 4-29
xii
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CONTENTS (Continued)
5. STATE OR REGIONAL CONSIDERATIONS 5-1
5. 1 Summary of State or Regional Issues 5-1
5.1.1 Reaction to Two-Car Strategy 5-1
5.1.2 Background/Experience Related to
Vehicle Control 5-2
5. 1.3 Region-Peculiar Factors 5-3
5.2 Discussion by State 5-4.
5.2.1 California 5-4
5.2.2 Alaska 5-12
5.2.3 Arizona 5-14
5.2.4 Colorado 5-19
5.2.5 District of Columbia 5-23
5.2.6 Maryland 5-29
5.2.7 Massachusetts 5-31
5.2.8 Minnesota 5-33
5. 2.9 New Jersey 5-34
5.2.10 New York 5-38
5.2.11 Oregon 5-45
5.2. 12 Pennsylvania 5-50
5.2.13 Texas 5-54
5.2. 14 Utah 5-57
5.2.15 Washington State 5-59
6. VEHICLE USER EFFECTS 6-1
6. 1 Two-Car Hardware and Cost Differences 6-1
6.2 Operational and Maintenance Differences 6-2
6. 3 Ability to Move from Area to Area 6-2
6.4 Resale Capabilities 6-3
6.5 Impact of Registration Requirements 6-3
6. 6 Impact of Retrofit Requirements 6-4
Xlll
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CONTENTS (Continued)
6.7 Ability to Acquire Replacement Parts and Service 6-4
6.8 Ability to Acquire Unleaded Gasoline on Trips
Outside of Control Region 6-4
6.9 Summary 6-5
7. COROLLARY ISSUES 7-1
7. 1 Impact on Used Car Industry 7-1
7.2 Impact on Replacement Parts Industry 7-1
8. APPENDIXES 8-1
A. Company/Agency Visits and Contacts A-1
B. Outline Used in Data Acquisition Activities B-l
C. Supplemental AQCR Description and Car Registration
Data C-l
D. Initial General Motors Two-Car Approach D-1
E. Subsequent General Motors Statement Re:Two-Car
Strategy E-l
F. Ford Comments Re:Multiple Air Quality Regions F-l
G. Overview of State or Regional Considerations G-l
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FIGURES
VOLUME II
2-1 Two-Car Control Strategy Regions, Percent of U. S.
Passenger Car Registrations 2-3
2-2 Two-Car Control Strategy Regions, Percent of State(s)
Registration Included in Region 2-4
2-3 Two-Car Control Strategy Regions, Percent of 1971
Domestic Car Sales as Percent of Total within Indi-
cated Region 2-5
2-4 Two-Car Control Strategy Regions, Percent of 1971
Foreign Car Sales as Percent of Total Sales within
Indicated AQCR 2-6
2-5 American Motors 1971 Registrations 2-8
2-6 Chrysler 1971 Registrations 2-10
2-7 Ford 1971 Registrations 2-10
2-8 General Motors 1971 Registrations 2-11
2-9 Datsun 1971 Registrations 2-11
2-10 Toyota 1971 Registrations 2-12
2-11 Vokswagen 1971 Registrations 2-12
2-12 U. S. Imported New Car Registrations, Percent of Total
New Car Registrations 2-13
2-13 Example of High CO Being Confined to Small Area. . . . 2-22
2-14 Example of Lack of Correlation between Hydrocarbons
and Oxidant Concentrations 2-23
2-15 Average Speed Correction Factor, Carbon Monoxide. . 2-24
2-16 Emissions from a Catalyst-Equipped Automobile. . . . 2-24
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TABLES
VOLUME II
1-1 Candidate Air Quality Control Regions, (in addition
to State of California) 1-3
1-2 Companies/Agencies Contacted 1-4
2-1 Car Registrations Summary (by Air Quality Control
Regions) 2-2
2-2 Car Registrations by States with AQCR > . . 2-3
2-3 1971 Passenger Car Registrations, Domestic Auto-
mobile Manufacturers 2-7
2-4 1971 Passenger Car Registrations, Foreign Automo-
bile Manufacturers 2-8
2-5 U.S. New Imported Car Registrations, 1967/72. . . 2-9
2-6 Effect of Attitude on Automobile Emissions, Colo-
rado 2-17
2-7 Air Quality Benefits - CO, by Air Quality Control
Region 2-18
2-8 Cities with Greatest Air Quality Movement -- No
Delay 2-19
2-9 Air Quality Control Benefits - Oxidant (by Air Qual-
ity Control Region) 2-21
2-10 Car Movement Summary 2-25
5-1 Daily Vehicle Miles on Rural and Urban Systems,
State of Arizona - 1971 5-18
5-2 Denver Region Car Population Distribution 5-23
5-3 1968 Auto Travel Inside Cordon Area 5-25
5-4 Taxicab Population - Percent by Year, New York
City 5-40
5-5 Percent Passenger Car Population, New York City. . 5-40
5-6 Portland Region Car Population Distribution 5-49
xvi
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SECTION 1
INTRODUCTION
1. 1 BACKGROUND, OBJECTIVES AND SCOPE
Prior to the Suspension Request Rehearings of March, 1973,
several auto manufacturers suggested that it would be advisable and beneficial
for the nation to embark on a two-car strategy in model year 1975. These :
proposals were similar in that they were all founded on the asserted inability
to meet 1975 light-duty vehicle Federal emission standards as currently
promulgated; beyond this point the similarity ended. One such proposal in-
volved incorporating catalysts on 1975 cars in California only in order to
provide a number of immediate benefits to the auto industry (learning time,
lessening of assembly-line impact, etc. ), and, hopefully, provide later
benefits to the nation's new car buyers (increased reliability, lower costs,
etc. ) when such catalysts were eventually produced nationwide. Under this
plan, the rest of the nation would use 1975 model cars meeting 1974 Federal
emission levels.
A second proposal recommended a two-car strategy wherein
a "low-emission" car would be used in all areas of the U.S. wherein auto-
motive pollution is a serious local problem and a high-emission car (slightly
lower than 1974 levels)would be used in the rest of the nation. The "low-
emission" car in this plan would meet emission standards substantially above
currently-promulgated 1975 emission standards and might not use a catalyst
to achieve these levels. In addition, under this proposal, such a two-car
strategy would be semipermanent, and not an immediate step toward meeting
Federal 1975/76 standards on a nationwide basis.
Those hearings held on remand from the United States Court of Appeals for
the District of Columbia Circuit relative to applications for suspension of
the 1975 motor vehicle exhaust emissions standards.
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In view of the diverse proposal approaches and their concomitant
results, the present study was initiated with the following objectives:
a. To identify, review, and discuss issues related to rational
courses of action available to the Environmental Protection
Agency (EPA) under the overall heading of "two-car" or
"regional" approaches to control of exhaust emissions from
new cars
b. To present the significant issues and results, favorable and
unfavorable, in a manner that will enable EPA to evaluate
and select future courses of action.
In meeting these objectives, evaluations were to be structured
and oriented to identify the results of potential implementation of such emis-
sion control strategies in the key areas of:
a. Emission level trends to be expected in areas in which the
strategy has been implemented
b. Possible administrative measures which might be used to
ensure compliance with the strategy
c. Resultant impact or effect on the automobile industry, the
government, and the vehicle user.
The study scope was directed by EPA to focus on control
strategy options wherein, for the 1975 model year only, a low-emission car
could be utilized in a region where automobile emissions are the dominant
air pollution problem; these cars would conform to 1975 Federal emissions
standards. A higher-emission car would, then, be utilized in regions where
air quality conditions would permit their use; these cars would conform to
1973/74 Federal emission standards.
Two candidate options were examined:
a. Use of low-emission cars only in the State of California. (All
other States would use higher-emission cars. )
b. Use of low-emission cars in the State of California plus other
selected metropolitan areas and/or basins. (All other States
and/or areas would use higher-emission cars. )
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Option a. is hereinafter referred to as the "California-only" strategy; option
b. is referred to as the "California-plus" strategy. Sixteen candidate air
quality control regions (in addition to California) were considered for the
California-plus strategy option (see Table 1-1).
Table 1-1. Candidate Air Quality Control Regions
(in addition to State of California)
HOUSTON, TEXAS
PHOENIX/TUCSON, ARIZONA
SOUTHERN LOUISIANA &
SOUTHEAST TEXAS
BOSTON, MASSACHUSETTS
PHILADELPHIA, PENNSYLVANIA
PORTLAND, OREGON
FAIRBANKS, ALASKA
BALTIMORE, MARYLAND
NEW YORK CITY/NEW JERSEY
SPOKANE, WASHINGTON
DENVER, COLORADO
WASHINGTON, D.C.
PITTSBURGH, PENNSYLVANIA
SEATTLE, WASHINGTON
MINNEAPOLIS/ST PAUL
MINNESOTA
SALT LAKE CITY, UTAH
'Designated by principal included metropolitan area
or state area
The study was not concerned with the examination or determina-
tion of emission standards in any way. The entire study effort was focused
on the identification, delineation, and discussion of the pros and cons of
issues basic to two-car strategy implementation, in keeping with the objec-
tives previously stated. Accordingly, no conclusions (per se) and/or recom-
mendations as to two-car strategy implementation desirability were contem-
plated or made.
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1.2
ACQUISITION OF RELEVANT DATA
Nearly all data reported herein were acquired and developed
between 7 March 1973 and 30 March 1973. Principal data sources were
technical discussions held during this period with representatives of the auto-
motive industry and with representatives of state and/or city agencies respon-
sible for formulating and enforcing local or regional air quality criteria.
Table 1-2 summarizes the companies and agencies contacted.
Table 1-2. Companies/Agencies Contacted
COMPANIES
AMERICAN MOTORS V
CHRYSLER L
FORD V
GENERAL MOTORS V
INT'L HARVESTER L
OATSUN L
HONDA L
MERCEDES-BENZ L
TOYO KOGYO L
TOYOTA L
MVMA V
R. L. POLK V
VOLKSWAGEN L
V = Visit
L = Letter with Telecon follow-up
T = Telecon only
STATE AGENCIES
ALASKA
ARIZONA
CALIFORNIA
COLORADO
MARYLAND
MASSACHUSETTS
MINNESOTA
NEW JERSEY
NEW YORK
NEW YORK CITY
OREGON
PENNSYLVANIA
TEXAS
UTAH
VIRGINIA
WASHINGTON
WASHINGTON D.C.
T
V
V
V
T
T
T
V
V
V
V
V
V
T
T
T
V
Appendix A contains a listing of each visit or communication,
including date of contact, company/agency contacted, and personnel involved.
In all cases of visit or letter contact, an outline of the major
elements of interest in the study was utilized to form the basis of discussion
and/or reply. This outline is included herein as Appendix B.
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The identification of the candidate air quality control regions
(ACQRs) to be considered in the California-plus control strategy option was
provided by EPA. Appendix C contains a geographical breakdown (by county)
for each ACQR considered.
In addition to visits and letter contacts, the Air Quality Imple-
mentation Plan for each affected state (except Utah) was acquired and re-
viewed for relevant descriptive material, planning, and enforcement informa-
tion. Also, where available, the studies performed for EPA regarding
transportation control strategies to reduce motor vehicle emissions in the
major metropolitan areas contained in the California-plus regions were
reviewed for relevant information.
In order to provide a consistent data base for car population
location and effects determination, passenger car registration data were ob-
tained from the R. L. Polk Company for the air quality control regions of
interest, in most cases at the county level breakdown.
Many other documents of related interest were reviewed during
the course of the study and are referenced herein where they are of particular
relevance.
1. 3 METHOD OF REPORTING
The results of the study are reported in the following order
and context:
Section 2 - Car Population Location and Effects:
An identification of domestic, import, and total passenger
car registrations in the air quality control regions of
interest; an analysis of the effect of control strategy
implementation on air quality; a summary of auto move-
ment and migration factors for the various air quality
regions.
1-5
-------
Section 3 - Potential Compliance Assurance Measures;
A brief summarization of potential compliance assurance
measures, current and new procedures, and associated
problem areas.
Section 4 - Auto Industry Considerations;
Includes a detailed as well as summary overview of the
current attitudes and reactions of the auto industry to
two-car strategies. Includes delineation of foreseeable
advantages and disadvantages attendant to control stra-
tegies examined, including compliance assurance
measures.
Section 5 - State or Regional Considerations;
Includes both a summary and detailed review of the
reactions of potentially involved state and/or regional
control authorities. Extends to the impact on current
air quality implementation plans, compliance assur-
ance potential, and region-peculiar factors.
Section 6 - Vehicle User Effects;
A brief summary of the possible impact of a two-car
strategy on the vehicle user in terms of operational and
maintenance effects, cost effects, compliance assurance
requirements, and ability to acquire unleaded gasoline
for catalyst-equipped car.
Section 7 - Corollary Issues;
A short summary of possible impacts on the used-car
and replacement parts industries.
\ It is to be noted that the content of Section 3 overlaps to some
extent with portions of Sections 4, 5, and 6. The auto industry, state govern-
ments, and vehicle owners may all be intimately affected by compliance
assurance measures which could be implemented under a two-car control
strategy. For completeness of thought and purpose, individual comments
regarding compliance assurance are given in Sections 4, 5, and 6 to enable
1-6
-------
a complete picture of the overall response of the company/agency in question.
The compliance assurance measure issue is initially summarized in Section 3
to present a concise view of the nature of the compliance-assurance problem
prior to stating individual company/agency responses to the issue.
1-7
-------
SECTION 2
CAR POPULATION LOCATION AND EFFECTS
The physical numbers and locations of the existing passenger
car population in the United States were examined for their effects under a
two-car strategy on potential 1975 new car sales distributions, metropoli-
tan area air quality, and car migration factors. The following sections
summarize the significant results of these examinations.
2. 1 VEHICLE REGISTRATION DATA AND EFFECTS
2.1.1 Introduction
Passenger car registration data presented in this section are
based on information received from R. L. Polk and Company, (Ref. 2-1),
covering domestic and foreign passenger cars in operation in the U.S. as
of July 1, 1972. These data are further broken down by vehicle make, model
year, and county of registration within each Air Quality Control Region
(AQCR) of concern.
State motor vehicle registration data, obtained during visits
to each state's motor vehicle departments, were found to be as much as 10%
higher than R. L. Polk data. These differences in passenger car registra-
tions may be attributed to several factors. One of these is that the available
state statistics were mixed with respect to the period of registration and in
many cases included light-duty pick-up trucks and vans within the passenger
car category.
Other differences include such factors as late or delinquent
registrations not recorded by the state in time to be tabulated by R. L. Polk
and the double count experienced by California (Ref. 2-2) whereby, for
example, a car first registered in September of a given year and renewed
in the annual registration in February would be counted twice within the
fiscal year, since the state registration data represents "processed work load"
rather than the number of separate vehicle registrations.
2-1
-------
Therefore, in order to provide a consistent set of data based
only on passenger car registrations, the R. L. Polk data have been used in
this section unless otherwise indicated.
2. 1.2
Vehicle Registrations
The total number of passenger cars in operation in the United
States as of 1 July 1972 was 86, 438, 957, of which 8, 737, 555 (10.1 percent)
were of foreign manufacture. A summary breakdown of these totals by
AQCR is presented in Table 2-1. It should be noted that the figure shown
in this table for California is for the entire state rather than specific AQGRs.
The number of passenger cars within each state encompassing
an AQCR is presented in Table 2-2, from which it can be seen that 49 per-
cent of all U.S. passenger cars are within the 18 states listed.
Table 2-1. Car Registrations Summary
(by Air Quality Control Regions)
AIR QUALITY
CONTROL
REGION
(AOCR)
1 CALIFORNIA (entire itota)
2 HOUSTON, TEX
3 PHOENIX/TUSCON, ARIZ
4 SOUTH LA & SOUTHEAST TEX
5 BOSTON, MASS
6 PHILAOEPHIA. PA
7 PORTLAND, ORE
8 FAIRBANKS, ALASKA
9 BALTIMORE, MD
10 NEW YORK CITY/NEW JERSEY
II 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
It 39,069
1,266,820
674,244
11,108
769,624
5,944,995
204,831
552,023
1,090,503
1.005.013
718,153
930,095
275,233
24,723,691
77,701,402
31.82
FOREIGN
1,809,696
86,742
90,542
99,740
140,617
153,737
132.684
2,800
91,155
772,376
27,406
101.750
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
1.47
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
2-2
-------
Table 2-2. Car Registrations by States with AQCR
STATE
CALIFORNIA
TEXAS
ARIZONA
LOUISIANA
MASSACHUSETTS
PENNSYLVANIA
OREGON
WASHINGTON
ALASKA
MARYLAND
NEW YORK
NEW JERSEY
IDAHO
COLORADO
WASH, D.C.
VIRGINIA
MINNESOTA
UTAH
TOTALS
TOTAL
9,344,450
4,617,455
842,893
1,323,596
2,228,662
4,690,633
963,936
1,515,485
101,724
1,488,071
6,224,601
3,260,464
308,769
1,091,215
369,325
1,804,603
1,756,706
456,502
42,389,090
PERCENT OF U.S. TOTAL
INDIVIDUAL
10.81
5.34
0.98
1.53
2.58
5.43
1.12
1.75
0.12
1.72
7.20
3.77
0.36
1.26
0.43
2.09
2.03
0.53
CUMULATIVE
10.81
16.15
17.13
18.66
21.24
26.67
27.79
29.54
29.66
31.38
38.58
42.35
42.71
43.97
44.40
46.49
48.52
49.05
0.27 o. 37
9.5/10
0.83
0.76
1.2
TOTAL % = 33.1
Figure 2-1. Two-Car Control Strategy Regions
Percent of U.S. Passenger Car Registrations
2-3
-------
The number of passenger cars in operation within each AQCR
expressed as a percentage of the U.S. total is shown in Figure 2-1. Dual
figures are given for California, with 9. 5 percent of the U.S. total being
located within the AQCRs and 10. 8 percent within the entire state.
The number of cars within each AQCR expressed as a per-
centage of the state total is shown in Figure 2-2. In those cases where the
AQCR is located in 2 states (e.g., Portland, Spokane, etc.), the combined
totals for the states involved have been used to obtain the indicated percent-
ages. Within California, 87.5 percent of the cars are within the specified
regions, while 1 JO percent would be considered in the case of a California-
only two-car strategy. New Jersey is also shown as 100 percent since all
21 counties within the state were included in the New York City/New Jersey
Air Basin.
WASH.
75.8 12.7
PENN
23.4 53.7
OREGON
71.5
87.5/100
f^
M::Vf\
13.7
TEXAS
25
20.7
20.5
70.8
NJ = IOO
NY= 55
31.9
Figure 2-2. Two-Car Control Strategy Regions
Percent of State(s) Registration Included in Region
2-4
-------
A more detailed delineation of both population and passenger
cars in operation within each AQCR and state is presented in Appendix C
wherein AQCR, State, and U.S. totals are shown as well as the percentage
of U.S. totals within each region and state.
The percentage of domestic new car registrations (1971) of
the 1971 total within each AQCR is shown in Figure 2-3. The complemen-
tary percentage for total (1971) foreign cars is shown in Figure 2-4. Both
figures clearly indicate a significantly higher percentage of foreign cars in
the far western AQCRs.
2. 1. 3
Vehicle Registrations by Manufacturer
The relative impact of each of several individual auto manu-
facturers was examined in terms of the percentage of cars within each AQCR
,72.2
83.9
Figure 2-3. Two-Car Control Strategy Regions
Percent of 1971 Domestic Car Sales as Percent
of Total Sales within Indicated Region
2-5
-------
27.8
36.5
19.7
Figure 2-4. Two-Car Control Strategy Regions
Percent of 1971 Foreign Car Sales as Percent
of Total Sales within Indicated AQCR
as well as the percentage of their total new car registrations within each
region. Data for four domestic manufacturers (American Motors, Chrysler,
Ford, and General Motors) and three foreign manufacturers (Datsun, Toyota,
and Volkswagen) were examined based upon the R. L. Polk data in conjunc-
tion with new car registration totals by manufacturer (as reported in Refs.
2-3 and 2-4).
The four domestic manufacturers accounted for 99.94 percent
of all domestic new car registrations and 84. 9 percent of the U.S. total for
1971. The three foreign manufacturers accounted for 65.6 percent of all
imports in 1971 and 9.9 percent of the U.S. total. Virtually the entire
remaining 5 percent of the U.S. total was accounted for by all other imports.
The relative position within each AQCR is summarized for the
domestic manufacturers in Table 2-3. It will be noted that approximately
2-6
-------
Table 2-3. 1971 Passenger Car Registrations
Domestic Automobile Manufacturers
AIR QUALITY
CONTROL
REGION
1 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
CM
TOTAL
5.34
Ml
0.48
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
CM
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
%
A OCR
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
%
A OCR
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
7.46
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
--
24 to 33 percent of their 1971 passenger cars are located within the AQCRs of
concern. By comparison, it will be noted in Table 2-4 that 48 to 52 percent
of the foreign cars are located within the air basins. 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. 1 1%, Volkswagen ~ 15. 09%).
The total of each manufacturer's vehicles, as a percentage
of the AQCR total and as a percentage of the manufacturer's total, is shown
graphically by AQCR for each of the four domestic and three foreign manu-
facturers in Figures 2-5 through 2-11. A more detailed breakdown is given
in Appendix C.
2.1.4
Foreign New Car Registrations
Foreign new car registrations of the ten top makes in the United
States, by make, are shown in Table 2-5 for each year from 1967 through 1971
(RcCs. 2-4 and 2-5 for 1972). A breakdown by manufacturer is not yet available
2-7
-------
Table 2-4. 1971 Passenger Car Registrations
Foreign Automobile Manufacturers
AIR QUALITY
CONTROL
REGION
I AQCR 1
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
%
A OCR
9.97
S.21
8.38
5.86
7.38
8.54
8.60
13.35
5.T1
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
48.00
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. M
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
..
% AQCR TOTAL
A % A.M. TOTAL
Figure 2-5. American Motors 1971 Registrations
2-8
-------
Table 2-5. U.S. New Imported Car Registrations, 1967/72 (Refs. 2-4 and 2-5)
M.-ike
Volkswagen
Tovota
Datsun
Opel
Capri
Volvo
Fiat
Mercedes -Benz
,\1C
Colt
Renault
English Ford
Std Triumph
All Others
Total Imports
Total U.S.
Imports. ^ U.S.
967
K t- g i s t r a -
tions
452. '.'37
33. 280
34. 028
50. 866
34, 392
£
19, 761
22. 387
19. 362
16. 19'
15. 306
80, 208
779, 220
8, 357. -121
9. 3
irh
U.S.
5. 1
0. 4
0. 4
0.6
0. 4
0.2
0. 3
0. 2
0. -
0. 2
1. 0
Cum.
% U.S.
5.4
5. S
6.2
6.8
7.2
7. 4
7. 7
7.9
8. 1
8. 3
9. 3
1968 1969
R eiiisira -
tions
563, 522
68. 779
40,219
80. 366
38. 335
28. 377
23.724
>:.
19. 359
22,983
18. 600
SI. 503
935, 767
9.403. 862
10. 5
3.
U.S.
6.0
0. 7
0.4
0.9
0. 4
0. 3
0. 3
0. 2
0. 2
0.2
0.9
Cum .
«i U.S.
6.0
6. 7
7. 1
8.0
8. 4
8. 7
9.0
9. 2
9. 4
n.6
10. 5
Registra-
tions
537,933
1 17, 384
58, 569
91. 161
36, 448
41, 519
24,693
21. K06
17,735
20, 750
:=:::
93,619
1.061.600
9,446. 524
11.2
a-^
U.S.
5. 7
1.2
0.6
1.0
0.4
0. 4
0. 3
0.2
0.2
0. 2
1.0
Cum.
TO u.s.
5. 7
6.9
7. 5
8. 5
8.9
9. 3
9.6
9. 8
10.0
10. 2
II. 2
1970
R cgi st ra -
tions
569. 182
184. 898
100, 541
83, 189
15,628
44,630
36.642
28.743
30, 548
:;
19, 589
-: -
->-
1 17, 371
1,230.961
8, 388. 204
14.7
To
U.S.
6. 8
2. 2
1.2
1.0
0. I
0. 5
0. 4
0. 3
0.4
0.2
I. 4
Cum.
% U.S.
6.8
9.0
10.2
11.2
11.4
11.9
12. 3
12.6
13.0
13.2
14.6
1971
Registra-
tions
509. 207
270. 512
182. 058
85. 554
53. 219
47,012
42.621
32,651
30,950
26, 503
rt-.-
,..,
.!:£
185. 386
1.465.673
9.729. 109
15. 1
7.
U.S.
5. 2
2.8
1.9
0.9
0. 5
0. 5
0. 4
0. 3
0. 3
0. 3
1.9
Cum.
% U.S.
5.2
B. 0
9.9
10. 8
11.3
11.8
12.2
12. 5
12.8
13. 1
15.0
1972 (P)
Regist ra -
tions
1,428, 500
9, 834, 500
14. 5
%
U.S.
Cum.
% U.S.
t-J
I
\"oi in production
Not in top ten
(PI Preliminary ami incomplete
-------
16.2
1.9,
15.9
1.6
15.8
* 1.3
% AQCR TOTAL
A % CHRYSLER TOTAL
Figure 2-6. Chrysler 1971 Registrations
24.3
A 9.3
25.6 *26.8
A 1.3 A 1.2
% AQCR TOTAL
A % FORD TOTAL
Figure 2-7. Ford 1971 Registrations
2-10
-------
29.0 30.6 .40.7
»V . A 0.
% AQCR TOTAL
A % CM TOTAL
Figure 2-8. General Motors 1971 Registrations
A 0.04
% AOCR TOTAL
A % DATSUN U.S. TOTAL
Figure 2-9. Datsun 1971 Registrations
2-11
-------
1.8
4.9
% AOCR TOTAL
A % TOYOTA U. S. TOTAL
Figure 2-10. Toyota 1971 Registrations
9.3
A 0.04
% AOCR TOTAL
A % VW TOTAL U.S.
Figure 2-11. Volkswagen 1971 Registrations
2-12
-------
for 1972, although preliminary (but incomplete) totals have been published
by the Department of Commerce (Ref. 2-6) based on data from R. L. Polk.
This information is displayed graphically in Figure 2-12, where it will be
noted that over 75 percent of the increase between 1969 and 1970 was attri-
butable to Datsun, Toyota, and Volkswagen.
2.2
2.2. 1
AIR QUALITY DATA AND EFFECTS
Introduction
The purpose of this portion of the study was to estimate the
effect of delaying the implementation of the 1975 Federal auto emission
standards for one year (1974 standards continuing in effect) on the air qual-
ity of 20 metropolitan areas at the end of 1975. Attention was focused on
ALL OTHERS
(incl. Capri)
HONDA
(0.1%, 1971)
MAZDA
(0.2%, 1971)
M-B
OPEL
1967 1968 1969 1970 1971
Figure 2-12. U. S. Imported New Car Registrations
Percent of Total New Car Registrations
2-13
-------
carbon monoxide (CO) and photochemical oxidants (O ), since these are the
7C
air quality factors that would be affected by the 1975 standards. While it is
true that the auto emission standards regulate hydrocarbons (HC) rather than
oxidants, the latter were calculated for several reasons. Hydrocarbons do
influence oxidant concentrations, although the functional relationship is
uncertain; this question will be examined later. In addition, a minimum of
hydrocarbon monitoring data are available and, also, a reduction in the
hydrocarbon emissions sufficient to allow photochemical oxidants to meet
air quality standards is deemed sufficient even if the specified hydrocarbon
standard has not been reached (Ref. 2-7). Only the 1975 Federal auto emis-
sion standards were considered; no allowance was made for retrofit, trans-
portation strategies, etc.
Air quality data -were taken either directly from the state
implementation plans or the TRW/GCA study of fourteen metropolitan areas
(see, for example, Ref. 2-8). The significance and uncertainty of such data
are discussed in the final paragraph of this section. Maximum 8-hour aver-
aged concentrations were found for various dates in the 1968 to 1972 time
period, depending upon location; they were reduced to a common 1970 base-
line by the same techniques used to estimate 1975 concentrations.
The following sections describe the computational procedures
for the CO and O concentrations and some of the factors that affect the
x
accuracy and significance of the results.
2.2.2 CO Calculations
All CO concentrations were assumed to be due to mobile
source emissions. This is an approximate but not unreasonable assump-
tion, since emission inventory data indicate that vehicles in metropolitan
areas contribute over 80 percent, and in many cases over 90 percent, of
the CO measured. However, light-duty vehicles (<6000-lb gross weight)
must be separated since their relative CO contributions will change over
the time period of interest. Based upon registration data for these vehicles
in the late 1960s, it was calculated that 86.5 percent of the vehicles were .
2-14
-------
light duty and 13.5 percent were heavy duty. It was also apparent from the
data that the number of heavy-duty vehicles was increasing at a rate of
approximately 5. 5 percent per year, whereas there was much less change
in the number of light-duty vehicles.
The remaining piece of needed data was the change in vehicle
CO emissions with time. Use we.s made of data in Ref. 2-9 (specifically
Fig. 2.7) which shows the fractional change in CO emissions from I960 on,
and the effect of various options for implementation of emission standards.
The data were derived from a computer model for automotive emissions in :
a typical urban area, accounting for such factors as vehicle age distribution,
vehicle mileage as a function of age, deterioration of emission controls with
mileage, etc. The emissions were normalized against a maximum value;
since only ratios were used in the calculations, absolute numbers were not
needed. The factors for the years of interest are:
1968 0.97
1969 0.92
1970 0.86
1971 0.78
1975 0.51 (with 1975 Federal standards)
1975 0.58 (one-year delay in 1975 standards)
These data accounted for the light-duty vehicle emissions only. For the
heavy-duty vehicles, it was noted in Table 13 of Ref. 2-10 that CO emis-
sions are essentially constant at 130 to 140 gm/mi over the entire period
of interest. Therefore, the only change' for these vehicles would be due to
the 5. 5 percent yearly growth factor assumed.
A typical calculation for the San Francisco area will illus-
trate the use of the above data.
1970: 13 ppm CO, maximum 8-hour concentration
1975 estimate with 1975 Federal car standards:
2-15
-------
c°ppm = <"7° c°> <*
(1 + growth factor /year X no. years)
= (13) (0.865) (§7g£) + (13) (0. 135) (1 + 0.055 X 5)
= 8.9
1975 estimate with one-year delay in 1975 Federal
standards:
CO = (13) (0.865) + (13) (°- 135) (J + 0-055 X 5)
ppm \ U. oo /
= 9.8
Therefore, the improvement in CO air quality due to imposing
1975 standards without a delay is 0.9 ppm. A similar procedure was used to
convert measured values for years other than 1970 to the 1970 baseline, and
to compute 1975 concentrations for all cities other than Denver and Salt Lake
City. The latter are classified as "high-altitude cities" (above 3500 ft) and
require an additional correction factor. This correction was calculated from
data in Ref. 2-10, giving emission factors for high and low altitude cities as
a function of vehicle model year, summarized in Table 2-6, also the fraction
of total miles driven by each model year. The procedure is illustrated for
the case of light-duty vehicles with no delay in 1975 standards:
For 1970
Product
0. 176
0.209
0.216
0.905
£ = 1.506
2-16
Model
Year
1970
1969
1968
pre- 1968
Fraction of
Total Miles
0.088
0. 174
0. 135
0.603
Emissions per Mile
at High Alt. Divided
by Emissions per
Mile at Low Alt.
X
X
X
X
2.0
1.2
1.6
1. 5
-------
For 1975
Model
Year
1975
1974
1973
1972
1971
1970
1969
1968
pre- 1968
Fraction of
Total Miles
0.088
0. 174
0. 135
0. 103
0. 115
0.097
0.083
0.060
0. 145
Emissions per Mile
at High Alt. Divided
by Emissions per
Mile at Low Alt.
X
X
X
X
X
X
X
X
X
1.0
2.2
2.2
2.2
2.2
2.0
1.2
1.6
1. 5
Product
£ = 1.856
Table 2-6. Effect of Altitude on Automobile Emissions
Colorado
MODEL
YEAR
PRE-1968
1968
1969
1970
1971
1972
1973
1974
1975
EMISSION RATIO*
CO
1.5
1.6
1.2
2.0
2.2
2.2
2.2
2.2
1.0
HC
1.1
1.3
1.2
1.7
1.8
1.8
1.8
1.8
1.0
'Emissions per mile at high altitude divided
by emissions per mile at sea level
2-17
-------
The multiplying factor for light -duty vehicles to account for high-altitude
1 856
effects is then ' or 1-23. Note that the high-altitude to low-altitude
emission factor for 1975 is 1.00, which assumes that all vehicles meet the
1975 standards. To calculate the correction factor for a 1-year delay, the
1974 ratio of 2.21 was used for 1975. Similar calculations were made for
heavy-dxity vehicles, but the correction was so close to 1 that the effect was
insignificant. The results are presented in Table 2-7 for all the cities and
ranked in Table 2-8 by the amount of improvement in air quality resulting
from the imposition of 1975 standards on time. Note that the Southern Louis-
iana and Southeast Texas "city" represents primarily the New Orleans area.
2.2.3
Oxidant Calculations
The basic assumption made in calculating the 1975 oxidant
levels was that oxidant concentration is directly proportional to HC
Table 2-7. 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/ST. 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
l-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
16.2
1975 CO
NO DELAY
ppm*
28.1
8.9
11.0
IS. 1
27.0
15.3
14.8
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
I.T
1.4
1.4
2.9
All concentrations averaged over B hr
Federal car program only. No retrofit, transportation strategies, etc,
and at end of 1975 production
2-18
-------
Table 2-8. Cities with Greatest Air Quality Movement -- No Delay'"
RANK
1
2
3
4
5
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. D.C.
SACRAMENTO
BALTIMORE
PHILADELPHIA
SEATTLE
MINNEAPOLIS/
ST. PAUL
SPOKANE
SAN DIEGO
SAN FRANCISCO
IMPROVEMENT
IN CO, ppm
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
8
CITY
LOS ANGELES
SAN DIEGO
SAN FRANCISCO
BALTIMORE
SACRAMENTO
DENVER
WASHINGTON, O.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
O.OIS
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 197S emission standards
concentration. Although this relationship is open to serious question, as
will be discussed later, it is very commonly employed and probably satis-
factory for purposes of this study.
The computational procedure based on the above assumption
differed somewhat from that for CO. Unlike the latter, emissions of HC
are not so predominantly from mobile sources and, in addition, show a con-
siderable variation in the mobile source contribution with locality. Of course,
the significance of distinguishing the source of HC lies in the fact that it is
the effect of 1975 auto standards that is of interest. The division of HC
emissions was estimated from emission inventories, and the assumption
was made that stationary source emissions would not decrease appreciably
in the 1970/75 period. The projected emissions for autos were again based
2-19
-------
upon data in Ref. 2-9 showing the effect of varying the time for implementing
standards on HC emissions. The factors used in the calculations were:
1969 0.82
1970 0.76
1971 0.70
1972 0.64
1975 0.38 (with 1975 Federal standards)
1975 0.42 (1-year delay in 1975 standards)
For heavy-duty vehicles, data in Ref. 2-10 indicated little expected decrease
in HC emissions to 1975; therefore, as in the case of CO, only the growth
factor of 5. 5 percent per year changed the contribution of these vehicles.
The following is a typical O calculation for the San Francisco
area.
1970: 0.30 ppm O , maximum 1-hour concentration
mobile contribution: 59 percent or 0. 177 ppm
1975 estimate with 1975 Federal car standards:
O = (1970 stationary O ) + (1970 mobile O ) [~(% LDV)
x ppm 7 x x {_
/1975 emission factor\ , iat -.,,» I4 . ., , . /
Il970 emission factor) + <% HDV) (1 + growth factor/year
X no. years)
= 0. 123 + (0. 177) F(0. 865) (^|) + (0. 135) (1 + 0. 055 X 5)1
= 0.229
1975 estimate with 1-year delay in 1975 Federal car
standards:
O =0. 123 + (0. 177) ["(0.865) f^4r) + (0. 135) (1.275)1
x ppm I \0.767 J
= 0.237
2-20
-------
Therefore, the improvement in O concentration due to imposing the 1975
X
standards on time is 0.008 ppm. Results for all cities are given in Table 2-9,
and the ranking in Table 2-8. Only Denver required calculation of an altitude-
correction factor; the procedure was similar to the CO case.
Table 2-9. Air Quality Benefits - Oxidant
(by Air Quality Control Region)
CITY
LOS ANGELES
SAN FRANCISCO
SAN 01 EGO
SACRAMENTO
HOUSTON
PHOENIX /TUCSON
S. LA. AND SE TEXAS
BOSTON
PHILADELPHIA
PORTLAND
FAIRBANKS
BALTIMORE
N.Y.C. AREA
SPOKANE
DENVER
WASHINGTON, O.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
84
60
22
60
24
44
--
66
--
64
69
--
66
86
77
--
..
--
1975 OX
1-yr DELAY*"
ppm'
0.501
0.237
0.280
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*
0.022
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
..
_-
--
*AII concentrations averaged over 1 hr
Includes heavy duty vehicles
'Federal car program only. No retrofit, transportation strategies, etc,
and at end ol 1975 production
2.2.4 Significance of Results
There is no dramatic improvement in the air quality in the
control regions with catalyst-equipped cars during the one-year period
examined. They would have an approximately 10-percent reduction in CO
and approximately 5-percent reduction in oxidant level beyond that level
resulting if only 1974 emission standards were in effect throughout the
1975 model year.
The results of these calculations should be evaluated with due
consideration to the quality of measured CO and O concentrations and the
5C
assumptions in projection methodology. Some of the factors that affect the
2-21
-------
accuracy, or at least the significance, of the measured data are location
and elevation of the surveillance equipment, vagaries of weather, traffic
flow, and congestion. A baseline year may not be representative of aver-
age conditions. In addition, high concentrations of pollutants such as CO,
occur very locally, as illustrated in Figure 2-13 for the Denver area.
Therefore, optimal control may not mean control of the entire air basin.
Regarding the extrapolated 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 from Ref. 2-9 were based on national averages for vehicle age dis-
tributions, miles driven per year, etc. They did not take into account local
variations. Another consideration is the assumption of a direct proportion-
ality between HC emissions and oxidant level. Figure 2-14, taken from
Ref. 2-8, shows data for the Houston area and, for comparison, a dashed
line corresponding to the envelope for Los Angeles, Denver, Cincinnati,
Philadelphia, and Washington. It is clear that there is little correlation of
HC and oxidant concentrations. Since EPA does allow a simple proportional
- -BO.U.LDE B_£flUNI Y -j
JEFFERSON COUNTY |
SHADED AREA
EXCEEDS STANDARD
UNITS ARE mg/m3 x I03
FEDERAL STANDARD IS 10 mg/mj
f
Figure 2-13. Example of High CO Being Confined to Small Area
2-22
-------
0.35
0.30
E
£t 0.25
LJ
O
HOUSTON
FROM "HYDROCARBON AIR
QUALITY CRITERIA" (Rel. 2-10)*
°-20
O 0.15
2 o.io
x
0.05
012 345.
6-9 AM AVERAGE TOTAL HYCROCARBON (ppm)
Figure 2-14. Example of Lack of Correlation between
Hydrocarbons and Oxidant Concentrations
rollback of HC to reduce O levels, the relationship was used in this study
for convenience. Finally, a possible source of large error could be the fact
that CO emissions of catalyst-equipped cars may be very high at low vehicle
speeds, due to insufficient mass flow to keep the catalyst temperature up to
the value necessary for good efficiency. For example, the speed correction
factor recommended in Ref. 2-10 is reproduced in Figure 2-15. It is nor-
malized to a value of 1.0 at a speed of 19.6 miles per hour used in the 1975
Federal Test Procedure. Actual New York City test data, shown in Fig-
ure 2-16, indicate that emissions from catalyst-equipped cars have a sub-
stantially different variation with speed, rising sharply in the idling and
stop-and-go speed range. Maximum CO concentrations in urban areas
occur as a result of bad traffic-jam situations, not 19.6 mile-per-hour
driving. These effects are not accounted for in the methodology of Ref. 2-10.
Similar potential effects of high altitude and low ambient temperature on
catalysts are also not accounted for.
2-23
-------
1.5
(J 1.0
O
in
at
o
LI
ui
ft
ALL MODEL YEARS
15 30 45
AVERAGE ROUTE SPEED, mph
0.39
J
60
Figure 2-15. Average Speed Correction Factor, Carbon Monoxide (Ref. 2-10)
1971 PLYMOUTH FURY No. 378
OCTOBER 12, 13, 1972
501
40
£ 30
O
10
2 20
5
ui
8 10
0 4 8 12 16 20
VEHICLE AVERAGE SPEED mph
Figure 2-16. Emissions from a Catalyst - Equipped Automobile (Ref. 2-12)
2-24
-------
2. 3
AUTO MOVEMENT AND MIGRATION FACTORS
Both the daily auto travel into and out of AQCRs and the annual
migration of autos into such a region may be important factors to be con-
sidered in a two-car strategy. These factors along with daily auto miles per
capita are presented in Table 2-10. Daily auto travel across AQCR bound-
aries is shown relative to all auto trips within the AQCR and is labeled "%
Trips External."
Table 2-10. Car Movement Summary
AIR QUALITY
CONTROL REGION
CALIFORNIA
SOUTH COAST (L. A.)
HOUSTON
PHOENIX -TUCSON
SO. LOUIS-TEXAS
SAN FRANCISCO
BOSTON
SAN 01 EGO
PHILADELPHIA
PORTLAND
SACRAMENTO
FAIRBANKS
BALTIMORE
NEW YORK
SPOKANE
DENVER
WASHINGTON
PITTSBURGH
SEATTLE
MINNEAPOLIS-ST. PAUL
SALT LAKE CITY
DAILY CAR
MILES PER CAPITA
17. 1
15.0
16.5
13.5
6. 1
13.8
11.1
13.8
8.2
8.2
15.1
9.5
7.4
12.0
11.3
12.0
8.8
13.5
14.0
15.8
% DAILY
TRIPS EXTERNAL
0.67
1.5
2.7
--
1.7
8.5
S.O
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-state registrations
Information on the percentage of external trips and daily auto
miles per capita was obtained for the most part from the many local area
transportation studies conducted over the past 15 years (Refs. 2-14 through
2-34). Auto migration data are not kept by most states, so a procedure was
developed based on the migration of people into AQCRs viz:
2-25
-------
Annual Auto Migration = (Annual Per sons-in-Migration)
X (Ratios of Autos Per Person
in the United States = 0.405)
Annual per sons-in-migration to AQCRs can be obtained from a report pub-
lished by the Bureau of the Census on "Migration Between State Economic
Areas." (Ref. 2-34) Some adjustment of the data in this report is required:
a. The report provides data on the migration of individuals 5
years of age or over. The ratio of total population to popu-
lation 5 years of age or older was used to account for migra-
tion of individuals younger than 5 years of age.
b. The report shows a significant number of people for whom
it is not possible to determine whether they are immigrants
or not. It was assumed that the fraction of these individuals
who are immigrants is equal to the ratio of known immi-
grants to the total population.
The following is a typical calculation for California, which
happens to be one of the few states that keeps data on auto immigration.
The computed value of 205, 000 autos per year coming irito the state is quite
close to the actual number reported, which is. 211,'850*. '. .
o
a. The total number of people aged 5, and over coming into
California for 1965 to 1970 is = 1.689 m from out of state
+ 0.47 m from out of the.country + 1. 034m unknown.' Pop-
ulation 5 or over = 18. 3 m. Total immigrants = 1.689 + 0.47
+ (1.689 + 0.47/18.3) (1.034 m)
Total Immigrants 5 or over = 2.28 m
b. Assume that the ratio of immigrants 5 or over to the total
immigrants equals the ratio of population 5 or over to the
total population.
Total immigration = 2.51 m in 5 years
c. Auto migration = 2.51/5 (0.405) = 205, 000/year;
actual = 211,850.
2-26
-------
REFERENCES
2-1. "Vehicles in Operation as of July 1972, for Domestic and Imported
Passenger Cars, by Make and County for Each AQCR," R. L. Polk
and Company.
2-2. "Projected Motor Vehicle Registration and Drivers Licenses Out-
standing 1970-1985," Report No. 31, March 1970, State of California
Department of Motor Vehicles.
2-3. "U.S. New Car Registrations by Makes," April 24, 1972, Automotive
News, 1972 Almanac.
2-4. Automotive Industries Annual Statistical Issues, 1967 thru 1971.
2-5. Automotive Industries, "U.S. New Imported Car Registrations,"
March 15, 1972.
2-6. "Survey of Current Business," U.S. Department of Commerce,
March 1973.
2-7. "Requirements for Preparation, Adoption, and Submittal of Imple-
mentation Plans," Volume 36, Number 158, Federal Register,
14 August 1971.
2-8. "Transportation Center Strategy Development for the Greater
Houston Area," Transportation and Environmental Operations of .
TRW, Inc., EPA Contract No. 68-02-0048, December 1972.
2-9. "Report by the Committee on Motor Vehicle Emissions," National
Academy of Sciences, 15 February 1973.
2-10. D. S. Kircher and D. P. Armstrong, "An Interim Report on Motor
Vehicle Emission Estimation," Environmental Protection Agency,
Office of Air Quality Planning and Standards, 12 January 1973.
2-11. "Air Quality Criteria for Hydrocarbons," National Air Pollution
Control Administration, March 1970.
2-12. "New York City Metropolitan Area Air Quality Implementation Plan
Transportation Controls," New York State Department of Environ-
mental Conservation, April 1973.
2-13. "Transportation Control Strategy Development for the Denver Metro-
politan Area," Transportation and Environmental Operations of TRW,
Inc., EPA Control No. 68-02-0048, December 1972.
2-27
-------
2-14. "Los Angeles Regional Transportation Study (LARTS)," California
Division of Highways, District 7, 1968.
2-15. "Galveston/Houston Transportation Study," Texas Division of
Highways.
2-16. "Valley Area Traffic and Transportation Study," Maricopa Associa-
tion of Governments.
2-17. "Tucson Area Transportation Study," Tucson Area Transportation
Planning Association, 1968.
2-18. "Lake Charles, Lafayette, New Orleans Study Areas," Louisiana
Department of Highways.
2-19. "Bay Area Transportation Study," Bay Area Transportation Study
Commission, 1969.
2-20. "Boston Transportation Planning Review."
2-21. "San Diego Metropolitan Transportation Study," California Division
of Highways.
2-22. "Penn-Jersey Transportation Study," Delaware Valley Regional
Planning Commission.
2-23. "Portland Metropolitan Area Transportation Study," Oregon Division
of Highways.
2-24. "Sacramento Area Transportation Study," California Division of
Highways.
2-25. "Baltimore Metropolitan Area Transportation Study," Maryland
State Regional Planning Council.
2-26. "Tri-State Transportation Study," Tri-State Regional Planning
Commission, 1963.
2-27. "Spokane Metropolitan Area Transportation Study," 1965.
2-28. "Denver Metropolitan Area Transportation Study," Denver Regional
Council of Governments, 1969.
2-29. "Washington Metropolitan Area Transportation Planning Study,"
Metropolitan Washington Council of Governments.
2-"0. "Southwest Pennsylvania Regional Transportation Study," South-
western Pennsylvania Regional Planning Commission.
2-28
-------
2-31. "Puget Sound Governmental Conference Study Area."
2-32. "Minneapolis/St. Paul Regional Area Transportation Study,"
Metropolitan Council of the Twin Cities Area.
2-33. "Salt Lake Area Transportation Study," Utah Division of Highways.
2-34. "Migration Between State Economic Areas," Bureau of the Census,
2-29
-------
SECTION 3
POTENTIAL COMPLIANCE ASSURANCE MEASURES
A number of approaches are possible to ensure compliance
with a two-car strategy, including use of existing or modified car registra-
tion procedures, direct control of car dealers, car inspection, and required
retrofit of higher-emission cars operating in controlled regions. These
techniques/approaches are briefly discussed below. Additional comments
regarding these potential measures are given in Section 4 (Auto Industry
Considerations) and Section 5 (State or Regional Considerations).
3. 1 VEHICLE REGISTRATION
Since all states require annual registration of new and used
cars, a preregistration requirement that purchasers of new cars to be used
in controlled regions show compliance appears relatively straightforward.
Unfortunately, existing registration procedures in most states are not
capable of being used without modification. In particular:
a. Very little effort is made to ensure that all cars are in fact
registered, nor are penalties for late registrations severe.
Enforcement is primarily through normal police or highway
patrol traffic activities, such as stopping cars for speeding
,' and reckless driving and in reporting and investigating
accidents.
b. Although all states require an address for car registration
none is 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, post office box, second
home, or business address are all 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 preregistration emission control
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regulations by registering a new car in a noncontrolled
adjoining state and bring the car into a controlled area for
permanent residence.
To use existing state car registration procedures for ensuring
compliance with a two-car strategy, expansion of state enforcement capabili-
ties 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 be operated. In particular, they must verify that residents of con-
trolled regions are provided with low-emission cars.
Dealers might verify which car to sell through determination
of a purchaser's legal address using such information as driver's licence,
place of employment, IRS address, etc. Further, if the dealers in controlled
areas were provided only with low-emission cars, this approach could make
it difficult to evade the two-car strategy. In California, all new cars presently
come equipped with the "California Package, " and dealers are not permitted
to sell new cars unless this package of equipment is operating at the time of
sale.
Difficulties with this approach are:
a. Most dealers are poorly equipped to determine their customer's
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.
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Inspection 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, modifi-
cations in registration procedures would be required.
3.4 VEHICLE RETROFIT
A program might be established to require that all 1975 higher-
emission cars entering 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 registration. 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 noncontrolled 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 send
customers in return for a "finder's fee, " indicates that evasion of two-car
strategy restrictions may be widespread. Oregon, which borders on California,
for example, has low registration fees and no sales tax. This obviously pro-
vides incentives for out-of-state new car buyers. A number of potential
control regions are interstate, with each state having different sales and local
taxes, all within easy driving distances of noncontrolled areas.
Therefore if the two-car strategy is to be completely successful,
certain controls are needed over car registrations and sales outside these
control regions. In particular, nonresidents of states outside controlled re-
gions should not be permitted to register higher-emission cars unless they
can show that the principal use of the car would be within that state, and sales
of such higher-emission cars should be prohibited to residents of controlled
regions.
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In addition, catalyst-equipped low-emission cars will require
unleaded gasoline. Therefore, unleaded gasoline should be available both
inside and outside of controlled regions, if residents of such regions are to
be able to use their cars freely on trips to other parts of the country.
3. 6 SUMMARY
A number of procedures are possible for ensuring successful
implementation of a two-car strategy, including tying compliance to car
registration, providing compliance through controls over new car dealers,
and enforcing compliance through car inspection and retrofit programs.
However, if 100 percent compliance is required, implementation of these
procedures will call for additional state legislation, new Federal regulations,
and expansion of state enforcement agencies.
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SECTION 4
AUTO INDUSTRY CONSIDERATIONS
In this section of the report, the feasibility of various
aspects of two-car control strategy is examined from the viewpoint of the
auto industry. First, a general discussion is presented which summarizes
auto industry comments/ reactions to preselected issue discussion topics.
Next, more detailed comments/reactions are presented based on discussions
held with the major domestic auto manufacturers. Finally, a brief summary
of auto industry considerations is presented. Unless otherwise referenced,
all information presented in this section is based on discussions or corre-
spondence with each respective auto company, as noted in Section 1.2, except
for the Chrysler comments abstracted from testimony presented in the
March 1973 Suspension Request Rehearings.
4. 1 GENERAL DISCUSSION
3
All auto companies contacted stressed their inability to meet
1975 Federal emission standards. Therefore, all discussions held with the
auto companies concerning two-car strategy were predicated on the low-
emission vehicle being their "best-effort" with a catalyst-equipped car
(whether or not it met 1975 emission standard levels) and the higher-
emission (non catalyst) car meeting 1973/74 Federal standards.
Estimates of car sales in this section are those made by the individual
manufacturer and may not agree with values in Section 2, which are based
on R. L. Polk and Company registration data.
Those hearings held on remand from the United States Court of Appeals for
the District of Columbia Circuit relative to applications for suspension of
the 1975 motor vehicle exhaust emission standards.
Except Honda (for prechamber-equipped Civic car), Mercedes Benz. (for
diesel), and Toyo Kogyo (for rotary engine).
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4.1.1 General Attitude Toward/About Two-Car Strategies
4.1.1.1 General Motors
General Motors had originally (prior to March 1973 Suspension
Request Rehearings) advocated a two-car strategy wherein the lesser-emitting
car did not meet 1975 emission standards and might not incorporate a catalyst.
The benefits of their approach were economic in nature, and they had esti-
mated an approximate 50/50 split in production of the two types.
General Motors now strongly advocates a California-only
strategy wherein the low-emission car does include a catalyst but meets
emission standards higher than the Federal 1975 levels, as follows (with
averaging):
o HC = 0.76 gm/mi
o CO =5.7 gm/mi
o NOX = 3.1 gm/mi
Under this approach, General Motors' production of the cat-
alyst-equipped car would be quite limited (approximately 7 percent of their
total sales are in California). They feel that extending the two-car strategy
to areas other than California would increase manufacturing and distribution
problems and involve a complex and difficult enforcement system.
4.1.1.2 Ford
Ford advocates a California-only two-car strategy with the low-
emission cars catalyst equipped (although not meeting 1975 standards). Ford
feels that expansion of the two-car strategy beyond California to include a
multiplicity of cities and/or regions is incalculably complex and difficult to
administer. Such an approach, to them, would be highly disruptive of normal
channels of distribution, sales, and enforcement.
4.1.1.3 American Motors
American Motors also advocates the California-only strategy
(with catalyst), as in the case of Ford. They feel that extending the strategy
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to other areas would make it very difficult for American Motors to comply,
due to their limited assembly and marketing facilities.
4.1.1.4 International Harvester
International Harvester feels they could handle the California-
only strategy, as they have done in the past with California-unique systems.
However, if a California-plus strategy were adopted, the additional areas
would have to be large geographically since the approach gets less feasible
as the areas get smaller in size.
4.1.1.5 Volkswagen
Volkswagen is not in favor of a two-car strategy of any type
as they feel they are not ready for catalysts in 1975 (perhaps by the end of
1975). They prefer a one-year extension to enable further catalyst fleet
tests. Even in this case, California would not be their preferred location
for fleet testing.
4.1.1.6 Toyota
Toyota favors a phasing-in process for catalyst-equipped cars,
which is not provided by the two-car strategy. In the case of the California-
only strategy, Toyota feels that California is too big to represent a mere test
sample (about Z5 percent of all Toyota U.S. sales are in California). However,
Toyota California sales represent only ~4.67% of their total passenger car
output. Their preference might be to equip one model only with a catalyst for
California sales.
4. i. 1.7 Mercedes Benz
The two-car strategy has little benefit for Mercedes Benz,
because 70 to 80 percent of their United States cars are sold in metropolitan
areas. They feel that because of the additional burden of dealership inventory--
problems of enforcement of distribution by regulation, inspection procedures,
training, and other related matters--the\disadvantages of a two-car strategy
far outweigh any possible benefits. They have only 8 zone offices to handle
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all U.S. distribution. (The San Francisco office also handles Washington and
Oregon; the Los Angeles office also handles Arizona and Nevada).
Six thousand diesel-equipped cars were sold in the U.S. last
year: 25 percent of all Mercedes Benz cars are shipped to California zones;
15 percent of this goes to adjoining states. They expect to sell only 36,000
to 37,000 1973 model year cars in the U.S. Their overall feeling is that it
would be beneficial to have a one-car strategy, with that car having the lowest
emissions possible.
4.1.1.8 Nissan (Datsun)
Nissan does not like a two-car strategy. They would prefer a
suspension of the 1975 standards which would allow each automaker to intro-
duce a low-emission car (e. g. , in California) on its own initiative to get field
test information. If promulgated, they would try to comply with a California-
only, two-car strategy, but they foresee many problems. Approximately
30 percent of Nissan's United States sales are in California, and this percent-
age is too large for a "test case." However, Nissan's California sales repre-
sent only ~5. 01% of their total passenger car output. Their California regional
offices also includes Arizona and Nevada sales, and this may be difficult to
manage; they may not have enough lead time to get two types of cars on the
assembly line.
With regard to the California-plus strategy, Nissan does not
like the option of controlling additional metropolitan areas at all. They feel
the problems associated with it would be too big to imagine.
4.1.1.9 Chrysler
Chrysler does not feel that catalysts are sufficiently well
developed for use, even in a limited area such as California. However, if
a California-only strategy were implemented, they would not forego the
California market despite their feeling about catalysts.
Chrysler prefers to use the extra year (of emission standards
suspension) to continue fleet testing development. Then, a California-only
strategy might be a proper next step.
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4.1.2 Ability to Produce Two Classes of New Cars
In general, there is no question but that the auto industry has
the capability to produce two classes of cars. However, there does appear
to be a degree of difficulty which varies with the size of the auto maker,
i.e., the larger the company, the easier it is to add options.
For example, General Motors states there is no real obstacle
to two-car production but that there are added problems and costs inherent
in the production and assembly operations. In their view, the California-
plus strategy option would require converting additional plants to two-car
assembly and/or cross-shipping of cars at additional expense to the public.
Ford feels that the number of states involved has a big impact on two-car
feasibility. Whereas the California-only strategy would not pose a problem,
the California-plus strategy would involve more plants and considerably
more complexity (the extent varying with each car line mix and plant location).
In the same vein, American Motors feels that extending the two-car strategy
to the California-plus option could make it difficult for them to comply due
to their limited assembly facility locations. On the other hand, International
Harvester, having a preponderance of special-equipment orders, feels that
they can produce effectively as long as no more than two vehicle classes are
involved.
4.1.3 Ability to Market New Cars
Again, there is generally no question but that the auto industry
has the capability to market two classes of new cars. However, there are a
number of factors associated with implementing a two-car strategy in 1975.
These include the impact of the number of regions controlled, the impact of
car pricing policy, warranty interpretations, and problems peculiar to foregin
car makers .
General Motors feels that their current network of assembly
plants and zone offices is adequate for the California-only strategy (affecting
about 7 percent of their national sales) and, although the California-plus
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strategy is not an impossible task, it would be very difficult for them to
provide a 1'ull new-car model mix for all the various cities involved. They
ieel that a major consideration, in either case, is the car-pricing problem.
Their experience with California emission control systems in the 1966/72
time period suggests that the additional hardware and costs of the low-
emission car should be handled as a "mandatory option."
Ford also feels that the California-only strategy may not be
too bad logistically (representing about 10 percent of their national sales).
On the other hand, they feel that a California-plus strategy could be highly
disruptive of their distribution and sales channels, although they do not
know which additional states or regions would be tolerable or intolerable.
Ford has not yet determined their two-car pricing policy (e.g., adding
increased costs only to low-emission cars or spreading them over all new
cars), but they do state that new car warranties would be interpreted the
same as now : i.e., replacement of defective parts, no performance
warranty.
American Motors feels they can market under a California-
only strategy but that their limited marketing facilities would make a
California-plus strategy less feasible as additional areas were added. .
International Harvester"feels that the California-only
strategy is satisfactory but states they could have marketing problems with
a California-plus strategy unless added areas were large in geographic size;
their cars are shipped to only six inventory places after manufacture.
Nissan states that even with a California-only strategy their
marketing would be adversely affected, since they normally have 30 percent
of their total U.S. sales in California.
Mercedes Benz distributes their cars through seven vehicle
preparation centers and eight zone offices. They foresee considerable dis-
tribution and logistics problems with the two-car strategy under their setup.
Because of the required lead time for shipment from Europe, keeping an
inventory commensurate with market demand is complex enough with a
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one-car concept. The two-car strategy would simply add the burden of
dealership inventories in both car classes.
Toyota prefers a California-only strategy to a California-plus
strategy. Although the California-only sample is much larger than desirable
(about 25 percent of total Toyota U.S. sales are in California), it would be
handled through their two existing California distribution centers.
4.1.4 Ability to Service Two Vehicle Classes
As in the case of production and marketing, there is general
agreement that two classes of vehicles can be serviced. The degree and
adequacy of service is impacted by the number of regions controlled, with
the feeling that service for low-emission cars will certainly be less adequate
outside the control region than inside the control region.
Under a California-only strategy, existing California ware-
houses can supply service parts for the low-emission car. Servicing and
training would be easier to implement and control in a single state; expedited
service could be utilized to provide faster customer response. For the case
of California vehicles becoming inoperative when out of state, the auto compa-
nies might have to rely on air-shipping of special parts (e.g., catalytic con-
verters, etc.), where 24-hour delivery is now standard U.S. practice. Also,
the training of servicemen in areas outside California would be minimal.
Under a California-plus strategy, the distribution requirements
for service in additional areas adds greatly to the complexity. Parts would
need to be available on almost a nationwide basis, and any special servicing
equipment would be required in all dealerships. Furthermore, a nationwide
training program would have to be implemented.
4.1.5 Vehicle Identification, by Control System Type
All states utilize the vehicle identification number (VIN), or
some portion therefore, for vehicle registration purposes. The VIN identifies:
a Model year
o Assembly plant
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o Body type
o Engine class
o Production serial number.
The various auto companies use a different number of digits in their VIN s
(e.g., General Motors uses 13 digits; Ford uses 11 digits). The VIN does
not currently identify the type of emission control system used on the car.
Certification tags on underhood panels and window stickers are used for this
purpose.
There may be a way to add a digit or redesignate the VIN to
show control system type (e.g., by groupings of manufacturing sequence
numbers). However, adding a digit may be a problem since some states
can only pick up a limited number of characters on their reading equipment.
In any event, changing the VIN system would involve extra costs
and efforts that may be unwarranted for a one-year, two-car strategy. Ford,
for example, objects strongly to adding digits to the VIN. All their historical
data banks are keyed to the existing VIN system, and it would be disruptive and
costly to rebuild computer programs and refit stamping and body machines.
Ford could produce an "after-the-fact" machine-processible record (tape) of
cars produced by control system type. This would not be part of the VIN sys-
tem but could aid in vehicle control system identification.
The Society of Automotive Engineers (SAE) is currently trying
to standardize VIN systems to help simplify auto registration problems in
general. However, General Motors feels that a "use sticker" would be
required for a two-car strategy anyway, in addition to registration control.
If this were so, it would certainly deemphasize any efforts to change VIN
methods for emission control system identification.
4.1.6 Dealer Delivery Control
In general, deliveries of new cars to dealers are made on the
basis of physical order forms sent by the dealer to the auto company. In
some cases the ultimate purchaser has given his address to the dealer
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(not necessarily his legal residence), but usually the purchaser's address
is not included on the order form sent to the auto company.
The auto companies stress that they lack effective techniques
for exercising control over dealers. Even if they had contractual authority
to do so, there is no uniformity in contract requirements because of varying
state laws affecting the allowable degree of control. They thus feel that they
may not be able to keep a dealer from ordering cars to be sold outside a given
control region. There are also problems of a mechanical nature, such as
simple errors occurring in the order blank.
Some limited control techniques are in use. Most companies
visually inspect the order form at the sales district level to see if the proper
emissions package has been ordered (based on point of delivery). General
Motors, on the other hand, scans the order by computer and automatically
adds the California emissions package when the order is from a California
deale r.
Other dealer control problems were cited. Dealer-to-dealer
trading is one of them. Large trading percentages in a given area are common.
For example, it was estimated that 50 percent of the new cars in the Detroit
metropolitan area were involved in dealer trades prior to ultimate sale to the
purchaser.
Fleet car sales is another problem (e.g., purchases by Hertz,
National, etc.). These companies purchase cars in one state for delivery
in another. In 1972, General Motors had 500,000 fleet car sales.
"Border" dealers with split sales districts (e.g., dealers
located on the California border selling to both California and Arizona
residents) pose still another problem, since their location enables them to
sell in more than one state.
Aside from fleet sales, per se, many dealers order cars for
delivery to other dealers in other states. Ford estimates that 10 percent of
their factory orders by dealers are for delivery to other dealers (including
fleet car sales).
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4.1.7 Requirement for Retrofit of Lesser-Controlled Cars
All responding auto companies are in general agreement that
any requirement to retrofit a 1975 car from the lesser degree of emission
control to the low-emission vehicle configuration and standards is a very
severe one. It may be physically possible but economically impractical to
do so. For example, it may be possible to add a catalyst but would be much
more difficult to change other parts such as intake manifolds, air injection,
controls, and cylinder heads. Air conditioners were mentioned as analogous
in the retrofit sense. It was never practical to retrofit air conditioning sys-
tems to factory-installed configuration and performance levels. Add-on units
were the only practical way of'accomplishing air-conditioner retrofit.
It is conceivable that planning for retrofit could ease some
of the problems. The auto companies would need to know of this requirement
in advance, and it might force the decision to make cars nearly identical
except for the catalytic converter itself. This situation, of course, might
not be equitable to the buyer of a lesser-controlled car.
Also, required retrofit could increase certification problems,
i.e., certifying the lesser-controlled car at 1974 emission levels, then certi-
fying the retrofitted version at 1975 emission levels.
4.1.8 Unleaded Gasoline Requirements, Noncatalyst 1975 Models
A diversity of opinions was expressed in this area. American
Motors feels that noncatalyst 1975 systems should still be required to use
unleaded gasoline. Their experimental data indicate that use of unleaded
gasoline:
4
a. Lowers NO levels (affected by deposits in EGR system )
b. Lowers HC levels (affected by valve deposits, valve
seatings, etc.)
However, American Motors has not decided to equip noncatalyst 1975 cars
with gasoline filler necks to "force" the use of unleaded gasoline.
4
Exhaust gas recirculation system.
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General Motors states that they would "encourage" the use of
unleaded gasoline for noncatalyst systems but that they would not make its
use mandatory. Ford had no position on this issue.
4.2 DISCUSSION BY DOMESTIC AUTO COMPANY
4.2.1 General Motors
4.2.1.1 General Attitude Toward/About Two-Car Strategies
Prior to the March 1973 Suspension Request Rehearings,
General Motors advocated implementation of a two-car strategy quite differ-
ent from the basic strategy options examined in the present study. Under the
General Motors plan (see Appendix D), Type "B" cars would be used where
automotive pollution is a serious local problem, and Type "A" cars would be
used in the rest of the nation. The choice of car use (Type "A" vs Type "B")
would be decided by local governments. The emission levels proposed for the
two cars were:
Emissions, gin/mile
Type "A" Type "B"
HC 3.0 1.0
CO 28.0 18.0
NO 3.1 1.5
X.
The Type "B" car may or may not have a catalyst. A catalyst might be used
to help improve driveability even though not required to meet Type "B" emis-
sion standards.
Under this type of system, General Motors estimated a 50/50
split between Type "A" and Type "B" cars. Principal argument for their
approach was economic in nature. Their two-car system would be at least
semipermanent in nature and result in a consumer savings of $14 billion
over a decade (see Appendix D for details).
At that time, General Motors felt that a California-only, one-
year, two-car strategy would not do too much toward changing or improving
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systems, although it would give an additional year for test purposes and
would lessen the assembly-line impact. However, if a two-car strategy
of any type were to be implemented, General Motors would expect to be able
to participate as well as any other auto manufacturer. They felt that registra-
tion control was necessary to make the two-car strategy work effectively.
In response to questioning about current two-car strategies at
the March 1973 Suspension Request Rehearings, General Motors reviewed
their position and issued a formal response (see Appendix E). In summary,
they feel that extending a strategy requiring catalyst-equipped cars in areas
other than California increases manufacturing and distribution problems and
involves a complex and difficult enforcement system. They feel that the
California-only strategy is the proper way to go, but propose certification
levels for California cars (with suggested changes, including averaging) as
follows:
Emissions, gm/mile
HC 0.76
CO 5.70
NOX 3. 10
Advantages cited by General Motors for the California-
only strategy include:
a. The wide variety of climatic and road conditions in
California
b. About 7 percent of General Motors'nationwide production
is sold in California
c. A single geographic area provides across-the-board
experience with several types and sizes of cars
d. Initial service parts distribution is limited to one area
e. Field service training can be more thoroughly evaluated
f. In the event of a need for recall or modification, all affected
vehicles would be in one general area.
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4.2.1.2 Ability to Produce Two Classes of New Cars
General Motors would not have a significant problem in
producing two classes of cars, even for the option of California plus all
AQCRs with serious automotive pollution (their preferred approach, prior
to March 1973 Rehearings). Of course, under General Motors' originally
proposed two-car approach, there could be a substantial "sameness"
between Type "A" and Type "B" cars, except for the possible catalyst
addition.
General Motors states, however, that the two-car approach
would entail some problems and additional costs. With regard to production
operations, two-car problem areas include:
o Material inventory
o Scheduling
o Handling
o Obsolescence
o Operator training
o Quality control
o Manpower productivity.
In the assembly operations area, additional problems and costs are foreseen
with regard to hardware and to vehicle order and distribution requirements.
All General Motors' California cars are presently emission
tested in the plants where they are assembled, as follows:
a. Steady-state idle HC and CO test as cars come off assembly
line, ~1 minute per car (100 percent tested; California
requires 75 percent).
b. Seven-mode hot test (2 minutes) for 25 percent of cars.
c. Audit checks on cold-start CVS test on 25 percent of cars.
General Motors currently has 21 plants assembling passenger cars and light
trucks. Three of these assemble light trucks only, and thirteen build or have
built both California models and Federal models. The California-plus
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strategy would require converting additional plants to two-car output and/or
cross-shipping cars at additional expense to the public.
4.2.1.3 Ability to Market New Cars
A two-car strategy should provide no marketing problem for
General Motors, even for extending the California-plus strategy to all AQCRs
with a serious automotive problem. Their current network of assembly
plants and zone offices should be adequate, although it could be very difficult,
though not impossible, to provide a full model mix for all included cities.
General Motors feels that the major marketing consider-
ation is the pricing problem. Their past California experience suggests
that the additional hardware and costs of the low-emission car could best be
handled as a "mandatory option. "
4.2.1.4 Ability to Service Two Vehicle Classes
General Motors foresees no real problems with either parts or
labor under a two-car strategy. Of course, they might have to use air-shipping
of special parts for inoperative vehicles outside their own region. If both car
types were substantially similar, except for the catalytic converter, servicing
difficulties would tend to diminish.
Service complexity is increased for the California-plus strategy
because of distribution requirements. Parts would need to be available almost
on a nationwide basis. Special service equipment would be required in all
dealerships, and a nationwide training program for servicemen would be
needed.
4.2.1.5 Vehicle Identification - By Control System Type
General Motors' vehicle identification number (VIN) uses 13
digits. They feel that there may be a way to add a digit or redesignate the
VIN to show the car emission control system type. One method might be to
group the manufacturing sequence numbers of the two car classes. General
Motors cautions that adding a digit to the VIN may be a problem, since some
states can only pick up 13 characters on their reading equipment.
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In any event, General Motors feels that a "use sticker" of
sonic sort will be required in addition to registration control.
4.2.1.6 Dealer Delivery Control
In the case of General Motors, their California dealers can
only obtain "California cars." The California emissions package is merely
considered similar to other options. First, the dealer checks the order if
a California emission package is desired (buyers name and address are not
on the order). Then, a computer scans the order and all California dealers
get cars with the California package whether they ordered it or not. (Non-
California cars get the California package if they desire.) The current
principal difference between California and non-California cars is the $15
price tag for assembly-line testing.
General Motors cautioned that dealer delivery control is
somewhat ineffective due to dealer-to-dealer trades and fleet sales. Dealer
trades are both significant and common. Fifty percent of the new cars in
the Detroit area were involved in dealer trades within the area. General
Motors had 500, 000 fleet sales in 1972. These cars are ordered in one
state, but delivered in another.
4.2.1.7 Nationwide Marketing/Design Impact
General Motors feels that a two-car strategy would not have a
great nationwide marketing/design impact, one way or the other. They feel
that the California-only, one-year strategy would not do too much for product
improvement. Only about 7 percent of General Motors sales are in California,
and the one-year period would not provide an adequate sample of high-mileage
cars, thus not yielding much field experience. Nor would it provide adequate
time to incorporate changes in the next year's models.
However, the California-only strategy would enable discovery
of "infant mortality" failures (those failures which occur early in a model
year production run) and would give an additional year for further testing
prior to the nationwide use of a catalyst. It would also greatly lessen the
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assembly-line impact of the catalytic converter. Traditionally, a new
system (e. g. , a new transmission) is introduced in a low volume car line
before all-model production is undertaken. It often takes five years to intro-
duce the new system into all car lines.
4.2.1.8 Unleaded Gasoline Requirements
General Motors would encourage the use of unleaded gasoline
for noncatalyst systems (e.g., the car meeting 1974 standards), but they
would not make it mandatory for such systems to use unleaded gasoline
(e.g., by using gas-tank filler arrangements for unleaded gasoline on non-
catalyst cars).
4.2.1.9 Requirement for Retrofit of Lesser-Controlled Cars
General Motors feels that a complete factory-installed type
of emission control system cannot be retrofitted. Components may be retro-
fitted, but not such items as cylinder heads, etc. The closer the two classes
of cars resembled one another (ini terms of hardware components) the easier
retrofit would be. General Motors referred to the air-conditioner analogy,
where it has not been found practical to retrofit with factory-type systems.
Add-on air-conditioner sys ems have been the only practical way of retrofit,
and no such add-on units are being or have been developed for 1975-type
emission control systems.
4.2.2 Ford
4.2.2.1 General Attitude Toward/About Two-Car Strategies
Ford advocates a California-only, two-car control strategy
(see Appendix E) wherein the California cars would incorporate a catalyst
while the rest of the nation would use cars with emission levels similar to
the 1974 models. They might prefer a two-year plan instead of a one-year
plan in order to be able to incorporate any meaningful design changes (product
improvements) and to provide better training and servicing.
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Ford's principal arguments for the California-only strategy
include:
a. They need a limited approach to permit learning about
the technical unknowns of catalyst systems (although they
still may get insufficient mileage accumulation per car in a
one-year plan).
b. It is the logical "next step" to their current California develop-
mental test fleet program (where 500 Fords will be built on
the Los Angeles assembly line starting 1 April 1973 and tested
in fleets in the Los Angeles, Sacrmento, and San Francisco
areas).
c. It would guard against "cataclysmic" effects of failures which
could happen if introduced nationwide.
d. It is the closest thing to the normal industry approach for new
and'improved design introduction where a single car line is
used (here it is a single state instead of a single car line).
e. They have been working with a two-car, California-only
strategy since 1966 and definitely feel it can be done.
Ford feels that any viable two-car strategy must have the
degree of regulation that California currently exercises or the program may
be a failure, at least as far as the car owner is concerned, since the antici-
pated benefits will not be realized. They also feel that legal problems may
be "horrendous" unless an affected state has regulations encompassing:
a. State-controlled mandatory vehicle inspection with emissions
testing and certified mechanics and inspectors
b. Vehicle registration control based on residency requirements
c. Vehicle alteration rules prohibiting tampering with the
emission control system.
Ford feels that the expansion of the two-car approach to include
a multiplicity of cities and/or regions is incalculably complex and difficult to
administer. It would be disruptive of normal channels of distribution, sales,
and enforcement for the consumer, the auto manufacturer, and the government.
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4.2.2.2 Ability to Produce Two Classes of New Cars
As far as Fojd is concerned, the number of states involved
has a big impact on the feasibility of producing two car classes. For exam-
ple, they have 18 U.S. passenger car assembly plants for Ford models. Nine
of these plants build cars for California sales, and their California assembly
5
plants ship cars out of California. Some plants produce only one line of
passenger cars. In many cases, their sourcing patterns change from time
to time, even within a single model year, since the plants have the capacity
for production changes.
The number of constant volume sampling (CVS) test facilities
and associated time and dollars increases as the number of states increase.
The emission test type(s) required under a two-car strategy is very
important; Ford would need to know if other test facilities are required.
If 5 percent of the cars produced were tested on the CVS cycle, this would
cost hundreds of millions of dollars in facilities (e.g., extensions of plant
buildings and expensive testing equipment).
Adding a multiplicity of additional areas (e.g., California-
plus strategy) would involve more Ford plants and considerably more com-
plexity, the extent varying with each plant and each car line mix.
4.2.2.3 Ability to Market New Cars
Ford has 34 sales districts in the U.S., and Lincoln-Mercury
has 19. Two of the Ford and two of the Mercury districts are in California
(and cover Hawaii as well); therefore, the California-only strategy is not too
bad logistically (about 10 percent of Ford's national sales are in California).
Their sales districts are not coincidental with geographical or
governmental boundaries, as their marketing areas are drawn to encompass
cross-sales which are affected by the density of locations and people. In gen-
eral their sales districts are smaller than standard metropolitan statistical
California assembly plants produce 40 percent Fords and Thunderbirds, 10
to 1 5 percent Pintos, and 50 percent trucks.
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areas (SMSAs). They don't know what the break-even point would be in terms
of adding other states or regions to California as part of a control scheme.
However, adding other areas would reduce the marketing flexibility of both
types of autos (e. g. , one Phoenix dealer presently gets cars from six different
assembly plants).
Ford has not determined what their car pricing policy would
be under a two-car strategy (i.e., charging California owners total cost
vs spreading cost out over all cars). However, warranties would be the
same as now (i.e., replace defective parts).
4.Z.2.4 Ability to Service Two Vehicle Classes
Ford feels they can properly service cars under the California-
only strategy. Their central warehouses in Los Angeles andSan Jose also
respond to parts requirements in other parts of the state.
Servicing and training (manuals, etc.) would be easier on a
statewide basis since training programs could be initiated in a limited area.
Faster customer response could be provided by limiting the low-emission car
to one concentrated area (California) to begin with. Service difficulties could
be more easily resolved and parts provisions could be expedited
4.2.2.5 Vehicle Identification -- By Control System Types
Ford agreed that it might be possible to add a number or
letter to their current 11-digit vehicle identification number (VIN) system to
identify emission control system type. However, they object strongly to
doing so. They point out that all Ford historical data banks are keyed to
their 11-digit VIN system. The VIN is used in hundreds of places and all
records would have to be changed. They estimated it would cost several
millior dollars to rebuild their computers and refit the stamping and body
machines that physically record VIN numbers on vehicle and engine parts.
As previously reported, Ford suggested instead that they
could produce an "after-the-fact" machine-processible record (tape) of cars
produced to meet standards of a given control region. Although not part of the
VIN, such a record could be used to verify emission control system type.
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4.2.2.6 Dealer Delivery Control
Ford builds and delivers new cars- to dealers solely on the
basis of physical,order forms sent by the dealer to Ford. The order form
is checked visually at the sales district level to see if the dealer has ordered
the proper emission package, but this is the only control exercised by Ford.
The dealer is responsible for determining that he has ordered the proper car
for the customer.
Even if Ford had contract authority to exercise more stringent
control over dealer orders, they feel that the lack of uniformity in state laws
concerning producer/dealer contracts would preclude them from effectively
exercising such control. They feel they may not be able to keep a dealer
from buying cars to sell in other areas.
Ford points to the problems of split sales districts, fleet car
buyers, and border dealers as further complications in dealer delivery con-
trol. Ten percent of Fords'factory orders are from dealers who stipulate
delivery to other dealers; this is in addition to interdistrict transfer between
dealers.
Border dealers, whose location enables them to sell in more
than one state, are a unique problem. Ford currently allows the border
dealer in California to decide whether the California emissions package is
required on cars ordered.
4.2.2.7 Nationwide Marketing Impact
Ford feels that their ability to market cars nationwide under
a two-car strategy depends on:
a. The type of responsibility imposed on the auto company
b. The selection of control regions on the basis of governmental
and geographic considerations, wherein state regulations
would be in support of a two-car strategy.
When the control areas are extended beyond California, Ford feels there is
a ten-to-twenty fold increase in complexity; therefore, they do not think the
California-plus strategy is very practical.
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4.2.2.8 Requirement for Retrofit of Lesser-Controlled Cars
Ford feels that although it may be "feasible" to retrofit 1975
catalyst systems, it is impractical frcm a cost standpoint.
1966/67 Ford cars were not retrofittable to the California con-
figuration (i.e., air pump and air injection in the exhaust manifold). California
currently recognizes retrofit impracticality of factory-installed systems
since:
a. If a car has been registered outside California, it is
acceptable in California if it has crankcase controls
b. If a used car has been properly registered elsewhere, it
can be sold in California.
4.2.2.9 Unleaded Gasoline Requirements
Ford had no position on the issue of requiring the use of
unleaded gasoline on noncatalyst cars meeting 1974-level standards.
4.2.3 American Motors
4.2.3.1 General Attitude Toward/About Two-Car Strategies
American Motors advocates a California-only, two-car
strategy in which California cars would incorporate a catalyst and the rest
of the cars would not. They do not feel that a one-year period is sufficient,
but it is better than nothing. They feel the strategy should apply across the
entire model year (don't want any 1975-1/2 models, for example).
From American Mo tors'viewpoint, the principal arguments
for their approach include:
a. It would provide more learning time. Carburetors need more
development time; new intake manifold designs may have mal-
distribution problems affecting HC control.
b. It would provide a measure of cost effectiveness, since
knowledge gained on initial catalyst designs would allow revi -
sions for lower-cost production. "Guessing" could be elimi-
nated in some areas: double-wall exhaust pipes might not be
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required, and altitude compensation may be needed only for
the main carburetor system and not for all modes.
c. It would provide a statistical base for projected warranty
recall costs in terms of warranty dollars expended by dealers.
This is the most important feature of the California-only, two-
car strategy to American Motors.
4.2.3.2 Ability to Produce Two Classes of New Cars
American Motors has a single major manufacturing plant for
car components (engines, etc.) located at Kenosha, Wisconsin. They have
four assembly plants; however, the Kenosha facility is the major assembly
plant. It supplies every car model to every sales zone and supplies all of
the California car models. Another assembly plant in Brampton, Ontario,
Canada supplies some car models to some sales zones. New York, for
example, gets some car models from Brampton and some from Kenosha.
The jeep assembly plant is located in Toledo, Ohio and also does some
manufacturing, although all engines come from the Kenosha manufacturing
plant. Another facility (AM-General Corporation in South Bend, Indiana)
exclusively produces government vehicles.
Under a two-car strategy, both vehicle classes would be pro-
duced with one common body line, the V-8 intake manifold would also be
common. Catalysts for the low-emission car would be purchased. American
Motors is currently committed to catalyst tooling costs, but have to purchase
only the actual number of catalysts required. For smaller lots of currently
unreleased items for "low-emission" cars, they could go to off-line produc-
tion if the number of vehicles involved were not too large.
4.2.3.3 Ability to Market New Cars
American Motors has 20 zone sales offices in the U.S. Two
are located in California (Los Angeles and San Francisco) whose sales repre-
sent about 7 percent o" American Motors' total market. Another sales office
is located in Portland, Oregon. American Motors feels they can control
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their marketing under a two-car strategy if the control region is large
enough in size.
They have not determined what their car pricing policy would
be between the low-emission car and the higher-emission car.
4.2.3.4 Vehicle Identification -- By Control System Type
There is currently no distinction in vehicle identification num-
ber between California cars and other models. Underhood labels and labels
on rear corner windows are used to specify emission control system type and
capability.
4.2.3.5 Dealer Delivery Control
American Motors feels that any attempt to control deliveries
to dealers would be much simpler on a statewide basis, as opposed to a
county or other regional basis.
4.2.3.6 Ability to Service Two Vehicle Classes
American Motors has more parts warehouses than sales zone
offices. They have a parts "hot line" system which guarantees parts delivery
to warehouses within 24 hours. Therefore, under the California-only strategy
a California driver with a breakdown out-of-state might have to contend with
this 24-hour delay problem.
In the area of service training, American Motors feels they
would have some problems but not insurmountable ones. They would plan
to update mechanics by providing service instructions for all car models and
control regions and by using training vans within the low-emission controlled
region.
American Motors' California car models have had unique
components for many years (evaporative-systems, carburetors, air injection,
etc.). They have utilized formal monitoring surveys where all dealer service
reports are prescanned at the zone office and segregated and fed through the
American Motors central computer as a California batch. They also have
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selected dealers who send in "hot line" service reports which are scanned by
eye and do not involve a computer delay.
Field surveillance would be a problem for American Motors,
since they do not have a California-based operations staff. They would have
to hire someone to do the job for them, and this may be expensive.
4.2.3.7 Nationwide Marketing Impact
American Motors feels that implementation of a California-only
two-car strategy would enhance their ability to eventually market nationwide
on a more realistic basis. They need to develop statistics concerning:
o What happens in assembly-line runs
o Variations in emission level spread
o Assembly-line testing variations
o Malfunction modes
e. Lean-to-rich carburetor calibration effects
o Wet spark plug effects
o Vibration modes (misalignments, etc.)
o Fuel economy effects.
4.2.3.8 Requirement for Retrofit of Lesser-Controlled Cars
American Motors feels that such a requirement is a severe
one. It may be physically possible, but the basic issue of economics may
preclude it. For example, it may be possible to add a catalyst, but it would
be much more difficult to make other system changes which may be part of
the overall control system (intake manifolds, air injection, controls, etc.).
It is conceivable that one could plan for retrofit by making the
cars identical except for the catalyst. However, the question would remain
as to whether or not this would be equitable to the buyer of the lesser-
controlled car.
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4.2.3.9 Unleaded Gasoline Requirements
American Motors feels that noncatalyst systems should slil.l
require the use of unleaded gasoline. They point to the benefits of:
a. Lower MO levels (affected by deposits in the EGR system).
b. Lower HC levels (affected by valve deposits, valve
seating, etc.).
However, a decision to equip noncatalyst 1975 cars with gasoline-tank filler
tubes to "force" the use of unleaded gasoline has not been made.
4.2.4 International Harvester
4.2.4.1 General Attitude Toward/About Two-Car Strategies
International Harvester feels they could handle a California-only
strategy; they have done so in the past. If a California-plus strategy were
adopted, they feel the added regions would have to be large geographical areas;
the strategy gets less feasible as the areas get smaller.
4.2.4.2 Ability to Produce Two Classe of New Cars
International Harvester feels that they can produce under a
two-car strategy as long as no more than two classes are involved. Special
orders have predominated for them (more than the rest of the industry)
because of their production of Light trucks and multipurpose vehicles. They
rmi.ke all their light-duty vehicles at Ft. Wayne, Indiana and Springfield, Ohio.
4. / . 4 . 3 Ability to Market New Cars
New cars are shipped to six inventory places after manufacture
hy .':'.'ii.r. .-national Harvester. They feel that they could have marketing problems
under a two-ear strategy unless the control regions are large and include
metropolitan areas to ease inventory control problems and to facilitate dis-
posal of used vehjoles. They also feel that retail dealers cannot be held
responsible for tla: ond-iise of cars delivered to them.
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4.2.4.4 Ability to Service Two Vehicle Classes
This should be no problem to International Harvester; it would
be similar to the different control systems serviced in the past.
4.2.4.5 Dealer Delivery Control
International Harvester's control over dealers is by contract
only, and this control authority differs from state to state .
They do have some checks on dealer orders to make sure that
proper emission control packages are ordered, including:
a. Screening of orders at zone level
b. Screening of orders at regional level
c. Screening of orders by computer.
4.2.4.6 Requirement for Retrofit of Lesser-Controlled Cars
International Harvester feels that it would not be practical to
retrofit emission control systems per factory installations and guarantee to
meet emission requirements. Control systems, as well as catalysts, would
have to be included in the retrofit.
4.3 SUMMARY OF AUTO INDUSTRY CONSIDERATIONS
4.3.1 General Attitude Toward/About Two-Car Strategies
With the exception of Chrysler, the domestic auto manufac-
turers were generally in favor of a California-only, two-car strategy. This
strategy wouLl only require use of catalysts in from 5 to 10 percent of each
individual manufacturer's new cars. These same companies were generally
opposed to any California-plus strategy primarily on the banis of assembly,
distribution, and marketing difficulties. If a California-plus strategy were
implemented, however, the prevailing opinion was that any idded geographi-
cal areas should be as large as possible.
Chrysler opposes any strategy requiring the use of catalysts.
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On the other hand, the foreign auto makers are generally
opposed to any mandatory two-car strategies; they prefer optional phasing-in
processes for catalysts. With regard to a 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, about 32 percent, Toyota, about
22 percent, VW, about 17 percent). Their distribution and marketing problems
would further escalate under a California-plus strategy; Nissan states (as
previously reported) that such problems would be "too big to imagine. " It
should be noted that the car sales in California of these manufacturers are a
relatively small portion of their overall passenger car output (e.g. , Nissan
-5.01%, Toyota -4.67%, Volkswagen -5.38%).
4.3.2 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 it might not have adequate lead time to
get two types of cars on the assembly line). The California-only strategy,
aside from any catalyst-system-unique production problems, is not unusual,
since the auto companies have worked with California-unique emission control
systems since 1966. The California-plus strategy would involve more assem-
bly plants to handle catalyst-equipped cars and entail additional 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).
4.3.3 Ability to Market New Cars
Again, as with the case of car production, there is generally
no question but that two classes of new cars can be marketed. There is,
however, a major impact resulting from the number of control regions
involved in a two-car strategy. The California-only strategy has been in
effect since 1966 with marketing groups set up to handle the California region
effectively.
The California-plus strategy may be highly disruptive of distri-
bution and sales channels, unless the additional areas are sufficiently large
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in size. It is not an impossible task but it may be very difficult to provide
a full mix of new models 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 vs spreading cost out over all
cars). It has been suggested by General Motors that it could best be handled
as a "mandatory option" as done in California in the past.
According to Ford, the warranty interpretation under a two-car
strategy would remain as it is now (replace defective parts).
4.3.4 California-only Strategy Comments Summary
Claimed benefits 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 car
production would be affected (6 to 10 percent for domestic
manufacturers; up to 32 percent 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 pro-
duction line); the knowledge gained on initial catalyst designs
would allow revisions for lower-cost production; it would pro-
vide a statistical base for projected warranty-recall costs at
limited risk (6 to 10 percent of sales in California for major
U.S. auto makers).
i. It would be a continuation of a California-only, two-car strategy
that was begun in 1966 and which has been shown to be workable.
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Claimed disadvantages include:
a. The one-year time period may not permit enough mileage
accumulation.
b. The one-year period may not permit enough time to incorpo-
rate design modifications.
c. The California sales of some importers are much larger than
of some domestic automakers, thus posing a more severe
burden on them (o. g. , 32 percent of Nissan's sales, 22 per-
cent of Toyota's sales, and 17 percent of Volkswagen's 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%).
4.3.5 California-plus Strategy Comments Summary
No benefits were stated or claimed from the auto company
viewpoint for a 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 include:
a. It increases manufacturing and distribution problems.
b. It involves a complex and difficult enforcement system.
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.
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SECTION 5
STATE OR REGIONAL CONSIDERATIONS
5. 1 SUMMARY OF STATE OR REGIONAL ISSUES
The following sections summarize the state or regional view-
points on issues concerning the two-car strategy options as they impact the
various jurisdictions that are candidates for control.
Because of the length of this section and the level of detail
treated, an overview of state or regional considerations is presented in
Appendix G in briefing chart format.
5.1.1 Reactions to Two-Car Strategy
The California-only strategy impacts the air quality implemen-
tation plans of other states. The impact varies in degree, depending upon the
contribution of vehicle sources to the degradation of air quality in the candi-
date control regions. For example, the effect is more significant in the
New York Metropolitan area than in the Minneapolis/St Paul region, where
the effect is relatively mild.
Complications associated with the implementation and adminis-
tration of a regional control strategy for a one-year duration is such that
many states would prefer the option of accepting 1974 automobile exhaust
emission levels for 1975 model year cars, provided 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 inside 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, felt that control of a metropolitan
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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 between
the two classes of new cars. Arguments against a broad-based control region
were raised in those areas where auto pollution problems are concentrated
in small central business districts. Most frequently, however, uniform con-
trol throughout the state was preferred to the regional control approach.
The majority of states or regions favored the California-only
strategy. An exception to this position 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 for 1975 exhaust
emission standards but conceded that the administrative complications involved
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 nonleaded gasoline
throughout the nation. However, the state has serious reservations about
being saddled with an emission control system which may ultimately prove to
be unsuitable. A regional control strategy within the state was rejected as
being unworkable.
5.1.2 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 administra-
tion of a regional emissions control program. For example, California
presently has both a regionally based and a statewide-based retrofit program.
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 on-highway emission inspection
program is in the pilot stage of development. The state has established a
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current program and procedures for assembly line inspection. Legislation
for enforcement and penalties for violation of emission laws has 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.
Washington, D. C. has a mandatory annual inspection program
for D. C. government vehicles that is tied to the existing safety inspection
program required for all D. C. passenger cars. New Jersey's emission in-
spection 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 i.leans by which two-car strategy control may be implemented.
A number of states have a mandatory periodic safety inspection
program. Few of these are tied to vehicle registration. However, New York
and New Jersey are two exceptions.
No existing regulations require proof of residency for registra-
tion. A number of states do not identify the domicile of the vehicle by county
or other jurisdiction. Accordingly, development of new laws and procedures
would be needed 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. However, the possibility of
implementing these proposed retrofit programs by 1975 seems extremely
remote.
5.1.3 Region-Peculiar Factors
California's size, population distribution, and border situation
lends itself to two-car strategy control.
The proximity of population centers in a number of east coast
regions requires interstate control zones in order to simplify the problem of
control and in order to realize a beneficial effect on air quality.
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Many of the AQCRs considered for control are largely rural
with only localized mobile source pollution problems.
Unique situations exist in Alaska and Colorado. With regard
to Alaska, catalyst control systems may not be effective in view of the Alaska
cold weather and CO and the ice-fog problems. Colorado and other high-
altitude areas require waivers to adjust emission control settings for high-
v "t
altitude effectivity and vehicle driveability.
5.2 DISCUSSION BY STATE
California is discussed first, followed by other potential
low-emission control areas in alphabetical order.
5. 2. 1 California
State and regional considerations pertaining to the two-car
strategy in California are summarized below. The information given is based
upon discussions held in Sacramento, California with personnel from the
California Air Resources Board, the California Highway Patrol, and the
Department of Motor Vehicles, augmented by data from the official publica-
tions of these and other state agencies.
5.2.1.1 Reactions to the Two-Car Strategy
In general, the reaction to the strategy option calling for
California-only statewide control suggests that the plan was regarded to be
feasible, though frought with many possible serious administrative and techni-
cal difficulties. Factors mentioned as supporting the feasibility of the plan
with respect to its application in the State of California were as follows.
First, the precedent for a special California emission control
package and the basis for its public acceptance has already been established
by the state's exhaust emission control program, which has imposed require-
ments that are generally more severe than those applicable to the rest of
the nation. Moreover, this program has evolved a special body of laws and
administrative procedures which, in some part, may be applicable to the
proposed control strategy. In particular, penalties for noncompliance and
procedures for testing and certifying new car control equipment may be directly
transferable to the proposed program.
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Another factor supporting the feasibility of the California
program is the geography of the state's borders and the remote location of
its urban population centers with respect to these borders. This situation
represents a close approximation of an isolated market for the sale of
stringently controlled new cars. It minimizes the problem of controlling
out-of-state car purchases by residents of the control region as well as the
degradation of air quality due to in-state circulation of cars from uncontrolled
regions.
Problems anticipated in implementing a California program
include the requirement for changing existing laws pertaining to the state's
present autonomous position in regulating and administering new car control
programs. These changes would impact (for example) the authority of the
Air Resources Board to review and approve standards, control devices,
assembly line inspection procedures, and the authority of the Department of
Motor Vehicles to enforce state regulations concerning vehicle registration
and operation. Options available to the state under a federally mandated new
car emission control program would be (a) to change the existing laws, (b) to
stretch the interpretation of existing laws where possible, (c) to adopt Federal
standards as California state standards, or (d) to continue to operate on a
waiver basis by adopting standards that are slightly more severe than the
Federal standards.
Another significant problem anticipated was availability of the
nonleaded gasoline needed for catalyst-equipped California cars operating out-
side of state boundaries. Serious questions were raised as to the feasibility
of enforcing a federally mandated requirement for nationwide distribution of
nonleaded gasoline solely on the basis of its possible need by new California
cars (representing only about one percent of the total car population).
The incentive for and consequences of California residents
buying new cars out of state and registering them as used cars in the state
was considered. The California vehicle code defines a new vehicle as one
that has never been sold and operated on the highways of any other state. If
the price differential between the two classes of new cars were significant,
5-5
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the incentive would exist for purchasing and registering new cars out of state
or for registering a new car purchased out of state as a used vehicle in
California after it had been registered or driven in an out-of-state zone.
With regard to the seriousness of this problem, it was considered that
(a) marketing objectives might minimize the price differential between cars,
(b) the existing code definition of a new vehicle could be appropriately altered
if justified by public reaction, and (c) the number of violations likely to be
involved would have negligible effect on air quality for a one-year program
duration.
Reactions to a regional control program within the state were
largely negative. It was suggested that a likely region for control would be a
combination of the South Coast and San Diego air basins. Proof of residency
as a condition for new vehicle registration might be required in order to
ensure compliance with the law by residents in the control region. This would
entail a change in the existing registration code, which does not demand veri-
fication of the domicile of the vehicle. The most serious objection raised to
this proposal, however, related to the anticipated difficulty of convincing
state legislators that either control or no control was suitable for their
respective jurisdictions.
The principal concern expressed in response to the California-
only strategy was that the state would be cast in the role of a "guinea pig"
for the trial development of an emission control system that may ultimately
prove to be unsuitable. On similar grounds, the state would object to a
program of indefinite duration, which might lead to the evolution of a unique
but burdensome solution to the California control problem.
In summary, a one-year statewide program was regarded to
be an acceptable possibility, provided (a) that the EPA could mandate a
supply of nonleaded gasoline throughout the U.S. for the control year under
consideration, and (b) that catalyst systems would not be dropped the following
year.
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5. 2. 1. 2 Background/Experience Related to Vehicle Control
5.2.1.2.1 Vehicle Registration Control
Similar to other states, California requires registration of
passenger cars and other operating vehicles on a yearly basis. The process
has been centrally controlled by the Department of Motor Vehicles (DMV) in
Scaramento. Applications for reregistration are mailed to the address pro-
vided in the previous registration application. The DMV must be notified of
a change in address within 30 days, and the new address must be provided in
the application for reregistration.
It is noted that the address provided for vehicle registration
purposes may be a business address, a residence address, or simply a
mailing address; it need not be the domicile of the vehicle being registered.
California vehicle registration is recorded on a county basis,
primarily for the purpose of disbursing license fee and gas tax revenues to
the various counties for road construction, highway patrol operations, and
other county programs. On registration, the applicant is required to certify
that he has resided in a specific county during the previous year. However,
this requirement refers to the domicile of the registrant, not of the automobile
registered. No proof of residency is required; no surveillance of the accuracy
of the residency statement is conducted.
With regard to registration procedures for new car sales, the
dealer is required to certify that the vehicle sold to a California resident is
equipped with the appropriate emission control package for the state of
California. Since proof of residency is not a registration requirement, it
appears possible to circumvent state laws by ordering a nonequipped car from
a California dealer on the basis of the purchaser's claim that he resides out-
side of state boundaries. As noted earlier, another circumvention technique
would be to purchase a nonequipped car outside of the state and register the
vehicle in California as a used car, which existing state laws exempt from
California new car controls.
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Out-of-state vehicles domiciled in California are permitted to
operate on California roads for a period of up to one year without reregistra-
tion as long as their current-state registrations are valid. There is no overt
program for enforcing this requirement, even though differences in registra-
tion fees sometimes provide the incentive for reregistering resident cars
out of state. This is possible because the lack of conditional registration
requirements (safety, emissions inspection) in many states makes it simple
to reregister in absentia.
5.Z.I.2.2 Safety Inspection Program
California does not have an established, periodic safety inspec-
tion requirement program. Safety inspections on a random sampling basis
are conducted in an on-highway program referred to as the California Passenger
Vehicle Inspection (PVI) program. This program utilizes mobile inspection
teams positioned randomly throughout the state. There are 71 teams con-
sisting of 5 men each. On-highway inspection locations are changed regularly
so as to achieve uniform sampling and surveillance throughout the local in-
spection zones.
Items of safety covered in the inspection include lights, brakes,
tires, windshield wipers, horn, and turn signals. An examination of the
engine compartment is also made for the purpose of surveying the complement
of emission control equipment. In this check, items such as the PCV valve
hose, air injection pump, carburetor linkages, and other obvious emission
hardware are examined. In addition to this gross check, eight of the inspec-
tion teams have been equipped with exhaust-gas analyzers for measuring HC
and CO emissions. This adjunctive program is designed to reject and eliminate
high emitters.
The inspection process takes 3 to 5 minutes. Each team
processes about 150 cars per day. About 12 to 15 percent of the car popula-
tion is checked yearly by this process.
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Upon failure of any part of the safety or emission check, a
citation is issued. Corrective repair or adjustment is required to be made
and verified by the Highway Patrol within 14 days. If the failure involves
headlights or emission control equipment, the corrective action must be
carried out and certified by a state-approved "Class A" garage or service
station. An approved vehicle is issued a color-coded windshield sticker
indicating that the car has been sampled in the current year.
5.2.1.2.3 Emission Inspection Program
Scheduled emissions inspection is not a requirement for
California cars. The emissions inspection tied to the random, on-highway
safety inspection program is estimated to impact from 1 to 2 percent of the
car population yearly. As indicated earlier, this program is designed to
eliminate on-highway excessive polluters. Pass/fail emission levels are
presently set so as to reject 23 to 25 percent of the cars inspected. Correc-
tive action by state-approved garages is required to be completed within
14 days.
All California new cars are assembly-line tested for emissions.
Seventy-five percent of production is subjected to an idle mode test, and
25 percent is subjected to one hot 7-mode cycle test. In addition to these.
tests, a quality audit sample consisting of 2 percent of production is subjected
to the Federal CVS cold-start test.
Primarily, the assembly line testing program is designed as
a screening device to eliminate vehicles on the high end of the production-
tolerance emissions distribution curve. The standard of performance is
defined by a 100-car sample taken at the beginning of each production quarter.
This sample is subjected to the idle and 7-mode tests, and the distribution of
emissions obtained by each test is established. From these distributions, the
emission levels at two standard deviations above the mean are used to de-
lineate the pass/fail points for the respective test cycles in the current quarter.
The quality audit sample provides the mechanism for controlling production
quality with respect to official California emission standards and test procedures
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There is another California emissions inspection mechanism
which is tied to the registration of cars previously registered in other states.
A precondition for such registration is a "Certificate of Compliance" obtained
from a state-approved Class A station, which verifies that the vehicle is
equipped with emission control equipment suitable for meeting state or Federal
standards, depending upon the vehicle model year. Model year cars of 1971
and later are required to meet Federal levels for equipment. Older cars are
subject to a retrofit requirement in accordance with the state's recently insti-
tuted retrofit programs. At present, the compliance inspection consists of
a visual and functional check of equipment and does not include an emissions
measurement.
5.Z.I.2.4 Retrofit Program
There are two California retrofit programs in force: one
applies to 1955 through 1965 cars; the other applies to 1966 through 1970 cars.
The 1955/65 retrofit program is a regionally based plan covering
essentially the South Coast Air Basin, San Diego County, and the San Francisco
Bay Area. Two retrofit devices (essentially spark-retard mechanisms) have
been certified for use. Retrofit becomes mandatory either upon transfer of
vehicle ownership or upon registering a vehicle in this model year group in the
state for the first time.
Enforcement of the 1955/65 program is accomplished by re-
quiring a certificate of compliance as a condition for either first registration
or reregistration and transfer of title. The certificate is issued by a state-
approved Class A station and verifies that the vehicle is appropriately equipped
for the address of residency provided by the owner. It is noted that the com-
pliance certificate does not display this address. The Department of Motor
Vehicles is not empowered or equipped to verify that the address provided for
registration coincides with the information given for the certificate of com-
pliance. Used cars sold by dealers are equipped on the basis of the dealer-
ship address. In the case of private cars, it appears that no completely
satisfactory mechanism for enforcing this law exists. This program has been
in force about one year and its effectivity has not yet been evaluated.
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The 1966/70 model year retrofit program is a statewide
program designed to improve NOx emissions in model year cars originally
controlled only for HC and CO. Four devices have been certified for use by
the Air Resources Board. These are all spark-retard mechanisms combined
variously in individual cases with EGR and thermal protection mechanisms.
This program, which began in February 1973, is being introduced on a county-
wide basis. Beginning in 1975 the final mechanism for statewide enforcement
will be proof of installation verified by a certificate of compliance as a condi-
tion of any reregistration.
5.2. 1.3 Region-Peculiar Factors
California's large automobile population of approximately
9 million cars represent about 10 percent of the national total. The new-car
fraction, which is also close to the national average of 1 0 percent, provides
a sufficiently large sample for a representative performance evaluation of
the 1975-type emission control system. Variations in geographical and
climatic factors over the state provide for a broad range of driving conditions
that encompasses many of the situations met nationwide.
The number of nonresident vehicles registering annually is a
small fraction (about 2. 5 percent) of the total vehicle population. From the '
standpoint of air quality considerations, therefore, the impact of uncontrolled
new cars taking up residency in the state would not be great.
California is unique in that the state is presently operating on
the basis of a two-car emission control strategy. This has evolved as a result
of the special requirements needed to meet California's exhaust emission
standards, which, as previously discussed, are more stringent than standards
applied elsewhere in the nation. As a result of this situation, and by virtue
of its unique experience, California is better equipped to administer a two-
car strategy.
The geography of the California border and the relative loca-
tions of large population centers comprise a nearly ideal situation with regard
to controlling purchases of noncomplying new cars. This feature appears
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especially attractive in the light of other alternatives to control. For example,
the possibilities for adopting a retrofit program as a means of deterring the
purchase of uncontrolled cars from out of state seem poor when California's
experience in implementing retrofit programs is considered. A total of three
years were required to launch the 1955/65 retrofit system, considering the
time required to enact the enabling legislation, define the performance speci-
fications for the device, test and certify systems, and make the hardware
available for distribution. It is estimated that any new retrofit program would
require a minimum of 1 5 months to implement, assuming that the enabling
legislation were already available.
5.2.2 Alaska
Two-car-strategy considerations for the State of Alaska are
summarized below. The bulk of this information was obtained by telecons
with personnel in the Alaska Department of Environment Conservation.
5.2.2.1 Reactions to Two-Car Strategy
The 1975 emission standards will have little effect on the
Fairbanks air quality. A 70-percent CO reduction is required to meet the
Federal air quality standards. This could only be achieved in 1975 by a
severe reduction in vehicle miles traveled (VMT).
The city of Fairbanks lies in a natural bowl, and the region is
characterized by extremes of low temperatures and inversion conditions. A
long, stable ice fog occurs in winter when the temperature is -30°F or lower,
which is caused by the water vapor in the automotive exhaust. The net effect
of fog is to reduce vehicle speed, thereby increasing the rate of CO emissions.
High CO emissions are also caused by the cold-weather effect on engine start-
ing and operating conditions: drivers start their cars before they intend to
use them and keep them running the entire day, thus causing considerable
idle CO emissions. The fog problem will not be helped by the use of catalyst
systems.
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Fairbanks is not a wealthy community. An adverse reaction
is to be expected if Fairbanks is singled out for more-expensive emission
controls. On the other hand, Anchorage, which has an active conservation-
ist group, may protest being excluded from control.
There are serious doubts about the effectiveness of catalyst
systems operating under extreme cold-weather and prolonged-idle condi-
tions, as is common for Fairbanks.
5.Z.2.2 Background/Experience Related to Vehicle Control
5.2.2.2.1 Vehicle Registration Control
Alaska registrations have a city and zip code identification.
There are no counties in Alaska; sub-state jurisdictional units are called
boroughs. Vehicle registration for the Fairbanks North Star Borough com-
prises about 20, 000 light-duty vehicles and about 1500 heavy-duty vehicles.
Vehicles new to the state are required to be registered in Alaska within
30 days of establishing residency.
5.2.2.2.2 Safety Inspection Program
The State of Alaska has no vehicle safety inspection program
at present.
5.2.2.2.3 Emission Inspection Program
Alaska has no emission inspection program in force. The
Fairbanks transportation control plan submitted to EPA includes an inspec-
tion and maintenance strategy that is proposed to consist of a simple idle-
check and tune-up conducted at 6-month intervals. Reductions of 50 to 60
percent in CO emissions are considered possible by this means. At the
present time only visible emissions are actively prohibited. This is
enforced by the local police.
5.2.2.2.4 Retrofit Program
Alaska has no retrofit program.
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5.2.Z.3 Region-Peculiar Factors
Fairbanks' geographical and climatic conditions (low
temperature and severe, long lasting temperature inversions) operate to
create a long, stable ice-fog condition in winter caused by the aforemen-
tion water vapor in the exhaust. Reductions in CO through the use of 1975
catalyst-type control systems will not help the fog problem.
Fairbanks' major pollutant is CO. Other pollutant concen-
trations may not be high enough to warrant placing Fairbanks in a Class I
region category. Both CO and fog could be ameliorated by transportation
control strategies such as suggested in the state implementation plans call-
ing for mass transit (Artie Rapid Transit System (ARTS) and restricting
VMT by private automobiles in the Fairbanks central business district (CBD).
Also militating against a regional strategy for Fairbanks is
the fact that catalyst systems and other emission systems may not function
under the extreme low-temperature and sustained-idle conditions that char-
acterize Fairbanks' vehicular operation. Thus, cold weather operation of
engines is a problem in itself, and catalyst devices at their present level of
development may add to these operating difficulties and ultimately to the
pollutant dump due to the possible continuing requirement for extended idl-
ing to offset starting problems.
5. 2. 3 Arizona
Meetings with representatives of the Motor Vehicle and Plan-
ning Survey Divisions of the Arizona State Highway Department and with the
Division of Air Pollution Control, Arizona State Department of Health,
Phoenix, Arizona were held to review the various aspects of the two-car
strategy impacting the State of Arizona.
Of particular interest was the Phoenix/Tucson AQCR. This
area encompasses five counties; Gila, Maricopa (Phoenix), Pima (Tucson),
Pinal, and Santa Cruz. This region comprises 81 percent of the total state
population, 84 percent of the passenger cars registered in the state, and
accounts for 74 percent of the motor vehicle fuel consumption.
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5.2.3.1 Reactions to Two-Car Strategy
Arizona officials indicated that although a regional or air-basin
approach to the two-car-strategy option appeared sound from a technical point
of view, they would strongly favor a statewide approach from both the politi-
cal and enforcement point of view. It was pointed out, for example, that over
six million out-of-state cars enter Arizona each year, which is over seven
times the Arizona passenger-car registration total. Thus, control of out-of-
state cars was not considered feasible. By comparison, it has been esti-
mated that approximately 5 percent of the annual registrations are out-of-
state cars (see Section 2. 3); however, because of the high incidence of out-
of-state "visiting" cars, the opinion was expressed that this would delay
achievement of the Arizona air quality goals.
5.2.3.2 Background/Experience Related to Vehicle Control
5.2.3.2.1 Vehicle Registration Control
Yearly registration of motor vehicles is mandatory in Arizona.
They are currently in the process of converting to a staggered registration
system whereby one twelfth of the motor vehicles will be registered each
month. Conversion to the staggered system is presently scheduled to be
completed by 1974. However, an extension of one year, to 1975, has been
requested but not yet approved. Motor vehicle registrations are identified
by county in Arizona.
An affidavit of emission control compliance is presently
required only for registration of used cars. This affidavit is signed by the
dealer on all dealer sales and by the buyer on all private party sales. The
state will accept the manufacturer's certification of compliance with Federal
standards for registration of new cars.
If the proposed emissions inspection program becomes man-
datory (see Section 5.2.3.2.3), compliance would be required as a condition
of registration.
Arizona does have reciprocity agreements with bordering
states whereby vehicles domiciled within a 25-mile corridor of the state
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border can be licensed in one state and operated in the other without being
registered in the second state.
5.2.3.2.2 Safety Inspection Programs
Arizona does not have a motor vehicle safety inspection
program.
5.2.3.2.3 Emissions Inspection Program
The Arizona Department of Health, Division of Air Pollution
Control, has been empowered by the State legislature to establish both motor
vehicle emission standards and testing methods, procedures, and techniques
for possible use in a mandatory emission inspection/maintenance program.
Legislation passed in 1972 allocated $1,000,000 to the Depart-
ment of Health to establish a pilot emissions testing program. One test sta-
tion, consisting of two lanes for testing and one lane for research, is sched-
uled for operation in Phoenix in July 1973. An additional test station is
scheduled for Tucson in January 1974.
The Department of Health is currently operating a portable
dynamometer in the Phoenix area for evaluating test procedures and stan-
dards. Vehicles are tested on the dynamometer at 50, 30, and 0 miles per
hour. Testing of privately owned vehicles is currently on a voluntary basis;
testing of state-owned vehicles is mandatory. To date, some 5,000 cars
have been tested, approximately 35 percent of which have failed to meet the
Arizona standards for HC and CO.
Results obtained under the pilot program are to be reported
to the State legislature by January 1974. It is expected to be the forerunner
of a mandatory emissions inspection/maintenance program. The current
legislative climate was said to favor a mandatory program in Phoenix and
Tucson by 1975, although the actual enabling legislation has not yet been
passed. Program standards and procedures would be established by the
Department of Health while the operation, administration, and enforcement
would be handled by the Department of Highways, Motor Vehicle Division.
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At the present time, some 14 stations are envisaged for Phoenix and 7 to 8
for Tucson. The cost to the state has been estimated at $12,000,000. The
cost per test is estimated to be $5 for the first 2 to 3 years and then $2 to
$3 after amortization of the capital investment.
5.2.3.2.4 Retrofit Program
Arizona has no retrofit program in force at the present time,
although the Department of Health is empowered to certify and require the
use of retrofit devices. They have recommended that such devices be tested,
but no action has been taken to date.
Arizona may ignore 1967 and older cars with regard to any
potential retrofit program, since these are estimated to constitute only 25
percent of the vehicle population by 1975.
It was also indicated that they may have to rule out the vacuum
advance-spark disconnect as a retrofit device because of the high ambient
temperatures in the Phoenix/Tucson areas.
5.2.3.3 Region-Peculiar Factors
The control of oxidants and CO (8-hour average) constitutes
the major problem in the Phoenix/Tucson air basin. The extremely high
incidence of out-of-state cars (6.4 million entered the state in 1971) could
have a significant impact on achieving the air quality standards in the event
a two-car strategy were adopted. Data in Table 5-1 show that approximately
30 percent of all VMT on state highways in Arizona are attributable to out-
of-state cars. Within the total Phoenix/Tucson air basin it is estimated
that approximately 12 percent of the VMT are attributable to this same
source.
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Table 5-1. Daily Vehicle Miles on Rural and Urban Systems
State of Arizona - 1971
1
Highway System
INTERSTATE
Vehicle Miles
Avfrage Daily Traffic,
Vehicles
Percent of All Systems
PRIMARY
Vehicle Miles
Average Daily Traffic,
Vehicles
Percent of Primary
Percent of All Systems
SECONDARY
\ chicle Miles
Ai-erage Daily Traffic,
Vchicleo
Percent of Secondary
Percent of All Systems
STATE ONLY
Vehicle Miles
Average Daily Traffic,
Vehicles
Percent of State Only
Percent of All Systems
TOTAL. STATE SYSTEM
Vehicle Miles
Average Daily Traffic,
Vehicles
Percent of State System
Percent of All State
Traffic
System
Miles
1,220.86
2,020. 30
1. 799.68
752.72
). 793. 56
Rural and Urban Miles Traveled
Local
Pass.
3,615, 178
2,961
35. 11
19. 10
2,740,511
I, 357
49. 17
14.48
1,039,213
577
47.67
5.49
239, 168
318
27. 18
1.26
7,634,070
1,318
40. 33
21.06
Foreign
Pass.
3,716,966
3,045
36. 10
19.64
1, 175,766
582
21. 10
6.21
368, 520
205
16.90
1.95
272.932
362
31.01
1.44
5, 534, 184
955
29.24
15.26
Comm.
2,963, 158
2.427
28.79
15.65
1,656,755
820
29.73
8.75
772, 300
429
35.43
4.08
367,912
489
41. 81
1.95
5,760, 125
991
30.43
15.88
All
Vehicles
10,295, 302
8,433
100. on
54. 39
5,573.012
2,759
100.00
29.44
2, 180,033
1,211
100.00
11.52
880.012
1, 169
100.00
4.65
18,928. 379
3.267
100.00
52.20
So'ircc: Arizona Highways Department, Planning Survey Division
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5. 2. 4 Colorado
A summary of the considerations pertaining to the two-car
strategy for the state of Colorado is given below. The information was
obtained from the Colorado Department of Health (Air Pollution Control
Division) and from the Colorado Motor Vehicle Division (Motor Vehicle
Safety Inspection), both located in Denver.
5.2.4.1 Reactions to the Two-Car Strategy
With the present Motor Vehicle Division makeup, the control
strategy could only be applied statewide. The political climate is against
regional control, even though only metropolitan Denver requires significant
rollbacks in oxidant and carbon monoxide pollutants generated by mobile
sources.
A 52 percent reduction in carbon monoxide and a 48 percent
reduction in hydrocarbon emissions are required to meet Denver objectives.
Oxides of nitrogen concentrations do not exceed air quality standards. Even
with all automobile emissions meeting Federal standards, there still will be
a need in 1977 for additional reductions of 29 percent in carbon monoxide and
18 percent in hydrocarbon. The pollution concentration over Denver is the
result of a temperature inversion layer which develops almost every night
of the year.
Colorado objects strongly to the mandatory Federal no-
tampering regulation pertaining to factory-set carburetion. Difficulties
are being encountered by all major car manufacturers -in meeting Federal
standards at Colorado altitudes. The altitude within the state varies between
3,000 and 10,000 feet. These altitudes require modification of all vacuum-
operated devices and special tune-ups to obtain normal autombile operation.
So far, Colorado has not obtained an exemption from the Federal no tampering
regulation. Both current 1973 cars and 1975-type experimental vehicles with
factory-set carburetors are not working properly in Colorado. In addition to
poor driveability, the adjustment restriction results in a 60 to 70 percent
increase in emissions above sea-level values.
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Legislation has not yet been established to implement an
automobile emission inspection program. Several proposals are now being
debated, but there is little likelihood that any will pass this session. In the
past, Colorado's legislature has been very negative with regard to auto-
mobile emission controls, particularly with regard to strategies limited to
the Denver air basin. The main reason for this is that uncontrolled regions
are within 60 miles of metropolitan Denver. It would be easy, for example,
for anyone to buy a car outside the Denver area. (A local sales tax of 6 per-
cent has already reduced new car sales in Denver.) Added cost for local
emission controls would provide the incentive to buy the car outside the con-
trolled region. Residence addresses provided by the purchaser are not
verified and, in any case, a postal box number is an acceptable registra-
tion address. One-year implementation of a two-car strategy would have
to be based on faith, since state machinery for control could not possibly
be developed before 1978.
5.2.4.2 Background/Experience Related to Vehicle Control
5.2.4.2.1 Vehicle Registration Control
Yearly automobile registration is mandatory in Colorado.
No special effort is being made to survey registrations except for routine
check by police when they stop a car. The state is not equipped to handle
actual residence verification and, so far, has had little need for it. Because
handling of registration is manual, few statistics are available.
The smallest unit of automobile registration classification is
the county. Automobile registration is staggered by month to distribute the
workload over the calendar year. New residents must register their car in
Colorado within 30 days. No special penalty is imposed on infractions,
except that the date of registration is retroactive to the date residence in the
state was established. A new car is deemed to have become a used car after
its first sale.
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5.2.4.2.2 Safety Inspection Program
Colorado's safety inspection program has been in operation
since 1950. Safety inspections are conducted by 4,000 state-licensed dealers
or garages and are not tied to automobile registration. The inspection is
mandatory twice a year, staggered by month. A compliance sticker must
be displayed on the windshield. Repairs in the inspecting facility are
acceptable. Undercover facility checks are conducted randomly. Stan-
dards for the safety inspection are established so as to fail 30 percent of
the applicants. Failure, however, can be simply some such maladjustment
as, for example, light-beam settings. The car can be impounded for failure
to display the safety sticker, and/or a fine of $5 can be imposed for failure
to comply. The inspection fee is now $1. 50.
To be licensed, mechanics doing the safety inspection must
pass a written and practice test at the Motor Vehicle Division. No mechanic
is authorized to do the safety inspection without a license.
5.2.4.2.3 Emission Inspection Program
The Colorado legislature has not enacted a law for automo-
bile emission inspections and is not likely to do so this year. However,
present plans call for an emission inspection program to be similar to
Colorado's highly successful safety inspection program. The same dealers
and garages would be expected to handle the emission inspections.
The emission inspection would use the idle-test mode. This
is deemed sufficient since control of carbon monoxide is the primary goal.
It is believed to be economically unfeasible to do key-mode or similar
"functional" tests, since a minimum of 100 dynamometer lanes would be
required. Whether the mandatory emissions inspection should be done once
or twice a year has yet to be decided. The mechanics would have to be
examined and licensed by the Motor Vehic.le Division, as in the case of
safety inspections noted previously.
Start of the inspection program could not be accomplished
before 1978 because of such constraints as obtaining and training necessary
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personnel and other needs. About 60 people would have to be hired and
trained to monitor the program; this is about four times the total personnel
now employed for all state environmental work. The total environment bud-
get is currently $700,000, which includes stationary source emissions. Only
about $100,000 per year is available for research and studies. Hence, it
takes a long time to do any extra planning. Therefore, considering the time
for setting standards and licensing mechanics, it would be 1980 before the
inspection plan could be fully implemented.
5.2.4.2.4 Retrofit Program
There is no existing law authorizing an emission system retro-
fit on used cars, and passage of such law is not expected this year.
The EGR plus vacuum-spark-retard has been considered as
a possible retrofit system, but no money has been allocated for an in-depth
study of the system.
It is believed that the greatest improvement in used car emis-
sions would result from tuning engines to the manufacturer's specifications.
5.2.4.3 Region-Peculiar Factors
Colorado cannot meet the Federal emission standards with
automobiles set for a low-altitude environment. A penalty of 60 to 70 per-
cent in exhaust pollutants resulting from the Denver 5, 000-feet altitude would
result in failure to meet Federal ambient air standards. Furthermore,
vacuum-operated devices would be nearly inoperative. Hence, a waiver to
the EPA no-tampering regulation must be obtained for satisfactory opera-
tion of automobiles in Colorado. All mountain states would face this same
problem.
There were 1, 179, 199 passenger cars registered in Colorado
in 1971. Data on the distribution of the car population in the Denver region
are provided in Table 5-2.
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Table 5-2. Denver Region Car Population Distribution
Passenger Car Percent of
Registrations State Cars
Adams 99,160 8.40
Arapahoe 95,150 8.10
Boulder 72,959 6.20
Clear Creek 3,219 0.27
Denver 272,577 23.10
Douglas 5,365 0.45
Gilpin 1,126 0.10
Jefferson 144,827 12.30
Denver Air 694,383 58.90
Region
There is a market for used Cadillacs in Colorado and many
are imported from out-of-state. The large-displacement engine operates
well at Colorado's altitudes. However, the Motor Vehicle Division does
not keep statistics on the Cadillac population.
5. 2. 5 District of Columbia
Considerations pertaining to the application of the two-car
strategy to Washington, D. C. are summarized below. This information is
based on discussions held in Washington, D.C. with personnel from the
District of Columbia Department of Environment Services (Bureau of Air
and Water Quality Control), the Metropolitan Washington Council of Govern-
ments (Department of Health and Environmental Protection), and the D.C.
Department of Motor Vehicles (Office of Safety Research).
5.2.5.1 Reactions to the Two-Car Strategy
Personnel in the Bureau of Air Quality Control expressed con-
cern that any consideration might be given to a control strategy which would
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exclude Washington, D.C. as a stringently controlled region. The D.C.
problem is predominantly a mobile source problem, since no industry is
permitted in the District. The main difficulty is in meeting the oxidant
standard, which requires a 53 percent reduction in HC pollutants. To
accomplish this, the District's implementation plan incorporates a number
of transportation control strategies (mass transit, retrofit, emission inspec-
tion, etc.). All of these plans, however, are predicated upon having new
cars that meet 1975 emission standards. Therefore, unless an extension in
the schedule for meeting air quality goals were to be granted, D. C. could
not tolerate a 1974 emission level car for model year 1975.
The District's problem is shared by other jurisdictions com-
prising the National Capitol Interstate Air Quality Control Region. These
include counties and independent cities in Virginia and two counties in
Maryland. No transportation control scheme could be effective without
considering traffic within the entire air basin boundary, including the juris-
dictions governed by Maryland and Virginia. (It is noted that the Metropoli-
tan Washington regional control strategy was developed on a joint coopera-
tive basis for the three local governments.) Control limited to the geo-
graphical area encompassed by the air basin was felt to be administratively
unwieldy and, perhaps, totally unenforceable should the price differential
between the two classes of new cars be significant. For this reason, it was
speculated that Metropolitan Washington control program might involve con-
trol of the entire states of Maryland and Virginia in addition to the District
of Columbia.
The availability of nonleaded gasoline for trips outside the
Washington control region was discussed. The District's transporation plan
calls for retrofit of late-model used cars with catalytic converters; however,
this proposal was based on the assumption that nonleaded gasoline would be
available nationwide because of new car catalyst system requirements in the
1975 model year. In contrast to this situation, the proposed regional control
strategy would demand that nonleaded gasoline be made available nationwide
5-24
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solely for the small percentage of stringently-controlled new cars operating
outside designated control regions. External-trip distribution data bearing
on this problem for the Washington Metropolitan area are shown in Table 5-3.
Table 5-3. 1968 Auto Travel Inside Cordon Area
TYPE OF TRIP
Internal Auto Driver
External Auto Driver
Throughs
Resident
Non-Resident
Total
Average
Weekday Trips
(in thousands)
3,407
277
17
123
137
3,684
Percent
of Trips
92.5
7.5
0.5
3.3
3.7
100.0
Average
Weekday VMT
(in thousands)
23, 443
4,619
28,062
Percent
VMT
83.5
16.5
100.0
Average
Trip Length
(Miles)
6.9
16.6
7.6
Source - 1968 COG/TPB Home Interview Survey
Source - 1968 COC/TPB External (Roadside) Survey
In summary, Bureau of Air Quality personnel felt that a one-
year regional control strategy for Metropolitan Washington, D. C. area might
be more trouble than it was worth. They would prefer a continuation of 1974
emission standards for 1975 model year cars if accompanied by a one-year
or longer extension in the schedule for meeting air quality standards.
5.2.5.Z Experience/Background Related to Vehicle Control
5.2.5.Z.I Vehicle Registration Control
Annual registration in Washington, D.C. is mandatory, and
the deadline for registration is March 31. All vehicles except field service
vehicles (nationally-mobile elements of the Post Office, Department of
Agriculture, military, etc.) are registered, including foreign national,
Federal, and District government vehicles (the latter two groups being fee
exempt). It may be noted that in most states Federal vehicles are not
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registered. The nonregistered group comprises less than 2000 vehicles,
or less than 1 percent of all cars registered.
Registration is not tied to the D. C. annual safety inspection
requirement, which falls on the anniversary of car purchase. License tags
are assigned to the registrant and are not transferred with change of vehicle
ownership.
Out-of-District vehicles must register in the District within
30 days of establishing residency. There is no overt program to enforce
this requirement. The nonresident fraction of new registrations each year
is not identified or recorded.
With regard to the two states sharing the D.C. Metropolitan
area air basin, Maryland does not register vehicles on a county basis;
Virginia registers both with respect to county and independent city, which-
ever applies. Both states have an annual registration requirement. Virginia
now registers on a staggered basis throughout the calendar year. Both state
and county license plates are used on Virginia cars. The independent cities
have a sticker display, in addition to the state license plate.
5.2.5.2.2 Safety Inspection Program
An annual safety inspection is required for all D.C. passenger
cars. Inspection falls on the anniversary of car purchase or on the vehicle's
first registration in the District. Taxicabs and school busses are inspected
twice a year.
The inspection program is city run and has been in operation
since 1939. There are two stations consisting of 4 lanes each. One lane in
each station is dynamometer-equipped for emission testing. Enforcement
is based on a color-coded and dated windshield sticker. Rejections on first
appearance have been running about 40 percent. A one dollar safety check
fee is paid on registration.
Safety inspection in the State of Maryland is required only
when the vehicle is resold. Virginia has a twice-yearly inspection require-
ment (proof of inspection is not required for registration). The program is
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conducted by state-licensed private garages for a two-dollar fee. Valid
inspections are identified by a color-coded and dated windshield inspection
sticker. One week is provided to make necessary corrections to safety
items failing the inspection check.
5.2.5.2.3 Emission Inspection Program
Washington, D.C. does not have a general requirement for
emission inspection. At present, only D.C. government vehicles are
required to be inspected. These inspections are performed once a year.
A pilot program for private vehicles s\ibmitted on a voluntary basis is under-
way. About one percent of the D.C. registered vehicles are checked on
this basis.
The inspections are conducted piggy-back to the safety inspec-
tion operation. One lane in each of the two safety inspection stations is
equipped with a dynamometer and gas analyzer apparatus. The duty cycle
used is the Clayton Key Mode (3-speed) cycle. To date, the data scatter
from this program is such that it is difficult to determine if the inspection
check and subsequent maintenance do any good.
An emission inspection program for all cars registered in
the D.C. Metropolitan area has been proposed as part of the regional trans-
portation control strategy for 1975. This program has been approved by
the D.C. City Council and the Mayor, and the required budget is included
in the D. C. budget that is submitted to Congress. No capital outlay for this
program is required; the plan calls for extending the operating hours for the
existing inspection stations.
Neither Virginia nor Maryland have an emission inspection
program. Virginia is planning to implement an emission program that would
be tied to the current safety inspection program administered by the Depart-
ment of Motor Vehicles.
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5.2.5.2.4 Retrofit Program
Currently, there is no retrofit program in force. A
coordinated program for retrofitting all vehicles in the Metropolitan
Washington, D. C. area has been proposed for adoption in the implementa-
tion plans for the District of Columbia, Maryland, and Virginia.
The proposed program would equip all 1968 through 1974
cars with a catalyst system such as the UOP Mini-verter and all pre-1968
cars with a device such as the GM spark-retard system. The Mini-verter
is expected to cost about $150 for a V-8 engine; some cars will further
require an air pump, involving additional cost. Based on EPA guidelines,
the Mini-verter system is expected to reduce HC and CO emissions by 56
percent relative to 1974 exhaust emission standards. Some retrofit exemp-
tions would be permitted, including cars with high-compression-ratio
engines.
The proposed retrofit program is under review by the indi-
vidual governments involved. Approval for the District would require con-
gressional review, even though the City Council nominally has blanket auth-
ority to implement emission control programs for the District of Columbia.
Neither Maryland nor Virginia has the enabling legislation that would permit
such a program to proceed within its jurisdictional areas. The Virginia
legislature is presently out of session and does not reconvene until January,
1974; the Maryland legislature adjourns in April. Accordingly, to expect
that retrofit for the D. C. Metropolitan area could be implemented in time
to meet 1975 air quality objectives appears unrealistic.
5.2.5.3 Region-Peculiar Factors
Though Washington, D.C. is thought to be a tourist city,
results of a 1968 travel survey indicate that less than 10 percent of the
vehicle miles traveled in the Washington Metropolitan area falls in the fee-
exempt registration category. This includes through travel, tourist travel,
and travel by diplomatic vehicles. Therefore, the air quality impact of
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nonresident new car travel into a controlled Metropolitan Washington, B.C.
area would appear to be negligible for a one-year program duration.
About 231,000 passenger cars are registered in the District
of Columbia; 1, 167,000 are registered in the air quality control region.
The District issues about 100,000 new titles yearly, of which about 30,000
are D.C. registration transfers. The balance, 70,000 titles or about one
third of the D. C. passenger car registration, would appear to be made up
of vehicles not previously registered in the District (new registrations).
This is an extraordinarily high turnover of the resident car population. It
seems possible that the new title statistic may be comprised in part of title
transfers from lienholders to owners; therefore it may not be a direct reflec-
tion of the number of new resident cars in the District. The new registration
fraction from out-of-District is not a statistic that is recorded by the
Washington D.C. Department of Motor Vehicles.
Implementation and administration of a regional control strat-
egy in the Washington Metropolitan area is complicated by the requirement to
coordinate the program among three local governments. However, the situ-
ation is not dissimilar to requirements elsewhere on the east coast: for
example, the Philadelphia/New Jersey/New York City region.
5.2.6 Maryland
Two-car strategy considerations for the state of Maryland
are given below. This information is based primarily on information
obtained in telephone communications with personnel in the Maryland State
Department of Health, Bureau of Air Quality Control.
5.2.6.1 Reactions to Two-Car Strategy
Maryland's air quality implementation plan relies heavily
upon attainment of 1975 emission standards for 1975 model year cars. A
California-only strategy would demand greater reliance on other elements
in the state's transportation control strategy, such as reduction of vehicle
miles traveled (VMT) by taking cars off the road. For example, if 1975
f>-29
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cars were controlled to 1974 levels, it was estimated that bus ridership in
Baltimore would have to be increased by 60 percent over what has been pro-
gramed (a 160-percent increase over current levels). A 70 percent reduc-
tion in HC emissions is needed to meet the oxidant standard in Baltimore.
With regard to a regional rather than a statewide strategy,
Maryland's reaction was negative. It was considered simpler to have a uni-
form control requirement throughout the state. Nevertheless, the problems
could be worked out.
False vehicle registration probably would be ignored as a
control issue for a one-year program duration.
Controlling only the Washington DC metropolitan region
(which includes two Maryland counties) would create problems arising out
of conservationist pressures in Baltimore.
Maryland would not be in favor of a permanent two-car strat-
egy. The state would prefer 1975 emission standards or the best Detroit-
deliverable emission levels for everybody nationwide.
.''5:2.6.2 Background/Experience Related to Vehicle Control
"5.2.6.2.1 Vehicle Registration Control
Maryland registrations are identified by county and zip code.
At the present time, the identification and check of car systems is possible
only on transfer of ownership, at which time the law requires a safety
inspection as a condition for title transfer.
5.2.6.2.2 Emission Inspection Program
There is no emission inspection program in force. The
state's implementation plan calls for a full inspection/maintenance require-
ment for all vehicles, to be implemented in 1975, although there is no
enabling legislation for carrying out this proposed program.
5.2.6.2.3 Retrofit Program
Maryland does not have a retrofit program in force. The
state implementation plan proposes a catalyst retrofit for all pre-1975
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light-duty vehicles by 1975. There is a bill in the General Assembly that
provides the means for enforcing this requirement for all vehicles reg-
istered in the state.
5.2.6.3 Region-Peculiar Factors
The Maryland state legislature is in session only three months
of each year. This could impact the response time to develop needed laws
for implementing two-car strategy enforcement and control procedures.
Control in two Maryland regions could be a consideration:
the Baltimore Metropolitan area and the Maryland counties included in the
Metropolitan Washington, D. C. region.
Five percent of through traffic in the Baltimore area is from
out of state. This is not capable of control, but the impact of the new car
fraction on air quality probably could be neglected for a one-year control
program.
5. 2. 7 Massachusetts
Two-car strategy considerations for the state of Massachusetts
are outlined below. This information was obtained in telephone communica-
tions with personnel in the Massachusetts Department of Public Health,
Bureau of Air Quality.
5.2.7.1 Reaction to Two-Car Strategy
A California-only strategy would impact Massachusetts'
implementation plans. The state will just about meet CO air quality stan-
dards by 1977, without additional transportation control strategies, on the
basis that new car emissions conform to 1975 standards. Boston also has
an oxidant problem the solution of which is not yet in sight. A VMT-
reduction approach does not look promising, although traffic management
actions instituted on an episodic or seasonal basis are being considered.
An extension in meeting this requirement may be necessary, regardless
of the resolution of the two-car strategy issue.
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Many problems are foreseen with a regional strategy within
the state. Adverse reactions are to be expected from people in the metro-
politan area because they will need to accept more expensive cars than will
people in the rest of the state.
A Boston-only control region may be subject to question
because similar CO problems exist in the Springfield area. One class of
low-emission cars is preferred to the proposed strategy.
5.2.7.2 Background/Experience Related to Vehicle Control
5.2.7.2.1 Vehicle Registration Control
Yearly registration is mandatory and is accomplished on a
staggered system. Registration may be carried out by mail or by applica-
tion and fee payment at Registry of Motor Vehicle offices.
Proof of insurance (no-fault) via certification provided by the
insurance company is a requirement for.registration. There is a large vari-
ation between rates of different cities and towns. A false address on insur-
ance can invalidate a company's liability. Nevertheless, many Boston students
use home addresses to obtain preferred rates, and other circumventions
probably exist. There is no enforcement of this issue by the state; insur-
ance companies perform only spot checks on the validity of addresses
provided.
5.2.7.2.2 Safety Inspection Program
Massachusetts has a statewide safety inspection program.
The inspection requirement is semi-annual, with deadlines at April 15 and
October 15. The inspection is conducted by private garages for a $1 fee.
The inspection check is coarse. Valid inspections are identified by wind-
shield stickers. Since there is no real control on the issuance of stickers,
however, they are easily obtained.
5.2.7.2.3 Emission Inspection Program
Presently, there is no emission inspection program. The
state's implementation plan proposes an emission inspection/maintenance
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program, with inspection conducted semiannually by stations owned and
operated by the state (Registry of Motor Vehicles), and using a loaded
(dynamometer) emission test. Valid inspection vehicles would be issued
a sticker permitting lawful travel in the state. Enforcement of this pro-
gram would be carried out by state and local police, although no enabling
legislation exists for this program.
5.2.7.2.4 Retrofit Program
There is no retrofit program in Massachusetts, nor is one
planned.
5.2.7.3 Region-Peculiar Factors
The CO problem in Boston is bad only in a limited area. Pro-
posed implementation-plan source controls are expected in time to achieve
compliance with ambient air standards.
An oxidant problem exists in Boston (0.20 ppm compared with
the standard of 0.08 has been measured); however, the incidence of this prob-
lem is low. State implementation plans suggest that episodic or seasonal
traffic-regulation approaches could avert these situations.
5.2.8 Minnesota
State and regional considerations pertaining to the application
of the two-car strategy to Minnesota are summarized below. This informa-
tion is based on information obtained during telephone communications with
the Minnesota Pollution Control Agency, Division of Air Quality Control.
5.2.8.1 Reactions to Two-Car Strategy
The two-car strategy involving California-only control was
considered to be a good idea. They cannot see the purpose of applying rigid
controls to the Minnesota farmland area.
Minnesota would be strongly opposed to a regional strategy
involving Minneapolis. The CO air quality standards are exceeded only in
the downtown area and by only 9. 5 percent. This problem is expected to
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disappear in 1976. Accordingly, the 1974 emission standard would be
acceptable, since the impact of new car controls on Minneapolis air qual-
ity is only 2 to 3 percent. Proposed transportation controls involving VMT
in the Minneapolis central business district could be augmented to offset
this effect.
5.2.8.2 Background/Experience Related to Vehicle Control
5.2.8.2.1 Vehicle Registration Control
Minnesota has yearly registration which is county-based.
Registration identification is not required to be carried in the vehicle or
on the person of the owner.
5.2.8.2.2 Safety Inspection Program
There is no safety inspection program in existence, and no
such program is proposed.
5.2.8.2.3 Emission Inspection Program
Minnesota has no emission inspection program. It would be
impossible to implement such a program within two years.
5.2.8.2.4 Retrofit Program
Minnesota has no retrofit program in force. It is not required
at the present time and no program is planned.
5.2.8.3 Region-Peculiar Factors
The state of Minnesota is largely rural. They see no need
for a stringently controlled regional strategy, particularly one involving a
nonoptimum emission control system.
5.2.9 New Jersey
State and regional considerations pertaining to the two-car
strategy as applied to New Jersey are outlined below. This information,
in part, summarizes a discussion held in Trenton, New Jersey with a
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representative of the Bureau of Air Pollution Control, New Jersey Department
of Environmental Protection. Additional data were extracted from documents
provided at this meeting.
5.2.9.1 Reactions to Two-Car Strategy
New Jersey's major problem areas are Newark and Camden,
but the large population centers are so compacted in this state that only a
statewide control program could be considered feasible as a minimum.
Furthermore, control of New Jersey alone would be difficult, because it is
sandwiched between two extremely large population centers in other states,
New York City and Philadelphia. The bulk of traffic into and through New
Jersey is from these cities. Accordingly, control over a broad interstate
region encompassing New York City and Philadelphia in addition to the State
of New Jersey would be best from the standpoint of achieving a useful air
quality benefit from the control program. However, the possibilities of a
grand cooperative effort between the individual state governments involved
was felt to be remote.
At present, there is no mechanism for controlling out-of-
state registrations by vehicles domiciled in New Jersey. The truck industry,
for example, registers vehicles out of state but uses depots within New
Jersey. The percentage of New Jersey cars so involved is small at the
present time. However, it was felt that this could become a significant
problem if there were a large price differential between the two classes of
1975 cars.
5.2.9.2 Background/Experience Related to Vehicle Control
5.2.9.2.1 Vehicle Registration Control
Yearly vehicle registration is mandatory in New Jersey. A
valid safety inspection is required in order for registration to remain in
force. Yearly registration followed by safety inspection is mandatory in
New Jersey and is tied to the anniversary of car purchase. Registrations
are not identified by county or by other jurisdictional/geographical regions.
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New residents are required by law to register vehicles in
New Jersey within six months of establishing residency. However, there
is no mechanisrn for controlling residents from registering vehicles out of
state. Border residents continue to renew New York and Pennsylvania reg-
istrations because of fee or inspection advantages. This situation is expected
to proliferate if the two classes of 1975 cars have a significant cost
differential.
5.2.9.2.2 Safety Inspection Program
As already mentioned, a yearly safety inspection is required
as a condition for registration in New Jersey. Inspections are staggered
over the calendar year on an anniversary-of-car-purchase basis. Inspec-
tions are conducted in 40 state-owned and operated stations distributed state-
wide. With a total of 69 inspection lanes available for use, motorists can
select any convenient station.
Inspection time is 5. 5 minutes (including a recently instituted
emissions check), though waiting on line for durations up to one hour is not
uncommon. The safety check includes such items as brakes, ball joints,
horns, lights, wipers. A valid inspection is identified by a color-coded and
dated windshield sticker. Failures are identified with a red windshield
sticker, and violations are required to be corrected within two weeks.
Repairs or adjustments can be made at any garage. This has been a source
of criticism for the New Jersey safety and emissions inspection program,
because it has resulted in much faulty or unneeded repair, adjustment, or
replacement work. In this regard, a ping-pong effect has been observed
wherein adjustments made to correct safety problems have resulted in a
repeat of the failure incident or have resulted in new violations. A state
senate investigation of the impact of the program on the motorist is being
conducted.
Enforcement of the inspection program is implemented by
the state police and meter maids on the basis of checking for the windshield
inspection sticker.
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5.2.9.2.3 Emission Inspection Program
New Jersey's emission inspection program was started in
July, 1972. This is the first state to initiate a yearly inspection require-
ment limiting HC and CO for all light vehicles in the resident car popula-
tion. Emission limits have been imposed in three progressive steps becom-
ing effective in 1972, 1974, and 1975. There are different limits for four
vehicle age groups: 1967 model year and older, 1968 and 1969 models, 1970
through 1974 models, and 1975 and newer models.
The emission inspection is carried out concurrently with the
safety inspection. The added test accounts for an additional 30 seconds of
inspection time. Exhaust concentrations of HC and CO are sampled by probe
under idle conditions. A loaded test was at one time considered, but was
rejected for this first-phase program.
Emission standards for each model-year group will become
progressively more severe. At present, the failure rate of the cars tested
is about 10 percent. This will increase to a maximum of about 33 percent
by 1975.
Strict enforcement with rejection and reinspection will begin
in July, 1973. Failure to pass would require the vehicle to undergo a retest
after adjustments or repairs were made. At present, repair or adjustment
following failure is voluntary.
To date, over one million cars have been tested. Eleven
percent have failed the standards at their present level. Forty percent of
the failed vehicles voluntarily repaired failed a second time, due apparently
to inadequate mechanic training. Beginning in July, failure of either emis-
sions or safety aspects of the inspection will be the basis for denying vehi-
cle registration.
5.2.9.2.4 Retrofit Program
New Jersey does not have a retrofit program in force although
the New Jersey transportation control plan incorporates a retrofit strategy.
Initially, this strategy would utilize equipment already certified by the state
of California.
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Statewide control and, preferably, interstate regional control
would be necessary to be effective. Furthermore, all vehicles regularly
operating within state boundaries would have to be equipped if 1975 controls
are to have a beneficial effect on New Jersey's air quality. Enforcement of
controls would take the form of tightening emission-inspection-station stan-
dards. This would be augmented by road checks of vehicle emissions, sim-
ilar to California's Passenger Vehicle Inspection (PVI) program. Pre-
sumably, citations would be issued to nonresident as well as resident vehi-
cles failing to meet New Jersey standards.
5.2.9.3 Region-Peculiar Factors
New Jersey's passenger vehicle registration comprises 3.26
million cars. This number, compacted in a relatively small geographical
area, gives New Jersey the greatest density of autos in the nation. In addi-
tion to the vehicle miles traveled (VMT) by resident cars, an overwhelming
VMT contribution is made by traffic moving into and through New Jersey
from the New York City and Philadelphia metropolitan areas. Of this,
truck traffic dominates.
These factors suggest that an interstate regional control
scheme would be needed for the New Jersey area. Eighty-eight percent of
New Jersey cars, along with much of the traffic that regularly enters from
nut of state, would be accounted for by a control region consisting of the
Metropolitan Philadelphia Interstate and the New Jersey/New York/
Connecticut AQCRs.
5. 2. 10 New York
State and regional considerations pertaining to the two-car
strategy as applied to New York are summarized below. This information
was obtained in discussions held in New York City and Albany with person-
nel from the New York City Bureau of Technical Services (Department of
Air Resources), the New York State Department of Environmental Conserva-
tion (Division of Air Resources), and the New York State Department of Motor
Vehicles (Division of Research and Development).
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5.2.10.1 Reactions to the Two-Car Strategy
The New York City reaction primarily reflected concern over
the severe CO problem which exists in the midtown area of Manhattan and
emphasized the deleterious effect on air quality which would result from
compromising the 1975 exhaust emission goals. Sixty percent of the VMT
in midtown Manhattan are made by taxis (there are 12,000 Medallion taxi-
cabs in the city). Approximately 50 percent of the Medallion cab fleet con-
sist of vehicles only one year old (see Table 5-4) while the overall Manhattan
new-car population comprises 21 percent of the total (see Table 5-5). These
factors translate into a significant CO emissions penalty for the midtown
Manhattan area should 1974 rather than 1975 emission standards be used in
New York's 1975 model-year cars. Thus, the position taken by the New
York City people was that it is imperative that the New York Metropolitan
area be a controlled region. The area of control, it was felt, could practi-
cally be confined to the New York metropolitan and surrounding regions
(New York City, Nassau, Suffolk, Westchester and Rockland counties).
New cars from uncontrolled regions taking residency in New
York was considered to be a potentially significant issue if a program longer
than one year's duration were to be proposed. In this case, a retrofit
requirement might be instituted.
Circulation of nonresident cars into the control region could
also be neglected if the program were to be one year in duration. This posi-
tion was supported by personnel from the State Division of Air Resources.
For a longer program, deterrants such as a city day-use tax, monitored at
the various bridge and tunnel crossings, might be employed. Regardless of
program duration, however, the problems of implementing and administer-
ing the control scheme were anticipated to be enormous, particularly for
the regional control option.
Medallion cabs are those which have purchased a license to cruise the
streets. Non-Medallion cabs are restricted to answering calls for taxi
service.
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Table 5-4. Taxicab Population - Percent by Year
New York City
Age, yr
1
2
3
4
5
6
7
8
9
10 or older
Fleet Medallion
50
45
5
-
-
-
-
-
-
Non-Fleet Medallion
17
31
21
18
7
3
2
0.5
0.3
0.2
Non- Medallion
5
11
17
23
20
10
7
4
2
1
Table 5-5. Percent Passenger Car Population
New York City
Age, yr
1
2
3
4
5
6
7
8
9
10
11
or older
Man-
hattan
21.3
18.9
12.6
8.7
8.2
7.9
6.1
5.4
3.9
2.. 5
4.5
Bronx
10.8
13.8
11.4
9.2
9.9
10.7
9.4
8.5
6.4
3.9
6.0
Brooklyn
10.2
13.1
11.5
9.5
10.5
11.2
9. 1
8. 3
6.1
4.0
6.4
Queens
12.8
14.0
12. 1
9.8
10.4
10.6
8.3
7.4
5.4
3.4
5.8
Rich-
mond
10. 1
13.0
11.5
9.4
10.4
11.0
9.2
8. 1
6.4
4. 1
6.8
Midtown
22.0
23.0
21.0
11.0
8.0
7.0
4.0
2.0
0.8
0.7
0.5
Down-
town
20.0
28.0
17.0
10.0
7.0
3.0
5.0
4.0
3.0
2.0
1.0
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State Department of Environmental Conservation personnel
added the commentary that the regional control scheme would be acceptable
if it were the only practical route toward achieving the 1975 Federal exhaust
emission standards. In addition to New York City, other cities in the state
might also be evaluated as candidates for stringent control. Schenectady's
CO problems were mentioned as one possible area for consideration.
Though the regional strategy appeared to present many admin-
istrative difficulties, it was emphasized that the regional approach made
more sense from the standpoint of cost and effectiveness than statewide
control.
In the opinion of DMV personnel, the mechanics of identifying
cars complying with resident-vehicle emission control requirements would
be simple. For example, it could be accomplished simply by use of a wind-
shield sticker. Such a device is being considered for use in connection with
proposed retrofit programs included in the New York transportation control
strategy. The use of vehicle identification numbers (VINs) to assist in vali-
dating appropriately equipped cars was questioned. It was estimated that
30 percent of DMV files were in error, primarily with respect to the VINs.
5.2.10.2 Background/Experience Related to Vehicle Control
5.2.10.2.1 Vehicle Registration Control
Registration yearly is a requirement in New York, and is
staggered throughout the calendar year, and is implemented by mail invita-
tion from Albany. Registration is not classified by county; however, the
address of record is used as the basis for disbursing tax revenues to the
county level. Applications are processed by local DMV registrars (70 loca-
tions) and the data are transmitted to a central computing and filing facility
in Albany.
The DMV uses the registration address primarily for the
purpose of mailing renewal applications. There is no law that prevents a
person from not identifying the domicile of the vehicle, from giving an
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address that is not his residence, or from giving an address that is not the
operating arena of the vehicle. Rental and state cars, for example, are
frequently registered in one city or county and operated elsewhere.
Preconditions for New York registration include proof of
vehicle safety inspection (both new and used cars), proof of ownership,
proof of insurance, and proof of identity and date of birth. A renewal of a
vehicle previously registered requires proof of insurance and the current
registration stub, which indicates that a valid inspection was performed.
Valid resident registrations are identified by a color-coded, license-tag
sticker containing a printed expiration date. In New York, the registrant
transfers license tags from vehicle to vehicle.
Concerning new cars, New York does not issue temporary
registrations as does, for example, California. The vehicle cannot be
legally driven until registration papers are obtained from the DMV. This
is frequently done by the dealership; however, there is no legal requirement
for the dealer to handle the registration details for the customer.
Out-of-state cars are required to register in New York within
60 days from establishing residency in the state. There is no active pro-
gram to enforce this requirement.
5. 2. 10. 2. 2 Safety Inspection Program
New York's state safety inspection program has been in oper-
ation since 1956. Every motor vehicle registered in the state is required to
be inspected yearly and/or upon transfer of ownership. The inspection is
conducted by 11,000 licensed and state-supervised stations. New York City
alone has 2400 of these official stations.
A certificate of registration which agrees with the vehicle
license plate number and which correctly describes the vehicle to be
inspected must be presented to the station before inspection can proceed.
The safety check encompasses brakes, steering, headlamps, auxiliary
lights, tiros, wipers, windshield and other safety items. The inspection
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fee is $3, part of which is returned to the state for financing a special police
enforcement and inspection group which also investigates alleged malpractices,
On successful completion of the inspection, a color-coded and
dated inspection certificate is issued which is displayed on the windshield. In
the event of an inspection failure, a certificate of rejection is issued and a
certificate of inspection extension is put on the windshield. In this case, cor-
rective action must be taken within 10 days.
Inspection is a condition for registration. In the case of vehi-
cles registering from out of state, a valid inspection certificate from the state
of previous residence is accepted. On expiration of this certificate, the vehi-
cle must be inspected in New York and must bear an official certificate of
inspection from a New York inspection station.
5.2.10.2.3 Emissions Inspection Program
New York does not have an emissions inspection program.
Existing legislation provides for emissions inspection to be added to the
existing safety inspection program as soon as a practical plan has been
defined by the DMV, in consultation with the Commissioner of Environmental
Conservation. This plan has not been promulgated.
New York's transportation control strategy includes the estab-
lishment of an emissions inspection program that would provide for 800 state-
operated or state-franchised inspection stations statewide, 140 of which would
be located in the New York Metropolitan area. Inspection would be required
once a year for passenger cars, twice a year for heavy-duty vehicles, and
three times a year for taxicabs.
5.2.10.2.4 Retrofit Program
There is no retrofit program in force in New York State. The
air quality implementation plan calls for all light duty vehicles registered in
1974 in the Metropolitan Area to be retrofitted with catalytic converters and
air pumps (3. 3 million vehicles). In all other areas of the state, where
necessary, an intake air-bleed system would be installed on all pre-1968
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cars. In addition to light-duty vehicles, retrofit devices for heavy-duty
vehicles are proposed for the New York Metropolitan area.
Emissions inspection is regarded to be a crucial adjunct to
the proposed foregoing retrofit programs. The existing DMV authority for
an inspection program tied to safety inspection is considered inadequate and
must be extended to provide for state-run or franchised inspection stations.
Viewed realistically, the retrofit program is regarded to be
unmanageable in the time period available for its implementation. Accord-
ingly, New York may request an extension for meeting the oxidant standard.
5.2.10.3 Region-Peculiar Factors
Of the 6. 1 million passenger cars registered in New York
State; 1.6 million are registered in New York City; and 3.3 million vehicles,
or over 50 percent, are registered in New York City Metropolitan area con-
sisting of New York City and the surrounding counties of Nassau, Suffolk,
Westchester and Rockland. About half of the total car population in the New
York/New Jersey control region are contained in the New York City area.
As previously stated, the Manhattan problem is CO, particu-
larly in the Midtown area. A large percentage of the Manhattan car popu-
lation consists of new vehicles (21 percent). Manhattan Medallion taxicabs,
which account for 60 percent of the downtown/midtown vehicle miles traveled
(VMT) and 40 percent of the CO emissions, contain a very high fraction of
new cars (50 percent of fleet and 17 percent of nonfleet Medallion taxis are
one year old or newer). For this reason, an extension of 1974 standards in
the New York area would have a serious impact on expected improvements
in overall ambient CO levels.
About 4.6 percent of New York City registrations, or 75,000
cars per day, enter the city from outside the metropolitan area. With regard
to the Manhattan CO problem, the uncontrolled new-car fraction of this
influx would have a negligible effect, considering that only 15 percent of
the midtown VMT is contributed by passenger cars.
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New York's oxidant problem is bad citywide. HC is 20 to 50
times the level needed to achieve Federal oxidant standards. These prob-
ably will not be met in 1975, because proposed transportation control strat-
egies targeted toward this problem (e.g. , retrofit) cannot be implemented
in the time available. Therefore, it appears that the issue of uncontrolled
new cars entering New York may be academic insofar as it determines
whether or not 1975 air quality goals are met for either HC or CO.
5.2. 11 Oregon
State and regional considerations pertaining to the two-car
strategy for the state of Oregon are highlighted below. This information
was obtained in interviews conducted at Portland and Salem with personnel
from the Oregon Department of Environmental Quality (Air Quality Control
Division) and from the Oregon Motor Vehicle Division (Administrative Serv-
ices and Traffic Safety Programs).
5.2.11.1 Reactions to the Two-Car Strategy
From the standpoint of both popular reaction and control
enforcement, Oregon would rather adopt statewide than regional automo-
bile emissions controls. On the other hand, downtown Portland is the only
area within Oregon requiring automobile emissions control to meet air qual-
ity standards. A rollback of 25 percent in oxidants and carbon monoxide is
needed to satisfy secondary requirements. Oxides of nitrogen are not a
problem.
The EPA has defined five air basins in Oregon: Portland,
Northwest, Southwest, Central, and Eastern. The Portland air basin is
interstate and contains the Washington State counties of Clark, Scamania,
Cowlitz, Lewis, and Wahkiakum. Oregon prefers to divide the state into
14 administrative regions that are more closely related to air pollution
sources. For example, the Portland air basin contains 3 administrative
divisions of which only the Columbia/Williamette air region (Portland) would
be significant in a two-car strategy. In fact, all studies have shown that
5-45
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control of vehicle emissions are needed only in 3 counties: Multnomah,
Washington, and Clackamas. They contain 40 percent of the state vehicle
registrations. Road surveys have shown that 85 percent of the Portland city
traffic originates within these 3 counties.
Enforcement of the control strategy could be implemented
statewide by the process of demanding compliance prior to issuing or renew-
ing license plates. However, regional controls would be very difficult to
police within the existing framework of state laws and regulations. Devel-
opment of new legislation for this purpose is unlikely within the time remain-
ing until 1975. Also, some public support is bound to be lost if only some
regions are selected for stiffer automobile emission standards (Portland had
a very poor experience with an automobile safety inspection program that
had been restricted to metropolitan Portland only). However, implementa-
tion of a 3-county mandatory plan would generate less overall resistance
than a control program for the entire Portland basin, which contains 10
counties that are mostly rural. A decision to control the entire state or
only some counties is likely to be a political one and would be hotly debated
by the legislature.
Any automobile emissions control scheme that would be expen-
sive for local residents runs the risk of being foiled by the simple expendency
of buying the car in an uncontrolled area. Distances between Portland and
rural areas are very short. There are no existing laws in Oregon which
would forbid a dealer in an uncontrolled region to sell a car to a resident
of a controlled region. Nor can a dealer be forced to check the residence
of a customer or to add emission control devices without the expressed con-
sent of the customer. Such laws are unlikely to be favored by the legisla-
ture. In addition, it would be perfectly legal to establish residence in an
uncontrolled area by the expediency of renting a mailbox address.
One-year implementation of a two-car strategy would have
little impact on Oregon's air quality. In 1972, there were 1,361,203 pas-
senger cars registered in Oregon, of which only 105,000 passenger cars
were new. This is less than 8 percent of the state's total passenger car
population.
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5.2.11.2 Background/Experience Related to Vehicle Control
5.2.11.2.1 Vehicle Registration Control
Yearly automobile registration is mandatory in Oregon. The
registration process and statistics are computerized and are handled by the
Motor Vehicle Division at Salem. The workload is evenly distributed by the
use of a monthly, staggered statewide registration process. Residence
location is entered in the computer by zip code, rather than by county,
because it has been found that, although zip codes are not quite in agree-
ment with county lines, they result in much fewer errors than the use of
the declared county of residence. People know their zip code better than
they know the county in which they reside. The county is the smallest polit-
ical entity under statistical control.
No efforts are being made to verify residence information.
It is felt that the "benefit" to be derived from license application verifica-
tions does not warrant the required added cost. In case of regional auto-
mobile emission controls, the added load of residence verification could
not be handled with present personnel and budget. It is perfectly legal in
Oregon to use a business address or a postal box number on the license
renewal application. This address need not agree with the address on the
driver's license, and new residents need not register their car until their
out-of-state registration expires. There were 103, 311 new-to-Oregon pas-
senger cars registered in 1962; a used car is defined as a car previously
licensed.
5.2.11.2.2 Safety Inspection Program
There is no safety inspection program in Oregon.
5.2. 11.2.3 Emission Inspection Program
There is no emissions inspection program in force. The
Department of Environmental Quality has the authority to set emission stan-
dards and to implement an inspection program, but it has no money to carry
5-47
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out this program. The budget is being debated in the legislature, and there
is little likelihood that funds would be allocated this session.
State plans call for a state-controlled emission inspection
program. This inspection would be required in order to obtain a certificate
of compliance and complete the license renewal. Thus, the inspections
would be staggered over the calendar year. The emission tests would be
based on the key-mode test cycle. The fee would range between $5 and
$7. 50. The proposed effectivity of the program is 1 January 1974, with
mandatory repairs starting 1 January 1975. The minimum permissible
emission standards will be based on 1974 calendar year inspection results
and on a rejection rate not yet determined.
Although only a 3-county inspection program is justifiable, it
might be easier to implement a statewide program. To this effect, 25 inspec-
tion facilities, run by the Oregon Motor Vehicles Division, would be distrib-
uted over the state of which 6 would have 2 lanes, 19 would have 1 lane, and
4 would be mobile installations. It is planned that the inspection facilities
will be Installed on abandoned gas station sites. Repairs would not be han-
dled by inspection facilities but could be done anywhere. Retest of vehicles
would be handled free of charge.
Public lobbying has been against mandatory automobile main-
.tenance as opposed to mandatory inspection and in favor of state-run inspec-
tion facilities.
5.2.11.2.4 Retrofit Program
Nothing has been decided on retrofit kits for used cars. The
California retrofit program will be watched closely, but it is felt that none
of the existing devices justify enough confidence to proceed with a mandatory
retrofit program at this time.
The Oregon legislature does not appear receptive to a manda-
tory "add-on" for used cars. It is believed that car maintenance to factory
specifications would suffice to meet the objectives of the Oregon implementa-
tion plans.
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A complication concerning regional control would be the sale
of used cars from uncontrolled regions into controlled regions. The ques-
tion is whether these cars should be retrofitted to the standard of the con-
trolled region. Enabling legislation would be very difficult to obtain.
5.2.11.3 Region-Peculiar Factors
Oregon is largely rural, with only metropolitan Portland
requiring abatement of automobile emissions. Traffic surveys have shown
that 85 percent of the downtown Portland traffic originates within the three
adjacent counties. The Federal Portland basin comprises 10 Oregon coun-
ties and 5 Washington counties, of which only three contribute significantly
to Portland's air pollution from mobile sources.
There were 1, 361 , 203 passenger cars registered in Oregon
in 1972. The distribution of cars in the Portland region is shown in Table 5-6.
Surveys have shown that only 6 percent of the downtown Portland traffic
originates in the five Washington counties included in the AQCR.
Table 5-6. Portland Region Car Population Distribution
Counties
Clackamas
Multnomah
Washington
Columbia
Marion
Polk
Yam Hill
Benton
Lincoln
Linn
Portland Air
Region (Oregon)
Passenger Car
Registrations
11,508
329,017
105,086
19,633
95,886
21, 342
26,722
28, 103
17,309
47,744
802,350
(1972)
Administrative
State Regions
District 2
565,244
District 3
Percent
of State
41.53
143,950
District 4
93, 156
802, 350
10.
6.
58.
58
84
94
5-49
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5.2.12 Pennsylvania
State and regional considerations pertaining to the two-car
strategy for the State of Pennsylvania are summarized below. The informa-
tion given was obtained in interviews conducted in Harrisburg, Pennsylvania
with personnel from the Pennsylvania Department of Environmental Resources
(Division of Air Resources) and the Department of Transportation (Bureaus
of Traffic Safety and Motor Vehicles).
5.2.12.1 Reactions to the Two-Car Strategy
In general, neither the California-only nor the California-plus
strategy options were acceptable to Pennsylvania. The California-only strat-
egy was rejected because of the impact that 1974-level new car emissions
would have on Pennsylvania's air quality implementation plans. In this
regard, there are two major metropolitan areas of concern, Pittsburgh and
Philadelphia. These two metropolitan areas account for 50 percent of the
state's automobile population. Presently planned transportation controls
needed to meet air quality goals in these areas call for extension additions
to or modifications of mass transit facilities to reduce vehicle miles trav-
eled (VMT) in the central business districts. These include extension of
the subway system in Philadelphia, dedicated freeway/highway bus lanes in
both cities, and a new rapid transit system in Pittsburgh.
The automobile VMT reductions needed in 1975, primarily to
meet the CO ambient air quality standard, are 30 percent for Pittsburgh and
50 percent for Philadelphia. Plans to institute disincentives for automobile
travel in the central business districts include parking bans, restrictive
parking rates, and restrictive tolls on bridges in the Philadelphia area.
These VMT reductions are predicated on having new cars in the automobile
population that are controlled to 1975 emission standards. On any other
basis, the percentage of VMT reductions needed to meet air quality goals
would increase. The present reduction requirements are considered dif-
ficult, if not impossible, to attain by 1975.
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With regard to regional control of the Pittsburgh and
Philadelphia areas, the reactions were wholly unfavorable because of the
problems foreseen in developing the necessary state legislation and in
administering the program on a local basis. Surveilling and enforcing the
sale of properly equipped vehicles to residents in the regions of control was
regarded to be impossible to deal with. Statewide control was felt to be a
more satisfactory approach, although from the standpoint of achieving
desired air quality goals, it would be necessary to extend the region of con-
trol to encompass five New Jersey counties in the Metropolitan Philadelphia
Interstate air-quality-control region. This would help in reducing the total
VMT by less-stringently controlled cars from typical out-of-state sources.
5.2.12.2 Background/Experience Related to Vehicle Control
5.2.12.2.1 Vehicle Registration Control
Yearly registration is mandatory in Pennsylvania. The reg-
istration process is wholly handled by the Bureau of Motor Vehicles (BMV)
facility in Harrisburg, which processes all registration applications by
direct mailing. There is no jurisdictional breakdown of registrations below
the state level. Any valid address within the state may be submitted for
registration purposes, regardless of where the vehicle is domiciled or
operated. This address is used solely for mailing and law enforcement
purposes. There are no BMV data which permit automobile population dis-
tribution within the state to be determined. Where required, these data
have been estimated on the basis of population statistics. There are no local
BMV offices except for temporary facilities recently established in a pilot
program designed to test the handling of peak registration mailings, which
occur as the March 31 registration deadline is approached.
Registration is not tied to Pennsylvania's existing safety
inspection program; valid inspection is not a requirement for registration
(the Bureau of Motor Vehicles and the Bureau of Traffic Safety operate inde-
pendent programs). Renewal registrations are identified by color-coded
license plate stickers. Pennsylvania transfers license plates from vehicle
to vehicle.
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Out of state vehicles are required to register within 30 days
of establishing residency in the state. There is no overt program to enforce
this requirement. It is not legal to register out of the state while residing
in the state. However, Pennsylvania permits the renewal of registration by
residents living out of state.
5.2.12.2.2 Safety Inspection Program
Pennsylvania's safety inspection program has been in opera-
tion for about 20 years. The inspections are conducted by 17,000 privately
owned, state-licensed stations, representing a major portion of Pennsylvania's
garage facilities.
Safety inspection is required twice a year. The safety check
appears to be quite comprehensive. A complete check takes about 45 min-
utes. There is no legal limit on the fee charged; this is normally regulated
by competitive pressures to about $5.
Vehicles passing the safety inspection are issued color-coded
and date-limited windshield inspection stickers. Safety deficiencies may
be corrected anywhere; inspection is repeated until the vehicle passes
inspection.
Inspection station operations are monitored by the state police
through the mechanism of unscheduled inspection checks made twice yearly.
The penalty for malpractice is $200 for each violation in addition to possible
loss of certification status. Mechanics are required to undergo recertifica-
tion training and to qualify for recertification by test every 3 years. Penn-
sylvania is attempting to upgrade their mechanics in anticipation of contin-
uing growth in the complexity and number of vehicle systems impacting
safety. The task is a massive one because of the large number of personnel
involved. Certified mechanics in Pennsylvania number 80,000.
5.2.12.2.3 Emission Inspection Program
Pennsylvania does not have an emission inspection program
at this time. A number of emission inspection alternative were examined
5-52
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as part of the overall state transportation control strategy. Of these, the
most cost-effective approach was determined to be a state-operated program
limited to the Philadelphia and Pittsburgh areas. The inspection scheme
under consideration consists of an engine parameter check, involving plugs,
timing, idle RPM, and possibly CO emissions.
Some pressure against a state-operated system is expected
to be exerted by the operators of the many existing safety inspection sta-
tions, in view of the fact that existing legislation empowers the state to
institute an emissions inspection program tied to the existing safety inspec-
tion program. However, the feeling is that emissions should be separated
from safety and should be conducted and controlled by the state to avoid the
proliferation of unnecessary repair and parts replacement incidents. At the
present time, there is no authority empowering the state to establish state-
operated facilities or to geographically circumscribe an emissions inspec-
tion program.
With regard to existing legislation, an act passed by the
Pennsylvania General Assembly provides for a statewide, semiannual,
control-device inspection program which would be tied to the existing safety
inspection operation. A definitive plan and schedule for implementing this
program was to have been defined by the State Secretary of Transportation.
At present there are no vehicle code regulations pertaining to this plan, and
no deadline for developing these regulations has been selected.
5.2.12.2.4 Retrofit Program
Pennsylvania does not have a retrofit program. Retrofit was
considered as a strategy for the state's transportation control plan, but it
was rejected because the anticipated technical difficulties in implementing
the program were regarded to be insurmountable and because legislation
needed to promulgate and successfully sustain a retrofit program was not
available.
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5.Z.12.3 Region-Peculiar Factors
The following region-peculiar factors apply to the Pennsylvania
situation:
a. The automobile population is about 5. 3 million cars,
b. 50 percent of all automobiles in the state are located in two
metropolitan areas, Philadelphia and Pittsburgh,
c. 95 percent of the VMT in the Pittsburgh metropolitan area
and in the Philadelphia Interstate Region are made by vehi-
cles domiciled in these areas,
d. Philadelphia receives a large percentage of its traffic from
nearby population centers in New Jersey.
The high concentration of automobiles in the two population
centers supports the contention that 1975 new-car emission levels would
have an impact on air quality in these areas. Nevertheless, this problem
may be overshadowed by local CO emission concentrations created largely
by adverse traffic conditions in the central business districts of these
metropolitan areas. The proximity of Philadelphia to population centers
in neighboring states suggests that an interstate control region encompass-
ing possibly the State of New Jersey along with Philadelphia and the Metro-
politan New York area would be required, if the air quality benefits from
1975 emission-level cars are to be realized.
5. 2. 13 Texas
The state and regional considerations regarding the two-car
strategy in Texas were reviewed with representatives of the Texas Air Con-
trol Board; the Texas Air Pollution Service, Texas Health Department; the
Texas Department of Public Safety; the Texas Highway Department; and a
representative of the New Car Dealers Association, in Austin, Texas.
The state of Texas has a total of 12 AQCRs. The designated
regions for the purposes of this study are: the Houston-Galveston area and
the southern Louisiana/southeast Texas interstate area, which includes 15
Texas counties and 39 parishes in Louisiana.
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5. 1. {'*>. \ Reactions to the Two-Car Strategy
II was indicated l.hal. both the Tlouston/Galvcston and southeast
Texari/southern Louisiana air basins are predominantly stationary source
problem areas. Because of the severe FIG problem, however, existing air
quality implementation plans would be compromised if emission inventories
could not take advantage of 1975 automobile emission levels.
It was further stated that a one-year delay in the introduction
of the 1975 emission standards might require the implementation of both
mandatory inspection /ma i ntenance and retrofit programs. However, since
specific enabling legislation would have to be passed to fully implement such
plans, serious doubts were expressed regarding the availability of sufficient
lead time to meet the 1975 or 1977 air quality standards.
The opinion was also expressed that since a two-car strategy
would slip their air quality control program, there should be a parallel
relaxing of the air quality standards.
5.2. 1 3. 2 Background/Experience Related to Vehicle Control
5.2. 13.2. 1 Vehicle Registration Control
Yearly vehicle registration is mandatory in Texas, but it is
primarily a tax collection process with no special means for enforcement.
Registration is not tied in to Texas' existing safety inspec-
tion program; valid inspection is not a requirement for registration.
Any changes in the vehicle identification number (VIN) for the
purpose of aiding vehicle identification in the event a two-car strategy is
introduced would require the Department of Motor Vehicles' computer soft-
ware changes (which might be possible) as well as additional personnel (and
dollars) for enforcement where none is budgeted at the present time.
No registration controls are imposed on the sale of either
new or used cars with regard to emissions controls.
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5.2.13.2.2 Safety Inspection Program
The Texas Safety inspection program has been in operation
since 1951. The inspections are conducted by privately owned, state-
licensed stations under the administration of the Department of Public
Safety. This inspection is not tied to vehicle registration.
The safety inspection is conducted annually on a staggered
basis and includes a visual inspection to ensure that the original emissions
control equipment has not been removed or altered. No emission tests are
conducted.
5.2.13.2.3 Emissions Inspection Programs
No emissions inspection program is in effect in Texas at the
present time. Federal law provisions constitute the only control on new car
sales. With regard to new car sales, it was pointed out that there are many
interdealer exchanges within the state prior to the first sale, which could
impact the regional approach to the two-car strategy.
A similar situation exists with regard to used cars, where
major wholesaling occurs .both within and out-of-state, depending on specific
demands at a given time. No used-car emission controls exist at the present
time, although, as pointed out above, the state safety inspection program
does include a visual inspection to ensure that the original emission control
equipment has not been removed or altered.
House bill 238, currently in committee, would provide for
studies only to be made of candidate mandatory inspection/maintenance pro-
grams. The state view is generally negative toward such programs.
The legal authority for inspection and testing exists in sec-
tion 3. 10(d) of the Texas Clean Air Act, although further legislation would
be required to fully implement such a plan.
5.2.13.2.4 Retrofit Program
No retrofit programs are in existence or contemplated in
Texas. Although legal authority for retrofit is contained in the Texas Clean
Air Act, no enabling legislation has been passed.
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5.2.13.3 Region-Peculiar Factors
Approximately 4.6 million passenger cars were in operation
in Texas as of 1 July 1972. Approximately 20 percent are located in the
Houston AQCR while 4.6 percent are located in the Texas portion of the
Texas/Louisiana AQCR.
The state of Texas has reciprocity agreements with border-
ing states which allow out-of-state car owners domiciled within a certain
number of miles of Texas to work and drive in Texas without registering or
licensing; similar rights exist for Texas residents in bordering states.
The entire state was reported to have an HC problem. Pre-
dominantly stationary source problem areas include the Houston-Galveston
area (18 percent due to autos), the southeast Texas/southern Louisiana area
(5 percent due to autos), and the Corpus Christi area. Mobile source prob-
lem areas were reported to include Austin/Waco; Dallas/Ft. Worth; San
Antonio/El Paso.
5.2.14 Utah
State and regional considerations pertaining to the state of
Utah were discussed via telephone communication with representatives of
the Air Quality Section of the Utah State Division of Health.
The Salt Lake City Air Quality Control Region is composed
of five counties: Davis, Morgan, Salt Lake, Tooele and Utah. Weber
county, situated immediately north of Salt Lake County, is not within the
AQCR, but it was also reported to have a mobile-source pollution problem
of greater magnitude than in sparsely populated Tooele and Morgan counties
within the AQCR. Those counties within the AQCR constitute about 68 per-
cent of the state population, while Davis, Salt Lake, Utah, and Weber coun-
ties were reported to include 80 percent of the state population.
5.2.14.1 Reactions to the Two-Car Strategy
The California-only, two-car strategy option was acceptable
to Utah since this option was expected to have a minimal effect on air quality.
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Conversely, however, they did not feel that the California-plus option was
acceptable. The reasons for rejecting the idea of a regional approach were
based on the fact that the people of Utah were not too excited about automo-
tive pollution problems, with the result that adverse reactions could be
expected if the Salt Lake City AQCR was included in the regional two-car
strategy.
Also, the auto pollution problem is one of CO in the six-square
mile area of the central business district of Salt Lake City. They have
examined a type of two-car strategy for this area and concluded that it would
be impossible to administer.
In addition, further problems were anticipated if Weber
County (not in the AQCR), having a higher auto pollution than Tooele County
(within the Salt Lake City AQCR), was allowed higher emitting automobiles.
5.2.14.2 Background/Experience Related to Vehicle Control
5.2.14.2.1 Vehicle Registration Control
Yearly registration is mandatory in Utah. Vehicle registra-
tions are identified by both county and community, although they have no way
to keep track of the cars once they are registered.
Registrations are not tied to Utah's existing safety inspection
program; valid inspection is not a requirement for registration.
5.2.14.2.2 Safety Inspection Program
Utah's safety inspection program has been in operation for
about 35 years. The inspections are conducted by privately owned, state-
certified inspection stations and are administered by the Highway Department.
The safety inspection is required annually on a staggered basis
as a function of the last digit of the license plate. The fee is $3.25, of which
$0.25 goes to the state.
As previously pointed out, a valid safety inspection is not a
requirement for registration. Proof of ownership is required, however,
as a part of the safety inspection.
5-58
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5.2.14.2.3 Emissions Inspection Program
No emissions inspection program is in effect in Utah at the
present time. Enabling legislation was passed by the state legislature at
the last session, but no specific plans have been made.
A visible emissions monitoring program is being conducted
by the Air Quality section (rather than the enforcement agencies). This
program, conducted on a low level of effort basis, is directed primarily
toward trucks in an attempt to get corrective action.
5.2.14.2.4 Retrofit Program
Utah has no retrofit program in effect at the present time,
although plans for such a program are contained in the state implementa-
tion plan. If instituted, the program could be accomplished within the
framework of the emissions inspection legislation.
The primary goal of any retrofit program was reported to be
directed toward the reduction of CO for 1966/74 model year cars.
5.2.14.3 Region-Peculiar Factors
Utah has a small population (approximately 1,000,000) which
is concentrated in a few areas. Thus, a large area of the state is essenti-
ally unpopulated, including Morgan and Tooele counties within the AQCR.
The only air pollution problem in Morgan county was reported
to be from a cement plant.
The only problem present in Tooele county arises from the
fact that many people live in Salt Lake City who work at Dugway Proving
Ground in Tooele County.
5.2.15 Washington State
Information on the state and regional considerations pertain-
ing to the two-car strategy for the state of Washington was obtained via tele-
phone contact with the State Department of Ecology, Technical Assistance
Division.
5-59
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The state of Washington encompasses allor portions of three
AQCRs covered in this report. Four counties comprise the Seattle region;
seven counties in Washington together with five in Idaho make up the Spokane
AQCR; and five Washington counties are included in the Portland, Oregon
AQCR. The Seattle region contains approximately 56 percent of the pas-
senger cars in the state. The Washington portions of the Spokane and Port-
land regions contain 12 percent and 8 percent of the cars, respectively.
5. Z.15.1 Reactions to the Two-Car Strategy
In general, neither the California-only nor the California-plus
strategy options were acceptable to Washington. The California-only strat-
egy would impact their air quality program, since the automotive pollution
problem is primarily one of reducing CO in the central business districts of
Seattle (55 percent reduction) and Spokane (48 percent reduction). The extent
of the reduction is predicated upon the 1975 emission inventories from auto-
mobiles and must be increased by some other means should the 1975 stan-
dards be relaxed.
With regard to the regional approach, they have examined
various control strategies for King County (Seattle) and Spokane County
(Spokane) only, since the political climate is generally unfavorable for
special controls in the other counties of the state. They did feel that Seattle
and Spokane must have common controls.
5.2.15.2 Background/Experience Related to Vehicle Control
5.2.15.2.1 Vehicle Registration Control
Yearly registration is mandatory in Washington. Registra-
tions are identified by county, although the state does not have any follow-up
program to verify that the vehicle is actually domiciled at the address of
registration.
5-60
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5. 2.15. 2. Z Safety Inspection Program
The state of Washington discontinued their safety inspection
program approximately 20 years ago. Current feelings are negative toward
restoring such a program.
5.2.15.2.3 Emissions Inspection Program
Washington does not have an emissions inspection program
at present, although a bill is pending to implement one. This bill, however,
would call for inspection in King (Seattle) and Spokane (Spokane) counties
only. The question on whether this program would be privately or state -
operated is still open.
5.2.15.2.4 Retrofit Program
No retrofit program is in effect in Washington. It was further
indicated that the state legislature is not willing to introduce any retrofit
legislation.
5.2.15.3 Region Peculiar Factors
As previously pointed out, a 55 percent reduction in CO is
required in Seattle and a 48 percent reduction is required in Spokane.
Because of strong reactions against control in the rural areas and counties
other than those containing Seattle and Spokane, the legislature was said to
be unlikely to vote for rigid controls outside of these two counties.
It was also pointed out that many non-Seattle residents buy
cars in Seattle because of lower prices. The introduction of a regional two-
car strategy could impact both marketing trends and regional control
problems.
5-61
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SECTION 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 that have
not as yet been made. The following sections discuss possible differences
between the two types of cars and their likely effects on the vehicle user.
6. 1 TWO-CAR HARDWARE AND COST DIFFERENCES
If 1975 Federal standards are to be met in the controlled
region, the new 1975 low-emission car will require as a minimum some
kind of catalyst 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, cylinder head, and ignition system may be
either physically different or have different permanent settings or calibra-
tions. 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 system selected. Conversely, a requirement that
retrofit be technically and economically feasible could affect catalyst emis-
sion 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 se, 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, and also on the car pricing policies
followed by the auto companies. Several pricing policies are possible,
including:
a. Low-emission car sold at full cost of emission control
system differences
b. Cost increases distributed over all cars
6-1
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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 NOX level and therefore about the same fuel consumption charac-
teristics. Also, basic maintenance costs should be similar for both vehicles
in terms of tuneups, etc. However, the reliability of catalyst systems is of
great concern and is one of the main reasons auto firms support strategies
that will permit a "pilot" program prior to nationwide use. While consumers
would 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 service and repair.
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, they may be required to retrofit
or sell their car. Whether this situation will, in fact, occur is dependent
upon the final regulations generated for controlling the area of new car sales
and regulations for used cars in the control region. Since annual migration
of cars into possible control regions is normally a small fraction (<5 percent
of the total number of cars within the region, forced sale or modification of
the higher-emission cars may be an unreasonable requirement.
6-2
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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 new 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 in value of the
catalyst system. Normally, fleet and lease cars are sold wherever there
is a market, and many times they are sold outside the area in which they
initially operated.
6.5 IMPACT OF REGISTRATION REQUIREMENTS
Generally no impact is foreseen unless inspection and/or
maintenance or retrofit is required as a prerequisite 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 the low-emission car, some owners may purchase, regis-
ter, and/or license higher-emission cars out of the state or out of the control
region, then bring such a car into the control region as a used car.
6-3
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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:
If the policy is not effectively enforced and the costs are
high, many owners would be encouraged to violate the laws
requiring retrofit.
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 could be a new car or even a pre-
1975 used car. Used cars might be particularly interesting
if they could be operated without installation of additional
emissions control devices.
If the ability to retrofit a higher-emission car is a requirement
levied on the auto makers, the initial cost of such cars might
be increased to cover the costs of retrofit for those cars poten-
tially 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 may be encountered by owners of low-emission
cars in areas outside the controlled region in obtaining replacement parts
(24-hour delays likely). In addition, service in such areas from mechanics
with little experience with catalyst systems may be of poor quality.
According to the auto companies contacted, parts and service
within controlled regions should offer no problems.
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 system. Present Federal regulations call for
unleaded gasoline to be available throughout the nation by July 1974.
6-4
-------
However, 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 would not
generally be available outside of controlled regions, several approaches
would be possible:
a. The catalyst system could be designed with a bypass that
would be adjusted for use prior to a trip outside the controlled
region and closed upon return to the region. To avoid wide-
spread use of the bypass within the controlled region, device
adjustments and legal approvals by the state or local regional
control authorities would likely be required.
b. For short periods of time, leaded gasoline may not perma-
nently degrade catalyst materials; therefore, in emergency
situations use of such gasoline may be allowed. However, the
extent of catalyst degradation would be unknown unless a test-
ing and inspection program for such cars were established.
c. For the few trips that most people would make outside of con-
trolled regions, the use of higher-emitting rental cars may be
desirable, and perhaps should be encouraged. In a number of
situations, such rental cars could provide better service at
lower cost than using the low-emission family car with a cata-
lyst that requires unleaded gasoline and special parts and
service.
6.9 SUMMARY
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 car models, unless specific policies are implemented
to ameliorate these burdens. Policies that would lessen the difference
between initial cost of the vehicles and the cost to retrofit higher-emission
cars that move into controlled regions on a permanent basis would help the
cost and resale problems of low-emission cars.
6-5
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SECTION 7
COROLLARY ISSUES
7. 1 IMPACT ON USED CAR INDUSTRY
The effect on the used car industry would be determined largely
by the differential between the initial price of high- and low-emission cars
and the cost involved should retrofit 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
initial purchase or traded between similar regions. There
would be little incentive for selling low-emission cars outside
control regions, because the extra initial cost of their cata-
lyst system would be lost on such sales, while the retrofit
requirement would likely increase the initially lower cost of
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. It may be diffi-
cult to resell low-emission cars unless the extra cost of their
catalyst system is absorbed as a loss.
c. If cost differences between cars are small and retrofit is
required, higher-emission cars would be pretty much
restricted to sales outside of controlled regions. The cost
of retrofitting such cars for sales in controlled regions would
make them more costly than low-emission cars.
d. If cost differences between cars is small and retrofit is not
required, migration of low- and higher-emission cars would
be pretty much as it is today for used cars, with customer
preference determining the movement of cars.
7.2 IMPACT ON REPLACEMENT PARTS INDUSTRY
It is expected that initially there would be no impact, with
dealers providing parts from auto makers and original-equipment suppliers.
However, if, over a period of time, low-emission cars require a high volume
of replacement parts to maintain proper operation, new suppliers may enter
the market.
7-1
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SECTION 8
APPENDIXES
8-i
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APPENDIX A
COMPANY/AGENCY VISITS AND CONTACTS
Date of Visit
Company/Agency
Name
Personnel Contacted
7 March 1973
American Motors
(meeting and
letter reply)
R. A. Peterson--Director,
Advanced Power Plants and
Research Engineering
D. L. Hittler--Manager, Emission
Development
27 March 1973
Chrysler
(telecon)
Mr. S. L. Terry - Vice President
Office of Public Responsibility
Environmental and Safety
Relations
8 March 1973
Ford Motor
Company
(meeting and
letter reply)
J. U. Damian- -Manager, Vehicle
Noise Programs
G. H. Anderson--Section
Supervisor, Emissions Control
Dept.
C. B. Kirkpatrick--Systems
Planning and Development Dept.
D. Manly--Sales
M. Lynch--Sales
D. Melville
9 March 1973
General Motors
Corporation
(meeting and
letter reply)
E. E. Nelson--Assistant Director,
Automotive Emission Control
E. C. Henricks--Service Section
D. Burnette--Emissions Reliability
and Manufacturing, Buick Division
27 March 1973
International
Harvester
(telecon only)
Mark Sherbinsky
29 March 1973
American
Honda Motor
Co., Inc. (letter
reply on market-
ing aspects only).
J. M. Murray, Automobile Sales
Manager
A-l
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Date of Visit
Company/Agency
Name
Personnel Contacted
6 April 1973
Mercedes Benz of
North America,
Inc. (telecon and
letter reply)
K. H. Faber, Engineering Planning
Manager
Bernard Steinhoff
26 March 1973
Nissan Motors
(meeting at
Aerospace Corp.)
Hiroyuki Maruoka, Engineering
Representative, Nissan Motor
Co., Ltd.
30 March 1973
Toyota Motor
Sales, U.S.A.,
Inc. (telecon
and letter reply)
Dan N. Koda, Executive Assistant,
Service
2 April 1973
Volkswagen of
America
(telecon only)
Hans Weisbarth, Manager,
Emissions and Development
6 March 1973
Motor Vehicle
Manufacturers
Ass'n. (meeting)
Mr. Rowe
Mr. Fry
6 March 1973
R. L. Polk Co.
(meeting and
correspondence)
Mrs. Ellen Huber, Account
Executive
27 and 28
March 1973
Alaska, Depart-
ment of
Environmental
Conservation
(telecon and data)
Thomas R. Hanna, Supervisor, Air
Quality Control Division
Tim Gilmore, Engineer, Air Quality
Control Division
James Anderegg
20 March 1973
Arizona, Depart-
ment of Health
Arizona, Highway
Department
(meeting and data)
Arthur Aymar, Director, Division
of Air Pollution Control
R. Bruce Scott, Chief, Service
Evaluation Section
R. Campbell, Superintendent
Phil Thorneycroft, Deputy
Superintendent
Ray Johnson, Staff, Planning
Survey Division
A-2
-------
Date of Visit
Company/agency
Name
Personnel Contacted
16 March 1973
California, Air
Resources Board
(Sacramento)
California, Dept.
of Motor Vehicles
California,
Highway Patrol
John Maga, Executive Officer
William Simmons, Legal Council
Elmer Brown, Registrar, Division
of Registration
Quinton E. Peters, Staff, Division
of Registration
Capt. W. A. Fradenburg,
Commercial Vehicles Section,
Headquarters
13 March 1973
California Air
Resources Board
(El Monte)
G. C. Hass, Chief of Vehicles
Emissions Control
16 March 1973
California -
Department of
Finance
(meeting and data)
I. Hambright
21 March 1973
Colorado, Air
Pollution Control
Division
Colorado, Motor
Vehicle Division
(meetings and
data)
Don Sorrels, Chief, Technical
Services and Evaluation Section
Richard Love, Head, Motor Vehicle
Safety Inspection
28 March 1973
Maryland, State
Department of
Health and Mental
Hygiene, Bureau
of Air Quality
Control
(telecon and data)
Donald Andrew, Chief, Mobile
Source Section
A-3
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Date of Visit
Company/Agency
Name
Personnel Contacted
28 March 1973
Massachusetts,
Department of
Public Health
(telecon)
Gilbert T. Joly, Director, Bureau
of Air Quality
Bill Cass
29 March 1973
Minnesota,
Pollution Control
Agency (telecon
and data)
Dr. John Olin, Deputy Director,
Air Quality Division
22 March 1973
New Jersey,
Department of
Environmental
Protection
(meeting and data)
John Elston, Staff, Bureau of Air
Pollution Control
23 March 1973
New York City,
Bureau of Tech-
nical Services,
Department of
Air Resources
New York State,
Department of
Environmental
Conservation,
Division of Air
Resources
New York State,
Department of
Motor Vehicles
(meetings and
data)
Brian Ketchum, Director, Office of
Planning and Implementation
Raymond Maurice, Deputy Director
Daphne Gemmill, Staff
John K. Hawley, Chief, Mobil
Service Section
Donald H. Miller, Associate Econo-
mist, Division of Air Resources
Mike Stawarz, Staff
Charles W. Bostick, Director,
Division of Research and
Development
Barry M. Hecht, Department of
Transportation
A-4
-------
Date of Visit
Company/Agency
Personnel Contacted
20 March 1973
Oregon, Depart-
ment of Environ-
mental Quality
Oregon, Highway
Department,
Motor Vehicle
Division
(meetings and
data)
H. M. Patterson, Director, Air
Quality Control Division
R. Householder, Supervisor, Motor
Vehicle Section
R. Jasper, Staff
Harvey B. Ward, Director
Administrative Services
Donald M. Stuhr, Director, Traffic
Study Programs
21 March 1973
Pennsylvania,
Department of
Environmental
Resources,
Bureau of Air
Quality and Noise
Control
Pennsylvania,
Department of
Transportation,
Bureau of
Traffic Safety
Pennsylvania,
Department of
Transportation,
Bureau of Motor
Vehicles
(meetings and
data)
Gary L. Triplett, Chief, Division
of Air Resources, Management
and Research
V. Ramadass, Chief, Planning and
Development Section, Division of
Air Resources Management and
Rese arch
Ward Baumbauch, Chief, Inspection
Division
Harry M. Scrignoli, Assistant to
the Director, BMV
Frank L. Pinola, Jr., Chief,
Accounts Division, BMV
A-5
-------
Date of Visit
Company/Agency
Name
Personnel Contacted
21 March 1973
Texas, Air
Control Board
Texas, Depart-
ment of Health
Texas, Depart-
ment of Public
Safety
Texas, Highway
Department,
Motor Vehicle
Division
(meetings and
data)
Ken Wade
Fred H. Hartman, Engineer, Air
Pollution Control Services
Joe D. White, Inspector, Motor
Vehicle Inspection and Planning
Division
James L. Keithly, Staff Services
Assistant
Edgar Burkhart, Chief, Accounting
Mr. Davidson, Representative,
New Car Dealers Association
29 March 1973
Utah, Division
of Health
(telecon and data)
Dr. Grant Winn, Chief, Air Quality
Section
Casper A. Nelsen, Engineer, Air
Quality Section
29 March 1973
Virginia, Air
Polution Control
Board (telecon)
James Alexander, Staff Member
Frank Osequeda, Staff Member
28 March 1973
Washington State,
Department of
Ecology (telecon
and data)
Henry Droege, Supervisor, Techni-
cal Assistance Division
A-6
-------
Date of Visit
Company/Agency
Name
Personnel Contacted
20 March 1973
Washington, D.C.,
Environmental
Health Adminis-
tration, Depart-
ment of
Environmental
Services
Washington, D.C.,
Metropolitan
Washington
Council of
Governments,
Department of
Health and
Environmental
Protection
Washington, D.C.,
District of
Columia Depart-
ment of Motor
Vehicles
(meeting and data)
John Brink, Chief, Bureau of Air
and Water Quality Control
S. Singh Bajwa, Engineering and
Planning Division
David Dijulio Head, Air Quality
Section
Sydney Berwager, Senior Transpor-
tation Engineer
Wiley W. Godsey, Chief, Office of
Vehicle Safety Research
Harry Gray, Chief, Data Process
Processing
A-7
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APPENDIX B
OUTLINE OF MAJOR ELEMENTS OF INTEREST IN CURRENT
STUDY ENTITLED, "Examination of the Issues Related to
Two-Car Regional Emission Control Strategy
Options/Alternatives"
B. 1 Identification/Synthesis of Control Strategy Options
Candidate options include:
a. Use of low-emission^ cars in State of California only (all
other States use higher-emission-^ cars).
b. Use of low-emission cars in State of California and selected
metropolitan areas and/or basins (all other States and/or
areas use higher-emission cars).
Candidate metropolitan areas^ and/or basins for selection
to use low-emission cars include (in addition to State of California):
a. Houston, Texas
b. Phoenix/Tucson, Arizona
c. Southern Louisiana and Southest Texas
d. Boston, Massachusetts
Options wherein a low-emission car is utilized in a region where automobile
emissions are the dominant air pollution problem, and a higher-emission
car is utilized in regions where permitted by air quality conditions.
Low-emission cars conform to 1975 Federal emissions standards.
Higher-emission cars conform to 1973/74 Federal emissions standards.
4
Metropolitan areas encompass those associated counties in "Standard
Metropolitan Statistical Areas" as published by the Executive Office of
the President/Bureau of the Budget.
These areas and/or basins are subject to changes as the study progresses.
B-l
-------
e. Philadelphia, Pennsylvania
£. Portland, Oregon
g. .Fairbanks, Alaska
h. Baltimore, Maryland
i. New York City, New York
j. Spokane, Washington
k. Denver, Colorado
1. Washington, D.C.
m. Pittsburgh, Pennyslvania
n. Seattle, Washington
o. Minneapolis/St. Paul, Minnesota
p. Salt Lake City, Utah
The time frame for the two-car control strategy options is the
1975 model year.
B . 2 Car Population Identification and Effects Analysis
Determination of the distribution of cars within the United
States:
a. By state registration location for control strategy
option la.
b. By area registration location (including county level
breakdown) for those areas of control strategy option Ib.
Determination of new-car sales distribution as in 2a and 2b
above.
Determination of the relative movement of cars from state-to-
state, or from area-to-area, as in 2a and 2b, in order to determine the
potential number of higher-emission cars that might enter low-emission-
control regions either on a permanent or transient basis.
B-2
-------
B. 3 Identification of Administrative Measures Related to
Compliance Assurance
Identify candidate measures/techniques related to control
strategy compliance assurance and assess possible effectiveness and/or
ramifications. Typical candidate measures/techniques include:
a. Vehicle registration control
b. Control of new car deliveries to dealers
c. Inspection of cars (both regional periodic inspection
and incoming checkpoint inspection)
d. Retrofit requirements for higher-emitting cars when
permanently entering a controlled region.
B.4 Control Strategy Feasbility Analysis
Assessment of the feasibility of implementing a two-car
strategy, for the strategy options la and Ib, from the standpoint of industry,
the Government, and the vehicle user.
Typical auto industry considerations include:
a. Ability to produce two classes of new cars
b. Ability to market new and used cars, including distribution
effects in low- vs high-emission controlled regions
c. Ability to service (parts and repair) both vehicle classes.
Typical government considerations (Federal/State/Local)
include:
a. Ability to implement, in a timely manner, the compliance-
assurance measures/techniques identified in 3a through 3d.
Typical vehicle user effects include:
a. Two-car hardware and cost differences
b. Operational and maintenance differences
c. Resale capabilities
B-3
-------
.d. Impact of retrofit requirements
e. Registration requirements
f. Inspection requirements (regional control).
Typical oil industry considerations include:
a. Ability to distribute and market leaded and unleaded gasoline,
as required by the control strategy options la and Ib.
B. 5 Corollary Issues Assessment
Identification of the more significant "pro's" and "con's" of a
number of issues potentially attendant to the implementation of control
strategy options la and Ib. Candidate corollary issues include:
a. Marketing impact on car producers. The impact of the
control strategy on the ability to market cars nationwide.
b. Impact of other potential requirements such as:
1. The requirement to produce lesser-controlled cars
capable of retrofit
2. The requirement to have lower-emitter controls as
optional features in other areas.
c. Impact on auto production rates such as:
1. Overseas deliveries of domestic producers
2. Number of foreign cars imported
3. Balance-of-trade ramifications.
d. Other impacts on the consumer, such as:
1. Ability to acquire replacement parts and service
2. Ability to move from area to area with a given car
3. Ability to acquire unleaded gasoline (if required) on
trips outside of a control region.
(:. Impact on replacement parts industry, in terms of ability to
meet customer demands.
f. Impact on used-car industry with relation to flow of cars from
area to area, under the control strategy options la and Ib.
B-4
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APPENDIX C
POPULATION AND PASSENGER CARS IN USE
WITHIN EACH STATE AND AQCR
C-l
-------
AIR QUALITY
CONTROL REGIONS
1 SAN FRANCISCO BAY
AREA AIR BASIN
(9 Counties)
2 SOUTH COAST
AIR BASIN
(6 Counties)
3 SACRAMENTO VALLEY
AIR BASIN
(14 Counties)
4 SAN DIEGO
AIR BASIN
(1 County)
TOTAL
REST OF STATE
STATE TOTAL
U.S. TOTAL
REGIONS % OF STATE
REGIONS % OF U.S.
STATE % OF U.S.
POPULATION
4,500,000
9,700,000
1,382,000
1,358,000
16,940,000
3,013,000
19,953,000
203,235,298
85
8.35
9.85
PASSENGER
CARS
REGISTERED
2,125,000
4,860,000
565,000
640,000
8,190,000
1,154,000
9,344,450
86,438,957
87.50
9.47
10.81
Figure C-l. Car Registrations, California
INCLUDED COUNTIES
1 AUSTIN
2 BRAZORIA
3 CHAMBERS
4 COLORADO
5 FORT BEND
6 GALVESTON
7 HARRIS
8 LIBERTY
9 MATAGORDA
10 MONTGOMERY
11 WALKER
12 WALLER
13 WHARTON
AIR QUALITY
CONTROL REGION
STATE TOTAL
U.S. TOTAL
REGION'S
% OF STATE
REGION'S
% OF U.S.
STATE'S
% OF U.S.
POPULATION
2,305,000
11,197,000
203, 235, 000
20.6
1.0
5.5
PASSENGER
CARS
REGISTERED
957,191
4,617,455
86,438,957
20.72
I.It
5.34
Figure C-2. Car Registrations, Houston, Texas Region
C-2
-------
INCLUDED COUNTIES
1 GILA
2 MARICOPA
3 PIMA
4 PINAL
5 SANTA CRUZ
AIR QUALITY
CONTROL REGION
STATE TOTAL
U.S. TOTAL
REGIONS
% OF STATE
REGIONS
% OF U.S.
STATES
%OF U.S.
POPULATION
1,429,000
1,711,000
203, 235, 000
80.50
0.70
0.87
PASSENGER
CARS
REGISTERED
714,849
842,893
86,438,957
84.80
0.83
0.98
Figure C-3. Car Registrations, Phoenix/Tucson Region
INCLUDED COUNTIES
TEXAS/15 COUNTIES
LOUISIANA/39 PARISHES
AIR QUALITY
CONTROL REGION
STATE TOTAL
(Texas + La )
U.S. TOTAL
REGION'S
% OF STATES
REGION'S
% OF U.S.
STATES'
%OF U.S.
POPULATION
3,360,000
11,197,000
3,641,000
14,838,000
203,235,000
22.10
1.65
7.30
PASSENGER
CARS
REGISTERED
(212,686) TEXAS
(1,007,564) LA
1,220,250 TOTAL
(4,617,455) TEXAS
11,323,596) LA
5,941,051 TOTAL
86,438,957
20.54
1.41
6.87
Figure C-4. Car Registrations, Southern Louiasiana/ Southeast Texas Region
C-3
-------
INCLUDED COUNTIES
1 ESSEX
2 MIDDLESEX
3 NORFOLK
4 SUFFOLK
AIR QUALITY
CONTROL REGION
STATE TOTAL
U.S. TOTAL
REGION'S
% OF STATE
REGION'S
% OF U.S.
STATES'
% OF U.S.
POPULATION
3,375,000
5,689,000
203,235,000
59.5
1.66
2.6
PASSENGER
CARS
REGISTERED
1,269,686
2,228,662
86.438,957
56.97
1.47
2.58
Figure C-5. Car Registrations, Boston, Massachusetts Region
INCLUDED COUNTIES
1 BUCKS
2 CHESTER
3 DELAWARE
4 PHILADELPHIA
5 MONTGOMERY
AIR QUALITY
CONTROL REGION
STATE TOTAL
U.S. TOTAL
REGION'S
% OF STATE
REGION'S
% OF U.S.
STATES'
% OF U.S.
POPULATION
3,844,000
11,794,000
203,235,000
32.6
1.9
5.8
PASSENGER
CARS
REGISTERED
1,422,557
4,690,633
86,438,957
30.33
1.65
5.43
Figure C-6. Car Registrations, Philadelphia, Pa. Region
.1
C-4
-------
INCLUDED COUNTIES
1
2
3
4
5
6
7
8
9
OREGON
BENTON
CLACKAMAS
COLUMBIA
LANE
LINN
MARION
MULTNOMAH
POLK
WASHINGTON
WASHINGTON
1 CLARK
2 COWLITZ
3 LEWIS
4 SKAMANIA
5 WAHKIAKUM
AIR QUALITY
CONTROL REGION
STATE TOTAL
1 Ore. + Wash. )
U.S. TOTAL
REGION'S
% OF STATE
REGION'S
% OF U.S.
STATES'
% OF U.S.
POPULATION
1,727,000
2,091,000
3,409,000
5, 500, 000
203,235,000
31.40
0.85
2.70
PASSENGER
CARS
REGISTERED
806, 928
(963,936) ORE
(1,515,485) WASH
2,479,421 TOTAL
86,438,957
32.55
0.93
2.87
10 YAMHILL
Figure C-7. Car Registrations, Portland, Oregon Region
INCLUDED COUNTIES
I CENTRAL DISTRICT
£
AIR QUALITY
CONTROL REGION
STATE TOTAL
U.S. TOTAL
REGION'S
% OF STATE
REGION'S
% OF U.S.
STATE'S
% OF U.S.
POPULATION
45,000
300,300
203, 235, 000
15
0.22
0.148
PASSENGER
CARS
REGISTERED
13,908
101,724
86,438.957
13.67
0.0161
0.118
Figure C-8. Car Registrations, Fairbanks, Alaska Region
C-5
-------
INCLUDED COUNTIES
t ANNE ARUNDEL
2 BALTIMORE CO
3 BALTIMORE CITY
4 CARROLL
5 HARFORD
6 HOWARD
AIR QUALITY
CONTROL REGION
STATE TOTAL
U.S. TOTAL
REGION'S
% OF STATE
REGION'S
% OF U.S.
STATE'S
% OF U.S.
POPULATION
2, 070, 000
3, 922, 000
203,235,000
53
1.02
1.93
PASSENGER
CARS
REGISTERED
860, 779
1 , 488, 071
86,438,957
57.85
1.00
1.72
Figure C-9. Car Registrations, Baltimore, Md. Region
INCLUDED COUNTIES
NEW YORK
1 BRONX
NEW JERSEY
2 KINGS
3 NASSAU
4 NEW YORK
5 QUEENS
6 RICHMOND
7 ROCKLAND
6 SUFFOLK
9 WESTCHESTER
ALL 21 COUNTIES
IN STATE
AIR QUALITY
CONTROL REGION
STATE TOTAL
(NY + NJ)
U.S. TOTAL
REGION'S
% OF STATES
REGION'S
% OF U.S.
STATES'
% OF U.S.
POPULATION
18,736,000
18,237,000
7,168,000
25,405,000
203.235,000
73.5
9.2
12.5
PASSENGER
CARS
REGISTERED
6,717,371
(6,224,601) NY
(3,260,464) NJ
9,485,065 TOTAL
86,438,957
70.82
7.77
10.97
Figure C-10. Car Registrations, New York City/New Jersey Region
C-6
-------
INCLUDED COUNTIES
WASHINGTON
1 ADAMS
2 ASOTIN
3 COLUMBIA
4 CARFIELD
5 GRANT
6 LINCOLN
7 SPOKANE
8 WHITMAN
IDAHO
I BENEWAH
2 KOOTENAI
3 LATAH
4 NEZ PERCE
5 SHOSHONE
AIR QUALITY
CONTROL REGION
STATES TOTAL
(Wash. + Idaho)
U.S. TOTAL
REGION'S
%OF STATE
REGION'S
% OF U.S.
STATE'S
% OF U.S.
POPULATION
526,000
3,409,000
713.000
4,122,000
203,235,000
12.80
0.26
2.02
PASSENGER
CARS
REGISTERED
232,237
(1,515,485) WASH.
(308,769) IDA
1,824,254 TOTAL
86,438.957
12.73
0.27
2.11
Figure C-ll. Car Registrations, Spokane, Wash. Region
F-
INCLUDED COUNTIES
t ADAMS
2 ARAPAHOE
3 BOULDER
4 CLEAR CREEK
5 DENVER
6 DOUGLAS
7 GILPIN
8 JEFFERSON
AIR QUALITY
CONTROL REGION
STATE TOTAL
U.S. TOTAL
REGION'S
% OF STATE
REGION'S
% OF U.S.
STATES'
% OF U.S.
POPULATION
1,241,000
2, 207, 000
203,235,000
56.00
0.61
1.09
PASSENGER
CARS
REGISTERED
653, 773
1,091,215
86.438,957
59.91
0.76
1.26
Figure C-12. Car Registrations, Denver, Colorado Region
C-7
-------
INCLUDED COUNTIES
MARYLAND
1 MONTGOMERY
2 PRINCE GEORGES
VIRGINIA
1 ARLINGTON
2 ALEXANDRIA
3 FAIRFAX
4 LOUDOUN
5 PRINCE WILLIAM
DISTRICT OF COLUMBIA
Md
WASH, D.C.
Va
f \f ***'
AIR QUALITY
CONTROL REGION
STATES TOTAL
(Md + Va)
U.S. TOTAL
REGION'S
% OF STATES
REGION'S
% OF U.S.
STATES'
% OF U.S.
POPULATION
2,940,000
3, 922, 000
4,648,000
756^000
9, 326, 000
203,235,000
31.50
1.44
4.60
PASSENGER
CARS
REGISTERED
1,167,419
(1,468,071 MO
(1,604,603 VA
1369,325 D.C.
3,661,999 TOTAL
86,438,957
31.88
1.35
4.24
Figure C-13. Car Registrations, Washington, D. C. Region
INCLUDED COUNTIES
1 ALLEGHENY
2 ARMSTRONG
3 BEAVER
4 BUTLER
5 FAYETTE
6 GREENE
7 INDIANA
8 WASHINGTON
9 WESTMORELAND
N /
AIR QUALITY
CONTROL REGION
STATE TOTAL
U.S. TOTAL
REGION'S
% OF STATE
REGION'S
% OF U.S.
STATES'
% OF U.S.
POPULATION
2, 876, 000
11,794,000
203,235,000
24.2
1.41
5.8
PASSENGER
CARS
REGISTERED
1,099,225
4,690,633
86,438,957
23.43
1.27
5.43
Figure C-14. Car Registrations, Pittsburgh, Pa. Region
C-8
-------
AIR QUALITY
CONTROL REGION
STATE TOTAL
U.S. TOTAL
REGION'S
% OF STATE
REGION'S
% OF U.S.
STATE'S
% OF U.S.
POPULATION
1,933,000
3, 409, 000
203,235,000
56.7
0.95
1.68
PASSENGER
CARS
REGISTERED
852,526
1,515,485
86,438,957
56.25
0.99
1.75
INCLUDED COUNTIES
1 KING
2 KITSAP
3 PIERCE
4 SNOHOMISH
Figure C-15. Car Registrations, Seattle, Wash. Region
INCLUDED COUNTIES
1 AMOKA
2 BENTON
3 CARVER
4 CHISAGO
5 DAKOTA
6 HENNEPIN
7 ISANTI
8 KANABEC
9 MILLE LACS
10 PINE
11 RAMSEY
12 SCOTT
13 SHERBOURNE
14 STEARNS
15 WASHINGTON
16 WRIGHT
AIR QUALITY
CONTROL REGION
STATE TOTAL
U.S. TOTAL
REGION'S
% OF STATE
REGION'S
% OF U.S.
STATES'
% OF U.S.
POPULATION
2,124,000
3,805,000
203,235,000
55.80
1.04
1.87
PASSENGER
CARS
REGISTERED
996,208
1,756,706
86,438,957
56.70
1.15
2.03
Figure C-16. Car Registrations, Minneapolis/St. Paul, Minn. Region
C-9
-------
INCLUDED COUNTIES
1 DAVIS
2 MORGAN
3 SALT LAKE
4 TOOELE
5 UTAH
AIR QUALITY
CONTROL REGION
STATE TOTAL
U.S. TOTAL
REGION'S
% OF STATE
REGION'S
% OF U.S.
STATE'S
% OF U.S.
POPULATION
722,000
1,059,000
203,235,000
68
0.355
0.52
PASSENGER
CARS
REGISTERED
316,307
456,502
86,438,957
69.29
0.37
0.53
Figure C-17. Car Registrations, Salt Lake City, Utah Region
C-10
-------
Table C-l. General Motors 1971 Registrations
AQCR
California
Houston
Phoenix /Tucson
La/Texas
Boston
Philadelphia
Portland
Fairbanks
Baltimore
NY/NJ
Spokane
Denver
Washington, D.C.
Pittsburgh
Seattle
Minneapolis
Salt Lake City
AQCR
Reg's
875,777
113,422
63, 506
127,263
156,438
150, 576
71, 623
1, 543
111,889
771,315
16,293
64, 124
157, 587
126,419
62,774
98, 045
28, 025
2,996,619
G. M.
Reg's
234,520
48, 698
21, 017
52, 579
59,995
61,694
18,222
387
50,230
319,373
5,018
18, 590
57, 050
47,715
16,771
39,882
8,549
1, 060,290
%
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
%
G.M.
Total
5.34
1.11
0.48
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 %
G.M.
Total
5.34
6.45
6.93
8. 12
9.49
10.80
11.31
11.32
12.46
19.73
19.84
20.27
21. 57
22.65
23.03
23.94
24. 14
o
I
-------
Table C-2. Ford 1971 Registrations
AQCR
California
Houston
Phoenix/ Tucson
La/Texas
Boston
Philadelphia
Portland
Fairbanks
Baltimore
NY/NJ
Spokane
Denver
Washington, D.C.
Pittsburgh
Seattle
Minneapolis
Salt Lake City
AQCR
Reg's
875,777
113,422
63, 506
127,263
156,438
150, 576
71,623
1,543
111,889
771,315
16,293
64, 124
157,587
126,419
62,774
98,045
28, 025
2,996,619
Ford
Reg's
213, 195
29,045
16,356
33, 558
37,737
32,849
16,036
362
33,383
154, 183
3,707
16,704
39, 537
29,708
15,760
26,297
7,516
705,933
%
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
o
I
-------
Table C-3. Chrysler 1971 Registrations
AQCR
California
Houston
Phoenix/ Tucson
La/ Texas
Boston
Philadelphia
Portland
Fairbanks
Baltimore
NY/NJ
Spokane
Denver
Washington, D.C.
Pittsburgh
Seattle
Minneapolis
Salt Lake City
AQCR
Reg's
875,777
113,422
63, 506
127, 263
156,438
150,576
71, 623
1, 543
111, 889
771,315
16,293
64, 124
157, 587
126,419
62.774
98, 045
28, 025
2,996,619
Chrys .
Reg's
99,446
15,246
8, 806
19,899
25,261
23,010
8,868
205
18,698
134, 156
2,616
8,463
25, 088
17, 274
8,339
16,808
4. 043
436,226
%
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
rr
Chrys.
Total
7.46
1. 14
0.66
1.49
1.89
Cum %
Chrys .
Total
7.46
8.60
9.24
10.75
12.64
1.73 14.37
0.66
0.015
1.40
10.06
0.20
0.63
1.88
1.30
0.63
1.26
0.30
32.70
15.03
15.05
16.45
26.51
26.71
27.34
29.22
30. 52
31. 14
32.40
32.70
n
-------
Table C-4. American Motors 1971 Registrations
AQCR
California
Houston
Phoenix/ Tucson
La/Texas
Boston
Philadelphia
Portland
Fairbanks
Bal timore
NY/NJ
Spokane
Denver
Washington, B.C.
Pittsburgh
Seattle
i
Minneapolis
Salt Lake City
AQCR
Reg's
875,777
113,422
63,506
127,263
156,438
150,576
71,623
1,543
111,889
771,315
16,293
64, 124
157, 587
126,419
62,774
98,045
28,025
2,996,619
A.M.
Reg's
17,856
1,631
2,005
1,486
1.906
4,873
2, -29 6
72
2,979
15,365
539
1,832
2,973
4,305
1,266
3,661
680
65,725
%
AQCR
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
%
A.M.
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 %
A.M.
Total
7.34
8.01
8.84
9.45
10.23
12.24
13.18
13.21
14.44
20.76
20.98
21.73
22.96
24.73
25.25
26.75
27.03
n
ii
*.
-------
Table C-5. Volkswagen 1971 Registrations
AQCR
California
Houston
Phoenix/ Tucson
La/ Texas
Boston
Philadelphia
Portland
Fairbanks
Baltimore
NY/NJ
Spokane
Denver
Washington, D.C.
Pittsburgh
Seattle
Minneapolis
Salt Lake City
AQCR
Reg's
875,777
113,442
63, 506
127, 263
156,438
150, 576
71, 623
1, 543
111, 889
771,315
16,293
64, 124
157, 587
126,419
62,774
98, 045
28, 025
2,996,619
VW
Reg's
87,328
5,914
5,321
7,477
11,538
12,858
6, 156
206
6,393
57, 800
1, 514
5,708
10,380
14,242
5, 226
4,394
2,442
244, 897
%
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
19.36
20.82
23.09
25.62
26.82
26.86
28. 12
" 39.47
39.77
40.89
42.93
45.73
46.75
47.61
48.09
n
-------
Table C-6. Toyota 1971 Registrations
AQCR
California
Houston
Phoenix/ Tucson
La/ Texas
Boston
Philadelphia
Portland
Fairbanks
Baltimore
NY/NJ
Spokane
Denver
Washington, D.C.
Pittsburgh
Seattle
Minneapolis
Salta Lake City
AQCR
Reg's
875,777
113,422
63, 506
127,263
156,438
150,576
71,623
1, 543
111,889
771,315
16,293
64, 124
157, 587
126,419
62,774
98, 045
28, 025
2,996,619
Toyota
Reg's
65,440
5,756
3,457
5,669
7,680
4,424
4, 578
128
2,322
24, 168
674
3,438
3,829
2,328
3,866
2, 144
1,633
141, 534
%
AQCR
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 %
Toyota
Total
24. 19
26.32
27.60
29.69
32. 53
34. 17
35.86
35.91
36.77
45.70
45.95
47.22
48.63
49.50
50.92
51.72
52.32
O
i
-------
Table C-7. Datsun 1971 Registrations
AQCR
California
Houston
Phoenix/ Tucson
La/ Texas
Boston
Philadelphia
Portland
Fairbanks
Baltimore
NY/NJ
Spokane
Denver
Washington, B.C.
Pittsburgh
Seattle
Minneapolis
Salt Lake City
AQCR
Reg's
875,777
113,422
63, 506
127,263
156,438
150, 576
71,623
1,543
111, 889
771,315
16,293
64, 124
157, 587
126,419
62,774
98, 045
28, 025
2,996,619
Datsun
Reg's
55, 202
1,436
2, 531
2, 177
2,316
1, 661
4, 658
67
2,408
9,232
1, 066
2,344
3,307
1, 620
3,470
657
890
95,042
%
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
45.45
46.74
48.56 :
49.45 .
51.35 :
51.72 :
52.20
o
I
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APPENDIX D
A TWO-LEVEL APPROACH TO NATIONAL
AUTOMOTIVE EMISSION CONTROL
General Motors, October 1972
-v
Abstract
This paper outlines a proposal that the U. S. convert to a two-
level approach for automotive emission control. One level would be a Type A
system meeting 1973 emission control requirements built for most of the
nation, and the other level a Type B system meeting more stringent control
requirements for those areas with automotive-related air pollution problems.
Ten-year cost savings to the nation of at least 14 to 22 billion dollars are
estimated, depending on the severity of control for the cars equipped with the
Type B system.
D-l
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APPENDIX D
A TWO-LEVEL APPROACH TO NATIONAL
AUTOMOTIVE EMISSION CONTROL
General Motors Statement
D. 1 Introduction
On February 28, 1972, the Ad Hoc Committee on the Cumulative
Regulatory Effects on the Cost of Automotive Transportation (RECAT) pub-
lished its report for the Office of Science and Technology. This report sug-
gested "a low emission car for those regions where automotive emissions are
a dominant air pollution problem or a major component of the problem and a
lower cost higher emission vehicle for those parts of the country where air
quality would not be essentially degraded by such less controlled vehicles. "
In addition to the economic benefits that would result from such a two-level
approach, there are also substantial benefits to the nation and the entire
world in the conservation of natural resources resulting from saving of fuel
and certain limited availability metallic materials. Further, there is the
probable improvement in driveability for vehicles with less severely con-
trolled emissions. The intent of this paper is not to explore in minute detail
all aspects of the two-level approach, but merely to indicate in a general way
the pros and cons, point out the potential savings and indicate the desirability
of pursuing such an approach.
D. 2 General Discussion
The RECAT report alludes to the possibility that the two-level
approach might be expanded to a three- or even a four-level approach with
graded levels of emission control. However, the Committee believes that the
added complexity which would result from more than two levels of emission
control would not be justified. In the first place, the present levels of emis-
sion control (1973 model cars) are already severe enough that interim steps
in control between the present level and what might be termed the "ultimate
D-2
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level" would be relatively small. Secondly, the added cost to manufacture
the additional types of emission control systems would tend to dilute the
economic benefits. As a result, The Committee proposes that the U.S. con-
vert to the two-level approach for automotive emission control; one fraction
of the new car population would be built to present (1973) emission standards,
hereinafter referred to as Type A cars, and the other fraction of the new cars
would be equipped with controls adequate to satisfy those areas of the nation
which have the most severe automotive air pollution problem. This Type B
car would be the same as the Type A car except that it would be equipped to
comply with the modified 1976 emission standards suggested by the Committee
and discussed in detail in the preceding paper.
In order to make an intelligent assessment of the two-level
concept, there are some additional details which need to be known and some
decisions which need to be made. The federal government should prescribe
the emission levels for Type A and Type B cars as well as the regulatory
rules necessary to ensure proper compliance by automobile manufacturers.
Different automotive emission regulations for each of the 50 states obviously
would be unworkable. The organization and procedures for federal control
are already well established by the U.S. Environmental Protection Agency.
The selection of either Type A or Type B cars for a particular locale should
be a decision made by the local government. This could result in the most
efficient cost-benefit tradeoffs of automotive emission control versus control
of emissions from stationary sources. From the standpoint of more practical
politics, the decision-making responsibility would be reserved for authorities
closest to the problem. However, the choice of locales which would be per-
mitted to have the foregoing decision-making authority would be made by the
federal government. Actually, these choices already have been made. They
are the air quality control regions defined by the Environmental Protection
Agency.
It seems axiomatic that a viable national two-level approach
nationwide must provide for a substantial fraction of lower cost Type A cars
in the total vehicle population. The RECAT report estimated a minimum of
D-3
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30% of the total population did not require more stringent emission control
than presently (then 1971 models) installed on new production vehicles. How-
ever, this estimate was based only on vehicle density data and RECAT sug-
gested that more precise estimates could be made after completion of the
state air quality standards implementation plans. GM engineers made such
an estimate from data contained in and related to these state implementation
plans. That estimate shows the two-level approach would include more than
50% of the Type A cars. The estimate was based on the assumption that any
air quality control region which was shown by the state implementation plan
to achieve the federal air quality standards in 1975 without control of auto-
motove emissions beyond federal new car standards could be considered to
require no more than the Type A car. The federal air quality standards would
be achieved with the 1973 automotive emission standards as essentially the
final level of automotive emission control, since 1975 cars would have only a
very limited impact on emissions from the total 1975 car population. Actually,
based on 1971 registrations of new General Motors automobiles, as much as
50% of the car population would satisfy the foregoing Type A criteria. Con-
sidering that the air quality standards recommended by GM are significantly
less severe than the federal standards, the 50/50 split between Type A and
Type B cars appears to be very conservative.
D. 3 Cost Savings Estimate
On the basis of a 50/50 split between Type A and Type B controls
on automobiles, the potential investment and maintenance and operating cost
savings to be realized from a two-car marketing program could be substantial.
The selection of appropriate cost data naturally requires that certain assump-
tions be made with regard to the emission control systems required, future
economics and inflation, the size of the new-car markets and General Motors
participation in new car sales, population growth and movement trends, and
possible future increased production and engineering efficiencies.
The emission control systems on the Type A cars would be the
same as those used on 1973 models. Production emission control systems for
D-4
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Type B vehicles are not as yet completely defined. However, the most
promising system is one involving the use of catalytic converter for oxidatiqfi
of the engine exhaust HC and CO. Exhaust gas recirculation (EGR) also is a
feature of the overall system. A high-energy ignition system (HEI) will be
incorporated to provide a much longer ignition system life and higher voltage
capability both to enhance the long-term reliability of the overall emission
control system and to permit the use of wider gap spark plugs resulting in
more reliable ignition of the mixture in the combustion chamber.
To meet the EPA's 1976 requirements, the only experimental
approach evaluated to date which shows promise is the addition of a reducing
catalytic converter to the Type B car.
Estimates of the cost of Type A and Type B emission control
systems (as well as "1976 EPA specification" hardware) have been taken from
the report of the RECAT Committee which cites U.S. automobile manufacturers'
responses to the Committee's questionnaire as their source. Additional data,
such as new car registrations, new car survival rates, maintenance and oper-
ating cost estimates and a "learning curve" estimate for engineering and
production efficiencies, were all taken from the RECAT report or the sources
cited there and adjusted to reflect only the difference in cost between Type A,
Type B and "1976 EPA" systems. (The RECAT figures are for advanced con-
trol systems versus a pre-1968, uncontrolled system. ) No estimate was
made for cost increases due to future economics or inflation. Therefore, the
figures in Table D-l represent a very conservative estimate of the potential
savings to the consumer and resultant preservation of national resources from
allowing Type A cars to be sold in selected areas after the 1975 model year.
The potential investment savings (first cost to the consumer)
by permitting both Type A and Type B cars to be sold is estimated to begin
at $164 per car and decreases to $112 per car at the end of ten years. Thus,
the "learning curve" for the automobile manufacturer is assumed to reduce
the consumer cost of the Type B car by $52 during the first decade of produc-
tion. A similar determination of maintenance and operating costs indicates
annual savings of $17 per car, decreasing to $12 per car after the first ten
years.
D-5
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It was assumed that annual operating and maintenance savings
per Type A vehicle manufactured after the 1975 model year remains the same
for the respective model years throughout the vehicle life. Vehicle life is
based on the RECAT survival rate table.
As shown in Table D-l, the estimated aggregate economic
savings of the two-level program from using 50 percent Type A versus 100 per-
cent Type B vehicles during the 1976-1985 period would be $7. 0 billion for
General Motors' customers alone. This represents an investment savings
component of $4. 5 billion and operating and maintenance component of $2. 5
billion. On an annual basis, the saving is $0.7 billion. After the initial
"conversion decade" (approximate time required to replace the U.S. car
population), the annual savings would be $0. 9 billion. It should be emphasized
that these savings could be realized by the nation's consumers and at the same
time maintain the required air quality. An average car would sell for about
$100 less in 1976 -- provided the investment savings is spread over all cars
sold to avoid a two-price system and about $200 less if the savings are passed
on to Type A car buyers only.
Table D-2 presents the estimated aggregate economic savings
of a two-level program using 50 percent Type A versus 100 percent 1976
EPA-specification vehicles during the 1976-1985 period. The aggregate
savings of $11. 2 billion includes $7. 3 billion of investment and $3. 9 billion in
maintenance and operating cost, or $1. 1 billion annually. After the conversion
decade, the annual savings would be $1.4 billion with equal investment and
maintenance and operating components.
The calculations presented in Tables D-l and D-2 can be ex-
tended to encompass the entire U.S. automotive market. This would result
in a savings more than double the savings estimated for General Motors cus-
tomers alone -- more than $14 billion for a decade of 50 percent Type A
versus 100 percent Type B cars.
Certainly these results indicate that serious consideration
should be given by the federal government to the adoptionof a two-level
approach for controlling automotive emissions.
D-6
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D. 4 Administrative and Regulatory Problems
The investigation of the economic merit of the two-level
approach raises certa'n administrative and regulatory questions. Obviously,
if the Type A and Type B cars are segregated on a statewide basis, the regu-
latory procedures are minimized. However, in this analysis, the federal air
quality control regions were used as the defined locales, and the boundaries
of those regions are defined by counties. In a few instances, they are even
interstate. Consequently, the control regulations do suggest some complica-
tions. The implementation of the following procedure would minimize the
administrative control segment of the two-level approach to automotive emis-
sion control.
The Type A and Type B cars would be identified through the
vehicle serial number. Considering the complexity of the system and the
body and engine modifications required to convert a Type A vehicle into a
Type B vehicle, it is expected to be difficult and economically impractical to
modify the emission control equipment in the after-market. Thus, the rela-
tive emission level of a car could be identified. New registration regulations
probably would prohibit the registration of a motor vehicle outside the county
of the owner's legal residence. The burden of proof would be the responsibility
of the automobile owner at the time of registration. This procedure is cur-
rently practiced in some states that have additional registration cost for un-
insured motorists and practically no financial burdens have been incurred from
an administrative standpoint. With little effort counties could effectively
control the registration of cars.
If a vehicle owner moved his residence from a Type A area to
a Type B area, one alternative would be to sell his vehicle and procure one
that met the requirements of the area. In response to the argument that this
is unfair treatment, one must consider that similar relocating disadvantages
already exist. For example, relocating to a city or state that has higher sales
tax or incoine tax rates. It would be simply part of the advantages or dis-
advantages of relocating. Another alternative would be for the Type B areas
D-7
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to place a punitive tax on the less controlled Type A vehicles to discourage
their ownership in Type B areas.
Another method of prohibiting the use of Type A vehicles in
Type B areas would be to have county-mandated vehicle inspection regulations.
One could not receive a vehicle inspection sticker unless the vehicle was
equipped with the proper emission control equipment. Obviously, the car
would require inspection in the county of the owner's legal residence.
A potential weakness of the two-level approach results from
the mobility of the American public. Car owners from regions which license
the Type A cars will need to have access to Type B areas. To deny this
freedom of mobility would surely impose cumbersome, disruptive and expen-
sive penalties; however, it should be noted that as currently considered, the
Type A cars would still have the 1973 level of emissions control equipment
which represents a reduction from the uncontrolled I960 level of 80 percent
of hydrocarbons, 69 percent of carbon monoxide and 38 percent of oxides of
nitrogen. So, even the Type A car would be a pretty "clean" car.
In addition, the counties surrounding metropolitan areas are
included in the air quality control regions as if all of them had unacceptable
air quality. This helps to keep the number of Type A cars moving into these
sections to a tolerable minimum, both visiting cars and through traffic.
D. 5 Manufacturers' Problems -- Marketing and Production
The marketing and production implications of a two-level
approach are not considerably different from those in the current U.S. auto-
motive market as a result of the difference between federal and California
standards. However, there are some potential problems.
The major marketing consideration is the pricing problem. A
two-level price reflecting the cost of additional equipment on Type B vehicles
would create regulatory burden by encouraging such buyers to acquire and
illegally operate Type A vehicles. If all manufacturers were required to
spread the gross savings over all vehicles, the two-tier pricing problem
would be eliminated. However, this would destroy the local incentive to allow
D-8
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Type A cars regardless of existing or anticipated air quality. Marketing
experience in California strongly suggests that the additional Type B hardware
and associated costs could best be handled at the retail level as a "mandatory
option. " Proper enforcement of the registration or inspection regulations
previously described could hold "cheating" to a negligible level.
In general, any change in vehicle design or marketing philosophy
which adds proliferation potential to the product line, affects production organi-
zations adversely. A two-level approach to emission control would thus be
expected to add problems and cost to areas of production operations such as
material inventory, scheduling, handling, and obsolescence as well as operator
training, quality control and manpower productivity. The degree to which
assembly operations would be affected would depend on precise definitions of
emission control hardware and vehicle order and distribution requirements.
D. 6 Conclusion
Certainly the implementation of a two-level approach to auto-
motive emissions control could not be accomplished without some additional
burdens on the manufacturer and governmental agencies. However, it appears
that the potential benefits to the nation outweigh those disadvantages to such
an extent that immediate serious detailed study by involved governmental
agencies is indicated.
D-9
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Table D-l. Estimate of Aggregate Economic Savings of a
Two-Car Marketing Program
Type A and Type B Vehicles (General
Motors Cars Only)
Time Interval
"Conversion
Decade"
(1976 - 1985)
Annual, First
Year After
"Conversion
Decade"
Savings (Billions of Dollars)
Maintenance
Investment and Operation
4. 5
0. 5
2.5
0.4
Total
7. 0
0.9
Annualized
Total
0.7
0.9
Table D-2. Estimate of Aggregate Economic Savings of a
Two-Car Marketing Program
Type A and 1976 EPA-Specification Vehicles
(General Motors Cars Only)
Time Interval
"Conversion
Decade"
(1976 - 1985)
Annual, First
Year After
"Conversion
Decade"
Savings (Billions of Dollars)
Maintenance
Investment and Operation
7.3
0.7
i
3.9
0.7
Total
11.2
1.4
Annualized
Total
1. 1
1.4
D-10
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APPENDIX E
GENERAL MOTORS STATEMENT - TWO-CAR STRATEGY
During the General Motors appearance at the 1975 emission
suspension hearing on March 12, 1973, EPA suggested that General Motors
consider the possibility of marketing cars with catalytic converters in the
fifteen most highly stressed air quality regions in the country rather than
only in the State of California as proposed by General Motors. The fifteen air
quality regions involved are assumed to be those identified by EPA.
An initial analysis of the EPA proposal has been made and is
presented herein. The analysis considers the risk to the public resulting
from manufacturing, marketing, logistics and enforcement problems as well
as the risks to General Motors, to the extent they can be evaluated in the
limited time available. The potential improvements in air quality have not
been developed, but they are estimated to be minor.
E. 1 Conclusion
Extending the limited production of 1975 vehicles with advanced
emission control systems to other areas than California, while having theo-
retical merit, would, in addition to increasing manufacturing and distribution
problems, involve a complex and difficult enforcement system. We would
need, roughly, to double the 7% of production figure to cover the 15 most
highly stressed areas. This would bring about additional complexity of dis-
tribution of the vehicles and training of personnel. We do not know how resi-
dents of the stressed areas could be prevented from buying cars in other areas.
E.2 Background
As an experienced manufacturer of mass-produced products.
General Motors normally schedules a phased or gradual introduction of-newly
developed and little-tested equipment. This is especially critical in the case
E-l
-------
of sophisticated emission controls. We require production experience and
actual knowledge of a product's performance in the field before committing
massive resources to across-the-board manufacture where the risks are
greatly and unreasonably multiplied.
To gain such experience, GM proposed that the EPA and the
State of California permit installation of catalytic converters and other special
control equipment in 1975 model cars sold in California. On these California
cars, the ceritification levels would be 0.76 grams per mile HC, 5.7 grams
per mile CO, and 3. 1 grams per mile NOx (on the premise that EPA adopts
the suggested changes with respect to averaging, end-of-line testing, and
warranty and recall regulations).
The choice of California for GM's proposed phased introduction
was based on these criteria:
a. California contains areas of the greatest stress in automotive
air pollution, and a wide variety of climatic and road conditions.
b. More than 7% of our nationwide production is sold in California;
an amount exceeded in only two other states.
c. Choosing a single geographic area rather than a single model
line for a phased introduction provides across-the-board ex-
perience with several types and sizes of cars.
d. An initial service parts distribution can be made in one area.
e. Field service training can be conducted in one area and
thoroughly evaluated before being conducted nationwide.
f. In the event a recall or modification is necessary, all of the
vehicles would be in one general area.
The General Motors proposal of introducing catalytic converter
equipped vehicles in California has been based on motor vehicles from all
car divisions (Chevrolet, Pontiac, Oldsmobile, Buick, Cadillac), but certain
models may not be available.
E. 3 EPA Proposal
At the EPA Suspension Hearing on 3-12-73, Mr. Sansom,
Assistant Administrator for Air and Water Programs, asked if GM would
consider a "major cities" distribution of catalytic converter cars to satisfy
E.2
-------
the demands of high stressed air quality regions rather than just the single
area of California. He recognized a higher percentage of production would
be involved (suggested 15%) and that strict regulation and enforcement would
be necessary in order to assure the sale and use of these vehicles. Implied
was the need for nationwide availability of catalytic converter fuel (low lead)
for either proposal to permit normal customer use.
The major problem with this proposal is one of regulation to
assure that vehicles with special emission control equipment are purchased
and used in the intended localities. An effective vehicle registration, licensing,
and inspection plan would have to be developed by the EPA, state and local
regulatory agencies.
E. 4 Proposal Evaluation
E. 4. 1 Hardware
While current plans provide for 100% capacity, installing a
single converter assembly line initially permits evaluation and debugging
prior to full production. First year production capability from a single con-
verter assembly line is estimated at approximately 12%. Assuming on-time
installation of all components of the manufacturing facility and development
of the processing technology, the production parts and service parts would be
built on an accelerating rate through the model year. Experience gained
would permit subsequent installation of additional manufacturing lines aimed
at providing nationwide capability during the following year.
E. 4. 2 Car Assembly
GM currently has 21 plants assembling passenger cars and
light trucks and three plants assembling light trucks. Thirteen of these plants
build or have built California models in addition to Federal models. The
complexity of two distinct, separate engine and power trains in otherwise
identical models has already been comprehended in these plants. The EPA
major cities plan would require converting some additional plants to being
"two-system" plants or would require cross shipping of cars, which would add
to the expense imposed upon the public.
E-3
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E.4.3 Car Distribution
GM is, of course, experienced in car distribution (the right
car in the right place at the right time) and while it would be very difficult for
us to provide a full model mix for various cities in the country, it would not
be an impossible task. Shipping two kinds of cars to a single major metro-
politan area for subsequent reshipment to outlying areas will impose logistics
problems. For example, a metropolitan dealer serving rural and urban areas
would require a very large inventory to adequately cover both kinds of vehicles
for both markets he serves.
E.4.4 Sales Consideration
A dealer will have many problems to cope with in a "controlled
city":
a. A potential customer may give his vacation home address or
use that of a family member to avoid buying a converter car.
b. Where does the control district stop? The customer may claim
he lives just outside the district.
c. If an owner has purchased a new 1975 car under false pretenses,
is the dealer obligated to buy it back or retrofit the car with a
converter?
These few are only suggestive of the large number of questions that can be
developed. A major training program will be necessary to properly inform
the sales people of the advantages of catalytic converter cars.
E. 4. 5 Service
Service complexity will be considerably greater than in the
original California proposal. Limiting 1975 introduction to California per-
mitted concentration in one area. Distribution in several major cities
requires:
a. Complete availability of service parts on practically a nation-
wide basis with the introduction of the 1975 models.
b. Special service equipment available in all dealerships, rather
than just Southwest U.S. to start.
c. A nationwide, Service Technician Training Program.
E-4
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E.4.6 Enforcement
The historical position of California since 1966 is important.
Cars with special emission equipment have been sold in the state at extra cost
to the customer for several years. The inspection and licensing procedures
are well established at the state level and California residents have generally
been receptive to emission controls. As we have previously mentioned,
mandatory installation of special emission equipment on a regional or city
basis will require elaborate licensing and inspection procedures. Enforce-
ment at less than the state level appears almost impossible.
Consider the problems of manufacturing, distribution, service
and enforcement, the original General Motors proposal to introduce catalytic
converters in the State of California for 1975 prior to going nationwide in
1976, is the most feasible for General Motors.
E-5
-------
APPENDIX F
SUPPLEMENTAL COMMENTS ON SELECTED INTRODUCTION '
OF CATALYSTS IN MULTIPLE AIR QUALITY REGIONS
Ford Statement
During Ford's appearance at these hearings on March 13, 1973,
questions were asked regarding the possibility of equipping passenger cars
with catalysts for use in 15 selected cities or regions across the country.
We have stated for the record Ford's view that the Administrator lacks the
requisite legal authority to compel such a result. This supplement to our
testimony addresses other aspects of Ford's position in opposition to such an
approach for 1975.
At the outset, we should express our view that a strategy
limiting the requirement for catalyst-equipped vehicles to California only is
feasible, practical and desirable. In fact, such a system has a historical
background incorporated as far back as 1961 on crankcase ventilation systems
and later in 1966 on exhaust emission systems controlling HC and CO, in 1970
on Evaporative Emission Controls and as recently as 1972 models embodying
NO controls. The California public, enforcement activities, legislature,
car dealers, mechanics, and the manufacturers' sales, service and manu-
facturing groups have had almost twelve years of experience in working with
such a system.
Expansion of this approach which would require catalyst-
equipped vehicles for a multiplicity of cities and regions is in our opinion
incalculably complex and difficult to administer. When one considers that the
extremely intricate enforcement would have to be set up by law in various
states for only a one-year period, its limitations become obvious.
It is disruptive of acceptable channels of distribution, sales and
enforcement for the consumer, government (Federal, State, County and City)
F-l
-------
as well as the manufacturer -- without concomitant benefits. To make such
a system operable involves sizable allocation of enforcement manpower,
passing of appropriate state and local enforcement laws involving the sale,
use and registering of motor vehicles, appropriation of money to put into
effect enforcement machinery not now available, and the changing of mass
production oriented facilities to selective options on geographical basis for
only a one-year period.
The problems can be categorized into the following broad
groupings: (1) Title and registration; (2) Enforcement; (3) Merchandising -
Service; and (4) Manufacturing and distribution.
F. 1 Title and Registration
To be effective as a controlled test, all new vehicles to be sold
in a city or geographic area must be equipped with the catalyst system. At
this time no state to our knowledge, has the legal and enforcement machinery
to control the registration of a specific equipped vehicle in a geographic area
less than an entire state. If the selected area is not identical with state
boundaries, the problem becomes immeasurably more complex.
For each such area, state vehicle registration requirements
must require residents to register only the appropriately equipped new vehicles.
Title and registration procedures on all new passenger car vehicles to be
effective for a given city or area must, at a minimum, have state laws passed
which make it illegal and provide appropriate penalties for:
a. A resident of a community to purchase a vehicle not equipped.
(Must be flexible to handle hardship cases such as accidents
outside the area, even state, etc. , and provide means for
enforcement. )
b. A resident to falsify his residency so he can purchase a non-
equipped vehicle.
c. Anyone in the state not to tamper, alter or make inoperable an
equipped vehicle.
d. A resident from operating a vehicle knowing that the emission
system has been altered or made inoperable.
e. A person selling or offering for a sale a new or used vehicle
not in compliance with the law.
F-2
-------
At the present and for the foreseeable near future (certainly
by September 1974), only California has or will have the experience necessary
to deal effectively with the problems associated with such requirements.
F. 2 Enforcement
This area relates specifically to insuring that the residents do,
in fact, buy and use new motor vehicles equipped with catalyst systems. A
requirement without enforcement is meaningless. Consequently, the enforce-
ment authorities must ensure that a catalytic converter has in fact been in-
stalled. A periodic vehicle inspection procedure is almost mandatory.
Random inspection coupled with changes of ownership inspection requirements
is effective to a lesser degree.
With a new and complex system it is obvious that previous
enforcement experience will mitigate problems. It is also likely that the
public enforcement relationship which had developed over a long period of
time will also tend to reduce problems in this area to a minimum. California
has this experience and the organization. No other state could really do this
in the time remaining between now and introduction of 1975 models in 18 months.
The fact that the proposal would operate only one year under present law
would make this seem impractical even if it could be accomplished in the time
remaining.
F. 3 Merchandising and Service
The problems associated with this area are also difficult to
resolve on anything but a state-wide basis. In certain areas, even state
boundaries would not adequately define the sales and service area. For
example, dealerships are located on a sales area basis as opposed to specific
air quality regions. The same is true of company district and regional sales
offices. Their total sales are not confined to their respective air quality
region. Sales are made not only from dealer to customer but from dealer to
dealer. Many dealers would have to cope with the problems attendant upon
storing, selling and servicing two distinct types of systems on each of their
F-3
-------
models. In stocking their inventories, dealers would be forced to estimate
the percentage of their sales to customers within and outside the specially
regulated area. The result in many cases could be vehicle inventories which
are out of line with customer demand. In any event, if the dealers have the
responsibility for not selling unequipped vehicles to residents of the selected
areas then they cannot fairly be held accountable for the truthfulness of the
customer relative to residency. Even with California standards on a state-
wide basis, California and contiguous state dealers have experienced these
problems over a considerable period of time.
Since the catalyst system involves engineering technology not
heretofore employed, considerable technical instruction and development of
repair techniques are required. By concentrating instructional talent and
facilities in one state, coverage can be made more complete and more effec-
tive thereby increasing the likelihood that the systems are serviced properly
and promptly by the largest and most proficient service group possible. It
is also clear that with one concentrated area to deal with, faster customer
response can be achieved. The resolution of service difficulties and the pro-
vision of parts can be expedited if only a single area is involved.
F. 4 Manufacturing and Distribution
By virtue of the intended selection of cities and areas through-
out the country, many of our assembly plants would be affected. These plants
must provide for assembling, storing and handling highly sophisticated equip-
ment such as the catalysts, unique engines and other devices for use in the
selected areas. At the same time, they must handle the mass assembly of
units using standard equipment. Under the California approach some of our
plants have had to supply one unique requirement area. To add a multiplicity
of additional areas would involve more of our plants with considerably more
complexity. The extent of this complexity would vary with eachplant and its
car line mix.
In summary, the introduction of catalysts in several select
areas is not in our opinion feasible or practicable from the standpoint of the
F-4
-------
legislative, regulatory, enforcement and service needs. The situation is
further compounded by those problems associated with the assembly and dis-
tribution of motor vehicles. It is our opinion that the time element is too
short for effective implementation by both local governments, manufacturers
and dealers. The best limited manufacture approach is to provide for catalyst
in vehicles in California only in model year 1975.
F-5
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APPENDIX G
STATE OR REGIONAL CONSIDERATIONS
This appendix is an overview of Section 5 of the main body of the
report. It is presented here in briefing chart format to enable the reader
to quickly grasp the essential ideas and facts without having to read
Section 5 in detail.
G-l
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TWO-CAR STRATEGY ISSUES
STATE OR REGIONAL CONSIDERATIONS
REACTIONS TO TWO-CAR STRATEGY
BACKGROUND/EXPERIENCE RELATED TO
VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
CAR INSPECTION PROGRAMS
RETROFIT PROGRAMS
REGION-PECULIAR FACTORS
CALIFORNIA
REACTIONS TO TWO - CAR STRATEGY
NEW CALIFORNIA LAWS WOULD BE NEEDED TO RESPOND TO FEDERAL PROGRAM
FOR TWO CAR STRATEGY - PRESENT LEGAL PROCEDURE FOR IMPLEMENTING
AUTOMOBILE EMISSION CONTROL PROGRAMS INVOLVES REVIEW BY CALIFORNIA
AIR RESOURCES BOARD (CARBI, FOLLOWED BY AUTHORIZATION TO DEPARTMENT
OF MOTOR VEHICLES (DMV) FOR SURVEILLANCE AND ENFORCEMENT
IF PRICE DIFFERENTIAL BETWEEN TWO CLASSES OF CARS WERE SIGNIFICANT,
PROBLEM WOULD BE CREATED BY RESIDENTS BUYING LESS STRINGENTLY
CONTROLLED CARS IN NEVADA OR ARIZONA - CURRENT CALIFORNIA LAW ON NEW
CAR EMISSION STANDARDS PERTAINS ONLY TO CARS FIRST SOLD AND REGISTERED
IN STATE
ASSUMING THE USE OF CATALYST SYSTEMS FOR 1975, AN ADEQUATE SUPPLY OF
BOTH LEADED AND NON-LEADED GASOLINE WOULD BE REQUIRED FOR THE
POPULATION OF NEW, USED AND NON-RESIDENT CARS. OUT-OF-STATE SUPPLY OF
NON-LEADED GAS WOULD ALSO BE REQUIRED FOR TRIPS OUTSIDE OF STATE
BOUNDARIES
GEOGRAPHY OF STATE BORDERS WOULD MAKE THE PROBLEM OF CONTROL
SIMPLIER THAN IN OTHER REGIONS
G-2
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CALIFORNIA
REACTIONS TO TWO - CAR STRATEGY (Cont'dl
A ONE-YEAR STATEWIDE PROGRAM MIGHT BE ACCEPTABLE IF EPA MANDATES A
SUPPLY OF NON-LEADED GASOLINE THROUGHOUT COUNTRY
CALIFORNIA DOES NOT WANT TO BECOME A "GUINEA PIG" FOR THE DEVELOPMENT
OF THE CATALYTIC CONVERTER - CONCERN IS THAT A PROGRAM OF INDEFINITE
DURATION WOULD LEAD TO THE EVOLUTION OF TWO PERMANENTLY DIFFERENT
CONTROL SYSTEMS IN THE U. S.
REGIONAL CONTROL WITHIN CALIFORNIA {for example, the South Coast plus San Diego
air basins) MIGHT BE ENFORCEABLE. HOWEVER, STATE LAWS CONCERNING
THE IDENTIFICATION OF RESIDENCY ON REGISTRATION WOULD HAVE TO BE
CHANGED
PROBLEM OF REGIONAL CONTROL WITHIN CALIFORNIA WOULD BE CONVINCING
LEGISLATORS TO ACCEPT CONTROL OR NON-CONTROL IN THEIR RESPECTIVE
JURISDICTIONS
CALIFORNIA IS PRESENTLY OPERATING A REGIONAL STRATEGY WITH RESPECT
TO RETROFIT EMISSION CONTROL SYSTEMS FOR 1955 - 1965 MODEL YEAR CARS
CALIFORNIA
BAKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
ANNUAL REGISTRATION MANDATORY - REREGISTRATIONS IMPLEMENTED BY MAIL
FROM SACRAMENTO DMV - REGISTRATION DEADLINE FEBRUARY 15
CERTIFICATION OF COMPLIANCE WITH EMISSION LAWS REQUIRED AS A CONDITION
OF REGISTRATION FOR VEHICLES REGISTERING FROM OUT-OF-STATE AND FOR
REREGISTERING USED VEHICLES ON TRANSFER OF OWNERSHIP - NEW CARS ARE
CERTIFIED BY DEALERS TO BE EQUIPPED WITH CALIFORNIA-TYPE EMISSION
CONTROLS
REGISTRATION IS BASED ON COUNTY OF RESIDENCE. PRIMARILY FOR THE PURPOSE
OF DISBURSING LICENSE FEE AND GAS TAX REVENUES TO LOCAL JURISDICTIONS -
REGISTRANT CERTIFIES BY SIGNATURE THAT HE HAS RESIDED IN SPECIFIED
COUNTY
NO PROOF OF ADDRESS IS REQUIRED - BUSINESS OR RESIDENCE ADDRESS MAY BE
GIVEN - NOT ILLEGAL TO GIVE ADDRESS DIFFERENT FROM LOCATION CAR IS
DOMICILED
OUT-OF-STATE VEHICLES REQUIRED TO REGISTER IN STATE WHEN CURRENT
REGISTRATION LEGALLY EXPIRES, BUT NOT LONGER THAN ONE YEAR DURATION
G-3
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CALIFORNIA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
SAFETY INSPECTION PROGRAM
SCHEDULED SAFETY INSPECTION IS NOT AN ESTABLISHED REQUIREMENT
FOR CALIFORNIA CARS
CURRENT PVI (Passenger Vehicle Inspection) PROGRAM CONSISTS OF RANDOM
INSPECTION BY HIGHWAY PATROL TEAMS 71 FIVE MAN TEAMS LOCATED
THROUGHOUT THE STATE EACH TEAM PROCESSES ABOUT 150 CARS/DAY
INSPECTION TAKES 3 TO 5 MINUTES LIGHTS. WIPERS. TIRES AND OTHER
SAFETY EQUIPMENT CHECKED GROSS SURVEY OF SMOG DEVICES IS
ALSO MADE
CITATIONS REQUIRED TO BE CORRECTED WITHIN 14 DAYS AT STATE - APPROVED
"CLASS A" STATION IF HEADLIGHT AIMING. BRAKES. OR SMOG DEVICES ARE
INVOLVED - ADJUSTMENTS MUST BE VERIFIED AT HIGHWAY PATROL OFFICES
ENFORCEMENT IS TIED TO COLOR CODED WINDSHIELD INSPECTION STICKER
PROGRAM CHECKS 12 TO 15 PERCENT OF CAR POPULATION YEARLY
CALIFORNIA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
EMISSION INSPECTION PROGRAM
SCHEDULED EMISSION INSPECTION IS NOT A REQUIREMENT FOR CALIFORNIA CARS
ALL NEW CALIFORNIA CARS ARE ASSEMBLY-LINE TESTED FOR EMISSIONS: 75%
IDLE. 25"; ONE HOT 7 MODE CYCLE. IN ADDITION 2% QUALITY AUDIT WITH
COLD START CVS CYCLE
ASSEMBLY LINE TESTING PROGRAM IS DESIGNED TO DETECT AND ELIMINATE
HIGH EMITTERS - THOSE EXCEEDING TWO STANDARD DEVIATIONS OF 100-CAR
CONTROL SAMPLE DISTRIBUTION
NEW CAR REGISTRATION REQUIRES DEALER CERTIFICATION THAT VEHICLE IS
EQUIPPED WITH CALIFORNIA CONTROLS - PENALTY FOR ATTEMPTING TO SELL
INVALID VEHICLE IS S5000
ON-THE-ROAO CARS ARE BEING CHECKED IN PILOT INSPECTION PROGRAM TIED
TO PVI SAFETY CHECK - 8 EXHAUST ANALYZERS IN OPERATION STATEWIDE
ROAD CHECK REJECTION RATE IS ABOUT 25% - REPAIRS/ADJUSTMENTS ARE
REQUIRED TO BE MADE AT STATE-APPROVED CLASS A STATIONS WITHIN
14 DAYS
EMISSION CONTROL EQUIPMENT IS ALSO CHECKED ON REGISTERING VEHICLE FROM
OUT OF STATE AND IN TRANSFERRING OWNERSHIP OF 1955 - 1965 MY CARS IN
CERTAIN COUNTIES - OUT-OF-STATE INSPECTION IS TIED TO FEDERAL EMISSION
REQUIREMENTS - TRANSFER OF OWNERSHIP INSPECTION RELATES TO
CALIFORNIA HC/CO RETROFIT PROGRAM
G-4
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CALIFORNIA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
RETROFIT PROGRAM
TWO RETROFIT PROGRAMS ARE IN FORCE - ONE FOR 1955-1965 MY CARS, ONE
FOR 1966-1970 MY CARS
1955 - 1965 PROGRAM IN OPERATION SINCE SEPTEMBER. 1972 - COVERS CARS IN
GEOGRAPHICAL REGION BASICALLY WITHIN SOUTH COAST AIR BASIN. SAN DIEGO
COUNTY, SAN FRANCISCO BAY AREA
TWO DEVICES HAVE BEEN CERTIFIED BY THE CARB - THESE ARE ESSENTIALLY
SPARK RETARD MECHANISMS
IMPLEMENTATION OF 1955-1965 RETROFIT PROGRAM OCCURS THROUGH TRANSFER
OF VEHICLE OWNERSHIP - CERTIFICATE OF COMPLIANCE ISSUED BY STATE-
APPROVED GARAGE, SIGNIFYING THAT VEHICLE HAS BEEN EQUIPPED. IS A
PREREQUISITE FOR REGISTERING VEHICLE DOMICILED IN CONTROL REGION
DMV IS NOT EQUIPPED OR EMPOWERED TO VERIFY ADDRESS OF APPLICANT
1966 - 1970 PROGRAM COMMENCED FEBRUARY, 1973 - FOUR DEVICES HAVE
RECEIVED CERTIFICATION BY CARB - PROGRAM HAS STATEWIDE COVERAGE -
TO BE INTRODUCED SEQUENTIALLY BY COUNTY - FINAL ENFORCEMENT WILL
BE INSTALLATION AS PREREQUISITE FOR REGISTRATION IN 1975
FOR BOTH DEVICES, RETROFIT OF VEHICLES FROM OUT OF STATE WILL BE
REQUIRED FOR REGISTRATION
CALIFORNIA
REGION-PECULIAR FACTORS
1972 AUTOMOBILE REGISTRATION TOTALLED 9. 1 MILLION
25 PERCENT OF AUTOMOBILE POPULATION CHANGES OWNERSHIP EACH YEAR
227,000 NON-RESIDENT VEHICLES REGISTER ANNUALLY 12.5 PERCENTI
CALIFORNIA BORDER SITUATION WOULD MINIMIZE THE DEGRADATION OF AIR
QUALITY DUE TO CIRCULATION OF LESS-STRINGENTLY-CONTROLLED VEHICLES
CALIFORNIA EMISSION STANDARDS LOWER THAN FEDERAL STANDARDS - CALIFORNIA
ONLY TWO-CAR STRATEGY EXISTS NOW. HOWEVER DIFFERENCE BETWEEN CARS
IS SMALL
WITH REGARD TO THE POSSIBILITY THAT RETROFIT MIGHT BE REQUIRED AS A
DETERRENT TO THE PURCHASE OF NEW CARS OUT-OF-STATE, CALIFORNIA
EXPERIENCE WITH CURRENT RETROFIT PROGRAMS INDICATES THAT A MINIMUM
OF 15 MONTHS WOULD BE NEEDED FROM PASSAGE OF LEGISLATION TO FIRST
INSTALLATION. PROCESS INVOLVES TESTING AND APPROVAL BY CARB.
MANUFACTURE AND DISTRIBUTION
G-5
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ALASKA
REACTIONS TO TWO-CAR STRATEGY
1975 EMISSION STANDARDS WILL HAVE LITTLE EFFECT
ON AIR QUALITY IMPLEMENTATION PLAN
FAIRBANKS HAS ICE FOG AND CO PROBLEM IN WINTER
LOWERING CO WILL NOT HELP ICE FOG PROBLEM
WHICH IS CAUSED BY WATER IN EXHAUST
TWO-CAR STRATEGY WON'T WORK IN ALASKA
FAIRBANKS IS NOT RICH COMMUNITY - ADVERSE
REACTION EXPECTED IF THEY ARE SINGLED OUT
FOR MORE EXPENSIVE EMISSION CONTROLS
SERIOUS DOUBTS ABOUT EFFECTIVENESS OF CATALYSTS
IN COLD WEATHER AND UNDER ENGINE IDLING
CONDITIONS
ALASKA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
REGISTRATION HAS CITY AND ZIP CODE
IDENTIFICATION
INSPECTION PROGRAMS
NO VEHICLE SAFETY PROGRAM
NO MANDATORY EMISSION INSPECTION
PROGRAM
VISIBLE EMISSIONS ONLY PROHIBITED
ENFORCED BY LOCAL POLICE
RETROFIT PROGRAMS
NO RETROFIT PROGRAMS
G-6
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ALASKA
REGION-PECULIAR FACTORS
FAIRBANKS IS IN NATURAL BOWL - LONG, STABLE ICE FOG OCCURS
IN WINTER WHEN TEMPERATURE IS BELOW -3
-------
ARIZONA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
YEARLY REGISTRATION IS MANDATORY
ARIZONA IS IN PROCESS OF CONVERTING TO STAGGERED. MONTHLY
REGISTRATION SYSTEM
REGISTRATION IDENTIFIED BY COUNTY
COMPLIANCE WITH PROPOSED EMISSIONS INSPECTION PROGRAM WOULD BE
REQUIRED AS CONDITION FOR REGISTRATION IF AND WHEN PROGRAM IS
AT PRESENT. AFFIDAVIT OF EMISSION CONTROL COMPLIANCE (without
inspection] ACCEPTED FOR REGISTRATION OF USED CARS - MANUFACTURER'S
CERTIFICATION OF COMPLIANCE WITH FEDERAL STANDARDS ACCEPTED
FOR REGISTRATION OF NEW CARS
RECIPROCITY AGREEMENTS PERMIT VEHICLES DOMICILED WITHIN 25
MILE CORRIDOR OF BORDERING STATES TO OPERATE IN ARIZONA
WITHOUT ARIZONA REGISTRATION
ARIZONA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
CAR INSPECTION PROGRAMS
NO SAFETY INSPECTION PROGRAM
PILOT EMISSIONS INSPECTION PROGRAM RUN BY STATE
DEPARTMENT OF HEALTH NOW IN OPERATION - UTILIZES
KEY MODE TEST PROCEDURE
EMISSIONS INSPECTION CURRENTLY IS MANDATORY FOR
STATE VEHICLES - VOLUNTARY FOR PRIVATE VEHICLES
PROGRAM IS FORERUNNER OF MANDATORY EMISSIONS
INSPECTION SCHEME ENVISAGED FOR PHOENIX/TUCSON
AREA - FULL SCALE PROGRAM REQUIRES ENABLING
LEGISLATION - WILL BE BASED ON PILOT PROGRAM
RESULTS TO BE REPORTED TO LEGISLATURE IN 1974 -
ABOUT 22 STATIONS ANTICIPATED
PROGRAM STANDARDS AND PROCEDURES TO BE
ESTABLISHED BY DEPARTMENT OF HEALTH - OPERATION
AND ADMINISTRATION TO BE HANDLED BY DEPARTMENT
OF HIGHWAYS, MOTOR VEHICLE DIVISION
G-8
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ARIZONA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
RETROFIT PROGRAM
NO RETROFIT PROGRAM IN FORCE
DEPARTMENT OF HEALTH HAS LEGAL AUTHORITY TO
CERTIFY RETROFIT DEVICES - HAS RECOMMENDED THAT
RETROFIT DEVICES BE TESTED - NO ACTION TO DATE
ARIZONA RETROFIT MAY IGNORE 1967 AND OLDER CARS -
ESTIMATED TO CONSTITUTE ONLY 25% OF VEHICLE
POPULATION BY 1975
ARIZONA
REGION PECULIAR FACTORS
STATE PASSENGER VEHICLE REGISTRATION IS ABOUT
890,000 - 84% OF CARS ARE IN PHOENIX/TUCSON BASIN
6.4 MILLION OUT-OF-STATE PASSENGER CARS ENTERED
ARIZONA IN 1971 (7 times state registration)
APPROXIMATELY 12% OF VEHICLE MILES TRAVELLED IN
AIR BASIN ATTRIBUTABLE TO OUT-OF-STATE CARS
APPROXIMATELY 30% OF VEHICLE MILES TRAVELLED ON
STATE HIGHWAYS ATTRIBUTABLE TO OUT-OF-STATE CARS
HIGH AMBIENT TEMPERATURES MAY NEGATE POSSIBLE
USE OF VACUUM ADVANCE SPARK DISCONNECT AS
RETROFIT TECHNIQUE
G-9
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COLORADO
REACTION TO TWO-CAR STRATEGY
DENVER METROPOLITAN AREA MUST BE CONTROLLED IN ORDER TO MEET
NATIONAL AIR QUALITY STANDARDS
ALTITUDE ADJUSTMENT ALSO REQUIRED
EFFECTIVE ENFORCEMENT DEMANDS STATEWIDE CONTROL
NO EXISTING OR PROPOSED LAWS TO ENFORCE REGIONAL CONTROLS
LEGISLATURE IS AGAINST STRATEGY LIMITED TO THE DENVER AIR BASIN
ONE YEAR IMPLEMENTATION IS INSUFFICIENT TO IMPROVE THE AIR QUALITY
NEW CAR SALES ARE 10% OF CAR POPULATION OF WHICH 39% ARE
SMALL FOREIGN CARS
CAR SALES WOULD BE ADVERSELY AFFECTED
A 6% SALES TAX IN DENVER HAS REDUCED CAR SALES IN DENVER
AN ADDED COST FOR LOCAL EMISSION CONTROL WOULD FURTHER
DECREASE SALES
DISTANCE TO NEXT AIR BASIN IS LESS THAN 60 MILES
EASY TO PURCHASE CAR OUT OF CONTROL REGION
POSTAL BOX NUMBER IS AN ACCEPTABLE REGISTRATION ADDRESS
COLORADO
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
NO ACTUAL RESIDENCE VERIFICATION
REGISTRATION SURVEILLANCE IMPRACTICABLE WITH
PRESENT MANPOWER AND BUDGET
NO ENFORCEMENT POLITICALLY POSSIBLE BELOW
COUNTY LEVEL
POSTAL BOX NUMBER IS A LEGAL RESIDENCE
NEW RESIDENTS MUST REGISTER WITHIN 30 DAYS OF
. ESTABLISHING RESIDENCE
MANUAL HANDLING OF REGISTRATION/NO COMPUTER
RECORDS
MONTHLY STAGGERED STATE WIDE REGISTRATION
A CAR IS DEEMED TO BE A USED CAR AFTER FIRST
SALE
G-10
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COLORADO
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
INSPECTION PROGRAMS
STATEWIDE AUTOMOBILE SAFETY INSPECTION MANDATORY TWICE A YEAR/NOT
RELATED TO REGISTRATION
THE LEGISLATURE HAS NOT ENACTED LAWS FOR AUTOMOBILE EMISSION
INSPECTIONS AND IS NOT LIKELY TO DO IT THIS YEAR
PROPOSED INSPECTION PROGRAM TO BE CONCURRENT WITH SAFETY INSPECTION
PROGRAM AND TO BE STATEWIDE
PROPOSED INSPECTION PROGRAM TO BE MADE BY STATE LICENSED MECHANICS
WITH REPAIRS PERMISSIBLE ON THE SPOT
PROPOSED INSPECTION PROGRAM TO USE IDLE TEST
PRESENT PLANS WOULD SET THE EMISSION STANDARDS ANNUALLY SO THAT 30% OF
TESTED CAR WOULD FAIL INSPECTION
EFFECTIVITY IS SEEN IN 1980 AT THE EARLIEST
RETROFIT PROGRAMS
EMISSION CONTROL RETROFIT PROGRAM HAS NOT BEEN AUTHORIZED/NONE LIKELY
IN NEAR FUTURE
EGR + VACUUM SPARK RETARD IS FAVORED AS A POSSIBLE RETROFIT KIT
COLORADO
REGION PECULIAR SITUATIONS
COLORADO REQUIRES AN EXEMPTION FROM THE FACTORY SET NON-TAMPERING
FEDERAL REGULATION BECAUSE HIGH ALTITUDES
MOST AUTOS OPERATED AT 5000 ft ELEVATION
CARBURATORS IN EXISTENCE OR IN DEVELOPMENT CANNOT HANDLE THE
ALTITUDE COMPENSATION RANGE REQUIRED IN COLORADO TO MEET
FEDERAL STANDARDS
FACTORY TUNING RESULTS IN IMPROPER VEHICLE OPERATION IN COLORADO
ALL CURRENTLY USED VACUUM OPERATED DEVICES REQUIRE CHANGE OF
SPRINGS TO OPERATE PROPERLY
CAR TUNED PER MANUFACTURER'S SPECIFICATIONS SHOWS A 160-170%
INCREASE IN CO AND HC EMISSIONS AT 5000 ft ELEVATION
1,179,199 PASSENGER CARS REGISTERED IN STATE IN 1971
694,383 PASSENGER CARS REGISTERED IN DENVER AIR REGION (58. 9%| IN 1971
10% OF STATE CAR POPULATION ARE NEW CARS, OF WHICH 28.6% ARE
FOREIGN IMPORTS
G-ll
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MARYLAND
REACTIONS TO TWO-CAR STRATEGY
CALIFORNIA-ONLY STRATEGY WOULD IMPACT MANYLAND AIR
QUALITY IMPLEMENTATION PLAN - WOULD REQUIRE
HEAVIER RELIANCE ON OTHER TRANSPORTATION CONTROL
STRATEGIES
TWO-CAR STRATEGY WITHIN STATE IS COMPLICATED BUT
COULD BE WORKED OUT - THEY WOULD NOT WORRY ABOUT
VEHICLE REGISTRATION CONTROL FOR ONE YEAR PERIOD
SIMPLER TO HAVE SAME CONTROLS FOR ENTIRE STATE
WASHINGTON DC METRO AREA (with two Maryland Counties)
AS CONTROL REGION WITH BALTIMORE EXCLUDED WOULD
CREATE PROBLEMS
WOULD PREFER 1975 EMISSION STANDARDS OR BEST
DELIVERABLE DETROIT STANDARDS FOR EVERYONE
DO NOT FAVOR PERMANENT TWO-CAR STRATEGY
MARYLAND
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
REGISTRATION IDENTIFIED BY COUNTY AND ZIP CODE
CHECK ON CAR NOW POSSIBLE ONLY ON TRANSFER OF
TITLE
INSPECTION PROGRAMS
SAFETY INSPECTION ONLY ON TRANSFER OF TITLE
SAFETY INSPECTION WITH STATE LICENSED GARAGES
(2000 garages in state)
NO EMISSIONS INSPECTION NOW - NO ENABLING LEGISLATION
RETROFIT PROGRAM
RETROFIT PROGRAM INCORPORATED IN STATE AIR QUALITY
IMPLEMENTATION PLAN
NO LEGISLATION FOR RETROFIT PROGRAM
G-12
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MARYLAND
REGION PECULIAR FACTORS
STATE LEGISLATURE MEETS ONLY FOR THREE
MONTHS OF EACH YEAR - COULD IMPACT ON
RESPONSE TIME FOR LEGISLATION IF REQUIRED
STATE OF MARYLAND COULD CONTAIN TWO
CONTROL REGIONS - BALTIMORE AREA AND
COUNTIES IN WASHINGTON METRO AREA
FIVE PERCENT OF THROUGH TRAFFIC IN AND
OUT OF BALTIMORE IS FROM OUT-OF-STATE -
CAN'T CONTROL THIS
MASSACHUSETTS
REACTIONS TO TWO-CAR STRATEGY
CALIFORNIA-ONLY STRATEGY WOULD IMPACT AIR QUALITY
IMPLEMENTATION PLANS - WITH 1975 EMISSION STANDARDS
FOR NEW CARS, THEY, JUST MEET CO AIR QUALITY
STANDARDS IN 1977 X
FORESEE MANY PROBLEMS WITH REGIONAL TWO-CAR
STRATEGY IN STATE - ANTICIPATE ADVERSE SENTIMENT OF
DISCRIMINATION AGAINST PEOPLE IN METROPOLITAN AREA
HAVING TO PURCHASE MORE EXPENSIVE CARS
IF BOSTON AREA ONLY IS REGIDLY CONTROLLED, EXCLUSION
OF SPRINGFIELD, MASSACHUSETS5 MIGHT BE QUESTIONED -
IT HAS CO PROBLEM SIMILAR TO BOSTON
WOULD LIKE TO SEE ONE CLASS OF LOW EMISSION CARS
G-13
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MASSACHUSETTS
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
STAGGERED REGISTRATION BY MAIL OR PAYMENT AT REGISTRY
OFFICE
NO-FAULT INSURANCE REQUIRED - NEED PROOF OF INSURANCE
TO GET REGISTRATION (certification form filled out by Insurance
company)
NO ENFORCEMENT BY STATE - ONLY SPOT CHECK BY INSURANCE
COMPANIES. WHO HAVE INCENTIVE BECAUSE OF POTENTIALLY
LARGE RATE DIFFERENTIAL FOR DIFFERENT LOCALITIES.
MANY BOSTON STUDENTS USE HOME ADDRESSES TO GET LOW
RATES
FALSE ADDRESS ON INSURANCE COULD INVALIDATE INSURANCE
COMPANY'S LIABILITY
INSPECTION PROGRAMS
SEMI-ANNUAL SIMPLE SAFETY INSPECTION NOW, BY PRIVATE
GARAGES (inspection deadlines - April 15 and October IS)
PROOF OF REGISTRATION NEEDED TO GET INSPECTION STICKER
NO REAL CONTROL ON ISSUANCE OF STICKERS - EASY TO OBTAIN
MAINTENANCE AND EMISSIONS INSPECTION RECOMMENDED IN
IMPLEMENTATION PLAN - BUT NO ENABLING LEGISLATION
RETROFIT PROGRAMS
NONE NOW; NO ENABLING LEGISLATION
MASSACHUSETTS
REGION-PECULIAR FACTORS
ONLY VERY LIMITED AREA IN BOSTON HAS BAD
CO PROBLEM - CAN ACHIEVE COMPLIANCE
GIVEN TIME
THEY ALSO HAVE OXIDANT PROBLEM (on paper) IN
BOSTON, BUT INCIDENCE IS RARE IN REALITY.
STILL SOME WAY TO GO ON MEETING OXIDANT
STANDARDS
G-14
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MINNESOTA
REACTIONS TO TWO-CAR STRATEGY
TWO-CAR STRATEGY IS GREAT FOR CALIFORNIA-ONLY
CASE
STRONGLY OPPOSE METROPOLITAN REGIONAL CONTROL
IF MINNEAPOLIS IS INCLUDED
AIR QUALITY STANDARDS EXCEEDED ONLY IN
DOWNTOWN MINNEAPOLIS - 1974 EMISSION
STANDARD ACCEPTABLE IF TRAFFIC STRATEGIES
WORK
ONLY PROBLEM IS CO BEING 9. 5% OVER AIR
QUALITY STANDARDS IN 1975 - EXPECT
PROBLEM TO DISAPPEAR IN 1976
MINNESOTA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
YEARLY REGISTRATION - COUNTY IDENTIFIED
REGISTRATION CARD NOT REQUIRED TO BE CARRIED
IN VEHICLE NOR ON THE PERSON OF THE OWNER
INSPECTION PROGRAMS
NO MANDATORY SAFETY INSPECTION
NO EMISSION INSPECTION EXISTING OR PLANNED
RETROFIT PROGRAM
NON PLANNED
REGION-PECULIAR FACTORS
MOST OF STATE IS RURAL - THEY DO NOT SEE
NECESSITY FOR RIGID CONTROL IF NON-OPTIMUM
EMISSION CONTROL SYSTEM IS REQUIRED
G-15
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NEW JERSEY
REACTIONS TO TWO-CAR STRATEGY
STATEWIDE CONTROL IS THE ONLY FEASIBLE OPTION BECAUSE
OF THE INTRASTATE PROXIMITY OF METROPOLITAN
POPULATION CENTERS
BULK OF TRAFFIC INTO AND THROUGH NEW JERSEY IS FROM
NEW YORK AND PHILADELPHIA, MAKING THE EFFECTIVITY
OF A NEW JERSEY-ONLY CONTROL SCHEME QUESTIONABLE
NO MECHANISM EXISTS FOR CONTROL OF OUT-OF-STATE
REGISTRATIONS BY VEHICLES DOMICILED IN NEW JERSEY --
THIS COULD BECOME SIGNIFICANT IF PRICE DIFFERENTIAL
BETWEEN TWO CLASSES OF CARS WAS LARGE
INTERSTATE REGIONAL CONTROL BY COALITION OF STATE
GOVERNMENTS WOULD BE BEST, BUT THE POSSIBILITIES
FOR A COOPERATIVE VENTURE OF THIS KIND SEEM REMOTE
NEW JERSEY
BACKGROUND'EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
YEARLY REGISTRATION IS MANDATORY Ion anniversary of
vehicle purchase!
REGISTRATION IS NOT IDENTIFIED BY COUNTY OR OTHER
LOCAL JURISDICTION
VALID SAFETY INSPECTION CERTIFICATE IS A CONDITION
OF REGISTRATION
LAW REQUIRES NEW RESIDENTS TO REREGISTER VEHICLES
IN NEW JERSEY WITHIN 6 MONTHS -- THERE IS NO OVERT
ENFORCEMENT OF THIS REQUIREMENT
TRUCK INDUSTRY REGISTERS VEHICLES OUT-OF-STATE BUT
USES DEPOTS WITHIN STATE -- BORDER RESIDENTS CONTINUE
TO RENEW OUT-OF-STATE FOR FEE OR INSPECTION
ADVANTAGES -- THERE IS NO MECHANISHM FOR EFFECTIVELY
CONTROLLING THIS
G-16
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NEW JERSEY
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
SAFETY INSPECTION PROGRAM
YEARLY INSPECTION REQUIRED AS A CONDITION FOR
REGISTRATION
e INSPECTIONS CONDUCTED AT 40 STATE OWNED AND
OPERATED STATIONS - TOTAL OF 69 INSPECTION LANES -
MOTORIST CAN USE ANY CONVENIENT STATION LOCATION
THROUGHOUT STATE
INSPECTION TIME IS 5 MINUTES (waits up to one hour) -
INCLUDES BRAKES, BALL JOINTS, HORNS, LIGHTS, WIPERS
IN EVENT OF FAILURE, OWNER GETS TWO WEEKS FOR
REPAIR AND REINSPECTION
REPAIR OR ADJUSTMENT CAN BE MADE AT ANY GARAGE -
FAULTY REPAIR OR UNNEEDED WORK HAS BEEN BASIS
FOR CRITICISM OF THE N.J. SYSTEM
VALID INSPECTION IS IDENTIFIED BY COLOR-CODED
WINDSHIELD STICKER
NEW JERSEY
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
EMISSIONS INSPECTION PROGRAM
PROGRAM INITIATED JULY. 1972
COMBINES EMISSIONS INSPECTION WITH EXISTING SAFETY INSPECTION
OPERATION
HC AND CO TESTED AT IDLE AND COMPARED WITH SPECIFIED INSPECTION
STANDARDS FOR VEHICLE MODEL YEAR
STANDARDS TO BE MADE PROGRESSIVELY MORE SEVERE - CURRENT FAIL RATE
IS ABOUT 10 PERCENT; WILL INCREASE TO 1/3 BY JULY. 1975
AT PRESENT. REPAIR OR ADJUSTMENT FOLLOWING EMISSIONS TEST FAILURE IS
ON VOLUNTARY BASIS; BECOMES MANDATORY JULY 1, 1973
TO DATE HAVE TESTED OVER ONE MILLION CARS - 11 PERCENT HAVE FAILED
40 PERCENT OF FAILED VEHICLES GETTING VOLUNTARY REPAIRS/ADJUSTMENTS
FAIL A SECOND TIME, PRIMARILY AS A RESULT OF INADEQUATE MECHANIC
TRAINING
ULTIMATELY. FAILURE OF EITHER EMISSIONS OR SAFETY TEST WOULD BE
BASIS FOR DENYING VEHICLE REGISTRATION
G-17
-------
NEW JERSEY
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
RETROFIT PROGRAM
NEW JERSEY TRANSPORTATION CONTROL PLAN INCLUDES
A PROPOSED RETROFIT STRATEGY
INITIAL APPROACH WOULD BE TO UTILIZE EQUIPMENT
ALREADY CERTIFIED BY STATE OF CALIFORNIA
TO BE EFFECTIVE, THE PROGRAM WOULD REQUIRE
RETROFIT ON A STATEWIDE OR INTERSTATE REGIONAL
BASIS, AND WOULD FURTHER REQUIRE ALL VEHICLES
OPERATING WITHIN CONTROL BOUNDARIES TO BE EQUIPPED
ENFORCEMENT WOULD TAKE THE FORM OF TIGHTENING
INSPECTION STATION STANDARDS, ALONG WITH EMISSIONS
ROAD CHECKS SIMILAR TO THE CALIFORNIA PVI
PROGRAM
NEW JERSEY
REGION-PECULIAR FACTORS
PASSENGER VEHICLE REGISTRATION IS ABOUT 3-1/4 MILLION
NEW JERSEY IS SANDWICHED BETWEEN TWO LARGE OUT-OF-
STATE METROPOLITAN CENTERS AND IS SUBJECT TO
SIGNIFICANT TRAFFIC FROM AND BETWEEN THESE CENTERS
88 PERCENT OF NEW JERSEY CARS ARE LOCATED IN TWO AIR
QUALITY CONTROL REGIONS: METROPOLITAN PHILADELPHIA
INTERSTATE REGION AND NEW JERSEY - NEW YORK -
CONNECTICUT INTERSTATE REGION
G-18
-------
NEW YORK
REACTIONS TO TWO-CAR STRATEGY
NEW YORK CITY
NEW YORK METROPOLITAN AREA MUST BE ONE OF THE
STRINGENTLY CONTROLLED REGIONS IF TRANSPORATION
CONTROL PROGRAM TO MEET AIR QUALITY GOALS ARE
TO BE MET
PRACTICALLY SPEAKING. ONLY THE NEW YORK
METROPOLITAN REGION AND SURROUNDING COUNTIES
WOULD NEED TO BE CONTROLLED
RETROFIT OF CARS TAKING UP RESIDENCE IN NEW YORK
MAY BE AN ISSUE
FOR ONE YEAR PROGRAM, TRAFFIC INTO AREA FROM
UNCONTROLLED REGIONS COULD BE NEGLECTED; FOR
EXTENDED PROGRAM, MIGHT CONSIDER A DETERRENT
SUCH AS CITY DAY USE TAX
INSTITUTIONAL PROBLEMS RELATED TO THE
IMPLEMENTATION AND ADMINISTRATION OF A LOCAL
CONTROL PROGRAM COULD BE SEVERE
NEW YORK
REACTIONS TO TWO-CAR STRATEGY (Cont'd)
NEW YORK STATE
REGIONAL CONTROL PROGRAM IS ACCEPTABLE IF IT IS THE
ONLY PRACTICAL WAY TO IMPLEMENT 1975 EXHAUST
EMISSION STANDARDS
IN ADDITION TO NEW YORK CITY, OTHER AREAS SUCH AS
SCHENECTADY SHOULD BE CONSIDERED FOR CONTROL
STATEWIDE CONTROL MAY INVOLVE LESS OF AN
ADMINISTRATION PROBLEM, BUT FROM THE STANDPOINT
OF COST, AND EFFECTIVITY, LOCAL CONTROL (where
required) MAKES MORE SENSE
CARS ENTERING THE METROPOLITAN AREA FROM LESS
CONTROLLED REGIONS MAY MAKE ATTAINMENT OF
LOCAL AIR QUALITY GOALS MORE DIFFICULT -- HOWEVER,
FOR A ONE-YEAR PROGRAM. THIS ADDITIONAL BURDEN
MAY BE ACCEPTABLE
DMV BELIEVES IT WOULD BE EASY FOR THE 5 COUNTIES
OF NYC TO ISSUE STICKER IDENTIFYING COMPLIANCE WITH
1975 EMISSION CONTROLS - CURRENTLY CONSIDERING
STICKER SYSTEM FOR USE IN CONNECTION WITH PROPOSED
METROPOLITAN NYC RETROFIT PROGRAM
G-19
-------
NEW YORK
EXPERIENCE/BACKGROUND RELATED TO VECHICLE CONTROL
VEHICLE REGISTRATION CONTROL
MANDATORY TO REGISTER EACH YEAR -- REGISTRATION IS STAGGERED
THROUGHOUT REGISTRATION YEAR (January - December! -- IMPLEMENTED
BY MAIL INVITATIONS
REGISTRATION NOT ON COUNTY BASIS -- ADDRESS OF RESIDENCE ON
REGISTRATION USED SOLELY FOR RENEWAL INVITATIONS. THERE IS NO
LAW WHICH REQUIRES REGISTRANT TO REVEAL ADDRESS OF DOMICILE
OR PREVENTS HIM FROM GIVING ANOTHER ADDRESS
PROOF OF VEHICLE SAFETY INSPECTION Iboth new and used cars) ALONG
WITH PROOF OWNERSHIP AND INSURANCE IS REQUIRED FOR REGISTRATION
VALID RESIDENT REGISTRATIONS ARE IDENTIFIED BY LICENSE TAG STICKER
COLOR AND PRINTED EXPIRATION DATE
NEW YORK LICENSE TAGS ARE TRANSFERRED FROM VEHICLE TO VEHICLE
BY REGISTRANT
OUT OF STATE CARS REQUIRED TO REGISTER WITHIN 60 DAYS FROM
ESTABLISHMENT OF RESIDENCY IN NEW YORK
NEW YORK
EXPERIENCE/BACKGROUND RELATED TO VEHICLE CONTROL
CAR INSPECTION PROGRAMS
NY SAFETY INSPECTION PROGRAM HAS BEEN IN OPERATION SINCE 1956
SAFETY INSPECTION REQUIRED FOR NEW VEHICLES. UPON TRANSFER
OF OWNERSHIP, AND YEARLY THEREAFTER WITHIN ONE YEAR FROM
LAST DAY OF MONTH IN WHICH LAST SUCCESSFUL INSPECTION
COMPLETED
INSPECTIONS CONDUCTED BY 11.000 PRIVATELY OWNED STATIONS
12400 in NYCI. LICENSED AND SUPERVISED BY STATE -- INSPECTION
COSTS S3 -- VALID CARDS ARE ISSUED COLOR-CODED AND DATED
WINDSHIELD STICKER
PART OF INSPECTION FEE RETURNED TO STATE AND IS USED TO
FINANCE A SPECIAL POLICE ENFORCEMENT AND INSPECTION GROUP WHICH
ALSO INVESTIGATES ALLEGED MALPRACTICES
NO EMISSIONS INSPECTION PROGRAM CURRENTLY IN FORCE
STATE IMPLEMENTATION PLAN PROVIDES FOR EMISSION INSPECTION
PROGRAM -- 800 STATE FRANCHISED INSPECTION STATIONS. 140 IN
NY METROPOLITAN AREA BY 1975 -- TAXICABS: THRICE YEARLY:
HEAVY DUTY: TWICE YEARLY: PASSENGER CARS: ONCE YEARLY
G-20
-------
NEW YORK
EXPERIENCE/BACKGROUND RELATED TO VEHICLE CONTROL
RETROFIT PROGRAMS
NO PROGRAMS CURRENT
STATE IMPLEMENTATION PLAN PROPOSES:
METROPOLITAN NY AREA: CATALYST SYSTEM RETROFIT
FOR ALL CARS 1974 MY AND OLDER
ALL OTHER AREAS WHERE NECESSARY: AIR-BLEED
SYSTEM RETROFIT FOR PRE-1968 MY CARS
LEGISLATION PROPOSED BUT NOT YET PASSED * -- VEHICLE
CODE STATES THAT EMISSIONS INSPECTION WILL BE ADDED
TO SAFETY INSPECTION PROGRAM AS SOON AS A PRACTICAL
SCHEME HAS BEEN DEFINED BY THE DMV IN CONSULTATION
WITH THE COMMISSIONER OF ENVIRONMENTAL CONSERVATION
* NY State Legislature adjourns in April -- reconvenes January 1974
NEW YORK
REGION-PECULIAR FACTORS
6. 1 MILLION PASSENGER CARS REGISTERED IN STATE
1.6 MILLION PASSENGER CARS REGISTERED IN NEW YORK CITY
31% OF MANHATTAN CAR POPULATION IS NEW EACH YEAR
75,000 CARS PER DAY 14.6% OF NYC registrmionsi ENTER NYC FROM OUTSIDE
METROPOLITAN AREA
60% OF NYC TAXI FLEET OR ABOUT 11,000 VEHICLES OPERATE IN MANHATTAN.
THESE ACCOUNT FOR 60% OF THE DOWNTOWN/MIDTOWN VMT AND CONTRIBUTE
40% OF THE CO EMISSIONS. 45% IS CONTRIBUTED BY TRUCKS AND ABOUT 15%
BY PASSENGER CARS
CONTROLLING TAXIS/NEW PASSENGER CARS TO 1974 INSTEAD OF 1975 STANDARDS
WOULD REDUCE CO EMISSION REDUCTION IN 1975 FROM 50 TO 20 PERCENT
(midtown Manhattan)
ON A METROPOLITAN-WIDE BASIS, CO IS NOT TOO BAD A CONTROL PROBLEM.
REAL DIFFICULTY IS MEETING OXIDANT STANDARD--HC EMISSIONS IN 1975
HAVE TO BE REDUCED BY 51 PERCENT, EITHER BY RETROFIT OR REDUCTION
IN VMT
G-21
-------
OREGON
REACTIONS TO TWO-CAR STRATEGY
PORTLAND METROPOLITAN AREA MUST BE CONTROLLED IN ORDER TO MEET
NATIONAL AIR QUALITY STANDARDS
EFFECTIVE ENFORCEMENT DEMANDS STATEWIDE CONTROL
NO EXISTING OR PROPOSED LAWS TO ENFORCE TWO CAR CONTROL STRATEGY
LOCAL RESTRICTIONS ARE LIKELY TO BE UNPOPULAR
PREVIOUS POOR EXPERIENCE ENCOUNTERED WITH AUTOMOBILE SAFETY
CONTROL LIMITED TO THE PORTLAND METROPOLITAN AREA
ON THE OTHER HAND. CONTROL WITHIN ENTIRE PORTLAND AIR BASIN
IMPOSSIBLE TO JUSTIFY - SEVEN COUNTIES OUT OF TEN ARE MOSTLY RURAL
OREGON SUGGESTS CONTROL ZONE COMPRISED OF THREE COUNTIES CONTAINING
85% OF PORTLAND TRAFFIC
ONE YEAR IMPLEMENTATION HAS LITTLE IMPACT SINCE NEW CAR SALES ARE
ONLY 7. 5% OF CAR POPULATION
CAR SALES WOULD BE ADVERSELY AFFECTED
DISTANCE TO RURAL REGIONS IS SHORT
DIFFICULT TO GET LAWS RESTRICTING DEALER COMMERCE TO LOCAL
OREGON
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
YEARLY REGISTRATION MANDATORY
REGISTRATION PROCEDURE COMPUTERIZED
MONTHLY STAGGERED STATEWIDE REGISTRATION
REGISTRATION STATISTICS BY POSTAL ZIP CODE/COUNTY
REGISTRATION SURVEILLANCE IMPRACTICABLE WITH
PRESENT MANPOWER AND BUDGET
BUSINESS ADDRESS OR POSTAL BOX NUMBER IS A
LEGAL RESIDENCE
NEW RESIDENTS MUST REGISTER AFTER OUT-OF-STATE
REGISTRATION EXPIRES
ONCE REGISTERED VEHICLE IS DEFINED AS A USED
CAR
G-22
-------
OREGON
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
CAR INSPECTION PROGRAMS
NO SAFETY OR EMISSION CONTROL PROGRAMS
DEPARTMENT OF ENVIRONMENTAL QUALITY HAS AUTHORITY TO IMPLEMENT
AN INSPECTION PROGRAM
NO BUDGET ALLOCATED
BEING DEBATED IN LEGISLATURE
NO ACTUAL EXPERIENCE WITH EMISSION SYSTEM INSPECTIONS
INSPECTION PROGRAM TO BE RUN BY STATE AND TIED IN WITH AUTOMOBILE
REGISTRATION
INSPECTION PROGRAM IS FOR PORTLAND AREA ONLY
3 COUNTIES OF 10 IN BASIN
INSPECTION PROGRAM TO USE KEY-MODE TEST
PROPOSED EFFECTIVITY IS I JANUARY 1974 WITH MANDATORY REPAIRS
STARTING 1 JANUARY 1975
STATEWIDE INSPECTION PLAN WAS NOT FORMULATED
COULD ONLY JUSTIFY 3 COUNTIES SINCE OTHERS HAD NO AUTO
POLLUTION PROBLEM
STUDIES SHOWED MOST TRAFFIC IN 3 COUNTIES
REGIONAL INSPECTION STRATEGY WAS ACCEPTED BECAUSE OF LIMITED
PROBLEM AREA
OREGON
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
RETROFIT PROGRAM
NO RETROFIT PROGRAM
PLANNED
NOT JUSTIFIED IN VIEW
OF OREGON AIR
QUALITY CONDITIONS
G-23
-------
OREGON
REGION PECULIAR FACTORS
1,361.203 PASSENGER CARS. REGISTERED
IN STATE IN 1972
545,601 PASSENGER CARS REGISTERED
IN TRI-COUNTY PORTLAND AREA (40%)
7.5%OF STATE CAR POPULATION ARE
NEW CARS
PORTLAND AIR BASIN IS LARGELY RURAL
ONLY 3 COUNTIES OUT OF 10 WOULD
BENEFIT BY CONTROLS
FIVE WASHINGTON COUNTIES IN PORTLAND
AIR BASIN CONTRIBUTE ONLY 6% TO
THE PORTLAND CITY TRAFFIC
PENNSYLVANIA
REACTIONS TO TWO-CAR STRATEGY
CALIFORNIA-ONLY STRATEGY WOULD RESULT IN
SERIOUS COMPROMISE OF PENNSYLVANIA AIR
QUALITY IMPLEMENTATION PLANS -- EVEN WITH
1975 EXHAUST EMISSION LEVELS. NEEDED
TRANSPORTATION CONTROLS CALL FOR 30%VMT
REDUCTION IN PITTSBURGH, 50% VMT REDUCTION
IN PHILADELPHIA
THESE TWO METROPOLITAN AREAS ACCOUNT FOR
50% OF THE AUTOMOBILES IN THE STATE --
NEVERTHELESS, CONTROL WOULD HAVE TO BE
IMPLEMENTED STATEWIDE TO MAKE ENFORCE-
MENT OF PROGRAM FEASIBLE
FURTHER REQUIRED TO INCLUDE THE FIVE NEW
JERSEY COUNTIES IN THE METROPOLITAN
PHILADELPHIA INTERSTATE AQCR WITHIN THE
ZONE OF CONTROL IN ORDER FOR THE PROGRAM
TO BE EFFECTIVE WITH RESPECT TO LOCAL
AIR QUALITY OBJECTIVES
G-24
-------
PENNSYLVANIA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
YEARLY REGISTRATION IS MANDATORY
REGISTRATION NOT IDENTIFIED BY COUNTY - HARRISBURG
DMV FACILITY PROCESSES ALL REGISTRATION APPLICA-
TIONS VIA DIRECT MAILING
REGISTRATION NOT TIED TO EXISTING SAFETY INSPECTION
PROGRAM - NO PROOF OF VALID INSPECTION REQUIRED
OUT-OF-STATE VEHICLES REQUIRED TO REGISTER WITHIN
30 DAYS OF ESTABLISHING PENNSYLVANIA RESIDENCY --
THERE IS NO OVERT CONTROL PROGRAM TO ENFORCE
THIS
ADDRESS OF RECORD NEED NOT COINCIDE WITH LOCATION
OF DOMICILE FOR VEHICLE
PENNSYLVANIA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
SAFETY INSPECTION PROGRAM
IN OPERATION 20 YEARS
NOT TIED TO VEHICLE REGISTRATION (Bureau of Traffic Safety vs Bureau of
Motor Vehicles!
VEHICLES INSPECTED TWICE A YEAR
INSPECTIONS CONDUCTED IN 16.000 STATE-CERTIFIED, PRIVATELY OWNED
STATIONS la major part of Pennsylvania garage facilities)
NO OFFICIAL FEE LIMIT
COMPLIANCE DESIGNATED BY COLOR-CODED AND DATED WINDSHIELD
INSPECTION STICKER
STATIONS INSPECTED TWICE YEARLY BY STATE POLICE (penalty for malpractice:
$200 fine, loss of certification)
MECHANIC RECERTIFICATION EVERY THREE YEARS MANDATORY
MECHANIC UPGRADING PROGRAM IS UNDERWAY: TASK IS MASSIVE BECAUSE
OF LARGE NUMBER OF CERTIFIED STATIONS
G-25
-------
PENNSYLVANIA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
EMISSION INSPECTION PROGRAM
NO PROGRAM FOR EMISSIONS INSPECTION CURRENTLY IN FORCE
STATE TRANSPORTATION CONTROL STRATEGY PROPOSES
SEVERAL INSPECTION/MAINTENANCE PROGRAM ALTERNATIVES
MOST COST-EFFECTIVE APPROACH IS STATE-RUN INSPECTION
STATIONS LIMITED TO VEHICLES IN PHILADELPHIA AND
PITTSBURGH AREA
NO EXISTING AUTHORITY IN PRESENT LEGISLATION FOR STATE-
OPERATED FACILITIES OR TO GEOGRAPHICALLY LIMIT
INSPECTION PROGRAMS
ACT PASSED BY PENNSYLVANIA GENERAL ASSEMBLY PROVIDES
FOR STATE-WIDE SEMI-ANNUAL EMISSION CONTROL DEVICE
INSPECTION TIED TO SAFETY INSPECTION, REGULATED AS
PRESCRIBED BY SECRETARY OF TRANSPORTATION - NO
DEADLINE FOR IMPLEMENTATION OF THIS PLAN HAS BEEN
SPECIFIED
PENNSYLVANIA
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
RETROFIT PROGRAM
NO RETROFIT PROGRAM IN FORCE; NONE
CONTEMPLATED
TRANSPORTATION CONTROL STUDY CONSIDERED
RETROFIT AS A CONTROL ALTERNATIVE BUT
REJECTED IT BECAUSE OF DIFFICULTY OF
IMPLEMENTATION AND LACK OF ENABLING
LEGISLATION
G-26
-------
PENNSYLVANIA
REGION-PECULIAR FACTORS
TOTAL PASSENGER VEHICLE REGISTRATION IS ABOUT 5. 3 MILLION
50 PERCENT OF ALL AUTOMOBILES IN THE STATE ARE LOCATED
IN THE PHILADELPHIA AND PITTSBURGH AREA
95 PERCENT OF THE VMT IN THE PHILADELPHIA REGION AND
IN THE PITTSBURG METROPOLITAN AREA ARE MADE BY
VEHICLES DOMICILED IN THESE AREAS
PROXIMITY OF PHILADELPHIA TO POPULATION CENTERS IN
NEW JERSEY AS DEFINED BY THE METROPOLITAN PHILADELPHIA
AIR QUALITY CONTROL REGION SUGGESTS THAT AN INTERSTATE
CONTROL REGION BOUNDARY WOULD BE REQUIRED
TEXAS
REACTIONS TO TWO CAR STRATEGY
HOUSTON-GALVESTON AND SOUTHEAST TEXAS-SOUTHERN
LOUISIANA AIR BASINS ARE PREDOMINANTLY STATIONARY-
SOURCE PROBLEM AREAS
NEVERTHELESS, EXISTING AIR QUALITY IMPLEMENTATION
PLANS WOULD BE COMPROMISED IF EMISSION INVENTORIES
COULD NOT TAKE ADVANTAGE OF 1975 AUTOMOBILE
EMISSION LEVELS
ONE YEAR DELAY IN INTRODUCTION OF 1975 EMISSION
STANDARDS WOULD REQUIRE IMPLEMENTATION OF BOTH
MANDATORY INSPECTION/MAINTENANCE AND RETROFIT
PROGRAMS
G-27
-------
TEXAS
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
YEARLY VEHICLE REGISTRATION IS MANDATORY
(Feb -Mar Period)
REGISTRATION NOT TIED IN TO EXISTING SAFETY
INSPECTION PROGRAM
REGISTRATION IS PRIMARILY A TAX COLLECTION
PROCESS - NO SPECIAL MEANS/ FOR ENFORCEMENT
CHANGING VIN FOR THE PURPOSE OF AIDING VEHICLE
IDENTIFICATION AND CONTROL WOULD REQUIRE DMV
COMPUTER SOFTWARE CHANGES (might be possible) AND
NEW STAFF FOR ENFORCEMENT WHERE NONE EXISTS
AT THE PRESENT TIME *
TEXAS
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
SAFETY INSPECTION PROGRAM
ANNUAL SAFETY INSPECTION REQUIRED
NOT TIED TO VEHICLE REGISTRATION
PROGRAM IS ADMINISTERED BY DEPARTMENT OF
SAFETY THROUGH STATE-LICENSED STATIONS -
$2. 00 FEE
^
COMPLIANCE DESIGNATED BY COLOR-CODED
AND DATED WINDSHIELD INSPECTION STICKER
G-28
-------
TEXAS
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
EMISSIONS INSPECTION PROGRAM
NO PROGRAM FOR EMISSIONS INSPECTION CURRENTLY
IN FORCE
FEDERAL LAW PROVISIONS ARE ONLY CONTROL ON
EMISSIONS RELATED TO NEW CAR SALES. NO USED
CAR EMISSION CONTROL REGULATIONS EXIST
SAFETY INSPECTION INCLUDES VISUAL INSPECTION TO
ENSURE THAT ORIGINAL EMISSION CONTROL EQUIPMENT
HAS NOT BEEN REMOVED OR ALTERED
HOUSE BILL 238 (in committee) WILL PROVIDE FOR
STUDIES OF POSSIBLE MANDATORY INSPECTION/
MAINTENANCE PROGRAMS
THE STATE VIEW IS GENERALLY NEGATIVE TO
INSPECTION/MAINTENANCE
LEGAL AUTHORITY FOR INSPECTION/TESTING EXISTS
IN TEXAS CLEAN AIR ACT - ADDITIONAL LEGISLATION
IS REQUIRED TO IMPLEMENT SUCH PROGRAMS
TEXAS
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
RETROFIT PROGRAM
NO RETROFIT PROGRAM IN FORCE; NONE
CONTEMPLATED
NO ENABLING LEGISLATION IS IN FORCE
ALTHOUGH LEGAL AUTHORITY FOR RETROFIT
EXISTS IN THE TEXAS CLEAN AIR ACT
G-29
-------
TEXAS
REGION-PECULIAR FACTORS
TOTAL PASSENGER CAR REGISTRATION IN STATE IS
ABOUT 4.6 MILLION
ABOUT ONE MILLION CARS (20% of Texas total) LOCATED
IN HOUSTON AOCR - ABOUT 200.000 (4.6% of Texas total)
LOCATED IN TEXAS PORTION OF TEXAS-LOUISIANA AOCR
ENTIRE STATE HAS HC PROBLEM
PREDOMINANTLY STATIONARY SOURCE PROBLEM AREAS
INCLUDE: HOUSTON-GALVESTON (18% due to autos);
SOUTHERN LOUISIANA-SOUTHEAST TEXAS (5% due to autos);
AND CORPUS CHRISTY
PREDOMINANTLY MOBILE SOURCE PROBLEM AREAS
INCLUDE AUSTIN-WACO; DALLAS-FT. WORTH;
SAN ANTONIO AND EL PASO
UTAH
REACTIONS TO TWO-CAR STATEGY
TWO-CAR STRATEGY IS FINE IF UTAH IS NOT LOW
EMISSION REGION
PEOPLE IN UTAH NOT TOO EXCITED ABOUT AUTO
POLLUTION PROBLEM - ADVERSE REACTION EXPECTED
IF SALT LAKE CITY IS CONTROLLED REGION
THEIR AUTO POLLUTION PROBLEM IS CO IN THE INNER
CORE OF SALT LAKE CITY (2 miles x 3 miles)
THEY EXAMINED A TYPE OF TWO-CAR STRATEGY
WITH RESPECT TO RIGID CONTROLS IN INNER CORE
OF SALT LAKE CITY - CONCLUDED THAT IT WOULD
BE IMPOSSIBLE TO ADMINISTER
CALIFORNIA-ONLY STRATEGY WILL HAVE MINIMAL
EFFECT ON AIR QUALITY
G-30
-------
UTAH
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
YEARLY REGISTRATION IN JANUARY-FEBRUARY
IDENTIFIED BY COUNTY AND COMMUNITY
NOT TIED IN WITH SAFETY
NO WAY TO KEEP TRACK OF REGISTERED CARS
INSPECTION PROGRAMS
ANNUAL SAFETY INSPECTION AT STATE CERTIFIED
GARAGES - STAGGERED SCHEDULE BY LAST DIGIT
OR LICENSE PLATE
NO EMISSION INSPECTION - ENABLING LEGISLATION
PASSED BY LAST LEGISLATURE, BUT NO PLANS
RETROFIT PROGRAM
HAVE RETROFIT PLANS IN IMPLEMENTATION PLAN
NO REGULATION, ALTHOUGH RETROFIT COULD BE
DONE UNDER INSPECTION LEGISLATION
UTAH
REGION PECULIAR FACTORS
UTAH HAS SMALL POPULATION CONCENTRATED, BIG
AREAS OF STATE ESSENTIALLY UNPOPULATED
COUNTY SUCH AS TOOELE (included in Salt Lake City
region) IS SPARSELY POPULATED. PROBLEM
WOULD ARISE IF TOOELE WAS LOW EMISSION
REGION AND WEBER COUNTY (not included in SLC
region) WITH HIGHER POLLUTION HAD LESS
CONTROLS
G-31
-------
WASHINGTON, D. C.
REACTIONS TO TWO-CAR STRATEGY
D.C. MUST BE INCLUDED AS ONE OF THE METROPOLITAN
CONTROL REGIONS IF DISTRICT'S IMPLEMENTATION PLAN FOR
ACHIEVING NATIONAL AIR QUALITY GOALS IS TO BE SUCCESSFUL
EFFECTIVE ADMINISTRATION AND ENFORCEMENT OF THE PROGRAM
MAY REQUIRE CONTROL THROUGHOUT THE ENTIRE STATES OF
MARYLAND AND VIRGINIA
AVAILABILITY OF UNLEADED GASOLINE FOR OUT-OF-REGION
TRIPS IS A PROBLEM THAT MUST BE RESOLVED
STRATEGY WILL NEVER WORK EFFECTIVELY UNLESS PRICE
DIFFERENTIAL BETWEEN CONTROLLED AND LESS-CONTROLLED
NEW CARS IS MINIMIZED
FOR ONE-YEAR DURATION, PROGRAM MAY NOT BE WORTHWHILE--
WOULD PREFER 1974 CONTROLS IF ACCOMPANIED BY A ONE-
YEAR DELAY IN MEETING AIR QUALITY STANDARDS
WASHINGTON, D.C.
EXPERIENCE/BACKGROUND RELATED TO VEHICLE CONTROL
VEHICLE REGISTRATION CONTROL
D.C. REGISTRATION MANDATORY EACH YEAR (registration
year ends March 31)
ALL VEHICLES BUT "FIELD SERVICE VEHICLES" (< 1%) ARE
REGISTERED INCLUDING DIPLOMATIC, FOREIGN NATIONAL,
FEDERAL, AND DISTRICT GOVERNMENT VEHICLES
REGISTRATION NOT TIED IN WITH YEARLY SAFETY
INSPECTION WHICH FALLS ON ANNIVERSARY OF PURCHASE
LICENSE TAGS ARE ASSIGNED TO REGISTRANT, NOT
TRANSFERRED WITH CHANGE OF OWNERSHIP
« D.C. REGISTRATION REQUIRED WITHIN 30 DAYS FROM
ESTABLISHING RESIDENCY IN DISTRICT
MARYLAND DOES NOT REGISTER VEHICLES ON A COUNTY
BASIS - VIRGINIA REGISTERS ON A COUNTY AND (independent)
ClTY BASIS
G-32
-------
WASHINGTON, D.C.
EXPERIENCE/BACKGROUND RELATED TO VEHICLE CONTROL
CAR INSPECTION PROGRAMS
DISTRICT OF COLUMBIA
« ANNUAL SAFETY INSPECTION FOR A^L D.C. REGISTERED CARS REQUIRED ON
ANNIVERSARY OF NEW CAR PURCHASE OR FIRST REGISTRATION IN DISTRICT
CITY-RUN SYSTEM IN OPERATION SINCE 1939 --- TWO STATIONS, 4 LANES
EACH, I LANE EQUIPPED FOR EMISSIONS - SAFETY INSPECTION ENFORCEMENT
BASED ON COLOR-CODED/DATED WINDSHIELD STICKER
AT PRESENT, EMISSIONS INSPECTION REQUIRED ONLY FOR D.C. GOVERNMENT
VEHICLES -- PILOT PROGRAM FOR EMISSION TESTS OF PRIVATE VEHICLES
UNDERWAY -- ABOUT 1% OF VEHICLES CHECKED
EMISSION INSPECTION PROGRAM FOR ALL D.C. CARS APPROVED BY CITY
COUNCIL AND MAYOR -- PROGRAM BUDGET INCLUDED IN D.C. BUDGET
REQUEST TO CONGRESS
MARYLAND
« SAFETY INSPECTION REQUIRED ONLY ON VEHICLE RESALE -- NO
EMISSIONS INSPECTION
VIRGINIA
TWICE YEARLY SAFETY INSPECTION PROGRAM - NOT TIED TO VEHICLE
REGISTRATION - CONDUCTED BY STATE-LICENSED PRIVATE GARAGES FOR
S2. 00 FEE - ENFORCED BY STATE POLICE ON BASIS OF COLOR-CODED/
DATED WINDSHIELD STICKER
NO CURRENT EMISSIONS INSPECTION PROGRAM - HOPE TO IMPLEMENT
INSPECTION PROGRAM TIED TO SAFETY PROGRAM RUN BY DMV
WASHINGTON, D.C.
EXPERIENCE/BACKGROUND RELATED TO VEHICLE CONTROL
RETROFIT PROGRAMS
NO RETROFIT PROGRAM CURRENTLY IN FORCE
COORDINATED RETROFIT PROGRAM FOR METROPOLITAN WASHINGTON AREA
PROPOSED IN DISTRICT OF COLUMBIA, MARYLAND AND VIRGINIA
IMPLEMENTATION PLANS
CATALYST SYSTEM FOR 1968-1974 MY CARS
MECHANICAL SYSTEM FOR PRE-1968 MY CARS
RETROFIT REQUIREMENT TO BE LINKED TO VEHICLE REGISTRATION IN
WASHINGTON METROPOLITAN REGION
D.C. CITY COUNCIL HAS BLANKET AUTHORITY TO TAKE NEEDED MEASURES
FOR EMISSION CONTROL -- HOWEVER, CONGRESSIONAL APPROVAL
WILL BE REQUIRED
ENABLING LEGISLATION FOR VIRGINIA AND MARYLAND NOT YET DEVELOPED;
VIRGINIA LEGISLATURE NOW OUT OF SESSION -- RECONVENES JANUARY 1974:
MARYLAND LEGISLATURE ADJOURNS IN APRIL
G-33
-------
WASHINGTON, D.C.
REGION-PECULIAR FACTORS
231,300 PASSENGER CARS REGISTERED IN DISTRICT OF COLUMBIA
100,000 NEW TITLES ISSUED YEARLY. OF WHICH 30.000 ARE D.C.
REGISTRATION TRANSFERS - ABOUT 70.000 CARS YEARLY OR
1/3 OF REGISTRATION IS NEW
NEW REGISTRATION FRACTION FROM OUT-OF-DISTRICT IS NOT
IDENTIFIED
ACCORDING TO 1968 TRAFFIC SURVEY, LESS THAN 10% OF VMT
IN THE WASHINGTON METROPOLITAN AREA FALLS IN EXEMPT
REGISTRATION CATEGORY. WHICH INCLUDES THROUGH TRAVEL,
TOURIST TRAVEL, AND TRAVEL BY DIPLOMATIC AND OTHER
FEE-EXEMPT VEHICLES
WASHINGTON STATE
REACTIONS TO TWO-CAR STRATEGY
CALIFORNIA-ONLY STRATEGY WOULD IMPACT AIR QUALITY
AUTO POLLUTION PROBLEM (CO) ONLY IN CENTRAL BUSINESS
DISTRICT OF SEATTLE AND SPOKANE
THEY HAVE CONSIDERED AUTO CONTROL STRATEGIES IN TWO
COUNTIES ONLY
KING COUNTY (Seattle)
SPOKANE COUNTY (Spokane)
WOULD HAVE REACTIONS AGAINST SPECIAL CONTROLS IN
OTHER COUNTIES BESIDES KING AND SPOKANE
SEATTLE AND SPOKANE MUST HAVE COMMON CONTROLS -
DIFFICULTIES IF ONE IS MORE STRINGENT THAN OTHER
G-34
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WASHINGTON STATE
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
REGISTRATION
YEARLY REGISTRATION - COUNTY IDENTIFIED
NO CHECKUP
INSPECTION PROGRAM
NO SAFETY PROGRAM NOW - HAD ONE 20 YEARS
AGO BUT DISCONTINUED. NEGATIVE FEELINGS
ABOUT SAFETY PROGRAM
BILL PENDING ON EMISSION INSPECTION PROGRAM
FOR TWO COUNTIES ONLY
RETROFIT PROGRAM
NONE - LEGISLATURE UNWILLING TO
INTRODUCE RETROFIT LEGISLATION
WASHINGTON STATE
REGION-PECULIAR FACTORS
NEED CO REDUCTION OF 55% IN SEATTLE AND 48%
IN SPOKANE
STRONG REACTIONS AGAINST CONTROL IN RURAL AREAS
AND COUNTIES OTHER THAN THE TWO COUNTIES
CONTAINING SEATTLE AND SPOKANE. LEGISLATURE
UNLIKELY TO VOTE FOR RIGID CONTROL OF MORE
THAN THESE COUNTIES
MANY NON-RESIDENTS BUY CARS IN SEATTLE
BECAUSE OF BETTER PRICE - COULD COMPLICATE
REGIONAL CONTROL PROBLEM
G-35
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SUMMARY OF STATE OR REGIONAL ISSUES
STATE OR REGIONAL REACTIONS TO TWO-CAR STRATEGY
CALIFORNIA-ONLY STRATEGY WILL IMPACT AIR QUALITY IMPLEMENTATION
PLANS OF OTHER STATES - MOST STATES WOULD LIKE TO SEE
EXTENSION OF IMPLEMENTATION PLAN DATE. HOWEVER - IMPACT OF
ONE YEAR STRATEGY IS SMALL
MOST STATES SEE MANY PROBLEMS IN ADMINISTRATION OF AND CIRCUM-
VENTION OF REGIONAL CONTROL WITHIN A STATE - UNIFORM CONTROLS
THROUGHOUT STATE GENERALLY PREFERRED
MOST STATES OR REGIONS FAVOR CALIFORNIA - ONLY STRATEGY -
EXCEPTIONS ARE NEW YORK CITY AND DISTRICT OF COLUMBIA
CALIFORNIA DOES NOT WANT REGIONAL STRATEGY WITHIN THEIR STATE -
WOULD ACCEPT CALIFORNIA-ONLY - STRATEGY FOR ONE YEAR ONLY
IF EPA MANDATES A SUPPLY OF NON- LEADED GASOLINE THROUGHOUT
COUNTRY
CALIFORNIA HAS SERIOUS RESERVATIONS ABOUT BEING THE ONLY STATE
IN THE COUNTRY SADDLED WITH A CATALYTIC CONVERTER SYSTEM
PROBLEM ASSOCIATED WITH METRO REGIONAL STRATEGY ARE
ACCENTUATED IF PRICE DIFFERENCE BETWEEN CARS IS LARGE
MANY OF REGIONS HAVE AUTO POLLUTION PROBLEMS CONCENTRATED
IN SMALL CENTRAL BUSINESS DISTRICT AREA. OBJECTIONS PROBABLE
IN HAVING STRINGENT CONTROL OUTSIDE THIS AREA
SUMMARY OF STATE OR REGIONAL ISSUES
REACTIONS TO TWO-CAR STRATEGY
GENERAL FEELING IS THAT FOR ONE YEAR
DURATION A TWO-CAR STRATEGY MAY NOT
BE WORTH THE DIFFICULTY OF SETTING UP
A SHORT-LIVED ADMINISTRATIVE PROCEDURE
MANY STATES SUCH AS NEW YORK, TEXAS,
MASSACHUSETTS, AND UTAH FELT THAT
CONTROL OF A METROPOLITAN AREA
WOULD BE AN ISSUE UNLESS ALL
SIMILARY-AFFECTED METROPOLITAN
AREAS WERE INCLUDED
G-37
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SUMMARY OF STATE OR REGIONAL ISSUES
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
CALIFORNIA HAS UNIQUE EXPERIENCE AND PROCEDURES FOR
ADMINISTRATION OF TWO-CAR CONTROL PROGRAM
CERTIFICATE OF COMPLIANCE WITH EMISSION LAWS
REQUIRED AS CONDITION FOR REGISTRATION
REGIONALLY CONTROLLED RETROFIT PROGRAM
ASSEMBLY-LINE INSPECTION PROGRAM
NEW CALIFORNIA LAWS ARE STILL REQUIRED TO IMPLEMENT
PROPOSED TWO-CAR STRATEGY
NEW JERSEY WILL HAVE MANDATORY EMISSION INSPECTION
PROGRAM COMMENCING JULY I, 1973 - TIED INTO EXISTING
SAFETY INSPECTION PROGRAM. INSPECTION REQUIRED
FOR REGISTRATION. POSSIBLE MEANS FOR TWO-CAR
STRATEGY CONTROL
MANY STATES HAVE MANDATORY PERIODIC SAFETY INSPECTION,
HOWEVER FEW ARE TIED TO REGISTRATION.
NO EXISTING REGULATIONS REQUIRE PROOF OF RESIDENCY FOR
REGISTRATION
SOME STATES DO NOT IDENTIFY COUNTY ON REGISTRATION
MAY REQUIRE NEW FORMS OR DATA HANDLING PROCEDURE
TO IDENTIFY REGISTRANTS IN CONTROL REGION
SUMMARY OF STATE AND REGIONAL ISSUES
BACKGROUND/EXPERIENCE RELATED TO VEHICLE CONTROL
SEVERAL STATES SUCH AS OREGON, WASHINGTON.
AND ARIZONA HAVE PLANS FOR REGIONAL
EMISSION INSPECTION PROGRAMS. THESE ARE
TIED TO AREAS WITH AUTO POLLUTION
PROBLEMS
SOME STATES LIKE NEW YORK CITY AND
WASHINGTON, D.C. HAVE PROPOSED
REGIONAL RETROFIT PROGRAMS
G-38
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SUMMARY OF STATE AND REGIONAL ISSUES
REGION-PECULIAR FACTORS
CALIFORNIA'S SIZE, POPULATION DISTRIBUTION. AND BORDER
SITUATION LENDS ITSELF TO TWO-CAR STRATEGY CONTROL
PROXIMITY OF POPULATION CENTERS IN A NUMBER OF EAST COAST
REGIONS REQUIRES INTERSTATE CONTROL ZONES FOR
EFFECTIVE CONTROL
MANY OF THE AIR QUALITY CONTROL REGIONS CONSIDERED
FOR CONTROL ARE LARGELY RURAL WITH ONLY LOCALIZED
MOBILE SOURCE POLLUTION PROBLEMS
ALASKA AND COLORADO HAVE UNIQUE SITUATION
1975 EMISSION CONTROL SYSTEM MAY NOT BE EFFECTIVE
FOR ALASKA PROBLEM
COLORADO AND OTHER HIGH ALTITUDE AREAS REQUIRE
WAIVER TO ADJUST EMISSION CONTROL SETTINGS
FOR HIGH ALTITUDE :
G-39
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TECHNICAL REPORT DATA
(Plcatc read Insiniciions on llic reverse before completing}
1. REPORT NO.
EPA-460/3-74-029-b
2.
3. RECIPIENT'S ACCESSION-NO.
4. TITLE ANDSUBTITLE
Examination of Issues Related to Two-Car Regional
Emission Control Strategies
Volume II - Technical Discussion
5. REPORT DATE
April 1973
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
M.G. Hinton, Toru lura, Jospeh Meltzer
8. PERFORMING ORGANIZATION REPORT NO
ATR-73(7324)-l
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
Aerospace Corp.
El Segundo, Calif.
11. CONTRACT/GRANT NO.
68-01-0417
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
Emission Control Technology Division
Ann Arbor, Michigan 48105
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
An examination and summarization of data pertaining to the issues relating
to the implementation of a two-car regional emission control strategy.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Ticld/Group
Automobile
Emissions
Production
Vehicle Migration
8. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
240
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
G-40
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