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.
                                    vn

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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
                                     xi

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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
                                  xiv

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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
                               xv

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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.
                                    1-1

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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. )
                                    1-2

-------
  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.
                                     1-3

-------
 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.
                                     1-4

-------
               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

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         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

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                              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

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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

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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

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                                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
                                    3-1

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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.
                                    3-2

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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.
                                    3-3

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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.
                                    3-4

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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).
                                    4-1

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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
                                    4-2

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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
                                    4-3

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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.
                                    4-4

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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
                                    4-5

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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
                                    4-6

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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
                                     4-7

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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
                                    4-8

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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.
                                    4.16

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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,
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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
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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
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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
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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
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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
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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
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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.
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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.
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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.
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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.
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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

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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

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 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

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 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

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 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

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 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

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         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

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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

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        .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

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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

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            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

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                     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

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   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

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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

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       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

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                                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

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                                    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

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                                  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

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                               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

i—i
*.

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                                 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

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                                  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

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                                    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
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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
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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
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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.
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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.
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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
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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
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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.
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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
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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
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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
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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.
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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.
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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.
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                               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)
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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.
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               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
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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

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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

-------
                    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

-------
                      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

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                    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

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                 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

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                     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

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                    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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