ANNUAL REPORT




             OF THE




ENVIRONMENTAL PROTECTION AGENCY




             TO THE




 CONGRESS OF THE UNITED STATES




       In Compliance With




       Section 202(b)(4)




       Public Law 90-148




 THE CLEAN AIR ACT AS AMENDED

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                          PREFACE


     This report is submitted to Congress in accordance with

Section 202(b)(4) of Public Law 90-148,  the Clean Air Act,

as Amended.  Section 202(b)(4)  reads as  follows:

     "On July 1 of 1971, and of each year thereafter,
     the Administrator shall report to the Congress
     with respect to the development of  systems neces-
     sary to implement the emission standards established
     pursuant to this section.   Such reports shall include
     information regarding the continuing effects of such
     air pollutants subject to standards under this section
     on the public health and welfare, the extent and
     progress of efforts being made to develop the neces-
     sary systems, the costs associated  with development
     and application of such systems, and following such
     hearings as he may deem advisable,  any recommendations
     for additional congressional action necessary to achieve
     the purposes of the Act.  In gathering information for
     the purposes of this paragraph and  in connection with
     any hearing, the provisions of section 307(a) (relating
     to subpoenas) shall apply."
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                   TABLE OF CONTENTS

                                                          Page
PREFACE [[[ ii

Chapter 1: Introduction .................................... 1-1

     A. Summary ............................................ 1-1

     B. Conclusions ........................................ 1-8

Chapter 2 : Background ...................................... 2-1

     A. History of State and Federal Emission
        Standards .......................................... 2-1

     B. Testing Procedures ................................. 2-3

     C . Significant EPA Actions ........................... 2-5

Chapter 3: Related EPA Programs and Activities ............. 3-1

     A. Introduction ....................................... 3-1

     B . Establishing Standards ............................. 3-1

     C. Testing and Enforcement ............................ 3-2

     D. Monitoring Technological Developments .............. 3-6

     E. National Academy of Sciences Contract .............. 3-7

     F. Regulation of Fuel Content ......................... 3-8

     G . Alternative Power Systems .......................... 3-9

     H. Federal Clean Car Incentive Program ................ 3-15

     I. Federal Low Emission Vehicle Purchase Program ...... 3-16

Chapter 4: Health and Welfare Effects ...................... 4-1

     A.   Emission Levels and Ambient Air Quality .......... 4-1

     B.   Photochemical Oxidants, Hydrocarbons, Carbon
          Monoxide, and Oxides of Nitrogen ................. 4-1

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                                                            Page
Chapter 5:   Industry Progress 	5-1

     A.  Basic Technology	5-1

     B.  Typical Control Concepts and Devices 	5-2

     C.  Industry Concerns 	5-12

     D.  Exchange of Technical Information 	5-13

Chapter 6:   Costs

     A.  Cost of Attaining the 1975 and 1976 Standards 	6-1

     B.  Cost Effectiveness of Motor Vehicle Control 	6-5

     C.  Relationship between Costs and Effectiveness
         in Reducing Air Pollution 	6-7

     D.  Industry Sponsored Research and Development 	6-12

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                 CHAPTER I: INTRODUCTION







A.  Summary




     The Clean Air Act as amended charges the Administrator of




the Environmental Protection Agency with major responsibilities




for the control of motor vehicle emissions.  These duties




include: establishing emission standards for pollutants




which endanger public health and welfare; administrating a




number of related activities concerned with vehicle testing,




certification and enforcement;  regulating the content of




fuels; demonstrating the feasibility of low-emission vehicles;




monitoring the development of improved devices to control




emissions from internal combustion engines; and directing




research and development activities related to alternative




power systems.




     In addition Sections 202(b)(l)(A) and 202(b)(l)(B)




require that:




     (1) 1975 automobiles achieve a 90% reduction in the




emissions of hydrocarbons  (HC) and carbon monoxide  (CO)




which were allowable in 1970, and




     (2) 1976 automobiles achieve a 90% reduction in the




emissions of oxides of nitrogen (NOX) from the average  levels
                             1-1

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measured on 1971 automobiles which were not subjected to




any federal or state NOX emission standards.




     Under Section 202(b) (5)(D)  the Administrator is per-




mitted to suspend the 1975 and 1976 standards for up to one




year, only if he determines that:




     "(i) such suspension is essential to the public in-




     terest or the public health and welfare of the




     United States,




      (ii) all good faith efforts have been made to meet




     the standards established by this subsection,




      (iii) the applicant has established that effective




     control technology, processes, operating methods or




     other alternatives are not available or have not




     been available for a sufficient period of time to




     achieve compliance prior to the effective date of




     such standards, and




      (iv) the study and investigation of the National




     Academy of Sciences conducted pursuant to subsection




     (c) and other information available to him has not




     indicated that technology,  processes or other alter-




     natives are available to meet such standards."
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     Since the establishment of the Environmental Protection




Agency on December 2, 1970, EPA has completed a number of




actions related to the control of emissions from motor




vehicles.  An initial contract has been signed with the




National Academy of Sciences to identify the resources




necessary to study the technological feasibility of attaining




the 1975 and 1976 standards.





      EPA has published an advance notice of proposed rule-




 making indicating its intention to control or prohibit the




 use of alkyl lead in motor vehicle gasoline.   Detailed




 studies of scientific, medical, economic, and technological




 data concerning this matter are currently under review.




      In February, the Administrator sent a letter to all




 domestic and foreign auto manufacturers requesting informa-




 tion about research and testing activities related to the




 development of emission control systems designed to meet




 the 1975 and 1976 standards.  EPA also conducted two days




 of public hearings on this subject during May of 1971.




 Twenty-one representatives of the automotive and related




 industries, of the academic and scientific communities,




 and of public interest organizations and groups presented




 statements and responded to questions.
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     EPA has published certification test results for 1971




model vehicles and engines.  National ambient air quality




standards have been promulgated which include motor vehicle




related pollutants.  Regulations have been proposed defining




the useful life of vehicles and requiring the inclusion




in owners'  manuals of maintenance instructions




for emission control systems.  Specific numerical standards




and test procedures have been established for 1975 and




1976 emissions of HC, CO and NOx.




     Demonstration  programs relating to low-emission vehicles




have been initiated.  Three contracts have been signed under




the Federal Clean Car Incentive Program whereby manufacturers




provide prototype vehicles for government testing and eval-




uation.




     The Low-Emission Vehicle Certification Board prescribed




by Section 212 of the Act has been established.  The Board




held its first meeting in June, 1971, and adopted procedural




regulations related to the preferential purchase of low-




emission vehicles for use in government fleets.




     EPA is also directing a research and development program




for low-emission vehicular power systems other than the in-




ternal combustion engine.






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     Chapter 2 of this report includes a brief history of




federal and state emission control standards and test pro-




cedures.  It also contains a more elaborate explanation of




EPA's initial accomplishments.   Chapter 3 provides an over-




view of all of EPA's programs and activities related to the




control of motor vehicle emissions.  While the industry is




giving prime attention to the development of add-on devices




to enable the internal combustion engine to meet the emission




standards prescribed in the law, EPA is also directing research




and development programs concerning alternative power systems.




     Chapter 4 deals with the health and welfare effects of




motor vehicle related pollutants.  While vehicular emissions




are important sources of pollution, especially in congested




urban areas, they are not the only sources of these contaminants.




In discussing health and welfare impacts it is important to




note that it is ambient air quality, the composition of a local




air mass, rather than emission levels from particular sources,




which is the significant factor although the two are clearly




related.




     It is difficult to generalize about the relative importance




of various contributions of the same air contaminants to am-




bient air quality because most air masses undergo lateral






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movements.  Thus relative impacts must be looked at in terms




of specific localities reflecting differences in geography,




meteorological conditions, traffic patterns and the size




and locations of all sources of the same pollutants.




     A detailed discussion of the progress reported by




industry is contained in Chapter 5.  This material describes




a number of control devices under development and outlines




some of the technical problems facing the industry.  This




material also reiterates a number of concerns experssed by




the manufacturers in their communications with EPA.




     The final section of this report, Chapter 6, deals with




the costs associated with motor vehicle emission control.  It




is not yet possible to provide precise estimates of the cost




per vehicle of attaining the 1975 and 1976 standards established




in the Act.  The total cost to the public will, however, include




the initial cost of the control system, its maintenance after




warranty, and expected increases in fuel consumption and




reductions in vehicle performance.




     Neither the final control system needed to achieve




the 1975 standards nor the technology for attaining the 1976




standards, have yet been identified.  Thus, the cost figures






                              1-6

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contained in Chapter 6 must be considered preliminary and




include informal industry estimates of initial costs ranging




from $80 to $600 per car for 1975.  However, it appears




clear that the costs associated with 1975 and 1976 standards




will be considerably greater than those experienced in




reaching Federal emission standards through 1974.




     Information provided to EPA by auto manufacturers




revealed a significant increase in emission control systems




research and development activity since the passage of the




1970 amendments to the Clean Air Act.  During the first six




months of accelerated development, industry laboratories have




reported the attainment of reduced emission levels.  While




there are many problems to be overcome to convert laboratory




results into reduced emission levels from mass-produced autos,




the added industry effort should improve prospects for signifi-




cant technological improvements.




B.  Conclusions




     During the recent public hearings industry spokesmen




expressed major reservations about the technological feasi-




bility of achieving the statutory emission standards within




the time limits prescribed by law.  The manufacturers were






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unanimous in asserting that the levels of reduction
required for 1975/76 precluded the substitution of alter-
native power systems, making it essential that emission
control be achieved through an improved internal combustion
engine.  Industry representatives consistently stated that
reaching the 1976 NOx emission levels goes beyond the limits
of current knowledge and will require some major technological
breakthrough early enough to permit mass production of 1976
models.  They also expressed concern about the high cost of
attaining the low levels of emissions required by the statute.
     At these same hearings representatives of public interest
organizations were skeptical of industry statements about
their inability to develop the necessary technology to
reduce emissions to the required levels.  These witnesses
pointed to previous instances of resistance by the industrial
community to deadlines which were ultimately achieved.  Sus-
picion was also voiced about the vigor of government enforcement
concerning interim standards and test procedures.  This
climate of mistrust makes it important that, to the degree
possible, matters related to motor vehicle emission control
be given full public exposure.
     Motor vehicle emissions are important sources of HC,
CO, and NOX pollutants especially in congested urban areas.
However, they are not the only sources of these contaminants.
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The specific contribution of vehicle emissions to the
degradation of ambient air quality is a complex matter and
varies from place to place.  These variations are attributable
to differences in geography, meteorological conditions,
traffic patterns, and the size and location of other
sources of these pollutants.  More information on these
matters is expected with the completion of State implementation
plans required under the legislation.  These plans are also
expected to include a variety of alternative abatement
strategies.  With additional information about the costs
and effectiveness of emission control from all types of
sources, it should be possible to undertake detailed cost-
effectiveness analyses in order to insure that the ambient
air quality standards are achieved at the most reasonable
cost to the American people.

     One of the unfortunate aspects of motor vehicle emission
control is that reducing levels of hydrocarbons and carbon
monoxide, which is done primarily through increasing the
efficiency of combustion, tends to make more difficult the
control of oxides of nitrogen, whose formation is largely a
function of the  heat  of combustion.  Thus, a major
technological challenge faces the Nation's auto industry
in meeting these emission standards.

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     EPA is moderately optimistic that the 1975 standards




can be attained especially since it is expected that




unleaded gasoline will be generally available at that




time.  We are also hopeful that technological developments




will enable the manufacturers to reach the 1976 standards.




However, the costs associated with achieving these standards




may be high.  Therefore, the Agency is not recommending any




legislative changes at this time, although they may be needed




in the future.
                           1-10

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                       CHAPTER 2:  Background






A.   History of State and Federal Standards




     The control of motor vehicle emissions was initiated in




the State of California in 1959 with the adoption of standards




to control exhaust hydrocarbons and carbon monoxide.  This was




supplemented in 1960 with standards to control emissions




resulting from crankcase blowby.  The early generations of




California standards were goals requiring the demonstration of




feasible technology before the establishment of implementation




deadlines.  Such scheduling was contingent upon the availability




and certification of devices,  systems, or modifications which




would enable motor vehicles to meet the standards.  In 1963,




California adopted diesel smoke standards; however, a-s with the




previous standards, there was  no immediate implementation




schedule.  As a result of the  certification of appropriate




devices and systems, California required a first level of




crankcase emission control effective with the 1963 models,




improved crankcase emission control for 1964, and control of




exhaust hydrocarbons and carbon monoxide in 1966.






     The 1965 Amendments to the Federal Clean Air Act gave the




Secretary of the Department of Health, Education and Welfare,




the authority to control emissions from motor vehicles.
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Accordingly/ on March 30, 1966, the initial Federal motor




vehicle emission standards were adopted to become applicable




with the 1968 models.  The standards and procedures were similar




to those which had been employed by California and required some




control of exhaust hydrocarbons and carbon monoxide from light-




duty vehicles and one hundred percent control of crankcase




emissions from gasoline-fueled cars, buses, and trucks.  The




term light-duty vehicle refers to self-propelled vehicles




designed for street or highway use, which weigh less than 6,000




pounds and carry no more than twelve passengers.  Thus, the




vehicle population is divided into two groups, light and heavy-




duty which generally correspond to cars as opposed to buses




and trucks.






     On June 4, 1968, revised Federal standards were published




which required more stringent control of hydrocarbons and




carbon monoxide from light-duty vehicles,of evaporative emissions




from the fuel tanks and carburetors of light-duty vehicles, of




exhaust hydrocarbon and carbon monoxide emissions from gasoline-




fueled engines for heavy-duty vehicles,and of smoke emissions




from diesel engines for heavy-duty vehicles.  The fuel




evaporative emission standards became fully effective with




model-year 1971.  The other standards applied to 1970 model year




vehicles and engines.  Thus  with the introduction of 1970






                               2-2

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models, the industry had reduced hydrocarbon emissions by




almost three-quarters and carbon monoxide emissions by about




two-thirds.






     On November 10, 1970, standards were published applicable




to 1972 model light and heavy-duty vehicles and heavy-duty




engines.  The significant modification in these standards




pertained to the method of evaluating the exhaust hydrocarbon




and carbon monoxide emissions from light-duty vehicles.




Improved methods of test operation, exhaust sampling and gas




analysis had been developed so that emissions measurements would




be more representative of actual discharges from in-use vehicles.






B.  Testing Procedures




     Testing procedures are complicated and require some added




explanation.  Numerical emission standards are meaningful only




when related to the specific test procedure employed.  As with




many other aspects of auto pollution control, test and




 analytical procedures have undergone modifications and




improvements over the years.  The initial testing in California




and at the Federal level used a 7-mode 7-cycle test procedure.




During this type of testing, a vehicle is run through seven




driving conditions or modes such as low and high speed




acceleration.  The resulting emission measurements are
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representative of the rate of emission during these particular




driving conditions, but do not measure total emissions.






In 1970, the Federal Government adopted a Constant Volume




Sample or CVS procedure during which the vehicle is run through




? test cycle designed to simulate urban driving.  The




characteristics of the standard test drive were based on an




elaborate study of Los Angeles traffic patterns in 1965.  All




emissions from ignition key-on after a 12-hour storage period




to the end of the test cycle are collected and analyzed.  The




CVS procedures result in measurements which are considered




more representative of actual emissions from vehicles as used




in urban areas.  However, the resulting numerical standards




are different from those revealed by earlier test procedures.




     EPA has recently announced a further refinement in test




procedures to include both a cold start (after a 12-hour




storage) and a hot start (after a 10-minute wait) and the




computation of a weighted average as a basis for 1975 and




1976 numerical standards.  These changes,  as well as certain




minor modifications in analytical techniques, are intended




to make test results more representative of emissions from




in-use vehicles.  The new test procedures are also expected




to be used in connection with the proposed 1973 emission standards,
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C.  Significant EPA Actions




     1) On January 30, 1971, the Environmental Protection Agency




published an advance notice of proposed rule-making concerning




its intention to promulgate controls or prohibitions on the addition




of alkyl lead to gasoline fuels for motor vehicles at the earliest




possible date. In accordance with the requirements of Section




211 of the Act, EPA is considering relevant, scientific, medical,




economic, and technological data prior to final rule-making




in this area. Systems designed to control NOX emissions to meet




standards applicable to 1973 model year cars may require that




a low lead gasoline be generally available in late 1972 and the




probable use of catalytic converters to achieve the 1975 HC-CO




standards makes it imperative that  unleaded  gasoline be generally




available by that time. These developments underscore the need




for implementing the President's request for a tax on lead




in gasoline to insure that unleaded gasoline will be competitively




priced.




     2)  On February 26, 1971, all domestic and foreign auto




manufacturers were requested by the Administrator to furnish




EPA with the following information:




1. A description of the basic techniques being explored as a




means of meeting the emission standards required under Section




202 (b) (1).




2. With respect tt> the techniques identified and described:




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    a.  An indication of the current state of development




        and testing, including durability testing of each




        one.




    b.  A summary of the emission data derived from any




        such testing.




    c.  An assessment of the prospects for perfecting each




        one to a point at which it could be used on production-




        line motor vehicles.




    d.  A description of the major problems that remain to be




        solved in order to perfect each type of unit.




    e.  An identification of all other companies participating




        in the development and testing.




    f.  A summary of the resources in dollars and professional-




        technical man years applied during calendar year 1970




        and expected to be applied during 1971 to the




        development and testing of the various units.




     3)  On April 7, 1971, a notice of proposed rule-making




was published concerning the requirement for the preparation of




State implementation plans necessary to achieve national




ambient air quality standards.  Under Sections 109 and 110 of




the Act, EPA is required to publish national ambient air




quality standards and States are required to prepare specific




implementation documents detailing how they propose to attain






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the prescribed ambient standards.  In this notice, attention




was called to the potential need to develop aftermarket




strategies to control motor vehicle emissions, which might




include vehicle inspection programs, mandatory maintenance,




and/or retrofit control systems for the existing auto population.




fhe technology for periodic inspection is being developed and




will be evaluated in terms of benefits, costs, and effectiveness.




     4)  On April 10. 1971. the Federal certification test




results for 1971 model year motor vehicles and engines were




published.




     5)  On April 30, 1971, national primary and secondary




ambient air quality standards were published as final rule-




making, including standards for hydrocarbons, carbon monoxide,




and oxides of nitrogen.  These pollutants are associated with




motor vehicle emissions.




     6)  Also on April 30. 1971. the State of California was




granted waiver of Federal preemption for motor vehicle emission




standards more stringent than  those currently in  effect  by




Federal regulation.  These pertain to:




a.  Auto emission standards and test procedures for the 1972




    model year.




b.  Auto assembly line standards and test procedures for the 1972




    model year.





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3.  Prohibition of the sale of automobiles that require




    gasoline of research octane greater than 91 effective with




    the 1973 model year.




4.  Gasoline powered truck emission standards and test




    procedures for the 1973 model year and more stringent




    standards for the 1975 model year.




'j.  Diesel powered truck emission standards and test procedures




    for the 1973 model year and more stringent standards for




    the 1975 model year.






    The waiver was granted on the basis of testimony presented




at a hearing held in Los Angeles, California, on January 26 and




27, 1971, additional material provided prior to February 22,




1971, and other related information available to the Environmen-




tal Protection Agency.  Additional waiver requests were denied




at that time but are under review within EPA.




     The legal basis for granting this waiver is contained




in Section 209 of the statute which concerns Federal preemption




of State and local emission standards.  However, the law also




permits EPA to issue waivers to California if, after public




hearing, the Administrator finds that State standards more




stringent than the Federal requirements are necessary to meet




compelling and extraordinary local conditions.
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     7)  On May 6 and 7. 1971.  hearings were held in
Washington, D. C. to supplement the industry responses to
the Administrator's letter of February 26,  1971.  Twenty-one
representatives of the automotive and related industries, of
the academic and scientific communities, and of public interest
groups and organizations presented statements and responded to
questions related to meeting the 1975-76  emission standards.
     In his introductory comments, the Administrator stated:
     "The law itself does not permit traditional
     conceptions of satisfactory driving performance
     to stand in the way of whatever changes in vehicle
     design and power system are needed to control
     emissions.  The same is true with regard to vehicle
     cost.  This hearing is part of the continuing effort
     by the Environmental Protection Agency to find out
     just what sacrifices might be needed in cost, in
     fuel economy,  in power, in acceleration and in other
     historic yardsticks of vehicle performance to produce
     an automobile  that we can live with as a people.

     "The low emission car of the future may be a more
     expensive car.  It may not equal today's car in road
     performance, but this is a price that  may be
     necessary if we are to have and preserve a healthy
     environment for ourselves  and our families,
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"As a consequence, we cannot and will not accept




anything less than a wide open research and




development effort to meet the actual requirements.




We will not, for example, find acceptable a




manufacturers decision not to explore innovative




designs or power systems on the grounds that a vehicle




so designed or so powered would be more costly or




would not meet traditional performance criteria.  We




must develop and apply whatever technology is needed




to achieve the degree of emission control required by




the Act and we must be willing to accept any necessary




sacrifices in other areas of vehicle performance."






He further stated a second point concerning,




"The specific power conferred upon me by the Clean Air




Act to suspend the effective date of an emission




standard for one year.  Exercise of this power is




carefully circumscribed by law.  I am required to make




a determination relating to good faith and two




separate determinations concerning the technological




feasibility of meeting the statutory standards."






"I have given serious considerations to the proper




construction of the statutory provision for suspension,
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It is my present judgment that the required determinations

relating to technological feasibility do not permit me to

suspend an emission standard in favor of a single appli-

cant or a group of applicants if technical knowledge

exists, in the industry or elsewhere, which would enable

any member of the industry to mass produce a light-duty

vehicle in compliance with the Act."


"It is important that all of the implications of this

construction of the law be well understood at the

earliest possible time.  It means that if any member of

the industry could meet the Act's deadlines for

compliance, all applications for extension will be denied.'


"Any other construction of the suspension provision would

be incompatible with the clear intent of the law to

require whatever changes in design or power systems are

needed to control emissions.  Where some manufacturers

meet the statutory deadlines by making major changes

which substantially increase the cost of the vehicles or

which require major sacrifices in vehicle performance, I

do not believe that Congress intended to subject such

manufacturers to competition from cars produced by other

manufacturers who are required to meet a less stringent

standard."
                          2-11

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     "As I read the law, the separate determination




     concerning good faith becomes applicable where it




     is not technologically possible for any member of the




     industry to comply with the Act's requirements.  In that




     event, suspensions for one year would be granted only




     to applicants who can establish that they made a good




     faith effort to meet the statutory deadlines for com-




     pliance.  Here, on the separate issue of good faith, the




     specific problems which may face a particular




     manufacturer appear to be pertinent."






     8)  On May 11, 1971. the proposed definition of useful




life for vehicles and requirements for the inclusion of




maintenance instructions for emission control systems in




owner's manuals were published to implement Sections 202(d)




and 207 of the Act.




     9)  In May, 1971, three contracts were awarded to provide




prototype cars for government ter-ting and ova Nation under the




Federal Clean Car Incentive Program.




    10)  On June 18. 1971, the Low-Emission Vehicle Certifica-




tion Board held its initial meeting and approved procedural




regulations concerning preferential purchasing of low-emission




vehicles for use in government fleets.  These activities




are prescribed in Section 212 of the Act.





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    11)   On June 29, 1971, the first Federal standards were




issued requiring control of oxides of nitrogen emissions and




prescribing measurement techniques for this pollutant




applicable to 1973 model light-duty motor vehicles.






    12)   On June 29, 1971, standards were promulgated to




prescribe the 1975 exhaust hydrocarbon and carbon monoxide




emission requirements,and 1976 oxides of nitrogen emission




requirements applicable to light-duty vehicles as required by




Sections 202(b)(1)(A) and 202(b)(1)(B).  In addition,




modifications in test and analytical procedures were included




as described in Section B of this Chapter.






         In addition, EPA has entered into an initial contract




with the National Academy of Sciences to study the




technological feasibility of meeting the 1975 and 1976




standards in accordance with the provisions of Section 202c of




the Act.
                               2-13

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         CHAPTER 3:   Related EPA  Programs  and Activities







A.  Introduction



     The Environmental Protection Agency has been assigned




responsibility for a number of programs and activities




designed to abate pollution emanating from motor vehicles.




Regulations establishing standards, testing procedures, and



enforcement practices have been developed and promulgated




to guide future actions.  Staff and contract personnel from




the National Academy of Sciences are assessing the technological




feasibility of attaining the  1975 and 1976 standards established




in tne legislation.  EPA is expanding its capability to monitor



industry progress whicn is primarily focused upon add-on




devices to clean up the internal comoustion engine.  Demon-




stration programs have been initiated concerning the




feasibility of low-emission vehicles.  EPA is also directing




a research and development program for alternative power




systems.




B.  Estab1ishing Standards



     The Clean Air Act as amended establishes specific




emission requirements for hydrocarbons, carbon monoxide, and
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oxides of nitrogen for 1975 and 1976.  However, EPA was




required to convert these parameters into specific numerical




standards related to 1970 and 1971 emission levels.  This




work has been completed, and the standards for 1975 and




1976 have been published.




     In addition, EPA also has responsibility under Section




202(a)(l) of the Act for promulgating emission standards for




other exhaust pollutants if they are found to endanger public




health and welfare.  Due consideration must be given to the




availability of appropriate control technology and the cost




of compliance.  These responsibilities carry EPA into analysis




of exhaust materials, research concerning health and welfare




impacts of pollutants, assessment of available control tech-




nology and studies of the economic impact of alternative




abatement strategies.




C.   Testing and Enforcement




     The enabling legislation assigns EPA responsibility for




testing, certification, and enforcement activities concerning




emission controls for new motor vehicles and engines.  At




present these programs generally follow the procedures outlined




below:  A quantifiable emission standard is promulgated
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to be met by a set deadline.   Manufacturers develop and



test prototype vehicles, with some confirmatory testing by



EPA.  If the prototype design is found to comply with the



standard, the group of vehicles represented by that unit is



certified for production and sale.  In-use vehicles are later



t.ested to determine whether production vehicles continue to



meet the standards.





     EPA's testing and enforcement procedures require the



certification of manufacturers' vehicle and engine product



lines based on the satisfactory testing of prototype



designs.  In formal application for certification, the



manufacturer is required to delineate pertinent mechanical



characteristics of the vehicles or engines and emission



control systems, and the projected sales of each configuration,



This information provides the basis for EPA selection of



configurations to be tested for establishing eligibility
          i


for certification.  The actual testing program involves two



groups of vehicles or engines.  One group is tested to



determine emission levels after engine break-in.  The second



group consists of vehicles or engines which are operated for



for extended periods with limited maintenance
                               3-3

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to simulate the rate of emissions degradation with normal




usage.  The certificability  of a group or engine family is




established if the emission value of each engine tested,




adjusted by the appropriate deterioration factor, is in




compliance with the standards.




     Surveillance testing of vehicles in routine service




has shown that production vehicles in use do not consistently




•display the low emission levels indicated in prototype




certification testing.  Procedures for assembly line testing




are under development but they require solutions to serious




problems.  High volume testing dictates the need for quick




test procedures which can be consistently related to the




certification test results.  Such procedures should ideally




provide diagnostic information so that appropriate repairs




can be made at minimum expense and with minimum loss of




time.  An effective quick test procedure could also be




useful in expanding the present surveillance programs to




determine when manufacturers should institute recall programs,




An extensive program is being conducted by EPA to identify




appropriate equipment and procedures.
                               3-4

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      To implement Section  207, manufacturers of nev motor




 vehicles and engines will  be  required to warrant  to the




 ultimate purchaser that  the vehicle or engine  is  designed,




 built,  and equipped to conform with applicable




 emission standards, and is  free from defects in materials




 and workmanship which might result in failure  to  conform to




 appropriate regulations    during its useful life.   Sur-




 veillance studies will be  strengthened and regulations will




 be  promulgated requiring manufacturers to recall  vehicles




 which are found to be out  of conformity with standards



 during  the warranty period.




     The testing of heavy-duty vehicles  entails the ap-




lication of substantially different procedures than those




associated with light-duty vehicles.   Heavy-duty engines,




both gasoline-fueled and diesel have a broad range of




uses in vehicles  larger than 6000 pounds.   Present pro-




cedures, therefore, involve engine testing as opposed to




vehicle testing.  EPA is currently reevaluating the




heavy-duty testing procedures with the objective of as-




suring that they  reflect, as much as possible,  the emissions




from such vehicles  in actual use.




                             3-5

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     Another important feature of EPA's testing program




concerns the verification of new control devices developed




by non-automobile manufacturers.  Section 206 provides for




the testing or any emission control system incorporated in




a motor vehicle or motor vehicle engine submitted to the




Administrator by any person.  If it is determined that the




vehicle or engine conforms to appropriate standards, the




Administrator shall issue a verification of compliance with




emission standards for the system.  The manufacturers and




the National Academy of Sciences shall be informed of these




results which shall also be made available to the  public.




Hopefully these provisions will accelerate the pace of




development of new emission control devices.




D.  Monitoring Technological Developments




     In order to carry out EPA responsibilities concerning




the 1975 and 1976 emission standards for light-duty vehicles,




we are expanding our capability to monitor the development




of appropriate control technology both within and without




the auto industry.  As described in Chapter 2 the Administrator



has requested specific information from the auto manufacturers




and has held public hearings on these subjects.  The results




of our initial contacts are reflected in Chapter 5.






                            3-6

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E.  National Academy of Sciences Contract




     Section 202(c)(l)  of the Act directs that the Administrator




"enter into appropriate arrangements with the National




Academy of Sciences to conduct a comprehensive study and




investigation of the technological feasibility of meeting




the emission standards required to be prescribed by the




Administrator" (for 1975 and 1976 light-duty motor vehicles).




In addition* the Administrator is directed to request the




National Academy of Sciences to submit semi-annual reports




on its progress to the Administrator and to Congress begin-




ning on July 1, 1971.



     Shortly after the passage of the Act,  EPA contacted




the staff of the Academy concerning this work.  A preliminary




contract was awarded to the Academy to allow them to assemble




the necessary resources, and develop specific plans and budgets




for carrying out the work.  The involvement of the National




Academy of Sciences will provide the Congress and the Admin-




istrator with an independent assessment of technological




feasibility of meeting the 1975 and 1976 standards.
                             3-7

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F.  Regulation of Fuel Content




     The fuel additive which has received most attention




related to auto emissions is lead.  It has been well docu-




mented that catalytic converters, which are among the




devices being developed to remove carbon monoxide, hydro-




carbons, and nitrogen oxides from vehicle exhaust, deteriorate




rapidly when exposed to fuels containing lead compounds.




Lead additives have also been shown by several investigators




to contribute to fouling of exhaust gas recirculation systems




used for nitrogen oxides control.




     As directed  in Chapter 4, the health effects of




lead emissions are now under serious review.  Studies are




also being sponsored by EPA to evaluate the economic impact




of curtailing or eliminating the use of lead in gasoline.




A comprehensive report concerning this matter is expected




later this year which will serve as a basis for further




discussion and eventual rulemaking.
                              3-8

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G.  Alternative Power System




     In order to meet the 1975-76 standards, the automobile




industry is concentrating its efforts on modifications of




the conventional internal combustion engine.  There is serious




question, however, about the ability of the conventional engine




to meet long term health and welfare needs of the nation as




now perceived.  Accordingly, the Environmental Protection




Agency has embarked on a program of federally sponsored re-




search and development of alternative engine systems which




are inherently cleaner than the conventional engine.  This




development activity is embodied in the Advanced Automotive




Power System Program (AAPSP).




     Five types of power systems initially were part of the




program when it began in July of 1970.  These include Rankine




cycle, the gas turbine, heat engine/electric hybrid, heat




engine/flywheel hybrid, and all-electric.  Two additional




systems, the stratified charge engine and the advanced design




diesel engine, have been added to the program.  Limited




privately sponsored research has been underway for some time




on all of those systems.






                           3-9

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     Each candidate system was at a different stage of




development when the program began and, depending on tech-




nical developments, may enter the hardware phase at a




different time.  The first 18-month phase of the program




is intended to be a period of evaluation wherein complete




systems are designed, critical components bench tested, and




decisions made on whether to proceed to first generation




system hardware.




        In the Rankine Cycle Engine, there is an external




combustor and an enclosed working fluid which is heated, ex-




panded to do work, then condensed into a liquid, with the




fluid being continuously recycled.  Three types of Rankine




systems are presently in the design and component test phase,




Two systems use organic working fluids one with a recipro-




cating expander, the other with a turbine expander.  The




third Rankine system is the steam engine.  The technical




problems confronting the successful development of the




Rankine cycle system are understood and are being studied.




Major problems appear in the inefficiency of components, and




complexity of the control systems.  Parallel research and




development of components for all three types of engines






                              3-10

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is currently underway.  The first prototype engines are




expected to be available for testing in 1972.




     More work has been conducted by the domestic auto




manufacturers on the gas turbine engine than on any other




candidate.  EPA sponsored research efforts are being focused




on solving specific problems which have made the gas turbine




unattractive for use in cars.  These problems include the




need for reducing the nitrogen oxide emissions in the exhaust,




developing manufacturing techniques for mass producing turbines




inexpensively, and increasing system reliability.  As




solutions to-these problems become available, it is anticipated




that industry will apply them to their own turbine designs.




     The hybrid engine candidates include the heat engine/




electric and the heat engine/flywheel.  The heat engine/




electric hybrid consists of a small size low-powered engine




(80-100 hp) and an array of batteries.  The hybrid system is




designed to extract power from the engine alone, or from




both engine and battery at the same time.  The basic system




is compatible with either a conventional internal combustion
                               3-11

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engine or a small gas turbine.   In either configuration the




system operates best by running the heat engine at a constant




speed with additional power for acceleration supplied from




the battery system.




     This hybrid concept offers potential advantages.  The




engine speed range is relatively small with an attendant




ease of control of exhaust emissions under such conditions.




Good road performance for a standard size American automobile




can be obtained with a relatively small and inexpensive heat




engine.  The basic problems of this system are its relative




complexity, higher cost, and the greater space required for the two



sources.  Development of improved lead-acid batteries to




accommodate the rapid charge-discharge characteristics needed




for this hybrid mode of operation is now underway.




        The heat engine/flywheel system would function in a




manner similar to the heat engine/electric with the battery




replaced by a mechanical storage device, a spinning flywheel.




Research has progressed from the analysis of practical fly-




wheel materials to the design and fabrication of specific




flywheels for cars.






                              3-12

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     The all-electric car engine development has been




underway for more than a year at Argonne National Laboratories,




It is anticipated that "proof-of-principle"  for a high




temperature lithium-sulfur system will be demonstrated




within the next 8 months.  Once proof-of-principle has been




achieved, the study will move into a development phase, first




with si goal of a 2 kilowatt (kw) battery,  then a 5 kw battery




and then a 20 kw battery system.  Development of the all-




electric system will not be completed early enough to meet




1975 standards because the project is still in the fundamental




research stage.  Moreover, an environmental cost/benefit




analysis is yet to be undertaken which would indicate whether




there would be a net gain from the environmental viewpoint




given the added burdens such a system might place on electric




power generation requirements.  However, such a low emission




vehicle might be highly desirable for conjested urban areas.




     The stratified charge engine is a gasoline-fueled




internal combustion engine with many hardware characteristics




of the conventional engine.  Differences appear mainly in




the combustion chamber design and the use of fuel injection.
                               3-13

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Much of the initial work on this engine was sponsored by




the U.S. Army Tank-Automotive Command.   The measured ex-




haust emission levels for an experimental stratified charge




engine installed in a small military vehicle and employing




a catalytic muffler are below the standards for hydrocar'. jns




and carbon monoxide set for 1975.  Further work must be con-




ducted to reduce the nitrogen oxide emissions to attain the




1976 standards.  Several generations of development have been




funded by the Army with some assistance by HEW.  EEA's work




on this engine has emphasized the reduction of nitrogen




oxide emissions.  Testing of this system in a fleet of vehicles




is now being contemplated.  However, there are many problems




to overcome to convert experimental engines into mass




produced vehicles with similar emission characteristics.



        The diesel enqine is not commonly used in American




made automobiles because it is heavier and more expensive




than the conventional automobile engine.  Emphasis is being




directed toward the development of a low compression diesel




with high-swirl injection and a modified prechamber design.




Exhaust emission levels for hydrocarbons and carbon monoxide




lower than the 1975 standards have been shown for this type






                              3-14

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of engine without the need for a catalytic  converter.  The




measured nitrogen oxide levels of the first generation




engine are relatively low although above the 1976 standards.




Studies are concentrating on nitrogen oxides reduction and




on performance, durability ind driveability testing.




H.  Federal Clean Car Incentive Program




     The Federal Clean Car Incentive Program (FCCIP) is




designed to foster private development of new types of




low emission vehicles related to the 1975 and 1976 emission




standards.  In the first stage of the program the developer




leases to the Government a candidate prototype vehicle




which is subjected to rigorous evaluation.  After success-




fully  passing stringent emissions and performance testing




on the leased prototype car,  10 additional vehicles  may




be purchased for more comprehensive testing.  The govern-




ment may later buy up to 100 vehicles for further evaluation.




If the low emission levels are maintained and road per-




formance is found to be satisfactory, the car is then




eligible for certification as a low-pollution vehicle




under the program described in the next section of this




report.






                          3-15

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     This program began in January* 1971, with approximately




20 initial proposals from industry.  Ten different vehicle




systems have been accepted into the program.  In May of this




year three contracts were approved to provide prototype cars




for testing.  The Incentive Program is expected to provide




valuable information about the feasibility of reaching the




1975-76 emission standards.




I.  Low-Emission Vehicles Purchase Program




     Section 212 of the Act provides for the creation of a Low-




Emission Vehicle Certification Board (LEVCB).  EPA initially




certifies vehicles which discharge significantly less pol-




lutants than required by current Federal regulations.  The




LEVCB identifies the class of vehicle for which the selected




cars are considered suitable substitutes taking into consider-




ation factors such as performance and cost of maintenance.




Certified vehicles may be purchased for use in government




fleets at premiums of up to 100% over the prices normally paid




by the government for equivalent vehicles.  The non-statutory




members of the Board have been named by the President and its




first meeting was held on Jufle 18, 1971.  At that time the




board adopted initial procedural  regulations.






                             3-16

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           CHAPTER 4:  Health and Welfare Effects


A.  Emission Levels and Ambient Air Onalil-y

     Motor vehicle emissions are important sources of air

pollutants especially in our congested urban areas.  The

following figures indicate EPA's estimate of the relative

contribution of vehicle emissions of HC,  CO, and NOX-


             % of National Emissions in 1969

    Source                 CO           HC            NOX
Motor Vehicles            64.7         45.7           36.6

Other forms of
  transportation           9.0          7.2           10.5

Fuel Combustion
  in stationary
  sources                  1.2          2.4           42.0

Industrial Processes       7.9         14.7            0.8

Solid Waste Disposal       5.2          5.3            1.7

Miscellaneous             12.0         24.7            8.4
                         100.0        100.0          100.0


     In addition, emissions of HC and NOX from motor vehicles

and other sources undergo complex chemical reactions in the

atmosphere and contribute to the formation of photochemical

oxidants associated with urban smog.
                            4-1

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     While the proportions indicated above hold true nationally,




the relative contributions of vehicle emissions to ambient




air quality varies among communities.  These variations result




from differences in geography,  meteorological conditions,




traffic patterns, and the size and location of other sources




of the same pollutants.  Thus in discussing health and




welfare impacts the key factors are ambient air concentrations




resulting from emissions fron all sources, rather than




emissions from any particular source.




     In accordance with Section 109 of the Clean Air Act,




EPA has published national primary and secondary ambient air




quality standards for a variety of air pollutants.  Primary




standards define levels of air quality which the Administrator




judges to be necessary, with an adequate margin of safety,




to protect public health.  Secondary standards reflect




concentrations judged necessary to protect public welfare




from any known or anticipated adverse effects.  Of interest




to a discussion of motor vehicle emissions are the ambient




air quality standards for photochemical oxidants, hydrocarbons,




nitrogen dioxide, and carbon monoxide which are shown in




Table 1.
                            4-2

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                          Table 1
  NATIONAL PRIMARY AND SECONDARY AMBIENT AIR QUALITY STANDARDS
              For Motor Vehicle Related Pollutants
   (Concentrations not to be exceeded more than once per year)
Pollutant
                    Concentration Limit
Micrograms Per
 Cubic Meter
Parts Per
 Million
Averaging Time
Photochemical
  Oxidants

Hydrocarbons
  (Methane free)

Nitrogen
  Dioxide
     160

     160
   0.8

   0.24
    1 hour

    3 hours
Carbon
  Monoxide
    10,000
    40,000
    9
   35
    8 hours
    1 hour
For the above pollutants, adverse welfare effects have not been
observed to occur at levels below those judged necessary to
protect the public health.  Accordingly,  the secondary standard
has been set at the same level.  Pursuant to the Act, primary
ambient air quality standards must generally be achieved by
June 1, 1975.
 Standards for short-term exposure rates for nitrogen dioxide
 have not been promulgated.  EPA has established safe annual
 exposure rates of 100 ug/m3 or 0.05 p.p.m.
                            4-3

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     Related to the establishment of national ambient air

quality standards are the provisions of Section 110 of the

legislation, which require that States prepare implementation

plans indicating how they will attain the national ambient

standards within their boundaries by 1975.  These documents,

which are to be submitted to EPA by January 30, 1972, will

indicate the relative contribution of motor vehicle emissions

to ambient air quality for communities in many parts of the

Nation.  They are also expected to include a variety of

abatement strategies and contribute greatly to our under-

standing of the significance of motor vehicle emissions

control.


B.  Photochemical Oxidants, Hydrocarbons, Carbon Monoxide,
    and Oxides of Nitrogen

     Detailed discussions of the effects of photochemical

oxidants, hydrocarbons, nitrogen oxides, and carbon monoxide

may be found in their respective Air Quality Criteria

Documents.  The following is a summary of the more important

effects of these pollutants in ambient air masses coming

from all sources and not just motor vehicles.

     Photochemical oxidants result from a complex series

of atmospheric reactions initiated by sunlight.  When

reactive organic substances and nitrogen oxides accumulate


                            4-4

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in the atmosphere and are exposed to the ultraviolet




components of sunlight, the formation of new compounds,




including ozone and peroxyacyl nitrates, takes place.




     Photochemical oxidants may adversely affect vegetation,




human health, animals, and certain man-made materials.  They




can cause injury to many important species of plants such as




beans, tobacco, petunias, peanuts, and pine trees.  Injury




to sensitive species has occurred after exposure of 4 hours




to 0.05 ppm of photochemical oxidants.  In southern California




hundreds of acres of pondercsa pine forest have been affected




by photochemical oxidants.




     The principal human effect associated with photochemical




oxidants include impairment of athletic performance and an




increase in attacks among asthmatics, the latter effect




having been observed when oxidant levels reached 0.15 ppm




for one hour.  Although eye irritation has been associated




with oxidant levels of 0.10 ppm in Southern California, it




has not been shown conclusively that any particular species




of photochemical oxidants is responsible.
                            4-5

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     Rubber, fabrics, and dyes are particularly sensitive




to photochemical oxidants as evidenced by rubber cracking,




reduced strength in cellulose fabrics, and the fading of




certain dyes after exposure.




     Hydrocarbons represent the major class of reactive




organic matter in the atmosphere that is responsible for




photochemical smog.  Through their reaction intermediates




and photochemical oxidation products, they are directly




responsible for the eye irritation associated with




photochemical smog and much of the characteristic vegetation




damage.  Hydrocarbon oxidation products are also believed




to be important contributors to the atmospheric aerosols




responsible for the reduced visibility associated with




photochemical smog.  In addition, ethylene, a specific




hydrocarbon, is directly responsible for certain forms of




plant injury—orchids are especially sensitive.




     The presence of nitrogen oxides in the atmosphere




is essential to the photo-oxidation of hydrocarbons and the




development of photochemical oxidants.   Sufficiently  reduced




 level?  of  either NOX or   HC alone  in the air  tend  to  alleviate




 the  formation  of photochemical  oxidants,  but  the exact




 relationships  are  extremely complex.
                            4-6

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Nitrogen dioxide, a type of oxide of nitrogen, is also a




specific air pollutant associated with increased incidences




of acute bronchitis in infants and school children and




acute respiratory disease in the entire faimily group.




Nitrogen dioxide has also been associated with damage to




vegetation and corrosion of electronic components.  Increases




in the incidence of respiratory disease were associated with




nitrogen dioxide levels ranging from 0.06 ppm to 0.08 ppm




over a 6-month period.




     Carbon monoxide is well known for its poisonous effects




at high concentrations.  It is absorbed through the lungs




and reacts primarily with the hemoglobin of red blood




cells.  As an air pollutant, carbon monoxide represents a




potential danger to human health and safety.  It decreases




the oxygen carrying capacity of the blood and reduces the




availability of oxygen-transported to vital tissues by the




blood.  Carbon monoxide concentrations of 10 ppm produce




blood carboxyhemoglobin levels of 2% in non-smokers.  This




carboxyhemoglobin level has been associated with impaired




time interval discrimination.




     Carbon monoxide concentrations of  30 ppm for 8 to 12




hours have been associated with impaired psychomotor performance




and reduced visual acuity in normal subjects and with




increased physiological stress to patients with heart disease.





                           4-7

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C.  Other Pollutants




1.  Lead




    Evaluations of available evidence are presently underway




to determine the specific health effects of lead particulate




matter emanating from auto emissions.  These evaluations




should be completed in the near future.  It is already known




that lead is a biologically nonessential metallic element




which is clearly toxic under conditions of prolonged and




excessive exposure (e.g., ingestion of paint containing lead).




Furthermore, lead accumulates in persons exposed to high




atmospheric concentrations.  Lead is absorbed primarily




through the gastrointestinal and respiratory tracts.




    As noted in Chapter 3, in addition to health effects,




lead in gasoline has been found to greatly reduce the




effectiveness of catalysts and therefore the availability




of unleaded gasoline is needed if these devices are to be




used on production vehicles.




     Since about 96 percent of the lead particulate matter




found in the atmosphere results from gasoline-fueled engines,




the reduction or elimination of lead from gasoline should




significantly reduce the incidence of lead particulate matter




in the future.
                             4-8

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2.   Other Substances




     The significance of the relationship between auto emission:;




of the materials listed below and the health or welfare dangers




has not been established.  Medical and biological investigations




of the following items are underway:




     (1)  Particulate materials—both organic and inorganic.




     (2)  Aldehydes and other carbonyl compounds.




     (3)  Nitrogen compounds other than nitrogen oxides,




          such as ammonia.




     (4)  Miscellaneous organic materials, such as polynuclear




          aromatic hydrocarbons.
                            4-9

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               CHAPTER 5:  Industry Progress









A.  Basic Technology




     The gasoline-fueled internal combustion engine is the




best understood and most reliable propulsion system currently




available.  The auto industry maintains that it is also the




only prospect for mass production in 1975-76.  Unfortunately,




 it  is also  an  inherently high-emission propulsion  system.  These




high emissions are caused,  to a major degree by the fuel




itself and relate to the difficulty in supplying thermody-




namically ideal air and fuel charges to the cylinders and




bringing about complete combustion over the full range of




vehicle operating requirements.






     The problem is maximized  at low engine start-up temper-




atures and when the humidity and temperature of the air supply




vary widely.  Additionally, variability in fuel density and




viscosity are factors which inhibit precise metering of the




fuel.  Gasoline in the liquid state will not burn and thus




the higher boiling point hydrocarbons do not vaporize and




burn when the engine is cold.  Cold engine starts require




extra amounts of gasoline to produce enough vaporized fuel to




provide a combustible mixture at the sparkplug.  The excess




non-vaporized portions then pass through the engine unturned .






                            5-1

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The problem is reduced as the volatility of the gasoline is




increased and the boiling range reduced.  The importance of




the fuel volatility factor is dramatized by the emission




performance of the internal combustion  engines when operated



on  natural gas or liquified petroleum gas  (LPG).  Typically,




such  changes  in  fuels  result  in lover emissions of HC and CO.






     While efforts aimed at leaner air-fuel mixtures tend to




reduce hydrocarbons and carbon monoxide, they tend to increase




emissions of nitrogen oxides.   This occurs because improved




combustion results in higher temperatures which in turn promote




the union of nitrogen and oxygen.   Efforts to control nitrogen




oxides to high levels within the engine tend to negate the




improvement gained in HC and CO control.  Thus NOx control




will probably require other measures to reduce peak combustion




chamber temperatures and/or the addition of an external control




system.






B.  Typical Controj^ Concepts and Devices




     Engine modificationsdesigned to reduce emissions during




the combustion process represent the principal approach used




for compliance with motor vehicle exhaust emission standards




now in effect. Such modifications, refined to promote even




more efficient combustion, will continue to be a fundamental
                            5-2

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part of the systems approach leading to compliance with future




standards.  However, add-on devices such as thermal reactors




and catalytic converters will most likely be required to




complete the system.






     Modification in gasoline composition, such as the elimination




of lead and, possibly,  changes in volatility characteristics,




may also be required in order to facilitate the use of certain




control techniques and optimize the potential of others.  A




review of the emission control techniques, components and




concepts, known to be under development by industry for gasoline




fueled motor vehicle follows:






     1.  Modification of Combustion Chamber Design




          A major source of hydrocarbon emissions from auto-




     mobiles is unreacted fuel-air mixtures expelled through




     the tailpipe.  This occurs primarily because the very




     thin layer of gaseous mixture which makes contact with




     the relatively cool combustion chamber surfaces does not




     burn.  By modifying the combustion chamber design to




     reduce the surface-to-volume ratio and by minimizing




     crevices, more nearly complete combustion of the full




     cylinder charge is promoted.
                            5-3

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 2.   Modification  of  Induction System




     Carbon  monoxide in  the exhaust results from insuf-




 ficient  oxygen  in the fuel-air mixture and consequent




 incomplete combustion.   Incomplete combustion is also an




 important source  of  hydrocarbons.  Leaner air-fuel mixtures




 to  assure more  complete  combustion can be accomplished by




 converting more of the liquid gasoline into the vapor




 form and by  providing for  improved fuel-air mixing and




 distribution among the cylinders.  Air-fuel induction




 systems  can  be  adapted to  provide heated intake air for




 more uniform carburetor  inlet temperatures thus allowing




 leaner fuel-air mixtures to be used.  Air temperature can




 be  maintained by  a thermostatically controlled mixing




 valve in the air  cleaner.  Intake manifold heating tends




 to  provide more uniform  fuel distribution.  Intake ports can




also be re-designed to give improved induction turbulence




 and mixing.  More uniform  distribution of the fuel-air




 mixture  to the  cylinders can likewise be accomplished through




 design changes.   Unfortunately, modification of induction




 systems  which improve combustion and reduce HC and CO




 emissions also  raise temperatures and worsen NOx control.






                       5-4

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3.  Carburetor Modifications




     The carburetor is a key element in effective emission




control by virtue of its role in metering the fuel in




proper proportion to inlet air.   Precise fuel metering,  in




accordance with changing engine  requirements, makes possible




operation with lean air-fuel mixtures.   Carburetors can  be




designed with stronger fuel metering signals end closer




calibration tolerances to assure better fuel mixing pre-




paration. Fuel injection systems  can provide more accurate




metering and deliver fuel under  pressure for maximum




atomization.  Electronic fuel metering  could also allow  for




altitude compensation and more precise  mixture control.






4.  Choke Modifications




     Gasoline in liquid form does not burn.  Consequently,




when an engine is started cold,  an extra amount of gasoline




is needed in order to obtain enough vaporized hydrocarbons




to mix with air and provide a combustible mixture at the




sparkplug.  The function of the  carburetor choke is to




supply the added fuel.  However, the unvaporized  hydrocarbons




pass through the engine unburned.  By tailoring choke action




to car requirements, enrichment  during  starting and warm-up




can be made compatible with satisfactory driveability over






                      5-5

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a wide temperature range.  Modification of the fuel to




achieve greater vaporization could obviate the need for




the choke or drastically reduce its periods of actuation.






5.  Ignition System Modifications




     Ignition systems optimized to initiate combustion in




accordance with engine operation and emission control




requirements, support improvements in fuel metering and




mixture control.  Spark retardation can be employed to




reduce emissions of hydrocarbons and nitrogen oxides.




Electronic ignition systems have been developed which will




improve control of spark timing at all engine operating




conditions greatly facilitate adjustments of spark timing on




vehicles in consumer use, and improve system reliability.




Retarding ignition timing results in more fuel being




burned during the exhaust phase of the combustion cycle.




Accordingly,  some loss in power and fuel economy results




and demands on the engine cooling system are increased.






6.  Lower Compression Ratio




     The use of high compression ratios improves engine




efficiency and results in more power output for a given




amount of fuel.  Combustion temperatures are high, however,
                       5-6

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causing high emission of nitrogen oxides.  The




octane requirements of high compression ratio engines




are high, necessitating the use of lead or expensive




fuel modification.  The presence of lead in gasoline




severely limits the effectiveness of catalytic converters




and reduces the life of other emission control system




components.  For these reasons,  compression ratios of




new cars are being redured to curtail NOx emissions




and promote the removal of lead additives.






7.  Air Injection




     Exhaust port air injection is one of the oldest concepts




used for controlling motor vehicle exhaust emissions.




Increased oxidation of hydrocarbons and carbon monoxide




is achieved by pumping air into the exhaust ports and




manifold.  Major revisions to the cylinder head and exhaust




manifold are required.  Since NOx control during




the combustion process has tended to increase HC and CO




emissions, interest in exhaust port air injection is




reviving.  Air injection pumps are also helpful




for effective operation of catal^ic converters




and thermal reactors.






                       5-7

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8.  Exhaust Gas Recirculation




    Recirculation of a portion of the exhaust gas into




the air-fuel mixture causes a reduction in the peak




combustion temperature and a reduction in the formation of




oxides of nitrogen.  Dilution of the fuel charge with




inert gases has the secondary effect of reducing engine




octane requirements, but with some loss in power.  Extreme




dilution causes misfiring and deterioration in driveability.




This can be compensated  for by increased throttle openings




and providing richer carburetion mixtures, but with some




loss of fuel economy.  Improved systems provide for




proportioning the recirculated exhaust gas to the air flow




demanded by the engine.  Sensitive induction system




components can be corroded and plugged by acid condensate and




dirt in the recycled exhaust.  The removal of lead and




associated scavengers from gasoline is expected to moderate




these problems.






9.  Thermal Reactors




    A thermal reactor functions as a combustion chamber




outside the engine and normally appears in the form of an




oversized exhaust manifold.  Thermal reactors receive the




hot exhaust gas from the engine, retaining as much heat as




possible with insulation.  Additional heat is generated by





                              5-8

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oxidation of carbon monoxide in the exhaust gases.   High




carbon monoxide concentrations are obtained by operating




the engine with rich fuel mixtures.  Such reactors  are




known as "rich thermal reactors."  Supplementary air is




required and it is necessary to create appropriate  mixing




and provide adequate residence time for the combustibles




present to react with the oxygen.  When designed for




rich fuel-air mixtures to promote NOX control, there is a




substantial fuel penalty.  In a "lean thermal reactor"




system the carburetion is set lean so that the exhaust




is inherently oxidizing and a secondary air pump is not




required.  Emissions are generally higher than from "rich"




reactors.






     Because of the extremely high temperatures that can




be reached, the selection of suitable materials to  give




satisfactory durability is a major challenge. Special




protective systems will be needed to prevent  overheating




vvhich could damage the engine or create a general




safety hazard for the vehicle occupants.






10.  Afterburner




     The afterburner is designed to oxidize unburned




hydrocarbons and carbon monoxide in the exhaust gas.





                       5-9

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It includes a precoihbustion chamber in which secondary




air and fuel are sparkignited to provide thermal energy




for the associated reaction chamber.  Over-temperature




problems present a serious handicap to its use.






11.  Catalytic Converters




     Catalytic converters are devices designed to




receive exhaust gases and foster chemical changes associated




with reducing levels of undesired pollutants.




The catalyst bed generally consists of an inert support




material on which the active material is deposited in a




thin layer.  Alumina is the most common support whereas




platinum, or platinum group metals, and transition metal




oxides are the most common active materials.  Catalysis




may be used for oxidizing the hydrocarbons and carbon




monoxide or reducing nitric oxide.  The basic construction




of reducing catalysts is similar to that for oxidizing




catalysts.  Reasonable effectiveness can be obtained for




both reactions with identical catalysts under ideal




conditions.






     The catalytic converter is a relatively low-temperature




device and need not be located in the engine compartment






                         5-10

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with attendant space problems.  Under body modifications




may be required, however, for heat insulation and adequate




ground clearance.  It has a high heat capacity,  requiring




a relatively long time to reach activation temperature,




but by the same token, it remains warm longer.  A catalyst




and thermal reactor combination represents an attractive




system for controlling vehicle emissions.  The thermal




reactor increases the exhaust gas and catalyst temperatures




and provides improved control during cold-start and warm-




up.  Deterioration tends to occur as a result of cyclic




exposure to a high temperature environment*  AS with



thermal reactors, fail-safe over-temperature controls




are required to prevent permanent damage resulting




     unit or engine malfunction.
     Oxidizing and reducing catalysts may be used in




combination but some mixture enrichment is needed to provide




the necessary reducing atmosphere in the reducing stage,  and




supplemental air may be required for the oxidation stage.




Warm-up problems in the second stage are accentuated in




"dual catalytic converters."  Good driveability and




minimal economy loss is possible with this concept.



However, reducing • -analysts with good endurance are





not yet available.





                       5-11

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C.  Industry Concerns




     Various industry representatives have expressed a




number of concerns about the prospect of meeting the 1975




and 1976 standards.  While no one speaks for "the industry,"




there is enough commonality in content to identify a number




of major concerns shared by many of the manufacturers.  It




has been asserted that the proposed standards cannot be attained




with available techro)ogy, would be far too expensive compared to




their effectiveness on axr quality and include deadlines that pro-




vide the industry with insufficient lead time. A number of




manufacturers have  also  expressed concern over  increases in




costs  and reductions  in  fuel economy and driveability after




modification to meet  the 1975 and 1976 standards.






     Various manufacturers have pointed out that t'.ie law




requires them to solve two very different technical problems




almost simultaneously.  Hydrocarbon and carbon monoxide controls




needed for the 1975 standards dictate more complete combustion




in an oxidation atmosphere while controlling oxides of




nitrogen necessitates lower combustion temperatures and/or




a reduction atmosphere to convert these emission to nitrogen




and oxygen gases.






                            5-12

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     A number of officials of both domestic and foreign




producers indicated that achieving the 1976 NOX standards




takes them beyond existing knowledge and  will require some




technological breakthrough.






D.  Exchange of Technical Information




     Several manufacturers have complained about present




limitations on exchange of technical information concerning




vehicle emission control.  These problems relate to the




civil antitrust action brought by the Department of Justice




in early 1969.  The Government's complaint alleged that the




Automobile Manufacturers Association and the four major United




States manufacturers of motor vehicles, conspired to eliminate




competition among themselves in the development and installation




of motor vehicle air pollution control equipment.  The




Government charged specifically that the defendants had agreed




to restrict public knowledge of research and development efforts




related to control of motor vehicle emissions, that the defendants




had delayed installation of control equipment, and that the




defendants had deliberately misinformed California regulatory




officials about the technical feasibility of reducing motor




vehicle emissions.  On September 11, 1969, the defendants,




without admitting the truth of these allegations, entered into





                              5-13

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a consent decree which, among other things,  prohibits each




defendant from agreeing with any other defendant, or with any




manufacturer of motor vehicles,  to exchange unpublished technical




information for developing, improving or lowering the cost of




motor vehicle air pollution control equipment.






     The consent decree expressly permits the defendants to




continue to exchange "basic research," as  distinguished from




"applied research," and defines  "basic research" to include




"theories of control of motor vehicle emissions..., "as well




as information pertinent to gaining a fuller knowledge or




understanding of the presence, nature, amount, causes, sources,




(or) effects... of motor vehicle emissions in the atmosphere."




The decree also permits the defendants to exchange information




that relates primarily to the "testing or measurement" of control




equipment and information that results from testing or measuring




"advanced stage" production prototypes.  In addition, the decree




expressly permits the defendants to exchange information that




is made public through disclosure to news media or at meetings




where persons other than employees of motor vehicles manufacturers




are permitted to be present.
                           5-14

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The decree contains other provisions which specifically allow




the defendants to purchase from each other or from other




motor vehicle manufacturers "specific commercial products*"




"specific existing patent rights," and "specific existing..."




information or "engineering services" related to vehicle emission




control. Finally, the decree does not prohibit any defendent




from entering into or performing an agreement to which the




Department of Justice consents in writing.




     A number of manufacturers of motor vehicles, including




most foreign manufacturers who sell motor vehicles in the




United States, contend that progress in emission control




technology is best achieved  through unrestricted information




sharing. The smallest of the major United States manufacturers




claims that exchange of technical information is essential




to permit it to design engine systems that are compatible with




components that it must continue to purchase from other




manufacturers. In general, the smaller manufacturers contend




that their resources are inadequate to support an independent




research and development program which encompasses more than




a few areas of technological promise. They contend that only




the large vehicle manufacturers are able to seek answers




simultaneously to all of the interdependent engineering and




scientific challenges that are encountered in attempting




to mass produce vehicles that perform adequately and meet




                          5-15

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statutory emission standards.






     While industry-wide research programs have been effectively




deterred by restrictions imposed on the major United States




manufacturers through the consent decree,  the Department of




Justice has approved certain limited arrangements involving




specific research projects in which participation from related




industries is regarded as particularly important or involving




vehicle manufacturers who must purchase essential engine




components from other manufacturers.  Pursuant to the decree,




the Department has consented to annual renewals of an inter-




industry research program which includes the Ford Motor Company,




certain foreign vehicle manufacturers, and a group of oil




companies.






     The "Inter-Industry Emission Control Project" is specifically




limited to five or six defined research topics, and it is




understood that the vehicle manufacturers participating in the




project undertake substantial research and development activity




independent of the project.  Foreign particpants are:  Fiat,




S.P.A., Mitsubishi Heavy Industries. Ltd., Nissan Motor Company,




and Toyo Kogyo Company,  Ltd.  In addition, Volkswagenwerk A.G.




and Toyoto Motor Company, Ltd., have more recently purchased




rights of access to the project's technical work.  However, these
                            5-16

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two additional foreign manufacturers are not full participants




in that they do not themselves provide the other project




members with technical information.   The Justice Department




has also permitted American Motors to purchase certain




emission control engineering services from General Motors.






     In general, the Environmental Protection Agency agrees with




the Department of Justice that technological progress in auto-




mobile emission control is best assured through primary reliance




on competition and independence in research and development




efforts conducted by manufacturers.   At the same time, it




must be recognized that the emission reductions required by




law present a technological challenge that may severely strain




the resources of smaller manufacturers and may raise special




problems in the case of manufacturers who must continue to




purchase major engine components from other manufacturers.






     It is also possible that a vehicle emission control




system or device could be independently discovered which,




if not generally known to members of the industry in time to




make necessary modifications in production facilities, could




radically affect existing competitive relationships in the




industry and could significantly reduce the number of independent




manufacturers.  The possibility that severe competitive dislocation
                           5-17

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could result from independent research and development activity




is a matter of major concern.  The compulsory licensing provisions




contained in Section 308 of the Act may not obviate this problem




because it applies only to patented devices.  The Environmental




Protection Agency will closely monitor research and development




activities conducted by each member of the industry.  In addition,




the Agency will urge the Department of Justice to continue to




approve limited arrangements between particular manufacturers




that may be needed to meet special problems.
                             5-18

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                    CHAPTER 6:  Costs






A.  Cost of Attaining the 1975 and 1976 Standards




     Precise estimates of the cost of attaining the 90%




reductions in HC, CO, and NOX required by the Clean Air Act




amendments of 1970 cannot be made at this time.  The total




cost to the public will, however, include the initial cost




of the control system, its maintenance after warranty,




and expected increases in fuel consumption and reductions in




vehicle performance.




     Preliminary estimates of the cost of the 1975 HC and CO




control systems have been made by the manufacturers.  However,




no final decision on the control system to be used has yet




been made.  Since the technology for achieving the desired




levels of NOX control for 1976 is not now available,




estimates of the related costs are even more speculative.




However, it appears that costs associated with 1975 and 1976




standards will be considerably greater than those experienced




in achieving Federal emission standards through 1974.




     A variety of control systems are under development for




meeting the 1975 HC and CO standards.  Figure 1 indicates the




estimated cost per car of achieving control standards through




1975.  Costs through 1974 are derived from estimates published




in EPA's Cost of Clean Air report of March 1971.   Estimates




                           6-1

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of the cost of 1975 vehicles were provided informally by




manufacturers and range  from 80 to 600 dollars per  car.




Thus far, EPA has not been able to develop an independent




estimate for 1975 costs.  As indicated above, precise cost




estimates cannot be made for 1976 standards.




     Also included on Figure 1 is a table showing the




percent reductions in emissions for the various model years




compared to those emanating from uncontrolled vehicles.




As explained in Chapter 1, the legislation requires that




1975 vehicles include a 90% reduction in HC and CO emissions




compared to the levels permissible in 1970, and that 1976




vehicles include a 90% reduction of NOX from the levels




observed in 1971 uncontrolled autos.  Since the 1970 base-




line vehicles included some emission controls of HC and CO,




the 1975 standards for these emissions require very high




levels of control when measured against uncontrolled




vehicles.  It should also be noted that the cost per car




indicated in Figure 1 covers only the initial production




costs and does not reflect any costs for maintenance after




warranty or increases in fuel consumption or reductions or




vehicle performance.




     Figure 2 was prepared by the Department of Commerce




on the basis of informal information obtained from automobile




industry sources.   This graph depicts the estimated increases




                            6-2

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   INITIAL COST PER CAR

   OF EMISSION

   CONTROL SYSTEMS

    Does not include the cost of
  maintenance after warranty and
      _^ • • •   	I  j, •   •  m  •
a:
^
o
02
LU
a.
<7>
o
o

ouu
500

400
300
200
100
0
ecomony and performance f
— &/
^ i
— ^'
/'
^^ A •
^^^^ is* f •
^J V •
-^ V • •
Q • • •
** • • •
< IQV •"•••"

69|70 71| 72 73|74 75 71
          MODEL YEAR
% REDUCTIONS OF POLLUTANTS REQUIRED
  BY FEDERAL STANDARDS COMPARED
     TO UNCONTROLLED VEHICLES
 62
  0
69
25
            FIGURE 1
97
25
97
90

-------
    ESTIMATED COST  PRICE  PER CAR


       TO  CONTROL AUTO EMISSIONS
COST(price)PER CAR
S600
 500  -
 400  -
 300  -
 200
 100
   0    10    20    30    40    50    60    70    80    90



      FIGURE 2   Percent AUTO EMISSION CONTROL   June 1971



   Source Generalized from manufacturers'private estimates   prepared by the Department of Commerce
100

-------
in production costs per car in the 1976 model year of




controlling HC, CO, and NOX at various levels of emission




reduction—assuming that all three pollutants would be




controlled at the same level.  Since all three pollutants




will not be reduced by the same amount from the baseline of




uncontrolled vehicles, this graph is merely illustrative




of the principle that costs of control are expected to rise




steeply as emission reductions move beyond some point.  The




thrust of this illustration is that the last 5-10% is likely




to be much more costly to remove than the first 5-10%, but




these figures are not known with certainty.






B.  Cost-Effectiveness of Motor Vehicle Emission Control




     Under Section 312(a) of the Act, the Administrator of




EPA is required to report to Congress on January 10 of each




year concerning the economic impact of achieving air quality




standards.  Among other things, that report is intended to




provide a basis for evaluating the program and costs for




achieving air quality standards.  Accordingly, future reports




submitted under Section 312(a) will address some of the key




economic issues involved.  In the public interest, ambient air
                          6-5

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quality standards should be achieved at the least cost

possible.  Since knowledge of effects of air pollution and

of technology for controlling emissions is constantly

improving, it will be necessary to periodically review the

effectiveness and costs associated with alternative approaches

of meeting ambient air Quality standards and thus protecting

the Nation's health and welfare.

     As indicated in Chapter 4, the control of auto emissions

is an important element in achieving the ambient air standards

for HC, CO, NOX, and photochemical oxidants.  However, the

relationships between automobile emissions control and the

achievement of national ambient air quality standards is

extremely complex.  For example:

     a)  Motor vehicles are not the only important sources

         of HC, CO,  and NOX.  Other sources are identified

         in the table on page 4-1.

     b)  The significance of auto emissions upon ambient air

         quality varies from place to place, and therefore

         so does the effectiveness of auto emission controls

         compared to controls over other sources.


     c)  The cost of HC, CO, and NOX control for motor

         vehicles are interrelated since some types of HC

         and CO control make it more difficult to reduce

         emissions of NOx-
                              6-6

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     d)   Meeting the 1975/76 standards will have a cumulative

impact over time on air quality as new controlled vehicles

replace older models in the automobile fleet.  This can

be seen on Figures 3,  4, and 5, which depict EPA estimates of

future national levels of NOx,  HC and CO emissions from gasoline-

fueled motor vehicles  assuming all future Federal standards are

achieved.  The graphs  do not reflect the possible impact of

modifying used vehicles to attain emission reductions.

     Considerations such as these are particularly important

in attempting to find  the least cost means of achieving ambient

air quality standards, since the impact of achieving various

reductions in automobile emissions will influence the costs

of reducing pollutants from other sources.  Other sources

of particular pollutants (e.g., NOX from power plants) may be

so important in some areas that the reduction of automobile

emissions will contribute relatively little to meeting ambient

standards in that area.


C.  The Relationships  between Costs and Effectivensss in
    Reducing Air Pollution

     As suggested earlier in this chapter, many of the

relationships between  costs and effectiveness are not yet

well understood.  All  of these factors require further study


                            6-7

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   <
Q

(/)  Q.
UJ  O
         OXIDES OF NITROGEN EMISSIONS FROM
         MOTOR VEHICLES IN THE UNITED STATES
                                     1965-1990
      10.0
8.0
       6.0
P  §   4.0
O  =!
      2.0
       1965
 FIGURE
    3
       1970
1990
     1975    1980    1985
      MODEL YEAR
PROJECTIONS BASED ON ACHIEVING
ALL FEDERAL EMISSION STANDARDS

-------
        HYDROCARBON EMISSIONS FROM
        MOTOR VEHICLES IN THE UNITED STATES
                                   1965-1990
O  d
       1965
 FIGURE
    4
1970
1990
     1975   1980   1985
      MODEL YEAR
PROJECTIONS BASED ON ACHIEVING
ALL FEDERAL EMISSION  STANDARDS

-------
   er
   LU
   LU
   o.
HI  O
         CARBON MONOXIDE EMISSIONS FROM
         MOTOR VEHICLES IN THE UNITED STATES
                                   1965-1990
      100
      80
      60
      40
      20
       1965
 FIGURE
    5
1970
1990
     1975   1980   1985
      MODEL YEAR
PROJECTIONS BASED ON ACHIEVING
ALL FEDERAL EMISSION STANDARDS

-------
to ensure that desirable levels of air quality are achieved




at the most reasonable level of costs to the American people.




Knowledge today is simply not adequate to identify specific




numerical values for costs and benefits.




     However, even without the specific data, some conclusions




can be drawn.  Beyond some point, costs will increase more




rapidly as successively greater reductions in emissions are




achieved.  However, in some situations, the la.<*t increment




of impurity in the air will be less important to remove than




the earlier increments.  Thus it will be important to consider




both the cost and value of incremental improvements in air




quality.




     A great deal of the knowledge required to assess the




cost-effectiveness of various alternative pollution control




strategies is expected from the review of State implementation




plans which must be prepared during the coming months.  These




implementation plans will provide considerable information on




the sources and amounts of emissions.  This knowledge will




increase further as monitoring and surveillance programs are




improved and expanded.  In addition, EPA's research programs




are designed to improve knowledge of the health and other




effects of various pollutants.  This information, together




with economic analyses that will be carried out or supported




by EPA should provide an improved basis for future program




                         6-11

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decisions.





D.  Industry Sponsored Research and Development




     In response to the Administrator's letter of February 26,




1971, the industry supplied EPA with information concerning




their expenditures for developing and testing emission control




systems.  These responses indicated industry-wide costs of




nearly $250 million in 1970 with a one-third increase




projected for 1971.  This information also revealed that




about six thousand professional and technical personnel were




engaged in emission control research and development programs




for the manufacturers in 1970,  with a similar one-third expan-




sion projected for 1971.  Thus, there has been a significant




increase in industry resources devoted to emission control




programs since the passage of the 1970 amendments to the Act.




     The information supplied by the industry appears to lack




total comparability due to the variations in definitions and




allocations of cost figures.  In addition, much of this




information furnished was indicated as being confidential




by the manufacturers who alleged that it related to "trade




secrets."  Section 208 of the Act allows the Administrator




to keep information confidential if he finds that it does in




fact relate to "trade secrets."  EPA does not agree that all




of the information so indicated relates to "trade secrets."




V7ork is underway to develop appropriate protocols to permit






                            6-12

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the collection of data on the magnitude of the industry's




emission control efforts on a fairly consistent basis.  This




information should be available for public distribution at




some time in the future.
                            6-13

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