Environmental and Economic Impact
Statement
Revised Evaporative Emission
Regulations for 1931
and Later Model Year Gasoline-
Fueled Light-Duty Vehicles and Trucks
Environmental Protection Agency
Office of Air and Waste Management
Mobile Source Air Pollution Control
Michael'^P. Walsh, Deputy Assistant ^Administrator
for Mobile Source Air Pollution Control
Approved By
Date:
-------
S-l
SUI^G-iARY f'iEETS
FOR
FINAL ENVIRONMENTAL IMPACT STATEMENT
PREPARED BY
OFFICE OF MOBILE SOURCE AIR POLLUTION CONTROL
ENVIRONMENTAL PROTECTION AGENCY
1. Title of Action: Revised Evaporative Emission Regulations
for 1981 and Later Model Year Light-Duty Vehicles and Light-Duty
Trucks.
2. Description of Action: EPA is establishing a more stringent
fuel evaporative emission regulation for light-duty vehicles (LDV)
and light-duty trucks (LDT). The standard established for 1978 and
later model year LDVs and LDTs is 6.0 grams of hydrocarbon (KC) per
test when measured by the SKED {Sealed Hous.ng for Evaporative
DeterTrir.ation} test procedure. The revised stanc-ard for 1981 and later
model year LDVs and LDTs will be 2.0 grams per tesS (using ttia SHED test).
3. Environmental Impact: This action will reduce Che total tons
of hydrocarbons emitted into the air nationwide by up to 900,000 tons
in the year 1990. This represents a 25 percent reduction in hydrocarbon
emissions fro^i mobile sources in that year. In those urban areas ejected
-------
S-2
Co have difficulty achieving oxidant air quality standards, establishing
2.0 grams per test as the allowable level of fuel evaporative emissions
for 1981 and later model year LDVs and LDTs should result in a 2 percent
improvement in oxidant air quality by the 1990.
This regulation will have no effect on exhaust hydrocarbon, carbon
monoxide, or oxides of nitrogen emissions. Nor will water pollution or
noise pollution be adversely impacted. There is some potential that a
fuel savings will be realized, but the overall effect on the nation's
consumption of fuel is expected to be negligible.
4. Economic Impact: EPA estimates that the incremental cost to
comply with this regulation will be between $1 and $5.50 per vehicle
(1977 dollars). Based on these costs and the expected sales of light-
duty vehicles and trucks for the period 1981-1985, the expected aggregate
cost of compliance would be between 79 and 400 million dollars for the
first five years of implementation. Actual costs may be lower as manufac-
turers will optimize control system technology and because many vehicles
already comply with with 2.0 giam per test standard and will not have to
be modified further in order to comply with the new standard.
The per vehicle cost increase is expected to have an insignificant
adverse effect on sales, less than a 0.12 percent decrease in unit sales.
No adverse effects on employment, competition or productivity are expected.
-------
S-3
5- Alternatives Considered:
A. Take no action (i.e., retain
present 6.0 g/test standard).
B. Further control of HC emissions
from stationary sources.
C. Further control of exhaust HC emissions
from mobile sources.
D. Alternative schedules for implementing a
2g/test evaporative HC emission standard.
1. Impose the standard beginning with the
1980 model year.
2. Impose the standard beginning with the
1981 model year.
6. Availability: The Office of Mobile Source Air Pollution Control
officially filed copies of the Final EIS with the Director, Office of
Federal Activities, U.S. Environmental Protection Agency, on AUG 8 15/8 ¦
Single copies of the Final EIS are available to the public upon request
from the Office of Mobile Source Air Pollution Control (AW-455) U.S.
Environmental Protection Agency, 401 M Street, S.W. , Washington, D.C.
20460. A copy is on file at the U.S. EPA Public Iaformation Reference
Unit (EPA Library), Room 2922, 401 M Street, S.W., Washington, D.C. and
is available for inspection and copying during normal business hours.
-------
Contents
Page
I. Summary
A. Background and Description o£
This Action 1
B. Environmental Impact 2
C. Economic Impact 3
1. Character of the Industry 3
2. Impact on Consumers 4
3. Impact on Industry 4
4. Government Costs 5
5. Cost Effectiveness 5
D. Alternative Actions 5
II. Introduction
A. Need for Control, Background and
Description of This Action 7
B. Alternative Actions Considered 12
C. Structure of Report 17
III. Description of LDV, LDT Industry
A. Definition of Product 20
B. Structure of the Industry (Pro-
duction and Marketing) 21
C. Sales and Revenues 25
D. Employment 31
-x-
-------
Page
IV. Environmental Impact
A. Primary Impact 32
1. Current and Projected Emission Factors 33
2. Vehicle Population and Vehicle Usage 37
3. Nationwide Emissions 43
4. Impact on Selected Air Quality Control Regions 48
B. Secondary Environmental Impacts 62
1. Energy Consumption 62
2. Exhaust Hydrocarbon Emission
latersction 63
3. VJater Pollution and Solid Wastes 63
V. Costs of Control and Its Impact on Consumers,
Industry and Government
A. Impact on Consumers 64
1, Initial Costs 64
2, Fuel Consumption 69
3, Maintenance Costs 70
B. Impact on Industry 70
1. Sales 70
2, Competitive Structure 75
3. Pe velopazc.Lal end Certification
Costs 7 5
4, Potential Impact on Employment 75
C. Government Costs 77
D. National Annualized Cost and Capital
Investment over 5 Years 7 7
VI. Cost Effectiveness 79
VII. Other General Considerations
A. Irreversible and Irretrievable
Commitment of Resources 84
E. Relstioaships
-------
Page
VIII. Problems and Objections P 'ised by Federal, State
and Local Agencies, and Ccher Persons 86
-iii-
-------
Clnpter I
Summary
A. Background and Description of this Action
This regulation establishes a 2.0 gram per test (g/test) fuel
evaporative emission level for 1981 and subsequent model year gasoline-
fueled light-duty vehicles and trucks (0-8500 lbs Gross Vehicle Weight
Rating) when measured by the Federal Evaporative Emission Test Procedure
implemented for 1978 model year evaporative hydrocarbon (HC) emission testing.
On January 13, 1976 a Notice of Proposed Rule Making (NPRM) was
published in the Federal Register (41 FR 2022), to revise the evaporative
emission test procedures and establish standards of 6.0 g/test for 1973
and 2.0 g/test for 1979 and subsequent model year light-duty vehicles and
light-duty trucks.
The 1978 6.0 g/test standard represented a large (about 7020 reduc-
tion from 1972-1977 light-duty vehicle and truck evaporative emission
levels. A 2.0 g/test standard would add to this significant improve-
ment in emissions, but there were complex issues surrounding this
standard tnat needed to be resolved before it could be promulgated.
The risk of not being able to implement the 6.0 g/test standard due to
the additional time necessary to thoroughly study and evaluate the
-1-
-------
technical feasibility, cost and lead time associated witn the 2 gram
level, and the relationship between a 2.0 g/test standard and back-
ground emission levels, was not justified. Therefore, in order to
allow timely implementation of the revised test procedure and the
6.0 g/test standard for 1978, the originally proposed regulatory
action was divided into two separate final rulemaking activities.
The revised test procedure and a 6.0 g/test standard were promulgated
on August 23, 1976 (41 FR 35626). Promulgation of the final rule-
making for a 2g/test standard was delayed pending further study of
the above-noted issues.
The implementation of a 2.0 g/test standard is needed since
it is projected that many Air Quality Control Regions (AQCR's)
will still exceed the ambient air quality standards for oxidants as
late as 1990, even with the implementation of all presently known
control strategies for reducing HC emissions from mobile and stationary
sources.
B. Environmental Impact
This rulemaking will result in reduction of nationwide hydrocarbon
emissions from all mobile sources by as much as 10% in 1985 and 25% in
the year 1990. In those Air Quality Control Regions that are expected
-2-
-------
to have the most difficulty meeting ancient air quality standards for
oxidants in 1990, a 2.0 g/test standard will result in reduction of
hydrocarbon emissions from all sources (mobile plus stationary) by an
average of about 5% in that year. This will result in a 2% improvement
in oxidant (hydrocarbon) levels in these areas.
The implementation of the 2g/test standard is not expected to have
any effect on water or solid waste pollution. With proper utilization
of existing control technology there should be no increase in exhaust
HC emissions as a result of promulgating this more stringent evaporative
hydrocarbon emission standard. Exhaust HC emissions are, in any case,
subject to separate standards.
C. Economic Impact
1. Character of the Industry
Only manufacturers of gasoline fueled light-duty vehicles and trucks
will be affected by this rulemaking. The primary manufacturers of these
vehicles are the General Motors Corporation, Ford yotor Company, Chrysler
Corporation, American Motors Corporation, International Harvester, Toyota
Nissan (Datsun), Volkswagen and Honda.
U.S. sales of light-duty vehicles and light-duty trucks in 1976
were 12.3 million vehicles sold at a total wholesale value of aprroximate
$40 billion. The industry employs 3.7 million employees in manufacturing
wholesaling, and retailing of motor vehicles.
-------
2. Imp.ict on Consumers
B3.sed on EPA and contractor studies, it is estimated that the retail
"sticker" price will increase an average of SI ~ ?5 per vehicle (1976
dollars) for control system components required to meet a 2.0 g/test
standard. This is equivalent to about $1.10 - $5.55 in 1978 dollars.
No additional costs over the life of the vehicle due to Ln.cre.asad fuel
consumption or maintenance are expected; and therefore the additional
emissions control will cost the consumer $1 - $5.50 over the lifetime of
the vehicle. The aggregate five year costs o: this. regulation are
expected to t»e $79-£QE million (undis 5 assuming no C£rty over - f
certification test data is used. However, since ovei 30 percent of light-
duty vehicles already rnaet a 3g/cest standard, these cosrs estimates nay
be as nuch as 30 percent high.
3. Impact on Industiy
The major impact on the industry will be due to any decrease in sales
resulting from the expected $1 - $5.50 increase in the price of vehicles.
The projected sales decrease is 0.02 - 0.12%, assuming a price elasticity
G,8&^. Little increase in the cost of certifying vehicles is expected-
It is expected that only those vehicles which have not achieved during
previous uodel year's certification a 2.0 g/test level would have to be
recertified.
JJ "The Effect of Tax and Regulatory Alternatives on Car Sales and
Gasoline Consumption," Prepared for CEQ by Chase Econometric
Associates, May 19 74, p. 4.
-4-
-------
A. Covermnent Cost"?
The cost to the government for the motor vehicle certification program
is not expected to change, as the test procedure is essentially unchanged.
5. Cost Effectiveness
The cost effectiveness of this rulemaking is estimated to be $20 - $10C
per ton of hydrocarbon removed. This action is more cost effective than
HC reductions that will be obtained via other promulgated mobile source
regulations, such as the statutory light-duty vehicle standard ($500-$1,400
per ton), light-duty truck standards for 1979 and later model years ($200
per ton) and heavy-duty engine HC standards for 1979 and later model years
($154 per ton).
D. Alternative Actions
The principal alternative actions considered were: (I) Take no
action (retain the 6.0 g/test standard); (II) Set a 2.0 g/test standard
for 1980 and subsequent model year vehicles; and, (III) Set a 2.0 g/test
standard for 1981 and subsequent modal year vehicles. Alternative
action I (no action) was rejected because further reductions in hydrocarbon
emissions are needed in order for a number of Air Quality Control Regions to
meet Ambient Air Quality Standards for oxidants. Alternative II was rejected
due to insufficient lead time now available to meet the 2.0 g/test level by
1980. The 2.0 g/test level for 1981 (Alternative 111) has been shown to
-------
be technically feasible and cost effet
of a standard more qcrindent than 2.0
Adequate lead time for development of
exists for implementation in the 1981
Live. The technical feasibility
'j,/test has not yet been demonstrated,
control systems and certification
model year.
Other alternatives generally considered were the control of stationary
sources of hydrocarbon emissions and the further control of exhaust
hydrocarbons from mobile sources. Due to the nature of stationary source
HC pollution and the current infeasibility of further exhaust hydrocarbon
control from mobile sources over what is currently planned, combined with
the fact that even if all known HC control techniques were effected, many
ambient air quality control regions would still fail to comply with
oxidant standrds, these alternatives were rejected and are not treated in
any detail in this report. (See Section B Chapter II)
-6-
-------
Chapter It
Introduction
A. Need far Control, Background and Description of This Action
In many geographic regions a large portion of hydrocarbons (HC),
carbon monoxide (CO), and nitrogen oxides (NOx) present in the air are
attributable to motor vehicle emissions. The Congress, in recognition
of the air pollution problem, passed the CLean Air Act which provides
for a national air pollution program to monitor and control emission',
from new motor vehicles and engines.
Section 202(a) of the Clean Air Act (42 U.S.C. 7521) provides
that the Administrator shall prescribe standards for motor vehicle
emissions if such emissions may reasonably be anticipated to endanger
public health or welfare. Under Section 206, the Administrator must test
Or require testing of new motor vehicles to determine compliance with
applicable standards under Section 206 and the general power to promulgate
regulations is granted in Section 301.
The need for further control of evaporative hydrocarbon emissions
is based on the determination that the present and planned regulations
for control of mobile and stationary source hydrocarbon emissions are
insufficient to bring many Air Quality Control Regions (AQCR's) into
-7-
-------
compliance with the ambient air quali'.y standards for oxidants. This
determination was based upon an analysis which used the best available
inputs of vehicle mix, growth rates, emission factors and current ambient
air quality data. In particular, Los Angeles, Sacramento, San Diego,
San Francisco, San Joquin Valley, Corpus Christi, Houston, Phoenix-Tucson
Denver, and the New Jersey portions of the New York AQCR will still
exceed oxidant standards in 1990.
The health effects of photochemical oxidants have been considered
and described in previous publications.^/ Photochemical oxidants are
created during photochemical reactions involving hydrocarbons and are
thus controlled indirectly by controlling hydrocarbons. Ambient air
quality standards have been set, based on those considerations, at
levels which assure adequate public protection from the regulated
pollutants. The air quality standard for oxidants is .08 parts per
million per cubic meter (maximum 1 hour concentration not to be
exceeded more than once per year). Since ambient air quality standards
will be exceeded in many air quality control regions as discussed earlier
further reduction of HC emissions is necessary.
Fuel evaporative hydrocarbon emissions have been studied and
measured since 1958. Federal control of evaporative emissions was
first proposed in the Federal Register on February 4, 1967 (32 FR,
pp. 2448-50) to become effective for the 1969 model year. At that
time a then novel and relatively untried measurement procedure was
1/ Air Quality Criteria Documents, Nos. AP-62, AP-63, AP-64, and
AP-84 ' _8_
-------
proposed in which the evaporative emissions would be collected in a
large sealed enclosure containing the rest vehicle. However, when
final rulemaking was published in the Federal Register on June 4, 1968
(33 FR, pp. 8304-24), the vehicle enclosure measurement procedure
was abandoned in favor of a better known procedure, called the carbon
trap method, which utilizes the absorption of hydrocarbon on activated
carbon to rr.easure emissions. The activated carbon, encased in a necal
canister, is weighed before and after the test to determine the mass of
hydrocarbon absorbed.
The evaporative emission test measures the evaporative hydrocarbons
emitted by the vehicle during simulated daily temperature changes,
vehicle operation, and periods of hot engine soaking. This is accom-
plished during a three part test. The first part consists of artifi-
cially heating the fuel tank during a one hour period to simulate the
normal rise m tank temperature resulting from normal daily ambient
temperature increases (diurnal losses). The second part of the test
measures the losses during vehicle operation over a 7.5 mile trip
(running losses). The third portion of the test consists of measuring
the evaporative losses during the first hour after*vehiclc operation,
when the engine is still hot (hot soak losses).
Using this test sequence, an emission standard was set at 6.0 g/test
for the 1971 model year as measured by the carbon trap method. The
evaporative emission standard was then reduced to 2.0 g/test for 1972
and subsequent model years.
-------
Over the intervening years since 1967 the vehicle enclosure method
has boon evaluated by several organize'ions. Ultimately it was decided
that is was "a superior technique, a versatile tool" (SAE paper 680125)
compared to the carbon trap method, and was developed into a Society of
Automotive Engines recommended practice (J171a)._2/ This procedure was
further modified to produce the Federal enclosure test method (Sealed
Housing for Evaporative Determination, or "SHED" procedure)
On January 13, 1976 a notice of proposed rulemaking (NPRM) was
published in the Federal Register (41 FR 2022), proposing the adoption
of the SHED evaporative emission test procedure and standards of 6.0 g/test
for 1978 and 2.0 g/test for 1979 and subsequent model years.
In the final rulemaking EPA decided at first to promulgate only the
new test procedure and the 6.0 gram/test standard. Based on comments
received to the NPRM it appeared evident that the issue of a 2.0 g/test
gram per test standard was much more complex tnan issues concerned with
the revised test procedures and the 1978 standard. However, the 6.0 gram
standard represented so large (about 70%) of a reduction from the existing
light-duty vehicle and truck evaporative emission levels, that any delay
in promulgating this standard due to performing analysis of issues related
to the 2.0 g standard was not justified. Additional time was necessary to
thoroughly study and evaluate (1) the technical feasibility, cost and lead
time associated with the 2.0 gram level and (2) the relationship between a
2.0 g/test standard and background emission levels. The revised test procedure
2/ "Measurement of Fuel Evaporative Emissions from Gasoline Powered
Passenger Cars and Light Trucks Using the Enclosure Technique -
SAE J17la," published in the SAE Handbook, 1973.
-10-
-------
and 1978 standard were promulgated sep irately from the final rulemaking
for a 2.0 gram/test evaporative emission standard; which is considered
in this impact statement. A separate impact statement was prepared
for the 6.0 g/test standard and revised test procedure (Environmental
and Economic Imp<--ct Statement: Revised Evaporative Emission Regula-
tions for the 1978 Model Year).
The regulations now being promulgated will require more stringent
control of evaporative emissioits from light-duty vehicles and light-duty
trucks by reducing the evaporative emission standard from a 6.0 g/test
to a 2.0 g/test. When originally proposed, the 2.0 g/test standard was
to apply to 1979 and later model year vehicles. However, implementation
of the more stringent 2.0 g/test standard will now bt> delayed until
1981 due to insufficient lead-time for implementation in either 1979 or
1930.
It should be noted that light-duty trucks (0-8500 pounds gross
vehicle weight rating) will be controlled to the same 2g/test level
as light-duty vehicles, beginning with the 1981 model year. Already
developed evaporative emission control technologies can be applied
effectively to light-duty trucks to achieve these levels.
-11-
-------
B. Alternative Actions Considered
The following alternative actions for further evaporative emissions
control will be considered in this report:
Alternative Action I - No action, i,e., retain the present
6.0 g/test standard.
Alternative Action ]1 - Set a 2.0 g/test standard for 1980 and
subsequent model years.
Alternative Action III - Set a 2.0 g/test standard for 19S1 and
subsequent model years.
EPA's procedures for the voluntary preparation of Environmental
Impact Statements state that EPA will "...[d]escribe and objectively
weigh reasonable alternatives to the proposed action, to the extent
3 /
such alternatives are permitted by law."— In determining which
alternatives are reasonable, EPA has traditionally exanined such
factors as magnitude of emission reductions, economic considerations,
expected adverse impacts and irreversible commitment of resources.
Only when all these factors have been balanced can an effective, non-
disruptive strategy for the control of emissions be selected.
3/ 39 FR 37419, October 21, 1974, section 3(c)(2).
-12-
-------
In the broadest sense the options open to EPA as alternative
actions to promulgating a more stringent federal evaporative hydrocarbon
standard include: more stringent control of other hydrocarbon emissions
from passenger cars, motorcycles, light-duty trucks, heavy-duty vehicles
or some as yet uncontrolled mobile source; and control of stationary
sources of KG emissions. Each of these strategies has its advantages
and disadvantagesj and on balance, EPA concludes that promulgating a
2g/test evaporative HC emission standard for light-duty vehicles and
trucks represents a reasonable, cost effective emission control strategy.
Control of Stationary Sources
The two categories of man-made sources of HC pollution are stationary
sources and mobile sources. In 1972, the stationary source contribution
to nationwide emissions of HC was roughly equal to the mobile source contri
but ion". Thus it could be concluded that HC emission control strategies
should be apportioned equally among stationary and mobile sources. In
practice however, and due to the statutory framework of the Clean Air Act,
reductions in HC emissions for significant mobile sources have been accom-
plished rruch more quickly than those for stationary sources.
In comparing any mobile or stationary source emission control strategy
as a reasonable alternative to this regulation, consideration must be
given to the purpose of Lhe control of emissions from both mobile and
stationary sources. The Clean Air Act as amended August 1977 requires
that the National Ambient Air Quality Standard (NAAAQS) for oxidants be
-13-
-------
met in all regions of the nation by 1S82. This goal may not be achieved
by a number of urban areas of the counLry so the Act permits States, if
a showing can be made that the standard can not be achieved by 1982, to
include in their implementation plans provisions which wilL provide for
attainment of the NAAQS as expeditiously as practicable, but not later
4/ ....
than 1987. — Obviously, large reduction in HC emissions wiLl be necessary
to meet this goal in many regions. To be able to consider one control
strategy as an alternative to another implies that the goal of achieving
the NAAQS can fce achieved by the majority of the nation by implementing a
few of the available strategies. Such may not be the case in some air
quality control regions given existing air quality levels. Thus some
apparent alternative actions are not really alternatives at all.
Analyses performed for a long-range Federal Government planning
effort—^ indicate the need for substantial emissions reductions in
large areas of the nation. The following chart, based on measured
air quality data for 197] through 1973, represents the emission reduc-
tions needed to meet the HC NAAQS from sources which existed during the
1971-1973 time period. t,Tien growth is considered, the needed degree of
control is increased (i.e., more control than is indicated by the
chart is needed today simply due to the growth in the number of both
r.obile and stationary sources).
47 Clean Air Act, Section 172.
bj Panel Report on Air Ouality, lioise and Health, "Interagency Task
Force on Mobile Vehicle Goals Beyond 1980, Marcn 1976.
-14-
-------
TABLC II-1
COST EFFECTIVENESS STRATEGIES FOR CONTROL OF HC EMISSIONS IN 2000
%of
Cum %
HC
Baseline
of
Cost
Anniui!
Cum Annual
Cum HC
Control Strategy
Removed
E misnons
Baseline
Effectiveness
Cost
Cost
Removed
(v/itli % Control)
(106 Tons}
Removed"
Removed
(S/Ton)
(106 Dollars)
(106 Dollars)
(10° Tons)
Decreasing 0-40' '
0 30
1 1
1 1
-210
-61
-61
0 30
Gtavure 0—03' '
0 22
08
1 S
-50
-11
-72
0 52
Gas Terminal 0—G7
0 91
3 4
5 2
0
0
-72
1 43
Acrylonnrilc. 0-35
0 10
0 5
5 5
0
0
-72
1 53
Polyethylene 0—95
O !9
0 1
6 2
0
0
-72
1 72
Chjrcoal 0—99
0 34
1 ?
1 4
0
0
-72
2 06
Miscellaneous Chemicals 0-313
0 GO
2 2
9 6
0
0
-72
2 6G
Dry Cleaning 0-80
0 48
1 7
11 3
10
5
-67
3 14
Industrial Finishing 0 -75
1 82
6 8
17 8
10
18
-49
4 96
C.jiijon 3lo<~- 0-95
0 11
0 5
18 3
10
1
-43
5 10
Formaldehyde 0-95
0 OG
0 2
18 5
10
1
-47
5 ID
Reiinmg 0—67
1 53
5 7
24 0
13
20
-27
G 69
Aicli Codiiii'js 0— 100
1 00
3 7
27 G
15
1 5
-12
7 69
GHDVEvop 5 8 — 0 5 gm/mi
0 58
2 1
29 7
18
10
-2
8 27
Open Burning 0-25
0 30
1 1
30 B
20
6
4
8 57
F thylcni' 0> tde 0-95
0 '14
1 6
32 4
20
9
13
9 01
Aciyloniitilf 30—99
0 17
0 6
33 0
37
6
19
9 13
£[fiy/crir» Qictylo housi 2 9-08 gm/mi
o r.i
3 1
50 2
470
395
1330
13 93
Foundrii'S O-bO
0 15
0 5
50 7
500
75
14 10
14 13
Lcttci press & l.tthoyfLipliv 0-90
0 27
i 0
5i 7
7 00
WO
1600
14 40
Gas 1 IdriUling 51-91
0 08
2 5
54 1
700
47b
2080
15 08
t3 is?11ri t mi\ icjih. , 1 0^ io«»s in 'COO oMot j11ue '0..V ot 0 l yn nu ,md Gl >DV cvjpoia i t loss 5 b ijiurrrti
T ir si ti o iii'iti'y ( » 11 -• i tl u nili »o cost i.-v.n^s duo .u 'CCuvf i»Cl rr.o'e Hi in of In 11 «r»g i lie CO -1 of lf'0 tonirol si rati jics
-------
Thus the Agency finds no reason to further examine alternative
mobile or stationary source emission control strategies in its examina-
tion of reasonable alternatives to this regulation. For HC emission
control, strategies, there do not appear to be an adequate number of
individual alternative control strategies sufficient to achieve the
NAAQS for oxidants in substantial portions of the country. For this
reason all reasonable HC emission control strategies are planned to
be implamented.
C. Structure of Report
This report is an analysis of the environmental and economic impact
of setting an evaporative emission standard of 2.0 g/test for 1981
and subsequent model years, and considers similar impacts for alternative
strategies for control of evaporative HC emissions.
Chapter III of this report will set the ground work for these
analyses by describing the light-duty vehicle (LDV) and light-duty truck
(LDT) industr ies with respect to production and employment, etc. In
addition, current and projected vehicle population^, and a description
of vehicle usage will be presented.
Chapter IV will discuss the primary and secondary impacts of the
alternative actions on environmental quality*
-17-
-------
In Chapter V, the analysis of the costs to the consumer, industry
and government will be discussed. The predicted costs reflect an average
cost to alL consumers and industry, and therefore ignore the variability
in cost to individual consumers resulting from manufacturer use of a
variety of emission control systems to meet the standard, and the costs
of the equipment in that system. The actual costs to consuners may
also vary depending on a manufacturer's perception of its market
position and the discretionary power he has in setting prices of vehicles.
The cost effectiveness of the 2.0g/test standard will be discussed
in Chapter VI. The cost effectiveness of this action and the cost
effectiveness of alternative actions for the control of hydrocarbon
emissions will be compared. Cost effectiveness will be expressed in
terms of dollars required to control a ton of hydrocarbons.
Chapter VII will discuss the impact of the alternative actions on
the irreversible or irretrievable commitment of our natural resources.
Along with this discussion, will be a discussion of the trade-offs
between short-term gains and long-term losses, or vice versa, and a
rationale for the timing of this action.
Comments on the draft impact statement will be summarized and
discussed in Chapter VIII. Comments related to the 2.0 gram/test
standard in general are summarized and discussed in detail in a
-18-
-------
separate document entitled, "Summary a^d Analysis of Comments to
the NPRM - 2 gram/test standard for Ev.toora t ive Hydrocarbon Emissions
from Light-Duty Vehicles and Trucks."
-19-
-------
Chapter IJ
Description of Product: and the Industry
A. Definition of Product
A Light-duty vehicle (LDV) is defined as a passenger car or pass-
anger car derivative capable of seating 12 passengers or less. Prior
to 1978, light-duty vehicles (and light-duty trucks) were required
to meet a 2.0 g/test evaporative emission standard as measured by the
carbon trap method. Beginning with the 1978 model year, light-duty
vehicles (and light-duty trucks) are required to meet a 6.0 g/test
evaporative emission standard as measured by the enclosure test method.
The definition of light-duty trucks (LDT) for the 1979 and later
model years is any motor vehicle rated at 8,500 pounds Gross Vehicle
Weight Rating (GVWR) which has a vehicle curb weight of 6,000 pounds
or less and which has a basic vehicle frontal area*of 46 square feet,
or less, which is : 1) Designed primarily for purposes of transportation
of property or is a derivative of sucli a vehicle, or 2) Designed prima-
rily for purposes of transportation of persons and has a capacity
of more than 12 persons, or 3) Available with special features enabling
off-street or off-highwav operation and use. Prior to the 1979 model
year, trucks between 6,000 and 8,500 pounds GW ware classified as
-20-
-------
heavy-duty vehicles .rind as such they v>Te not required to comply with
evaporative emission regulations.
The manufacturers of LDVs and LDTs produce a wide variety of vehicles
consisting of many significant variations in vehicle design and size
and many engine configurations, engine sizes, fuel tank sizes, etc.
However, variations in product configuration should pose no unsolvable
problems for the industry in complying with further evaporative regula-
tions. EPA surveillance data on controlled 1972 and 1973 light—duty
vehicles did not show any statistically significant correlation between
fuel tank or engine size and evaporative hydrocarbon emissions.
B. Structure of the Industry (Production and Marketing)
Domestic manufacture of light-duty vehicles in the U.S. is almost
entirely done by four motor vehicle manufacturers: General Motors Corporation,
Ford Motor Company, Chrysler Corp., and American Motors Corp. However,
a sizeable percentage of new LDV sales is comprised of imported vehicles.
U.S. domestic producers imported over 750,000 cars from plants they operate
in Canada. The major foreign importers are Toyota^ Nissan (Datsun),
Volkswagen and Honda. Imports accounted for roughly 18% of new car
sales in the U.S. in 1976.
-21-
-------
The manufacture of light-duty truc':s sold in the U.S. is primarily
accomplished by the major domestic pasfunger car producers. General
Motors (Chevrolet and GMC divisions) Ford Motor, and Chrysler (Dodge)
all have separate truck divisions which light-duty trucks. American
Motors operates the Jeep division which manufactures light-duty trucks.
The other major domestic manufacturer of LDTs is the International
Harvester Corporation (IHC). International does not produce light-duty
passenger vehicles but does produce various models of light and heavy-duty
trucks.
Some LDTs sold in the U.S. are imported. The majority of U.S.
imports of trucks come from the Canadian plants operated by U.S.
domestic producers. Others, however come from Japanese producers and
consist primarily of light pick up trucks under 4000 pounds GVW. The
major importers are Nissan (Datsun), Toyota, Isuzu and Toyo Kogyo
(Mazda). Both Toyota and and the British LcyLand Company import
utility vehicles under 6,000 lbs GVW. Imports account for about 5%
of all 1975 factory sales of trucks with a GVW less than 10,000 pounds.
Table III-l shows unit factory sales for light-duty vehicles and
light-duty trucks from U.S. plants. Most data available on light-duty
trucks are presented in two categories, based on GVW. There is a
0-6,000 pound and a 6,001-10,000 pound category. Since the definition
-22-
-------
Table ITI-l
Lighc-Dmy Vehicle and Li£hi-Ducy Ti ucl
Faccoiy Sales from U.S. PlanLS^"
l'y oo n_C V o 11 i_cj e
Liglic-DuLy Vehicle
L l y,h L - l)u t. y Truck
i udef. l ncd cl.i^s
(0-3,500 ]b. GV\/)
T IIV plus redefined
I.UT c ] Jes
19/0'
1 lJ 7 3
197 - i
197 3
] 9 7 2
1971
8,A 97,603 6,712,852 7,331,966 9,657,667 8,823,938 8,584,592
2 , 503/(63 1,863,223 2,156,892 2,372,269 1,899,206 1,598,785
11,003,051 8,561,075 9,686,838 12,029,916 10,723,162 10,183,377
Source: Motor Vehicle ManitLac Curers \ssociaiion oC the United Scales, Inc.
1) Includes cho-;e veliLcle produce in U.S. thaL are expoi ted
2) Data C rop\ Auioi.'ouve Uo'.'s, 1 97 7 Market DaLu Book
n 11a La fn>iM Automotive MeJ~> Ali'iainc, 197 5
-------
of light-duty trucks includes only trvcks up to 8,500 pounds GVw, some
adjustment to the 6,001-10,000 categor / was necessary. Industry production
da:\3 available to EPA indicate that oi'Ly five percent of all trucks with
GVWs less than 10,000 pounds have GVWs o£ more than 8,500 pounds. This
five percent figure is used in Table III-I and throughout this analysis
analysis to adjust production data to fit the proposed LDT definition.
Table III-2 shows new car and truck registrations for 1973 through
1976. These figures represent the numbers of both domestic and imported
vehicles bought by U.S. consumers in those years.
Table III-3 is a breakdown of market sales by manufacturer for 1976
light-duty vehicles. Al;,o included is the percent o£ the passenger car
market for each manufacturer. Table III-4 gives similar information for
the light-duty truck industry. It should be noted that Table III-4
gives market shares for 0-10,000 pounds. GVW truck sales. Data indicating
the portion of sales for 0-8,500 pounds. CVW trucks for each manufacturer
were not available and the assumption that 5% of sales would be over
8500 pounds. GVW is not valid for every manufacturer.
U.S. light-duty vehicle and light-duty truck manufacturers operate
with a fair degree of vertical integration. As is typical of r.auy
capital intensive industries, the manufacturer t^eeks to assure himself
of some control over the quality and availability of the final product.
-24-
-------
Thus, the major manufacturing companie have acquired subsidiaries or
started divisions to produce many of t'ie parts used in the manufacture
of their cars and trucks. None, however, build their vehicles without
buying some equipment from independent vendors.
The vertical integration typical of passenger car and truck manu-
facturers extends beyond the production of the vehicle into its sale.
The manufacturers establish franchised dealerships to handle retail
trade and servicing of their products. Most also produce and sell the
parts and accessories required to service their vehicles. Many of the
truck dealerships are coupled with the passenger car dealerships. As
of January 1, 1977, there was a total of 24,268 passenger car dealerships
and 23,021 truck dealerships. The total truck dealerships include
dealerships for heavy-duty as well as light-duty trucks, and accounts
for those dealerships operating jointly with passenger car sales offices.
Table III-5 provides a breakdown of all light-duty vehicle dealerships
by manufacturer and Table I1I-6 provides this information for light-duty
truck dealerships.
C. Sales and Revenues
Passenger car sales from domestic manufacturers for 1976 were 8.50
million vehicles at a toLal wholesale value of about $30 billion. For 1975,
6.71 million vehicles were sold at a wholesale value of $23.4 billion.
The light-duty truck industry (0-8,500 lbs. GVW) had 2.51 million sales
at a value of about $10 billion in 1975 and 1.85 million sales at a
-25-
-------
Tab Lc Ii T — 2
New Vehicle: Rc3' irutions
Source Mew Car Registrations
19 7 6 3 19 7 5 3 1974 A 1973*
LDV 5,751,485 8,261,840 8,701,094 11,350,995
LOT2 2,533,213 1,995,016 2,143.193 2,431,454
Total 12,339,698 10,256,856 10,344,292 13,782,449
1) Includes imports
2) I\ede_"ined Lignt-Duty Truck Class (0-8,500 lb. GWj)
3) Source. Automotive News, 1977 Market Data 3oo'<.
4) Source: Automotive Mews .^j-.anac, 1975
-26-
-------
T a b 1 r> III-3
MarxaL Sales of ..luht-Di-t;.' Vehicles
by Manjfactvrcr ccr 1"973
Mir.uf acdirc
Chcvrolat
Pontiac
Old Smobilc
3ui ck
Cadillac
GM Total
N'o. of Units Produced
2,035,S5S
706,460
S61, 435
700.77S
293,716
4,604,297
°L of: Passenger
Car klcirkcL.
20.38
7. 24
8.90
7.19
3.01
47 .22
Ford
Lincoln
ilercurv
Tord Total
1,665,619
115,301
4 08,121
2,139,541
17.OS
1.19
4 .18
22.45
Plynou th
Dodge
Oh it" s La r
Chrysler Total
526,957
460,647
271,061
1,259,076
5.40
4.72
2. 73
12.90
American Motors Corp.
247,032
2.53
Miscellaneous
1,451,539
14 .39
To tal
9,751,435
100%
Source: Antor.otive Nevs, 1977 V.ar::et Dcta 3ook
-27-
-------
Table III-4
Market Sales of Light-Duty Trucks^
by lianufacturer for 1976
No. of U.S.
7, of Light
Manufacturer
Truck Sales
Truck Market
Chevrolet
1,011,377
37. 12
GMC
223,305
3.21
Ford
870,231
31. 94
Chrysler
338,075
12.41
AMC/Jeep
107,437
3.95
IHC ?
Other Manufacturers"
34,100
1. 25
139,350
5. 12
Total
2,724,435
1
1
1
O
O
j
Source: Aitc-otive ne'-.s, 1977 Market Data 2ook
^ Light Truck defined as 0-10,000 lb GV.'
^ Induces imports
-28-
-------
Table II.'-5
Passenger Car Dcalershi
,"s by Manufacturer
To tal
Dealers as
Unit
Sales
Franchises as
of Jan. 1,
Per
Outlet
Ikinufacturar
of Jan. 1, 1977
1977
1976
1975
American Motors
1,690
1,690
140
177
Chrysler Corp.
9,235
4,811
Chrysler
3,272
86
70
Dodge
2,850
166
117
Plymouth
3,113
174
127
Ford Motor Co.
10,125
6,637
Fc ru
5,567
308
276
Lincoln
1,618
7 6
62
Mercury
2,940
143
119
General Motors
CorT. 17,205
11,670
Buick
3,045
244
171
Cad xllac
1,610
190
166
Chevrolet
5,990
350
302
Oldsmobil2
3,315
272
192
Pontiac
3,245
233
155
Totals
38,255
24,SOS
Minus
Intercorporate Deals
54 0
Net Dealers
24,268
Source* AuticxiO
tive \'ews, 1977 Market
Data Hook
-29-
-------
Table II-G
Truck. Retail Outlel\ by Manufacturer
Manuf ac turer
Ford
Cne^role C
CMC
Dodge
IHC
AKC/Jeep
Others
Total
Adjustments for
Multiple Jranchises
Outlecs as of
January 1, 1977
5,626
5,590
2,750
3,170
1,9^8
1,623
3,534
Unit Sales Per Outlet
1976 1975
14,246
1, 225
169
1S8
93
126
52
67
132
136
62
90
52
54
Total
23,021
Source: Automotive N'vs, 19 7 7 Market Data Book
-30-
-------
value of about $7 billion in 1975.
D. Employment
It is estimated that 3,661,549 workers are employed in manufacturing,
wholesaling and retailing of motor vehicles (passenger cars, trucks, and
buses) with a total $25.5 billion dollars in annual wages paid to those
employees. Accurate employment figures for the separate manufacturing,
wholesaling and retailing of light-duty trucks or light-duty vehicles
are difficult to find. Most employment data are aggregated for all
producers of all classes of cars and trucks since some production facilities
manufacture both light and heavy trucks. Statistics show that approxi-
mately 31,400 workers were employed in 1972 by U.S. manufacturers of
trucks. The annual payroll of these workers totalled $250.25 million
dollars. Much of this employment is centered in California, Michigan,
Ohio, New York, Indiana, Illinois and Missouri.
-31-
-------
Chapter IV
Environmental Impact:
A. Primary Impact
the
r VI,
Alternative Action I: No action (retain the 6,0 g/test
standard].
Alternative Action II: A 2.0 g/test standard for 19S0 and
subsequent model years.
Alternative Action III: A 2.0 g/test standard for 1931 and
subsequent model years.
This section will describe th
establishment of a more stringent
measured by the FederaL enclosure
alternative actions considered in
are as follows:
e expected environmental impact of
evaporative emission standard when
test method adopted foe 1973. The
this Chapter, Chapter V and Chapte
-32-
-------
The primary impacts of other control strategies will be presented
here as a reference to show the relative effectiveness of the final
rulemaking in the reduction of hydrocarbon emissions. These strategies
include establishment of the 6.0 g/test evaporative emission standard
as measured by the enclosure test method, reduction of light-duty
vehicle exhaust hydrocarbon standards to the statutory level (0.41 g/mile)
and an inspection maintenance program.
1. Current and Projected Emission Factors
In order to evaluate the effect of the alternative actions on
ambient air quality, the rates for exhaust and evaporative hydro-
carbons must be determined as a function of vehicle age.
Tables IV-1 and IV-2 give the evaporative hydrocarbon emission
rates for light-duty vehicles and light-duty trucks, respectively. Past
emission rates for light-duty vehicles were obtained from surveillance
testing of 1957 through 1972 model year vehicles. 1971 through 1977
vehicles are controlled for evaporative emissions under the "carbon
trap" certification test method. 1973 and subsequent model year vehicles
will be controlled for evaporative emissions under the Federal enclosure
testing method. The 6.0 and 2.0 g/test standards for 1973 and 1981
respectively, assume that the emissions would be comprised of 1.0 g/test
from the diurnal portion of the evaporative emission test, '.'ith the rest
being contributed during the hot soak portion of the test.
-33-
-------
Table IV-J
FvnporatLye 1IC Emission Factors
lor Light Duty Vcluclcs by Model Year
Evnporn t lvc HC Dm q;, ion Factors
By Source Coinpo;¦ Lte 1 Missions
Diunv 1
Hot Soak
Model Yeir(s)
O./d.iv)
(ft/trip)
1
p,/ni
pre ]970
26.0
16.7
74.5
2. 53
1970 (Calif.)
16.3
10.9
52.3
I. 78
1970 (non-Calif.)
26.0
14.7
74.5
2. 53
1971
16.3
10.9
52.3
1. 78
197,2-77
12.1
12.0
51.7
] . 76
6 j;/ter.t std.
1.0
5.0
17.5
0. 60
2 f;/teM: std.
J .0
1 .0
4.3
0.15
Source: Supplement No. 5 for Conpilation of Air Pollutant Umussion
Factors, AP-42.
\
Gram per day values are hot soak emissions times the .^verar.e nunber
of trips per day plus diurnal emissions. Nationwide data frori Lhe
Department of Transpoi t ation and AuLonobi] e N.mu f .n c lurers Assoc.ia Lion
indicate that the avcia^e vehicle is used J. 3 trips per day. Graiii/
p:ile values were detei'inne by dividing average g/day by the average
nationwide travel per vehicle of 29.4 mj/day.
-34-
-------
TcibT.2 XV-2
f/.'nprir--11; ivc HC Ilr.us^1' TncLors
for Jincy Trucks 1>_. Model Year
HC Emission Factor^"
Made: I Vc,ir (s) (f/mi)
pic 1970 3.6
1970-1CJ 77 3.1
5 g/icst Stzand.ird .60
2 g/tcst Strmdnvd .15
Source. Snppl cniL'H t x!o . 5 for Car,pild lion of A: r 1Jo ] I lit.in C
Urussjon FncLors, AP-42.
^ Cram per r.::lc vnluM are based on 3.3 hot so.nks per day
and 29.4 miles travelled per d?y.
-35-
-------
In order to estimate Che environmental impact of a 2.0 g/test
standard for the 1981 model year, hydrocarbon emission factors must bo
coupled with vehicle miles travelled data during a year's time in order
to estimate the tons of hydrocarbons emitted per year. For Che com-
putation of hydrocarbon emissions from various mobile sources, the
following assumptions were made:
a. Light-duty vehicles - The standard of 1-5 g/mi for exhaust
hydrocarbons is in effect until 1979. In 19S0 light-duty
vehicles will meet the statutory exhaust hydrocarbon emission
standard of 0.41 g/mi. Evaporative emission rates will be
those shown in Table IV-L.
b. Light-duty trucks - In the analysis, light-duty trucks are
defined as all trucks with gross vehicle weight below 8500
lbs. Prior to 1979, trucks below 6000 lbs. are regulated at
a level of 2.0 g/mi of e;ch.3ust hydrocarbons, and trucks between
6000 and 8500 Lbs. are regulated as heavy-duty vehicles with
an estimated exhaust HC level of 5.6 g/mile. In 1979 and
subsequent years, all light-duty trucks are assumed to be
regulated to an exhaust HC standard of 1.7 g/mi. Evaporative
HC emissions from LDT's are as shown in Table IV-2.
-36-
-------
c. Heavy-duty vehicles - In this analysis, heavy-duty vehicles
are defined as all trucks with a gross vehicle weight above
8500 lbs. It is assumed that exhaust HC emissions from
heavy-duty gasoline vehicles are regulated at a level of
19.7 g/mi between 1970 and 1973, 12.4 g/mi between 1974
and 1978, and 3.2 g/ni in 1979 and subsequent years. It
is assumed that heavy-duty diesel trucks are regulated at
a level of 4.5 g/mi starting in 1974. Evaporative emissions
from heavy-duty vehicles are not currrently being regulated.
d. Motorcycles - For this analysis motorcycles are not considered, since
data on which population and emission factors for in-use vehicles
are not available on a nationwide basis. Motorcycle exhaust carbons,
however, are being controlled beginning with the 1978 model year
and by 1^80 must be less than 5.0 g/kilometer. There is no
evaporative emission standard for motorcycles.
2. Vehicle Population and Vehicle Usage
In order to estimate the amount of a pollutant released to the
atmosphere, it is necessary to know how many vehicles are in use and
what proportion of different age vehicles are in that population. It is
also necessary to know hew much mileage is accumulated by the different
segments of the vehicle population.
-37-
-------
Table IV-3
Passenger Car and Truck Registration
For che Last; 10 Years1"'
Year P
asser.£iir Cars
Trucks *¦
1974
105,290,000
25,030,000
1973
101,762,67 7
23,232,372
1972
96,980,314
21,238,922
j.971
92,754,061
19,837,063
1970
89,230,567
18,767,294
1969
86,852,275
17 , Sli2 ,129
196S
83,591,694
16,941,293
1967
30,414, ItiO
16,173,34 9
1966
78,122,965
15,516,895
1965
75 , 251,3d6
14 ,795,C51
'¦•'Includes privately
and publicly owned
vehicles.
Source: ;\.utoii'0 tive
Tacts ana Fisures,
MVIIA, 1975
1) A11 classes of trucks included
-38-
-------
Tabic IV-
Nationw: n
Fraction oi Annual Travel by Model Year
for Liglit Ditty chxclus
Fraction of Total
Average Annual
Fraction of
. /^e
Vehicle-?, in une
miles dL'jvcn
Animal Ml lee
(yori'O
K.11ion1, idc 'o)
(b)
n >: b
Trovol '.'J
1
0.033
15,900
1,320
0.116
2
0.103
15,000
J ,54 5
0.135
3
0.102
14,000
1,428
0.125
4
0,106
13,100
1,389
0. 122
5
0.099
12,200
1,203
0.10 6
6
0.037
11,300
903
0. U^o
7
0.092
10,300
948
0.033
8
0.038
9,400
t!27
0.072
9
0.05S
8,500
578
0.051
10
0.055
7,600
418
0.0_w
11
0.039
6,700
261
0. 023
12
0.021
6,700
141
0. 012
213
0.057
6S 700
382
0.0J3
Source:
Supplcnenr Mo. for coripi
lation of Air Pollu
tanC hniissi
or. Frct'ors,
AP't 2.
-39-
-------
Tabic JV-5
Nation .'Ldc
Traction of Li£ht-
-Dut;1 'I ruck Annual
Travel
by
Model Vear
traction of Total
Average
Fraction
42.
-40-
-------
Table IV-6
Total Vehicle ililes Travelled
by light-Duty Vehicles
Los Angeles
Mew Jersey part
Houston-
Phocnix-
Denver
Nar louwiile2
AQCR b
of New Yoik AGCtlc
Galveston AQCR^
Tuscon A0CRe
AC C K
(billions of
(billions ot
(billions of
(billions of
(billions
(bill ions
Year
miles)
miles)
miles)
miles)
of miles)
of niles)
71
44.6
27.0
11 . 3
8. 22
5.60
72
9S6
45.9
27.6
11.9
8.63
6.09
73
101 6
47.2
28. 1
12. 5
9.06
6. 62
7 4
1046
48.6
28. 7
13.2
9. 51
6.82
75
107 7
50.0
29.3
13.8
9.98
7.01
76
] 100
51.5
29.9
14. 5
10. 5
7 . 23
77
1144
52.9
30. 5
15.2
11.0
7.44
78
1177
54.4
31.1
16.0
11.6
7. 67
79
1713
56.0
31.7
16.8
32.1
7.90
80
J 24 9.
57.6
32.3
17.6
12.7
>. j
85
1 4 4 9
65.1
35.7
19. 5
14 .8
8. 99
90
16 7 9
73.8
39.4
21 . 5
17.1
9.91
a. Rnsed on I'iilJA Highway Statistics and an assumption of a 3% growLh iaLe after
197'..
b. iia-jcd on tiara from "Tr u nspor Cau on ConLrol Strategy Developr.enL for the Metropolitan L.A. Region",
AP1D-1372, Doc. 197 2.
c. Baaed on vehicle registration data from M>'\• Jersey, census data relating the fraction of the population
jn AQt'k, and on n
-------
Table TV-7
Tola] Vehicle Miles Travelled
by Light-Duty Trucks
Year
Nv. c lotiuidc2
Los Angeles
A0CKb
New Jersey part
oC Mew York A0CRc
houston-
Galvcston AQCR^
Phoenix-
Tu scon _AQCR£
(blllions
of miles)
Derive r
.'cc:< i
(l)J llxona of
miltb)
(billions of
wilca^
(billion;; of
Its)
(billj oris of
miles)
(billiors
of Pll^V
71
4.39
3.22
1.35
I -19
. 567
72
156
-1.51
.j. 2 3
1.42
1. 25
. 725
73
ISO
'l _ 0 -i
3.25
x.69
] .31
, 783
74
165
A. 73
3.42
1.57
1. 3G
.81 2
7 b
170
4.91
3. 4 9
1.64
1.45
.335
76
175
5.06
3.56
1 .73
1.52
.361
77
180
5. 20
3.63
1.31
1.60
.86 6
73
186
3.35
3.70
1.90
1.63
.Qli
79
192
5.50
3.77
2.00
3 .76
. -J~> L
60
LOT
3 . ()*>
3. b5
2. 10
1.85
.969
U5
2 29
6. 40
4.25
2.32
2.14
1.07
9u
266
7. 25
4.69
2.56
2.4 9
1. ]S
a. BaS^d on Highway Scatjsii.es ancl an c-issu»»nCi en of a 32! 2ro;'Ll: rate aFtcr
!j . cn caLa frcm "3 l aftsporLatiori Control Strategy Development cor the Metropolitan L-A.. Region",
AP'JLU-1J7 2, Dec. 1972.
c. Based on vehicle registration d.us from r^ei: Jersey, ccn^u^ data rclatJnj; the fraction o[ Lhe population
j n Lisa AfjCK, and on na ui um/i <\ e vehicle miles travelled average fiou Al'42 Compilation ot Air Pollution
rmib'^oa L'acloLb. Assumed IT. per year £ru'..Ln rciLi.
d. based on Te..as Highway recent Data. Growth rnLc assumed to be j% until 1980 .and 2% thereafter.
e. Based on Arizona Highway Depart men L Da La and ^rcvjlh ratei, of 3% unLil 1SSJ, 3?= thereafter.
f. Dated on Colorado JJiv. of lEighways data jiid assumed grawLb rates of 3% until JSoO, 2% thereof tar.
-------
Table IV-3 gives vehicle registrations for 1965 through 1974. Table
IV-4 and IV-5 give the fraction of ann .al travel by model year for light-
duty vehicles and light-duty trucks, respectively. By coupling these
fractions with the overall annual mileage (urban plus rural) and the
emission rates from different age vehicles, one can predict the total
amount of hydrocarbons emitted by these vehicles to the atmosphere in a
given year. Similar data can used to determine the contribution of other
mobile sources.
Mileage accumulation rates nationwide and for the five Air Quality
Control Regions to be evaluated in this section are given in Tables IV-6
and IV-7 for light-duty vehicles and light-duty trucks, respectively.
3. Nationwide Emissions
Table IV-8 and Figuie IV-1 show the results of an analysis such as
is described m the preceding section. Figure IV-1 shows that exhaust
hydrocarbons will be reduced by 1990, but will have leveled off. If a
further reduction in the evaporative emission standard (to 2.0 g/test)
is not made, evaporative emissions will contribute.roughly the same
amount of HC emissions as exhaust emissions from light-duty vehicles
and trucks. Figure IV-2 shows that evaporative hydrocarbons will
contribute roughly 36% of all hydrocarbons in 1990 from mobile sources
if no further action is taken. Figure IV-2 also shows that a 2.0 g/test
standard will significantly lower the percent contribution of evaporative
emissions to total mobile source hydrocarbon emissions.
-43-
-------
T.i'.K I V- S
1U i' rocn . .>on Fr.i 1 5.L. lim-i from MoliiJii SmirLdi, (10^ rod/', >. .11 )
I-> h . us L £. Cr:nik- I - V A1 * Lv/Al'
T 'l.n L Ci : lJSC ci',o nn;; j_[ir j_nr imn linn _i_ny j_p_r i nv i_ru ldv i >,r
i 0 72 r> 3 1 23 .59 . 22 1.6-', . ] 5 2 54 .59 2 54 59 2.54 .59
lvr-. 4 7 1 r~. .15 .OS 1.53 .If) 2.45 .61 2.45 Gi 2.45 .61
197- 3.7 SO 05 .OS ] 31 1 7 2 . 27 (,() ? .27 M 2.27 . oO
19SO J.O .(,y 0 0 1.19 .18 1.89 .49 1.82 48 1. S9 .49
r;r> i o o .9: 20 1 .rs .74 20 .33 -?J,
{<)')! 76 ^ 0 0 .83 .23 1.10 .17 31 .06 .33 _ C6
1) 1; ¦ - ci o< Lml-. ¦. LO'i i.iCijrj loui'.l in "Si.o;>li i<_:u No. 5 fur Coup 11 1l1 on of ^ir Pollut.iiL LiiiSion Factors,"
> _ ' I
_/ = • ,.>J O'1 T .i,h r C ir^ ro. "C "S^liiihI VlJendi' 1 10 terror..lu'irn I.nc 1 l 1 >-J ' K<_vio;.l L'mi. "Cl^ o t "Vocal
.. . > l :: 1 .¦ U^.'ljuin' I'ur unv.".j " tic.mo fio"' S. Cny horno-.,, I I' \ , Co I-^iu-.sc 8
K jo.i ivi ,, ".A, I'.-Ti1; , lj/6, (:.'/u lI.iIjI o . '1 t.l'\ public doci.>.c).
*
^^(.1 1 Lnia iio'i r..cr>;rs i'ou"^ in "I.'UIl.*: I/-1 atul IV-2.
¦O
¦P-
-------
i'lgurc IV-l
I'l u j ri- led iN iL Loir.vii!c 'oliU'le hi I in I-.s ior.-.
Year
-45-
-------
ri&utrc 1 V- 2
Projected PcrccnCa^c: of
A L Lr i. ihio 1.0 Lvaporn;
Duty V'cuiclc:, and L-Lgit
?! * i) 1J c Source 1!C H.iussims
j >? rinisf, UHvi fi on L lh;11 L
i'rucks
10 _
~T~
72
) 3
SO
32
3^
S3
90
:&?. r
-46-
-------
l:i£ure [V-3
Vrujoc Li-'d iiaiion^-Jr1 Hyd roc-nrboi!
Dnssions from '>!>:.le Sources
-------
Figure IV-3 contrasts the effect of the alternative actions on
nationwide hydrocarbon emissions from t„obile sources from 1972 to 1990.
It shows that, while emissions are expected to decrease significantly,
larger reductions will be realized if evaporative emissions are further
controlled by implementation of a 2.0 g/test standard. Using the data
in Table IV-8 it is estimated that this regulations would decrease
mobile source HC emissions by approximately 25% from levels that would
occur if the 6.0 g/test standard were maintained.
Table IV-9 shows what reductions in hydrocarbons are expected by
the year 1990. A 2.0 g/test standard implemented for 1981 and subsequent
model years would lead to the reduction shown by the year 1990. The
table also shows the reductions that will be realized by retaining
through 1990 the 197S 6.0 g/test evaporative emission regulations,
implementation of the exhaust hydrocarbon emission standard of 0.41 g/mile,
and the implementation ot an inspection maintenance program.
4. Impact on Selected Air Quality Control Regions
Analyses have been performed which indicate tijat many Air Quality
Control Regions (AQCRs) will still be unable to meet established National
Ambient Air Quality Standards for oxidants in 1935 and 1990. Sorre current
non attainment areas are listed in Table IV-10. Four of these regions have
been analyzed to show what the effects would be on the tons of HC emitted in
-48-
-------
Ta'11 e IV-9
Projected Nationw-te HC Reduction in 1990
Act ion
Alternative Action I
Alternative Action II
Alternative Action III
1978 Evaporative Regulations
Redace LDV Exhaust Standard
from 1.5 to 0.4L g/raile
2/
Inspection Maintenance —
1/
Nationwide
HC reduction in 1990
in 106 ton/year
0.9
0.88
2.9
1.9
.88-3.1
1_/ 2.0 g/test via carbon canister test procedure to 6.0 g/test
via SHED test procedure.
2/ Source: Internal EPA memo from M. Williams to J. Lane,
Aug. 18, 1975, assuming a 20% failure rate.
-49-
-------
Table IV-10
Non-attainment Regions
with Population Greater Than 200,000
New York, New York -
Northeastern New Jersey
Los Angeles Long £each3 California
Chicago, Illinois - Northwestern
Indiana
Philadelphia, Pennsylvania
Detroit, Michigan
Cleveland, Ohio
Houston, Texas
Seattle - Everett, Washington
Miami, Florida
Kans.-is City, Missouri
Denver, Colorado
Phoem -•, Arizona
Louisville, Kentucky
Norfolk - Portsmouth, Virginia
Oklahoma City, Oklahoma
Omaha, Nebraska
Salt Lake City, Utah
Tucson, Arizona
Mobile, Alabama
Little Rock, Arkansas
Source: List Complied by Control Programs Operations Brancn,
Office of Air Quality Planning and Standards, EPA, February 1973.
-50-
-------
Tab Je TV-ll
llyd i ocarbon Emission Reductions in 1985
!!C Chiissions 111 10 tons/year
Mobi1o HC Son rces
No Action
2g standard
]n 1980
Total HC Sources
Reduction No Action
2g standard
i n 19BO
Redur t ion
l.trVpl 5 ^Gt;d<_'u
to Moo l Anbienc
Air Oii.ilatv Stf-nu;
I'lioen l:.-
Tuscon
I.os Anj.',cle.s
IX nvo r
Hi >u'-. l on
0a 1 v-j s l on
52. 3
17 5.1
34. 7
61 0
46.3
150 7
31 - 3
53.5
5.0
2-'.
3.4
7.5
17 5.1
619.1
57.7
369. 2
169.1
59'. .7
5 '.. 3
361 . 7
5.0
24 .4
3.4
7.5
o
25.S
61 . 5
-------
Table 1V-12
Hydrocarbon Cntssiu.i RtJucc lohs in 1990
HC Emissions in 10 ton/year
1'lioen j \-
Tn^con
Los .^nye 1 l s
Ik-nve r
lUm^ nni-
Cj Lv
-------
1985 and m 1990 for tha two extreme alternative actions considered;
i.e., no control beyond 6.0 g/test (alternative I), and a 2.0 g/test
standard beginning with 1980 model year (alternative II). As previously
shown in the environmental impact analysis on a nationwide basis,
there would not be a large difference in total HC atmospheric loading
in 1990 between the 1980 implementation date the 19Si implementation
date (alternative III).
The four AQCRs analyzed are Phoenix-Tucson, Los Angeles, Denver,
and Houston-Galveston. Trends similar to the ones shown in Figures
IV-1, IV-2 and IV-3 for national emissions exist for these AQCRS.
More importantly, however, is what percent reductions in overall hydro-
carbons will be achieved in these various regions due to implementa-
tion of a 2.0 g/test standard, and whether or not this will allow
these regions to meet the oxidant ambient air quality standard.
Tables IV-11 and IV-12 show what the mobile and total hydro-
carbon levels will be in 19S5 and 1990, respectively, for the two
alternative actions analyzed. Also, the hydrocarbon levels required
3
to neet the oxidant ambient Air Quality Standard oi .OS ppm/m (one
hour maximum) are given for each of the four AQCR's. These tables
indicate that while a sizeable reduction in hydrocarbon emissions
would be achieved, these regions will still be unable to meet the
A:nbient Air Quality Standards. (Note: This analysis assumes that
that the LDV exhaust HC standard of 0.41 g was implemented with the
1978 model year rather than 1980, so the predicted levels of HC
emissions in Tables IV-11 through IV-14 are somewhat lower than
currently expected.)
-53-
-------
Table IV-13 and IV— 1 show the e-'oected reduction in hydrocarbon
emissions as a percent of mobile HC erissions, total HC emissions,
and as a percentage of the emission levels needed to meet the Ambient
Air Quality Standards by 1985 and 1990 respectively. Table IV-14 shows
that implementing a 2.0 g/test standard will result in a 2.7 to 10.2
percent reduction in total hydrocarbon emissions in these air quality
control regions.
Another way to examine the impacts of alternative emission control
strategies on air quality control regions is to use a computer modeling
approach. Using the modified rollback model—^ it is possible to
estimate the effect that a given emission control strategy will have
on ambient oxidant concentrations in selected air quality control regions,
as well as the number of regions that will exceed standards and the
number of times the standards are exceeded. To conduct this analysis
the emission factors for mobile sources given in the January 1978 revision
to Supplement 5, A.P-42, Compilation of Air Pollutant Emission Factors
were used. (Summaries are given in Appendix A.) The revised Supplement
5 data represent the latest assessments of the expected emission
performance of in-use vehicles. Since the updated emission factors differ
from those used formerly, the results of the rollback model analysis and
that of the four-region study just described may also differ significantly.
1/ N. de Nevers and R. Horns, "Rollback Modeling - Basic and
Modified," presented at the annual meeting of the Air Pollution
Control Association, June 24-28, 1973 Chicago, Illinois,
Paper No. 73-139.
-54-
-------
Table TV-]J
HC Emission Reductions as 7,
of Mobile Sources, Total Sources and
Ambjcnt Air Quality Standard in ]9S5
Phoen i.:-
'I uscon
Los Angeles
Do nve t
Hour, ton
C.ilvos ton
HC Reductions
Due to 2 g/lOSL SLd.
in 19^0 ( ] 0"1 tons/vi")
5.0
2-'..
3. A
7.5
I1C Reductions
HC Reductions
as 7, of Mobile HC as % of Total HC
Sou ires
9.6
13.9
2.3
Average
11.
Sources
2.9
3.9
5.9
2.0
3. 7
IIC Reductions
as % of Aiiibjcnt"
Air Oua11 t v S td
5 . 7
A3. 7
1 3. 3
12.2
] 8. 7
-------
Table IV-LA
HC ['mission Reduc L iu n b js %
of Mob lIu Sources, Total Sourus and
AmbicnL Ail Quality Standard in 1900
PIiOl' iux-
rLi i;.com
Lo^ Anij*.1 lu:
Denvc r
Iloiiu Lon-
C.i] ve<; t on
HC Reduc t. ] ons
Due Co 2 g/t:csl :,td.
in 1980 (10 tons/vi)
8.9
38.0
5.2
1 1 .A
HC Rtduc ci on£>
as % o f Mobile
Source;
2 3.8
26 8
22.1
liC Reductions
a % of To L^i 1 11C
Sources
h .6
5.5
10. 2
21,. 9
:. 7
11C Reductions
as % of AnbieuL
Air Qua 1 j Cv Srd
10. 2
63. 2
20. 1
IS
Avoi
-------
Forty eight AQCRs were studied ii this analysis. The results
of the analysis on a regional basis sie shown in Table IV-15. The
total HC emissions in 1990 with and without implementation of the
2.0 g/test evaporative emission standard in 1981 are given. The
total reductions of HC emissions in 1990 for these regions is 311.7
thousand tons if a 2.0 g/test evaporative standard is promulgated.
This represents a 15.7% reduction in mobile source emissions and a
3% reduction in total HC emissions for these 48 regions. For
individual regions, the reduction in total HC emissions ranged
from 0.8 to 5.9X.
The reduction in hydrocarbons for the regions studied will
result in an additional 2 percent reduction in oxidant air quality
concentrations from levels that would occur without the more
stringent evaporative standard. Table IV-16 shows that if the
6.0 g/test standard were retained through 1990, the oxidant con-
centration in that year would be reduced 35 percent from the levels
measured in the base year (1975). However, if a 2g/test standard
is promulgated, oxidant concentrations would be reduced by 37 per-
cent. It should be noted that this 37 percent reduction is obtained
whether the 2.0 g/test standard is promulgated in 1980 or 1981.
Table IV-17 shows l.hat with the more stringent evaporative
HC standard, 3 additional air quality control regions would meet
ambient standards for oxidants in 1990. Further, there would be
403 fewer violations of the oxidant standard, a reduction of 10.3^.
-57-
-------
Table IV-L5
1990 Hydrocarbon Emissions (tons x 10
a/
48 Air Quality Control Regions —
Emissions from
Regions Mobile Sources
(with a 2g std in 1981)
Emissions from
All Sources
(with a 2g std
in 1981)
1.
Bi rminghaw
24.0
324.0
2.
Pensacola
35.0
185.0
3.
Clark-Mohave
6.2
20. 7
4.
Phoenix-Tucson
28.8
103. J
5.
Los Angeles
64.0
857.5
6.
Sacramento Valley
9.2
73.0
7.
San Diego
26.2
63.0
8.
San Francisco
83.4
241.3
9.
San Joaquin
33. 7
118.8
10.
Se Deserto
2.6
8.1
11.
Denve r
29.7
83.5
12.
Ny-NJ-Conn
188.0
986.8
13.
Philadelphia
79.5
442.8
14.
Nat. Capital
48.1
158.0
15.
Chicago
77.2
584.1
16.
St. Louis
43.1
205. 1
17.
Cinc i una t i
25.4'
172.9
L8.
S. Lou/S. E. Tex
46.2
726.3
19.
Baltimore
31.4
216.6
20.
Bos ton
42.5
182.9
21.
Minn - St. Paul
31.8
195.5
22.
El Paso
7.0
28.7
23.
Consse-Fngr Lakes
15. 2
75.3
24.
Day ton
18.1
85.5
Emissions from Reduc tion
A11 Sources (As % cf
(without 2g) (tons) total Emissions)
327.4
3.4
1.0
190.9
5.9
3.1
22. 0
1.3
5.9
108.9
5.6
5.1
887.9
30.3
3.4
77.3
4.3
5.6
67.4
4.4
6.5
255.4
14.1
5.5
124.6
5.8
4.7
8.5
0.4
4.7
88.0
4.5
5.1
1021.0
34.2
3.3
456.0
13.2
2.9
166.6
8.6
5.2
598.2
14.1
2.4
212.0
6.9
3.3
177.3
4.4
2.5
7 34. 3
8.0
1.1
222. 2
5.6
2.5
190.4
7.5
3.9
200. 7
5.2
2.6
30.0
1.3
4.3
78.1
2.8
3. 2
88.7
3.2
3.6
-------
Table IV-15 Continued
25.
Por tla nd
36.4
147.8
153.6
5.8
3.8
26.
S.W. Fonr.
40.5
152.9
159.7
6.8
4.3
27.
Corpus-Chris t i
7.6
167.2
168.6
1.4
0.8
28.
Dallas-Ft. Worth
37.6
237 .2
243.1
5.9
2.4
29.
Houston Calston
30.4
540.5
545.8
5.3
1.0
30.
Puget Sound
27.0
104.7
109.4
4.7
4.3
31.
iJart ford
45.6
148.9
157.4
8.5
5.4
32.
W. Cent. Fla
34.0
99.0
104.6
5.6
5.4
33.
Atlanta
25.1
107.6
112.2
4.6
4.1
34.
Louisvi1le
10.8
96.6
98.4
1.8
1.8
35.
Ind ianapolis
20.8
80.9
84.2
3.3
3.9
36.
Metro Omaha
11.3
101.9
103.4
1.5
1.5
37.
Providence
32.0
131.5
137.0
5.5
4.0
38.
Merrimack Val
20.7
98.5
10 2. 2
3.7
3.6
39.
Detroit
76.6
403.9
416.9
13.0
3.1
40.
Roches t er
21. 7
73.8
77.4
3.6
4.7
4L.
Del Valley
28.7
130.5
135.3
4.8
3.5
4 2.
Central N.Y.
16.0
69.0
71.9
2.9
4.0
43.
Hudson Valley
24.2
78.7
83.1
4.4
5.2
44.
Niagara
16.5
76.7
79.7
3.2
4.0
45.
CharloLte
18.1
78.9
81.7
2.8
3.4
4 6.
Cleveland
52.8
326. 3
335.8
9.5
2.8
47.
Columbus
18.7
75. 6
79.0
3.4
4.3
48.
S.E. Wisconsin
29.4
4
2 74.0
27S.7
4. 7
1.7
Total
1,678.8
9,941.4
10,252.9
311.7
-
a/ Emission inventories taken from "Evaluating Llie Air Quality Impacts of
Alternative Evaporative Emissions Control Strategies," Office of Air
Quality Plrnnmg and Standards, EPA, March 1978.
-------
Table IV-16
Average Percentage Reduction in Oxidant Air Quality Concentrations
From Base Year L975 —
1981
1985
1990
6. Og
1978-1990
M.
14
27
35
6.0g
1978-1979,
2g
1980
14
28
37
6.0g
1978-1980,
2g
1981
14
28
37
a/ Source: "Evaluating The Air Quality Impacts of Alternative
Evaporative Emissions Control Strategies," Office of
Air Quality Planning and Standards, EPA,
March 19 73.
-60-
-------
Table IV-17
6.Og 1973-1990
6.0g 1973-1989; 2.0g 1980^
6-Og 1973-1930; 2.0g 1981
Number of Cities
Above Standard
38
35
35
Total Number
of Violations
3909
3506
3506
if Source: "Evaluating The Air Quality Inpacts of Alternative
Evaporative Emission Control Strategies," Office
of Air Quality Planning and Standards, EPA,
March 19 78.
-61-
-------
B. Secondary Environmental Impacts
This section deals with the secondary environmental impacts of the
alternative actions. The secondary impacts that are discussed are
1) the effect on energy consumption, 2) the possible interactive effect
of evaporative emissions and exhaust emissions, and 3) the potential
impact on water and solid waste pollution.
1. Energy Consumption
No change in energy consumption is anticipated through the promul-
gation of these regulations. Specifically, no increase in fuel con-
sumption is expected as this should be relatively independent of the
manufacturer's choice of evaporative control technology. Considering
the fuel which is now lost to the atmosphere by evaporation, but which
could be burned in the engine with evaporative control, it is possible
that evaporative emission control could conserve fuel.
Most evaporative control systems expected to be used to neet either
a 6.0 or 2.0 g/test standard use a canister contaiaing activated carbon.
Fuel vapors from the fuel tank and the carburetor fuel bowl are vented
to this canister during periods when the engine is not running. These
fuel vapors are purged out of the canister during vehicle operation.
Reducing the standard to 2.0 g/test will decrease the amount of vapors
lost to the atmosphere by .45 g/mi on the average. If a vehicle life-
time is assumed to be 100,000 miles, then this reduction would, over
-62-
-------
the lifetime of the vehicle, amount to approximately 15 gallons of
fuel not lost to the atmosphere. ActuiL savings may be less than
that. (Sea discussion in Chapter V, Section A-2).
2. Exhaust Hydrocarbon Emission Interaction
Depending on the design of the evaporative control system used to
meet a 2.0 g/test standard, an interaction can occur due to the purging
of additional evaporative emissions into the engine which will cause
additional exhaust hydrocarbons and carbon monoxide to be generated
from the combustion process. Whether or not this occurs is dependent
on the rate and the total anourst of hydrocarbons purged into the
engine and the operating condition of the vehicle when purging takes
place. These interactions need not occur with proper utilization
of existing control technology. Therefore, this rulemaking is not
expected to have any measurable effect upon exhaust emissions.
3. Water Pollution and Solid Wastes
The problem of evaporative emissions is one vhich affects the air
quality, and it is not one which should have any significant effect on
water quality. Similarly, no effect on the quantity or quality of
solid wastes is expected. This is equally true of the control of
hydrocarbon emissions by the imp Lemsr.t ation of the alternatives
discussed dealing witti controlling exhaust hydrocarbons.
-63-
-------
Chapter
Costs of Control and Its Impact on Consumers,
Industry, and Government
A. Imoact on Consumers
From the consumer's perspective the cost of controlling emissions
consists of two elements. First, there is a charge levied on the consumer
by the vehicle manufacturer to cover the costs of the emission control
system. This is annually done by increasing the "sticker" price of the
vehicle. Secondly, the consumer must pay for any additional cost to
operate and/or maintain the vehicle due to any change made to the vehicle,
in order to reduce emissions.
1. Initial Costs
The initial cost to the consumer which is reflected in a higher
sticker price, is due to the costs of research and development, production,
design, raw materials, manufacturing and markup (profit) of any required
component change or addition to the vehicle. The actual cost, of course,
will vary from vehicle to vehicle depending upon the technologies used to
meet a 2.0 g/test standard in 1981.
-64-
-------
A study of the cost of achieving i 2.0 g/test emission level has
been conducted by Exxon Research and Engineering Company under EPA
contract (No. 68-03-2172)-^. In this study, six 1973-75 production
vehicles which represented the four major U.S. light-duty vehicle manu-
facturers and two foreign manufacturers, were modified in order to
reduce evaporative emissions. Costs for the required modifications were
then estimated. The resulting sales weighted retail price increase
to reduce evaporative emissions from a 6.0 g/test level to a 2.0
g/test level on each vehicle was estimated to be $1 per vehicle.
(1976 dollars)
2/
A further study done by EPA— evaluated the cost of manufacturer
developed control systems which have given test results of Less than
2.0 g/test. The component costs used were the saiae as those used in
the Exxon study. This evaluation concluded that the sales weighted
retail price increase would be $5 per vehicle to go from a 6.0 g/test
level to a 2.0 g/test level. (1976 dollars)
Therefore, it has been concluded that the incremental retail price
increase will be between $1 and $5 per vehicle. This is in agreement
with EPA's original estimate of $3.70 contained in the NPRM.
_1/ Clarke, P.J. , "Investigation and Assessment of Light-Duty Vehicle Evapo- «
rative Emission Sources and Control", Exxon Research and Engineering,
EPA Contract #68-03-2172, June 1976.
2/ "Cost Effectiveness of a 2.0 g/test SHED Evaporative Standard for Light-
Duty Vehicles and Trucks," Issue Paper by Michael W. Leifen?an, U.S.
EPA, Ann Arbor, Michigan, June 1976.
-65-
-------
To estimate a wholesale price inc'-oase (to be used in calculating
the drop in vehicle sales), the estimated retail price increase
($1 - $5 per vehicle) should be reduced by 22%. This value is
3/
based on the historical dealer discount structure for General Motors. —
The wholesale price increase would therefore be $0.80 - $3.90 per vehicle.
(1976 dollars )
To inflate the $1-5 dollar per vehicle cost of compliance obtained
in the Exxon Research and EPA studies to be representative of 197S prices,
the Transportation Price Index (from the Survey of Current Business )
was used. The resultant cost range is $1.10 to $5.55. Because it is
impractical to anticipate what these costs will oe in 1981 through
1985, the 1978 costs were used to calculate the aggregate five year costs
of compliance for this regulation.
Table V-l shows the total cost of U.S. consumers between 1981 and
1985 based on a retail price increase of $1.10—$5-55 per vehicle. This
cost was multiplied by the projected sales figures for light-duty
vehicles and light-duty trucks during those years. The projected sales
of light-duty vehicles were generated by the econometrics model used
by Data Resources, Inc. Since similar econometrics modeling of light-
duty vehicle trucks has not been accomplished at this time, it was
3/ Discount data presented in Automotive News, August 10, 1975.
-66-
-------
Table V-L
Projected Sales and Incremental
Cost of Control for a 2.0 g/test Standard
U.S. Sales (millions)
Incremental Cost to
Year
LDV— LDT— LDV & LDT
the consumer ($ mil lion)
3
1981
1982
1983
1984
1985'
12.0
11.6
11.4
11.4
11.4
3.0
2.9
2.8
15.0
14.5
14.2
14.2
14.2
16.5 - 83.3
16.0 - 80.5
15.6 - 78.8
15.6 - 78.8
15.6 - 78.8
2.8
2.8
72.1
79.3 -400.2
1 "Data Resources Inc. - U.S. Long Term Bulletin - Winter 1976" p. 20.
2 Predicted values are based on the assumption that LDT market will be
25% of the size of the LDV market as it as in 1974 as reported in
"Automotive News Almanac",1975.
3 Based on a retail cost increase of $1.10 — $5.55 per vehicle for a
2.0 g/test standard in 1981.
4 Sales projections for 1984 and 1985 were not available. It was
assumed, therefore, that sales would be the same as in 1983.
-67-
-------
assumed that -lie light-dut? irjck ir^rk-t wouL-d be 25X of clic size af
the light-duty vehicle market during that period, as it was in 1974.
The trend in sales in the last few years shows an increasing percen-
tage of Light-duty trucks being purchased, so the sales estimate nay
be conservative.
One limitation of the analysis shown in Table V'-l is of course
the assumption that the costs of the pollution control systera will
remain constant over time. Tending to reduce consumer costs are the
cost saving engineering developments which are likely to occur
as manufacturers gain more experience in using the system. Tending to
increase costs to the consumer are the persistent increases in material
costs that are likely to occur in the future. Accurate predictions of
how these factors will affect the cost estimates made in this
chapter are virtually impossible to make ar.d thus the constant dollar
assumption is used.
Another factor which should be considered in estimating aggregate
costs of pollution control is the assumption that essentially all light-
duty trucks and passenger cars will use gasoline engines. Currently such
an assumption is valid as practically all light-duty vehicles and light-
duty trucks do use gasoline engines. Howeverj some manufacturers £.re
introducing Diesel engines in light-duty vehicles and light-duty trucks.
The extent to which Diesel engines are used in the future could tend to
reduce EPA estimates of the aggregate costs of controls, as Diesel fuels
have a very low volatility, resulting in very low evaporative emissions.
It should be noted at this point that this regulatory action does not
include Diesel powered light-duty trucks and ligtit-duty vehicles for
-68-
-------
this reason.
The data in Table V-l also assunii that all cars will have to be
equipped with additional control components not used in prior model years.
However, certification data for the 1978 model year indicate that many
vehicles already have achieved control of evaporative emissions to the
2.0g level. These cars will no£ havj to be equipped with any new equipment
in 1981 to meet the 2.0g standard, and so for these vehicles there is no
cost associated with the implementation of this standard. Therefore total
costs in actuality may be considerably lower than the 79-^00 million
dollars estimated.
2. Fuel Consumption
The fuel control devices used for the containment of evaporative hydro-
carbon emissions present no degrading effect on fuel economy and depending
on the control strategy used, a cost savings due to fuel saved could
occur. As was discussed in Chapter IV, a potential savings of 15 gallons
of fuel over the vehicle lifetime could occur due to the trapping of fuel
vapors and their suosequent burning in the engine. At current gas prices
of around $.60 per gallon this represents a potential lifetime savings
of $9. However, this estimate assumes that all of the fuel trapped
would be used efficiently. The actval use of this trapped fuel would
probably be somewhat less due to inefficiencies of the evaporative
emission control system used. Since it is unkown how much could
actually be saved, it will be assumed that no savings will be
realized.
-69-
-------
3. Maintenance Costs
Current systems are designed to list the lifetime of the vehicle
without replacement or major maintenance of system components. Thus,
for systems expected to be used to meet a 2.0 g/test standard, no
maintenance cost should be encountered. Therefore! Che Lnitial cost
to the consumer is the only cost he should have to bear as a result
of this rulemaking.
B. Impact on Industry
Manufacturers are faced with two tasks as a result of this rulemaking.
First, they must adapt existing or develop new control systems to
accomodate their various models of light-duty vehicles and light-duty
trucks. Secondly, they must minimize the cost of additional control
devices and/or modifications to existing devices m order to minimize
its potential adverse impact on sales if passed in the form of higher
vehicle prices or lower profits if the costs are absorbed.
1. Sales
The first task
which show that for
or can be developed
-70-
is the most critical. Evaluations have been made
the industry as a whole technology is available
by 19S1 which can achieve 2.0 g/test levels for
-------
k!
both light-duty vehicles arid trucks.— Further sufficient lead
lead time exists for manufacturers to meet a 2.0 g/test standard
for essentially all 1931 model year vehicles.—''
It is expected that increased production costs to the manufacturer
will be passed on to the consumer as stated earlier. Thus, the cost
to the motor vehicle industry will not directly be due to the cost of
control, but rather due to any decrease in sales resulting from adverse
consumer reaction to increased sticker prices. Generally, it can be
stated that sales are inversely proportional to price changes. The degree
of sensitivity to price changes is indicated by the price elasticity index.
A price elasticity, for example, of .3 would indicate that a 1^ increase
in price would result in a 0-3% decrease in sales. For the purposes of
this study the price elasticity for motor vehicles is assumed to be .88.—^
The average wholesale price of a 1978 model year light-duty vehicle
or light-duty truck was approximately $4,000. Based on this unit price,
the price increase due to evaporative controls, and assuming a price
4/ "Technical Feasibility of a 2.0 g/test SHED Evaporative Emission Standard
for Light-Duty Vehicles and Trucks", Issue Paper by Michael W. Leifertaan,
U.S. EPA, Ann Arbor, Michigan, June 1976 (Revision November 1977).
5/ "Lead Time Requirments for an Evaporative Emission Standard for 2.0 g/test
for Light-Duty Vehicles and Trucks", Issue Paper by Michael W. Leiferman,
U.S. EPA, Ann Arbor, Michigan, June 1976 (Revision November 1977).
6/ "The Effect of Tax and Regulatory Alternatives on Car Sales and Gasoline
Consumption, "Prepared for CEQ by Chase Econometric Associates,
May 1974, p.4.
-71-
-------
elasticity index of 0.88, the sales d*-p in sales can be predicted.
Table V-2 summarizes such an evaluation. Table V-3 shows the drop in
actual sales for 1981 through 1985 for an assumed price elasticity of
0.88. As can be seen from Tables V-2 and V-3 the expected drop in sales
due to the implementation of a 2.0 g/test standard in 1981 is very small
compared to overall sales.
One manufacturerj GM: has indicated that it will have to expand its
production capacity in order to comply with the 1981 2.0g/test standard.
This extra plant capacity is for production of evaporative emission control
equipment in sufficient numbers to equip all GM model trucks and passenger
cars. No estimate of the capital costs GM will incur to expand its
capacity was provided by that firm.
This manufacturer has also claimed that it may encounter some diffi-
culty designing its vehicles to achieve a 2.0 g/test evaporative emission
standard. This is especially true for the larger light-duty trucks
(6,000-8^500 pounds GVWR) in their product line which customers may wish
to purchase with optional larger fuel tanks (about 25% of sales according
to GM). Representatives of GM at several neetings.with EPA personnel
(See Appendix B for summaries of these meetings) have indicated a belief
that a 2.0 g level may not be achieved for trucks with gas tank capacities
of about 40 gallons due to inadequate canister systems. The EPA technical
staff, however, has concluded that these problems are not insurmountable.
Other manufacturers, noteably the Ford Motor Company, have told EPA that
they intend to develop technologies sufficient to achieve a 2.0 g/test level
-72-
-------
Table V-2
% Drop in Sales Due to Evaporative Controls
Action Taken
Alternative
Action I
(No Action)
Re t a i1
Price Increase ($)l
-0-
% Increase
in Retail
Price
-0-
% Drop 0
in Sales"*
-0-
Alternative
Action III $1.10—$5.55
(2.0 g/test Std. in 1981)
1) 1978 dollars
,02-.14
2) Based on price elasticity of 0.88 from "The Effect of Tax and
Regulatory Alternatives on Car Sales and Gasoline Consumption,"
Prepared for CEQ by Chase Econometric Associates, May 1974, p.4.
.02-.12
-73-
-------
Table V J
Dro.i in Actual Sales of LifJiL-'Uily Voiucios and Trucks
Due co Evaporative Controls iron 198L Lo 19^5
Action Taken 1931 1932 1933 1984 1985
ALterna ti'-e
Action I
(Mo Action)
-0- -0- -0- -0- -0-
AUernaui-'e 3,200- 3,400- 3,200- 3,200- 3,200-
Accion III 16,000 16,000 16,000 16,000 16,000
(2.0 g/test
Sea. ip. '31)
1 !3usea on sales projections presentee m Table V-l nnG a price elasticity
of 0.3S iron "The Effect of Tax ana Regulatory Alternatives oa Car Sales
ana Gasoline Consumpcio.i," Preparaa for CIO by Chase Iconoretric Associates,
May 19 74, p. 4.
-74-
-------
by 1981, even for trucks with larger I nan normal fuel tank capacities
(See Appendix B). Further, GM has tcid EPA that it has tested 2 vehicles
with 40 gallon tanks that achieved control levels of 2.35 and 2.85 grams
per test (using 2,500 cc canisters and an air filter with activated
charcoal). Therefore, EPA concludes that control systems should be
available by 1981 which will permit GM to meet the 2.0g/test standard
for most, if not all, of their model line options including the heavier
light-duty trucks. It may be, however, that GM may not be able to optimize
their evaporative emission control system by that time so that they can
continue to offer to buyers of new light-duty trucks optional larger fuel
tank capacities. With time such optimization should -be possible and GM
would again be able to continue to offer auxiliary tanks for sale on its
vehicles. But for some period GM may suffer lost sales and revenues (if
consumers buy trucks from other manufacturers who have been successful in
certifying trucks equipped with larger tanks) or lost revenue (if consumers
elect to buy the GM truck anyway, but forego the purchase of the optional
fuel tank from GM). The extent to which this will effect the revenue and
profitability of GM are impossible to predict with any accuracy, but are
likely to be inconsequential.
2. Competitive Structure
The effects of these regulations on the competitive structure of
the light-duty vehicle or light-duty truck industries are expected
to be minimal. Historically, the market shares shown in Tables
111—2 and III-3 in Chapter III have been quite stable and a ninor price
increase of up to . would not be expected to have any effect.
-75-
-------
3. Development and Certification Costs
The manufacturer1s cost of developing and implementing specific
control systems can not be separately determined. However, the
development cost per vehicle vehicle should be very small compared to
the $1 - §5 estimated vehicle retail price increase. Some develop-
ment costs will have been incurred as part of manufacturers' efforts
to meet the California 2.0 g/test standard in 1980.
The cost of certifying vehicles at 2.0 g/test rather than a
6.0 g/test emission level should also be minimal. Many vehicles
are already performing at less than a 2.0 g/test level. These vehicles
should not have to be recert if iei'. Still others may have achieved the
2.0 g/test level of control by 1981.
4. Potential Impact on Employment;
Nro production plant closures by any manufacturer of light-duty
vehicles or light-duty trucks are anticipated due Co the implementation
of these regulations. The decrease in sales due to increased vehicle prices
discussed earlier is expected to be very small and therefore its impact
on employment at worst is expected to also be very small.
-76-
-------
It is li'rely that increased engzr^ering and manufacturing effort
wxLl be required Co provide the new control systems. As noted earlier,
CM has said that it will expand plant, capacity to produce the required
control systems thereby creating nev jobs. However, little effect on
the size of the overall work force is expected to occur. Generally
the control cevic-es required will be modifications or redesigns of
existing devices and, thuSj the major work effort will be in the
engineering and skilled trades labor force.
C. Government Costs
This ruleEia'iir.g »L1L r.ot aCgnifLcar.tL" offset ihs fevernnient's
cost oE vehicle certification, since the test methodology is unchanged,
and the number of tests are essentially independent of the level of
control.
D. National Annualized Cost and Capital Investment over 5 Years
The national annualized coat of attaining a 2.0 g/test standard for
1981 and subsequent model year vehicles is estimated co be between $12
-77-
-------
million and $62 million by the fiftl> year of implementation, 1985.
Since there is no change in operating or maintenance cost associated
with this action, the annualized cost is based entirely upon the annualized
cost of five model years of control systems for cars and light-duty
trucks assuming a 10 year useful Life (i.e., the value of the vehicle at
the end of 10 years is zero) and a 10% annual interest rate.
The national gross capital investment over the first five years is
it t £-
estimated to total between $79 million and $400 million . This
-Jr
compares to a projected $280 billion in retail sales of new cars and
light-duty trucks during the same time period, i.e., 1981-1985.
* 1973 dollars
-78-
-------
Chapter V1
Cost Effectiveness
One of the goals of the Mobile Source Air Pollution Control activity
is to obtain clean air at minimum cost to society. For effectiveness in
implementing this goal, a mechanism is needed by which the relative cost
and effectiveness of the various mobile source emission control strategies
can be assessed. Cost effectiveness (CE) is such a mechanism by which to
assess the cost per unit of desired result. In this case, cost effective-
ness is expressed in terms of dollars spent to prevent one tor of pollutant
from entering the atmosphere. Once cost effectiveness is calculated for
a series of control strategies, the strategies can be compared. The most
efficient strategy is the one with the lowest cost necessary to control
a ton of pollutant. In addition to the cost effectiveness of given
strategies, the amount of control available by the strategies and the amount
of control required to meet the air quality goal must also be known. A
given strategy may be very cost effective but not provide much pollution
control. Alternately, a strategy might provide a large amount of
pollution control but not be cost effective. Ideally, those strategies
which are both cost effective and which control large amounts of pollutants
should be implemented first. Other strategies would be implemented as
needed to meet air quality goals.
The most appropriate measure of the societal cost of control
is the cost that the consumer must bear. This cost consists of an
-79-
-------
initiaL cost caused by an increase in tue manufacturer's suggested
retail price and a continuing cost which consists of the support or
maintenance cost per unit of operation (e.g., per mile) for the life of
the vehicle. For this rulemaking, the incremental operating costs are
expected to be zero. The initial cost will consist of the cost to the
manufacturer to attain the required control plus a mark-up (profit)
whi.ch is at the discretion of the manufacturer.
The measure of effectiveness of control can most appropriately be
determined by comparing the emission per unit of operation (per mile)
from vehicles representing the appropriate level of control. The
difference between the two represents the amount of control (i.e., the
mass per unit of operation (g/mile)) which is gained by the control
strategy. The cost effectiveness (CE), then, is the ratio of the
total vehicle cost to the total pollution controlled:
C£ ( $ /1 on)__ Initial Cost + ["(Operating Cost, $/roile) >: (Total lifetime distance ,
(Reduction in emissions, tons/nile) x (Total lifetime distance,
For this cost effectiveness analysis, the assumption was made that
an average vehicle or truck will last 10 years and travel 100,000 miles
during that time. The assumption used for other mobile source control
strategies, that the deterioration facto: will remain constant over the
100,000 mile life of the vehicle, will be used here. This means that,
when the vehicle nreets the certification requirements at 50,000 miles,
the average emission rate for the entire 100,000 mile period will be at
or below the standards.
-SO-
-------
The equivalent g/ini reductions in emissions for light-duty vehicles
and light-duty trucks are shown in Tabie VI-L. For the cost effectiveness
analysis it will be assumed that by 1990 all vehicles will be emitting at
an evaporative level of 2.0 g/test (equivalent to ,15g/mile), and at statutory
exhaust hydrocarbon emission level (0.41 g/mile). This assumption is based
on the fact that almost all vehicles on the road in 1990 will have been certi-
fied at those levels and that the proportion of vehicles old encrjgh to have been
certified at higher levels (1979 and earlier model year vehicles) will be
relatively small.
Table VI-2 gives the cost and cost effectiveness for controlling a
light-duty vehicle or truck to the various levels discussed. Also
included are the cost effectiveness figures for the 6.0 g/test standard
assuming a SHED test measurement technique, the cost effectiveness of going
to the statutory exhaust HC level for light-duty vehicles from a 1.5 g/mi
standard, and the cost effectiveness of an Inspection-Maintenance program.
These other control strategies are included for additional comparison with
the alternative evaporative control actions to show their relative cost
effectiveness. The cost effectiveness of alternative action III and achieving
statutory exhaust HC levels is in each case based fin the composite LDV,
LDT reductions from Table VI-1 and the costs shown. Comparison can also
be made with various strategies for control of HC emissions from stationary
sources by referring bac:< to Table 11 — 1 in Chapter II.
-81-
-------
T,,/in j redik r. i on
1.1 gh L -Dn Ly
Truck',
R/"ii l.
g/mi
reduc tion
ComposlC c
LI)V + 1.I1T
1
g/iru
r; / [m L reduction
Current Evaporative
Phu ss ion ] cvels
(6 g/test Evnp. Stund-
d rd)
0. 60
0.60
0.60
2 Lest Cvjp. Stand-
o i d
0.15 0. e, 5
0.15
0.4 5
0.1 5
0.4 5
i
Co
I-O
I
C'ur rent
I [)V h:hausc Emit>i>icn
S L.jnda ids
btaLuLory I-I)V L"hausL
Lnii ¦ js j on l.evel
] . 50
0.41 J.09
linked on vehicle miles Lr.ivellcd by IjghL-duLy vehicles being 87.2% of Lotnl vehicle miles
travelled by light-duly vehicles and light-duty trucl.o
-------
Table VI-2
Per Vehicle Cost -.ind Cost Effectiveness
of Alternative Actions
Per Vehicle Cost
of Control
Alternative
Action I
(No Action)
Alternative
Action III
(2.0 g/test Std. in 1931)
1978 Evap. Regulations^"
LDV Exhaust HC Emissions
to Statutory Level
3
LDT Exhaust HC Emissions
(2.0 to 1.7 g/mile & expand
class to 8,500 lbs. CVWR.)
$1 ~ $5
$7.30
§62 - $164
$2203
Cost Effectiveness
$/ton HC
20-100
50
500-1400
$200
HDV Exhaust HC Emissions
Inspection Maintenance
$120
$154
$58-408
"Environmental and Inflationary Impact Statement - Revised
Evaporative Emission Regulations for the 1973 Model Year", Aug. 1976.
2
Source: Analysis of Some Effects of Several Specified Alternative
Automotive Emission Control Schedules", prepared jointly by EPA, DOT
and FEA, April 8, 1976, p. 15. Assumes cost to achieve statutory levels
for CO and HC are equally split, (i.e., 50% for CO, 50^ for HC). Large
range is due to the large range of expected lifetime costs (which in-
cludes initial costs, fuel costs, and maintenance costs).
3 .
Source: "Environmental Iirpact Statement - Emission Standards for flew
Light-Duty Trucks", November 29, 1976. Cost of $220 is to bring 6,000
to 8,500 lb. trucks into compliance. $8 for all others.
4
Source: "Environmental Impact Statement and Economic Impact Analysis -
Revised Heavy-Euty Engine Regulations for 1979 and Later Model Years",
August 4, 1977.
3 Source." Internal EPA memo frora M. Williams to J. Lane, Aug. 18, 1975,
assuming a failure rate of 20%.
-83-
-------
ClhlpLOL" VII
Other General Cons idei l Lions
A. Irreversible and Irretrievable Coi;.mtir.enc Pes.-urces
No irreversible ^nd irretrievable commitment of resources is
caused by this rulemaking. This rulemaking action will not cause any
fuel consumption penalty, and commitment of resources sucn as steel,
aluminum, and carbon for the evaporative emission control systems is so
small as to be completely over-shadowed by normal market fluctuations.
B. Relationsnns of Short-Term Uses of the uviror.T.ent ant'
¦Maintenance ana Cnnpnce.-.ier ¦" of hon^-Term Procjctivitv
This rulemaking will result m immediate reduction of nycrocarbon
emissions from nev lignt uuty venicles and light duty trucks and, as
oluer vehicles are replaced i;ith newer vehicles neecmg t ie revised
evaporative emission standards, will result m significant reductions in
levels of oxidants m tne ambient air. This reduction uill also be
bcneiicial and aid in the long term maintenance of ambient air quality
levels.
No short term or long term losses to the en/irjnnent are associated
vita this rulemaking. Tne timing and stringency of tne standards are
aimed entirely at the maximum reduction m evaporative h/crocarbon ernis-
-84-
-------
sicrns in l!ie shortest time period tha mLI not result in undue economic
dislocation to t!ic liyhc duty vehicle and light duty truck industry.
-85-
-------
Chapter' /III
Problcns and Ooiections Poised L- Federal, Si-ate, and Local
Agencies, and Ocher Persons
Comments were received cn the Draft Environmental Impact Statement
for the Revised Evaporative Emission Regulations for 197S and Subsequent
Model Years from private industry, the Council on Wage and Price Stabil-
ity, and the Department of Commerce. The comments regarding a 2.0
g/test standard focused on tne issues of Feasibility, Lead Time, Cost,
and Cost Effectiveness of a 2.0 g/test standard. The comments on the
issues of Feasibility, Lead Time, and Cost were analyzed in detail in
the Summary and Analysis of Comments paper supporting this rulemaking
12 3
and in three issue papers on tnose subjects. ' '
Tne following is a suxmary of tnose discussions:
1. Test results on production and modified vehicles show that an
evaporative emission standard of 2.0 g/test (including stabilized back-
ground) is technically feasible;
^ "Tecnnical Feasibility of a 2.0 g/test SUED Evaporative Emission
Standard for Light-Duty Vehicles and Trucks," Issue Paper by
Michael W. Leiferrnan, U.S. EPA, Ann Arbor, Michigan, June 1976.
2
"Lead Time Requirement for an Evaporative Emission Standard of
2.0 g/test for Lignt-Ducy Vehicles and Trucks", Issue Paper by
Michael W. Leiferoian, U.S. EPA, Ann Arbor, Michigan, June 1976
(Revision N'ovemDer 1977).
"Cost Effectiveness of a 2.0 g/test SHED Evaporative Standard for
Lignt-Duty Vehicles and Trucks", Issue Paper oy Micnael .•!. Leiferrnan,
U.S. EPA, Ar.n Aroor, ilicnigar, June 1976.*
-86-
-------
2. Due Co the Hire requirement; ' >r equipment definition, design,
d ev c lopme :i L and production, the propo.^il 1979 implement a tion date is
impossible and implementation for the 1930 model year appears impractical.
It is recommended that the 2.0 g/test standard be promulgated for the
1981 model year;
3. The incremental sales weigh tec increase in the retail vehicle
price is expected to be between $1 and $5 per vehicle.
Comments received on the issue of cost effectiveness from the
Council on Wage and Price Staoility have not been analyzed in the above
mentioned documents, and will, therefore, be dealt with in detail here-
The following is a sumnary of the comments from the Council on Wage and
Price Stability:
"The Council has reviewed the EPA's economic anal/sis and has
concludea that it indicates that these regulations are, for the
most part, cost effective. There are, however, several points that
the Council would like to sec addressed by the CPA before these
standards are promulgated."
There is some disagreement regarding the increased price that will
result from ti.e 2.0 g/test standard. EPA estimates trie cost at
$11, but one manufacturer (Chrysler) gave the Council an estimate
of $50 (costs to go from current levels to 2.0 g/test level). If
the copt of a 2.0 g/test system is $50, the incremental cost in
-87-
-------
going from 6.0 g to a 2.0 £ star. ¦ ird would be $c354/ton as opposed
co che $74/lOii incremental cose estimate of EPA. The Council urges
Chat EPA resolve this cost effectiveness issue before a decision is
rendered on Che 2.0 g/test standard.
Cost data provided by the UFA for tie,incremental cost per ton of
hydrocarbon pollutants removed includes $29/ton for HDV interim
exhaust emission standards, $22b/ton for LDT interim exhaust emission
standards, $303 for LDV federal interim exhaust emission standards,
and $515/ton for the 1973 federal statutory levels for LDV's and
LDT's. In view of these estimates, it would seem more cost effective
to impose the stricter HDV exhaust emissions standards before
imposing a 2 g/test evaporative emission standard on LDVs and LDTs.
"The Council would also urge EPA to consider the economic feasibility
of a 2 g/test standard using a SHED procedure that includes background
emissions. ...In other words, it is the Council's position that
this technical element of the proposed stanaarcs be evaluated in a
cost effective manner and that the benefits be weighed against the
ccscs before a definitive decision on including background emissions
in a 2 gram/test standard using SHED is made."
"Another issue that the Council urges EPA to consider more explicitly
in its deliberations on the 2 g/test standard is whetrier or not the
incremental benefits justify the incremental costs... Pr.e council
would ask whether or not these types of benefits (i.e., million
tons per year of reduced hydrocarbon emissions) coula be converted
-88-
-------
Lulu Lcnas thai would be more im 'lingL'ul Lo Llic general publLc.
...The Council i/ould suggest:, i£ feasible, chat the benefits be
translated into such terms as a reduction in certain types of
illness or at least m terms of tne reduced risk of contracting
certain types of illnesses."
Discussion
The first concern raised was that the cost estinate of $50 ($44
incremental) from Chrysler was sucn higher than EPA's original cost
estimate of $11 ($2.70 incremental). This issue was dealL with m
detail in the Analysis of Comments ana m the issue paper on the cost of
a 2.0 g/test standard. It was shown in those papers that the cost
estimate from Chrysler was much higher than what will be necessary to
control evaporative emissions to a 2.0 g/test level. The predicted
average incremental retail cost increase was $1 to S5 whicn is m
agreement with EPA's original estimate of an incremental retail cost
increase of $3.70 (from $7.30 to $11).
The calculated cost effectiveness of reducing the evaporative
enission standard from 6.0 g/test to 2.0 g/test is $20 to $100 per ton
or iiydrocarbon renO'/ed (based on a $1 to $5 retail price increase) .
Therefore, reducing the evaporative emission standard to 2.0 g/test is
e>roected to be rore cost effective than any other control strategy
currently being considered except for the HDV interim e::naust enission
-89-
-------
standards wnich lias a cost effectivei1' ss of $29 per Con of liC removed.
If the ultimate cost cffccriveucss oj a 2.0 g/tesL standard is actually
$20 per con of HC removed, Che 2.0 g/'test standard would be Che nose
cost effective action of any currencly considered strategy for controlling
mobile source HC emissions. It should be further pointed out that the
HDV interim e::haust emission standards are being implemented in 1979.
Therefore, they are as the Council suggests, being imposed before imposing
a 2.0 g/test evaporaCive emission scandard on LDV's and LDT's in 1981.
EPA's analysis of the cost of a 2.0 g/test standard included
measurement of stabilized background emissions. Manufacturers can
either use old venicle bodies or artifically aged new vehicles by
exposing cheti co elevated temperatures, removing vinyl and plastic
components, etc. Manufacturers will be able to obtain vehicles with low
stabilized background levels by such means whether or not an allowance
for backgrodund levels is aaae. It is EPA's position that the manufacturer
can and will obtain low background test vehicles.
The Council on Wage and Price Stability has also requested chat a
cost benefic analysis be performed which would coiTvert the tons/year
reduction into terms more meaningful to the public. EPA would very much,
like to be able to translate incremental emission reductions into
incrcTcntr.l health effects such as reduced illnesses, etc. However, the
relationship between emission reductions and ambient air quality anc
effects upon human health are r.ot sufficiently veil known co provide
-90-
-------
reliable qunnLificntion of the expcc'-d health bcncfiLs. Co-.plicating
this further is the different mir.tur^s and levels of pollutants in
cities across the Nation.
The National Ambient Air Quality Standards were established in
orcer to quantify the level of pollutants in the ambiei'.. air above whicn
there were observed adverse health and welfare effects. It is to the
goal of bringing the quality of the air m U.S. cities to such acceptable
levels that the evaporative emission standards are addressed. That a
large numoer of Air Quality Control Regions are expected to e::ceecl the
stancards in 1985 and later and that the proposed 2.0 gran/test standard
provj.des a significant reduction in emissions at a cost-effectiveness
level that is very favorable compared to other ongoing strategies is
considered sufficient justification for the action.
-91-
-------
APPENDICES TO
FINAL
ENVIRONMENTAL IMPACT STATEMENT
-------
APPENDIX A
Appendix A contains material related to the air quality impact
analysis that was completed to determine the effect this regulation
would have on oxidant formation by the year 1990. Because of its
length, a complete copy of the report "Evaluating the Air Quality
Impacts of Alternative Evaporative Emissions Control Strategies,"
prepared by the Office of Air Quality Planning and Standards, U.S.
EPA, has not been included in this appendix. Only a summary of
the report is presented. A copy of the complete report is available
for public inspection and copying during normal business hours at
the Public Information Reference Unit, Room 2922 (EPA Library),
401 M Street, S.U., Washington; D.C., 20460. As provided for
in 40 CFR Part 2, a reasonable fee may be charged for copying services.
-------
6Tb ¦' UNI I CD SI A i TG (TNVIis'ONMCf Al. PKO I LC I ION A(_.r_NCY
rnO1^"
WA'jIIINO IOM if.
or rii_r: or
Aii-i «.vjo ..Asrc m^nr-Gi.¦-1C.
MAR 0 2 1978
SUBJECT:
FROM:
Air Quality Proiectzions for Alternative LDV/LDT
Evaporative Emission Control Strategies
Eric 0. Stork, Deputy Assistant Administrator
Cor Mobile Source Air Pollution Control (AV—455)
_ .t. A*<1
MEMO TO: Jim Wilson
Control Simulation Section (ILD—i4)
THRU: Robert Meiigan
Monitoring and Data Analysis Division, OAQPS
This office is m the process of completing tne Env ironrren tal
Inpact Statement to accompany a final rulemaking for control of fuel
evaporative enissions from lignt-duty venicles and trucks. Tnis
regulation will reduce the maximum allowable levels of evaporative
hydrocarbon (KC) from 6.0 grans per Lest (3/test) to 2.0 g/test
beginning with the 1981 model year. To complete the SIS
we must ask you to provide us with air quality projections oased on
anticipated enissions from these vehicles when tne 2.0 g/test
standard is in effect, as well as for cvo alternative strategies
we consicered. h'ote that only hydrocarbons are at issue m this
rulemaking, so the only air quality analysis that will neea to
be conducted is for oxidants-
Attached are tables vhich contain the emission factors for
mobile sources wnich you will need to co your analysis.
These were calculated using the data contained in the January
197S final draft of Supplement S to AP-42- Fyd r oc.»rbon emission
factors for light-duty vehicles (LDYs) and light-duty trucks (LDTs)
have been separated into an exhaust and an evaporative ;!C emission
component- These are presenteu 111 Tnbies I.i nnd b and Tables
11a nnd b- Three <11 t o rn a t j v e evaporative emission standards
were considered. They are: Maintain the current 6-0 g/tesc
standard through 1990; implement a 2.0 g/test standard in
1980; and, implement a 2-0 g/test standard m 19S1. Thus for
model >ears 1930, 19S1, 1985, ana 1990 you will find three
evaporative emission factors for LDVs and LDTs based on tro
assumptions underlying each alternative. Heavy-duty vehicles
and moLorcycles arc not impacted by this rulemaking, and so
only a total hydrocarbon emission factor is given- (See
Tables III and IV)
P-/
-------
All enissio.i factors for non-higl -ay vehicles and stationary
bou'ees, growth rates, retirement race , V.'IT splits, etc.,
should be selected Co be consistent v; -.h c'ne nose recent meriiua
range (1990) projections which have bean circulated outside
the agency- l.'e would like to receive a list of the various
factors used in making the projections for use in documenting
the CIS for this regulation.
Fro;n your analysis vc voulc like to know what effect each of the
alternatives has on oxidant air quality in 1985 and 1990- We would
also like to rccci-ze emission inventory data for 1930, 1931, 1985,
and 1990 as well as for the base year (1975). Our current schedule
for completing work op the environmental Impact Statement is March
21', so we would like to receive the results of your analysis on or
about i'arcn 13- Based on your past rapid turn around on our past
requests for support ana because only an analysis fcr only one air
quality proDlem is required we trust that tins is sufficient tir.e.
I would again Iikc to express our appreciation of the fine
support ycu have provided this office during our past rulemakings.
At tacnnen ts
-------
I'.m lr f t
lie
.on
'actorb - Light Daty VenicLes
Mtrctri Year
Cxnaust UC (g/mi)
Cvjpor.mva I1C (g/ni)
1975
1976
1977
1978
19/9
1980
1981
1985
1990
5-83
5. A3
5.02
4.62
23
3-77
3-31
2-06
2.26
2.12
2.02
1.82
1.60
See Table I'd
Table lb
Evaporative hC Emission Factors
r.pi;,siort Assur.ntion
6-0g 197S-1979 6.0 1978-1980
6. Op. 1978-1 990 2.Or. 1980-1990 2-0;; 1981 -1990
1S80 1.41 1.36 1.41
19S1 1.23 1.12 1.19
1985 .79 -A3 .52
1990 .63 .20 .21
f)-3
-------
Tib ! t» I L.i
riC Linssion TncLors - Lighc Duty True! i (0-8,500 lb)
Cc.u.*~c£ci^_
* y* y ? «2 r
E\hr.11st HC (e/ni)
i.^^tjorap.vi t-.o
(g/mi)
1975
19 75
1977
1078
1979
19S0
1981
19S5
1990
6. 7£
6-36
6.09
5.9*.
5.70
5.52
5.21
4.09
2-86
2.72
2. 5i
2.i0
2.22
2.01
See Taole lib
Table I I'd
Evaporative HC Emission Fcccors
Emission Assuntion
5-0s 1973-1979 6.0^ 197S-19S0
\4<*krir Year 6. On (1978-1990) 2.0.7 19S0-1990 2.Cr- 1981-1990
1930 1 . 78 1 - 7/. 1 . 78
1931 1.56 1.^6 1-52
1935 .99 .71 .75
1990 .73 .3A .35
r?'
u
-------
L d h 1 o 1 [ i
ik', ilm^sbion Tsctor, - .le.'wy - Only Vc'icLo<
ic;
1975
1976
19 7 7
19 78
19 7?
19C0
1931
19S5
1990
Gasoi i.no
To en J !'C (g/ni.1
33- 51
37.82
37-40
3 7.09
3 5 -1] 2
33-CS
30.51
20.96
17.03
DlCSCl
ToCd! HC (s/rni)
5-03
5.09
3.10
5.11
5.1 G
5.23
5.29
4.54
3-69
7aDie IV
:!C Emission focCorb - '.'oLorcycIcs
(.a/**.
¦y^ucl Year Tot.i J HC (g /mi)
1975
19 7 6
1977
1978
1979
19-SO
1981
1935
1990
11.-3
11.43
11.20
10-12
8.4 3
7.11
6.07
2. 30
0.63
-------
D AT C 2
UNITED STATES ENVIRONMENTA PROTECTION AGENCY
,, ,,rn 1070 Ofli.cc of Axi" Quality Plam-ng and Standards
^ ' ! Research Triangle Par! , Noi 1 li Ciirolin:i 27711
ECT Air Quality Projections for AlLernativ- Evaporative Enissions
Control Strategies
FR0^ James H. Wilson, Source Analysis Section , C'li',r£j \
Axr Management Technology Branch, MDAD (MD-14^'/
and ^
Uarren P. Freas, Technology Development Section
Air Management Technology Branch, MDAD (MD-14) ^
THRU: Robert E. Neligan, Director
Monitoring and Data Analysis Division (MD-14)
TO: Eric 0. Stork, Deputy Assistant Administrator for
Mobile Source Air Pollution Control (AW-455)
Enclosed are the results of the air quality projections for the
Environmental Impact Statement to accompany the final rulemaking for
control of fuel evaporative emissions from light-duty vehicles and
trucks. Table 1 summarizes the estimated air quality impact of three
alternative evaporative emissions control strategies. Tables 2 through
10 present the results on an AQCR-by-AQCR basis for each strategy.
Table 11 presents the input data used in the projection models. Hydro-
carbon emission inventories for the three strategies and four projection
years (1980, 1981, 1985 and 1990) are presented as Table 12. Finally,
ratios of projected hydrocarbon emissions to base year emissions for
each strategy and projection year are presented as Tables 13 through 15.
In addition, a copy of your March 2, 1978, memorandum requesting
this analysis has been enclosed as an Appendix. The change from model
year to calendar year was discussed with Robert Smith of your staff.
Enclosure
cc: Edward J. Lillis
Bruce Jordan
fo,,„ 1370 /, ffc'tv 3 ?6>
-------
VALUATING THE AIR QUALITY IMPACTS OF ALTERNATIVE
EVAPORATIVE EMISSIONS CONTROL STRATEGIES
Air Management Technology Branch
Monitoring and Data Analysis Division
Office of Air Quality Planning and Standards
March 1973
-------
EVALUATING THE AIR QUALITY IMPACTS OF ALTERNATIVE
EVAPORATIVE EMISSIONS CONTROL STRATEGIES
Tins report presents the air quality impacts of three alternative
strategies for the control of evaporative emissions of hydrocarbons.
These air quality projections were made using the (Modified Rollback
Model. Trie oxidant analysis also includes projections made using the
Ozone IsopTeth Technique. The iscpleth analysis included in this report
assumes that the i!KHC/i!Q ratio is 10:1 in all AQCR 1 s , ,and the effects
X
of natural background and downwind transport effectively cancel each
other to produce a negligible oxidant background. Table 1 summarizes
the projection results. The table shows the average percentage change
in air quality concentration frcm the 1975 base year for the years 1980,
1931, 1985 and 1990.
The three cases analyzed are as follows:
Evaporative
Case Emission Assumption (LDV's and LOT's)
I 6.0 g 1978-1990
II 6.0 g 1978-1979; 2.0 g 1380-1990
III 6.0 g 1978-1SSQ, 2.0 g 1931-1990
Tables 2 through 10 presort the results of the air <;ea"ity projec-
tions on an AQCR-by-AQCR basis. Most of the AQCR's analyzed include
large metropolitan areas with violations of the HAAQS. The base-year
concentrations for oxidants are the maximum 1-hour concentrations during
the second-worst day in any year from 1971 through 1976.
The annual growth in vehicl;. miles traveled for mobile sources is
-------
-2-
assumed to be 2 percent. The stationai/ source growth rate is assumed
to be 3.2 percent. These assumptions are equivalent to those used in
the recent analyses of alternative automotive emission standards pre-
pared for the U.S. Congress. The frequency of occurrence of standards
violations was estimated for oxidants for each area under analysis. The
frequency of violation calculations for this pollutant are based on
national average frequencies of occurrence derived from air quality data
m the 1973 "Trends" Report. The oxidant data from the 1973 "Trends"
Report were used to relate the second highest hourly oxidant concentra-
tion to the percentage of hours in the year when the oxidant standard is
violated. A curve was fitted to these data points so that when the
oxidant concentration for an area is projected to a future year, this
same curve can be used to estimate the number of l-'nour periods in
excess of the .03 ppm standard. Because all oxidant frequency of viol-
ation calculations are based on national average frequencies of occur-
rence, these values my not apply to specific locations.
Table 11 shows the composite emission factor ratios for mobile and
stationary sources considered in evaluating the three alternative standards.
These composite emission factors were provided in the March 2, 1978,
memorandum from the Office of Mobile Source Air Pollution Control.
All emission factors for stationary sources are equivalent to those
used for air quality projections in the Air Quality, Noise and Health
Report of the Interagency Task force on Motor Vehicle Goals Beyond 1980.
M
-------
-3-
Table 12 shov/s the base year ennsr>>on inventory for hydrocarbons
from NEDS and the hydrocarbon emission inventories projected to 1990.
Tables 13 through 15 provide ratios of projected hydrocarbon emissions
to 1975 base year emissions.
The Appendix includes a copy of the March 2, 1978, memorandum from
the Office of Mobile Source Air Pollution Control. Corrections to some
column headings have been noted in Tables 1 through 3 of that memorandum.
B-/o
-------
TADIE 1
Average Percentage Reduction in Oxidant Air Quality Concentrations
From Base Year 1975
Linear Rollback With Zero Background
1980
1981
1985
1990
Case
I
10
14
27
35
Case
II
10
14
28
37
Case
III
10
14
28
37
Linear Rollback With .04 ppm Background
1930 1981 19S5 1990
Case I 8 ]Q 2U 27
Case II 8 11 22 29
Case III 8 10 21 29
Ozone Isopleths With 10:1 NMHC/NO Ratio With Ho Background
X
1930 1981 190S 1990
Case I 2 3 8 13
Case II 2 3 9 15
Case III 2 3 9 15
Percent reductions reflect the impact of the DOT Report emission
control assumptions plus the impact of evaporative emission controls.
/)-//
-------
APPENDIX B
Appendix B contains memoranda which summarize meetings or dis-
cussions between EPA and manufacturer representatives after the
public comment period had closed to consider the tschnological
feasibility of meeting a 2g/test evaporative emission standard.
Copies of these and other documents on the subject of cost, lead-
time, and technological feasibility of the 2g/tesc standard, which
were submitted to or prepared by the Agency both during and after
the official comment period, are maintained in the Public Information
Reference Unit, Room 2922 (EPA Library), 401 M Street, S.W.,
Washington, D.C., 20460, These records are available for public
inspection during normal business hours. As provided for m
40 CFR Part 2, a reasonable fee may be charged for copying services.
-------
datc N'uvnnlx.'i 2l), I')7 7
'Uuject Meeting witn Cencral Motors Concerniiv Lead Time Necessary for Imp lamentation
of a 2.0 g/test. Evaporative Emission .-',:andards for Light Duty Vehicles and
Light Duty Trucks.
from Michael W. Leiferman, SDSB/
TO
THE FILE
THRU: Charles I. Gray, Chief, SDSB^ '
On November 4, 1977 a meeting between GM and EPA representatives in
regard to the lead time necessary for a 2.0 g/test evaporative emission
standard was held at the EPA Ann Arbor laboratory. GM representatives
present were Gerald Barnes (EAS), Stu Martens (EAS), A1 Taylor (EAS) ,
Duane Tangue (Cuick), Louis Taix (Chevrolet), T. K. Recrpan (Rochester)
and Roger Lundquist (Oldsmobile). EPA members present were Charles Gray,
Ronald Kruse, Clifford Tyree, Martin Rememan and Mick Leiferman.
GM representatives presented evaporative emission data on venicles
which had received various modification, to their induction systems.
Most of these modifications were done m an attempt to prevent hydrocaraon
leaks from various parts of the carburetor. Among tne modifications
tested were sealing the interface between the carburetor air horn and
the mam body of the carburetor, sealing of the accelerator pump shaft
and idle mixture screw, sealing the air cleaner housing snorkel during
engme-off, sealing of the throttle and choke shafts, installation of
activated carbon in the air cleaner housing, and venting of the bottom
of the charcoal canister to the air cleaner. Altnough the data showed
that by using some combination of these measures evaporative emissions
could be reduced to below 2.0 g/test, GM seated that tne production
designs for most of these changes had not been finalised.
The modification which appears to require the longest tooling leac time
is the addition of activated carbon to the air cleaner. This approach
appears more desirable than sealing the snorkel because sealing of the
air cleaner results in the vapors oemg expelled from other locations.
GM stated that the tooling time required for putting activated carbon in
air cleaners was 93 weeks, and this lead time estimate applies to either
the carbon air filter element or carbon in the air cleaner housing. GM
is currently working on a design to con Lam the activated carbon m the
air cleaner housing so that carbon covered air filter elements will not
be required.
"=A ronw I 320-6 l"EV. 3-7SI
-------
Another uodLfLcnliou whu:h nay require- i;-, much lead time as the activated
carbon air cleaner is an improved seal between the carburetor air horn
and the main body of the carburetor. lM stated that reducing this
source of leakage to an acceptable level would require either an improved
gasket or a machining operation lo the mating surfaces. If an improved
gasket was found acceptable, the lead time required to obtain this iten
would be 20 weeks. If a satisfactory gasket could not be developed, the
lead tine for tools to perform the machining operations would be two
years. Rochester Products has five carburetor production lines. In
anticipation of a California evaporative emission standard of 2.0 g/test
in 1980, they are equipping one of these five lines with the tools to
perfor-n this machining operation. To make this change for the 1SS0
model year, the tooling must be installed by March 1, 19 79. The tool
making lead time for one line is one year, so the blueprints must be
released by March 1, 197S. GM stated that the same change for all five
production lines requires a tooling time of two years. This is mainly
because of the limited availability of tool makers.
GM indicated that implementing the other modifications which were incorporated
in the experimental carburetors would not be as major a problem as the
two modification discussed above. HC leaks around the idle mixture
screws could oe eliminated by applying a sealant to the steel plug which
will be used to make these screws tamper resistant. And Mr. Redman
stated that tne acceleration pump shaft leakage problem could be overcome
by the 1980 model year. In view of this, it also seems reasonable that
an acceptable throttle shaft seal could be developed m the same time
frame. Since it appears that choke shafts would be more sensitive to
movement interference than acceleration shafts and throttle shafts, it
might be expected that seals for this application would need to be more
sophisticated than for the other applications.
There was sone discussion at the meeting ss to whether GM had been
making a reasonable effort to develop systems capable of complying with
a 2.0 g/test evaporative emission standard. When asked che current
level of nanhour effort at Rochester Products, the response was that
tney did not have sufficient knowledge to answer the question. The
Rochester Products representative did state, however, that they did not
begin working on the carburetor sealing problem until the first of tnis
year (1977). Roger Lundquist, GM representative from Oldsnobile, said
that the reason for Rochester's late start was that prior to that time
the CM car divisions believed they would be able to meet a 2.0 g/cest
requirement without carburetor sealing improvements. He stated that one
test program which had lead them to this conclusion was with 1974 model
year vehicles. A1 Taylor also emphasized chat the reason Rochester
Prouucts had not been working on the carburetor sealing problen prior to
1977 was that until that ti"
-------
g/tcst standard. In face, in their co menus to the evaporative NPRM
published in. January, 1976, CM stated ' liat the technological feasibility
of a 2.0 g/test standard had not been 'emonstrated and that they did not
kno'.v or any hardware vnich could he used to meet such a standard.
Considering Mr. Lundquist's and Mr. la/lor1 s statements at the meeting
it apoears that GM comments to tha NPRM may have been something lass
than tne vhcle truth, On the other hand, iL between tests such as Mr.
Lur.dquist had described and the submittal of comments to tha NPRIl (m
March, 1971J GM had obtained information shoving that controlling evapor-
ative emissions was going to be a mora difficult tasri than previously
e::pccted, it appears that some foot dragging occurred before Rochester
Products started wording on the problem.
When asked if they could meat a 2.0 g/test standard m 19SO, the GM
representatives agreed that they could not. A1 Taylor expressed the
strong opinion that although GM. could not comply witn a 2.0 g standard
in 1930, they had been making a good faith effort in developing systems
to meet such a level. Charles Gray e>:p; essed disagreement with Mr.
Taylor's view.
In summary, GM stated that they could not comply wit 11 a 2.J g/test
standard in 1980; however, they were quite confident in being able to do
so for the 1981 model year. The 1930 model year was not possible because
of the tooling lead tine associated with one, or possibly tvo, itens.
The first being an activated caroor. containing air cleaner, and the
second being an improved seal between carburetor air horn and main body.
The lor.,'; toolin time woulc be eliminated for the second item if an
adequate gasket can be developed. The cine which is now needed for GM
to comply ivith a 2.0 g/test requirement appears to be a result of duo
factors — up until 2 or 3 years ago CM underestimated the effort that
would be required to comply with the standard, and GM's carburetor
division was not involved in the effort until sone time after the
magnitude of the problem was realized.
Attached are two handouts \Mic'n ware distributed by the GM representatives
cc: Charles C-ray
Ron Kruse
Cliff Tyrca
ATTACHMENTS (2)
-------
STATUS or "2 GRAM." CVAPORA1IVC GtISSIO:i
DEVELOPMENT PROTOTYPE \ .ft!CLCS
AUGUST 1, 1977
All tests were conducted at the Chevrolet Engineering Center Laboratory.
Tests were conducted with new equilibrated and purged canisters and new,
adsorption type air cleaner elements. Vehicles are conditioned for
minimum background emissions but are low mileage. These data should be
considered with the qualification that the carburetors (and air cleaners)
of the test cars received special treatment to minimize vapor leakage
beyond a level likely to oe achievable with production cars. Special
treatment included:
o Hand selected low leak carburetors.
o Installation of experimental accelerator pump boots (impractical
except for lab. work).
o Machined mating surfaces (e.g., air horn).
o Silicone seal over air horn/air cleaner joint.
Number ,\'o.
Model Vehicle Engine Evao. System Grams Tests
Impala
7B485
LG-4
2200cc
to Charcoal
.04+.69=.73
1
V-8/4 Bbl.
Ai r
CIeaner
Monza
7H582
LG-3
2500cc
to Charcoal
.25+.7S=l.04
1
V-3/2 Bbl.
Air
CIeaner
(Outside engine
compartment)
Chevette
7T099
1Y-5
ISOOcc
Cani ster
.57+.56=1.23
2
L-4/1 Bbl.
15G0cc
and Charcoal
.45+.50=.95
1
Ai r
CIeaner
1500cc
to Charcoal
.23+.48=.71
3
Air
CI eaner
Corvette
7Y065
L-43
2500cc
to Charcoal
.20-1.17=1.37
1
V-8/4 Btjl.
Ai r
Cleaner
Pickup
7C302
L5-9
2500cc
to Charcoal
.82+1.53=2.35
2
{2x20
V-8/4 Bbl.
Air
CIeaner
gal)
350 CID
Suburban
7C515
LF-3
2500cc
to Charcoal
.60+2.25=2.85
1
w>
(AO gal)
V-8/4 Sbl.
Air
CIeaner
454 CID
-------
Olchmobilc Developing' 1 Test Date
The attached tcbles illustrate recent efforts ot Oidsmobile Engineering to achieve
minimum levels cf evep. emissions cs measured by the SHED technique (1978
Federcl test). Target emission levels for such development work are 1.0 to 1 .2 g
for a system which might quclify for a 2 g certification stcndcrd.
All listed date include non-fuel background HC emissions; background levels were
not measured separately except for the 260 "B" ccr which showed less then 1/2 g
background. Test ccr age ond mileage in all ccses were adequate to assure a
level of background emissions typical or certification ccrs, i.e., less than 1/2 g/test.
This is confirmed by the similarity of the "bese car" data with similar 1978 cerrificc-
tion cars. It should be noted, however, thct the latter four cars of the following
comparison had carburetors selected for flatness of air norn-fo-bowl costing joint
surfcces end sealed accelerator pump sncfts.
SHED Evcp., g/1 est
Cor
260/2 B
350/4 C
403/4 C (Calif.)
403/4 E
403/4 E (Calif.)
Attached Dctc
3.67
3.14
3.50
4.99
3.14
4000 Mi.
Cert. Data
1 .86-5.79
2.23-5.93
3.26-4.60
2.13-2.16
Vehicle modifications tested (detailed below) ore experimental simulations of
possible production changes. They have not been evaluated for durcbiliry, safety
or other possible side er'fecrs. Improvements shown may or may not be achievable
with production hora'ware. „
Seeled Air Horn (403/4 E car)
Sealed Accelerator Pump end
Idle Needles
Semi-Sealed Throttle Shafts
Sol Op Door A.C. ond
Trcpc'oor A.C.
Chcrcccl Air Cleaner
(403/4 E Car)
Air Horn epoxied to Eowl Casting
Pump Shaft ond Idle Needles seeled
with epoxy (pump inoperative)
Clecrcnce filled with silicone lubricant
Solenoid cperctec' cover c'oor for
air clecner snorkel
Annulus between air filter element
end air clecmer housing filled
with chcrcccl crcnules
_Q-
-------
full Height AC Clement
Half Height AC Element
Canister Vented to Air Cleaner
1500 cc Con.
2200 cc Can.
2500 cc Can.
Bo Jed charcoal ring insie'e filter paper
jnd integral with filter element
Same except chcrcocl ring "covered" only
lower half of filter paper
Bottom of charcoal canister (filtered vent)
closed and bottom of canister (charcoal
charge) venred to eleen sice of engine
air cleaner, either lid or base of housing
1978 Production Charcoal Canister
Experimental Canister Containing 22C0 cc
of charcoal
Experimental Canister Containing 2500 cc
of charcoal
-------
MINIMUM EW. EMISSION DEVELOPMENT TESTS
OLDS 403/4 E
GRAMS FOR TOTAL
TEST
4.99
3.27
1.84
1.44
1.26
5 U'rf/ rrnrs/v.'/ 503
11/2/77
0
<
•v/
SEALED ACC.
CANISTER
SEALED
PUMP £
SCMI SCALED
SOL
OP
CHARCOAL
VENTED TO
CARB
AIR HORN
IDLE f.'EEDLES
THROTTLE SHAFTS
DOOtt
A.C.
A.C.
AIR CLEANER
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
EVAP. ErUSS[Oi1! OEV: LCPMENT TESTS
OLDS. B WITH 260/2 FED
TEST COMPONENTS RESULTS
CANISTER
1500 cc 2500 cc FULL HEIGHT HALF HEIGHT TRAPDOOR VENTED TO GRAMS FOR
CAN CAN AC ELEMENT AC ELEMENT AC AIR CLEANER TOTAL TESTS
Lid Base
X 3.656
X X 1.371
X X 1.450
X X 1.976
X X X 1.237
X X X 1.25a
x X X 1.335
X X X 1.420
X X X 1.576
SWM/rir,n/w/657
1/2/77
3-2
-------
MINiriUM EVAP. EMISSION D£';CLOP'-'E?IT TESTS
OLDS. C WITH 350/4 FED
TEST COMPONENTS , RESULTS
o CANISTER
: 2200 cc 25G0 cc FULL HEIGHT HALF HEIGHT TRAPDOOR VENTED TO GRAMS FOR
CAN CAM AC ELEMENT AC ELEME'IT AC AIR CLEANER TOTAL TESTS
Lid Base
3.138
X 2.214
X 2.163
X X 1.2S8
X X 2.QS9
X X 3.062
X X 1.364
X X 2.077
X X 3.273
X X 1.890
X X X 1.439
3-?
-------
MINIMUM EVA?. EMISSION DEVELOPMENT TESTS
OLDS- C WITH 403/4 CAL
TEST COMPONENTS RESULTS
CANISTER
500 cc FULL HEIGHT HALF HEIGHT TRAPDOOR VENTED TO GRAMS FOR
CAR AC ELEMENT AC ELEMENT AC AIR CLEANER TOTAL TEST
Lid Base
X 3.496
X X 2.1 AO
X 2.065
X XX 2.161
X X X 3.506
V.'M/ r~n/vj/730
1/2/77
-------
7
MINIMUM EVAP. ''V'SSIOM CF'.'ELOfTENT TESTS
OLDS. E WITH 403/4 CAL
TEST CO:iPOME:iTS RESULTS
CAM ISTcR
1500 cc 2200 cc 2500 cc FULL HEIGHT HALF HcICHT TRAPDOOR VESTED TO GRAMS FOR
CAN CAM C-VI AC ELEMENT AC ELEMENT AC AR CLEANER TOTAL TEST
Lid Base
X 3.135
X X 2.289
X X 2.533
X X 2.634
X X X 1.676
X X X 1.910
X XX 2.055
X X 2.5C9
X X X 2.907
X X 2.497
X X X 2.159
X X 3.393
SW;yrrVW
-------
datc,' 11'1'1 1 y i> • 1 v
suoject MccLliii*, / x L t i General Motorr. (CM) Corn in tag CM' h Pro^rcs'. in
l)u veloprag J fji L — I J*j ty "lu ck Cvnporat , i- Contiol Sys I ci.is Lor the
Proposed 2.0 g/test Standard
FROM
General Motors (GM) representatives requested a meeting with ECTD to
inform EPA of GM's current status in developing light-duty truck evap-
orative control systems aimed at a 2.0 g/test standard. The meeting was
held at the EPA Ann Arbcr facility on January 19, 1973 and CM repre-
sentatives attending were Louis Taix (Chevrolet), Gerald Barns (EAS),
Stu Martens (CAS) and Roger Lundquist (Qldsmobile). EPA personnel
present were John Dci
-------
the arrounc or activated carbon vas '".uficiont to adequately adsorb the
vapors discharged to the canister(s-! from one hoc soak and out diurnal.
Consequently, it appears that one of two mechanisms (or a combination of
Lhe tvo) accounted for the high measured hot soak emissions. One is
that the activated charcoal did not purge sufficiently on the FTP to
make it capable of adequately absorbing the vapors discharged to it
during the following hot sock. The other possible reason is that during
the hot soak a substantial amount of the vapors Much were generated
escapea from Lhe fuel system (e.g., carburetor fittings) without being
transported to ihe charcoal beds.
Since truck-like vehicles do more work on the FTP than typical passenger
cars, it is expected that these vehicles also have greater canister
purging than passenger cars. Consequently, it seems unlikely that in-
adequate canister purging was the cause of the relatively hign hot soak
losses on the pickup trucks, van and suburoan Induction system leakage
appears lo be the more probauie mechanism. The likelihood that in-
duction system leakage reaLly is the source of the hot soak emissions
is also consistent with the fact that gasoline float-bovl temperatures
are higner for these vehicles than for typical passenger cars, and,
therefore, more carbureLor vapors arc generated.
cc: J DeKany
C. Gray
R. Kruse
5-13
-------
UNITED STATES El V IRONfcENTAL PROTECTION AGENCY
OAre ;ijrcn 22, 1973
subject Dlscussiots '-ten Fard Votor Cor.par./ and Chrysler Corporation Corcemir.g
tha Feasibility of Controlling Evaporative Emissions froui Ligrt-Di^v
Trucks (0-5500 lbs GV^K) co a 2.0 g/cesc Standard for the 1981 >'oc^ i Year
In Che past two rior.ths, 1 nave twice contacted Ford :i)Cor Corraany
rGprasencs.t;i%a Eon Euist (Executive Engineer for Cemf•.la^ion) re-
garding Ford's effores and concerns relative to 19S1 -race! ^aar 12-
planencation of the oroposad 2.0 g/test evaoorative e-iiss:on scandara,
specifically for lignt-cuty trucks (LDT).
In a phone conversation vith J1r. auist on Faoruary 6, 1978, he stated
Chat control of evaporative emissions cron L3X was nc c greatly cirferetc
than controlling evaporative cnission ilroT U3V. Mr. Suist saia that
controlling emissions froc LDT equipped with optional higr. capacity fuel
tanks was sone'jnat nora difficult cran passenger car control, and oacaasa
of this they plan to use tvo charcoal canisters on LDTs ecui^med with
those larger fuel tanks, tfe seated cnat tests snow that ciurnal emissions
can typically ce controlled co less than 0.5 g/cese, ev.-»n for large fuel
capacity systans; and cue greatest source of UC loss, as vicr passenger
cars, is caroaretor leakage during the hot-soak tests. Mr. Suisc stated
that if trie proposed 2.0 g/test star.aard is proniul^atec for t~.c 1981
nocel year, Ford intends to certify their LDTs, ooth standard capacity
and optional hign capacity fuel sjstens, to that requirement.
On March 14, 1973 I a^air. called Mr. 3uist and asi-.ed hit: if, since I
had last discussed LDT evaporative con>;r:l vich in-n, Fore hac oocamed
any nev test cata or if he had any new views on che iubiecc. He stated
chat they r.sd not condjcted any ne*v tests, ana his position regarding
LDT evaporative cnission control rud not chaagea.
In surrary, if promulgated for t.ne 19S1 nclei year, Fore intends to
conply vith tie proposed 2.0 g/test evaoroative emission standard for
LDV anc LDT (standard and Che optional r.ign capacity fuel systems).
On Marca 14, 19<8, I talV.eu to Chrysler Corporation representative
Cordon Allarcyce (emissions Planning Specialist) concerning LDT evaporative
cortrol. I asked him for anv dcveloprrent data or information tn^y had
regarding cortrol of LDT evaporative emissions to below 6 g/test, especially
large fuel cfpnci ty svscct.s. tic stated chat the/ have roc done a lar.-;e
amount ot sacn testing ai^ed at tne 2.0 g/c?sc level of control, dj: re
would asse-ale -V.ac in fona cio-r. they die nave and sir.c it to us..
cc: R. ;'.rjso
TO
;[ec.orar.du.- co the File
THRLf: Charles L. Gray, Chi.ar, SD53 r
c>> fssi ijm-3 pe'v 1 :s
B-w
-------
ILiy 13, 1973
Meeting with General Hotors in Regard to Evaporative Erdsbion Standards
for Trucks
I'dchael W. Leifenan, SDSB
1
-------
f'£-1359
[fivrfonfifiijl Ac.initio* Srotl
GC'iip/o) mows Cotfio. ation
Ccit-rai Moles Tuci>ihc;jl Ccnlci
y/j/rsn Michigan 480SQ
May 12, 1973
Mr.. Charles Cray
Acting Director
Emission Control Technology Division
U.S. environmental Protection Agency
?.-j65 Plymouth Read
Ann Arocr, HI 48105
Dear Mr. Grey:
On Apr1I 10, 1973 we submitted to Mr. Stork a "PetiLion" for considera-
tion of a set of graduated evaporative emission standards for truchs.
V;e explained in that submission our concern for the inequity of impos-
ing passenger car evaporative emission standard on trucks over C0C'J,r
GVW--C1S currently proposed by CPA. We also provided detailed technical
support for o
-------
Mr. Charles Gray
May 12, 157C
The attached data support the appr jpriateness of graduated truck stan-
dards begilining at the passenger car level in the case of light trucks
increasing by 1 g/test for medium trucks (6,0C0 to &,500-r GVW) and by
2 g/test for heavy trucks (above 8,500? GVW). However, these aata also
strongly suggest that such a schedule of truck standards based on a
passenger car level of 2 g/test may well exceed our present capabil-
lty--particu1arly for the heavy trucks.
It will be seen in the attached data and associated notes that passen-
ger car experience is being applied to trucks in our attempts to
achieve minimum evaporative emission levels, e.g., larger carbon canis-
ter, "sealed11 carburetors, and carbon air cleaners. An additional ap-
proech in the truck work has been the substitution of steel tubing for
a substantial amount or'rubber fuel hose (our April 10 submission
mentioned the recently discovered problem of hose permeation). it
should be noted however, that some of the rubber hose replacement ac-
complished for these laboratory tests probably represent greater hose
elimination than could be accomplished in a production'design.
The notes associates with several test vehicles indicate that two "full
high" carbon air cleaner elements were used. In these cases, two car-
bon containing air cleaner elements v/ere stacked vertically requiring
increased air cleaner height, This expedient attempt to improve tju
performance of the air cleaner through the incorporation of additional
carbon is shown to be disappointing.
The data shown for the t.-,o hea'/y duty "Cab Chassis" support the posi-
tion of our- April 10 submission that an equitable standard for ngrn ve-
hicles would be substantially higher than for a "passenger car or for ,i
liglu truck because of the substantially higher uncontrolled w.is: ion-,
from hectvy trucks. Again wH emphasize, as m the April 10 run.;: ir,: ic.i,
the cited uncontrolled cat a ao not include running losses and rb'.'ivfore
understate the actual uncontrolled emission levels on these vehicle..
Limitation of the avail aole test facilities^also acts to und^rsl'.l*
evaporative emissions from these veinc 1 es—boih controlled ar.!
uncontrolled. Ir.emz weight and 50 mph Road Load Power sei:.,M!S ¦¦f*
limited to 8700 los. and 40 hp — substantially below those or ¦'•i- ¦- <
"Recommended Practice.'1 "Ihe higher dynamometer loadings '"ll|; ¦
required by th* EPA procedure would increase engine load arJ :-v
very likely increase hot soak emissions.
It is '..'all also cc inject a note of can Li on regarding the !
emission measurements for the second Cab Chassis vcmcle •
hot soak emissions measured for the uncontrolled condition ¦"
hide appear unreali stickily lev,' at 5.4 g. Tins is a :1 ' i
lower level "than one would expect for the carburetor 1
and represents a single test value. Confirmatory and pr-1- • ' • ¦,
tic testing would be required defore that value could t»'
t rv 1 y rep re s e n t c 11 ve.
B-/?
-------
Mr'. Ciurlcs Of ay
3
May 12, 19/C
Again we submit these da La for t! -; edification of EPA in its current
deliberations, tic believe they . 11usLrate quite dramatically the rea-
son fcr our concern v/i th the proposed extension of a 2 y/test--or even
a moderately higher—passenger car standard to all trucks.
Sincerely,
T. M. Fisher, Director
Automotive Emission Control
4SWM/0504/1
cc: M. P. Walsh
R. E. Kruse
a
-------
CrNEPvU M070KS
TEUCK f.VAPQRAli ¦'£ [AMISSION PLVilOPMENT SUMMARY
MAY 1 , 1978
Vehicle: • GC07 8 - Pickup, Class: Light D"ty
Ert.inr:: 350VS-quhJ (Paadrajot:) , Fuo : tank: 20 gal (oasc)
Control System. 2500cc Canister, vented to parfci.il mgn
carbon air cleaner, carburetor seals one bowl
vent to canister,- 40" less rubber fuel hose
Evap Lnissions: 3 Test average
.31 diurnal + 1.21 hot soak = 1.55 grans
Vehicle: 7 ? C 3 0 2 - ? ickiro , Class: Light Duty
Engine: 3~j u V 3 - a"b ] (Quad ran d bos-I vent
to canister
lamp l.mssions' 3 Lest average
.40 diurnal + .96 hot soak = 1.36 grars
Vehicle: Pic'; , Class- T.irht Put/
Knyme. 250LG-'^bnl (Vara ict) , Fuel TanV /0 gal.
Contiol System: 2:>00cc canister, carburetor seals c.->a bawl
vent to canister
Evap Emissions: 2 test average
.92 + .90 = 1.82 grams (unsaturated)
Vehicle: !¦ 8C2 2 8-?ici:up , Class: Ligrt Duly
Engine: 2?0L6-^.)':>1 (''arajet) , Fuel Ta : 2P ral.
Control system-
2500cc Canister
1500cc Canister
(similar to 79
production)
Note Light Duly mcens trucks \,ndcr 6C0Q" GV'Yf.
Canister as noted, carburetor seals and bowl
vent to canister
1.00 + = 2 . -1 presaturated
.65 + 1.50 = 2.15
.43 t 1.40 = 1.30 unsaturated
.GO 1.05 - 1.65 presaturated
.70 + 1.10 - 1.30
&-20
-------
Vehicle: ir 8G 2 G 2 Utility Van, Class: Liaht Duty
Engine TOQVti-^b'j L (Quadrant) , Fuel
Control System: 2500cc canister vented
i'ink. 3 3 gal.
o full high carbon
cleaner, carburetor sealb and bowl vent to canister
modified fuel hoses.
1979 Pioduction
PI limb j ncj
72" less fuel
hose
•13 + 1.90
90 + 2.30
2 . 30
3 .20
.47 + 1.60 = 2.07
2,7 9 Average
Vehicle: i'7C515 - Suburban, Cla^s: i'eriium Dutv
Engine: 4 OQ'/8-''bn3 (Quodraiet) , Fuel Tank- 2 5 cal.
Control System:
Evao Emissions:
2500cc-canister vented to partial nigh carbon ai;
cleaner, scaled carburetor and bowl vent to cam:
2 Test average
.76 + 1.77 = 2.53 -grams
Vehicle has 75 gram/test background
Vehicle: '' 6C10 j-Suburban , Class:
Zr.cj inc.
Medvun Duly
00.ee canister vented to air cieaner with t\.o fu.l
high carbon elements, carburetor seals and do ;1
vent to canister, 32" less rubber fuel hose
Lvap Emissions. .55 + 1.75 = 2.30 2.60 Gram Ave;
.80 + 2.10 = 2.90
/Ci tl c
Vehicle:
Engine.
Control
7C5S-Pickuo , Class: Mediun Duty
'oIVG-'I'.jdI (Qi.adrn-jct) Fuel Tank:
;c canister vented to air cleane
System: 2j00
Dual 20 gal =
'0 a
a 1.
Uvap Emission:
i JUUCL l_.il! Li HJI VtlUSU LU ci J. i tieantii with
high carbon elements, carburetor seals and bo-./l
vent to canister
\.o full
.53
. 5 5
. G5
. 73
95
37
72
20
= 2.53
= 2.92
= 3.37
= 2.93
2.9') Average (Unsaturated)
Nofe. Light Duty means trucks under 6000^ GW,'. Medium Duty means trucks
between 6000;/ end 8500' GW,
B-2(
-------
Vehicle: !ifiC532 PiciU'j, CI. s:
Cnqinc
3 5ilVS-A obi (Ouaar. ct)
Medmn Dusty
, Fuel Tank:
Control System:
Evap Emissions:
presaturatod
Dual 20 gal = 4 0 qa 1
2500oc Canister vented to air cleaner with t*>o
fuj 1 hign carbon ele.nsr.ts, sealed carburetor with
bo^l vent to canister
.25 + 1.93 = 2.93
1.20 + I.S3 = 3.03
. 79 + 1.53 = 2.37
2.77 average
not saturated
-2 + 1.75 = 2.17
71 + 1.59 = 2.3 0
2.24
¦14 average
Vehicle: 7C508 Plcar>, Class: E-iodiurr. Pi'ty
Ungine. f, 5 4 V ft -' o j I I On a d r a i e t) Pud Tan.-;
Control System:
Evap Emissions:
^ ^ 0 ra 1 - 'J <' a 1
Ca:ustcrs - see oelo^, carburetor seols and ioTl
vent to canister, tv/o full hig'" carbon demerits
ii: sir cleaner
25O0cc
Canister.
.52
.60
>
+
1. 87
2 . 35
_
2 . 39
2.95
2.67
unsaturated
1.20
+
2. 14
-
3. 34
presaturated
Triple
Canj. sLcrs :
150Qcc oa tank
. -5 7
. ' 1
+
+
2 .09
2.10
=
2.56
X . 7
? . <14
unsa turated
S50cc to carb
. 5 B-
+
1.45
=
2 . 03
1. 30
+
1. 82
—
3.12
prcsa turated
Fuel hoses short
eiad
69
If
2 50 0cc Caaister
. G "t
+
1.57
=
2.2\
unsaturated
triple Canibter
. 79
+
1.70
=
2.49
unsaturated
Vehicle. !''I'0333 - Ob Chassis, Class- Kcfl_vv_natv
Engine. 7; 2 7 V G - o i "l (: -o 1 lc y ] , Fuel Toni-"*: ^ 0 = 130 q -a * s
Control System: Dial 1500cc canstors, dual bowl vents uo second
canister
Evap i in i sicp..
Uncor.Lioiled 52.3 3 ¦+ 39.1'; - 91.19 gcarr-3
Controlled I. 9 1.1G = 5.B5
Vcniclc. ,'IT3 30 9-Cr.b Chassis, Class: Koavy Dutv
r.n^i.'.c*. 3'jJ";S - /sol, ruc-L Tcir.k s: Dua I 50 = 10 0 gals
Control Si'stcv D'-izl 1500cc canister, r^owl vo.it to second ca.ustor
Cvap i iiUbsions
UncC'L-, Lro3 lc«J <9.50 + 5.'ii"> = 5'*. 90 c.rsms
Controlled 3.10 + 1.3 8 = -1. <3 8 "unsaturated
Note lAodiurn Dufy means trucks bsiwjcn 6000' end S500J GV\V. Hoavy DjJ-v
------- |