DRAFT
REGULATORY ANALYSIS, ENVIRONMENTAL IMPACT
STATEMENT and NOx POLLUTANT SPECIFIC STUDY
for
PROPOSED GASEOUS EMISSION REGULATIONS FOR
1985 AND LATER MODEL YEAR LIGHT-DUTY
TRUCKS AND 1986 and LATER MODEL YEAR
HEAVY-DUTY ENGINES
PREPARED BY
OFFICE OF MOBILE SOURCE AIR POLLUTION CONTROL
APPROVED BY
J L ''..
3el P. Wtflsh, Deputy As si
* «« M nk 1 1 r> C/MI W *¦» A • aa n ^ 1 1
MicFrfel P. W^ish, Deput^JTAssistant Administrator
for Mobile Source Air Pollution Control
DATE:
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DRAFT
REGULATORY ANALYSIS, ENVIRONMENTAL IMPACT
STATEMENT and NOx POLLUTANT SPECIFIC STUDY
for
PROPOSED GASEOUS EMISSION REGULATIONS FOR
1985 AND LATER MODEL YEAR LIGHT-DUTY
TRUCKS AND 1986 and LATER MODEL YEAR
HEAVY-DUTY ENGINES
PREPARED BY
OFFICE OF MOBILE SOURCE AIR POLLUTION CONTROL
APPROVED BY
Michael P. Walsh, Deputy Assistant Administrator
for Mobile Source Air Pollution Control
DATE:
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IMPORTANT NOTICES
After the completion of this document, EPA found it neces-
sary to change its approach to this rulemaking in several ways.
First of all, what had originally been planned as a Notice of
Proposed Rulemaking (NPRM) has now been changed to an Advance
Notice of Proposed Rulemaking (ANPRM). Second, the effective model
year for heavy-duty engines was changed from 1985 to 1986.
Third, we do not anticipate proposing the 75 percent reduction LDT
NOx standard of 0.9 g/mi; instead, we expect to propose a standard
of 1.2 g/mi, representing equivalent stringency with passenger
cars. Finally, we have developed an alternate heavy-duty NOx
emission level of 4.0 g/BHP-hr, representing the general range to
which we expect to revise the statutory heavy-duty standard.
None of these changes are reflected in this document. Thus,
for example, this document refers to the rulemaking action as a
proposal rather than an advance notice. The ANPRM goes into some
depth about the changes and discusses briefly how the analyses will
change if they are redone using the more recent numbers. Briefly,
the primary effects of delaying the model year of compliance for
heavy-duty engines are to provide an additional year for capital
accumulation and electronic control system development. In the
probable event that the final LDT and HDE standards are set at
levels above the 75 percent reduction levels, the air quality
benefits computed in this document will decrease proportionally.
The impact on costs varies among the vehicle/engine classes.
Light-duty truck costs will not change greatly since three—way
catalysts are likely to be used anyway. Heavy-duty gasoline engine
costs will depend on whether three-way systems are necessary at the
revised NOx level, dropping substantially if less expensive systems
are pursued. And finally for heavy-duty diesels, the costs cal-
culated here are actually valid for the 4.0 g/BHP-hr range, since
that level seems to be the limit to HDD NOx control without sub-
stantial loss of fuel economy.
Revisions to this document have not been made at this time
because of both the early stage of rulemaking represented by an
ANPRM and the general usefulness of the document as it stands.
During preparation of our NPRM, all needed revisions will be made.
This document constitutes a draft for the Regulatory Analysis
required by Executive Order 12044, as well as the Economic Impact
Assessment required by Section 317, and the Pollutant Specific
Study required by Section 202 of the Clean Air Act as amended.
This document also contains an Environmental Impact Statement
and an Urban and Community Impact analysis.
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TABLE OF CONTENTS
Page
I. Introduction and Summary of the Regulatory
Analysis 1
A. Introduction .... ...... 1
B. Summary 3
II. Description of the Product and the Industry 10
A. Light-Duty Trucks 10
B. Heavy-Duty Vehicles 31
III. Technological Feasibility 59
A. Low-Mileage Emission Targets 59
B. Heavy-Duty Gasoline Engines 59
C. Heavy-Duty Diesel Engines 72
D. Light-Duty Trucks - Gasoline 80
E. Light-Duty Trucks - Diesel 80
IV. Environmental Impact 82
A. Introduction 82
B. Health Effects 82
C. Welfare Effects 92
D. Baseline Emission Inventory 102
E. Emission Reductions 110
F. Air Quality Impacts 119
G. Potential Secondary Environmental Impacts ... 122
V. Economic Impact 133
A. Light-Duty Trucks 133
B. Heavy-Duty Engines 169
C. Urban and Community Impacts 203
VI. Alternate Actions 209
A. The Standard/The Standard Setting Process . . . 209
B. Durability Testing Procedures 213
C. Allowable Maintenance Provisions 214
VII. Cost Effectiveness 215
A. Introduction and Summary 215
B. Overall Proposal ..... .... 215
C. Allowable Maintenance 217
D. In-Use Durability 218
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Chapter I
INTRODUCTION AND SUMMARY OF THE REGULATORY ANALYSIS
A. Introduction
1. Background
Heavy-duty engines (HDEs) and light-duty trucks (LDTs) were
both subjected to recent EPA rulemakings. On January 21, 1980 the
final rules for the control of heavy-duty engines emissions (HC and
CO) were published (45 FR 4136). A similar rulemaking addressing
HC and CO emissions for LDTs was published recently as well (45 FR
63734). These two rulemakings are the initial response of EPA to
portions of the 1977 Amendments to the Clean Air Act (CAA) which
dealt with "heavy-duty" vehicles and engines. The amended CAA
called for regulations that would realize a 90 percent reduction in
hydrocarbon (HC) and carbon monoxide (CO) emissions from heavy-duty
engines and LDTs, as compared to pre-controlled gasoline emission
levels. The two rulemakings fulfilling that mandate are to become
effective for 1984 LDTs and HDEs. The CAA also called for estab-
lishment of a NOx standard representing a 75 percent reduction
from pre-controlled levels. That requirement is the subject of
this proposal.
Several changes in the way that LDTs and HDEs are certified
and a new heavy-duty test procedure were also introduced in the two
recent rulemakings. Two of these changes, the redefinition of
"useful life" and the restricting of emission-related maintenance,
are incentives for manufacturers to place new emphasis on the
durability of emission control systems. Also, engine parameter
adjustment rules, previously applicable only to light-duty vehicles
and trucks, were expanded to cover heavy-duty engines and hence
encourage the design of tamper resistant engines in that class as
well. These new regulatory provisions are accompanied by new
production-line auditing methodologies, requiring virtually all
LDTs and HDEs to comply with the standards as they leave the
factory. Finally, a shift to a "transient" heavy-duty test pro-
cedure will allow a better laboratory representation of on-the-road
emissions. Taken together, this combination of new and revised
regulatory approaches improves the effectiveness of EPA's mobile-
source emission control program and helps assure the statutory 90
percent reductions in HC and CO will actually be achieved.
2. Overview of the Rulemaking
The current proposed rulemaking is another step in EPA's
compliance with its mandate under the 1977 amended Clean Air
Act relating to motor vehicle gaseous emissions. The main features
of the proposal are new standards for the control of oxides of
nitrogen (NOx) emissions, one for light-duty trucks (LDTs) and one
for heavy-duty engines (HDE$). For LDTs, the proposed standard is
0.9 g/mi; for HDEs, 1.7 g/BHP-hr. These standards represent the 75
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percent reduction called for by the CAA. (NOTE: As stated in the
Notice at the beginning of this document, the final form of the
proposed standards differs from the earlier form described in this
paragraph.)
The rulemaking proposes a program for implementing 1) the
remaining aspects of EPA's direct congressional mandate regarding
vehicles whose GVWRs (gross vehicle weight ratings) exceed 6,000
lbs., 2) two changes in the certification process which we pro-
posed earlier in a similar form but did not finalize, and 3)
several minor changes to the heavy-duty transient test procedure.
This package of requirements completes another stage in the com-
prehensive regulatory approach we began in the two recent rule-
makings. Following the completion of the forthcoming, heavy-
duty diesel particulate rulemaking, most aspects of the LDT and HDE
emission control program will be in place.
The "heavy-duty" class referred to in the 1977 amendments to
the CAA spans not only EPA's "heavy-duty engine" class but a
portion of our light-duty truck class as well. Thus, the per-
centage emission reductions mandated by Congress for vehicles and
engines which exceed 6,000 lbs. GVWR actually apply to EPA's
heavy-duty engine class (engines used in vehicles with GVWRs
exceeding 8,500 lbs.) as well as the "heavy" portion of the light-
duty truck class (LDTs between 6,000 and 8,500 lbs.GVWR).
Although the "light" LDTs (those below 6,000 lbs. GVWR) are
not covered by the mandate of §202(a)(3)(a)(ii) of the amended Act,
authority for their regulation is found in the general authority of
§202(a)(l). The 1980 LDT rulemaking invoked this authority to
establish the same HC and CO standards for the "light" LDTs as for
the "heavy" LDTs. Our justification for class-wide standards at
that time is equally valid in the context of these proposed NOx
standards.
In addition to new NOx standards, EPA proposes for LDTs and
HDEs two significant changes in the way vehicles and engines are
certified for production. One is a proposed program that requires
that service accumulation be accomplished by in-vehicle on-the-road
operation. The other requires manufacturers to give some indica-
tion that the maintenance they recommend to their customers will
actually be performed in the field. Both initiatives were proposed
earlier during the recent LDT and HDE rulemakings. (Those Notices
of Proposed Rulemaking are found in the Federal Register at 44 FR
9464 (heavy-duty) and 44 FR 40784 (light-duty truck)). The two
proposed actions were withdrawn from the rulemakings for further
consideration, and are reproposed here in slightly different
forms. EPA is also proposing maintenance intervals for electronic
engine controls plus oxygen sensors and related transducers.
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B. Summary
1. Organization of the Regulatory Analysis
This analysis presents an assessment of the environmental and
economic impacts of the heavy-duty engine and light-duty truck
(LDT) regulations EPA is promulgating. It provides a description
of the information and analyses used to review all reasonable
alternative actions before implementing the final rule.
The remainder of this statement is divided into five major
sections. Chapter II presents a general description of both
light-duty trucks and heavy-duty vehicles and engines, a brief
description of the manufacturers of this equipment, and the market
in which they compete. It also will discuss the uses to which
heavy-duty vehicles and LDTs are put, and describe the primary user
groups.
Chapter III discusses the technological feasibility of ob-
taining the 75 percent NOx emission reduction on heavy-duty diesel
engines, heavy-duty gasoline-fueled engines, light-duty gasoline-
fueled trucks and light-duty diesel trucks. Additionally discussed
are factors affecting the feasibility.
An assessment of the primary and secondary environmental
impacts attributed to the proposed regulations is given in Chapter
IV. The degree of control reflected by standards is described and
a projection of air pollution emissions for the national heavy-duty
vehicle and LDT population, with the standards in place through
1999, is presented. The impacts of these regulations on urban
emissions and the expected air quality benefits are considered.
Secondary effects on other air pollutant emissions, water pollution
and noise are also discussed in this section.
An examination of the cost of complying with the regulations
is presented in Chapter V. These costs include those incurred to
install emission control equipment on heavy-duty engines and LDTs,
the costs to certify, and any increased vehicle operating costs
triiich might occur. Analysis is made to determine aggregate cost
for the 1985-89 time frame. Finally, the impact that this regula-
tion will have on industry and consumers will be reviewed.
Chapter VI will identify and discuss the alternatives to this
rulemaking action, their expected environmental impacts, and the
reasons none have been proposed at this time.
Chapter VII will present a cost effectiveness analysis of this
rulemaking action, including an evaluation of the cost effective-
ness of the in-use durability and allowable maintenance portions of
the proposals.
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2. Chapter Summaries
a. Industry Description
i. Light-Duty Trucks
The light-duty truck industry uses both gasoline and diesel
engines and consists of five domestic manufacturers which together
account for 91.2 percent of the U.S. market and five foreign
manufacturers. All of the manufacturers, with the exception
of International Harvester, also produce passenger cars. The LET
market is dominated by GM, Ford, and Chrysler* who together account
for about 85 percent of sales. Imports are a small but rapidly
increasing fraction of the market.
Sales of LDTs in 1979 were about 2.9 million units. LDT sales
have beau increasing faster than sales of passenger cars over a
period from. 1974 ta 1978. Eowever, the growth rate 13 not expected
to be the same in later years and a decline in sales occurred in
1979. In the past two years energy availability and price has
affected the sale of LDTs, whose fuel economy is lower than LDVs.
Extrapolation of sales growth over the past decade predicts that
1985 sales will be about 3.5 million units. By 1989 sales will be
about 4.0 million units! light-duty diesel trucks sales are esti-
mated at over .75 million.
Vehicles in the light-duty truck class are mainly pick-up
trucks and vans used primarily for personal transportation. Those
produced by the manufacturers i^ich also produce passenger cars
share many components with those: cars. Emission control technology
used on passenger cars has generaLly been easily adapted far use on
light-duty trucks* This is expected to be the case in the future
.as we21.
ii. Heavy~Duty Vehicles
The "heavy-duty industry'1 discussed "here refers to that
collection of companies which manufactures the trucks, buses, and
engines found in on-the-road applications whose gross vehicle
weights (GVW) exceed 8,500 pounds. The rather complex picture
presented by the numerous manufacturers and their diverse product
lines is simplified aomewhat by the realization that only a few of
these companies are responsible for the bulk of the industry's
production.
General Motors, Ford, Chrysler, and International Harvester
(IHC) share over 99 percent Df the heavy-duty gasoline engine
market; Cummins Engine, Detroit Diesel, flack, Caterpillar and IHC
are the primary diesel engine producers. Only GM (including
Detroit Diesel) and IHC make both types of engines in significant
quantities.
Vehicles in the industry are produced in many configurationa
(single unit or tractor, gasoline or diesel, various a-xle arrange-
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ments and load capacities, etc.) by a number of manufacturers, but,
as with the engines, most vehicles are built by the largest pro-
ducers. GM (Chevrolet and GMC), Ford, Chrysler (Dodge), and IHC
make over four fifths of all U.S.-built trucks.
The applications of trucks to real world tasks vary widely
depending on load capacity, ranging from personal transportation
and agriculture, to construction, trade, and "for hire" uses. The
companies and individuals who purchase trucks and buses take
advantage of the diversity of available products and choose
vehicle-engine combinations which economically fulfill their
needs.
b. Feasbility
i. Heavy-Duty Gasoline Engines
The achievement of the full 75 percent reduction in NOx
emission is technologically feasible, in EPA's judgement, through
the application of three-way catalyst technology and certainly if
used in conjunction with oxidation catalysts.
Another factor affecting feasibility is the durability
of the three-way catalyst system. Technology for attainment
of the 100,000 mile durability of the major components (oxygen
sensors, catalysts, and feedback control loop components) must
still be developed. However, with a four year leadtime until
1985, the Agency believes that there wiLl be adequate time to
obtain in-use durability information to develop durable compo-
nents.
ii. Heavy-Duty Diesel Engines
EPA believes that significant NOx reductions are possible, but
the 75 percent reduction is probably out of reach for diesels. Two
options to achieve lower NOx levels (timing retard and EGR) are
tried and proven. However, fuel economy penalties may be asso-
ciated with substantial NOx reductions. Other technologies,
variable injection timing and electronic engine control, allow for
continuous optimization of the first two mentioned technologies and
other parameters to achieve effective emission and fuel economy
per formance.
iii. Light-Duty Trucks - Gasoline
The light-duty vehicle standard for 1981 is very close to the
1985 LDT standard. Technology is already available on the market
to allow the achievement of the 1981 standard.
The prime candidate system will likely be a three-way catalyst
system with feedback carburetor and electronically controlled
spark timing. EGR and dual bed catalysts may be necessary on
larger GVW vehicles, but not on the majority.
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iv. Light-Duty Trucks - Diesel
Technology forcing development work on advanced methods of NOx
control as a result of waivers given to GM and VW for the 1981 LDV
NOx Diesel-Powered Vehicle Standards is already under way. This
development work may be applied to LDDTs in 1985. EPA sees
no reason why within the time frame of the standards that the
technology will not be developed.
c. Environmental Impact
Through compliance with the proposed standards, 1985 low-
altitude non-California vehicles will experience lifetime NOx
reductions of 0.19 ton, 0.92 ton, and 7.82 tons for LDTs, HDGEs,
and HDDEs, respectively, as compared to 1984 vehicles. On a
percentage basis, the reductions are 59 percent for LDTs, 77
percent for HDGEs, and 79 percent for HDDEs.
Currently, the ambient NOx problem is somewhat localized;
only a few air quality regions exceeded the ambient NO2 stan-
dard in 1976. It is crucial to realize, however, that the growth
of NOx emission sources, especially in the absence of these
regulations} will cause a substantial increase in NOx emissions
over the next decades. The recent association of NOx emissions
with acid rain, as weLl as the other health and welfare implica-
tions of ambient NOx, speak to the need to minimize the growth in
NOx emissions.
Nationwide emission reductions are important from the stand-
point of welfare effects, such as damage to materials, visibility,
and acid rain. The per-vehicle reductions estimated above trans-
late into a 12 percent reduction in nationwide NOx emissions
¦which would otherwise occur by 1999.
On the other hand, the impact of the proposed regulations on
urban air quality is best analyzed by looking at the specific
regions that already have high ambient NO2 levels. These pro-
posed regulations should produce an approximately 30 percent
improvement in average air quality for NO2 by 1999, compared to
what would otherwise occur. Using 1976 as a base year, our anal-
ysis of these regions indicates that the change in the average
NO2 air quality by 1999 should range between a net decline of 6
percent to an improvement of 22 percent, depending on the extent of
growth. In the absence of these regulations, there would be a net
loss in air quality regardless of growth rate.
d. Economic Impact
i. Light-Duty Trucks
The five major costs to the manufacturers consist of research
and development, emission control hardware, certification, in-use
durability testing, and allowable maintenance.
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Users of light-duty trucks can, as a result of the proposed
regulations expect to pay an average increase of $153 over 1984
light-duty trucks (1980 dollars). Operating costs of light-duty
diesel trucks may increase if losses in fuel economy occur ($75 for
every one percent change in fuel economy). Conversely, operating
costs of light-duty gasoline trucks may decrease due to slight
improvement in fuel economy.
The aggregate cost to the nation of complying with the pro-
posed 1985 Federal LDT Emission Regulations consist of the sum
increased costs for development, new emission control hardware,
certification, in-use durability testing, and compliance with the
allowable maintenance provisions. The aggregate cost of complying
with the new regulations for the five-year period (1985 to 1989) is
equivalent to a lump sum investment of about $2.4 billion (1980
dollars).
ii. Heavy-Duty Engines
The five major costs to manufacturers consist of research and
development, emission control hardware, certification, in-use
durability testing, and allowable maintenance.
The expected average first price increase for a heavy-duty
gasoline-fueled engine is $284 and $741 for heavy-duty diesel
engines. Both figures are in 1980 dollars. Operating cost changes
should be slightly decreased for gasoline-fueled heavy-duty engines
as a result of improved fuel economy. An increase in operating
costs could occur for heavy-duty diesel engines if a fuel economy
penalty occurs ($638 for every one percent change in fuel economy).
The aggregate cost of complying with the new regulations for
the five-year period (1985 to 1989) is the equivalent of a lump sum
investment of about $1.98 billion (1980 dollars).
e. Alternatives
Alternatives considered in the development of the regulation
are primarily in the areas of the standard, durability procedures,
and allowable maintenance provisions.
i. The Standard/The Standard-Setting Process
The Clean Air Act Amendments of 1977 gave EPA the authority to
establish new NOx standards, and directed that these be established
by specific methodologies. The scenarios presented are not mutual-
ly exclusive; they represent parts of the overall derivation
methodology. They are broken down here for illustrative purposes:
1) Scenario 1 portrays an immediate and permanent standard
derived from at least 75 percent reduction from the baseline
levels. (This scenario presumes technological feasibility and no
standard changes per 202(a)(3)(E).)
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2) Scenario 2 portrays an initial relaxation of the 75
percent standard to a revised level. This revised standard must
reflect the maximum reductions achievable with available tech-
nology. Incremental increases in standard stringency can occur at
three year intervals, again to the limits of available technology,
until the full 75 percent reductions are achieved.
3) Scenario 3 portrays a change from either the 7 5 percent
reduction, or from the lowest standard achievable by available
technology. This change may be made in 1980 and every three years
thereafter, based upon data pertaining to the health effects of the
-applicable pollutant and their relationship with the level of the
standard. The wording of the law is ambiguous (perhaps inten-
tionally) to the extent that the direction of the change in stan-
dard (i.e., upward ar downward) is not specified.
ii. Durability Testing Procedures
Alternatives considered to the durability test procedures used
to determine deterioration factors (CFs) for LDT and heavy-duty
engine (HDE) family certification involve three options. These
options are 1) use the current 1980 procedure, 2) carry-over the
procedures from the 1983 LDT FRM and the 1984 HDE FRM, 3) adapt a
previously proposed program (1984 HDE NPRM) that contains an in-use
durablity procedure to determine DFs.
The current 1980 regulations include a test track procedure
for LDTs and a dynamometer procedure for HDE's. The Agency be-
lieves that the dynamometer test and test track procedure are
simplistic and not representative. The 1983 LDT and 1984 HDE FRM
allows the manufacturer to determine their own DFs providing that
any testing used simulate real-world emission deterioration.
However, there is no mechanism to verify the manufacturer's sub-
mitted DF. The final alternative, adaptation of the previously
proposed durability program, would allow the manufacturer to
determine a "preliminary" DF until an updated DF is obtained from
an in-use durability test procedure. This alternative is con-
sidered by the Agency to be more representative.
iii. Allowable Maintenance Provisions
Under consideration by the Agency are three basic options:
1) Follow the current 1984 heavy-duty engine FRM (i.e.,
exclude the demonstration of in-use performance provi-
sions). This alternative would offer no assurances that
critical in-use maintenance will be performed, and would
present a risk to air quality.
2) Include the in-use performance provisions as written in
1983 heavy-duty vehicle and light-duty truck NPRMs so
that the industry must demonstrate the likelihood of
in-use maintenance. This alternative raises legal
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questions pertaining to EPA's authority to make the
manufacturer responsible for in-use performance of items
not designed exclusively for emission control.
3) Modify alternative above so the "non-critical emission-
related maintenance" be excluded from the requirements of
in-use maintenance demonstration. "Critical" items under
this redefinition would be items such as catalysts and
oxygen sensors. Exempted "non-critical" items would be
spark plugs, wires, hoses, etc. A greater assurance that
maintenance-related in-use emission deterioration will be
minimized is provided by this alternative and is well
within EPA's authority under the Clean Air Act Amendments
of 1977.
f. Cost Effectiveness
In the context of improving air quality, cost effectiveness is
expressed in terms of the dollar cost per ton of pollutant con-
trolled. An analysis of the cost effectiveness of the overall
proposal and the allowable maintenance/in-use durability proposal
elements are presented. In all cases, light-duty gasoline-fueled
trucks (LDGTs), light-duty diesel trucks (LDDTs), heavy-duty
gasoline-fueled engines (HDGs) and heavy-duty diesel engines
(HDDs) cost effectiveness are given individually.
The overall proposal has the following cost effectiveness for
NOx emissions: LDGT, $900/ton; LDDT, $276/ton; HDG, $326/ton.
Because of the apparent infeasibility of the proposed standard for
heavy-duty diesels, we did not calculated a cost effectiveness
number for them. Allowable maintenance provisions provide a net
savings for both HC and CO pollutants and a negligible reduction in
NOx emissions. These savings are : LDGT -$81/ton (HC), -$3/ton
(CO); HDG -$44/ton (HC), -$2/ton (CO). Diesels are unaffected
by the allowable maintenance provisions. Cost effective figures of
in-use durability programs are divided three ways for light trucks
and heavy-duty gasoline-fueled engines. These values are $7/ton
(HC), $l/ton (CO) and $lA/ton (NOx) for LDTs and $32/ton (HC),
$4/ton (CO), and $95/ton (NOx) for HDEs. Heavy-duty diesel
vehicles costs are divided two ways, $8/ton (HC) and $2/ton
(CO).
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CHAPTER II
DESCRIPTION OF THE PRODUCT AND THE INDUSTRY
Introduction
Light-duty trucks and heavy-duty vehicles present a very
diverse spectrum of functions, capabilities, and styles. Their
production is supported by large and varied industries. Their sale
and use are subject to a variety of influences. This chapter
outlines and describes these and other important considerations
with respect to LDTs and HDVs.
A. Light-Duty Trucks
1. Description of Light-Duty Trucks
a. Definition of Light-Duty Trucks
The light-duty truck (LDT) class includes all motor vehicles
which have a gross vehicle weight rating (GVWR) of 8,500 pounds
(3,546 kg) or less, have a vehicle curb weight of 6,000 pounds
(2,722 kg) or less, have a basic vehicle frontal area of 45 square
feet (4.3 square meters) or less, and which are: (1) designed
primarily for purposes of transporting property or are derived from
such vehicles, (2) designed primarily for transporting persons and
have a seating capacity of more than 12, or (3) are available with
special features enabling off-street or off-highway operation and
use. Heavier light-duty trucks are those with GVWRs greater than
6,000 but less than or equal to 8,500 pounds.
Initially, Federal regulations classified all vehicles with
GVWRs of 6,000 pounds or less as light-duty vehicles (LDVs);
vehicles with GVWRs greater than 6,000 pounds were subject to
heavy-duty engine (HDE) requirements. Beginning with the 1975
model year, non-passenger car vehicles with GVWRs of 6,000 pounds
or less were reclassified as light-duty trucks. This ruling
resulted in an increase in the number of vehicles certified with
GVWRs greater than 6,000 pounds, since these vehicles would then be
subject to standards less stringent than those applicable to the
LDT class. As a result of this migration, EPA expanded the LDT
class GVWR ceiling to 8,500 pounds, effective for the 1979 model
year. The above definition reflects this change.
The proposed emission regulations for 1983 and later model
year light-duty trucks contain a definition of what is meant by
the phrase: "special features enabling off-street or off-highway
operation and use." This is meant to include those vehicles
which: (1) have four-wheel drive, and (2) have at least four of
the following characteristics (calculated when the vehicle is at
curb weight, on a level surface, with the front wheels parallel to
the vehicle's longitudinal centerline, and with the tires inflated
to the manufacturer's recommended pressure): (a) an approach angle
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of not leas than 28 degrees, (b) a breakover angle of not less than
14 degrees, (c) a departure angle of not less than 20 degrees, (d)
a running clearance of not less than 8 inches, and (e) front and
rear axle clearances of not less than 7 inches each (see Figure
II-AM/
The automotive and truck industries have traditionally used
GVWR categories for vehicle classification purposes. Historically,
classes I and II have included vehicles with GVWRs between 0 and
6,000 pounds, and between 6,001 and 10,000 pounds, respectively-
For the purposes of this regulatory analysis, Class IIA will
include GVWRs from 6,001 to 8,500 pounds, and Class IIB will
include GVWRs from 8,501 to 10,000 pounds. Since all vehicle
production and sales data are still reported on the basis of the
traditional categories, an estimate must be made concerning the
percentage of those trucks with GVWRs between 0 and 10,000 pounds
which also have GVWRs greater than 8,500 pounds. Based upon
production data for recent years, EPA has estimated this percentage
to be approximately 5.5 percent. It is anticipated that this
figure will increase to roughly 13 percent in the next few years as
manufacturers re-rate some of their vehicles to GVWRs greater than
8,500 pounds in order to make them subject to less-stringent
emission and fuel economy standards.^/
b. Use of Light-Duty Trucks
Light-duty trucks are produced in a wide variety of body-types
encompassing a wide variety of possible functions. Virtually all
light-duty trucks have two axles and four wheels, and most are
equipped with gasoline-powered engines and two-wheel drive. A
small number make use of diesel engines, and an increasing per-
centage are equipped with four-wheel drive. From 1976 to 1978,
sales of LDTb equipped with four-wheel drive increased from 23.8
percent to 28.5 percent of total LDT sales.3/ The three largest
categories of light-duty trucks are, in order: pickups, vans, and
utility vehicles. Together, these categories comprise approxi-
mately 95 percent of all U.S. light-duty truck sales (see Table
II-A). The remaining sales include station wagons built on truck
chassis, passenger carriers, and multi-stop vehicles.
Pickups have an enclosed cab, with varying amounts of seating
and storage space. Behind the cab is an open, flat load-bed, with
a hinged rear gate. Pickups can be equipped with caps which
enclose the load-bed or with camper units of varying size. The
pickup category includes three major types: conventional, compact,
and car-type pickups. The compact pickups are, so far, nearly all
either foreign or captive imports. Car-type pickups have a cab and
front end similar to those of a passenger vehicle.
Vans have an enclosed load area which is typically connected
with the driver's compartment, and can be used for transporting
cargo and/or passengers, and for personal and recreational pur-
poses. Host vans have very short hood lengths, allowing improved
visibility and maneuverability.
-------
Figure II -A
A -- APPROACH ANGLE
FRONT ® " BREAKOVER ANGLE
wheels c — departure angle
REAR
WHEELS
-------
-13-
Th e third major category of light-duty trucks is composed of
general utility vehicles such as the Cherokee, Scout II, Blazer,
Bronco, etc. These vehicles, in general, are capable of trans-
porting both passengers and cargo, and of pulling fairly large
trailers. Approximately 95 percent of the utility vehicles sold in
1978 were equipped with four-wheel drive.3/ Table II-A shows a
breakdown of U.S. new truck retail deliveries by body type for the
years 1976 to 1978.
Since they are available in a variety of styles, and because
of their versatility, light-duty trucks are capable of being put to
a wide range of uses, both private and commercial. Host can be
used for transporting either heavy and/or bulky loads or moderate
numbers of passengers. Some, with various possible configurations,
can perform both functions (such as a passenger van with removable
seats). Because of their heavy construction, LDTs are often
well-suited for trailer-towing. Also, many LDTs are capable of
rough, off-road use and operation under adverse driving conditions,
particularly when equipped with four-wheel drive. In general, LDTs
are better able to perform these functions than are passenger cars,
which have limited load and passenger-carrying capacity, are
lighter in construction, have less-powerful engines, and are
usually confined to on-road use. Clearly, these characteristics
make LDTs much more attractive and capable than passenger cars for
performing certain functions.
Private uses can include such activities as personal transpor-
tation, moving and hauling, travel, sport and recreation, etc.
Commercially, LDTs are used for such purposes as delivery of goods
and services, public and personal transport, moving and hauling,
trailer-towing, off-road service, etc., and find such uses in
a variety of businesses and industries. Table II-B shows a
percentage breakdown of light trucks by major use in 1972.
An important consideration with respect to the use of LDTs is
the use and non-use of their capabilities. Clearly, many of the
needs currently met by LDTs could not be reasonably met by other
means or modes of transportation, and it can be expected that this
will continue to be the case. In many other instances, however,
consumers may buy a LDT because of anticipated requirements it can
fill, but may then fail to make efficient use of its capabilities.
For instance, a buyer, attracted by its utility, versatility, and
durability, might purchase a 1-ton pickup when he may have only
occasional light hauling to do. In this case, a smaller pickup may
be sufficient to meet the user's requirements, with greater use of
the vehicle's capability. As economic and energy constraints
become more pronounced, it is likely that consumers will tend to
purchase LDTs more suited to the jobs they will be required to
perform. This trend would result in higher sales of smaller,
lighter, more fuel-efficient LDTs, with (consequently) lower
emissions.2/4/
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-14-
Table II-A
U.S. New Truck Retail Deliveries by Body Type, 1976-1978
(GVWR 1 8,500 pounds)
Body Type
1976
%
1977
%
1978
%
Conventional Pickup
1,610,139
62.7
1,834,440
62.5
1,961,120
59.7
Compact Pickup
94,737
3.7
125,960
4.3
132,996
4.1
Car-Type Pickup
63,000
2.5
72,762
2.5
78,928
2.4
Van and Cut-Away
Chassis
494,060
19.2
544,294
18.5
636,630
19.4
Utility
201,600
7.8
238,158
8.1
335,832
10.2
Station Wagon
(Truck Chassis)
69,240
2.7
82,959
2.8
94,873
2.9
Passenger Carrier
4,984
0.2
5,728
0.2
6,492
0.2
Multi-Stop
31,678
1.2
33,209
1.1
36,092
1.1
Other
430
—
4
-
-
-
Total
2,569,868
100.0
2,937,514
100.0
3,282,963
100.1
Source: Estimated from
Ward's Automot ive
Yearbook.
-------
Table II-B
Percentage Breakdown of Light Truck Class by Major Use, 1972
(GVWR < 10,000 pounds)
Use
%
Personal Transportation
53.4
Agriculture
20.1
Services
7.7
Construction
6.9
Wholesale and Retail
6.1
Utilities
2.5
Manufacturing
1.3
For Hire
0.6
Forestry and Lumbering
0.5
Mining
0.2
All Other
1.2
Source: Census of Transportation, 1972, Truck
Inventory and Use Survey: U.S. Summary; U.S.
Bureau of the Census.
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-16-
2. The Light-Duty Truck Industry
a. Structure
Light-duty trucks can be divided into two primary categories:
domestic and imported. There are five manufacturers of LDTs in the
United States; these are: General Motors (GM), Ford, Chrysler,
American Motors (AMC), and International Harvester (IRC). With the
exception of International Harvester, these manufacturers also
produce light-duty vehicles (passenger cars), resulting in much
common technology between the two types. General Motors and
Chrysler each operate two LDT-producing divisions: for GM,
Chevrolet and GMC; and for Chrysler, Dodge and Plymouth. American
Motors operates the Jeep division. International Harvester, which
also produces a large number of heavy-duty vehicles, markets its
LDTs under the name of Scout. The domestic manufacturers' relative
market shares (see Table II-C) have been rather stable over the
past few years, although the penetration by foreign manufacturers
has been increasing significantly.
The two foreign manufacturers with the largest sales of LDTs
imported for sale under their own names are Toyota and Nissan
(Datsun), Another company, Toyo Kogyo, manufactures and sells a
moderate number of trucks under the Mazda name. Toyo Kogyo, Isuzu,
and Mitsubishi manufacture large numbers of trucks for sale by
domestic companies (captive imports). Other foreign companies
which produce LDTs for sale in the United States are Suzuki and
Volkswagen; these companies have, so far, had 3mall sales or have
only recently entered the market- Nearly all of the trucks pro-
duced by these companies, as either foreign or captive imports, are
coapact pickups. A Large number of LDTs are marnifactured in
Canadian plants of domestic companies and imported into the United
States; these trucks will be considered as part of the domestic
production.
b. Sales and Revenues
Financial sales data show the largest of the domestic LDT
manufacturers to be General Motors, followed by Ford, Chrysler,
International Harvester, and American Motors. Table II-D shows
for each of these companies (along with some heavy-duty manufac-
turers) their total sales, net income, and average total number of
employees. It must be recognized that these figures are company-
wide totals, and not just those pertaining to LDT production.
The only company showing a net loss for 1979 was Chrysler,
with a loss of 1,097.3 million dollars. Because of its weak
financial condition, Chrysler has sought, with some success,
government-sponsored financial aid.
As was stated previously, International Harvester, although a
manufacturer of light- and heavy-duty trucks, is not a manufacturer
of automobiles. There has traditionally been a large carryover of
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-17-
Table II-C
U.S. LDT Sales by Manufacturer, 1979
(GVWR S 8,500 pounds)
Manufacturer Sales % Total
Domestic
GM 1,202,782 41.2
Ford 973,965 33.4
Chrysler 316,564 10.8
AMC 145,214 5.0
IHC 23,464 0.8
Total Domestic 2,661,989 91.2
Imported
Toyota 129,288 4.4
Nissan (Datsun) 98,912 3.4
Other 29,803 1.0
Total Imported 258,003 8.8
TOTAL 2,919,992 100
Source: Automotive
News, 1980 Market Data Book Issue, April
30,
1980.
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-18-
Table II-D
1979 U.S. Vehicle and Engine Manufacturer Information
Company Total Sales ($) Net Income ($) Employees
American Motors 3,117,049,000 83,944,000 28,400
Caterpillar 7,613,200,000 491,600,000 89,266
Chrysler 12,001,900,000 -1,097,300,000 133,811
Consolidated 768,566,000 33,742,000 24,300 1/
Freightways (Mfg. Operations)
Cummins Engine 1,770,834,000 57,938,000 23,846
Ford 43,513,700,000 1,169,300,000 494,579
General Motors 66,311,200,000 2,892,700,000 853,000
International 8,392,042,000 369,562,000 97,660
Harvester
Mack Trucks 1,833,837,000 67,298,000 17,100 2/
Paccar 1,882,722,000 120,147,000 13,433
White Motor 1,211,023,000 12,921,000 9,685
1_/ Company-wide total.
2/ 1978 figure.
Source: Fortune, May 5, 1980; Moody's News Reports; Company annual reports.
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-19-
technology from the light-duty vehicle industry to the light-duty
truck industry. Because of this, IHC lacks the broad technological
base which is available to the other LDT manufacturers, all of whom
also market automobiles. This situation was a primary factor in
NHTSA's decision to subject IHC LDTs to fuel economy standards less
stringent than those applicable to the rest of the industry for
1981.2/
c. Employment
In addition to financial data, Table II-D shows corporate
average employment levels in 1979 for the five domestic LDT
manufacturers. Because of the high degree of integration between
the LDV and LDT industries (except in the case of IHC), only an
estimate can be made regarding the number of employees involved in
the production of LDTs. This estimate was made for 1978 as fol-
lows: the corporate employment figures of GM, Ford, Chrysler, and
AMC were totaled (1,531,000), and this figure was divided by the
total number of vehicles produced by these four companies (18,640,
700); a ratio of 0.082 employees per vehicle was obtained. This is
a rough approximation of the number of employees required for the
production of each vehicle. This same ratio of employees to
vehicles was assumed to be applicable to LDT production. Multi-
plying this figure by the total number of LDTs produced in the
United States during 1978 (3,083,647) yields an industry-wide
employment estimate of approximately 253,000. A similar analysis
indicated an approximate yearly payroll of 5.5 billion dollars for
the U.S. LDT industry in 1978. (Base data for this analysis was
obtained from Ward's Automotive Yearbook, 1979.)
3. Light-Duty Truck Sales
a. Historical Sales
The past few years have seen a significant increase in LDT
sales. This growth has been greater than that for light-duty
vehicles. From Table II-E, it can be seen that from 1974 to 1978,
LDT sales increased by nearly 58 percent, while passenger car sales
increased by about 27 percent. Sales of both, however, dropped in
1979. The growth in total LDT sales can be attributed to an
increase in the sale of heavier LDTs (those with GVWRs greater than
6,000 pounds). Since 1974, sales of LDTs with GVWRs less than or
equal to 6,000 pounds have actually decreased, as Table II-F
shows, while sales of trucks with GVWRs between 6,001 and 10,000
pounds have increased substantially.
A closer look will now be taken at some of the constituents of
these sales figures. First, California LDT sales will be con-
sidered. Table II-G shows California and 49-state sales for
1973-1979. These figures are for heavy as well as light-duty
trucks, but it is assumed that the percentages would be nearly the
same for only light-duty sales. As can be seen, California sales
as a percentage of total U.S. sales decreased from 1973 to 1977,
but showed slight increases in 1978 and 1979.
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-20-
Table II-E
U.S. New Car and Truck Sales, 1974-1979
Year
Cars
LDTs*
1979
10,334,911
2,920,000
1978
10,946,104
3,356,000
1977
10,826,234
2,949,500
1976
9,751,485
2,574,600
1975
8,261,840
1,984,500
1974
8,701,094
2,131,900
Estimated.
Source: Automotive News, 1980 Market Data Book Issue; April 30, 1980.
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-21-
Table II-F
U.S. Truck Sales, 1974-1979
Year 0-6,000 lb GVWR
1979 1,272,934
1978 1,143,064
1977 1,281,094
1976 1,284,876
1975 1,204,259
1974 1,616,309
6,000-10,000 lb GVWR
1,791,040
2,408,269
1,903,103
1,439,103
895,758
639,689
Source: Automotive News, 1980 Market Data Book Issue; April 30, 1980.
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-22-
Table II-G
California and
49-State Truck Sales,
1973-1979
Year
California
49-State
California Sales
as Percent of Total
1979
318,107
3,149,803
9.17
1978
347,245
3,616,095
8.76
1977
303,049
3,206,279
8.64
1976
264,937
2,793,072
8.66
1975
213,404
2,184,013
8.90
1974
241,897
2,415,021
9.10
1973
315,483
2,638,424
10.68
Source: Ward's Automotive Yearbook, 1979, p. 178; Automotive News, 1980
Market Data Book Issue, April 30, 1980.
-------
-23-
SaLes broken down on the basis of domestic, captive, and
imported LDTs are shown in Table II-H for the years 1975-1979.
These figures show that sales in each of the three categories
increased significantly during the time period 1975-1978, but that
domestic and total sales decreased in 1979.
Another way in which to consider LDT sales is on the basis of
manufacturer. Table II-I shows LDT sales by manufacturer for the
period 1974-1979. With the exception of IHC, all LDT producers
increased their sales during the years 1974-1978. However, all
except Plymouth and the importers (Misc.) experienced decreased
sales in 1979.
Several important factors become apparent from these data. A
slump in vehicle Bales (both car and truck) is clearly noticeable
for the years 1973 to 1975 and for 1979. This is most likely due
to the combined effects of economic slowdowns and gasoline supply
and price problems. These inter-related factors can have consid-
erable influence on the automotive industry. Also of inter-
est is the remarkably rapid growth of LDT sales in the late 1970's.
A large factor in this surge must be the sudden "popular" image of
LDTs, particularly of vans and sport/utility vehicles. An in-
creased number of LDTs were being used for sport and recreation
purposes. Another trend worthy of consideration is the increased
sales of heavier LDTs. While lighter LDT sales dropped from 1974
to 1978, heavier LDT sales rose significantly. An obvious apur to
this was the re-rating of some vehicles to higher GVWs in order to
circumvent emission and fuel economy regulations.
b. Projected Sales
It can be expected that factors which influenced LDT sales in
the past will continue to do so in the future. Primary among these
will be fuel availability and price. In the past two years,
gasoline prices have practically doubled, and supply has at times
been a problem. This undoubtedly has an effect on the sale of
LDTs, whose fuel economy is lower than that of LDVs, and probably
played a large role in the declining LDT sales of 1979. Also of
primary importance are economic influences. Historically, economic
slow-downs and recessions have had a pronounced impact on the
automotive industry. This will obviously continue to be the case.
Other factors, possibly of secondary importance, include fuel
economy and emission standards, re-rating, and social influences.
Manufacturers may find it necessary to shift production toward
smaller, lighter LDTs, if not to meet government regulations, then
perhaps to meet increased public demand for more efficient vehicles
and to compete with foreign manufacturers. There will, of course,
always be some demand for larger LDTs by those whose needs can not
be met by smaller trucks. In addition, manufacturers are likely to
re-rate some of their trucks in order to make them subject to
less-stringent regulations. Social factors will also continue to
be felt by the LDT industry. If a negative image of truck owner-
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-24-
Table II-H
U.S. LDT Sales, 1975-1979
(rounded to nearest hundred)
Year
Total, 0-8500 lb*
Domestic
Captive
Import
1979
2,920,000
2,454,300
207,700
258,000
1978
3,356,000
3,005,000
140,700
210,300
1977
2,949,600
2,630,400
133,300
185,900
1976
2,574,600
2,334,900
100,300
139,400
1975
1,984,500
1,744,000
102,800
137,700
* Estimated.
Source: Ward's Automotive Yearbook; Automotive News, Market Data
Book Issues.
-------
Table II-I
U.S. LDT Sales by Manufacturer, 1974-1979
(estimated for GVWR is 8,500 pounds)
1974
1975
1976
1977
1978
1979
Chevrolet
759,651
730,569
955,751
1,033,745
1,166,066
980,017
GMC
134,242
132,902
211,496
225,230
267,942
222,765
Ford
718,536
627,731
822,368
993,761
1,152,610
973,965
Dodge
244,342
237,056
314,875
367,012
374,473
296,886
Plymouth
4,277
4,141
4,609
5,559
7,572
19,678
AMC/Jeep
91,509
80,487
101,575
117,977
154,553
145,214
IHC
69,605
41,555
32,225
30,559
34,081
23,464
Miscellaneous*
116,392
137,705
139,357
185,912
210,274
258,003
* Includes non-captive imports.
Source: Automotive News, Market Data
Book
Issues.
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-26-
ship and use develops, for whatever reason, a significant decline
in sales could result. Conversely, a positive image would be
likely to have a boosting effect on sales.
Given the dependence of LDT sales on a variety of complex
variables, the difficulties in forecasting such sales can be
recognized. A number of such efforts have been undertaken, with
wide variations in results. EPA's projections, based on informa-
tion from Data Resources Inc., NHTSA, previous EPA studies, and
historical data, are presented in Table II-J. Although total LDT
sales are expected to increase through 1989, domestic production is
anticipated to level off around 1986, while import, captive, and
diesel-powered truck sales continue to increase. An increase
in import and captive truck market shares would seem to suggest a
trend toward LDTs with lower GVWRs.
Unexpected events and trends could easily shift sales from the
projected values, but these figures represent EPA's beat estimate
based on available data and the most likely scenario of develop-
ments for the next several years.
4. Other Considerations
a. Diesel Engine Penetration
A large unknown with respect to LDTs is their future use of
diesel engines. Diesels are attractive in our current fuel-
conscious era because of their significant gas-mileage improvements
over gasoline-fueled engines, as well as for their high durability
and their relative ease of maintenance. Diesels are also rela-
tively low in HG and CO emissions. They do, however, have moderate
levels of NOx emission and high levels of particulate emission.
Concerns about these latter two factors are preventing current
large-scale dieselization of the LDT fleet. Possible adverse
health effects of particulate emissions are currently under in-
vestigation- However, as Table II-K indicates, manufacturers
have already increased the use of diesel engines in LDTs (along
with LDVs and HDVs). The largest increase is seen to be in the
lighter LDT category. If the problems of NOx and particulate
emissions can be satisfactorily resolved, coming years are likely
to bring considerable growth in the use of diesel engines for
LDTs. Table II-J shows EPA's estimate of this growth for 1985-
1989 .V 6/
b. Fuel Economy Standards
Another consideration relevant to LDTs is their fuel economy.
Gas mileage has become an item of primary concern for buyers of
LDVs, and it can be reasonably expected that this will be reflected
in LDT sales as well. NHTSA is applying fuel economy standards of
increasing stringency to LDTs. Table II-L shows current and
proposed standards (the figures for 1983 to 1985 are proposed
ranges within which the finalized standards are likely to fall).
-------
-27-
Table II-J
LDT Sales
Projections
(millions)
0-10,000
lb 0-8500
Domestic
Import/Captive
GVW y
GVW 2/
LDT 5/
LDT 4/
LDDT 3/
1985
4.09
3.56
2.70
0.45
0.41
1986
4.29
3.73
2.75
0.47
0.51
1987
4.45
3.87
2.75
0.48
0.64
1988
4.52
3.93
2.75
0.49
0.69
1989
4.60
4.00
2.75
0.50
0.75
\J Data Resources Inc. Long Term Review, Spring 1980.
2/ 87 percent of the 0-10,000 Lb. GVW sales projections. This 87
percent figure was taken from the Rulemaking Support Paper, Light-
Duty Truck Fuel Economy Standards Model Years 1982-1985, December,
1979, NHTSA, DOT.
_3/ Figures used are based on percentages from the Regulatory
Analysis of the Light-Duty Diesel Particulate Regulations; February
1980, OMSAPC, EPA.
k) Using 1980 projected sales, imports and captives represented
12.5 percent of total sales.
5J Total 0-8500 - (Imports/Captives + LDDT).
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-28-
Table II-K
U.S.
Factory Sales of Diesel
Trucks by
GVW
Year
0-6,000 lb
6,
,001-10,000
1979
33,019
950
1978
35,019
990
1977
2,392
1,128
1976
-
1,596
1975
-
1
1974
—
-
Source: MVMA Motor Vehicle Facts and Figures, 1979, p. 14;
MVMA FS-5, February 15, 1980.
-------
-29-
Table II-L
Fleet Average Fuel Economy Standards
4x2
4x4
Captive
Captive
Limited
Model Year
Imports
Other
Imports
Other
Production
1979
-
17.2
-
15.8
-
1980
16.0
16.0
14.0
14.0
14.0
198 L
15.7
16. 7
L5.0
15.0
14.5
1982
IB.
.0
16.0
1983 (proposed)
18.0-
-20.0
15.6-18.0
1984 (proposed)
18.8-
-21.4
16.1-19.3
1985 (proposed)
29.7-
-22.4
16,2-19.9
Source: Rulemaking Support Paper, Light Truck Fuel Economy Stan-
dards, Model Years 1982-1985; NHISA, DOT; December, 1979.
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-30-
Th e limited production line category includes only International
Harvester, which was deemed unable to satisfy the standards set for
the rest of the industry in 1980 and 1981. It is EPA's belief
that decreased vehicle emissions and increased vehicle fuel
efficiency are not incompatible goals.
c. Emission Standards
Presented in Table II-B are past, present, and proposed
Federal and California emissions standards for LDTs. California
has adopted standards based on vehicle inertia weight which are
stricter than the comparable Federal standards. EPA's LDT stan-
dards are within the capability of manufacturers applying state-
of-the-art technology. It is expected that manufacturers will make
use of much of the technology developed initially for the LDV
class. This includes such methods and devices as: exhaust gas
recirculation, turbocharging, catalytic converters, air injection,
and electronic controls. New devices such as trap-oxidizers for
particulates, and high-technology engines are currently being
researched and developed.7/
d. High-Altitude Standards
High-altitude areas are defined to be those elevations greater
than 4,000 feet (1,219 meters) above sea level. Outside of Cali-
fornia, there are 112 U.S. counties located substantially above
4,000 feet in elevation. In 1977, LDT sales in high-altitude areas
comprised approximately 5.5 percent of national LDT sales. In
1978, registrations of light and heavy-duty trucks in eight states
(not including California) containing high-altitude areas were 6.9
percent (273,229 units) of the total U.S. new truck registrations,
while California registrations were 8.8 percent (347,245 units) of
the total. The eight states are: Arizona, Colorado, Idaho, Mon-
tana, Nevada, New Mexico, Utah, and Wyoming.3/
Vehicles which, after being designed and adjusted for use at
low altitudes, are operated under high-altitude conditions experi-
ence a degradation in emissions performance. In particular,
emissions of hydrocarbons and carbon monoxide are significantly
higher for maladjusted vehicles at high altitudes than at low
altitudes. For this reason, and since air pollution in a number of
high-altitude areas (primarily urban) is a serious problem, EPA has
considered and proposed measures affecting vehicles destined for
sale and/or use at high altitudes.
The Clean Air Act Amendments of 1977 require that, beginning
in 1984, all vehicles be able to comply with emission standards at
all altitudes. EPA has proposed that for the 1982 and 1983 model
year, vehicles be able to meet the standards applicable to the
altitude at which they are sold and be modifiable to meet the
standards at either high- or low-altitude. The proposed high-
altitude standards which 1982 and 1983 model year LDTs would be
required to meet when tested at a reference altitude of 5,400 feet
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(1,650 meters) are: 2.0 g/mile HC and 26 g/mile CO in 1982, and 1.0
g/mile HC and 14 g/mile CO in 1983. The NOx standards would be
equivalent to those applicable at low-altitude. In addition,
EPA has proposed that manufacturers be required to provide adjust-
ment instructions for improving high-altitude emissions performance
for 1968 and later model year light-duty vehicles and trucks.8/9/
B. Heavy-Duty Vehicles
1. Description of Heavy-Duty Vehicles
A heavy-duty vehicle (HDV) as defined by EPA is a vehicle
whose gross vehicle weight rating (GVWR) exceeds 8500 pounds.
This differs from the definition in the amended Clean Air Act
which specified 6000 pounds GVW as the lower limit of HDVs. The
reason for this difference is that although EPA is required to
regulate all vehicles heavier than 6000 pounds GVWR to at least
the levels dictated by the Act 10/, light-duty trucks in the 6,000-
8,500 pounds GVWR range are dealt with separately.
The industry as well uses GVWR as a basis for reporting
production and sales data. Their traditional categories are:
Class Weight (Pounds - GVWR)
I
0
- 6,000
II
6,001
- 10,000
III
10,001
- 14,000
IV
14,001
- 16,000
V
16,001
- 19,500
VI
19,501
- 26,000
VII
26,001
- 33,000
VIII
33,001
and over
EPA's definition of light-duty trucks sets the division
between the LDT class and heavy-duty vehicle class at 8,500 pounds
GVWR. Thus, some of the Class II trucks will be included with all
of those in Classes III through VIII in the heavy-duty vehicle
class. Table II-M gives the U.S. domestic factory sales plus
imports from Canada of all trucks and buses for years 1972 thru
1979.
Heavy-duty trucks represent a heterogeneous class of vehicles
in terms of use and functional characteristics. While light-duty
trucks are used by-and-large for personal transportation and
agriculture, heavy-duty trucks are almost exclusively used for
commercial purposes. The 1972 Census of Transportation conducted
by the Department of Commerce indicates that trucks are used in
agriculture, construction, mining, wholesale and retail trade,
manufacturing, and lumbering and forestry, as well as by the
utility, service and "for hire" industries. Most functional
applications of HDVs are not readily transferable to other trans-
portation modes such as air, rail, water, or pipeline.
-------
Table II-M
U.S. Trucks and Buses by GVWR (pounds)
(U.S. Domestic Factory Sales plus Imports from Canada)
Year
0-*
8,500
8,501-
10,000
10,001-
14,000
14,001-
16,000
16,001-
19,500
19,501-
26,000
26,001-
33,000
33,000
and over
Yearly
Totals
1979
2,557,153
148,829
17,366
2,361
3,147
139,542
47,239
173,675
3,089,312
1978
3,218,772
187,336
34,014
5,959
3,982
157,168
41,516
163,836
3,812,583
1977
2,972,752
173,017
30.064
3,231
4,989
160,396
32,249
148,728
3,525,426
1976
2,525,755
147,002
43,411
67
8,920
149,293
22,918
103,098
3,000,466
1975
1,790,355
104,201
19,497
6,508
13,916
152,070
24,698
74,896
2,186,141
1974
2,088,200
121,535
8,916
8,120
24,366
215,221
32,364
160,465
2,659,187
1973
2,370,208
137,949
52,558
8,744
37,043
199,481
40,816
155,814
3,002,613
1972
1,929,883
112,321
57,803
10,353
37,492
177,723
40,150
130,328
2,496,054
* The MVMA does not split sales at 8,500 pounds GVWR, but rather publishes sales for the 0-6,000 and the
6,001-10,000 pound classes. The split in the table represents EPA's estimate.
Source: FS-3, MVMA data.
Total Vehicles Subject to HP Regulations
1979 532,159
1978 593,811
1977 552,674
1976 474,709
1975 395,786
1974 570,987
1973 632,405
1972 566,170
-------
-33-
As Table II-N shows, the uses of heavy-duty vehicles vary
with gross vehicle weight. For the lighter trucks, those in the
8,500-20,000 pound GVWR range* we find that the primary applica-
tions are in the agriculture, construction, services, and wholesale
and retail trade markets, where the trucks are generally used for
pickup and delivery. Personal use of trucks in this category,
while limited, consists primarily of operation of motor homeB built
on truck chassis. Some people also use "heavy" pickup trucks for
personal transportation.
HDVs in the 20,001 - 26,000 pound GVWR range find uses in the
agriculture, construction,and wholesale and retail trade markets.
Forestry, lumbering,and manufacturing account for most of the other
applications.
The heavier trucks (26,001 pounds GVWR and over) are primarily
found in the construction, wholesale and retail trade, and "for
hire" markets. While the number of trucks used for mining and
manufacturing is not large, these markets use the heavy trucks
extensively. Trucks in this category are used only to a limited
extent in the other market sectors.
Since the ultimate goal of the various commercial enterprises
that use heavy trucks is to make a profit, trucks operated by these
businesses are designed specifically to meet particular functional
needs in an economical manner. Thus, the heavy-duty vehicles
produced for the U.S. market are often "custom" built to satisfy
requirements of the operational environment faced by the ultimate
user. This operational environment might be defined in terms of
economic variables (i.e., operating costs of alternative means of
transport, value of products to be transported, operating costs of
alternative types of trucks) or operational variables (i.e.,
distances to be travelled, qualities of the load to be transported,
types of shipping procedures to be utilized, state and federal
regulations on truck use, safety, operation).
Buses equipped with heavy-duty engines are usually in the
19,501 - 26,000 pound GVWR (Class VI) category. Uses of buses
include school transportation as well as intercity and transit
passenger service. Host school-type buses are gasoline-fueled,
the remainder being diesels.
By defining their operating environment, users of heavy-duty
vehicles can tell vehicle manufacturers exactly what characteris-
tics their truck should have when it is completed. Examples of the
design parameters which may be specified include engine type
(diesel or gasoline-fueled), horsepower, number of cylinders,
displacement, natural aspiration vs. turbocharging, transmission,
body type (single unit, or combination), gross vehicle weight,
maximum load weight, vehicle length, number of axles, axle ar-
rangement, distance between tandem axles, and tire size.
-------
Table rf-V
Trucks: Percent Distribution of Size
Classes by Vehicle and Operational Characteristic: 1972
10,000
10,001-
20,001-
26,001
Number
Or Less
20,000
26,000
Or More
Characteristic (Thousands)
Percent
Lbs. GVW
Lbs. GVW
Lbs. GVW
Lbs. GVW
MAJOR USE
Agriculture
4,258
21.6%
20.1%
32.1%
33.2%
10.3%
Forestry and Lumbering
187
1.0
.5
1.4
2.8
3.6
Mining
77
.4
.2
.6
.7
1.9
Construction
1,693
8.6
6.9
10.2
14.0
19. L
Manufacturing
443
2.3
1.3
3.3
4.4
8.5
Wholesale and Retail Trade
1,875
9.5
6.1
18.9
23.0
18.3
For Hire
770
3.9
.6
6.0
7.2
30.6
Personal Transportation
8,122
41.2
53.4
11.0
2.1
1.0
Utilities
505
2.6
2.5
3.1
3.8
1.9
Services
1,409
7.6
7.7
10.5
6.0
2.5
All Other
327
1.7
1.2
3.5
3.4
2.8
BODY TYPE
Pickup, Panel,
14,464
73.3%
92.6%
31.3%
4.4%
2.1%
Multi-Stop,or Walk-in
Platform
1,645
8.4
2.2
27.4
28.9
21.0
Platform w/ Added Device
336
1.8
.4
5.6
7.0
4.4
Cattlerack
479
2.5
1.4
6.7
6.7
2.4
Insulated Nonrefrigerated Van
96
.5
.1
1.2
1.2
3.1
Insulated Refrigerated Van
178
1.0
.1
2.4
2.3
5.3
Furniture Van
192
1.0
3.7
2.8
3.2
Open Top Van
58
.3
.1
.6
.4
1.9
All Other Vans
610
3.1
.7
6.3
7.2
18.6
Beverage Truck
87
.5
.1
1.4
3.0
1.6
Utility Truck
370
1.9
1.7
3.4
2.0
.9
Garbage and Refuse Collector
69
.4
.1
1.3
1.4
1.2
Winch or Crane
83
.5
.1
.8
3.5
1.8
Wrecker
115
.6
2.3
.6
.2
Pole and Logging
53
.3
.1
.3
1.4
2.4
Auto Transport
30
.2
.1
.2
.1
1.4
Dump Truck
468
2.4
3.1
17.3
14.0
Tank Truck for Liquids
287
1.5
.1
2.3
9.7
9.1
Tank Truck for Dry Bulk
29
.2
.1
.6
1.5
Concrete Mixer
66
.4
.1
.2
.1
4.1
All Other
33
.2
.1
.6
.5
.6
ANNUAL MILES
< 5,000
4,621
23.5%
22.0%
33.2%
35.8%
12.7%
5 - 9,999
5,540
28.1
30.2
25.6
25.2
13.8
10-19,999
6,598
33.5
36.2
27.8
24.0
22.4
20-29,999
1,647
8.4
8.1
8.1
8.3
11.5
30-49,999
772
4.0
2.9
4.1
4.9
13.4
50-74,999
270
2.4
.5
.9
1.5
11.5
> 75.000
300
1.5
.4
.6
.5
15.1
Total Percent
100.0%
100.0%
100.0%
100.0%
100.0%
Total Trucks
19,745
14,598
2,822
828
1,500
Source: 1972 Census of Transportation, U.S. Department of Commerce.
-------
-35-
2. Heavy-Daty Vehicle Euair.es
One of the basic parameters that heavy-duty vehicle users must
consider in determining what vehicle they need is the type of power
plant they will use. Both diesel and gasoline-fueled engines are
used to power heavy trucks and buses. Some tradeoffs that vehicle
purchasers consider in the selection of diesel or gasoline-fueled
engines for their vehicles follow:
Diesel Engines
1. Diesel fuel costs less than gasoline.
2. Diesels get up to twice the fuel mileage of comparable
gasoline-fueled engines.
3. Diesels require less maintenance.
4. Diesels are generally more durable than gasoline-fueled
engines and are often rebuilt.
5. The dieseL rebuild interval (250,000-300,000 miles) is
up to three times longer than that for gasoline-fueled
engines (100,000 - 125,000).
6. Diesels have higher resale values.
Gasoline-Fueled Engines
1. Gasoline is more readily available in moBt areas.
2* Gaaoline-fueled engines generally start more easily in
cold weather and give better overall performance,
3, Gasoline-fueled engine service and parts are more readily
available.
A. Gasoline-fueled engines weigh less.
5. Gasoline-fueled engines cost considerably less than
comparable diesel engines (about one-third as much).
The lighter trucks, classes IIB - VI, are usually equipped
with gasoline-fueled engines, as shown in Table II-O.
The heavier trucks (Classes VII and VIII) are equipped with
diesel engines¦ as shown in Tables II-P and Il-Q. However, as
fuel economy and fuel costs become more important to truck opera-
tors, diesel engines will become more popular in some of the
lighter truck classes. Diesel engines are more fuel efficient
and diesel fuel is cheaper than gasoline.
Manufacturers can effectively boost the power of both gaso-
line-fueled and diesel engines through turbocharging, though the
first cost of the engine suffers somewhat. Because the avail-
ability of turbocharged engines is a further consideration of the
prospective buyer/user, we have included a brief description.
A turbocharger combines a turbine, driven by engine exhaust
gases, with a compressor which increases the air flow into the
-------
-36-
Table II-O
Gasoline Engine Usage in Heavy-Duty Vehicles
8,501 10,001- 14,001- 16,001- 19,501- 26,001- 33,001- Yearly
Year 10,000 14,000 16,000 19,500 26,000 33,000 and over Totals
1979 148,829 17,366 2,361 3,146 123,625 19,043 7,645 322,015
1978 187,336 34,014 5,959 3,982 144,923 15,597 7,160 398,971
1977 173,017 30,064 3,231 4,989 149,254 13,526 6,005 380,080
1976 147,002 43,411 67 8,920 143,077 11,597 5,561 359,635
1975 104,201 19,497 6,508 13,757 147,267 13,509 8,748 313,487
1974 121,535 8,916 8,120 24,325 211,861 19,382 19,138 413,277
1973 137,949 52,558 8,448 37,037 195,741 22,587 17,473 471,793
1972 112,321 57,803 10,138 37,487 174,019 27,482 13,855 433,105
Source: Table II-M and Table 1I-P.
-------
-37-
Table II-P
Diesel Usage in Heavy-Duty Vehicles
8,501 10,001- 14,001- 16,001- 19,501- 26,001- 33,001- Yearly
Year 10,000 14,000 16,000 19,500 26,000 33,000 and over Totals
1979 — — -- 1 15,917 28,196 166,030 210,144
1978 — — — — 12,245 25,919 156,676 194,840
1977 — — — — 11,142 18,723 142,723 172,588
1976 — — — — 6,216 11,321 97,537 114,894
1975 — — — 159 4,803 U.IH9 66,148 82,299
1974 — — — 41 3,360 12,982 141,327 157,710
1973 — — 296 6 3,740 18,229 138,341 160,612
1972 — — 215 5 3,704 12,668 116,473 133,065
Source: FS-5, MVMA data.
-------
-38-
Table II-Q
Diesels Factory Sales as a Percentage of
All Heavy-Duty Vehicle Factory Sales
8,501- 10,001- 14,001- 16,001- 19,501- 26,001- 33,001 All HD
Year 10,000 14,000 16,000 19,500 26,000 33,000 and over Vehicles
1979 — — — — 11% 60% 96% 39%
1978 — — — — 8% 62% 96% 32%
1977 — — — ~ 7% 58% 96% 31%
1976 — — — — 4% 49% 94% 24%
1975 — — — 1% 3% 45% 88% 21%
1974 — — — — 2% 40% 88% 28%
1973 — — 3% — 2% 45% 89% 26%
1972 — — 2% — 2% 32% 89% 24%
Source: Tables II-M and II-P.
-------
-39-
engine combustion chambers. Increasing the amount of air entering
the combustion chambers permits more fuel to be injected and
therefore more power is generated per piston stroke. In addition
to generating more power than a naturally aspirated engine, turbo-
chargers improve the fuel economy and emission characteristics of
the engine. The increased air flow into the combustion chamber
increases the inlet air pressure and inlet air temperature. This
results in more complete combustion of the air/fuel mixture,
particularly under cruise conditions. Fuel economy is improved and
emissions of HC and CO are reduced. DOT and EPA have estimated
that a 0 to 7 percent fuel economy improvement can be gained
by the use of turbochargers on heavy-duty diesel engines.11/
Though turbocharger units can cost from $300 to $1,200, this higher
first cost is soon paid back through lower operating costs. 12/
3. Manufacturers
Unlike the automobile industry, in which the vehicle manufac-
turer and the engine manufacturer are one and the same, heavy-duty
vehicles and the engines used in them are often manufactured by
independent companies. A single vehicle manufacturer may, in fact,
use engines produced by several different companies. Even vehicle
manufacturers that produce their own engines may use another
company*8 engine in the vehicles they produce.
To simplify this discussion of producers of domestically sold
heavy-duty trucks, vehicle manufacturers and engine manufacturers
will be considered here separately. As an aid to the reader, the
list below is provided giving the names of most of the manufac-
turers in the heavy-duty vehicle industry and their product(s).
Summary financial and non-financial information on many of these
companies can be found in Table II-D.
Manufacturers
Engines
(G-Gasoline)
(P-Diesel)
Vehicles
Chrysler
Ford
General Motors
IHC
Mack Trucks
Mercedes-Benz
Volvo
White Engines, Inc
Caterpillar
G,D
G,D
D
D
D
D
D
D
D
D
D
D
D
D
G
G
(Chrysler, Dodge)
X
(Chevrolet, GMC)
X
(Mack, Brockway)
X
X
Cummins
Deutz
Nissan
Fiat
Hino
Isuzu
Mitsubishi
-------
-40-
Manufacturers
Engines
(G-Gasoline)
(D-Diesel)
Vehicles
Scania Vabis
Perkins
Transit Sales Corp.
Freightliner
Peterbilt
Kenworth
FWD
Oshkosh
Renault
White Motors
Bluebird
Revcon
D
D
D
X
X
X
X
X
X
X
X
X
a. Engine Manufacturers
Manufacturers of engines used in heavy-duty trucks typically
fall into one of two categories, those that produce gasoline-fueled
engines and those that produce diesel engines. Two companies,
General Motors and International Harvester, produce both gasoline-
fueled and diesel engines for use in on-road heavy-duty vehicles.
The manufacturers of gasoline-fueled engines and the engines
they certified in 1980 are listed in Table II-R. All these
manufacturers are domestically based and all produce their own line
of heavy-duty trucks or buses. General Motors (GM), Ford, and
Chrysler are perhaps most widely known as producers of light-
duty passenger cars since it is from that line of business that
they derive most of their revenue. However, all produce light-duty
trucks and heavy-duty vehicles in addition to gasoline-fueled
heavy-duty engines.
A fourth company producing gasoline-fueled engines for trucks
sold in the U.S. is the International Harvester Company (IHC).
Like the other three, IHC produces complete vehicles as well as
gasoline engines — but no passenger cars. Their concentration is
in the heavy-duty truck market with some emphasis on light-duty
trucks. IHC also makes off-the-road vehicles for construction and
industry and farm equipment.
Using past sales data supplied by the manufacturers EPA has
estimated each manufacturer's market share. Assuming no gasoline-
fueled engine sales are made to other manufacturers, the following
market shares result:
These market shares are only an estimate since some engines
are indeed sold to other manufacturers and also to recreational
vehicle manufacturers.
GM
Ford
Chrysler
IHC
43%
29%
16%
12%
-------
-41-
Table II-R
Manufacturers of Gasoline-Fueled Engines
for Use in Heavy-Duty Vehicles
Manufacturer Engine Families Displacements Available (CID)
Chrysler 3 318, 360
Ford 5 300, 351, 370, 400
429, 460, 477, 534
GM 4 292, 350, 366, 427, 440, 454
IHC 4 345, 391, 400, 446, 537
Bluebird 1 427
Revcon 1 454
Source: Federal Register Vol. 44, No. 140, Part III, July 19, 1979;
EPA Certification data.
-------
-42-
As we turn to a discussion of diesels, it is important to
realize that their manufacture and sale is accomplished by a
different set of manufacturers than those involved in the produc-
tion of gasoline engines. Only GM, via its subsidiary Detroit
Diesel Allison, and International Harvester manufacture both engine
types in significant quantities. Together their production of
diesels accounts for something less than 35% of the total produced.
The leading producer of diesel engines used in the U.S. trucks is
the Cummins Engine Company, followed by Detroit Diesel (GM),
Caterpillar, Mack Trucks, and IHC. A list of the engines made by
these companies and several others is given in Table II-S. Table
II-T presents a distribution by manufacturer of diesel engines
used in U.S.-made trucks. In Figure II-B, manufacturer sales
trends are shown graphically.
Like gasoline engines, most diesels are produced by domestic
companies. Detroit Diesel Allison and Perkins Engine are subsid-
iaries of GM and Massey-Ferguson, LTD, respectively. Detroit
Diesel sells both diesel engines and aircraft engines. In addition
to Perkins' sales of diesel engines, Massey-Ferguson also produces
agricultural, industrial and construction machinery, and recreation
products.
Several of the other manufacturers of diesel engines, like
Massey-Ferguson, make off-the-road vehicles. Caterpillar's product
line includes construction, warehouse, agricultural, logging and
petroleum equipment, accounting for 90% of total sales.
Mack Trucks produces diesel engines and the on-road trucks
that use them. Mack is a subsidiary of Signal Companies, Inc.,
whose business includes aerospace and industrial equipment, petro-
leum and petrochemical products, and construction and fabricated
products.
Cummins Engine Company is the leading producer of heavy-duty
diesel engines with about 30% of the market. Cummins is unique in
that it does not manufacture any vehicles, either on-road or
off-road; nearly all of its sales are engines. Cummins also
produces and markets crankshafts, turbochargers, and related
components.
b. Vehicle Manufacturers
It is the vehicle manufacturers who combine their own or
someone else's engine with a chassis to fabricate the final product
needed by the heavy-duty vehicle user. This final product is a
bus, a single unit truck, or a tractor for pulling trailer units.
Tables II-U and II-V show the domestic factory sales numbers
for trucks and buses respectively during 1979. It is clear that
some firms concentrate on producing trucks of a certain weight
class while others produce the entire spectrum. In 1979 trucks
built by Ford, GM (Chevrolet and GMC), Chrysler (Dodge), and IHC
-------
-43-
Figure II-B
MVMA DIESEL ENGINE IN TRUCK APPLICATION
STATISTICAL SUMMARY FACTORY SALES
100-
8
O 90 H
X
q:
<
UJ
>
85-
80-
75-
70-
cr 65^
U 60 H
55-
UJ 50-j
? 45-
40-
0
Z
LlJ 35-1
Li. 30-
° 25-
20-
cr
LlJ
S 15—1
Z) 10-
Z 5H
CUMMINS
-- DETROIT DIESEL
MACK
- CATERPILLAR
• l.H.C.
i
'"1 '
' '
:
i i
/i il i
i
I
i' \ '
„ >i' \'i i *
t I in /
I
M / / \V » .
/ V ,\/ « I /'
y v /v i "
I I I I | I
1950 1955
1PT115
I I | I I I I | 1 I I I | I I I I | I I I I |
1960 1965 1970 1975 1980
YEAR
Source: from Mack Trucks, May 7, 1980,
-------
-44-
Table II-S
Manufacturers of Diesel-Fueled Engines
for Use in Heavy-Duty Vehicles
Manufacturer
Engine Families
Displacements Available (CID)
Caterpillar
9
636, 638, 893, 1099
Cummins
10
555, 855, 903, 1150
Deutz
2
288, 374
GM (DDA)
13
212, 318, 426, 500, 552, 568
736
Hino
1
393
IHC
3
466, 551
Isuzu
2
235, 353
Iveco-Fiat
2
494, 584
Mack
5
475, 672, 998
Mercedes Benz
3
346, 589
Mitsubishi
1
243
Scania Vabis
1
475
Volvo
4
219, 334, 409, 586
White Engines
1
478
Renault
2
335, 538
Transit Sales
Corp. 1
146
Source: Federal Register Vol. 44, No. 140, Part III., July 19,
1979; EPA Certification data.
-------
Table U-T
Diesel Engines Used In Trucks
Ft out U.S. - 1979
Diesel Enfiine Manufacturer
Vehicle
Scania
Mfr.
Cat.
Cumnina
CM (DDA)
1HC
Isjzu
Hack
Nissan
Olds
Perkins
Vabis
Chevrolet
1,606
926
6,414
_
_
, _
24,734
__
Chrysler
—
912
—
—
—
—
—
96
—
Ford
19,761
11,539
8,321
—
—
—
—
Freightlioer
1.334
9,624
3,743
—
—
—
—
—
CMC
2,506
6,596
19,534
—
—
—
7,997
—
IKC
2,637
27,584
9,794
17.593
—
—
950
—
—
Jeep
—
—
—
—
288
—
—
—
—
Kenworth
2,854
8,247
4,124
—
—
—
—
—
—
Hack
331
2,767
541
—
—
30,661
—
—
572
Peterbilt
2,464
4,967
2,372
—
—
—
—
—
—
White
&63
7,628
3,499
—
—
—
—
—
—
Others
584
634
930
—
—
—
—
—
—
Total
34,942
81,424
59,272
17,593
23-B
30,661
950
32,731
96
572
Total
33,680
1,008
39,621
14,701
36,633
58,558
288
15,225
34,874
9,803
11,990
2,148
258,529
Source1979 MVMfc Data.
-------
Table II-U
U.S. Truck Sales by Make and GVW Class, 1979
6,001-
10,001-
14,001-
16,001-
19,501-
26,001-
33,001-
10,000
14,000
16,000
19,500
26,000
33,000
and over
Total
Autocar
—
—
—
—
—
2,227
2,227
Chevrolet
591,506
4,948
—
1,786
34,892
1,139
5,050
639,321
Dodge
207,453
32,869
4,936
—
—
—
—
245,321
Ford
734,342
456
—
—
53,843
15,228
22,478
826,347
Freightliner
—
—
—
—
—
—
13,636
16,636
GMC
167,198
1,020
—
1,041
24,983
1,973
18,393
214,608
IHC
23,464
—
—
—
27,221
27,309
38,585
116,579
Jeep
61,813
—
—
—
—
—
—
61,813
Kenworth
—
—
—
—
—
—
14,893
14,893
Mack
—
—
—
—
—
—
29,264
29,264
Peterbilt
—
—
—
—
—
—
8,693
8,693
Plymouth
5,250
—
—
—
—
—
—
5,250
Western Star
—
—
—
—
—
—
1,133
1,133
White
—
—
—
—
—
—
9,145
9,145
Miscellaneous
14
43
6
31
2,687
1,666
2,362
6,809
Total
1,791,040
39,336
4,942
2,858
143,626
47,315
165,859
2,194,976
Miscellaneous includes: Imports, Brockway, Diamond Reo, FWD, Hendrickson, Oshkosh, etc.
Source: Automotive News, 1980 Market Data Book Issue; April 30, 1980.
-------
-47-
Table II-V
1979 U.S. Domestic Bus Sales
(Including School Bus Chassis)
8,500- 10,001- 14,001- 16,001- 19,501- 26,001- 33,001
10,000 14,000 16,000 19,500 26,000 33,000 & Over Total
Chevrolet — — — — 4,582 — — 4,582
GMC — — 2,736 189 1,579 4,504
Ford — — — — 5,046 — — 5,046
IHC — — — — 13,304 968 — 14,272
AM/General — — ~ — — — 382 382
Others — — — — 1,001 2 1,003
TOTAL — — — — 25,668 2,158 1,963 29,789
Source: FS-3, 1979 MVMA data.
-------
-48-
appeared in nearly every class. GM and Ford dominated the market
in almost every category and accounted for 39 percent and 38
percent respectively of total heavy-duty sales. Along with Chry-
sler (Dodge) and IHC, they produced all but a few of the vehicles
with GVWRs below 26,000 pounds. Most of each of these manufac-
turer's trucks are gasoline-powered, using their own engines.
International Harvester is the largest producer of Class VII
and VIII (26,000 pounds GVW and above) vehicles, and overall
is fourth (behind GM, Ford, and Chrysler) in the production of
heavy-duty trucks. As noted earlier, IHC also produces both
gasoline and diesel engines.
The rest of the heavy-duty vehicle manufacturing industry
consists of firms which account for less than 5 percent of total
truck production. These firms concentrate on the production of the
"heavy heavies", the Group VIII trucks (33,000 pounds GVW and over)
that are used primarily for long haul work. FWD is a privately-
owned company specializing in the production of custom-built trucks
used primarily by owner-operators. FWD produces an expensive truck
package that is custom-built to the buyer's specifications and
produced in limited quantities. Mack, as mentioned in the heavy-
duty engine manufacturers description, produces heavy-duty engines
and Class VIII heavy-duty trucks. The White Motor Corporation is
represented by "White", "Autocar", and "White Western Star", while
also producing agricultural and construction equipment. Other
manufacturers of Groups VII and VIII heavy trucks include Kenworth
(PACCAR) and Peterbilt (PACCAR). These manufactuers specialize in
custom-built HDVs which are primarily procured by individual
owner-operators (as opposed to fleets).
In contrast to the production of heavy-duty trucks, bus
manufacturing is limited to only larger companies in the transpor-
tation manufacturing industry. As one can see from Table II-V,
IHC, GM, and Ford are the primary producers of intercity, transit,
and school bus chassis in this country. For none of these com-
panies is the sale of buses critical to the financial success of
the firm.
A brief look at the employment picture in the industry shows
that 763 manufacturers of truck and bus bodies (including light-
duty trucks) employed 40,796 people in 1976, and the 292 firms
building truck trailers employed 20,697. (Table II-D gives the
number of employees in the major vehicle and engine manufacturers.)
4. Users of Heavy-Duty Vehicles
As section 1 of this chapter notes, most heavy-duty vehicles
are used for commerical purposes. The types of trucks used to meet
the transportation needs of various enterprises are as diverse as
the needs themselves. Basically, however, these trucks move some
commodity from one point to another.
-------
-49-
Table II-W lists some of the types of products moved by trucks
and other means of transport and the percentage (by weight)
that each means of transit carries. Though the data is somewhat
outdated, it is interesting to see the fractional distribution of
freight and how it is transported. As of 1972, nearly half of the
commodities listed were shipped by truck, and in 1977, trucks
carried almost 25% of all intercity freight.13/
Trucking can be divided into two types of carriers, local and
intercity. The rule of thumb is that local carriers are those who
conduct 50% or more of their business in a metropolitan area. The
intercity (line haul or over-the-road) carriers conduct local
pickup and delivery between metropolitan areas. Local "carriers
accounted for $67.5 billion in freight transportation expenses and
intercity carriers $67.3 billion in 1978.13/
Another way of examining the trucking industry is to distin-
guish between private ownership and "for hire" trucking. The
trucks in "private" fleets are under the control of each particular
company for the shipment of their own goods, trucking not being
their principal business. Examples of "private" truck owners are
the various utility companies (e.g., Bell Telephone System)
or retail stores that own their own delivery trucks, and manufac-
turers of consumer products who make deliveries to retail concerns.
In contrast, "for hire" trucks are used by companies or
individual owner/operators whose business it is to transport
someone else's freight.13/ Examples of firms in this latter
category are United Parcel Service, Roadway Express, Consolidated
Freightways, and the various movers of household goods (United Van
Lines, North American Van Lines, Allied Van Lines). Some com"
panies, like Hertz and Ryder, are in the business of renting trucks
for use by others.
"For hire" trucks accounted for about 4% of the trucks in use
in 1975. Over fifty percent of these trucks were combinations
(tractor-trailer), most with five or more axles (see Table II-
X).14/
To remain competitive with alternative means of transport,
intercity carriers work on a small margin over costs. Costs for
drivers are about 30% of the total. Costs of equipment account for
another 9.0% of the total and operating costs (fuel/maintenance)
about 11%. In 1974 there were approximately 2,800 Class I and II
motor carriers. Finally, employment in the trucking industry
amounted to 9,052,000 people in 1973 (ATA estimate).
Heavy-duty engine exhauBt emission regulations will, of
course, also apply to buses. As an example of how this segment of
the vehicle population is made up, in 1977 there were about 20,000
buses being operated in the U.S. by 1050 intercity transit bus
companies, employing about 44,000 people. There were also 48,700
buses being operated by local transit companies. Most of these
-------
Commodities
Tons
Motor
Private
Total
Group
Carrier
Truck
Truck
Heat fit Dairy Products
41.7%
39.1%
80.8%
Canned, Frozen & Other
20.3
23.0
43.3
Food Products
Candy, Cookies, Beverages
25.7
58.4
84.1
Tobacco Products
Basic Textiles & Leather
61.4
27.7
89.1
Products
Apparel & Related Products
69.4
15.6
85.0
Paper & Allied Products
28.0
17.9
45.9
Basic Chemicals.Plastics,
30.1
12.1
42.2
Synthetic Rubber & Fibers
Drugs,Paints & Other
38.6
15.7
54.3
Chemical Products
Petroleum & Coal Products
16.0
8.4
24.4
Rubber & Plastic Products
59.1
15.2
74.3
Lumber & Wood Products,
16.2
36.3
52.5
Except Furniture
Furniture & Fixtures
41.4
34.7
76.1
Stone, Clay & Glass
47.2
23.7
70.9
Products
Primary Iron & Steel
44.4
6.7
51.1
Products
Primary Nonferrous Metal
31.4
15.1
46.5
Products
Fabricated Metal Products
55.3
25.1
80.4
Metal Cans & Misc. Metal
44.1
17.8
61.9
Products
Industrial Machinery,
59.4
18.9
78.3
Except Electrical
Machinery, Except Elec-
53.4
17.7
71.1
trical and Industrial
Communication Products
64.5
12.4
76.9
& Parts
Table II-W
Shipped by Mode of Transport
Tons/Miles
Motor
Private
Total
Rail
Other
Carrier
Truck
Truck
Rail
Other
18.8%
.4%
54.3%
17.2%
71.5%
27.8%
.6%
50.7
6.0
18.3
9.5
27.8
66.8
5.4
15.4
.4
28.8
25.8
54.6
43.1
2.2
9.7
1.2
61.0
21.0
82.0
16.1
1.8
8.5
6.5
67.0
9.5
76.5
13.4
10.1
51.7
2.3
18.9
5.6
24.5
73.8
1.5
48.6
9.2
21.6
4.7
26.3
63.1
10.5
37.8
7.9
32.0
8.4
40.4
44.3
15.2
9.7
65.8
3.4
1.6
5.0
7.9
87.1
24.4
1.2
56.8
9.3
66.1
32.1
1.8
45.8
1.6
7.6
10.7
18.3
76.8
4.9
22.0
1.9
39.9
20.5
60.4
37.1
2.5
21.9
7.2
36.6
11.3
47.9
45.3
6.7
43.7
5.2
35.9
4.8
40.7
51.6
7.7
51.6
1.9
23.4
7.7
31.1
67.2
1.6
17.3
2.3
60.1
13.0
73.1
23.3
3.6
36.8
1.3
40.3
7.1
47.4
50.5
2.1
19.6
2.0
75.7
8.9
84.6
12.3
3.0
26.5
2.3
49.7
8.9
58.6
37.7
3.6
13.0
10.0
59.9
5.6
65.5
18.0
16.5
-------
Table II-W (Cont'd)
Commodities Shipped by Mode of Transport
Tons Tons/Miles
Motor
Private
Total
Motor
Private
Total
Group
Carrier
Truck
Truck
Rail
Other
Carrier
Truck
Truck
Rail
Other
Electrical Products
49.3
14.1
63.4
35.0
1.3
46.0
8.4
54.4
43.2
2.6
& Supplies
Motor Vehicles &
37.3
3.0
40.3
59.3
.4
17.4
1.0
18.4
80.9
.8
Equipment
Transportation Equip-
23.9
54.8
78.7
19.5
1.8
30.3
43.1
73.4
24.0
2.7
ment Except Vehicles
Instruments, Photo
63.8
10.9
74.7
20.9
4.4
53.9
5.7
59.6
34.4
6.0
Equipment Hatches &
Clocks
TOTAL ALL SHIPPER GROUPS
31.1Z
18.3Z
49.4%
31.7%
18.8Z
20.9Z
6.8Z
27.7%
42.0%
30.33
Total all Shipper Groups
Except Petroleum and Coal
35.7Z
21.3Z
57.0Z
38.4Z
4.5Z
28.6Z
9.1Z
37.7%
56.9%
5.42
Source: Motor Vehicle Facts and Figures, 1976
Data from 1972 Commodity Transportation Survey - U.S. Bureau of Census.
-------
-52-
Table II-X
"For Hire" Trucks In Use (1975)
Single-Unit Trucks
2 Axles 378,845 39.4
3 Axles 43,276 4.6
Subtotal 422,121 44.0
Combination Trucks
3 Axles 70,181 7.3
4 Axles 145,899 15.2
5 or more 321,499 33.5
Subtotal 537,579 56.0
Total Trucks for Hire 959,700 100.0
Total Trucks In Use 23,648,008
% Trucks Used for Hire 4.06%
Source: Transportation Energy Conservation Data Book, Edition 3,
February 1979, Oak Ridge National Laboratory, Table 1.26.
-------
-53-
transit buses are equipped with diesel engines. School buses,
however, account for the overwhelming number of buses on the
roads. In 1977 over 298,800 publically- and privately-owned school
buses were in operation. They accounted for over 80 percent of all
buses on the road and were nearly all gasoline-powered.13/
5. The Future of Heavy-Duty Vehicles
The next decade is sure to bring changes in the heavy-duty
vehicle industry. Changes in GNP and weight and length restric-
tions may tend to slow the rate of growth of the heavy-duty vehicle
fleet. Increasing real fuel costs will certainly lead to further
development and utilization of the efficient diesel engines.
Although precise predictions are impossible, the discussion which
follows addresses some of the major factors which will affect the
size and composition of the heavy-duty vehicle fleet in the next
decade.
The GNP growth rate is expected to slow in the next decade as
compared to the 1970's, in which it slowed as compared to the
1960'b. The main reason is the energy problem. A corollary
of a declining rate of growth in GNP is a declining rate of growth
in commercial freight and, therefore, a lesser growth rate in sales
of heavy-duty vehicles to move that freight.
Another area of change which will affect the sales of heavy-
duty vehicles in the next decade is deregulation of the trucking
industry. Spurred by the trucking industry, the Federal Govern-
ment, and the fuel crisis, states should continue to move towards
uniform weight and length limitations. This will decrease the
number of miles that trucks have to travel since many unnecessary
miles are due to the differences in state regulations.15/ Trucks
today go around states where regulations are more restrictive since
that is cheaper than making two trips through the state to meet
weight restrictions or having to reload into a shorter trailer to
meet length restrictions.
Along with uniform regulations, less-strict weight and length
limits may be implemented. Double and triple-trailer rigs can
substantially reduce the gallons of fuel used per ton-mile tra-
veled. It is estimated that doubling of gross combination weight
results in more than a doubling in fuel efficiency as measured by
ton-miles per gallon of fuel. Of course these weight and length
restriction changes will continue to be debated in view of safety
and environmental concerns.
Restrictions on return trip loads should be eased. This will
reduce the number of empty backhauling trips and therefore increase
fuel efficiency.
All of the afeove regulation changes will tend to decrease the
rate of growth of the heavy-duty vehicle fleet. Trucks will carry
more freight per trip from both a weight and a volume viewpoint.
-------
-54-
Also, the number of miles per trip should decrease due to less
bypassing of overly restrictive states. On the other side of the
future heavy-duty vehicle sales equation is the fact that heavy-
duty vehicle lifetimes may tend to diminish somewhat since they
will be doing more work per hour and per mile. This will place
more stress on engines and drivetrains resulting in increased wear
and tear. Durability will become increasingly important.
The fuel crisis, while being an underlying cause of all of the
above changes, will be a direct cause of the shift from gasoline-
fueled engines to diesel engines. As mentioned previously in this
chapter, diesel engines are more fuel efficient than gasoline-
fueled engines. Coupled with the greater durability of diesels,
the fuel efficiency advantage should continue to increase the
diesel's market share.
The switch to diesels will not be as fast as the mechanical
advantages of diesels would predict. Environmental, social, and
economic concerns will prevent the extremely rapid rate of diesel-
ization predicted in some studies.12/16/ Concern over future
particulate and NOx regulations will prevent manufacturers from
fully committing to diesel production until they are confident that
such regulations can be met without adversely affecting the eco-
nomic advantage of the diesel. As more diesels are put into
use, the diesel fuel shortages may increase to a greater degree
than gasoline fuel shortages. This was demonstrated with the fuel
shortages in the spring of 1979. The specter of diesel fuel
shortages may dampen demand. Basic economics predicts that as
diesel fuel demand increases, its price will increase, vrtiich will
also remove some of the diesel advantage. Finally, lack of confi-
dence in diesel cold-start capability and maintenance availability
is still a concern with many prospective owners.
EPA is projecting that the total number of vehicles and
engines subject to heavy-duty regulations will increase signifi-
cantly in coming years, and that this increase will occur largely
in Class IIB. The primary factor in this trend will be the move by
manufacturers to re-rate some of their vehicles to GVWRs greater
than 8,500 pounds in order to make them subject to less-stringent
fuel economy and emission regulations. These vehicles will gener-
ally be heavy pickup trucks and vans vAiich are currently (or were
until recently) classified as light-duty trucks, and will typically
be equipped with V-8 engines. Should most LDTs tend to decrease in
size and GVWR due to fuel economy considerations, there will
doubtless be those vfao still require or desire the capabilities of
a larger, heavier truck. Manufacturers, then, will try both to
satisfy these customers and to re-rate these vehicles to the HDV
class. This will result in a large increase in the number of
vehicles in Class IIB (8,501-10,000 pounds).
It is expected that the dieselization of the HDV class will
continue to increase at a fairly steady rate for the years 1985 to
1989. Tables II-Y and II-Z show EPA's estimate of total, diesel,
and gasoline HDV sales for 1985 to 1989 as well as important VMT
data for the heavy-duty class.17/
-------
-55-
References
\J Federal Register, Gaseous Emission Regulations for 1983 and
Later Model Year Light-Duty Trucks; EPA; Thursday, July 12,
1979.
_2/ Rulemaking Support Paper: Light Truck Fuel Economy Standards,
Model Years 1982-1985; Office of Automotive Fuel Economy
Standards, NHTSA, DOT; December, 1979.
_3/ Ward's Automotive Yearbook, 1979.
Preliminary Regulatory Analysis: Light Truck Fuel Economy
Standards, Model Years 1982-1985, NHTSA, DOT, December, 1979.
5/ Neil M. Szigethy, "Will Diesels Dominate?" Fleet Specialist;
May/June, 1979, pp. 31-39.
6/ Regulatory Analysis: Light-Duty Diesel Particulate Regula-
tions; ECTD, OMSAPC, EPA.
JJ Draft Regulatory Analysis: Proposed Emission Regulations for
1983 and Later Model Year Light-Duty Trucks; ECTD, OMSAPC,
EPA; June 28, 1979.
_8/ Draft Regulatory Analysis: Environmental and Economic Impact
Statement for the Proposed 1982 and 1983 Model Year High-
Altitude Motor Vehicle Emission Standards; SDSB, ECTD, OMSPAC,
OANR, EPA.
9/ Federal Register, Control of Air Pollution from New Motor
Vehicles and New Motor Vehicle Engines, Submission of Altitude
Performance Adjustments; EPA; Thursday, January 24, 1980.
10/ Clean Air Act as Amended, August 1977; 202(b)(3)(C).
11/ Panel Report Number 7, Truck and Bus Panel Report, "Study
of Potential for Motor Vehicle Fuel Economy Improvement," U.S.
DOT and U.S. EPA, January 10, 1975.
12/ Interagency Study of Post-1980 Goals for Commercial Motor
Vehicles; U.S. Department of Transportation, Draft Report,
June, 1976.
13/ Motor Vehicle Facts and Figures, 1978 MVMA data.
14/ Transportation Energy Conservation Data Book, Edition 3,
February 1979, Oak Ridge National Laboratory, Table 1.26.
-------
-56-
15/ Trucking in 1995, Motor Vehicle Manufacturers Association,
Contract No. LADU 7502-C6.12, June 1975.
16/ The Impact of Future Diesel Emissions on the Air Quality of
Large Cities; U.S. EPA, Contract No. 68-02-2585, February,
1979. Also available as EPA 450/5-79-005.
17/ Regulatory Analysis and Environmental Impact of Final Emission
Regulations for 1984 and Later Model Year Heavy-Duty Engines;
U.S. EPA, OMSAPC, ECTD, December 1979.
-------
Table II-Y
Estimated HDV Sales for 1985 to 1989 1/2/3/
Teer
8,301 - 10,
Gas
000 lbs 4/
Diesel
10,001 - 19,
Gss
500 lbs 5/
Diesel
>20,000 lbs 6/
Gas Diesel
Total Gas
Ssles
Total Diesel
Sale*
Total HDV
Sale*
1989
229.275
(.82)
50,329 (.18)
68,053
(.82)
14,939
(.18)
176,672 (.28)
448,732
(.72)
474,000 (48X)
514,000 (52Z)
988,000
1988
232,490
(.84)
44,284 (.16)
69,008
(.84)
13,144
(.16)
187,502 (.30)
431,572
(.70)
489,000 (50Z)
489,000 (50Z)
978,000
1987
235,592
(.86)
38,352 (.14)
69,928
(.86)
11,384
(.14)
198.4B0 (.32)
415,264
(.68)
504,000 (52Z)
465,000 (48Z)
968,000
1906
231,109
(.M)
31,515 (.12)
68,598
(.88)
9,354
(.12)
201,296 (.34)
386,131
(.66)
501,000 (54Z)
427,000 (46Z)
928,000
1983
224,645
(.90)
24,961 (.10)
66,679
(.90)
7,409
(.10)
202,676 (.36)
355,630
(.64)
494,000 (563)
388,000 (44*)
882,000
1/ Data Resources Inc, Long Ttra leview, Spring 1980, Trendlong.
7/ Gas-Diesel splits are taken froa, "Regulatory Analyst* ami Enviromsentel Impact of Pinal Eaission Regulations for 1984 and Later Model Tear
~ Heavy-Duty Engines", U.S. EPA, OMSAPC, ECTD, December, 1979. Table III-H, extrapolated to 1989.
3/ The fractions shown in the ( ) represent the gssoline and diesel fractions of each group.
T/ 28.3X of ell HDV Sales.
7/ Classes III, IV, AMD V, 8.4* of HDV Salee.
?/ Classes VI, VII, and VIII, 63.3Z of HDV Salee. Virtually ell of the gasoline selee are in Class VI.
-------
Table II-Z
VMTDaea
Ctioline Engine 1/ Dieiel Engine XJ
CVWR
Cltai
Urban Fraction oF
Lifetime Hileajte
Average
Ufetiae 2/
Urban Fraction of
l.ifetine Mileage
Average
Lifetime 2/
Fraction of
Sale* Gat 3/
Fraction of
Relet Dieael 3/
Fercent Tot el KD
Sale* Per Glut 3/
IIB
.45
120,000
.45
120,000
.8
.2
28.3
III
.66
120,000
.46
120,000
.8
.2
5.3
IV
JW
114,000
.46
200,000
.8
.2
.9
V
.66
114,000
.46
200,000
.8
.2
2.2
VI
.75
114,000
.40
200,000
.55
.45
32.2
VII
.61
114,000
.17
475,000
0
1
5.9
VIII
.61
114,000
.17
475,000
0
1
25.2
T7 SAE Paper780430.
2/ EPA Technical Report , SDSB 79-24 and EPA eitiaatea.
T/ Base aa reference 2, Table Il-Y.
-------
-59-
CHAPTER III
TECHNOLOGICAL FEASIBILITY
As determined by the baseline test program, the mandated
75 percent reduction in NOx emissions from the uncontrolled
level resulted in a standard of 1.7 grams per brake horsepower-
hour for heavy-duty engines, and .90 grams/mile for light-duty
trucks. The ability to comply with these standards depends
firstly upon whether an engine is gasoline or diesel-fueled.
Secondly, the 10 percent AQL and full life deterioration factors
require low mileage emission targets well below the level of the
standards.
A. Low-Mileage Emission Targets
For the purposes of this analysis, the staff will use the
low-mileage emission target levels presented in Table III-A.
Hydrocarbon (HC) and carbon monoxide (CO) emission targets are
identical to those used in the 1984 Heavy-Duty Engine and Light-
Duty Truck HC and CO Rulemakings. Since NOx emissions at these
levels are related to HC and CO, it is appropriate that these
targets also be discussed.
B. Heavy-Duty Gasoline Engines
The NOx emission levels of several current technology heavy-
duty gasoline engines are presented in Table III-B. Note that the
average level of NOx emissions is not substantially lower than the
1972-73 baseline level.
It is the staff's judgement that achievement of the full
75 percent reduction, i.e., a reduction to the level of the
1.01 g/BHP-hr emission target level, is technologically feas-
ible through the application of three-way catalyst technology, and
certainly if used in conjunction with oxidation catalysts to
maintain the 90 percent HC and CO reductions. Additional NOx
control, if necessary, could also be provided by EGR. This judge-
ment is based upon a test program conducted at the EPA Motor
Vehicle Emission Laboratory in which a three-way/oxidation catalyst
system was retrofit on a 1978 IHC 404 CID V-8 heavy-duty gasoline
engine (California calibration).
A summary of the results of this test program are contained in
Table III-D. Technical specifications of equipment used in the
program are presented in Table III-E. A comprehensive discussion
of this test program will be published in a forthcoming SAE paper,
tentatively entitled, "The Application of a Three-Way Conversion
Catalyst System to a Heavy-Duty Engine," to be presented at the SAE
Congress in March 1981.
Examination of the data reveals several things. Total three-
way catalyst volume of 300 cubic inch in configuration 3 (for a
-------
-60-
Table III-A
1985 Target Emission Levels U _3/
HC CO NOx 2/
HD Gas .50 5.9 1.01
(1.3) g/BHP-hr (15.5) g/BHP-hr (1.7) g/BHP-hr
HD Diesel .89 — 2/ 1.19
(1.3) g/BHP-hr (1.7) g/BHP-hr
LD Trucks .49 5.5 .55
(.80) g/mi (10.0) g/mi (.90) g/mi
T7 Proposed NOx and finalized HC and CO emission standards are
presented in parantheses.
2/ HD diesel brake specific CO emissions are insignificant.
_3/ Targets and target derivations for NOx are extractable from
the June 24, 1980 memo from J. Wallace to J. Andersen, "MOBILE 1
Modifications and Emission Rate Assumptions for the LDT and HDV NOx
Regulatory Analysis."
-------
-61-
Table III-B
Current Technology HD Gasoline Engine NOx Emission Levels
. (Based upon the Transient test procedure)
NOx Control
Engine BS NOx Technology
1979 IHC 446 5.48 EGR
1979 IHC 345 6.46 EGR
1979 GMC 366 8.42
1979 GMC 350 6.62
1979 Ford 400 4.29 EGR
1979 Ford 370 5.54 EGR
1980 Chrysler 360 4.36 EM,EGR
(California
calibration)
1979 Chrysler 440 4.48 EM,EGR
1979 GMC 454 6.23
1979 GMC 292 9.74
1979 GMC 350 6.58
Arithmetic Mean x": 6.20
Standard Deviation: 1.70
1972/73 Baseline
Sales-Weighted Average: 6.55
Proposed Standard: 1.70
-------
Table III-C
1979 Diesel Engine Family Cercification Data
Engine
Engine
Turbo-
Inter-
After-
Inj.
Compression
Rated-
Rated
Mir.
Er.eir.e Fanily
Cycle
Charj»er
Coaled
Cooled
Timin?,
Ratio
CID
Speed
BHP
GM
4L-53T
2
X
8",10*
18.7
212
2500
155-170
GM
6L-7 IS
2
13*,15*
18.7
426
2300
164-239
GM
8V-71N
2
12\ 13"
18.7
568
2300
248-316
GM
6V-7ISC
2
10*. 13*
18.7
426
2100
160-190
GM
8V-71NC
2
12*.13*
18.7
568
2100
230-270
GM
6V-92TA
2
X
X
10*.14*
17.0
552
2100
300- 35
GM
SV-71TA
2
X
X
12", 14*
17.0
568
2100
350
GM
8V-92TA
«">
X
X
n'.n*
17.0
736
2100
435
c-:i
6L-71T
2
X
11\14*
17.0
426
2100
260-275
CEC
091 (SH 230,250) 4
19*
15.8
855
2100
220- 40
CEC
092A
4
X
19*
15.0
855
1900
293
CEC
0S2C
4
cr.c
093E(STC 350,
400) 4
X
X
19*
14.1
855
2100
400
cue
I72A(VTB 903,
350) 4
X
903
350
CEC
I72C("
" ) t,
X
21*
16.6
903
2100
275
CrX
!v2i> (r;r 450)
H
X
!8.5*
15.5
1150
2100
450
cue
193 (KTR 600)
4
X
X
18.5*
14.5
1150
2100
600
CEC
221 (V555)
4
22*
17.0
555
3300
216
CEC
222 (VT225)
4
X
22*
16.2
555
3000
225
use
DT-466
4
X
16*
16.3
466
24-2600
210
iiic
4
16*
19.1
551
2800
180
IHC
DTI 4652
4
X
X
15*
16.3
466
2600
210
1979
Certification SuRl SwRI
13-Mode 13-Mode Transient
ECS*
NOx
NOx NOx**
FM
7.2
—
8.2
—
7.7
TD, SPL
8.2
TD, SPL
7.2
T0, SPL
7.9
7.58 5.83
TD, SPL
6.5
TD. SPL
7.0
TD, SPL
9.4
—
7.9
AFC, SPL
8.7
SPL, AFC
8.7
5.76,7.81 4.91<5)(E);6.98(7.44)
SPL
7.8
AFC, SPL
7.5
6.93 5.74(6.33)
AFC, SPL
8.6
AFC, SPL
9.7
—
8.7
—
8.3
FM, SPL
8.4
5.96 5.67(5.90)
PCV
-
FM, SPL
6.4
5.69 5.56(6.67)(E)
-------
Table III-C (Cont'd)
1979
Certification SwRI SwRI
Engine Engine
Turbo-
Inter-
After-
In j .
Compression
Rated
Rated
13-Mode
13-Mode
Transient
Mfr.
Engine Family Cycle
Charger
Cooled
Cooled
Timing
Ratio
CID
Speed
BHP
ECS*
NOx
NOx
NOx**
Hack
8 (ETZ 1005) 4
X
18*
15.0
998
2100
354
SPL
8.7
Mack
9 (ENDT 676) 4
X
X
19*
14.99
672
18-2100
283-315
SPL
7.9
6.11
5.25 (6.73)
Mack
10 (ETAZ(B)1005A) 4
X
X
17*
17.0
998
2100
392
SPL
7.9
Mack
11 (ETZ 675) 4
X
18*
17.0
672
2100
235
SPL
8.2
Mack
SIB (ETZ 4T7B) 4
X
15*
15.5
475
2400
210
SPL
8.1
Cat
3 (3208) 4
16*
16.5
636
2800
160-210
—
8.3
Cat
4 (3306) 4
X
12*
17.5
638
2200
250
FRC, SPL
5.7
Cat
'9 ( 3406) 4
X
10*
16.5
893
2100
325
AFRC,
SPL
6.8
Cat
10 ( 3406) 4
X
X
10*
16.5
893
2100
375
AFRC,
SPL
5.7
5.13
5.12 (5.41)
Cat
11 (3406) 4
X
28*
14.5
893
2100
300- 25
AFRC,
SPL
9.0
Cat
12 (3408) 4
X
X
11*
15.3
1099
2100
450
AFRC,
SPL
5.8
Cat
13 (3208) 4
16*
16.5
636
2800
200
EGR
6.3
Cat
14 (3306 ) 4
X
X
8.5*
17.5
638
2200
245
AFRC,
SPL
4.8
Cat
IS (3408) 4
X
28*
14.5
1099
2100
400
AFRC,
SPL
7.4
Cat
16 (3406) 4
X
X
26.5*
14.5
893
19-2100
350- 80
AFRC,
SPL
8.7
7.20
7.41 (8.41)
Cat
17 (3408) 4
X
K
28*
14.5
1099
2100
450
AFRC,
SPL
6.6
Average: 7.66 6.46 3.83 (6.64)
* ECR > Exhaust Gas Recirculation
FM » Fuel Modulator
TD » Throttle Delay
AFC ¦ Air Fuel Control
AFRC ¦ Air Fuel Ratio Control
PCV • Positive Crankcase Ventilation
SPL * Smoke Puff Limiter
ECS » Emisson Control System
** CVS bag-sanpled NOx and, in parenthesis, dilute continuous sample. Where one of the two saapling techniques was not used, an
approximation is given based upon the observed average (1.2) ratio of the two methods, and is indicated by an (E).
-------
-64-
Table III-D
Heavy-Duty Three-Way Catalyst System,
IHC 404 Test Program
1984 FTP
Weighted
Test Condition/ Weighted Reference
Configuration BSHC BSCO BSNOx BSFC BHP-hrl/4/
1. Baseline configuration:^/ 2.31 65.25 4.68 .732 11.717
2. Feedback carburetor,
one air pump, no EGR,
dummy catalysts -
- Open loop WOT,_7/
medium feedback
response :_6_/
- Closed loop WOT,
medium feedback
response:
3.58 50.96 7.81 5/ .692
11.527
4.24 51.05 7.85 .685
10.355
3. Feedback carburetor,
three-way catalysts,
dummy oxidation cata-
lysts, one air pump,
no EGR -
- Open loop -
- fast response. 0.76
- medium response: 1.36
- Closed loop -
- fast response: .94
- medium response: 1.28
4. Feedback carburetor,
three-way and oxida-
tion catalysts, one
air pump, no EGR -
- Open loop -
- fast response: .87
- medium response: .67
- Closed loop
- medium response: .84
21.35 0.70 .682 11.405
23.71 1.52 .705 11.467
18.46 .76 .701 10.128
17.13 1.44 .697 10.566
5.66 2.24 .787 11.527
4.35 1.98 .697 11.527
3.14 1.83 .728 10.355
5. Feedback carburetor,
three-way and oxida-
tion catalysts, two
air pumps, no EGR, open
loop, fast response: .92 4.24 1.95 .726 10.665
-------
-65-
Table III-D (cont'd)
1984 FTP
Test Condition/
Configuration 8/
6. Feedback carburetor,
three-way catalysts,
dummy oxidation cata-
lysts, no air pump,
medium response,
open loop lean F/A
sett ing:9J
- EGR:
- no EGR:
7. Feedback carburetor,
three-way and oxidation
catalysts, one air
pump, medium response,
open loop:
- EGR:
- no EGR:
BSHC
.94
1.21
.84
.97
BSCO
9.72
12.14
2.95
3.11
Weighted
BSNOx BSFC
3.01
3.68
.704
.665
1.13
1.78
.713
.673
Weighted
Reference
BHP-hr1/4/
11.297
11.297
10.795
10.795
T7The reference BHP-hr is derived from the engine map and
reflects the WOT power available in a given configuration.
If Standard carburetor, single air pump, four dummy catalysts,
EGR operational.
3/ Interesting emission differences were obtained between con-
figurations 1 and 2. Transient HC was higher in all eight cycle
segments (NYNF, LANF, LAF, NYNF, NYNF, LANF, LAF, NYNF) for con-
figuration 2. Highly transient CO (as evidenced by the NYNF
segments) was approximately twice as high for configuration 1,
(suggesting that the additional air injection in configuration 2
eliminated much of the CO generated during fuel-enriched accelera-
tions). High power CO (as evidenced by the LAF segments) was
approximately 17 percent lower in configuration 1 than configura-
tion 2, however, resulting in roughly equivalent total test CO.
Inconclusively small variations were noted in transient NOx in the
eight cycle segments. The parasitic effects of four dummy cata-
lysts were higher than those attributable to an additional air
pump, as evidenced by the differences in reference BHP-hr and BSFC
over the cycle.
-------
-66-
Table III-D (cont'd)
kj Actual BHP-hr for all teats, predominately attributable to
control system calibration, ranged from -62 to +1.52 deviation
from the reference. The emission effects of this variation are
negligible.
5/ Note the increase in NOx and fuel economy with the addition of
The feedback carburetor and the elimination of the EGR.
6/ The feedback carburetor was equipped with remote instrumen-
tation which would allow controlled variations in the rate of
response of the closed-loop F/A control system. Slow, medium, and
fast responses (representing 5.0, 2.8, and 0.2 seconds) were
tested. For the most part, the medium response setting was used.
The slow settin gproduced virtually identical emissions performance
with the medium, but the fast response would sometimes produce
observeable driveability problems (i.e., oscillatory throttle
pumping).
7/ The feedback carburetor was equipped with a microswitch which
if desired could open the feedback F/A control loop at wide open
throttle and permit power enrichment. Both closed loop and open
loop WOT configurations were tested.
8/ Each separate configuration, plus open vs closed loop WOT
calibration with each configuration, was mapped separately for the
purpose of reference cycle generation.
9/ The nominal F/A setting used in all other tests was changed to
a leaner setting for this test series.
-------
-67-
Table 11I-E
Technical Specifications: IHC 404 Three-Way Test Program
Three-Way catalysts: Two, 151 C ID monolithic, 50 grams/ft-*
loading, platinum-rhodium ratio of 5:1,
(manufactured by Englehardt), Corning sub-
strate of 300 cells/in^.
Oxidation catalysts: Two, 113 CID monolithic, 50 grams/ft^
loading, platinum-palladium ratio of 4:1,
(manufactured by Englehardt), Corning sub-
strate of 300 cells/in^.
Feedback carburetor: Holley 2210 modified for experimental use by
Holley Carburetor Co., Division of Colt
Industries, for stoichiometric closed-loop,
idle and main-jet operation. Engelhardt
design microswitch on throttle, activated
during the last approximate 9 degrees of
throttle movement prior to wide open throt-
tle, provided fixed 4.5 percent CO (A/F ratio
¦ 12.8) in place of conventional power
valve.
Logic Box: Holley Model 8 experimental type designed and
built with adjustable
- set point (AF ratio)
- response time
- AC gain
- wide open throttle A/F ratio
- cold start override
Oxygen sensor: Standard passenger car sensor, Production R.
Robert Bosch, No. 0258001001
Air pump capacity: Each pump delivers 7.21-8.30 CFM @1000 pump
RPM and 1.6 inches Hg backpressure, (IHC no.
446746-C92, 461369-C91).
-------
-68-
catalyst/engine volume ratio of 300/404 = .74) was sufficient to
reduce NOx emissions below the proposed standard, marginally
effective at HC control, and not sufficient to reduce CO emissions
to below the 1984 standard. (Note the better results with the
fast response system, i.e. the more accurately the F/A ratio is
controlled, the more effective the three-way catalyst is for HC and
NOx control). The addition of oxidation catalysts (configurations
4, 5 and 7), intended primarily for CO control, did indeed reduce
CO well below the low mileage emission target (LMT), reduced HC to
within very close of the HC LMT, but presumably resulted in the
formation of additional NOx.
Two approaches were then taken to achieve additional NOx
control: abandonment of the oxidation catalysts while operating at
a leaner F/A ratio to maintain HC and CO control (configuration 6),
and reactivation of the EGR for use in conjunction with the feed-
back control and catalyst systems (configuration 6 and 7). As is
evident from Table III-D, the nominal F/A setting, both sets of
catalysts, air injection, and EGR reduced HC and NOx emissions to
well below the standard (but not quite the low mileage targets),
and reduced CO well below the target levels. These reductions were
achieved while simultaneously reducing brake specific fuel consump-
tion (i.e., improving fuel economy) by 2.6 percent relative to the
1978 baseline engine configuration.
There are two highly poignant facts to be made about this
engine. First of all, the 404 is one of the larger heavy-duty
gasoline engines sold, and therefore puts out more exhaust feedgas
through the catalysts, making it more difficult than most to
achieve emission control. The feedback control circuit was no more
than a bench version of simple feedback loops curently used in a
majority of the light-duty vehicle fleet. (Indeed, this was the
experimental set-up used in the early testing of prototype three-
way catalyst systems for light-duty vehicles.) There is no reason
to believe this data is unrepresentative of the engine, or any
heavy-duty engine, or any of the emission control apparatus and
strategies available to the industry. The ability of the engine to
attain low emission levels even when the feedback carburetor
circuit was overridden (i.e., allowed power enrichment) at wide-
open-throttle, thereby allowing full power and rich driveability,
indicate that a three-way system can offer acceptable full power
performance for the heavy-duty market.
Secondly, EPA considers the attainment of these low emission
levels to be especially significant given the complete lack of
internal engine design refinements made to the 1978 baseline
engine. The emission control hardware used and the design of the
baseline engine represent an unoptimized, quick-fix system, incor-
porating few of the refinements and electronic control capabilities
already used in the light-duty fleet. Table III-F lists potential
design improvements which can further reduce emission levels and
optimize fuel economy for heavy-duty gasoline engines. The
cumulative effect of these changes to the engines and emission
-------
-69-
Table III-F
Heavy-Duty Gasoline Engines
Potential Engine Design Improvementa
A. Update design of intake manifold
- increase exhaust cross-over heat
- reduce thermal mass of cross-over heat region
- improve A/F distribution between cylinders
- reduce any tendency for fuel to puddle in manifold
- fuel injection (indirect means of improvement)
B. Improve combustion chamber design
- reduce HC emissions
C. Reduce fuel flashing during deceleration
- fuel shut-off during deceleration with either
carburetor or fuel injection
- utilize fuel injection
- increase operating region of throttle kicker during
deceleration
D. Improved EGR
- incorporate improved EGR control techniques
- increase EGR flow (to meet 1.7 g/BHP-hr standard)
E. TWC catalyst/control system
- more compact "Y" in exhaust pipe
- locate exhaust gas sensor closer to exhaust manifolds
-------
-70-
control systems will probably result in an integrated electronic
control module similar to that which has evolved for passenger car
engines, resulting in the precise and optimum control of F/A
ratio, EGR flow, and ignition timing for emissions control, fuel
efficiency, and driveability. EPA plans to conduct further
testing with heavy-duty gasoline engines, in particular in the
area of comprehensive electronic engine controls, prior to Final
Rulemaking.
In summary, these test results indicate to EPA that the 1985
HC, CO, and NOx low mileage targets are achievable. EPA does not
consider the non-attainment of low mileage emission targets for HC
and NOx by an unoptimized, hobby-shop prototype to be significant.
Rather, the attainment of emission levels well below the standards
for all pollutants in the absence of internal engine design im-
provements is especially indicative of the feasibility of compli-
ance .
Three-way system hardware durability over the full useful
life of the engine is a major factor in the overall question of
feasibility. Table III-G lists certification deterioration factors
from 1980 light-duty vehicles for both three-way and oxidation
catalyst systems. Note that three-way NOx df's are higher than the
NOx df's of oxidation catalyst systems. This is to be expected,
however, since deterioration of NOx reduction capability exists
in three-way systems. The staff's concern is the relationship
between today's light-duty and tomorrow's heavy-duty deterioration,
e.g., can three-way catalysts and oxygen sensor durability be made
adequate in the heavy-duty environment?
With this NPRM EPA is proposing allowable maintenance in-
tervals of 100,000 miles (essentially the full life) for oxygen
sensors, catalysts, and feedback control loop components, in-
cluding electronics. Technology for attainment of this full life
durability for the large part must still be developed. The Agency
desires these proposals to be technology-forcing, however.
Furthermore, many of these components are currently being studied
in the field in LDV's, providing in-use data. Given several years
lead time until 1985 the Agency believes that adequate time and
data resources are available to allow these technological hurdles
to be cleared, unless conclusive proof to the contrary is made
available.
In summary, three-way catalyst systems, and certainly if
used in conjunction with oxidation catalysts and EGR, appear
capable of achieving all low mileage emission targets in 1985. The
staff believes that greatly increased durability can be achieved
for future heavy-duty three-way systems if the motivation exists to
develop them.
In the absence of three-way technology, the ability of
a heavy-duty gasoline engine to achieve the appropriate NOx
emission target of 1.01 g/BHP-hr is another matter. Strategies
-------
-71-
Table 11I-G
Light-Duty Catalyst System
Certification Deterioration Factors
Number of vehicles in
the data base:
Average 5OK mile NOx
deterioration factor:
Range:
Standard deviation:
Three-Way System
Only
49
1.05355
.476-2.321
.2711
Oxidation System
Only
102
.96015
nc u
NC 1/
T7Hot computed.
-------
-72-
such as compression ratio reduction, spark retard, and increased
EGR rate - or any strategy intended to reduce combustion tem-
perature - will also decrease combustion efficiency and fuel
economy to the point where the control strategy is unacceptable.
The industry is specifically requested to provide data on the
maximum NOx reductions achievable without three-way systems and the
resultant fuel economy effects in their comments to this proposal,
along with their comments on three-way system technology and its
applicability to the heavy-duty market.
C. Heavy-Duty Diesel Engines
NOx emission results from transient testing of heavy-duty
diesel engines appear in Table 1I1-H. Two average emission levels
are presented, representing the two different measurement tech-
niques .
Table III-H presents 13-mode certification data for 1980
HD diesel engines certified for sale in California, where emission
standards are stricter (see Table III-I).*
Upon examination of this data, four observations can be
readily made:
1. At least on the 13-mode test, NOx emission levels
for 1980 engines sold in California are 38 percent lower than
those sold nationwide. (It is presumed that 1980 Federal engines
are not substantially different from 1979 Federal engines; the
majority are carryovers.)
2. Sixty-two percent of Federal diesel engine families
are not sold in California, under any calibration.
3. No observed NOx emission levels are even close to the
presumed 1.19 g/BHP-hr low mileage emission target.
4. Only one engine family incorporates NOx control tech-
nology (EGR - Caterpillar Family 13) over and above timing changes.
With regard to observation 1, it should be noted that al-
most no transient data is available at the 13-mode NOx emission
levels of 4-5 gm/BHP-hr seen in California and conclusions based
upon 13-mode data must be qualified. At the present NOx emis-
sion level of 6-8 g/BHP-hr (13-mode), transient NOx is generally
in the same ballpark. Based upon experience with other pollu-
tants, however, it can be argued that certification to a low
transient standard is more difficult than certification to a
numerically equivalent 13-mode standard.
* Note that deterioration factors are not calculated in Cali-
fornia. Low mileage emissions are the determining factor in
certification testing.
-------
-73-
Table III-H
1980 Nox Levels for Diesel Engines
Certified for Sale in California (May 1980)
Manufacturer Engine Family
Caterpillar
12
13
14
16-C
NOx
ECS
EGR
1980
Certification
NOx 1/
4.7
4.8
5.2
4.1
Transient
NOx 2/
Cummins
09 3G
092
3.7
4.7
Detroit Diesel
8V-92TA
6L-71TA
8V-8.2
6V-92TA
4.9
5.2
5.0
4.9
IHC
DT-466B
DTI-466B
4.2
4.9
Mack
11
10
12
5.2
5.7
4.1
4.61 (5.15)
Average: 4.75
17 Obtained from telephone conversation with CARB.
1] Bag-sampled, and in parenthesis, continuous dilute inte-
grated .
-------
-74-
Table III-I
1980 Federal and California Emission Standards
(grams/BHP-hr)
HC HC + NOx
Federal 1.5 10.0
California 1.0 6.0
-------
-75-
Observations 2 and 3 relate to the effectiveness of current
control strategies in reducing NOx emissions. Injector timing
retard has achieved moderate emission reductions in California,
although some adverse consequences of using this strategy are
indicated by the small fraction of engine families available
for sale (38 percent of the total available in the forty-nine
states). Furthermore, no emission levels on current technology
diesels even approach the 1.19 g/BHP-hr design target. The primary
problem with large timing retard is its excessive degradation of
engine fuel economy. Alone, injection timing retard is at best an
unattractive strategy, and most likely an impossible one for NOx
emission reductions approaching the mandated 75 percent. The
fact that timing retard is the only strategy applied to date,
however, by no means indicates that further NOx reductions are
unattainable through use of other technologies.
GGR has been proven to be an effective controller of NOx
emissions. Three potential drawbacks have been noted to EGR for
heavy-duty diesels, however: reduced fuel economy (or conversely,
less available power), increased particulate emissions, and de-
creased engine durability due to particulate recirculation within
the combustion chamber. Comparative fuel economy and EGR dura-
bility data are not available for the Caterpillar 3208-Family 13
from EPA Certification Records. (The only fuel usage data pre-
sented in the Part I materials is for full-power durability
testing, and the EGR is programmed not to operate at full power,
i.e., the full-power durability testing does not indicate EGR
effects.) Caterpillar has made available* transient emission data
for both Family 3 and 13 3208's - identical in every respect except
for the presence of EGR on 13. This data, based upon averaged
results of multiple tests, is presented below:
Transient Emissions (g/BHP-hr)
HC
CO
NOx
Part.
3208
(3)
.83
3.43
9.5
.66
3208
(13-EGR)
.58
3.93
4.8
.99
Based upon this data, a 50 percent decrease in NOx and a 30 percent
decrease in HC were achieved, while particulate emissions rose by
50 percent, relative to the non-EGR version.
From the limited data the Agency has in hand, we note that
EGR does indeed increase particulate although we must note that
probably no design consideration was given to particulate control.
Light-duty diesels will be subject to a stringent NOx standard and
a particulate standard by 1982, and much of the research and
development for controlling and trading-off these pollutants in the
light-duty area is well underway. EPA sees no reason why this
* In a 23 July, 1980 letter to S. Martin of SwRI.
-------
-76-
technology cannot be transferred to the heavy-duty sector, although
we recognize that the heavy-duty emissions cycle is altogether
different from the light-duty cycle in terms of transience and
load factor, and will induce different design, calibration, and
performance criteria, as will the heavy-duty marketplace itself.
With such little data available in the area of NOx/particulate
interrelationships, we cannot conclude that an increase in partic-
ulate as NOx levels are lowered with EGR is representative of what
is achievable given research time and effort to address the prob-
lem. Furthermore, although experience tells us that increased EGR
rates adversely affect fuel economy, the magnitude of this trade-
off at a given NOx level is engine dependent and can be optimized
by other technologies (e.g., increased aftercooling) to offset the
impact of additional NOx control. Finally, EPA has no data to
substantiate the claim that durability is adversely affected by
EGR. In short, EPA considers EGR a viable NOx control strategy
capable of substantially reducing NOx emissions, and is not con-
vinced that EGR is inapplicable to heavy-duty diesels. Realis-
tically, however, the adverse impacts of EGR - most importantly
fuel economy and performance - will not be correctable sufficiently
to allow EGR alone to achieve anything near the 1.7 g/BHP-hr level.
Injector timing retard has been the universal NOx control
strategy to date, but one whose future potential is limited to
complementing other control strategies, although improvements in
the technique are possible. For example, variable injector timing
has been developed. The Agency has little knowledge of its effec-
tiveness at NOx control in actual comparative testing. It is
reasonable to presume, however, that since static injector timing
has such a significant effect on NOx emissions, variable timing
will not only allow NOx control, but may also eliminate some of the
fuel economy tradeoffs associated with highly retarded static
t iming.
This injection optimization over many different speed/load
combinations is also made possible by electronics. Electronic fuel
pumps, incorporating electronic control of fuel injection based
upon engine speed and load, and incorporating high pressure fuel
injection have the potential for optimizing the combustion process
for emissions and fuel economy. The electronic pump controls
injection timing, duration, and fuel flow, and optimizes each
parameter under all engine operating conditions. At least one
manufacturer has developed a working prototype. Electronic control
of EGR rate is another strategy yet to be incorporated on heavy-
duty diesels, and represents the next step beyond mechanically-
variable EGR rates. In short, the field of electronic controls -
which already have revolutionized the light-duty fleet and which
will certainly be carried over into the heavy-duty gasoline engine
fleet - is a control strategy which EPA believes will permit
significant NOx reductions to be realized at minimum penalty.
Engine modifications are another option available for NOx
control. These modifications would be intended to reduce the high
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combustion temperatures and pressures conducive to NOx formation,
or to make the engine more adaptable to increased rates of EGR.
Engine modifications in the past, in particular injector modifica-
tions, have had primary success at HC control, although several
have been noted to be potentially effective on NOx. For example,
more efficient turbochargers, higher pressure fuel injection and
new fuel delivery systems, torque rise limiters, low overlap
camshafts, and optimized methods of charge cooling (aftercooling)
could all either reduce peak combustion temperatures and thus limit
NOx, or perhaps permit sufficient increases in engine efficiency to
negate fuel economy losses due to increased NOx control using more
direct strategies (e.g., EGR and timing retard). The NOx reduction
capabilities of engine modifications are uncertain, however, and
will most likely be used to complement other control strategies.
More radical, less developed, and perhaps more problematic
techniques for NOx control have also been advanced.
The concept of alternate fluid injection into the combustion
chamber, in particular water, appeared in the technical literature
years ago, but no production system has even been developed. The
key to this lack of development effort have been the availability
of other alternatives, the lack of a true need (i.e., a tight NOx
standard), and perceived problems of cylinder corrosion, engine
durability, practicality of consumer use of a "dual fuel system,"
and storage problems of pure water in extremes of cold. However,
water injection has been found to be both effective at reducing
peak flame temperature due to its high heat capacity (the secret of
EGR's effectiveness), and to be advantageous to efficiency by
allowing higher compression ratios with only small amounts of
water. Although water injection is presently precluded by the
above technical problems, not to mention the drawback of requiring
periodic consumer attention Co maintain effectiveness (i.e., water
tank fill-ups), it remains a technological option yet to be fully
explored. One study* took a Mack ETAY (B)673A engine, equipped it
with an APE fuel pump, and fed water directly into the pump to
produce a water/fuel macroemulsion just prior to injection. Using
a mixture of water and diesel fuel (30 percent water by mass),
13-mode NOx decreased by 24 percent, and particulate decreased by
54 percent while fuel consumption (with and without water) remained
constant. At least on a laboratory test basis, the technique is
highly effective, with no adverse effects on fuel economy or other
pollutants.
Besides alternate fluid injection, the concept of alternate
fuels for combustion is receiving increasing attention in the
technical literature. Methanol, ethanol, and other fuels, either
* "Effect of Six Variables on Diesel Exhaust Particulate," by K.
Springer, et al., ASME Report No. 80-DGP-42, presented at Energy
Technology Conference and Exhibition in New Orleans, February 3-7,
1980.
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in pure form or in blend with conventional fuels are being studied
primarily as extenders or substitutes for petroleum-baaed fuels. A
spin-off from use of these fuels, however, are environmental
benefits. For example, EPA is currently testing a prototype diesel
engine at the Southwest Research Institute in San Antonio. A Volvo
TD100C (6 cylinder, 586 CID) diesel engine has been modified to run
both on alcohol fuel and alcohol/diesel blends and will be tested
on the transient cycle for gaseous and particulate emissions using
a variety of fuels. Preliminary steady-state data is encouraging:
13-Mode Emissions (g/BHP-hr)
Fuel
HC
CO
NOx
Part.
Diesel #2
.51
2.06
8.08
Unknown
100% methanol
1.27
2.97
5.50
0.00
100% methanol
.16
.22
4.98
0.00
w/ oxidation
catalyst
The diesel-fueled version's EPA certification emission levels
are presented, while the 100 percent methanol-fueled version was
calibrated for optimum fuel economy (at 24° BTDC timing) and tested
at Volvo's lab in Sweden. Volvo has informed EPA that retarding
the timing to 19" BTDC would certainly lower NOx below the 5.0
g/BHP-hr level. Note also that methanol fuel emits no particulate
emissions. For this reason, an oxidation catalyst can be used if
necessary to further reduce HC and CO; this data ls also presented
above. The potential for a workable NOx reduction catalyst for
methanol-fueled diesel engine has yet to be pursued.
Another fact is worth noting about methanol. Water is
entirely soluble in methanol and all the potential benefits
of water injection for NOx control are available. Furthermore,
cold weather storage of methanol/water mixture is much less
troublesome than cold weather storage of pure water. Methanol/
water blending could easily be done either at the pump or at the
refinery.
The major drawback to these alternative fuels is current
availability, both at the pump and at the refinery. Methanol can
be extracted from coal and bioraass, of which plentiful supplies
exist, but the investments in equipment and capital needed for
large scale production have not yet been made. Given adequate
refining capacity, distribution to the pump should be no more
difficult than the introduction of unleaded fuel was in the mid-
1970' s. EPA considers methanol and methanol blends to be a valid
strategy for emission control - one with significant potential for
environmental and conservation benefits, but one which has yet to
be actively pursued by government and industry.
One manufacturer has been investigating catalytic reduction of
NOx from diesel engines through exhaust aftertreatment. Catalytic
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-79-
treatraent of exhaust is standard technology in the gasoline engine
field, but the particulate missions stemming from diesel engines
have precluded the use of any solid catalyst system to date on
diesels. (Particulates and soot quickly coat the solid catalytic
surfaces and deactivate them,) To promote a catalytic reduction of
NOx, the manufacturer has studied the approach of injecting
a gaseous reducing agent directly into the exhaust - in particular,
gaseous ammonia (NH3) in conjunction with a zeolite or vanadium
catalyst. The by-products of a perfect reduction reaction are
harmless - diatomic nitrogen and water. A prototype system in-
stalled on a tractor trailer was demonstrated for EPA personnel,
and engineers claimed that at least 50 percent reductions in NOx
emissions at the tailpipe (i.e., exclusive of engine modifications
and other control techniques) are routinely achieved. This tech-
nique, however, is hardly perfected and has several drawbacks.
First of all, a "perfect" reduction reaction depends upon a finely
controlled introduction of ammonia into the exhaust in proportion
to exhaust mass flow; a Less than perfect control results in either
a loss of effectiveness at NOx control or introduction of gaseous
ammonia - an unregulated emission with its own adverse health
impacts - into the ambient air. Design of an adequate, reliable,
and tamperproof injection control system is a hefty technological
challenge. Furthermore, questions about catalyst durability in the
diesel exhaust environment have yet to be answered. Finally, and
perhaps most importantly, the amount of ammonia necessary to handle
the typical diesel exhaust flow is high enough to require frequent
fill-ups, requiring regular consumer attention and expense for the
maintenance of a system not vital to the day-to-day functioning of
the vehicle. EPA has never deemed adequate any control system
which requires constant consumer maintenance to remain effective.
This, and the subsequent need to provide adequate ammonia supplies
at nationwide service stations and truck stops, cast serious doubts
on the future viability of this technique.
To summarize EFA's analysis of the technical options for
heavy-duty diesel NOx control, it is EPA's belief that NOx control
technology in production today, in comparison with the control
techniques applied to LD gasoline vehicles and applicable to HD
gasoline engines, has not been developed to its maximum potential.
In most part, this lack of development of refined control tech-
niques stems from a lack of a need to develop them. The 1985 NOx
standard will provide that need. The staff believes that sig-
nificant HOx reductions are possible for heavy-duty diesel engines
using a variety and combination of techniques. The Agency is
committed to the intent of the Clean Air Act, i.e., that the
maximum NOx reductions achievable "without increasing cost or
decreasing fuel economy to an excessive and unreasonable degree" be
realized through a good faith effort on the part of the industry to
achieve them.
-------
-80-
D. Light-Duty Trucks - Gasoline
Table III-J presents data from actual certification tests
conducted at EPA's Motor Vehicle Emissions Laboratory on 1980
Federal and California light-duty trucks. The sales-weighted
average NOx emission level of 1980 light-duty trucks is approxi-
mately 1.50 g/mi for all fifty states; a 63 percent reduction is
required to meet a low mileage emission target of .55 g/mi.
The lowest 1980 4K NOx emission level observed in an actual
test at the EPA laboratory was .70 g/mi on a Volkswagen Bus (engine
family 11, 120 CID, California calibration) with three-way cata-
lyst, closed-loop feedback carburetor, and no EGR.
The light-duty vehicle NOx standard for 1981 is 1.0 g/mi (40
percent AQL, 50,000-mile useful life). The light-duty vehicle
standard is very close to the proposed light truck standard. One
production truck has achieved a low mileage emission level halfway
between the proposed standard and the presumed target level using a
three-way catalyst system but no EGR, i.e., additional control
possible. Admittedly this is only one vehicle, but light-duty
trucks currently certify to a 2.3 g/mi standard and there has been
no need in the past to design to lower NOx levels. Technology is
already on the market today to allow light-duty vehicles to achieve
a 1981 1.0 g/mi standard. Light-duty trucks should be able to
comply with a .9 g/mi standard by 1985, despite the proposed
changes to the AQL and useful life definition, if such a standard
is deemed appropriate relative to that for light-duty vehicles.
The prime system candidate will likely be a three-way catalyst
system with feedback carburetor with electronically controlled
spark timing. EGR and dual bed catalysts may be necessary on
larger GVW vehicles, but not on the majority.
E. Light-Duty Trucks - Diesel
Both General Motors and Volkswagen applied for and received a
waiver from the 1981 LDV 1.0 g/mile NOx standard for diesel-pow^red
vehicles. In their waiver submission it was claimed that excessive
fuel economy and durability penalities were realized using EGR as
the prime emission control system at a 1.0 gram/mile level. A two
year extension with a two year review was granted by the Agency to
allow development of new technology. In short, technology-foTcing
development work on advanced methods of NOx control is already
underway and the results of that work will no doubt be applicable
to light-duty diesel trucks in 1985. Certification to a .9 g/mile
NOx standard will be possible, although tradeoffs associated with
this level are uncertain. The staff sees no reason why, within the
time frame of these proposed standards, technology will not be
developed to minimize adverse consequences of a tight NOx standard
for LDT diesels.
-------
Table III-J
Sales Weighted (by Current Sales) Emission
Contributions of 1980 Federal and California LPT Fleets
Sales-Weighted 4K
4K Emissions (Fed./Calif . ) Emissions (Fed./Calif.)
Comparative
Families (Fed./Calif.)
HC
CO
NOx
HC
CO
NOx
AMC BT9A1/B76C1
.42/.
18
5.62/2.47
1
.50/1.30
.0039/.0017
.0523/.0230
.0140/.0121
AMC CT3A1/CT4W1
.42/.
36
9.52/5.64
1
.70/1.25
.0101/.0087
.2294/.1359
.0410/.0301
AMC CT3H1/CT4W1
.67/.
40
6.35/4.43
2
.00/1.41
.0095/.0057
.0902/.0629
.0284/.0162
AMC HT3A1/HT3V1
.84/.
33
7.07/3.35
1
.65/1.19
.0050/.0020
.0424/.0201
.0099/.0071
AMC NT3A1/NT3A1
.64/.
37
13.00/9.50
1
.51/1.84
.0161/.0144
.3276/.2394
.0381/.0464
Chrysler 225 BCP/BXP
.58/.
23
11.00/1.81
1
.60/1.28
.0149/.0059
.2827/.0465
.0411/.0329
Chrysler 318/360 BFP/BCP
.55/.
30
10.35/7.90
1
.18/1.45
.0215/.0117
.4047/.3089
.0461/.0567
Ford 4.9 NA/ND
.72/.
24
6.90/4.15
1
.46/1.75
.0567/.0189
.5430/.3266
.1149/.1377
Ford 5.0 NA/NB.NG
.60/.
35
6.89/3.53
1
.58/1.58
.0805/.0469
.9239/.4734
.2119/.2119
GM 08K4G/08K4AA
.54/.
41
12.74/5.18
1
.30/1.50
.1230/.0934
2.9010/1.180
.2960/.3416
Nissan TL20F/TL20C
.67/.
21
9.25/2.59
1
.57/1.13
.0167/.0052
.2302/.0645
.0391/.0281
Mitsubishi G52TF/G5TC
.45/.
23
5.61/3.26
1
.60/1.15
.0045/.0023
.0555/.0323
.0158/.0114
Toyo Kogyo OMAT/OMAT
.40/.
24
6.23/2.37
1
.49/1.10
.0042/.0025
.0654/.0249
.0156/.0116
Toyo Kogyo 0WBT/0WBT
.30/.
24
7.14/2.54
1
.56/1.20
.0024/.0019
.0578/.0206
.0126/.0097
Toyota 2F(F)/2F(C)
.47/.
23
9.11/3.25
1
.75/1.30
.0012/.0006
.0237/.0085
.0046/.0034
Toyota 20R TF/TC
.93/.
17
12.18/1.99
1
.77/1.17
.0183/.0033
.2399/.0392
.0349/.0230
VW 37PF/37PC
1.30/.
20
6.09/1.47
1
.70/1.20
.0034/.0005
.0158/.0038
.0044/.0031
IHC V304/V304
.61/.
65
4.72/4.98
1
.75/1.36
.0029/.0031
.0222/.0234
.0082/.0064
IHC V345/V345
.57/.
78
5.52/6.80
1
.50/2.00
.0030/.0041
.0293/.0360
.0080/.0106
IHC 4-196/4-196
.50/.
55
6.80/8.90
2
.00/1.70
.0008/.0009
.0109/.0142
.0032/.0027
Isuzu AITB/AITC
1.40/.
23
13.00/3.51
1
.80/1.14
.0249/.0041
.2314/.0625
.0320/.0203
Total =
.4235/.2378
6.779/3.1466
1.0198/1.0230
Adjusted
Totals* =
Federal:
.61
9.80
1.47
California:
.34
4.55
1.48
1983
Federal Targets:
.49
5.50
1.40
1985
Federal Targets:
.49
5.50
.55
* Adjusted for sales not represented. The sales represented by the Federal families presented here are 69
percent of the total.
-------
1^/jJUaP 4 F (^ 82
CHAPTER XV
ENVTROWMENTAT. TMPAET
A. Introduction
In this chapter we will examine the environmental effects
which can be expected from implementation of the proposed regul-
ations. The evaluation will proceed on the basis that the stand-
ards are achievable for all truck classes. This assumption is most
important for heavy-duty diesel engines, where the feasibility of
attaining the standard has yet to be established. As we shall see,
heavy-duty diesels contribute a major share of the benefits of this
proposal.
By way of background, the impact assessment begins with
a review of health and welfare effects which are associated
with NOx emissions. . After that, emissions data on various known
sources of NOx will be presented. Projections of future NOx
emissions in the absence of the standards contained in this
proposal will also be made. Since some NOx air quality problems
are localized (e.g., exceedances of the national ambient air
quality standard in urban areas) while others are very broad in
scope (e.g., acid rain), both the nationwide emissions and a
smaller subset of regions with relatively high ambient NOx con-
centrations will be presented.
Following the presentation of the baseline emissions data, the
impact of the proposed emission standards will be evaluated.
Average reductions on a lifetime per-vehicle basis, reductions in
the overall emissions inventory and air quality impact of the
reductions will be considered. The environmental assessment will
conclude with a brief review of potential secondary environmental
impacts.
B. Health Effects
The adverse health effects of exposure to oxides of nitrogen
(or any other pollutant) are a function of such variables as
the concentration and duration of exposure, the state of health
of the subject(s) being exposed, and the synergistic effect
of other substances or environmental factors which may be pre-
sent. Due to these influencing factors, an absolute determina-
tion as to the adverse health consequences of NOx exposure is
difficult to determine. Numerous studies have, however, been
undertaken to qualify and to the extent possible quantify these
effect#.
The primary. form in which HOx is emitted into the atmosphere
if nitric, oxide (NO). NOj 1.a also emitted in gas turbine and
diesel exhaust in smaller amounts. -However* NO2 is formed mainly
by the .oxidation of N6 in the atmosphere in a complex set of
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chemic^l pathways involving hydrocarbons and ozone. Ultimately NO2
is also oxidized to nitric acid gas and small nitrate particles.
Therefore, the population is exposed to a variety of nitrogen
containing compounds as a result of vehicle exhaust emission of NO
and NO2 and the atmospheric transport and transformation of these
substances.
An analysis of pertinent studies indicates that exposure to
ambient concentrations of nitric oxide (NO) and nitrites results in
no direct health effects. Exposure to atmospheric nitrate may
result in increased asthmatic attacks but definite conclusions can
not be drawn from data developed to date. There is, however, a
significant data base associating nitrogen dioxide (NO2) with a
number of health effects. The following discussion will revolve
around NO2 and its associated health effects.
In the following discussion it is important to note the
elevated atmospheric concentrations of NO2 have been measured
in the United States. Peak 1-hour NO2 concentrations equalling ...
or exceeding 750 ug/m^ (0.4 ppm) were experienced ^^1975-6
in Los Angeles" artel several other California sites; AsETnnT;
Kentucky and Port Huron, Michigan. For the same period, Phoenix,
Arizona; St. Louis, Missouri; New York City, N.Y.; 14 additional
California sites; Springfield, Illinois; Cincinnati, Ohio; and
Saginaw and Southfield, Michigan have all reported 1-hour values
equal to or greater than 500 ug/m^ (0.27 ppm). Hourly values in
excess of 250 ug/m-* (0.13 ppm) NO are quite common nationwide.
Annual arithmetic mean values of 100 ug/m^ are reported in several
California sites; Chicago, Illinois; and Southfield, Michigan. As
will be discussed later, these values are expected to increase in
the future.
These observed levels can now be compared with studies
establishing the existence of human health effects of NO2 and the
exposure time over which responses were observed.
1. Effects on Humans
a. Controlled Clinical Studies
Human clinical studies have generated extensive information on
the lowest dose levels for induction of respiratory effects by
single short term NO2 exposure. Such studies have been performed
both with healthy adults and with individuals with chronic respira-
tory problems, e.g., asthmatics and bronchitics.
For healthy individuals, increased airway resistance and other
physiological changes suggesting impaired pulmonary function have
been clearly demonstrated with single 2-hour exposures to NO2
concentrations of 3,760 to 13,200 ug/rn^ (2.5 to 7.0 ppm) in a
number of studies (Yokoyama, 1972; von Niedinjg, 1977; Beil and
Ulmer, 1976). On the other hand, a number of studies have reported
no statistically significant effects on pulmonary function for
-------
-84-
2-hour exposures to 1880 ug/m^ (1 ppm NO2) or lower concentrations
(Hackney, 1975; 1978; Beil and Ulmer, 1976; Folinsbee, 1978). One
study found increased airway resistance with a 10 minute exposure
to a varying level of NO2 ranging from 1300 to 3800 ug/nH (0.7
to 2.0 ppm) (Suzuki and Ishikawa, 1965). Exposure levels were
reported to have varied during the study, however. The results
reported are averaged for ten subjects and may have reflected a
response averaged over several exposure conditions. The results
are, therefore, difficult to interpret.
Several studies have reported clinical results on pulmonary
function changes with combinations of NO2 and other pollutants.
Suzuki and Iskikawa (1965) suggest recovery time from NO2 ex-
posure is delayed when SO2 and O3 were simultaneously dosed.
However, Hackney (1975) found no significant influence of 940
ug/m^ (0.5 ppm) NO2 on minimal level ozone response. Horvath
and Folinsbee Q3790 report no greater than additive effect of
combined exposur^^&f 940 ug/m^ NO£ (0.5 ppm) and 980 (0.5 ppm)
ug/m^ O3.
Several studies have been reported using bronchitic or
asthmatic subjects. Studies by von Nieding et al. (1971; 1973)
show that, in persons with chronic bronchitis, concentrations of
7500 ug/nH (4.0 ppm) and 9400 ug/m^ (5.0 ppm) produced decreases in
arterial partial pressure of oxygen and increases in the difference
between alveolar and arterial partial pressure. Exposures to NO2
concentrations above 3000 ug/m^ (1.6 ppm) for 30 inhalations
produced significant increases of airway resistance in this study,
but no statistically significant changes were formed below 2800
ug/m^. Thus, results for bronchitic and healthy individuals appear
to differ little.
Orehek (1976) reported that exposures to 190 ug/m^ (0.1
ppm) NO2 increased the sensitivity of 13 out of 20 asthmatics
to the broncho constricting agent carbachol. Considerable con-
troversy exists regarding the interpretation of this study and the
health significance of the increased response to a bronchocon-
strictor.
Kerr (1979) has reported measurements of pulmonary func-
tion in 13 asthmatics and 7 bronchitics dosed with 940 ug/m^ (0.5
ppm) NO2 for two hours. Small but statistically significant
changes in two of the measured parameters were found when the two
groups were analyzed together but no significant differences were
found if each group was analyzed separately. The authors state the
results are generally negative and the small statistically signi-
ficant changes could have been caused by chance alone. Conclusive
statements regarding the status of asthmatics cannot be made at
this time.
b. Epidemiological Evidence
Studies of the effects of air pollution on community health
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-85-
are usually complicated by the fact that many pollutants are
present at the same time and that their concentrations usually vary
in the same way because of weather influences. Generally, the most
that can be obtained from such studies is a general association
between health effects and the ambient concentrations of a given
mixture of pollutants or, sometimes, with subtractions of the
mixture.
Community studies on the effects of NO2 prior to 1973 are of
questionable validity due to the use of the Jacobs-Hocheiser
technique in measuring the atmospheric concentrations of NO2.
Community exposure studies most often cited in NO2 health
effects discussions are summarized in Table IV-B. Most of these
consistently tend to show that the reported daily mean concentra-
tions or peak values of NO^, alone or in combination with other
pollutants has no significant effects on lung function in the
exposed population.
An exception is Kagawa and Tayama (1975) study of 20 eleven
year-old school children which showed some correlations between
either maximum expiratory flow rate or specific airway conduance
and NO2 concentration levels. Reported NO2 levels ranged from 40
to 360 ug/m^ (0.02 to 0.19 ppm). However, the reported NO2 data
were insufficient to permit quantitative association of NC>2 levels
with pulmonary function decrements.
Pearlman, et al. (1971) reported frequency of lower respira-
tory disease in schoolchildren in Chattanooga, Tennessee. Bron-
chitis rates were significantly greater in areas characterized as
having high NO2 levels than in lower level areas. However,
clearcut estimates of NO2 level are not available. v
M 6*4 Af-/ t An-t //'/ /An~<
Several recent studies have suggested that small chijftlren are
at special risk from N02-induced increases in respiratory disease.
These studies are summarized in Table IV-C. Melia, et al (1978)
reported that average NO2 levels were 136 ug/m^ (0.072 ppm) NO2 in
homes using gas cooking stoves and 18 ug/m^ (0.01 ppm) in homes
with electric ranges. Melia, et al (1977, 1979) subsequently
demonstrated increased symptom and respiratory illness rates among
children living in homes with gas stoves.
Supporting evidence of these effects are also found in
the reports of Florey, et al. (1979) and of Goldstein, et al.
(1979). Speizer, et al • (1980) have recently reported a study
of 8,120 children in 6 different communities which show a signi-
ficant relationship between a history of serious respiratory
illness before the age of 2 and the use of gas cooking ranges in
the home. Concentrations estimated in this study range from
39-111 ug/m^ (0.02 to 0.06 ppm) annual average for gas ranges
and 17.6-95.2 ug/m^ (0.02 to 0.06 ppm) for electric ranges. . j
-------
Table IV B EFFECTS OF EXPOSURE TO NITROGEN DIOXIDE ON PULMONARY FUNCTION IN COMMUNITY STUDIES
N02 Exposure
Concentrations Study
Measure M9/m3 PP"> Population Effect Reference
Los Angeles:
Median hourly NO^
90th percentile NOg
Median hourly 0x
90th percentile 0x
San Francisco:
Median hourly NOg
90th percentile NOj
Median hourly 0^
90th percentile 0W
130
250
65
110
0.07
0.13
0.15
0.15
0.35
0.06
0.02
0.03
205 office
workers 1n
Los Angeles
439 office
workers In
San Francisco
No differences in most tests. Linn,
Smokers in both cities showed et al.
greater changes in pulmonary (1976)
function than non-smokers.
-------
Table IV li(continued)
N02 Exposure
Concentrations
Measure
pg/m3
ppm
Population
Effect
Reference
Mean "annual,,b 24-hr
103 ~
0.055 +
Pulmonary
No difference in various pul-
Spelzer
and
concentrations: high
92 SO,
0.035
function
monary function tests.
Ferris,
exposure area
£
S02
tests admin-
istered to
1973
low exposure
75 ~
0.04 ~
128 traffic
Burgess
et al
area
36 SO,
0.014
policemen in
1973
SY
0.14
urban Boston
1-hr mean:
260
and to 140
high exposure
to
to
patrol officers
area
560
0.30
in nearby sub-
low exposure area
110
to
170
0.06
to
0.09
urban areas.
High exposure group:
Annual mean
24-hr concentrations
90th percentile
Est1mat|d 1-hr
maximum
Low exposure group:
Annual mean
24-hr concentrations
90th percentile
Estimated 1-hr
maximum
96
188
480
to
960
43
113
225
to
430
0.051
0.01
0.26
to
0.51
0.02
0.06
0.12
to
0.23
Nonsmokers No differences In several ventil-
Los Angeles atory measurements Including spi-
(adult) rometry and flow volume curves
Cohen et al.,
1972
Nonsmokers
San Diego (adult)
-------
Table IV B(contlnued)
N02 Exposure
Concentrations Study
Measure pg/m3 ppm Population Effect Reference
1-hr concentration 40 0.02
at time of testing to to
(1:00 p.m.) 360 0.19
20 school During warmer part of the year
children (April-October) N0_, 50- and
11 years of TSP* significantly correlated
age with V * at 25% and 50* FVC*
and wltfi specific airway con-
ductance. Temperature was the
factor most clearly correlated
with weekly variations 1n
specific airway conductance with
V at 25% and 50% FVC.
Significant correlation
between each of four pollutants
(H0_, HO, SO., and TSP) and
Vmax at 25% ®nd 50% FVC but
no clear delineation of pollu-
tant concentrations at which
effects occur.
Kagawa and
Toyaita,
1975
Kagava et al.
1976
'Estimated at 5 to 10 times annual mean 24-hour averages
bMean "annual" concentrations derived from 1-hour measurements using Saltzman technique
*FEV0.75: Forced expiratory volume, 0.75 seconds
V : Maximum expiratory flow rate
max
FVC : Forced vital capacity
TSP Total suspended particulates
-------
TAdLE IV C F.FFF.TTS ( F EXPOSURE TO NITROGEN DIOXIDE V. l'KE HOWE ON
THE 'NCIDF.NCE OF ACl'TE RESPIRATORY DISEASE IN EPIDEMIOLOGY STUDIES INVOLVING GAS STOVES
Pollutant'
NOz
Concentration
Mg/n3 ppn
Study
Population
Effects
Reference
Studies of Children
NO, plu(
otfier gas stove
combustion products
NO. concentration
not Measured at
tine of study
2554 children from hones
usinit nas to cook compared
to 3204 children froa hones
using electricity. Axes
6-11
Bronchitis, day or night cough,
aorning cough, cold going to cheat,
wheeze, and asthaa increased in
children in hones with gai stoves
Nelia et al., 1977
HOj plus other gas
NO, concentration
4827 children
Higher incidence of respiratory
Nelia et al., 1979
stove combustion
not awasured in
ages S-10
symptoms and disease associated
products
same homes studied
with gas stoves.
N02 plus other
Kitchens:
808 6- and 7-year-olds
Higher Incidence of respiratory
Florey et al., 1979
gas stove
9-596 (gas) 0.005-0.317
illness in gas-stove homes
Coaq>anion paper to
combustion
11-353 (elec) 0.006-0.188
Nelia et al., 1979;
products
Bedrooas:
7.5-318 (gas) 0.004-0.169
6-70 (elec) 0.003-0.037
(by triethanolamine
diffusion saaplers)
Goldstein et al.,
1979
M>2 plus other
gas stove
conbustion
products
NOj plus other
gas stove
conbustion
products
Saaiple of households
24 hr avg gas
(.005 - .11 ppn)
electric (0 - .06 ppn)
outdoors (.015 -
.05 ppn) several peaks
> IU0 |i(/a (1.0 ppn)
aoniloring location not
reported 24-hr avga
by Modified Jacobs •
Hochheiser (sodiuis
arsenite); peaks by
cheniluminescence
128 children 0-5
346 children 6-10
421 children 11-15
No significant difference
in reported respiratory
illness between hones with gas
and electric stoves in children
from birth to 12 yesrs
Mitchell et al., 1974
See alio Keller et al.,
1">79
Sample of sane
households as reported
above but no new
monitoring reported
174 rhildren under 12
No evidence that cooking mode
is associated with the incidence
of acute respiratory illness
Keller et al., 1979
-------
TASIJF.IV C(rortt inurrO
Concentration
PoUutant
SOj plua other
(is itcve
ccnabuation
product*
V*tn*
PP«
Study
Population
9S pmtatllr of
24 hr jv* in ¦rtlvit;
JOB* J1 - 116
t.Dl - ,061n ((>1)1
17. S - 95,2 iig/m*
(.01 - ,os) (elecl:
frequent [>riin
" 1100 »t/n
(0.4 rP") nil pttk
IJ*0 MH/'i"
(] .0 nn); !* * Kr ky
mdtrtvd todiun
¦ri«nlc# peakt bf
chnl limine scenre
B.1J0 children 6-10
6 different CDfaunjtokio( wtth
H>| amrlitnl with an Increatt
in rraoursttft diunic
Keller, et al., 19T9
I")j pjua other
(as U»w
product!
Set (iMc above
for aurni tar inn
Nmhrri of 461 household*
Wo significant difference in
reported respiratory illne**
among abulia in gas vs electric
cooking hoatei
WlrkMI, et al., 11K
See alao Keller et al.
|Q!«
KOj plus other
Itow
rnmJmi tian
products
5w table above
for Iwnltaiinit
Henhera of 120 household!
No aiRnlficant difference in
acute reapiratocy disMtr
InrUrnrr |t"" »• electric
ronhtiiR hAirn nanni ailulln
Keller et at., 1"9
-------
-91-
Frequent peak values for gas ranges were approximately 1100 ug/m^
(0.6 ppm).
A number of studies involving adults showed no significant
relationship between gas ranges and respiratory disease (Mitchell,
et al., 1974; USEPA, 1976; Keller, et al., 1979). Also two of
these studies have reported no significant correlation between
respiratory illness and gas stove use in children under twelve
(Mitchell, 1974; Keller, et al., 1979). However, both these
studies used far fewer subjects than either the Melia or Speizer
studies. Consequently, it appears that respiratory disease in
children is associated with the presence of NO2 and other gas
stove combustion products in homes. The NO2 exposures represent
annual averages in the order of 54 ug/m^ (0.03 ppm) with frequent
short-term exposures to levels of about 1100 ug/m^ (0.6 ppm).
Results of animal experiments with NO2, cited below, have
demonstrated that repeated short-term exposure to NO2 increases
susceptibility to infection to some microorganisms as much as
continuous exposures to the same concentration. NO2 exposures
causing increased infection from streptococcus have been observed
across a wide range, beginning at 940 ug/nP (0,5 ppm) for repeat-
ed exposures over a 90-day period.
Taken together with the gas range studies, these results
suggest that humans, especially children, may be subject to an
increased risk of respiratory disease because of repeated exposures
to NO2. Levels at which these responses are first observed are
exceedingly difficult to establish with certainty. The variety of
data sets involving human exposures seems to converge close to 940
ug/m^ (0.5 ppm).
c. Lethal Dose
Accidental exposure to high concentrations of NO2 has estab-
lished the fatality level from acute exposures at 282 mg/m-* (150
ppm) and above.1/ Although such high levels are far above ambient
concentrations, they do demonstrate the potential toxicity of
N02.
2. Effects on Laboratory Animals
Experiments performed on animals have long been an important
scientific tool since they allow the experimenter greater flexi-
bility than human studies. As they relate to the adverse health
effects of NOx exposure, animal studies have provided information
on maximum tolerated doses, helped define target organs, and
established clues as to the mechanisms of damage. Anatomical
differences among the various species explain why identical expo-
sures can cause diverse pathological disturbances. Such differ-
ences make it difficult to apply results of animal studies to human
health implications. The effects on laboratory animals therefore
-------
-92-
should be considered as a supplement to human studies as opposed to
a more in lieu usage.
The Nayapnal Academy of Sciences has conducted a literature
review of NCJx-related laboratory animal studies.W The following
f\ is a dj^cussion of the significant findings of that review.
A -^Pathologic abnormalities (such as ciliary loss, alveolar cell
/j i-' idisruption and bronchiole obstruction) occur in mice and rats after
I continuous exposure to 0.94 mg/m^ (0.5 ppm) NO2. Higher concen-
/ trations cause more severe cellular and structural damage, which in
the rabbit and rat resembles emphysema.
I if
9 Physiologic alterations (such as rapid respiration, increases
in airway resistance, decreases in tidal volume and in static
compliance) occur in nonhuman primates, and rodents after exposures
of 2 months or longer to 9.4 mg/m^ (5.0 ppm) or higher NO2 concen-
trations. Decreases in blood oxygenation occurs in rabbits
after continuous exposure to 15 mg/vfi (8 ppm) NO2. These data
did not include measurements of small airway function nor the
effect of exercise and are therefore not considered comprehensive.
The most sensitive index of pollutant-induced damage in
laboratory animals is a reduced resistance to infection. Continu-
ous exposure to 0.94 mg/m^ (0.5 ppm) and higher NO2 concentrations
for 3 months and intermittent daily exposures for 6 months or
longer diminishes murine resistance to pulmonary bacterial in-
fection. Similar results in nonhuman primates occur from exposures
to 9.4 mg/m^ (5.0 ppm) NO2. Such decreases in resistance to
infection have caused pneumonia and death. Mice exposed for less
than 24 hours to NO2 concentrations of 3.8 mg/m^ (2.0 ppm) also
develop defects in pulmonary defense mechanisms.
Prolonged exposure to NO2 at concentrations below 0.94 mg/ra^
(0.5 ppm) has produced no detected adverse effect on normal ani-
mals. Synergism with carbon monoxide, ozone, or sulfur dioxide has
not been established. Mortality occurs at NO2 concentrations of 75
mg/m^ (40 ppm).
C. Welfare Effects
1. Effects on Materials
The National Academy of Sciences reports that oxides of
nitrogen, principally nitrogen dioxide and airborne nitrates can
have deleterious effects on textile dyes, natural and synthetic
fibers, and metals.J^/ Such damage can be very costly at the
consumer level; for example, over $100 million annually are spent
by the American public due to fading of textile dyes by nitrogen
oxides.If This section will discuss the material-damage aspects of
nitrogen oxides.
-------
-93-
a. Fading of Dyed Fabrics
Among the fabrics most susceptible to fading by nitrogen
oxides are cellulose acetate, cotton, viscose rayon, permanent
press polyester, and nylon. The degree of a fabric's sensitivity
to fading is primarily a function of that fabric's color and its
ability to absorb NOx. Since blue dyes commonly used are chemi-
cally vulnerable to nitrogen dioxide, shades which contain these
dyes, even in small amounts, are especially susceptable to NOx
induced fading.
One technique used to combat this problem involves special
dyes which inhibit the fading action by NOx. These dyes, referred
to as Class A dyes, are more costly to produce than their more
standard counterparts, Class B dyes. Class A dyings of acetate
fabrics, for example, cost an additional 4.4 cents per meter.W
The net monetary loss caused by nitrogen oxide fading of dyes on
acetate is estimated to be $52.8 million per year, $22.05 million
for cotton fabrics and $21.6 million for viscose rayon.1/
Several studies have been undertaken to determine the exposure
conditions most conducive to dye fading ._1/ From them, the fol-
lowing conclusions can be made: 1) higher temperatures and rela-
tive humidities increase dye fading; 2) dye fading on cotton,
rayon, and cellulose acetate can take place within 3 months at a
nitrogen dioxide concentration of 380 micrograms per cubic meter
(0.2 parts per million) ;5_/ 3) sulfur dioxide accelerates the fading
process, but by itself produces no change.
In addition to causing certain dyes to fade, NOx is also
responsible for the yellowing of white fabrics. In a study by
Salvin,^/ 18 white fabrics were examined for yellowing. Of the 4
pollutants tested (sulfur dioxide, nitrogen dioxide, ozone, and
hydrogen sulfide), nitrogen dioxide was the only one determined to
play a role in yellowing. An overview of the significant NOx
related results of this study is in Table IV-D.
b. Effect on Fibers
Nitrogen dioxide can have deleterious effects on cotton
fibers. In a study by Morris et al., cotton yarn samples were
exposed in two cabinets open to sunlight.7/ In one cabinet, air
was filtered to remove nitrogen dioxide, while the second contained
unfiltered ambient air. Results of three separate 28-day exposures
indicated that unfiltered air deteriorated cotton yarn to a greater
extent than filtered air. Sunlight was found to accelerate the
reaction between air pollutants and the fibers.
Derivatives of nitrogen oxide* (acidic aerosols) contribute to
the weakening of cotton and nylon fibers.1/ Since approximately 18
percent of all fibers are used for industrial applications, the
safety implications of debilitated cords, tarpaulins, etc. are
important.
-------
-94-
Fiber
Table IV-D
Yellowing of Whites by Nitrogen Dioxide 6/
Concentration
of Pollutant
Exposure
ug/m^ ppm Time Effect
Rubberized
Cotton
Spandex
Acetate
Optical
brightener
Nylon
Optical
brightener
Nylon
Anti-Stat
finish
Cotton
Cationic
softener
Chamber
Chamber
Chamber
Chamber
376 0.2 16 hr Yellowing of
anti-oxidant
376 0.2 8 hr Action on
fiber
376 0.2 8 hr Yellowing
Chamber 376 0.2 16 hr Yellowing
High Humidity
Chamber 376 0.2 16 hr Yellowing
Eigh Humidity
376 0.2 16 hr Yellowing
-------
-95-
c. Effect on Metala and Alloys
The annual cost of air pollution induced metal corrosion is
estimated to be $1.5 billion.8/ Although it is generally accepted
that of the major air pollutants sulfur oxides play the most
important role in metal corrosion, nitrogen oxides can also be
portentious. Nitrogen oxides can accelerate the rate of corrosion
of certain metals and alloys through electrochemical reaction
associated with NOx derived acids and salts.
Nickel-brass (an alloy composed of nickel, copper and zinc) is
especially vulnerable to air pollution induced corrosion. Nickel-
brass wire springs used in telephone equipment in the Los Angeles
area have failed within 2 years of installation.9/ Upon investiga-
tion it was found that the springs were covered with a dust layer
rich in nitrates. Bell Laboratories later determined that the
nitrates, which had accumulated on surfaces adjacent to cracks were
responsible for the failures. The combination of atmospheric
moisture and nitrates yields a solution that can selectively leach
zinc from the nickel-brass alloys.1/
Stress-corrosion problems with nickel-brass components have
also been reported elsewhere in California, and in Texas and New
Jersey as well as the cities of Philadelphia and New York.10/ Bell
Laboratories also reported a different type of NOx-related cor-
rosion problem which was noticed in such places as Cincinnati,
Cleveland, Detroit, Los Angeles, New York, and Philadelphia.^/ The
nickel bases of palladium-topped contacts of crossbar switches
corroded, forming products which covered the palladium cap of the
contact. This resulted in electrically open circuits. Investiga-
tions concluded that the corrosion was promoted by the presence of
anions, principally nitrates in accumulated dusts.
2. Visibility
Visibility degradation is perhaps the most noticeable effect
of air pollution on today's society. It is caused by the scatter-
ing and absorption of light by gases or particles in the atmos-
phere. In addition to the adverse effects previously delineated,
oxides of nitrogen and their daughter nitrate particles can play a
significant role in reducing visibility.
Nitrogen dioxide (NOj) is the only gaseous species present
in the atmosphere in high enough concentration to adversely affect
visibility through light absorption (primarily in the longer
visible wave lengths - the blue range).11/ This phenomena is
manifested in many major cities as a reddish-brown haze. In an
unpolluted atmosphere visibility can be calculated to be approxi-
mately 26Q kilometers (visibility being reduced from a theoretical-
ly infinite line of sight by the inherent capability of gas mole-
cules to scatter light, making the sky blue). The presence of 0.05
parts per million NOj, the National Ambient Air Quality Standard
for this pollutant, can reduce visibility from the 260 kilometer
level to 41 kilometers, an 84 percent reduction.11/12/
-------
-96-
As mentioned above nitrate particles can also affect visi-
bility. The primary mechanism whereby this occurs is particle
scattering. Particles whose radii lie in the 0.1 to 1.0 micrometer
range are the most efficient at scattering as this size range
corresponds to the wave lengths of visible light,Y\J Some typical
particles in this size range (and up to 2.0 micrometers in dia-
meter) include sulfates and organic compounds such as condensed
hydrocarbons and oxidized organic matter.13/ By contrast such
particles as soil and tire dust, road debris, fly ash, and airborne
products of rock-crushing have little influence on scattering
(except in the case of rare dust storms). 13/ The degree to which
nitrates scatter light is, however, as yet undetermined due to the
lack of data on particulate nitrate concentrations in ambient air.
3. Acid Precipitation
Acid precipitation is currently one of the most talked about
adverse consequences of industrialization. Figure IV-A shows the
growth of this phenomena in the eastern U.S. over the past 25
years. Born from the marriage of combustion products, principally
sulfur dioxide (SO2) and oxides of nitrogen (NOx), and atmos-
pheric water vapor, it is capable of eliminating life from streams
and lakes, leaching vital nutrients from soil, and causing physical
damage to plants. What follows is a discussion of "acid rain" (as
it is commonly called), its causes, history, and effects.
a. Background
In order to understand the ramifications of acid rain, it is
helpful if one is familiar with certain concepts of chemistry. For
example, the degree to which a solution is acidic is typically
expressed in terms of its pH. The pH scale ranges from 0 to 14,
with 7 representing neutrality. Values above 7 indicate greater
alkalinity (more basic) while values below 7 represent increasingly
acidic solutions, the lower the pH the higher its acidity. Mathe-
matically; the pH of a solution is determined by taking the nega-
tive logarithm of the effective hydrogen ion (H+) concentration.
The fact that the pH scale is logarithmic is an important one
since, for example, a solution whose pH is 4 is 10 times as acidic
as a solution whose pH is 5, and 100 times more acidic than a pH 6
solution.
Precipitation is defined as acidic if its pH is below 5.6, a
level representative of "normal" precipitation.15/ Figure IV-A
shows that in 1972-73 precipitation in all areas of the eastern
U.S. was below 5.6. Precipitation with a pH of 4.22 or lower was
reported in parts of Pennsylvania, New York, Vermont, and New
Hampshire. Widespread areas from Maine to Indiana to North Caro-
lina had precipitation as low as 4.30 pH. Acid precipitation is
not limited to the east coast. Data from the San Francisco Bay
area indicate that the pH of precipitation has decreased from 5.9
in 1957-1958 to 4.0 in 1974, and seems to be correlated with the
NO" concentration.^/ In Boulder, Colorado the pH of precipita-
tion has dropped from 5.43 to 4.63 over a three year period.16/
-------
FIGURE ™-a. THE WEIGHTED ANNUAL AVERAGE OF pH OF PRECIPITATION
IN THE EASTERN UNITED STATES IN 1955-56 AND 1972-73.m/
-------
-98-
Th e baseline 5.6 value is slightly below neutral due primarily
to the formation of carbonic acid (H2CO3) frotn dissolved carbon
dioxide (C02).17/ Other substances present in the atmosphere can
shift the pH Tn either direction. Certain soil particles and
ammonia gas, a natural product of decaying organic matter, can lead
to a higher pH (more basic). Their influence, however, is often
negligible when compared to the pH lowering potential of such
man-made atmospheric emissions as sulfur and nitrogen oxides.
These combustion products lead to the formation of sulfuric (H2SO4)
and nitric (HNO3) acids, two very strong acids.
Although sulfuric acid is the dominant acid in acid precipi-
tation, the role of nitric acid is becoming more significant;
Figure IV-B, which shows sulfur and nitrogen oxides emissions in
recent years, supports this conclusion. Further, analysis of
rainwater samples indicates that currently, nitric acid is respon-
sible for about 30 percent of the excess acidity.17/
b. Effects
Acid rain can dramatically alter the ecology of lakes. The
susceptibility of a lake to acidification is not only a function of
the amount and strength of acid precipitation falling on its
watershed, but also the ability of the watershed to buffer (neu-
tralize) acid precipitation. The buffering capacity of a region
reflects the type of bedrock and/or the type of unconsolidated
deposits such as glacial till present. Generally speaking, areas
where large amounts of calcium are present are good buffers.
Figure IV-C shows regions in North America sensitive to acidifi-
cation. It is an unfortunate coincidence that many areas receiv-
ing highly acidic precipitation, e.g. the Adirondacks, are also
weak buffers.8/
One of the most dramatic effects of acid rain has been declin-
ing fish populations in many lakes and the elimination of fish-life
from others. In the Adirondack Mountains 50 percent of the lakes
above 600 meters elevation have pH values below 5.0.14/ Of this
fraction, 90 percent are void of fish; in the 1929-1937 time frame,
only 4 percent of the same lakes had a pH below 5.0 or were devoid
of fish.14/ The exact mechanism(s) whereby fish are adversely
affected by acidic water is (are) not completely understood, but it
has been suggested that it interferes with the metabolism of
certain vital elements.19/ Table IV-E shows the pH values which
have been demonstrated to render certain fish species unable to
reproduce.
Acid rain can also have significant affects on the plant
kingdom. Among the more direct effects are necrosis (tissue
death), loss of leaf area, and accelerated loss of chemical ele-
ments from foliage.21 / As acid rain flows over (and through) the
watershed it can leach important nutrients from the soil and thus
affect the health and growth of many plant species.22/ Lowered
soil pH has the tendency of increasing the availability of poten-
tially toxic metals to plants, 23/ and of creating conditions which
-------
-99-
Figure IV-B
Nationwide Emission Trends For
Nitrogen Oxides and Sulfur Dioxide 7/
-------
-100-
F±EprecipSationRI8/anSN°rth America with fakes that ar* sensitive to acidification by acid
-------
-101-
Table IV-E
Approximate pH at Which Fish in the La Cloche
Mountain Lakes, Canada, Stopped Reproduction 20/
_EL
Species
Family
6.0 to 5.5
Small mouth bass
Micropterus dolomieui
Walleye
Stizostedion vitreum
Burbot
Lota lota
Centrarchidae
Percidae
Gadidae
5.5 to 5.2
Lake trout
Salvelinus namaycush
Trout'perch
Percopsis omiscomaycus
Salmonidae
Percopsidae
5.2 to 4.7
Brown bullhead
Ictalurus nebulosus
White sucker
Cato3tomu8 commersoni
Rock bass
Ambloplites rupeatris
Ictaluridae
Catostomidae
Centrarchidae
4.7 to 4.5
Lake herring
Coregonus artedii
Yellow perch
Perca flavescens
Lake chub
Couesius plumbeus
Salmonidae
Percidae
Cyprinidae
-------
-102-
favor fungal rather than bacterial populations.24/ Since bacteria
are responsible for carrying on the process whereby nitrogen and
certain nitrogen containing compounds present in the atmosphere are
fixed to soil in a form usable by most plants (nitrification),
acid rain could inhibit this process.24/ A decline in bacterial
populations could also adversely alter rates of decomposition and
remineralization of essential elements for plant growth.24/
In addition to ecdsystem-and biologic-related effects, acid
precipitation can also cause damage to certain materials. Among
those reported to be affected by acid precipitation are; steel,
copper, linseed oil, alkyd paints on wood, antirust paints on
steel, limestone, sandstone, concrete and both cement-lime and lime
plaster.25/ High acidity promotes corrosion because hydrogen ions
act as a sink for electrons liberated during the corrosion pro-
cess.26/ When one considers the wide range of applications of
those materials, the potential economic, safety, and cultural
onsequences pi acid precipitation induced damage are forboding.
Jasoline Emission Inventory—- . /. y-
— fls
Previous sections of thit!* chapter have discussed the effects
of NOx in the envi^ppmept ,/^fln order to relate those discussions to
the 11 ifii 1 sin mm 1iai"g J g"*' light- and heavy-duty trucks, we
need to examine the contributions which these vehicles make to the
overall emissions of NOx./' ^We will look -f^st at the nationwide
inventory, and then examine a smaller subset of that inventory.
cot
T
1. Nationwide Emissions
fa
The base year which has b$en chosen for nationwide analysis is
1977. The total natioi»
-------
-103-
Table IV-P
Nationwide Emissions of
Oxidea of Nitrogen for 1977 27/
NOx Emissions
Source Category
(1000 torts)
Light-duty vehicles
4,015
Light-duty trucks
944
Heavy-duty gas
828
Heavy-duty diesel
1,506
Off highway vehicles
1,109
Railroads
760
Marine and Air
291
Total Mobile Sources
Stationary Sources
9,454
12,321
Total All Sources
21,775
-------
-1 OA-
Table IV-G
Fractional Portions of Nationwide Emissions
of Oxides of Nitrogen for 1977
Percent of
Mobile Source Percent of
Source Category Emissions Total Emissions
Light-duty vehicles 42 18
Light-duty trucks 10 4
Heavy-duty gas 9 4
Heavy-duty diesel 16 7
Off highway vehicles 12 5
Railroads 8 4
Marine and Air 3 1
All Mobile 100 43
Stationary 57
All Sources 100
A JL-i- Un,
-------
-105-
H\a t " :
the same for all counties. In fap£, btr a eaunty by -ccmitj basis,
mobile source contributions cluprer around the area ^presenting x &
j .-55-95 percent of total. For Approximately half of aft Tmm l/l® 8,
— mobile sources represent 83 percent or more of the tp^taj. N(Jjr
l emissions. The mean DjMeent of the emissions for all coWt"xS3vaue
qK to mobile sources ia( /^/percent. Comparison of this result with
the 43 percent which mobile sources contribute to the total nation-
wide inventory indicates that the highest county friactions occur in
counties with relatively low total NOx emissions^ — """"" ^ ^
A majority of the counties in the jygfftOffiride inventory are
free of violations of the NAAQS for NO^ (0.(W^pm annual mean).
Those regions experiencing such violatiot!S7~"or near that level,
- will be examined more closely later. Levels near or above the
' NAAQS are important from the viewpoint of health effects and
/; j j relatively localized welfare effects (e.g., plant damage). How-
ry ever, for very broad scale effects, particularly the acid rain
problem discussed earlier, the NAAQS cannot be used as a satis-
factory indicator. Even though the NAAQS is met in most places,
acid rain is a serious and growing problem, and the portion of that
problem due to NOx emissions is substantial. To combat this
problem it will be necessary to obtain emission reductions of SOx
and NOx, wherever they are reasonably available. Light-duty
^ j? trucks, heavy-duty gasoline-fueled trucks and diesel trucks are
in*
* -p
. source categories where significant reductions can be made.
f Figure IV-D presents estimated projections of the growth in
nationwide NOx emissions from the 1977 base year to 1999. The
projections represent what is considered the base case, to be
used as a reference in evaluating the proposed regulations. The
base case projections, therefore, do not include the light-duty .
truck or heavy-duty vehicle standards of this proposal. Rather,/fob
NOx emission standards for these vehicles are assumed to remain a ffa** *
the ilevelc^of the <1383 light-duty truck standards and 1980ieavy-
duty) engine standards^ 'for' other Aoutfce categories, known future
rol programs are included.28/
Two sets of projections are given in Figure IV-D, one labled
"low growth rates" and one labled "high growth rates." These two
sets of projections are based upon growth rate data developed
in connection with the analysis being done by EPA of the NO2
ambient air quality standard.28/ At this time EPA expects that
actual future growth rates witT probably follow closer to the low
growth assumptions than the high growth assumptions. For sta-
tionary area sources, annual growth rates of one and two percent
are used for the low and high growth rates. Vith the exception of
heavy-duty engines, mobile soueaes use ni'Utftft rati* of—-»ac
three percent annually.-—lleavy-duty engines use the growth w
developed by EPA in its analysis of the resent heavv-duUu-g«*n regulat ions for 19 84 and latAg- Model Vearengines .29/
These are" -2 percent per year for heavy-duty gasoline-fueled
engines and +5 percent per year for heavy-duty diesel engines. The
same rates are used for both low anid high growth projection#.
-------
_fj£URE IV-D
BASE CASE PROJECTIONS OF NATIONWIDE NOX EMISSIONS
<=30000
GC
tu
>-
225000
©
o
in
z
a
20000
15000
Eioooo
LU
x 5000
LOW GROWTH RATES
23672
21774
2179*
220SJ
is:
ItZ
10Z
J 71
lii
1 (X
101
S)I
151
111
1 u
t*t
151
101
1QZ
611
1977 1980
1985 1990
TEAR
35000
=30000
ac
bJ
>-
<225000
®20000
o
to
z
o
15000
£10000
z
UJ
X
o
5000
HIGH GROWTH RATES
23342
22228
210?B
2177*
151
1SX
lOt
ill
lit
in
111
S«t
151
111
C 21
tit
lit
1M
131
til
25121
16Z
91
lOt
6JZ
1995
28*35
ltt
121
132
tot
28037
171
91
102
651
ALL TRUCKS
LDV
OTHER HOB ILE
STATIONARY
1999
313*0
ltt
12Z
131
sit
ALL TRUCKS
L0V
OTHER MOBILE
STATIONARY
1977 1980 1985 1990 1995 1999
YERR
-------
-107-
For stationary point sources, a single growth rate of 2 1/2
percent per year is used.
It can be seen from Figure IV-D that for either the low or
high growth race projections, total NOx emissions will increase
with time. This growth becomes moBt pronounced for the period
after 1985. Stationary sources are indicated as continuing to be
the dominant source category; however, mobile sources account for
35-43 percent of the total throughout the period. Among mobile
sources, light-duty vehicles are initially the biggest category.
However, they are gradually surpassed by light- and heavy-duty
truck emissions, and even by the "other mobile" source category
(off-highway, rail, marine and aircraft).
2. Regions With High Ambient NO2 Levels
(AQCRs)
^-of the
^sis is
In order to assess the impact of this proposal on regions at
or near the NAAQS, a subset of the nationwide inventory was se-
lected. The subset includes those Air Quality Control Regions
with "design values" of NO2 which are at least 60 percent
eve\ of the NAAQS. The base year for this regional analy-
(976J The "design value" has been chosen as the highest
observed\anpual average in 1976. This is the latest year for which
sufficiently comprehensive data is currently'fvailable tS do the
required air quality analysis. There are/thirty foup^regions
which meet the 60 percent selection criteria^. Of ttj£4% 04J four
are California regions and two are high-altixtKiH""*regiowp./ The
regions analyzed are listed in Table IV-H.
In analyzing for these more localized impacts of NOx emis-
sions, we will be departing from past practice somewhat and ex-
cluding major point sources from the analysis. The reason for this
is that area sources, rather than point sources, are likely to be
the principal causes of high annual average Npj concentrations at
urban monitoring sites. Point sources are frequently remote from
urban centers; and even when they are not, high stacks result in a
high degree of dispersion before emissions reach ground level.
Exclusion of point sources is equivalent to what has been done in
rollback modeling of carbon monoxide when a
factor" of 0.0 is assigned to point sources.
'source con;
4$s
of
Even though they are remote from the citycenter or have high
stacks, point sources can still be expected' to majte some swill
contribution to annual average levels at uxbfjL-^setntora-^ This
ft - in Assumed
.004 ppb^V. The
background level represents approximate ^j^the l^aljilmt' wuld be
expected if contributions from all «« Atj^rfimlnated.28/
Figure XV-E presents area source emissions for the/aA/selected
regions for the baseline year of 1976plus projections to 1999.
-------
-108-
Table IV-H
Air Quality Control Regions
With High Design Values for NO2
REGION
YEAR
CONC
004
BIRMINGHAM
1976
• 04
015
PHOENIX-TUCSON
1976
.04
018
MEMPHIS
1976
.05
042
hartforo
1976
.05
043
ny-nj-cgnn
1976
.05
045
PHILADELPHIA
1976
.04
047
NAT. CAPITAL
1976
.04
056
ATLANTA
1976
.04
067
CHICAGO
1976
.06
078
LOUISVILLE
1976
.04
079
CINCINNATI
1976
.05
OSO
INDIANAPOLIS
1976
• 04
085
OMAHA
1976
.03
115
BALTIMORE
1976
• 04
119
BOSTON
1976
.05
122
CENT MICHIGAN
1976
.OS
123
DETROIT
1976
.OS
125
SOUTH MICHIGAN
1976
.04
131
MINNEAPOLIS
1976
• 04
167
CHARLOTTE
1976
.04
173
DAYTON
1976
• 03
174
CLEVELAND
1976
.05
178
YOUNGSTOWN
1976
.04
208
MIDDLE TENN
1976
• 04
215
OALLAS-FTWORTH
1976
.04
216
HOUSTON
1976
• 05
229
PUGET S0UN0
1976
• 04
239
SE WISCONSIN
197b
.03
024
LOS ANGELES
1976
.07
028
SACRAMENTO
197b
.03
029
SAN DIEGO
1976
• 06
030
SAN FRANCISCO
1976
.04
036
DENVER
1976
.05
220
WASATCH FRONT
1976
.04
-------
_1$%gure IV-E
Base Case Projections of Area Source
NOx Emissions - 34 Regions
4485
4000 -
3000 "
NOx
(1000 Tons)
2000 "
1000
Other
Commer-
cial
Resider
tial
4315
Mobile
10%
86%
** 4006
4156
11%
M.
84%
1%
3832
3696
JJJ
82%
2%
11%
82%
2%
11%
83%
2%
10%
4%
84%
1%
w
GrVwth
Rjtt\s
1976 1980 1985 T990 199T 1999
YEAR
5876
5000"
NOx
(1000 Tons)
4000.
3000"
2000
1000
5218
4545
Other
Coomer ¦
cial
Resi-
den-
tial
Mobile
4315
105
3
86%
1%
4234
1U%
"TT
84%
1%
4137
11%
—Ml
83%
1%
10%
4%
84%
10%
M
85%
1976 1980 19851990 1995
YEAR
1%
9%
J1
86%
1999
1%
Growth
Rates
-------
Growth rates used in these projections are -tb«—soma—ao mcwtioaad.
-irf-T fn— ¦ 11 ' ii j Figure IV-E indicates that
once the major point sources are removed from consideration, mobile
sources represent over 80 percent of the NOx emissions. Largely
because of this fact, it is the shrinkage and growth of mobile
sources emissions which sets the pattern for total area source
emissions.
For both the low and high growth rates, total emissions reach
a minimum in 1985 and increase after that time. For the low growth
rates, total emissions surpass the 1976 base emissions between 1995
and 1999. For high growth rates, this would happen some 10 years
earlier. In either case, the projections indicate that by the end
of the 1980's growth in the total number of sources will begin to
outstrip emission reductions obtained from implementing EPA's
various NOx control strategies.
Figure IV-F presents, for the low growth rate estimates, the
mobile source portion of the overall emissions broken down into
various categories. Throughout the 1980s, light-duty vehicles
represent the largest single category. After that time, heavy-duty
diesel emissions become the largest single category. Light-duty
trucks plus heavy-duty vehicles coLlectively represent from 32
percent (1976) to 46 percent (1999) of all mobile source emission.
The "other" category, which includes such things as rail, aircraft
and off-road sources also plays a significant role.
For the case of the high growth rate estimates, the mobile
source emissions are as shown in Figure IV-G. NThe percentage
distributions among source types are similar to ttWe of Figure
IV-F, with the exception that light-duty vehicles and\the "other"
category represent larger portions of the total in ^the later
yeara. Of course, total emissions in future years are greater for
the higher growth rates.
E. Emission Reductions
1. Emission Factors
Considerable work has been done within EPA in an attempt to
determine accurate emission factors for mobile sources. This work
depends heavily on in-use vehicle testing under EPA's Emission
Factor Program. To answer the question of how well vehicles
perform in actual use, EPA has administered a series of exhaust
emission surveillance programs. Test fleets of consumer-owned
vehicles within various major cities are selected by model year,
make, engine size, transmission, and carburetor in such proportions
as to be representative of both the normal production of each model
year and the contribution of that model year to total vehicle miles
traveled. These programs have focused principally on light-duty
vehicles and light-duty trucks.
The data collected in these programs are analyzed to provide
mean emissions by model-year vehicle in each calendar year, change
-------
-Ill-
Figure IV-F
Base Case Projections of Mobile
Source NOx Emissions - 34 Regions
Low Growth Rates
4000 -
3000
NOx
(1000 Tons) .
2000 -
1000 -
HDG
HDD
LDT
LDV
3697
Other
8%
15%
9%
45%
23%
3363
8%
19%
8%
39%
26%
3047
8%
23%
7%
31%
31%
3163
6%
28%
7%
28%
31%
3467
5%
32%
6%
27%
30%
3779
Ml
1976 1980 1985 1990 1995 1999
YEAR
-------
-112-
Figure IV-G
Base Case Projections of Mobile Source
NOx Emissions - 34 Regions
High Growth Rates
5000 "
4000 -
NOx
(1000 Tons)
3000
2000 _
1000 -
3697
HDG
HDD
LDT
LDV
Other
8%
15%
9%
45%
23%
3566
173
9%
40%
27%
3452
7%
21%
8%
33%
32%
3818
5%
23%
7%
31%
34%
5,061
4,444
4%
25%
7%
30%
34%
3%
1976 1980 1985 1990 1995 1999
YEAR
-------
-113-
in emissions with the accumulation of mileage, change in emissions
with the accumulation of age, percentage of vehicles complying with
standards, and effect on emissions of vehicle parameters (engine
displacement, vehicle weight, etc.). These surveillance data,
along with prototype vehicle test data, assembly line test data,
and technical judgment, form the basis for the existing and pro-
jected mobile source emission factors.30/
For this regulatory analysis, changes have been made to the
emission factors for heavy-duty vehicles. The emission factors
found in the mobile source emission factors document for heavy-duty
vehicles are based upon steady-state data gathered on the 9-mode
and 13-mode test procedures. In the course of developing the
recently finalized heavy-duty engine regulations, EPA has accumu-
lated substantial data on the transient emissions of heavy-duty
engines. Both the CAPE-21 data gathering program and resultant
transient test procedure were designed to accurately characterize
in-use operation and therefore in-use emissions. Therefore, the
available transient test data has been used to revise the heavy
duty truck emission factors which are currently being used. The
emission factors for future heavy-duty engines have also been
revised to reflect accurately the proposed standards coupled with
Selective Enforcement Auditing at a 10 percent acceptable quality
level. 31./32/
The general form of all the emission factors Eor mobile
sources is an equation with some starting new vehicle emission rate
plus a mileage dependent deterioration rate. This means that to
determine the emissions from a given vehicle one must know the
accumulated mileage. To determine the average emission rate for
the fleet made up by a given class of vehicles (for example,
light-duty trucks), it is necessary to account for the fact that
the on-the-road fleet consists of a mix of vehicles of varying ages
and model years. The appropriate emission rate is applied to each
fraction of the fleet and the fractions are summed into a compo-
site.
When vehicles meeting a new emission standard are introduced
into the on-tfte-road fleet, they at first represent only a small
fraction of the whole fleet. As time passes, the newer technology
vehicles come to represent a larger and larger share of the entire
fleet. This means that the composite emission rate for the entire
fleet will show a gradual change in response to new standards,
rather than a sudden change.
As an illustration, the composite emission rate for heavy-duty
gasoline engines applicable to low altitude non-California regions
changes as follows:
Composite NOx
(g/mi) 1980 1985 1990 1995 1999
Base Case 9.76 9.62 9.59 9.53 9.54
Control Case 9.76 9.15 5.05 3.18 2.69
-------
-114-
Th e new standard is introduced in 1985, but does not make a
substantial impact until well into the 1990's. Emission rates for
heavy-duty diesel engines and light-duty trucks (gasoline-fueled
and diesel) follow similar patterns.32/
2. Lifetime Emission Reductions
One way to examine the effect of this proposal is to compare
the emissions of vehicles built to meet the proposal with emissions
of earlier vehicles. Using the emission factor equations.32/ the
total lifetime emissions of a given model year vehicle may be
estimated. This will be done for 1972 (representative of the
1972/1973 "baseline" model year for derivation of the standards),
1984 (representing vehicles built just prior to the proposed
standards), and 1985 (the proposed year of implementation for the
new standards) model year vehicles. The calculations will use
average vehicle lifetime emissions of 120,000 miles for light-duty
trucks, 114,000 miles for gasoline fueled heavy-duty trucks, and
475,000 miles for heavy-duty diesel trucks¦33/ The resulting
lifetime per-vehicie average total emissions are given in Table
IV-I.
Table IV-I indicates that heavy-duty diesel trucks have by far
the greatest lifetime emissions. This fact results both from the
higher per-mile emission rate of heavy-duty diesels and from their
higher average lifetime mileage. For the 1972 model year, an
average heavy-duty diesel vehicle would emit over 18 times as much
NOx as a light-duty truck and nearly 8 times as much as a gasoline-
fueled heavy-duty vehicle.
The impact of the proposed standards for 1985 vehicles is
apparent for all categories. In Table IV-J, the reductions for
1985 vehicles are expressed as percentages of 1972 vehicles and
1984 vehicles. Substantial reductions of all categories are
indicated.
3. Nationwide Emission Reductions
The emission rates associated with this proposal can be
incorporated into the base case nationwide NOx emission projections
of Figure IV-D. The effect of this change on mobile sources is
shown in Figure IV-H, for the years 1990, 1995 and 1999. For both
low and high growth rates, the implementation of the proposed
limits would substantially reduce nationwide NOx emissions. For
low growth rates, mobile source emissions are reduced 23, 32 and 35
percent in 1990, 1995 and 1999, respectively. For high growth
rates, these percentages become 20, 26 and 28 percent. The major
portion of these reductions can be seen to come from heavy-duty
diesel engines.
Table IV-K indicates the effects of these reduced mobile
source emissions on nationwide total levels. Shown are both the
total NOx values for the base and control case and the percent
-------
-115-
FIGURE IV-H
PROJECTIONS OF NflTIONHIDE-NOX EMISSIONS
BASELINE AND CONTROL CASES
=12000
CL
llJ
>-
£10000
o
o 8000
o
-
<210000
©
o
8000
to
z
o
6000
£ 4000
Ui
X 2000
o
z
HIGH GROWTH RATES
986)
61
241
•X
JO X
322
7907
JJL
122
72
372
40X
(A) tB)
1990
11471
it
26X
bi
291
321
»447
13062
»X
6X
40X
44 X
II
42
262
82
29X
322
Cfi) (8)
1995
9373
92
402
442
11HDG
HDD
LOT
L0V
OTHER
(fi) (B)
1999
HOC* J
(A) t*«*iia«
(ft) Cottrol e«>*
-------
-116-
Table IV-I
Average Per-Vehicle Total Lifetime Emissions
(Tons)
Model Year
Vehicle Class 1972 1984 1985
Light-Duty Trucks (Gas and Diesel)
1. Low Altitude, Non-California 0.62 0.32 0-13
2. California 0.61 0.22 0.13
3. High Altitude 0.41 0.23 0.13
Gasoline Fueled Heavy-Duty VehicleB
1. Low Altitude, Non-California 1.48 1.19 0.27
2. California 1.48 0.92 0.27
3. High Altitude 1.00 0.74 0.27
Diesel Powered Heavy-Duty Vehicles
1. Low Altitude, Non-California
2. California
3. High Altitude
11.56
11.56
6.33
9.89
6.80
6.43
2.07
2.07
1.34
-------
-117-
Table IV-J
Percentage Reductions in Average Per-Vehicle Total
Lifetime Emission Due To Proposed Standards
Reduction Compared Reduction Compared
Vehicle Class to '72 Vehicles to '84 Vehicles
Light-Duty Trucks (Gas and Diesel)
1. Low Altitude, Non-California 79% 59%
2. California 79% 41%
3. High Altitude 68% 43%
Gasoline Fueled Heavy-Duty Vehicles
1. Low Altitude, Non-California 82% 77%
2. California 82% 71%
3. High Altitude 73% 64%
Diesel Powered Heavy-Duty Vehicles
1. Low Altitude, Non-California 82% 79%
2. California 82% 70%
3. High Altitude 79% 79%
-------
1977
1980
1985
1990
1995
1999
1977
1980
1985
1990
1995
1999
-118-
Table IV-K
Nationwide NOx Emission
Projections for Base and Control Case
LOW GROWTH KATES
Total NOx
(1000 tons)
Percent
Change from 1977
Base
Control
Base
Control
21,774
21,774
0
0
21,799
21,799
0
0
22,087
21,888
1
1
23,672
21,767
9
0
25,921
23,017
19
6
28,037
24,524
29
13
HIGH GROWTH RATES
Total NOx
(1000 tons)
Percent
Change from 1977
Base
Control
Base
Control
21,774
21,774
0
0
22,228
22,228
2
2
23,078
22,876
6
5
25,342
23,384
16
7
28,455
25,431
31
17
31,390
27,701
44
27
-------
-119-
change from the 1977 base year represented by those totals. The
percent change numbers indicate that even with the proposed
regulations, total NOx emissions increase over the period eval-
uated. For the low growth projections total NOx holds nearly
constant throgh 1990, but begins a rapid climb thereafter. By
1999, the control case results in 16 to 17 percent (for the low and
high growth projections) less growth in the baseline year emissions
than does the base case.
4. Emission Reductions for Regions With High Ambient N(?2
Levels
Turning again to area source emissions for the 34 regions with
relatively high NO2 levels, the effect of controlling light- and
heavy-duty trucks to the levels of this proposal are shown in
Figures IV-I (low growth rates) and IV-J (high growth rates). In
these figures, mobile source emissions for the base case examined
earlier are compared with those after light- and heavy-duty truck
rates are controlled. This is done for the years 1990, 1995, and
1999.
Considering first the low growth rate case of Figure IV-I
(which was earlier noted as the more likely scenario), substantial
emission reductions occur in all 3 years. Total mobile source
emissions are reduced by 22 percent in 1990, 30 percent in 1995,
and 34 percent in 1999. In 1999, the year of maximum impact,
fleet-composite light-duty truck emission are reduced by 46 per-
cent, heavy-duty diesel by 77 percent, and heavy-duty gasoline by
70 percent.
For the high growth rate case of Figure IV-J, lower percentage
reductions in total mobile sources occur. Total mobile source
emissions are reduced by 18 percent in 1990, 25 percent in 1995,
and 26 percent in 1999. Fleet composite emissions for light-duty
trucks, heavy-duty gasoline and diesel trucks are reduced by the
same percentages as for low growth rates.
F. Air Quality Impacts
Air quality impact of the emission reductions will be evalu-
ated for the previously identified set of 34 regions with ambient
levels close to the National Ambient Air Quality Standard.
The assessment will be done using the Modified Linear Rollback
methodology, where changes in air quality are assumed to be
directly related to changes in emissions. In using an approximate
model such as the modified rollback approach, the absolute levels
of air quality are not as reliable as the relative changes between
various strategies. Therefore, the results will be expressed as
percentage gains over baseline, and strategies will be compared on
that basis. In addition, although the individual regions used in
the analysis have been identified, the rollback results are not
-------
-120-
4000 -
Figure IV-I
Projected Mobile Source NOx
Emissions for Baseline Case and Control Case
34 Regions - Low Growth Rate
3000 -
HDG
NOx
(1000 Tons)
HDD
2000 -
LDT
LDV
1000 -
3163
Other
6%
28%
7%
28%
31%
2480
4%
14%
36%.
39%
(a) (b)
L990
3467
5%
3 %%
6%
27!?
30%
2424
12%
XL
38%
42%
3%
(a) (b)
1995
3779
4%
36%
6%
25%
28%
2513
2%
12%
.52.
38%
43%
(a) (b)
1999
NOTE:
(a) =
(b) -
Baseline
Control
YEAR
-------
-121-
Figure IV-J
Projected Mobile Source NOx
Emissions for Baseline Case and Control Case
34 Regions - High Growth Rates
5000 -
NOx
(1000 Tons)
4000 -
HDG
HDD
3000 -
LDT
2000 -
LDV
1000 -
Other
5 %
23%
7%
31%
34%
3118
4%
11%
6%
38%
41%
(a) (b)
1990
4,444
4%
7%
30%
34%
3361
8%
5%
40%
44%
2%
5.061
(a) (b)
1995
3%
27%
7%
30%
33%
3,738
1%
3%
5%
40%
45%
(a) (b)
1999
NOTE:
(a) -
(b) -
Baseline
Control
YEAR
-------
-122-
considered accurate enough to be used for a region-by-region review
of the proposal. Rather, averages over all areas analyzed will be
used.
The average air quality improvements over 1976 levels for both
the base case (no new heavy-duty or light-duty truck NOx regula-
tions) and the control case (implementation of this proposal) are
given in Table IV-L. Results for both the low and high growth rate
assumptions discussed earlier are included.
Looking first at the base case projections, it is evident that
control programs currently anticipated for NOx will "peak out" in
the late 1980s. After that point, the growth in numbers of sources
will be greater than the emission reductions, and overall air
quality will begin to deteriorate. For the high growth rate
projections, air quality by the end of the 1990s would be 36
percent worse than in 1976. For the more likely case of the
low-jgrowth projections, deterioration in average air quality would
be much less. However, the projections indicate that even with low
growth, air quality by 1999 would be worse than in 1976.
The control case projections indicate that the emission
reductions embodied in this proposal would profoundly alter the
base case situations. By 1999, average NOx air quality would be
improved 28-30 percent over the base case for that year. For the
high growth rate projections, 1999 air quality would still be worse
than in 1976 (by 6 percent). For the low growth projections, 1999
air quality would be 22 percent better than in 1976.
Table IV-M translates the average air quality projections into
numbers of regions exceeding the air quality standard (0.05 ppm
annual average). The trends in Table IV-M parallel the changes in
average air quality. For the base case, the number of regions
exceeding the standard begins to increase by 1990. The high growth
rate projections indicate up to 20 regions exceeding the standard
by 1999. The. low growth rate projections indicate 6.
For the control case, the high growth projections yield a
substantial reduction in violating regions, from 20 down to 7 in
1999. However, this is still a greater number than the three
regions for the base year. Under the low growth projections,
implementation of this proposal is shown to eliminate all viola-
tions throughout the 1990s.
G. Potential Secondary Environmental Impacts
Two areas of secondary impact have been identified. These are
energy consumption (i.e., fuel economy) and use of precious metals.
EPA knows of no other intermedia impacts at this time.
The subject of fuel economy has been discussed earlier in the
treatment of feasibility, and will also be addressed in evaluating
costs. The standards proposed in the NPRM could result in fuel
-------
-123-
Table IV-L
Average Air Quality Percent Reduction
From 1976 Base Year
LOW
GROWTH
RATES
1980
1985
1990
1995
1999
Base Case
6
12
9
1
-6
Control Case
6
13
24
25
22
HIGH GROWTH RATES
1980 1985 1990 1995 1999
Base Case 1 2 -7 -21 -36
Control Case 14 9 3-6
NOTE: A negative value indicates an increase above the 1976
base year value.
-------
-124-
Table IV-M
Number of Regions Exceeding the NOx
Ambient Air Quality Standard*
LOW GROWTH RATES
1976 1980 1985 1990 1995 1999
Base Case 3 2 12 4 6
Control Case 3 2 10 0 0
HIGH GROWTH RATES
1976
1980
1985
1990
1995
Base Case
3
3
3
5
13
Control Case
3
3
3
2
2
1999
20
7
0.05 ppm annual average.
-------
-125-
economy penalties. These seem most likely for light-duty trucks
and heavy-duty diesel engines. During the comment period on this
proposal, EPA hopes to obtain data usable for quantification of
possible fuel economy penalties. The reader is referred to the
feasibility chapter for further discussion.
Transition from oxidation catalysts to 3-way catalysts will
change the usage patterns for platinum, palladium and rhodium.
Palladium will be reduced, while platinum and rhodium usage will
increase. Demand for palladium will decline by 64,200 troy ounces
in 1985. Platinum demand will increase by 252,870 troy ounces and
rhodium demand will increase by 40,672 troy ounces in the same
year. These figures are based upon sales projections, catalyst
sizing and precious metal loadings from Chapter V - Economic
Impact. In the event that recycling of catalyst precious metals
becomes economically practicable, the increased platinum and
rhodium usage could be more than offset.
-------
-126-
Referencea
\J Nitrogen Oxides, National Academy of Sciences, Washington,
D.C. 1977.
2/ Shalamberidze, O.P. Reflex effects of mixtures of sulfur and
nitrogen dioxides. Hyg. Sanit. 32(7-9):10-15, 1967.
3/ Nakamura, K. Response of pulmonary airway resistance by
interaction of aerosols and gases in different physical and
chemical nature. Jap. J. Hyg. 19:322-333, 1964. (in Japanese)
translated by EPA; available from the Air Pollution Technical
Information Center, Research Triangle Park, N.C., as Aptic No.
11425).
4/ Suzuki, T., and K. Ishikawa. Research of effect of smog
on human body. Research and Report on Air Pollution Pre-
vention. 2: 199-21, 1965. (In Japanese).
5/ Hemhill, J. Color fastness to light and atmospheric contami-
nants. Textile Chem. and Color 8(4):60-62, 1976.
6/ Salvin, V.S. Yellowing of White Fabrics Due to Air Pollutants,
pp. 40-51. In Collected Papers of the American Association of
Textile Chemists and Colorists, National Technical Conference,
New Orleans, October 1974.
TJ Morris, M.A. Effect of Weathering on Cotton Fabrics. Cali-
fornia Agricultural Experiment Station, Bulletin 823. Davis,
Calif. 1966.
8/ The Economic Damages of Air Pollution, U.S. EPA, EPA-600/5-
74-012, May 1974.
9/ Hermance, H.W., et al. Relation of Airborne Nitrate to
Telephone Equipment Damage. Environ. Sci. Technol. 5:781-785,
1971.
10/ Air Quality Criteria for Nitrogen Oxides, U.S. EPA, January
1971.
11/ Visibility Protection for Class I Areas, The Technical Basis,
Washington University, Seattle, Prepared for Council on
Environmental Quality, Washington D.C., August 1978, Pb-288
842.
12/ Stern, A.C., Air Pollution, Volume II, 3rd Edition, Academic
Press, New York, 1977, p. 10.
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-127-
13/ "Airborne Particles," National Academy of Sciences, November
1977, EPA-600/1-77-053, PB-276 723.
14/ Likens, G.E. Acid Precipitation, Chem. Eng. News 54_ (48):
29-44. 1976.
15/ McColl, J.G. and D.S. Bush. Precipitation and throughfall
chemistry in the San Francisco Say Area. J. Environ. Qual.
2:352-357, 1978.
16/ Lewis, W.M. , Jr. and H.C. Grant. Acid Precipitation in the
Western U.S. Science 207:176-177, 1980.
17/ Likens, Gene E., Richard F. Wright, James N. Galloway and
Thomas Butter, Acid Rain, Scientific American, Oct. 1979, Vol.
241, no. 4. pp. 43-51.
18/ Galloway, J.N. and E.B. Cowling. The Effects of precipitation
on aquatic and terrestrial ecosystems: A proposed precipita-
tion network. JAPCA 28;229-235, 1978.
19/ Nitrates: An Environmental Assessment, National Academy of
Sciences, Washington, D.C. 1978.
20/ Beamish, R.J. Acidification of Lakes in Canada By Acid Precip-
itation and the Resulting Effects of Fish. Water, Air and
Soil Poll. 6^:501-514, 1976.
21/ Tamm, C.0. and E.B. Cowling. Acidic precipitation and forest
vegetation. Ln: Proceedings of the First International
Symposium on Acid Precipitation and the Forest Ecosystem, Kay
12-15, 1975, Columbus, (Alio (Dochinger, L.S. and T.A. Seliga,
eds.K U.S. Forest Service General Technical Report NE-23.
Northeastern Forest Experiment Station. Upper Darby, Pa.
1976. pp. 845-856.
22/ Overrein, L.N. Sulphur pollution patterns observed; leaching
of calcium in forest soil determined. Aabio. 1:145-147.
1972.
23/ Barrows, H.L. Soil pollution and its influence on plant
quality. J. Soil Water Cons. 21:211-216. 1966.
24/ Brock, T.D. Biology of Microorganisms. Prentice-Hall, Inc.
Englewood Cliffs, N.J. 1970. pp. 485-487.
25/ Cowling, E.B., and L.S. Dochinger. The Changing Chemistry of
Precipitation and Its Effects on Vegetation and Materials.
AICHE Symposium Series. Control and Dispersion of Air Pollu-
tants: Emphasis on NOx and Particulate Emissions. 7^:134-142,
1978.
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-128-
26/ Nriagn, J. Deteriorative Effects of Sulfur Pollution on
Materials. pp. 2-59. In. Nriagn, J. ed. Sulfur in the
Environment Part II: Ecological Imports. pp. 482. John
Wiley and Sons, New York, 1978.
27/ a. Nox National Emission Inventory Estimates, EPA-AA-TEB-80-
19, M. Wolcott, August 1980.
b. 1977 National Emissions Report, National Emissions Data
System of the Aerometric and Emissions Reporting System, EPA
Office of Air Quality Planning and Standards.
28/ Data Base for Air Quality Impact Assessment of Proposed
Heavy-Duty Vehicle Emission Standards, Warren P. Freas, OAQPS,
March 20, 1980.
29/ Regulatory Analysis and Environmental Impact of Final Emis-
sion Regulations for 1984 and Later Model Year Heavy-Duty
Engines, EPA OMSAPC, December 1979.
30/ Mobile Source emission Factors - Final Document, EPA-400/9-
78-005, March 1978.
31/ California Emission Factors for Heavy-Duty NOx Proposal,
John Anderson, SDSB, April 30, 1980.
32/ a. Mobile 1 Modifications and Emission Rate Assumptions for
the LDT and HDV NOx Regulatory Analysis, J. Wallace, June 24,
1980.
b. Air Quality Impact of Proposed 1985 and Later Model Year
Light-Duty Truck and Heavy-Duty Vehicle Emission Standards for
Oxides of Nitrogen, EPA-AA-TEB-80-21, M. Wolcott, July 1980.
33/ Average Lifetime Periods for Light-Duty Trucks and Heavy-Duty
Vehicles, EPA Report SDSB 79-24, G. Passavant, November
1979.
34/ Folinsbee, L.J., S.N. Horvath, J.F. Bedi, and J.C. Delehunt.
Effect of 0.62 ppm NO2 on cardiopulmonary function in young
male non-smokers. Environmental Research 1_5: 199-205, 1978. •
35/ Kagawa, J., and T. Toyama. Photochemical air pollution: Its
effects on respiratory function of elementary school children.
Arch. Environ. Health. 30: 117-122, 1975.
36/ Yokoyama, E. The respiratory effects of exposure to SO2-NO2
mixtures on healthy subjects. Japan J. Ind. Health 14:
449-454, 1972. (In Japanese).
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-129-
37/ Von Niedling, G. , H.M. Wagner, H. Lollgen and H. Krekler.
Acute effects of ozone on lung function of men. VDI-Ber.
270: 123-129, 1977. (in German).
38/ Von Nieding, G., H. Krekeler, R. Fuchs, H.M. Wagner, and K.
Koppenhagen. Studies of the acute effect of NO2 on lung
function: Influence on diffusion, perfusion and ventilation
in the lungs. Int. Arch. Arbeitsmed. _3_1_: 61-72, 1973.
39/ Von Nieding, G. , H.M. Wagner, H. Krekeler, U. Smidt, and K.
Muysers. Absorption of NO2 in low concentrations in the
respiratory tract and its acute effects on lung function and
circulation. Paper No. MB-15G presented at the Second Inter-
national Clean Air Congress of the International Union of Air
Pollution Prevention Assoc. Washington, D.C., December 6-11,
1970.
40/ Abe, M. Effects of mixed N(>2~S02 gas on human pulmonary
functions. Effects of air pollution on the human body. Bull.
Tokyo Med. Dent. Univ. 14(4): 415-433, 1967.
41/ Beil, M., and W.T. Ulmer. Wirkung von NO2 ub MAK-Bereich
auf Atemmechanik und Acelytcholinempfindlichkeit bei Normal
personen. (Effect of NO2 in workroom concentrations on
respiratory mechanics and bronchial susceptability to acet-
ylcholine in normal persons.) Int. Arch. Occup. Environ.
Health. 38: 31-44, 1976.
42/ Hackney, J.D., F.C. Thiede, W.S. Linn, E.E. Pedersen, C.E.
Spier, D.C. Law and D.A. Fisher. Experimental studies on
human health effects of air pollutants. IV. Short-term
physiological and clinical effects. Arch. Environ. Health.
33(4): 176-181, 1978.
43/ Hackney, J.D., W.S. Linn, R.D. Buckley, E.E. Pedersen, S.K.
Karuza, D.C. Law, and D.A. Fischer. Experimental studies on
human health effects of air pollutants. I. Design considera-
tions. Arch. Environ. Health. 30: 373-378, 1975.
44/ Hackney, J.D., W.S. Linn, J.G. Mohler, E.E. Pedersen, P.
Breisacher, and A. Russo. Experimental studies on human
health effects of air pollutants. II. Four-hour exposure to
ozone alone and in combination with other pollutant gases.
Arch. Environ. Health. 30: 379-384, 1975.
45/ Hackney, J.D., W.S. Linn, D.C. Law, S.K. Karuza, H. Greenberg,
R.D. Buckley, and E.E. Pedersen. Experimental studies on
human health effects on air pollutants. III. Two-hour expo-
sure to ozone alone and in coobination with other pollutant
gases. Arch. Environ. Health. 30: 385-390, 1975.
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-130-
46/ Von Nieding, G. , H.M. Wagner, H. Krekeler, U. Smidt and K.
Muysers. Minimum concentrations of NO2 causing acute effects
on the respiratory gas exchange and airway resistance in
patients with chronic bronchitis. Int. Arch. Arbeitsmed.
27: 338-348, 1971. Translated from German by Mundus Systems
for Air Pollution Technical Information Center, U.S. Environ-
mental Protection Agency, Research Triangke Park, North
Carolina.
47/ Kerr, H.D., T.J. Kulle, M.L. Mcllhany, and P. Swidersky.
Effects of Nitrogen Dioxide on Pulmonary Function in Human
Subjects. An Environmental Chamber Study. EPA-600/1-78-025.
U.S. Environmental Protection Agency, Office of Research and
Development, Health Effects Research Laboratory, Research
Triangle Park, North Carolina, April, 1978.
48/ Orehek, J., J.P. Massari, P. Gayrard, C. Grimaud, and J.
Charpin. Effect of short-term, low-level nitrogen dioxide
exposure on bronchial sensitivity of asthmatic patients. J.
Clin. Invest. 57; 301-307, 1976.
49/ Shy, C.M., J.P. Creason, M.E. Pearlman, K.E. McClain, F.B.
Benson, and M.M. Young. The Chattanooga school children
study: Effects of community exposure of nitrogen dioxide. I.
Methods, description of pollutant exposure and results of
ventilatory function testing. J. Air Pollut. Control Assoc.
20(8): 539-545, 1970.
50/ Linn, W.S., J.D. Hackney, E.E. Pedersen, P. Breisacher, J.V.
Patterson, C.A. Mulry, and J.F. Coyle. Respiratory function
and symptoms in urban office workers in relation to oxidant
air pollution exposure. Aider. Rev. Resp. Disease. 114:
477-483, 1976.
51/ Speizer, F.E. and B.G. Ferris, Jr., Exposure to automobile
exhaust. II. Pulmonary function measurement. Arch. Environ.
Health. 26(6): 319-324, 1973.
52/ Burgess, W., L. Di Berardinis, and F.E. Speizer. Exposure to
automobile exhaust. III. An environmental assessment. Arch.
Environ. Health. 26: 325-329, 1973.
53/ Cohen, C.A., A.R. Hudson, J.L. Clausen, and J.H. Knelson.
Respiratory symptoms, spirometry, and oxidant air pollution in
non-smoking adults. Amer. Rev. Resp. Disease. 105: 251-261,
1972.
54/ Kagawa, J., T. Toyama, and M. Nakaza. Pulmonary function test
in children exposed to air pollution. La: Clinical Implica-
tions of. Air Pollution Research Action, A.J. Finkel, Jr. and
W.C. Duel, eds. MA, Publishing Sciences Group, 1976. pp.
305-320.
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-131-
55/ Pearlman, M.E., J.F. Finklea, J.P. Creason, G.M. Shy, M.M.
Young, and R.J.M. Horton. Nitrogen dioxide and lower respira-
tory illness. Pediatrics 47(2): 391-398, 1971.
56/ Melia, R.J.W. , C. duV. Florey, and S. Chinn. The relation
between respiratory illness in primary schoolchildren and the
use of gas for cooking. I - Results from a national survey.
Int. J. Epid. 8i 333, 1971.
57/ Melia, R.J.W., C. duV. Florey, D.S. Altman, and A.V. Swan.
Association between gas cooking and respiratory disease in
children. Brit. Med. J. 2: 149-152, 1977.
58/ Florey, C. duV., R.J.W. Melia, S. Chinn, B.D. Goldstein,
A.G.F. Brooks, H.H. John, I.B. Craighead, and X. Webster. The
relation between respiratory illness in primary schoolchildren
and the use of gas for cooking. Ill - Nitrogen dioxide,
respiratory illness and lung infection. Int. J. Epid. 8:
347, 1979.
59/ Goldstein, B.D., R.J.W. Melia, S. Chinn, C. duV. Florey, D.
Clark, and H.H. John. The reLation between respiratory
illness in primary schoolchildren and the use of gas for
cooking. II - Factors affecting nitrogen dioxide levels in
the home. Int. J. Epid. 8k 339, 1979.
60/ Speizer, F.E., B.G. Ferris, Jr., Y.M.M. Bishop, and J.
Spengler. Respiratory disease rates and pulmonary function in
children associated with NO2 exposure. Am. Rev. Resp. Dis.
121: 3-10, 1980.
61/ Mitchell, R.I., R. Williams, R.W. Cote, R.R. Lanese, and M.D.
Keller. Household Survey of the Incidence of Respiratory
Disease in Relation to Environmental Pollutants. WHO Inter-
national Sumposium Proceedings: Recent Advance in the Assess-
ment of the Health Effects of Environmental Polutants, Paris,
June 24-28, 1974.
62/ Keller, M.D., R.R. Lanese, R.I. Mitchell, and R.W. Cote.
Respiratory illness in households using gas and electric
cooking. I - Survey of Incidence. Environ. Res. ^19: 495-
503, 1979.
63/ Scientific and Technical Data Base for Criteria and Hazardous
Pollutants. 1975 ERC/RTP Review. EPA-600/1-76-203. U.S.
Environmental Protection Agency, Research Triangle Park, North
Carolina, 1976.
64/ Melia, R.J.W., C. duV. Florey, S.C. Darby, E.D. Palmers, And
B.D. Goldstein. Differences in N02 levels in kitchens with
gas or electric cookers. Atm. Env. 12: 1379-1381, 1978.
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Horvath, S. M., and L. J. Folinsbee. Effects of pollutants on
cardiopulmonary function. Report to U.S. Environmental
Protection Agency, EPA Contract 68-02-1723, 1979. (Manuscript
submitted).
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CHAPTER V
ECONOMIC IMPACT
This chapter examines the compliance costs associated with the
manufacturers' efforts toward complying with the proposed regula-
tions covering 1985 and later model year light-duty trucks and
heavy-duty engines. For the two affected classes the costs of
research and development (R&D), emission control hardware, in-use
durability testing, certification, and the allowable maintenance
provisions will be considered. The emission control hardware costs
estimated in this chapter are those for the optimum emission
control system currently available, as described in Chapter III,
Technological Feasibility. Possible changes in operating costs
will also be evaluated.
Because of the inherent differences between the LDT and HDE
classes, this analysis will examine these classes separately.
Splitting this analysis will facilitate the analysis and increase
its usefulness to the manufacturers.
A. Light-Duty Trucks
This section will present GPA's analysis of the potential cost
impact for light-duty trucks to meet the NOx emission standard and
will cover fixed costs such as R&D and certification and variable
costs such as emission control hardware.
1. Cost to LDT Manufacturers
a. Research and Development
At the present time, EPA cannot accurately predict these
costs. It is inevitable that some development and testing costs
will be incurred as the more sophisticated emission control tech-
nology used on light-duty vehicles, and in light-duty trucks
certified for California, is applied to all light-duty trucks.
The NOx emission standards for light-duty vehicles and light-duty
trucks are shown below:
Standard 50,000 mile 100,000 mile
1983 Federal LDV 1.0 g/mile
1983 California LDV .4 1.0
1983 California LDT
IW: 0 - 3999 lb .4 1.0
4000 - 6000 lb 1.0 1.5
6001 - 8500 lb 1.5 2.0
The proposed LDT NOx emission standard is comparable in
stringency to these standards, so EPA expects that similar tech-
nology will be applied. Because similar technology will be used,
it is reasonable that the initial R&D costs should not be large.
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-134-
EPA expects that the bulk of the expenditures will be aimed at
practical application and optimization of this new technology
rather than pure development work. As an initial estimate, a cost
of about $2 per LDT seems reasonable. This cost would cover the
application and optimization of the catalytic converter, EGR, and
electronic engine control technology expected, as well as the
additional driveability and fuel economy testing brought on by the
expected change in emission control technology. If it is assumed
that these R&D costs are recovered over five model years, then the
initial R&D effort would sum to about $38 million dollars industry-
wide .
As will be discussed later, EPA is proposing full life
(100,000 mile) maintenance intervals for both electronic engine
controls and exhaust gas oxygen sensors. Based on recent data
available to EPA from several manufacturers, a 50,000 mile oxygen
sensor is quite easily feasible and there are also some preliminary
indications that even a greater interval is possible using present
technology. Full life electronic controls should be feasible with
little or no cost increase.
As an initial estimate, EPA will assume an R&D cost of 8
million dollars to develop full life oxygen sensors and full life
electronic engine controls for LDTs. Additional costs to develop
full life oxygen sensors and electronic controls will also be
discussed in association with heavy-duty gasoline engines.
This R&D may ultimately lead to the need for changes in oxygen
sensor design, materials, or location all aimed at increasing
component durability. Possible increases in material costs will be
addressed later. For use by manufacturers in 1985, these full life
components will have to be available by late 1983.
This cost plus the development and testing costs outlined
above comes to about $46 million dollars. This analysis will be
carried out such that all fixed R&D costs would be recovered in the
first five model years.
To be conservative EPA will apportion these R&D costs over the
first four years which the manufacturers and vendors will have
available for development and optimization, according to the
following schedule:
On the average only 20 percent of the R&D funds will be
expended as development plans are established and longer leadtime
R&D is started. The bulk of the practical application and optimi-
zation work would be accomplished in 1982 when approximately 60
percent of the R&D funds would be spent. The final two years 1983
and 1984 would be primarily continued optimization and driveability
and fuel economy testing.
1981
1982
1983
1984
20 percent 9.2 M
60 percent 27.6 M
15 percent 7.0 M
5 percent 2.2 M
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-135-
It is quite possible that some manufacturers will conduct
some of their NOx development work, concurrently with their
R&D aimed at meeting the 1984 revised HC and CO emission standards.
These R&D costs were addressed in the recent LDT HC and CO final
rulemaking, and amounted to about $165 million over the five year
period 1981-1985.
EPA expects that the proposed 1985 regulations will not
require as much development work as the 1984 regulations. Much of
the required increases in component durability will already be
achieved, the manufacturers will have a years of experience with
the more stringent 10 percent AQL, and the likely emission control
technology is already in use on light-duty vehicles.
b. Emission Control System Costs
i. Gasoline-Powered LDTs
EPA believes that the proposed standard can be met by all
LDTs, but expects that a variety of emission control strategies may
be used based somewhat on manufacturer preference. However, the
control technology used will be driven primarily by the emission
characteristics of a given LDT family.
This analysis will evaluate the cost of five different control
strategies each of which may be viable for some engine families.
These five configurations are shown below:
Configuration Catalyst Type EGR Air Injection
1
3-Way
2
3-Way
X
3
3-Way
+
Ox Cat
X
4
3-Way
+
OxCat
X
5
3-Way
+
OxCat
X
X
In addition to these five configurations, basic engine modi-
fications are also possible, but a fuel economy penalty may occur
with some types of engine modifications.
To estimate a range for emission control hardware costs, the
costs for these five configurations will be evaluated. As a
reasonable means of estimating these costs, EPA has divided the LDT
class into three major subclasses. The subclasses are LDTs with
either 4, 6, or 8 cylinder engines. Based on the characteristics
of current light-duty truck engines, our analysis will pair the
engine CID and number of cylinders together in the following
manner: 4 cylinder/125 CID, 6 cylinder/250 CID, and 8 cylinder/325
CID. Reasonable inertia weights for these three subclasses are
3,000, 4,000 and 5,000 pounds respectively. These pairings are
representative of the 1980 LDT fleet .^7
When calculating the actual hardware costs with each con-
figuration, only the emission control hardware actually required
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-136-
will be costed. Cost credits will be taken when hardware cur-
rently in use is no longer required. The hardware coats have
been estimated using the data and methodology in a cost esti-
mation report prepared under contract for EPA.l/ This method-
ology was altered by allowing for the effects of inflation,
increased real cost of materials (such as noble metals) and
an adjustment for a realistic percentage markup for overhead
and profit.2/3/ The cost for a closed loop electronic engine
control system is an EPA estimate. All cost figures presented in
this chapter are in 1980 dollars.
Tables V-A-l, 2, and 3 show the estimated increase in hardware
costs for each configuration (1-5) for LDTs with 4, 6, or 8 cylin-
der engines. Configuration 1 was considered only for LDTs with 4
cylinder engines because it was not considered reasonable for 6 or
8 cylinder engines. The credits taken are based on hardware
changes from the emission control system which EPA expects will be
used to comply with the recently promulgated 1984 HC, CO, and NOx
emission standards.4/
As can be seen in the tables, the hardware cost estimates
range from a low of $51 for 4 cylinder configuration 1 to $274 for
8 cylinder configuration 5. To allow an estimate of the costs in
each LDT subgroup some decision as to the percent of LDTs in each
subgroup which may use each technology is necessary.
For the 4 cylinder LDTs, configuration 2 is the system which
EPA expects will be used in the majority of the families, but
configuration 1 may be feasible for the smallest LDTs. At this
point EPA does not expect that 4 cylinder LDTs will require three-
way plus oxidation catalysts to achieve the revised emission
standards. For further analysis the three-way catalyst system with
EGR will be considered as the primary control strategy for four
cylinder (<200 CID) LDTs.
For six cylinder LDTs the likely control strategies expand to
both three-way and three-way plus oxidation catalyst systems.
Undoubtedly some of the smaller six cylinder engines will be able
to meet the emission standards with three-way catalyst/EGR systems
(configuration 2), but the larger CID six cylinder engines will
probably require a configuration employing three-way plus oxidation
catalysts (configuration 5). As a reasonable estimate of this
split, EPA shall assume that all LDTs with engines sizes of 250 CID
or less will require three-way catalysts and all LDTs with engine
sizes exceeding 250 CID will require three-way plus oxidation
catalyst systems. The use of a simple split such as this provides
only the crudest of estimates. Many other factors which affect
vehicle emission levels are not tied directly to the engine size.
With these considerations in mind, the approximate split is 40
percent of the six cylinder LDTs using three-way catalyst/EGR
systems and 60 percent using a three-way plus oxidation catalyst
-------
Tabic V-A-l
Eaisaion Control Syitca Cost per Truck
Four Cylinder 125-CID Engine! Conf igiirationa 1-5
Hardware Added Hardware leaoved
Configuration
Iliree-Way
Catalyat
Three-Way
plua Oxidation
Catalyat
Feedback
Carburetor
Modificationa
Electronic
Controla
(cloaed loop)
Oxidation
Catalyat
Air
Injection
ECU
Electronic
Cont rola
(open loop)
TOTAL
1
9«3
-
$7
$140
$86
$27
$6
$60
$51
2
$•3
-
$7
$140
$86
$27
-
$60
$57
3
-
$108
$7
$140
$86
$27
-
$60
$82
4
-
$108
$7
$140
$86
-
$6
$60
$103
5
-
$106
$7
$140
$86
-
$6
$60
$109
I
U>
I
-------
Table V-A-2
Emission Control System Cost per Truck
Six Cylinder 250 CIP Engines Configurations 2-5
Three-Way
Configuration Catalyst
2
3
4
5
$155
Hardware Added
Three-Way
plus Oxidation
Catalyst
$188
$188
$188
Hardware Removed
Feedback
Carburetor
Modificationa
$7
$7
$7
$7
Electronic
Controls
(closed loop)
$140
$140
$140
$140
Oxidat ion
Catalyst
$80
$80
$80
$80
Air
Injection
$27
$27
EGR
$6
Electronic
Controls
(open loop)
$60
$60
$60
$60
TOTAL
$135
$168
$189
$195
I
I—1
u>
00
1
-------
Table V-A-3
Eaiiitoa Control Syaten Co#t p«T Truck
Bight-Cylinder 32>-CIP Engine* Cooti-KUft ion» 2-5
Tbre«-Wajr
Hardware Added
Three-Way
plna Oxidat ioa
Feedback
Carburetor
Electronic
Controla
Oxidatioa
Hardware keaoved
Air
Electronic
Controla
Configuration
Cat«1rat
Catalyat
Hodificationa
(cloaed loop)
Catalyst
Inject ion EGK
(open loop)
TOTAL
2
Ml
-
*7
$140
$az
927
9M
$159
3
-
1269
$7
$140
$82
$27
$60
$247
A
-
92«»
$7
9140
$82
M
$60
$268
5
-
1269
$7
9140
982
-
$60
$274
UJ
iO
I
-------
-140-
configuration. 5J It is possible that some of the six cylinder LDTs
requiring a three-way plus oxidation catalyst system may be able to
remove either EGR or the air injection system and still achieve the
emission standards. However, EPA will conservatively assume that
all will use the full three-way plus oxidation catalyst/EGR/air
injection system (configuration 5).
For eight cylinder LDTs it is projected that the three-way
plus oxidation catalyst will be the dominant emission control
strategy. Eight cylinder engines range in size from 302 to 400
cubic inches with the bulk lying in a range from 318 to 360 cubic
inches inclusive. An analysis which uses the methodology and
rationale described above and 318 cubic inches as the cut point
between three-way and three-way plus oxidation catalyst systems,
yields a split of 25 percent three-way systems and 75 percent
three-way plus oxidation catalyst systems. This methodology shows
a decreasing percentage of LDTs able to meet the target emission
levels without a three-way plus oxidation catalyst system as the
engine CID increases. This trend is correct because of the larger
engine sizes (>300 CID) and the effect of the other emission
related factors alluded to previously. However, it may be too
optimistic to project that 25 percent of the 8 cylinder LDTs will
be able to meet the target emission levels using only the three-way
catalyst/EGR emission control system. This is especially true for
the first model year, when time is a crucial factor in the develop-
ment program and future production plans depend on the successful
completion of a certification program. Manufacturers will initi-
ally tend to develop an emission control system which will insure
that emissions compliance will not interfere with production
plans. As emission control system optimization occurs in the later
model years, the percentage of 8 cylinder LDTs using three-way
catalyst/ EGR systems may approach 25 percent, but to be con-
servative, this analysis will assume that in the first few model
years only 10 percent of the LDTs in this subclass will be able
to use the three-way catalyst/ EGR system (configuration 2).
The remaining 90 percent will require full three-way plus oxida-
tion catalyst systems including air injection and EGR (configura-
tion 5).
Table V-B summarizes the expected emission control system
strategy for each LDT subclass.
Having now identified the emission control system costs which
are expected for 4, 6, and 8 cylinder gasoline-powered LDTs the
market percentages for each of these types of engines must be
projected for the analysis period (1985-1989).
EPA expects a general downsizing of LDT engines to occur
over the next several years due primarily to fuel economy pres-
sures, with emissions as a secondary consideration. In addition
to the introduction of new more fuel efficient truck lines with
smaller engines, EPA expects that domestic manufacturers will
adjust their sales mixes such that they sell fewer of their
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Table V-B
Emission Control System Requirements per LPT Subclass
Three-Way
Catalyst/EGR
4 cylinder 100%
avg. 125 CID
avg. IW 3000 lb.
6 cylinder 40%
avg. 250 CID
avg. IW 4000 lb.
8 cylinder 10%
avg. 325 CID
avg. IW 5000 lb.
Three-Way plus Oxidation
Catalyat/Air Injection/EGR
602
90%
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large CID engines and more of the smaller more fuel efficient
engines. The 1980 sales projection data submitted by the manu-
facturers breaks neatly into the three cylinder/CID groups dis-
cussed previously (See Table below). However, EPA expects that
by the mid to late eighties a large shift will occur in these
percentages. The current and future market splits are shown
below:
Sales Splits
Number of
Cylinders
4
6
8
Engine
CID Range
0-200
200-300
300-400
1980 Market
Percentage
11 percent
19 percent
70 percent
EPA Market
Projection
(1985-1989)
30 percent
45 percent
25 percent
These market projections will be used later in this analysis to
estimate the average emission control hardware cost per vehicle.
ii. Light-Duty Diesel Trucks (LDDT)
In 1980 only three manufacturers certified LDDT, but EPA
expects that several more manufacturers will introduce LDDT lines
by 1985. EPA is projecting, that over the five year period of this
analysis, LDDT sales will average 15.6 percent of the total
market .6_/
The costs of meeting the NOx target emission level are diffi-
cult to estimate. The manufacturers are all using pre-chamber
injection and retarded timing presently, and EGR is expected in two
of three families prior to 1985 (IH and GM). Increases in EGR flow
rates or further timing retard could further reduce NOx emissions,
but at the expense of increased fuel consumption and a slight
increase in the levels of other pollutants.
There are at least two other control strategies which may
reduce NOx emissions. Combustion chamber redesign aimed at
reducing maximum temperatures reached or residence time in the
combustion chamber would aid in reducing NOx emission levels.
These redesign costs are estimated at $50 per engine considering
the sales volumes affected. Advanced fuel injection and electronic
engine controls could also reduce NOx levels substantially.
Cost estimates for this hardware range from $200 to $300.8/
Four control strategies have now been identified. Retarded
timing would have no first price increase impact, but would have a
negative impact on fuel economy and other emission levels. An
increase in EGR flow rates or changes in EGR design are available
with no significant first price increase, but fuel economy and the
emission levels of other pollutants might be adversely impacted.
The third alternative, combustion chamber redesign, would reduce
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NOx emission levels and may have a positive impact on fuel economy
and other pollutants. Finally, advanced fuel injection and elec-
tronic engine controls could substantially decrease NOx emission
levels and possibly provide improvements in fuel economy and other
emissions, but at a larger first price increase.
For this analysis, it is reasonable to expect that the LDDT
fleet in the mid to late eighties will have emission characte-
ristics similar to those of the present fleet. In a broad sense
this may overestimate the NOx emission levels, because one of the
present families (GM 350 diesel) was not designed purely as a
diesel, as will be the new LDDT lines introduced in the mid-
eighties .
Based on data submitted to GFA in the recent light-duty
diesel NOx waiver request it appears that the proposed NOx stan-
dard may be achievable in the 1985 model year using primarily
engine modifications and EGR.9/ Based on the current NOx levels
of the three LDDT families (GM 2.0-2.1 g/mile, IHC 1.4-1.6 g/mile,
and VW 1.2 g/mile) it appears that one family (GM) will have
to add EGR and the remaining two families will require either
increased EGR and some form of combustion chamber and injector
redesign or slight changes to injection timing. Although the GM
family currently does not use EGR it is possible that EGR will be
added in 1984 in response to the implementation of the 10 percent
AQL for selective enforcement audits.
To estimate an average cost for this additional hardware
the low point in the cost estimates will be used, and, as stated
previously, the LDDT fleet of the mid eighties will be expected
to have emission characteristics similar to the present fleet.
Thus one-third will have to add EGR and two thirds will probably
require injector/combustion chamber redesign. This gives an
average hardware cost of $42 per engine as shown below:
.33 ($25) + .67 ($50) - $41.75 - $42
This cost will be carried forward to compute the average hardware
cost for all LDTs.
iii. Fleetwide Emission Control Hardware Costa
Having now estimated control system costs for gasoline
and diesel-powered LDTs all that remains is to determine the
fleetwide average cost. In the five year period, 1985-1989,
gasoline-powered LDTs are expected to average 84.4 percent of
all LDT sales with diesel powered LDTs comprising the remaining
15.6 percent. As was discussed previoualy> EPA is projecting
that 4, 6, and 8 cylinder LDTs will comprise 30, 45, and 25
percent of the gasoline-powered LDT market respectively. Using
these percentages and the hardware costs discussed previously,
the average LDT hardware cost is estimated at $146 per vehicle:
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.156($42) + .844(.30($57) + .45((.40)($168) + (.60)($195)) +
.2 5((,10)($159) + (.90)($274))) = $146
c. Certification
Certification is the process in which EPA determines whether a
manufacturer's vehicles conform to applicable regulations. The
manufacturer must prove to EPA that its vehicles are designed and
will be built such that they are capable of complying with emission
standards over their useful life. Under current regulations, the
certification process begins by a manufacturer submitting to EPA an
application for certification. This will continue under the
proposed revision to the regulations. The proposed regulations
will require two types of certification testing subsequent to the
submittal of the application: first, pre-production testing of
prototype vehicles to determine preliminary deterioration factors
and low-mileage emission levels, and second, in-use service accumu-
lation and emission testing to determine in-use deterioration
factors.
i. Preliminary Deterioration Factor Assessment Costs
Pre-production testing will be necessary to establish prelimi-
nary deterioration factors for each engine family-emission control
system combination, and to determine the emission levels of the
emission-data vehicles at the 4,000-mile (low-mileage) point. The
preliminary deterioration factors will then be multiplied by the
emission levels at 4,000 miles to predict whether the emission-data
vehicles comply with the standards over their useful life.
Under the proposal, manufacturers will design the test pro-
cedures used to determine the preliminary deterioration factors.
There are few specific requirements on the test procedures, which
do not necessarily have to require testing of complete vehicles but
may, instead, entail bench testing of components. With this
flexibility, it is not possible to predict accurately the cost of
the manufacturers' test programs. EPA has assumed for the purpose
of this cost analysis that the manufacturers' preliminary deteri-
oration factor assessment programs will not be more costly than a
full program of durability testing under the current regulations.
The calculation of the industries' cost for finding these
preliminary deterioration factors under this assumption is shown in
Table V-C. The unit costs are based on EPA estimates of what
manufacturers have spent on testing durability-data vehicles in the
past. The estimates were made in 1975,10/ but have adjusted for
inflation. The fourteen emission tests allow for tests at 5,000
mile intervals during 50,000 miles of test track operation and four
tests associated with maintenance. Based on the current number of
engine family-emission control system combinations, EPA estimates
there will be about 40 combinations requiring preliminary deter-
ioration factors certified by ail manufacturers in 1985. Assuming
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Table V-C
Certification Costs Associated with Determining
Preliminary Deterioration Factors
1980 Dollars
I. Cost per Engine - Emission Control System Combination
Prototype Vehicle $ 35K
Mileage Accumulation to 50,000 miles, $131K
Maintenance, and Overhead
Fourteen Emission Tests $ 6K
at $400 per test
$172K
II. Total Cost Industry Wide
Assuming forty engine-system combinations will be tested and
two vehicles per engine family:
80 x $172K - $13.76M Total Cost
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two preliminary deterioration factor assessment vehicles per
family-control system combination, total industry costs are esti-
mated at $13.76 million dollars.
ii. Emission Data Vehicles
The testing of emission data vehicles will not be affected
by the proposed regulations, except that carry over of emission
test results from previous model years will be disrupted. EPA's
method for estimating the coat impact of this disruption is
to assume that no emission data carry over is possible in the
first affected year. This over estimates the incremental im-
pact in the first year, since 100 percent carry over would not
have occurred in any case. However, the disruption also has an
incremental impact in the second and following years as some
manufacturers may choose to re-certify optimized emission systems,
thus incurring more cost. EPA reasonably assumes that the various
errors cancel each other.
The calculation of the costs of testing emission data vehicles
is shown in Table V-D. Again, unit costs are based on EPA esti-
mates made in 1975 (adjusted for inflation). EPA also estimates
that 200 emission data vehicles will require testing, an average of
4 per engine family-control system combination. (The ratio of
emission-data vehicles to combinations is not fixed by regulation,
so there is some variability from combination to combination and
from year to year.) Emission data testing costs total about $4.68
million.
iii. In-Use Durability Testing
The proposed in-uae durability testing regulations require
that after a manufacturer is granted a certificate of conformity
for an LDT engine family-control system combination based on
preliminary deterioration factors, it must then start a program
of in-use service accumulation including periodic emissions
testing. As part of this program, the manufacturer will select
three or more production vehicles from each family-system com-
bination. Each manufacturer will be allowed to waive durability
testing for any family-system combination whose projected sales
does not exceed 5,000 LDTs per year, up to a total of 5,000
LDTs per manufacturer. These vehicles will be run on a test
track for 4,000 miles to determine their low mileage emission
levels consistent with the way emission data vehicles are tested.
The manufacturer may then either place these vehicles into a
typical service application as would be done by a consumer,
or continue test track operation or operation solely to accumu-
late mileage. The vehicles will accumulate mileage at a prescribed
rate over each year and be tested for emissions at intervals of
four to twelve months, at the manufacturer's discretion. Mileage
accumulation and emissions testing will continue until the vehicle
reaches its average useful life as prescribed by the manufacturer
in its certification application.
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Table V-D
Certification Costs Associated with
Emission Data Vehicle Testing
I. Cost per Emission Data Vehicle
Prototype Vehicle $13.8K.
Mileage Accumulation to 4,000 miles, $ 8.8K
Maintenance, and Overhead
Tvo Emission Tests at $400 per test $ 0.8K
$23.4K
II. Total Cost Industry Wide
Assuming 200 engine data vehicles from 50 families:
200 x $23.4K - $4.68M Total Cost
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EPA has identified costs in five major areas associated with
in-use testing. The first major expense involves the "purchase" of
LDTs for use in the fleets. EPA expects that each manufacturer
will run three LDTs per family and that approximately 40 LDT
families will undergo in-use testing. As a reasonable first
estimate this analysis will assume that one-half of the LDTs are
placed into a useful service application and one-half are run
solely to accumulate mileage. Those LDTs which are placed into a
useful service application will probably replace other LDTs already
being used in a manufacturer's corporate fleet, so no real addi-
tional cost to the manufacturer will occur. However, those LDTs
which are run just to accumulate mileage will have to be "pur-
chased". If one-half are run solely to accumulate mileage, 60 LDTs
will have to be purchased. At an average of $7000 per LDT this
comes to an industry-wide cost of $420,000.
The second major expense involves initial emissions testing
for all LDTs in the fleets. Three sets of expenditures are expec-
ted: zero hour emission tests (3), mileage accumulation to 4,000
miles, and 4,000 mile emission tests (3). As is detailed in Table
V-E this comes to $11,200 per LDT or $1,344 million dollars
industry-wide.
EPA expects that eleven of the twelve manufacturers which
certified LDTs for 1980 will have sufficient 1985 sales to require
in-use testing for at least one family. It is reasonable that each
manufacturer will staff at least one additional engineer to handle
the supervisory/administrative portion of running the in-use
fleets. For the purpose of this analysis, it is reasonable that
each manufacturer will require approximately three years to finish
its in-use testing and thus will require this position over that
time period. After the initial in-use fleets have completed
testing, the number of new fleets which might be required in
additional model years should be small enough that the permanent
certification staff could absorb the additional supervision and
administration. The engineering supervision cost comes to $1.98
million dollars for the period 1985-1987 inclusive.
A fourth major expense is the actual cost of running the
in-use fleets. As stated previously, manufacturers will have the
option of either running the in-use vehicles just to accumulate
mileage or placing the vehicles into a useful service application.
If the in-use fleets are run just to accumulate mileage then all of
the running expenses will be an additional cost to the manufac-
turer. If the vehicles are placed into a useful service, then no
additional running expense will be incurred. As before, EPA will
assume that one-half are driven solely to accumulate mileage and
one-half are placed into a useful service application. These costs
are estimated at $150,000 per LDT or $9 million dollars industry
wide, assuming a 100,000 mile lifetime.
The final major expense is the actual cost of emissions
testing during the useful life. There is great flexibility in the
emissions testing requirements, but testing is required at least
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Table V-E
Testing Costs Prior to In-Use
Service Accumulation
Zero hour emission tests (3) $1,200
Mileage Accumulation to 4,000 $ 8,800
miles (maintenance and overhead)
4,000 mile emission tests (3) $ 1,200
$11,200
$11.2K x 3 vehicles x ,n , ...
. . . —c—t ^0 families
vehicle family
$1.344M
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annually, and three tests are allowed each time a vehicle is
tested. As a conservative estimate EPA will assume that the
manufacturers test their in-use fleets each four months and that
each LDT undergoes testing three times at each test point (4
months). Using a total of 12 emission tests per year at $400 per
test over a three year period, the testing cost comes to $14,400
per LDT or $1,728 million dollars industry wide for all 120 in-use
LDTs.
The five major costs involved in the in-use durability testing
program are summarized in Table V-F and are presented in the year
in which they are expected to occur. As can be seen in the table
the undiscounted cost of this program comes to $14,472 million
dollars or an average cost of about $360K per LDT family. If all
in-use fleets were placed into a service application total costs
would be reduced to $5,052 million dollars. However if all fleets
were run solely to accumulate mileage the total costs would rise
$23,892 million dollars.
iv. Allowable Maintenance
Due to the critical nature of several emission related compon-
ents, EPA has proposed, and in some cases already finalized,
maintenance intervals for important emission related components.
EPA is very concerned that these components be replaced or main-
tained during the life of the vehicle. The most desirable situa-
tion is that the component durability be such that the maintenance
interval recommended by the manufacturer equal or exceed the
average useful life of the vehicle.
EPA has proposed full life (100,000 mile) maintenance inter-
vals for both electronic engine controls and oxygen sensors.
Electronic engine controls should be able to achieve or surpass
the maintenance interval with little or no work. As discussed
briefly in the beginning of this chapter, this may not be the
case for oxygen sensors. EPA is expecting that some R&D work will
be necessary to achieve this interval, and that an increase
in material costs may evolve as a result. As a first estimate, EPA
will include a cost of $1.50 per vehicle to cover improved mater-
ials and design, in addition to the R&D funds discussed previously.
This $1.50 approximates the current manufacturing costs of oxygen
sensors .^_/
v. Total Costs to Manufacturers
The five major costs to manufacturers R&D, emission control
hardware, certification, in-use durability testing, and allowable
maintenance, are summarized in Table V-G and are shown in 1980
dollars. The costs presented are shown in the year in which they
are expected to occur, and inherently include profit and overhead.
The $2.89 billion dollars (undiscounted) in Table V-G should
provide sufficient funds to comply with all aspects of this pro-
posed rulemaking action.
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Table V-F
Light-Duty Truck In-Use Durability
Testing Costs (1980 Dollars)
Year
1985
1986
1987
Vehicle
Purchase
$42 OK
$42 OK
Initial
Testing
$1344K
$1344K
Engineering
Supervision and
Administration
$660K
$66 OK
$660K
S1980K
Maintenance
and Mileage
Accumulation
$3000K
$3000K
$300QK
$9000K
Emissions
Testing
$576K
$576K
$576K
$1728K
Undiscounted total cost: $20.472M
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Table V-G
Total Cost to Manufacturers
1985-1989 (LDTs)
In-Use Allowable Emissions
Year
R&D
Certification
Testing
Maintenance
Hardware
1981
$ 7.6M
-
-
$
1.6M
-
1982
$22.8M
-
-
$
4.8M
-
1983
$ 5.8M
$13.8 M
-
$
1.2M
-
1984
$ 1.8M
$ 4.7M
-
$
0.4M
-
1985
-
-
$6.0M
$
4.7M
$519.8M
1986
-
-
$4.2M
$
4.8M
$544.6M
1987
-
-
$4.2M
$
4.8M
$565.OM
1988
-
-
-
$
4.9M
$573.8M
1989
-
—
-
$ 4.9M
$584.OM
$38.OM
$18.5M
$14.4M
$32.1M
$2787.2M
Total
undiscounted
cost $2890.
2M -
- 1980 dollars
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2. Cost to Users of Light-Duty Trucks
a. Increases in First Costs
The added cost to manufacturers for R&D, certification,
allowable maintenance, and emission control system hardware will be
passed on to the purchasers of light-duty trucks. The amount a
manufacturer must increase the price of its vehicles to recover its
expenses depends on the timing of the costs and of the revenues
from sales and on the cost of capital to the manufacturer. Table
V-G showed the manner in which the manufacturers costs are distri-
buted over the period 1981-1989. EPA expects that over the long
run manufacturers face a 10 percent cost of capital and that they
increase the vehicle prices to recover, their investment in five
model years, 1985-1989.
The expected average sales-weighted first price increase is
$154. This is comprised of $3.19 for development and testing,
$1.38 for certification, $.84 for in-use durability testing, $146
for emission control hardware, $2.26 for allowable maintenance
provisions (gasoline-powered LDTs only).
The first price increase would range from a minimum of $65 for
4-cylinder LDTs using three-way catalysts to $282 for 8-cylinder
LDTs with three-way plus oxidation catalysts. LDDTs would increase
in price by $47. First price increase estimates for LDT subclasses
mentioned previously are presented in Table V-H.
b. Fuel Economy
Three-way catalyst emission control systems do not inherently
cause a reduction in fuel economy and in some cases will actually
allow a fuel economy improvement over the oxidation catalysts now
in use.
These potential fuel economy improvements are available in
three areas. The first area of potential savings is related to the
use of electronic engine controls and feedback carburetors. These
components will allow the engine to keep the air/fuel ratio near
stoichometric conditions and allow maximum use of the energy
available in the fuel. This increase is difficult to quantify, and
may be as small as one percent on a fleetwide basis.
A second potential fuel economy improvement lies in the
removal of the air injection system from LDTs requiring only
three-way systems. The potential fuel savings could range from 0
to 4 percent. These savings are expected to occur in approximately
40 percent of the LDT fleet, but it is possible that come LDTs
which might otherwise be able to remove an air injection system
will require air injection for cold start reductions. This need
for reducing cold start emissions may lead to air pumps being
replaced by a "pulse air" type system.
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Table V-H
First Price Increases
for Light-Duty Trucks
4 cylinder with 3-way catalyst $ 65
6 cylinder with 3-way catalyst $143
6 cylinder with 3-way plus Ox-Cat $203
8 cylinder with 3-way catalyst $167
8 cylinder with 3-way plus Ox-Cat $282
Light-Duty Diesel Trucks $ 47
Sales-Weighted Average: $153
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A third potential fuel savings lies in the use of feedback
carburetors and evaporative emissions storage canisters. Using
feedback carburetors, evaporated fuel stored in a canister can be
burned as efficiently as liquid fuel, and thus provide a fuel
economy savings over the pre-1985 system.
Finally, it should be noted that LDDT may incur a fuel economy
penalty as a result of these regulations. The LDDTs which use
retarded timing to control NOx may incur a fuel economy penalty in
the 0 to 5 percent range.9/ LDDTs which use conventional EGR to
reduce NOx emission levels may incur a fuel economy penalty.
However, it is possible that any fuel economy penalty with in-
creased EGR may be avoided by the use of electronically controlled
EGR flow rates.
The fuel economy changes which may occur cannot be quantified
precisely at this time. A fuel economy change of one percent
for gasoline-powered LDTs means a lifetime change in operating
costs of approximately $64. For LDDTs a one percent change in
fuel economy means a $49 change in lifetime operating costs.11/
Figure V-A shows the change of operating costs with fuel economy
for both types of light-duty trucks.
Manufacturers' comments on the fuel economy effects of three-
way systems, the removal of air injection systems, the efficient
use of evaporated fuel and LDDT EGR systems is requested and
strongly encouraged.
c. Total Costs to Users
To summarize, users of light-duty trucks, can as a result of
the proposed regulations standards, expect to pay an average of
about $153 more for 1985 model year light-duty trucks than for
comparable models purchased in 1984 (1980 dollars). Operating
costs of LDDT could increase as a result of these regulations
if losses in fuel economy occur. Conversely, operating costs
of gasoline-powered LDTs may decrease as a result of improvements
in fuel economy.
3. Aggregate Costs
The aggregate cost to the nation of complying with the pro-
posed 1985 Federal LDT emission regulations consist of the sum
increased costs for development, new emission control hardware,
certification, in-use durability testing and compliance with the
allowable maintenance provisions. All of these costs will be
calculated for a five year period of compliance.
The five-year costs of compliance are dependent on the number
of light-duty trucks sold during the period. The accuracy and
validity of projecting vehicle sales as far into the future as
1989 is problematic, so cost estimates based on such projections
are subject to some qualification. However, because the largest
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Fi.i^e. V-ft
I
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portion of the costs in this analysis are variable costs (hard-
ware) and not fixed costs (certification, R&D etc.) the accur-
acy of the sales projections is not as important as might be the
case in some other rulemaking actions. Future sales of LDT for the
analysis period were discussed previously, and are shown in Table
II-J.
The various costs associated with this rulemaking action will
occur in different periods. In order to make all costs comparable,
the present value at the start of 1985 of the aggregate costs has
been calculated, based on a discount rate of 10 percent. Use of a
discount rate emphasizes that because of the time value of money, a
cost incurred now is worth more to the nation than a cost incurred
in the future.
The calculation of the present value in 1985 of the aggre-
gate costs, with the assumptions required for the calculation
is shown in Table V-I. The aggregate cost of complying with
the new regulations for the five-year period is equivalent to
a lump sum investment of about $2.43 billion (1980 dollars)
made at the start of 1985. Expressed in other terms, the ag-
gregate cost of compliance is equivalent to an investment of
$153 per LDT made at the start of the year the LDT is produced.
The aggregate cost changes by about $1.19 billion dollars for each
one percent change in light-duty truck fuel economy.
It is estimated that LDTs over 6,000 lbs. GVWR comprise
45 percent of the LDT group.12/ In accordance with the Clean
Air Act, any vehicle over 6,000 lbs. GVWR is a heavy-duty vehi-
cle and must meet emission standards developed using the method-
ology outlined in the Clean Air Act for heavy-duty engines.
Using the appropriate portions of the fixed and variable costs,
the expenditure for meeting the reductions required by statute
is about $680 million dollars (discounted). However, EPA is
expecting that the percentage of LDTs above 6000 lbs GVWR will
decrease throughout the eighties due to vehicle downsizing and
possible re-rating caused by the proposed LDT fuel economy stan-
dards. Downsizing will increase the number of LDTs rated at less
than 6000 lb GVWR and re-rating may increase the number of trucks
in the 8,500-10,000 lb GVWR group. These re-rated trucks would
then be classified as heavy-duty vehicles and exempt from the LDT
fuel economy standards. The costs of meeting the reductions
required by statute are subject to revision based on improved
estimates of the portions of the LDT class and above and below 6000
lb GVWR.
For ease of reference, the components of the cost of compli-
ance and the different ways of expressing it are summarized in
Tables V-J, V.-K and V-L.
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Table
v-r
Present Value in 1985
of the Aggregate Costs
of Compliance for the
1985-1989 Model Years
Year 1/
Cost 2/
Present Value in 1985
1981
$ 9,200K
$ 13.470K
1982
27,600K
36,736K
1983
20,710K
25.059K
1984
6,930K
7.623K
1985
530.491K
530.491K
1986
553.639K
503.313K
1987
574.103K
474.439K
1988
578.637K
434,730K
1989
588,878K
402,204K
Total:
$2,890,188K
$2,428,065K
T7 CostB are assumed to occur at the start of each year, and
allocated according to Table V-G.
2/ 1980 dollars, including profit and overhead.
2/ 10 percent discount rate.
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Table V-J
Aggregate Costs of Compliance for LDTs
Produced During Model Years 1985-1989
(Discounted at 10% to January 1, 1985)
Development and Testing
Certification
In-Use Durability Testing
Allowable Maintenance
Emission Control Systems
$ 50.466K
21,798K
13.352K
30.725K
2,311,724K
$2,428.065K
Operating Costs 1/
Change in aggregate cost
per one percent change
in fleetwide fuel economy
1.058M
l7 5 percent discount January 1, 1985.
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Table V-K
Undiscounted Cost of Compliance per LDT
for LDTa Produced During 1985-1989
Development and Testing $ 1.99
Certification .97
In-Use Durability Testing .76
Allowable Maintenance 1.68
Emission Control Hardware 146.00
(sales weighted average)
Undiscounted Cost per Vehicle $151.40
Operating Cost
Change in operating $ 76.00
cost per one percent
change in fuel economy
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Table V-L
Discounted Cost of Compliance per LPT 1/
for LDTs Produced During 1985-* 1989
Development and Testing $ 3.19
Certification 1.38
In-Use Durability Testing .84
Allowable Maintenance 1.91
Emission Control Hardware 146.00
(sales weighted average)
First Price Increase: $153.32
Operating Costs 2/
Change in operating $ 62.00
cost per one percent
change in fuel economy
Discounted to Model Year Produced at 10 percent.
Discounted to Model Year Produced at 5 percent.
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4. Socio-Economic Impact
a. Impacts on Manufacturers
i. Capital Expenditures
It is difficult to estimate the total capital investment
which the industry will require to meet the proposed regulations.
However, with the recent cash flow problems of the manufacturers,
it is important to attempt an estimate of these capital costs.
For the purpose of this analysis, capital investment will
be defined as all expenditures required before any return on
investment is realized. These costs will lie in four areas:
development and testing, certification, research and development
for allowable maintenance, and redesign and retooling for new
emission control hardware.
EPA's initial estimate of these capital investment costs
is shown in Table V-M. In the first three areas (development and
testing, R&D for allowable maintenance and certification) these
costs have been discussed previously, and the costs stated expli-
citly.
The area of emission control hardware is quite different from
the three areas discussed previously. Much of the capital invest-
ment required to produce catalytic converters, electronic engine
controls, feedback carburetors, etc. is borne by vendors and not by
the manufacturers themselves. The figure shown in Table V-M is for
a total of six vendors at an annual production of approximately
625,000 units per annum.13/ This figure is not a pure incremental
increase over the current expenditures. Much of the equipment and
tooling costs which EPA expects the manufacturers will spend to
produce three-way and three-way plus oxidation catalysts would have
been spent as necessary recurring equipment and tooling costs in
the production of oxidation catalysts.
One final area related to emission control hardware is the
combustion chamber redesign costs for LDDT. This cost will be
borne primarily by the manufacturers and is to a large degree
purely capital investment. It is reasonable that a redesigned
combustion chamber or other engine modifications would cost no more
to produce and the selling price would increase only by the amor-
tized retooling and research costs. As an initial estimate of
these costs to include R&D, redesign, and retooling a sum of about
four million dollars seems reasonable, if not conservatively high
for the three or four LDDT manufacturers which will require these
engine and combustion chamber modifications.
In total, all of the capital investments identified for LDT
vendors and manufacturers sum to $170 million dollars. However,
these costs are not as large as they appear. The figures presented
here actually cover a four year period (1981-1984 inclusive) and
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Table V-M
Pre 1985 Capital Investment
(1980 Dollars Undiscounted)
Development and Testing $ 38,000K
Certification 18,440k
Allowable Maintenance 8,000K
LDDT (Combustion Chamber Redesign) 4,000K
Vendor:
Gasoline-powered LPT 101,112K
tooling and equipment for
catalytic converters, closed
loop electronic controls, and
other emission related hardware
$169,552K
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are spread over the entire industry (twelve manufacturers and
numerous vendors). In addition, these costs are not pure incre-
mental increases over what otherwise would have been spent. There
are always expendable tooling, product improvement and recertifi-
cation costs which would occur irregardless of these regulations.
At this point, the optimum analysis would take the estimated
capital expenditures outlined above and allocate them to the
vendors and manufacturers. However, due to the dynamic state
of the LDT market and the large number of product changes expected
in the next five years it is inappropriate to attempt an estimate
of this type. This is further compounded by the large capital
investments EPA expects will be necessary by the emission control
hardware vendors, and not the manufacturers. An allocation based
purely on market shares would be of limited usefulness. Comments
on the appropriate amount of capital investment required for this
rulemaking is solicited from each manufacturer. This capital
investment data is an essential input in determining the financial
ability of each manufacturer to comply with the proposed regula-
tions .
ii. Effects on the Demand for LDTs
Changing the prices of light-duty trucks may, of course,
impact sales. An average first cost increase of $153 means a
selling price rise of about 2 percent. This increase is less than
the usual annual increase of 5 to 7 percent.14/
EPA knows of no specific estimates of the price elasticity of
demand for LDTs. The short term elasticity of demand for LDVs and
LDTs has been estimated at -0.70.15/ Lacking any other estimates,
this short term elasticity of demand was assumed as valid for
LDTs. In a report by EPA's Office of Noise Abatement Control, a
long-term elasticity of demand of -0.32 was cited for all trucks
and buses.16/ Considering that LDTs comprise the vast majority if
vehicles in this group, and the long-term elasticity of demand for
heavy-duty vehicles is near -0.7, using the -0.32 as the long-term
elasticity demand for light-duty trucks, is a reasonable estima-
tion.
One method of estimating the sales decrease is the Ford
Econometric Model.17/ This model accounts for first cost in-
creases, changes in fuel economy, and increases cost of operation
and maintenance. Using some of the data presented in this chapter
and making some simple assumptions as to LDT average retail price
and fuel economy, the model predicts that LDT sales should decrease
about 0.8 percent in the short term and about 0.4 percent in the
long term as a result of these regulations. Sales by some smaller
manufacturers of LDTs may decline more than those of larger manu-
facturers due to their smaller sales volume over which the develop-
ment, certification and tooling costs can be amortized. The small
decrease in total industry sales, due to these regulations, will be
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more than overcome by normal sales growth and thus can be expected
to have no noticeable effect on any single manufacturer's sales.
It is unlikely that the sales mix between LDTs, HDVs, and LDVs
will be significantly affected. Only commerical concerns would
consider switching from an LDT to an HDV for delivery or other
purposes, but the greater selling price and operating costs of
heavy-duty vehicles would greatly deter this switching. In addi-
tion, HDVs are expected to have a comparable if not larger first
price increase as a result of these proposed regulations. Some
vehicle owners who drive LDTs for pleasure may choose to switch to
LDVs, or lower GVWR LDTs, as a result of this action.
Since commercial LDTs are used primarily for intracity deliv-
ery, no switch to shipping freight by rail or air is feasible.
It is not expected that the promulgation of the regulations
will have any long term impact on employment or productivity in the
light-duty truck industry, since industry-wide sales will be
affected little.
iii. Impact on Users
Users of light-duty trucks will be affected by the higher
vehicle costs. The expected average, sales-weighted first cost
increase of $153 should not substantially impact the owner's
ability to pay for new LDTs.
iv. Effects on Energy Use
EPA expects that compliance with the proposed regulations will
be based on the use of closed loop catalyst systems. These closed
loop catalyst systems may actually yield a slight fuel economy
gain. In addition, LDTs using only a three-way catalyst system may
be able to remove the air injection system which would yield a 0 to
2 percent fuel economy savings. Fuel economy for gasoline-powered
LDTs may also improve as a result of more efficient use of stored
evaporative emissions. The proposed regulations will have no
negative fuel economy impact for gasoline-powered LDTs and will
not inhibit the manufacturers' ability to comply with the LDT fuel
economy standards.
LDDTs will use engine and combustion chamber modifications and
EGR to comply with the proposed LDT NOx standard. LDDTs employing
EGR for the first time, or increasing EGR flow rates or timing
retard may encounter a fuel economy penalty in the 0 to 5 percent
range. The actual level of this projected penalty is tenative and
will be revised based on manufacturer's comment. It is possible
that a fuel economy penalty for LDDT can be avoided by using
electronic controls.
As stated previously, each one percent change in gasoline-
powered LDT fuel economy means a lifetime operating cost change of
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$64 and each one percent change in LDDT fuel economy means a $49
change in operating coats.
v• Inflationary Effects - Consumer Price Index
The consumer price index (CPI) is one of the primary indica-
tions for changes in the general price level. It is estimated that
light-duty trucks contribute about 0.5 percent to the CPI deter-
mination.^/ Combining this percent contribution with the average
estimated price increase of about 2 percent will give only a .01
percent increase in the CPI. Needless to say this increase is
negligible compared to other elements of the CPI. Therefore, EPA
concludes that these emission regulations will have no significant
price level impact. Further, since the public will receive air
quality and related health improvements in exchange for the higher
LDT prices, the rise in the CPI that will occur cannot properly be
termed inflationary.
vi. Balance of Trade Effects
The implementation of three-way catalyst technology over
oxidation catalyst technology will cause an increase in the imports
of noble metals, primarily rhodium and platinum. Imports of
palladium are expected to decrease.
The incremental changes in noble metal imports discussed below
are the changes which will occur as a result of the implementation
of the revised NOx standard and implicity incorporate the 4, 6, and
8 cylinder engine sales split expected in the mid to late eight-
ies. The change in these imports is shown below:
Annual Noble Metal Imports Due to LDTs (Troy oz)
1985 1985
No Revised NOx Std Revised NOx Std
Platinum 158,386 389,829
Palladium 87,227 47,329
Rhodium 0 32,811
At current market prices these figures translate into an
increase of $74.8 million dollars for platinum, $20.2 million
dollars for rhodium and a decrease of $6.9 million dollars due to
decreased palladium. The sum of these three figures yield an
increase in imports of $88.1 million dollars per year. These
figures are subject to revision in the final rulemaking process.
Oxygen sensors also use platinum, but these amounts are so small as
to be negligible in comparison to catalysts.
Another major balance of trade impact is related to the first
price increase of imported LDTs, most of which are four cylinder.
Based on the hardware costs in Table V-H this comes to about $63
per LDT. If one assumes a constant market share for imported LDTs
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this yields a loss in the balance of trade by an average of about
$26 million dollars per year.
Each one percent change in light-duty truck fuel economy means
increased or decreased consumption of 49 gallons of fuel for
gasoline-powered LDTs and 45 gallons of fuel for LDDTs over the
vehicle lifetime. Assuming 42 gallons per barrel of imported oil,
at $30 per barrel yields a $131 million dollar impact on the
balance of payments for each model year.
vii. Local and Regional Effects
The domestic light-duty truck manufacturers operate about 22
plants in assembling their products. Their location for each
manufacturer, are shown in Table V-N.19/ A total of twelve states
are included.
General Motors operates nine assembly plants to produce
light-duty trucks and vans. Some o£ these plants are also used
to assemble passenger cars. General Motors has plants located in
seven states with three in Michigan. Ford operates seven assembly
plants spread over seven states. Chrysler and AMC currently
operate two each.and IHC and Volkswagen operate one each.
It is reasonable that any slight decrease in employment which
might be related to these regulations would be spread evenly
across the twenty-two plants affected. If production were to
drop 0.4 percent as a result of these regulations, spreading
that drop evenly over the twenty-two plants would yield a drop
of only 0.4 percent at each plant. This is a relatively incal-
culable impact considering other factors affecting production,
and thuB only a very insignificant drop in employment might
result.
Offsetting this slight drop would be the jobs created or
sustained by the research and development effort anticipated. This
impact would be strongest at the large volume manufactures (GM,
Ford, Chrysler) and at the vendors which produce emission related
components.
In any event, the expected annual sales increases and the
effects of the dynamic condition of the LDT market will render
the employment impact of these regulations negligible. As a
result, EPA concludes that no locality or region will suffer
noticeable or disproportinate economic impact, positive or nega-
tive, as a result of these regulations, and all areas will bene-
fit by the improvements in air quality these regulations will
bring.
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Table V-N
Light Truck Assembly Plants
in the United States
General Motors:
Fremont, California
Lakewood, Georgia
Baltimore, Maryland
Detroit, Michigan
Flint, Michigan
Pontiac, Michigan
St. Louis, Missouri
Lordstown, Ohio
Janesville, Wisconsin
Ford:
San Jose, California
Louisville, Kentucky
Wayne, Michigan
Twin Cities, Minnesota
Kansas City, Missouri
Lorain, Ohio
Norfolk, Virginia
Chrysler:
Warren, Michigan
St. Louis, Missouri
American Motors:
Toledo, Ohio
South Bend, Indiana
International Harvester:
Fort Wayne, Indiana
Volkswagen:
Westmoreland, Pennsylvania
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B. Heavy-Duty Engines
This portion of Chapter V will examine the costs of com-
plying with the proposed NOx emission standard and related con-
trol strategy for 1985 and later model year heavy-duty engines.
Costs of compliance are in four main areas: 1) development.,
production and installation of new or redesigned emission con-
trol systems and some minor engine redesigns, 2) certification
and in-use durability testing to assure compliance with the
emission standards 3) costs associated with the allowable main-
tenance provisions and 4) possible increases in operating/main-
tenance costs. For gasoline-fueled engines the primary cost
is that for emission control systems. For diesel engines, the
primary costs are for engine redesign and hardware for emission
control. However, diesel engines may also have increased operating
costs associated with increased fuel consumption.
The engine manufacturer must bear the initial capital costs
for engine modifications, emission control hardware, certification,
and in-use durability testing. In addition, gasoline-powered
vehicle/engine manufacturers will have to comply with the allowable
maintenance provisions. These costs will be added to the price of
the engines it sells to vehicle manufacturers or uses in its own
trucks or buses if it also produces vehicles. These costs in turn
will be passed on to its customers, the truck and bus owners and
operators. These operators must also bear the increased operating
(fuel and maintenance) costs which may be caused by the more
stringent emission standards.
1. Cost to Engine Manufacturers
The emission control system cost estimates discussed in the
following paragraphs inherently include costs to cover the allow-
able maintenance provisions and more stringent NOx emission stan-
dards while at the same time including compliance with all pre-
viously promulgated regulations affecting heavy-duty engines (e.g.,
revised useful life definition, 10 percent AQL, etc.)
a. Gasoline-Fueled Heavy-Duty Engines
The actual cost of complying with the proposed emission
standards can be divided into two main areas: 1) pre-production
development and testing of the required emission control technology
and 2) the actual cost of the emission control hardwttre installed
on each engine produced.
i. Development and Testing
Development and testing should not be as large a task as is
expected for the recently promulgated HC and CO standards and
emission control program for 1984 and later model year heavy-duty
engines. Manufacturers and vendors of heavy-duty catalysts will
have gained considerable experience in the technology necessary to
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increase catalyst durability by 1985. In addition, three-way
catalyst technology is well understood and developed. Therefore,
EPA is expecting only small development and testing costs related
to adding three-way catalyst technology to heavy-duty engines.
However, three-way and three-way plus oxidation catalysts will
require closed loop electronic engine controls with feedback
carburetors. These closed loop systems are now in use on light-
duty vehicles but some further development and modifications will
probably be necessary for heavy-duty engine applications.
As a first estimate of the development and testing costs EPA
expects an average per engine cost of about four dollars. Four
dollars per engine amortized over five years allows an industry-
wide cost of about $10 million dollars. On a per manufacturer
basis this cost may not be shared equally. Manufacturers such as
IHC which do not market light-duty vehicles will have a relatively
larger share of the expense than their market share might indi-
cate. The same may be true for a manufacturer with a larger number
of small sales volume engine families.
As before with light-duty trucks, EPA is proposing full life
(100,000 mile) maintenance intervals for electronic engine controls
and exhaust gas oxygen sensors. Neither electronic controls nor
oxygen sensors are currently in use on heavy-duty gasoline engines,
so obviously, the feasibility of this interval has not been demon-
strated .
EPA believes that full life electronic controls are feasible
for only a small amount of development and testing cost. Full life
oxygen sensors should require more development work and perhaps
eventual changes in design, materials, or sensor placement. As an
initial estimate to cover these costs a sum of $8 million dollars
was estimated for LDTs. This same figure will be used here,
bringing the total to $16 million dollars to develop full life
electronic controls and oxygen sensors, and then make the tooling
and other capital expenditures necessary to produce the more
durable components.
As before for LDTs these costs will be spread over the four
years preceding implementation of the regulations on the schedule
shown below:
1981
1982
1983
1984
20 percent
60 percent
15 percent
5 percent
$3.6 million
$10.8 million
$2.7 million
$0.9 million
Initial expenditures of R&D funds will occur in 1981 as program
planning and development begin for emission control system appli-
cation and oxygen sensor improvement. The bulk of the system
application and optimization testing will occur in 1982 together
with the majority of the work involved in improving the durability
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of oxygen sensors and electronic engine controls. The final two
years of development will be primarily continued optimization as
well as initial testing for driveability, fuel economy, and safety.
ii. Emission Control Hardware
EPA expects that manufacturers of gasoline-fueled engines will
adopt three-way and three-way plus oxidation catalyst systems
together with EGR and air injection to comply with the emission
standards proposed for 1985. The components EPA expects will be
used are shown in Tables V-0 and V-P and are discussed below. The
system is costed assuming a 360 CID engine. Costs for emission
related components were estimated from a recently finalized EPA
report.27/
Monolithic 3-Way Catalysts - Two 198 cubic inch catalysts
loaded with 50 g/cu ft. of platinum and rhodium in a 9:1 ratio.
The catalyst volume engine CID ratio is 1:1.
Feedback Carburetor Modifications - The current standard
carburetorwil1haveto be modified/redesigned to accept the
feedback signal from the electronic control unit and supply the
proper fuel metering to optimize the air-fuel ratio.
Closed Loop Electronic Engine Controls - This covers a full
closed loop electronic control system for heavy-duty engines. It
includes the following: electronic control unit closed/ loop wiring
harness and straps, manifold absolute pressure sensor, throttle
position sensor, electromechanical carburetor solenoid, advance and
retard solenoid for spark control, detonation sensor, vacuum switch
(idle and deceleration), cold start switch, miscellaneous manifold
revisions, electronic spark control, oxygen sensor(s), miscel-
laneous tubes and valves. Cost is an EPA estimate, and includes
installation, overhead, and profit.
Monolithic 3-Way plus Oxidation Catalysts - Two monolithic
three-way plus oxidation catalysts each having a volume of 288
cubic inches. The three-way portion has a volume of 150 cubic
inches and is loaded with 30 g/cu. ft. of platinum and rhodium in a
9:1 ratio. The oxidation catalyst portion of each catalyst has a
volume of 138 cubic inches and is loaded with 30 g/cu. ft. of
platinum and palladium in a 2:1 ratio.
Monolithic Oxidation Catalysts - The two monolithic oxidation
catalysts shown as credits are the systems which will be removed in
1985 and replaced by the catalysts discussed above. Each of these
catalysts has a volume of 180 cubic inches and is loaded with 45
g/cu. ft. of platinum and palladium in a 2:1 ratio.20/
In addition to the hardware shown in Tables V-0 and V-P and
discussed above, approximately one-half of the heavy-duty gasoline-
fueled engines may have to add EGR for the first time, at a cost of
about $16.27/ All engines which use EGR will need proportional
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Table V-0
Emission Control Component Costs
for Gasoline-Fueled Heavy-Duty Engines
Component EPA Estimate
Two monolithic 3-way catalysts $295
Feedback carburetor modifications $ 17
Closed-loop electronic engine controls $150
$462
Less
Two monolithic oxidation catalysts $289
$173
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Table V-P
Emission Control Component Costs
for Gasoline-Fueled Heavy-Duty Engines
Component EPA Estimate
Two monolithic 3-way plus oxidation $390
catalysts
Feedback carburetor modifications $ 17
Closed-loop electronic engine controls
$150
$557
Less
Two monolithic oxidation catalysts $289
$268
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EGR, but this change to proportional EGR from the current systems
should have no significant cost.
iii. Fleetwide Hardware Costs
At this point, EPA is estimating that approximately 10 percent
of the heavy-duty engines will be able to meet the revised emission
standards with the use of three-way catalyst/EGR technology, and
the remaining 90 percent will require three-way plus oxidation
catalyst/EGR technology. Heavy-duty engines using only three-way
catalysts may not require air injection or at least will require
less air injection than is expected for 1984.
Hardware costs can be summarized as shown below, using the
percentages and costs discussed previously.
.10($173) + .90($268) + ,5($16) - $267
b. Heavy-Duty Diesel Engines
The actual costs of complying with the proposed emission
standards can be divided into two main areas: 1) pre-production
R&D and 2) the actual cost of any hardware ultimately installed to
control NOx emissions.
i Pre-Production Research and Development
The costs of pre-production R&D are extremely difficult to
estimate. The exact control technology which may be used to
achieve a NOx emission standard of 1.7 g/BHP-hr has not as yet been
identified. Some of the methodology which EPA expects will be used
to reduce NOx emission is moderately R&D intensive. For example,
the application of electronic engine controls, combustion chamber
redesign, injector redesign, or other engine modifications would
require a fairly intensive R&D effort.
As an initial estimate of these costs EPA will estimate an
industry wide cost of twenty-five million dollars spread over the
four years of production preceding 1985. These costs will be
spread over the four-year period according to the schedule shown
below:
1981: 3 million 12 percent
1982: 15 million 60 percent
1983: 5 million 20 percent
1984: 2 million 8 percent
The rationale for the percentages shown above is the same as that
used for heavy-duty gasoline-fueled engines.
EPA recognizes that these figures are only initial estimates
and will update these figures and percentages during the final
rulemaking, based on the manufacturers' comments.
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ii. Emission Control Hardware
EPA expects that manufacturers will need to employ several
techniques in reducing NOx emissions. Among the more likely are:
1) electronic engine controls, 2) exhaust gas recirculation, 3)
intercooling/ aftercooling, 4) injector combustion chamber and
other engine modifications, 5) retarded injection timing, and 6)
high pressure fuel injection.
Perhaps the most promising of the NOx control techniques is
electronic engine controls. These controls would be somewhat
similar to those used on gasoline-fueled engines, but they would
control different engine parameters. This technology is relatively
undeveloped for heavy-duty diesel engines, so its full impact on
NOx emission levels, fuel economy, and performance cannot be fully
determined. It is quite likely that electronic controls can bring
substantial reductions in NOx emissions without increases in
particulate levels or a fuel economy penalty.
Exhaust gas recirculation reduces the peak combustion temper-
ature thus decreasing NOx emissions.
An intercooling or aftercooling unit following the turbo-
charger increases the air density and reduces the inlet air temper-
ature leading to a decrease in NOx formation, and the opportunity
to increase engine efficiency.
Injector and combustion chamber redesign and other engine
modifications will be aimed at reducing combustion chamber hot
spots and peak temperatures by modifying air motion in the chamber
and the spray pattern or angle of injectors. Changing the physical
characteristics of the combustion chamber itself is another avail-
able option, but this is more expensive.
Retarded injection timing has long been known as a NOx control
strategy. However, it does carry a fuel economy penalty and
sometimes causes an increase in the level of other pollutants.
Some manufacturers contend that it is as effective as EGR without
some of the potential engine durability problems associated with
EGR.
One final potential control technology is a form of high
pressure fuel injection. In some cases this has been shown to give
small, but significant, NOx reductions with accompanying decreases
in particulate levels and slight improvements in fuel consumption.
As alluded to above, both retarded injection timing and EGR
can provide substantial reductions in NOx emission levels.
However, it is generally known that tubstantial timing retard
usually leads to an increase in the levels of other pollutants (HC,
smoke) and causes a degradation in fuel economy. Conventional EGR
is more expensive than retarded timing and may have the same
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emission and fuel economy liabilities as retarded timing. However,
with the possibility of electronic controls for diesel engines, the
potential fuel economy and emission impacts may be avoided. To be
conservative in this analysis, EPA will assume that all manufact-
urers use EGR, even though some may choose to avoid the potential
engine durability problems associated with EGR by using only
retarded injection tuning.
Table V-Q shows EPA1s estimate of the first price increase for
the six methodologies described above. These figures are only
estimates and are subject to revision based on EPA's analysis of
public comment.
Having now identified the most readily available NOx control
strategies, these strategies must be spread over the heavy-duty
diesel fleet and costs allocated appropriately.
EPA's initial estimate of this allocation, on a fleetwide
basis as shown in Table V-R. Percentages less than 100 indicate
that the technology is already implemented or will be prior to
1985.
In conclusion, the hardware costs for diesel heavy-duty
engines can be computed as shown below, using the percentages and
costs from Table V-R.
1($400) + 1($50) + .33($275) + 1($25) + 1($150) - $716.67
The exact amount of NOx reductions available with the emission
control approaches described above has not been quantified, nor has
the fuel economy impact of these approaches been quantified. The
cost estimates being made here should be considered only order of
magnitude estimates and could be off by as much as fifty percent
for some engines families.
Manufacturers are strongly urged to supply EPA with data in
this area that can be used to more precisely quantify the possible
NOx reductions and fuel economy impacts available with varying
emission control strategies.
c. Certification
Under this new proposal the costs of certification can be
divided into three distinct areas: preliminary deterioration
factor assessment, emission data engine testing, and in-use dura-
bility testing. These three areas will be discussed below for both
gasoline-fueled and diesel heavy-duty engines.
i. Preliminary Deterioration Factor Assessment
The first step involves the determination of preliminary
deterioration factors for the regulated pollutants. These deteri-
oration factors must be multiplicative in nature for both gasoline-
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Table V-Q
First Price Impact of NOx Control
Technologies for Heavy-Duty Diesels
Electronic Engine Controls_I_/_3/ $400
Proportional EGR2/JJ/ $ 50
Intercooling/Aftercoolingl/ $275
Injector/Combustion Chamber Redesign and $ 25
Mod i f icat ions_l/
Retarded Injection Timing2/
High Pressure Fuel Injection $150
T7Slight fuel economy gain possible.
2/ Slight fuel economy loss possible.
7/ Includes associated allowable maintenance coBts.
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Table V-R
Fleetwide NOx Control Technology Application
Percent of Cost per Engine
Control Technology Fleet Impacted EPA Estimate
Electronic Engine Controls 100% $400
Proportional EGR 100% $ 50
Intercooling/Aftercooling 33% If $275
Injector/Combustion 100% $ 25
Chamber Redesign
Retarded Timing 100%
High Pressure Fuel Injection 100% $150
17 In 1985 approximately 50 percent of sales are expected to be
turbocharged and aftercooled with 17 percent naturally aspirated
and 33 percent turbocharged only.
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fueled and diesel heavy-duty engines. The engine manufacturer may
determine these preliminary deterioration factors in any manner it
deems necessary to ensure that the preliminary deterioration
factors it submits to EPA for certification purposes are accurate
for the full useful life. Manufacturers must state that their
procedures follow sound engineering practices and specifically
account for the deterioration of EGR, air injection, catalysts,
oxygen sensors, electronic controls as well as other critical
deterioration processes which the manufacturer may identify. In
addition, where applicable, the manufacturers must follow the
allowable maintenance intervals established for the emission-
related items. The manufacturer would submit full life deteriora-
tion factors in each case where current certification procedures
require testing of a durability data engine. Beyond these require-
ments EPA would not approve or disapprove the manufacturers pre-
liminary deterioration factor assessment procedures.
For the purpose of this cost analysis, the following assump-
tions are reasonable based on past practice. In 1985 the manufac-
turers will certify one emission control system per engine family
resulting in the need for one set of preliminary deterioration
factors for each family. As a base for this cost estimate, EPA has
assumed that the manufacturers will follow the current procedures
established by EPA. For a gasoline-fueled engine, this is a 1500
hour period with an emissions test each 125 hours, plus tests
associated with scheduled maintenance. For a diesel engine this
covers 1,000 hours with a test each 125 hours plus tests associated
with scheduled maintenance.
The cost of preliminary deterioration factor assessment for
each engine type is shown in Table V-S. These costs are based on
manufacturers comments on the recently promulgated 1984 heavy-duty
engine emission standards, but have been increased slightly to
allow for the effects of increased fuel cost and inflation over the
period.20/
ii. Emission Data Engines
Step two involves emission data engines. This part of the
certification program remains relatively unchanged from the
current procedure. One to four engines will be required for
each engine family. These engines would then be operated for
125 hours in a procedure designed by the manufacturers prior to the
emission test. The preliminary deterioration factor will then be
multiplied by the 125-hour emission data test results to predict
whether the emission data engines would meet the standards for
their full useful life. If the emission data engines are predicted
to pass the standards over the full useful life, then the engine
family is granted certification.
For the purpose of this cost analysis EPA will assume that
three gasoline-fueled emission data engines are tested from each
family. In addition, two diesel engines will be tested from each
-------
-180-
Table V-S
Certification Tests
Test . Gasoline-Fueled 1/ Diesel 2/
Prelminary deterioration $123,000 $109,000
factor assessment^/
125 hour emission $ 13,000 $ 20,000
data engine 4/
17 Includes normal emissions testing and idle test.
2/ Includes normal emissions testing and smoke test.
2/ Assumes manufacturers follow current durability procedures,
but this is not required.
4/ The manner in which the 125 hour break-in period is conducted
is at the manufacturers discretion.
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-181-
family. In accordance with past practice EPA expects that manu-
facturers which qualify as "small volume" will have only one
emission data engine selected for testing.
The costs for emission data engine testing are shown in Table
V-S. As before, these costs are based on manufacturer comment on
the recent heavy-duty gaseous emission regulations for 1984.
iii. In-Use Durability Testing
The proposed in-use durability testing regulations require
that after a manufacturer is granted a certificate of conformity
for each heavy-duty engine family, based on preliminary deteriora-
tion factors, it must then start a program of in-use service
accumulation including periodic emissions testing. As a part of
this program, the manufacturer will select three or more production
engines from each affected family and place them into a representa-
tive vehicle. Each manufacturer will be permitted to waive
durability testing for any engine family whose projected sales does
not exceed 5,000 engines per year, up to a total of 5,000 engineB
per manufacturer.
These engines will be run on a dynamometer for 125 hours to
determine their low mileage emission levels consistent with the way
emission data engines are tested. The manufacturers must then
install these engines into representative vehicles and may then
either place these vehicles into a typical service application as
would be done by a consumer, or operate the vehicles on a test
track or on public roads solely to accumulate mileage. The vehi-
cles will accumulate mileage at a prescribed rate over each year
and the engines would be tested for emissions at intervals of four
to twelve months, at the manufacturers discretion. Mileage accumu-
lation and.emissions testing will continue until the engine reaches
its average useful life as prescribed by the manufacturer in its
certification application. The results of the periodic emission
tests will be used to generate in-use deterioration factors which
will replace the preliminary deterioration factor.
EPA has indentified costs in five major areas associated with
in-use testing. The first major expense involves the "purchase" of
heavy-duty vehicles/engines for use in the fleets. The proposed
regulations require that each manufacturer run three vehicles per
family. As a reasonable first estimate this analysis will assume
that each manufacturer places half of its fleets into a corporate
motor pool (useful service application) and half of the vehicles
are run solely to accumulate mileage. Those heavy-duty vehicles
irtiich are placed into a useful service application will probably
replace other heavy-duty vehicles already being used in the manu-
facturer's corporate fleet, so no real additional cost to the
manufacturer will occur. However, those heavy-duty vehicles %toich
are run just to accumulate mileage will have to be "purchased."
These vehicles will also be available to replace vehicles in the
corporate fleets when they are undergoing emissions testing. Based
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-182-
on discussions with retail dealers, EPA estimates that heavy-duty
gasoline-fueled vehicles cost an average of $16,000 and heavy-duty
diesel vehicles cost an average of $35,000.
The second major expense involves initial emissions testing
for all heavy-duty engines in the in-use fleets. Three sets of
expenditures are expected: zero hour emission tests (3), 125 hours
of mileage accumulation, and 125 hour emission tests (3). Based on
the emission data engine test costs shown previously, these tests
will cost about $39,000 for each gasoline-fueled engine family and
$60,000 for each heavy-duty diesel family.
A third major expense involves engineering supervision of the
in-use fleets. For each manufacturer which is required to run
at least one in-use fleet, EPA expects one additional supervisory
engineer will be necessary. For the purpose of this analysis, it
is reasonable that each manufacturer will require approximately
three years for heavy-duty diesel engines and four years for
heavy-duty gasoline engine manufacturers. Thus the additional
engineering postion will be required for these periods. After the
initial in-use fleets have completed testing, the number of new
fleets which might be required in future model years should be
small enough that the permanent certification staff could absorb
the additional supervision and administration. For the purpose of
this analysis, a total compensation and overhead cost of $60,000
per engineer is reasonable.
A fourth major expense is the actual cost of running the
in-use fleets. As stated previously, the manufacturers will have
the option of running the vehicles solely to accumulate mileage
or placing the vehicles into a useful service application. If the
in-use fleets are run just to accumulate mileage then all of the
running expenses will be an additional cost to the manufacturer.
If the in-use fleets are placed into useful service application,
such as a corporate motor pool, then no additional running expense
will be incurred. As before, EPA will assume that one-half are
driven solely to accumulate mileage and one-half are placed into a
useful service application. Assuming an average useful life of
100,000 miles for heavy-duty gasoline engines and 200,000 miles for
heavy-duty diesel engines the per family operating costs are
estimated at $600,000 and $525,000 per family respectively.
The final major expense is the cost of emissions testing
during the useful life. There is great flexibility in the emis-
sions testing requirements, but testing is required annually, and
three tests are allowed each time an engine is tested. As a
conservative estimate, EPA will assume that the manufacturers test
their in-use fleets each four months and that each engine is tested
three times at each 4 month test point. This amounts to a total of
nine tests per engine per year, or twenty-seven tests per family
per year. EPA expects that scheduled maintenance tests will be
used as one of the three tests each year. As will be detailed
later, this testing cost amounts to $31,500 per year for each
-------
-183-
heavy-duty gasoline engine family and $36,000 for each heavy-duty
diesel family.
Based on 1980 certification data and publicly known manufac-
turer product plans for the next five years, EPA expects that there
will be a total of 14 heavy-duty gasoline engine fleets and 19
heavy-duty diesel fleets. The 5,000 engine per manufacturer waiver
will allow waivers for 3 heavy-duty gasoline families and 35
heavy-duty diesel families, but only 10 percent of total sales.
Table V-T summarizes the pre in-use certification costs for
both types of engine manufacturers, and Table V-U summarizes all
in-use durability testing costs. Finally, Table V-V combines the
results of the two preceding tables, and presents total certifica-
tion costs by year and engine type.
As can be seen in the tables, the preliminary deterioration
factor assessment costs sum to $3,793 million dollars, emission
data engine costs sum to $2,019 million dollars and in-use dura-
bility testing costs sum to $15,833 million dollars. If all in-use
fleets were placed into a useful service the in-use durability
costs would drop to $4,998 million dollars. If all fleets were run
solely to accumulate mileage, in-use testing costs would rise to
$26,668 million dollars.
d. Allowable Maintenance
Due to the critical nature of several emission related com-
ponents, EPA has proposed, and in some cases already promulgated,
maintenance intervals for important emission related components.
EPA is very concerned that these components function properly over
the useful life of the engine and that they be replaced or main-
tained if necessary.
The most desirable situation is that the component durability
be such that the recommended maintenance interval equal or exceed
that average useful life of the engine. EPA has therefore proposed
full life (100,000 mile) maintenance intervals for both electronic
engine controls and oxygen sensors. Electronic engine controls
should be able to achieve or surpass this maintenance interval with
little or no additional cost. As discussed briefly earlier in this
section, this may not be the case for oxygen sensors. EPA is
expecting that some R&D work will be necessary and that an in-
crease in material costs may be necessary. As a first, and con-
servatively high estimate, EPA will include a cost of about $1.50
per engine to cover improved materials and designs, in addition to
the R&D funds discussed previously. This $1.50 approximates the
current manufacturing costs of oxygen sensors.J/
Heavy-duty diesel engines using E6R for the first time will be
required to comply with the allowable maintenance provisions
related to E6R. Based on the options available in the allowable
maintenance proposal, diesel. engine manufacturers may either pay
-------
Table V-T
Certification Costs Prior to In-Use Testing
Gasoline-Fueled Engines
Large volume families
Small volume families
(waived)
(a)
Number of
Families J_/
14
1
(b)
Preliminary
DF Costs 2/
$1722K
(c)
Emission Data
Engine Costs _3/
$546K
§ 13K
(d)
Total
Costs hj
$2268K
$ 13K
i
oo
Diesel Engines
Large volume famlies
Small volume families
(waived)
19
35
69
$2071K
$3793K
$760K
$700K
$2019K
$2831K
$ 700K
$5812K
\J Based on 1980 certification data.
2/ (a) x values in Table V-S.
3j 3 engines large volume gas, 1 engine small volume gas,
2 engines large volume diesel, 1 engine small volume diesel.
4/ (b) + (c).
-------
table V-U
Iii-Use Durability Testing Costs
Number of
Initial
In-Use
In-Use
Durability
Vehicle
Emissions
Engineering
Fleet
Emissions
Total
Fleets 1/
Purchase 2/3/
Testing 4/
Supervision 5/
Operation 6/
Testing 7/
Costs
Gasoline-Fueled Engines
14
$ 335K
$ 546K
$ 960K
$4200K
$ 588K
$ 6629
Diesel Engines
19
$1050K
$1140K
$1080K
$5250K
$ 684K
$ 9204K
33
$1385K
$1686K
$2040K
$9450K
$1272K
515833K
\J Same as number of large volume families on Table V-T.
2/ Assumes 3 vehicles per family at 35K for diesel and 16K for gasoline.
3/ Assumes one-half are placed in useful application and as a result do not incur this expense.
4/ $39K per gasoline family and $60K per diesel family.
_5/ $6OK per year per manufacturer - 4 gasoline engine and 6 diesel manufacturers - 4 years gasoline and 3 years diesel.
6/ $150K per year per gasoline family and $175K per year per diesel family.
TJ $10,500 per year per gasoline family and $12,000 per year per diesel family.
i
m
CD
r
-------
Year
Prelim DF
Assessment
Gasoline-Fueled Engines 1983
1984
1985
1986
1987
1988
Diesel Engines 1983
1984
1985
1986
1987
$1722K
$2071K
Table V-V
Heavy-Duty Engine
Certification Costs by Year
Init ial In-Use In-Use
Emission Data Vehicle Emissions Engineering Fleet Emissions
Engines Purchase Testing Supervision Operation Testing
$ 559K
$335K
$546K
$240K
$240K
$240K
$240K
$1050K
$1050K
$1050K
$1050K
$147K
$147K
$147K
$147K
$1460K
— $1050K
$1140K $360K
— $360K
$360K
$1750K $228K
$1750K $228K
$1750K $228K
-------
-187-
for EGR maintenance at each 50,000 mile interval or see that
visible or audible signals are placed in heavy-duty vehicles which
inform the operator that EGR maintenance is necessary. If the
visual or audible signal option is chosen, the engine manufacturers
must also supply survey data which shows that the signal is effec-
tive in getting the heavy-duty diesel vehicle operators to perform
the EGR maintenance.
EPA estimates the visual or audible signal and the required
survey would require less than $3 per heavy-duty diesel vehicle,
but this figure will be used as the approximate cost. This cost
has already been included in the $50 estimated as a first cost
increase associated with heavy-duty diesel EGR.
e. Total Costs to Manufacturers
The five major costs to manufacturers R&D, emission control
hardware, certification, in-use durability testing, and allowable
maintenance are summarized in Table V-W and are shown in 1980
dollars. The costs are shown in the year in which they are ex-
pected to occur and inherently include overhead and profit.
2. Costs to Users of Heavy-Duty Engines
a. Increases in First Costs
The added cost to manufacturers for R&D certification, allow-
able maintenance, and emission control system hardware and engine
modifications will be passed on to the purchasers of heavy-duty
engines. The amount a manufacturer must increase the selling price
of its engines to recover its expenses depends on the timing of
costs and revenues received from sales and on the costs of capital
to the manufacturer. Table V-W presented a schedule of the timing
of the manufacturers costs for the period 1981-1989.
EPA expects that over the long run manufacturers face a 10
percent cost of capital and that they increase the engine selling
price to recover their investment in five model years, 1985-1989.
Using standard discount methodology, and discounting at 10
percent to the first year in which expenses are recovered, 1985,
the expected average first price increase for heavy-duty gasoline-
fueled engines is $284 and $741 for heavy-duty diesel engines.
These figures are both in 1980 dollars.
For heavy-duty gasoline-fueled engines these costs are $6.46
for R&D, $1.31 for certification, $2.85 for in-use testing,
$6.66 for allowable maintenance and $267 for emission control
hardware. For heavy-duty gasoline-fueled engines with three-way
catalysts this cost is $194 and for those engines with three-way
plus oxidation catalysts the average first price increase is $289.
For heavy-duty diesel engines the first price increase is
comprised of $17.35 for R&D, $2.15 for certification, $4.57 for
-------
-188-
Table V-W
"Sear
Heavy-Duty Engine
Manufacturers Compliance Costs Yi
R&D
Certification
In-Use
Testing
Gasoline-Fueled
Allowable
Maintenance
Emission
Hardware
1981
1982
1983
1984
1985
1986
1987
1988
1989
$ 2000K
6000K
1500K
500K
$ 17 22K
559K
$2318K
1437K
1437K
1437K
$1600K
480 OK
1200K
400K
741K
752K
756K
733K
71 IK
$131,898K
133,767K
134.568K
130,563K
126.558K
Diesel
1981
1982
1983
1984
1985
1986
1987
1988
1989
$ 3000K
15000K
5000K
200CJK
$2071K
1460K
$4528K
2338K
2338K
$278,068K
306.018K
333.252K
350.452K
368,368K
1/ Undiscounted costs, 1980 dollars.
-------
-189-
in-use testing and $716.67 for emission control hardware and
related engine modifications. The technology which might be
used to meet the proposed standard is not adequately defined or
developed to justify any further detail at this time.
b. Fuel Economy
The proposed regulations could have both positive and negative
fuel economy benefits.
Fuel economy gains will probably be available for gasoline-
powered heavy-duty vehicles in as many as three areas: electroni-
cally controlled fuel metering with feedback carburetors, removal
or reduction of air injection requirements, and efficient recovery
of fuel from the evaporative emissions storage canister.
The use of electronic engine controls with a feedback carbur-
etor allows the air/fuel ratio to be maintained nearer stoichio-
metric conditions and thus allow the most efficient use of the
energy available in the fuel. This should lead to a fuel economy
gain, but the absolute amount of the gain may be as little as two
to three percent.
A second potential fuel economy gain lies in the strong
probability that there will be a reduction in the amount of
air injection required for these engines. In the 1984 heavy-duty
gaseous emission regulations EPA projected that manufacturers would
need to double or perhaps triple the volume of air injection. EPA
estimates that reducing the amout of air injection could yield a
fuel economy savings of approximately 4 percent.21/
The use of feedback carburetors together with the evaporative
emission control hardware expected for the proposed 3.0g evapora-
tive emission standard for heavy-duty gasoline-fueled engines
should allow the efficient use of the evaporated fuel stored in the
canister. This fuel would then be burned as normal fuel instead of
being "purged" and burned in a rich mixture. With a 3.0 g/test
standard, EPA estimates a fuel savings of about 1.62 g/mile.22/
Conversely, heavy-duty gasoline-fueled engines using EGR for
the first time may incur a fuel economy penalty. At this point it
is not clear whether these engine will Tequire EGR, but if they do
a penalty in the range of 0 to 5 percent is possible. These
engines may be able to meet the emission standards solely with a
three-way catalyst and engine modifications. Electronically
controlled EGR, which has not yet been used on heavy-duty engines,
may lead to the elimination of any negative emission or fuel
economy impacts of EGR.
These potential savings and penalties will not be incorporated
in this proposal, but Figure V-*B gives some indication of the
potential impact over the useful life. These figures have been
computed using a fuel cost of $1.30 per gallon, a fleet average
-------
Fiaure V-fi
H DV Fuel EEconoir^ CVvojrvge. (."&>)
-------
-191-
fuel economy of 10 miles per gallon, a 114,000 mile/8 year life-
time, and a 5 percent discount rate.^_3/ These computations
ultimately show that each one percent change in fuel economy yields
a $129 change in operating costs for fuel. (See Figure V-B.)
The fuel consumption of heavy-duty diesel engines may suffer
as a result of these regulations. The use of conventional EGR and
retarded timing to control NOx emissions usually yields a fuel
economy penalty. The range of these penalties is difficult to
estimate but fuel economy on a percentage basis could drop by as
much as 10 percent depending on the degree of timing retard and the
amount of exhaust gas recirculation. It may be possible to avoid
any fuel economy penalties associated with conventional EGR by
employing electronically controlled EGR in its place. This has not
yet been done on heavy-duty engines so the effectiveness of elec-
tronic controls in programming diesel EGR is unknown. However,
this has been accomplished in light-duty vehicles.
Conversely, the addition of electronic engine controls and
intercooling/aftercooling may yield a fuel economy improvement.
The same is also true for combustion chamber/injector redesigns and
modifications.
At this point EPA cannot accurately quantify the full fuel
economy effects on heavy-duty diesel engines. EPA is very concern-
ed about the fuel economy impact of the proposed emission standard
and strongly desires manufacturers comments on the fuel economy
impacts of diesel EGR, injector timing retard, plus the potential
benefits with electronic engine controls and intercooling/after-
cooling.
Figure V-B demonstrates the fuel economy impact of these
regulations on a per vehicle basis for the average heavy-duty
diesel vehicle. This line was constructed using a fleet average
fuel economy of 7 miles per gallon, a diesel fuel cost of $1.10 per
gallon, a 5 percent discount rate, and a 475,000 mile/9 year
lifetime.23/ Each percent loss of fuel economy for heavy-duty
diesel engines means an additional lifetime consumption of 580
gallons of diesel fuel at a cost of $638.
Because of the rising cost and projected scarcity of motor
vehicle fuel EPA is very concerned about the fuel economy impacts
of the proposed emission standards. Manufacturers comment is
requested on the potential fuel economy improvements and fuel
economy losses described above.
c. Total Costs to User
To summarize, owner/operators of gasoline-powered heavy-duty
vehicles can as a result of the proposed NOx emission standard
expect an average first price increase of about $284 per engine.
Operating cost changes for these engines have not been quantified,
but should be slightly decreased as a result of improved fuel
consumption characterisitics.
-------
-192-
Heavy-duty diesel engines would increase in price by an
average of $741 per engine, and would probably have increased
operating costs due to the loss of fuel economy. This fuel
economy loss cannot be precisely quantified, but the lifetime
impacts could be in the thousands of dollars per vehicle.
3. Aggregate Costs
The aggregate cost to the nation of complying with the 1985
Federal heavy-duty emission regulations consist of the sum of
increased costs for research and development, certification, in-use
durability testing, allowable maintenance, and emission related
hardware. These costs will be calculated for a five year period of
compliance (1985-1989), but will not include changes in fuel
operating costs which may occur for vehicles produced in that
period. These costs have not been included because the potential
benefits and losses cannot be accurately quantified for this
proposal.
The five year costs of compliance are dependent on the number
of heavy-duty vehicles sold during that period, and the mix of
gasoline-fueled and diesel engines used in those vehicles. The
accuracy and validity of projecting vehicle sales as far as nine
years into the future is problematic, so cost estimates based on
such projections are subject to some qualification. The engine
sales scenario which EPA used to make these cost calculations is
discussed in detail in Chapter II of this analysis. These sales
figures reflect the rerating of LDTs to heavy-duty vehicles which
manufacturers projected in their comments to the recent LDT fuel
economy standards proposal and the increased dieselization expected
in all heavy-duty classes.24/20/
The various costs associated with the regulations will occur
in different periods. In order to make all costs comparable, the
present value in 1985 of the aggregate costs has been calculated,
based on a discount rate of 10 percent. Use of a discount rate
emphasizes that because of the time value of money, a cost incur-
red today is worth more to the nation than a cost incurred in the
future.
The calculation of the present value in 1985 of the aggregate
costs is shown in Table V-X. The timing assumptions used in Table
V-W were used in computing the aggregate costs. It is estimated
that the aggregate cost of complying with the proposed regulations
for the five year period is the equivalent of a lump sum investment
of about $1.98 billion dollars (1980 dollars) made in 1985.
Expressed in other terms, the aggregate cost of compliance is
equivalent to investments of $741 per diesel engine and $284 per
gasoline-fueled engine made at the start of the year the engine is
produced.
For ease of reference, the components of the costs of compli-
ance and the different ways of expressing it are shown in Tables
V-Y, V-Z, and V-AA.
-------
-193-
Table V-X
Heavy-Duty Engine
Present Value in 1985 of the Aggregate Cost of
Compliance for the 1985-1989 Model Years
Year Cost Present Value in 1985
Gasoline-Fueled (2,462,000 engines)
1981
3,600 K
5,271
K
1982
10,800 K
14,375
K
1983
4,422 K
5,351
K
1984
1,459 K
1,605
K
1985
134,957 K
134,957
K
1986
135,956 K
123,597
K
1987
136,761 K
113,019
K
1988
132,733 K
99,723
K
1989
127,269 K
86j925
K
584,823 K
Diesel (2,283,000 engines)
1981
3,000 K
4,392 K
1982
15,000 K
19,965 K
1983
7,071 K
8,556 K
1984
3,460 K
3,806 K
1985
282,596 K
282,596 K
1986
308,356 K
280,324 K
1987
335,590 K
277,347 K
1988
350,452 K
263,300 K
1989
368,368 K
251,600 K
1,391,886 K
1985 Present Value of Aggregate Cost $1,976,709 K
-------
-194-
Table V-Y
Undiscoutited Costs of Compliance per Engine
for Engines Produced 1985-1989
Cost Affecting Selling Price
Research, Development & Testing
Certification
In-Use Durability Testing
Allowable Maintenance
Emission Control Hardware
Gasoline-Fueled
$4.06
.93
2.69
4.75
267.00
$279.43
Diesel
$10.95
1.55
4.03
716.67
$733.20
Operating Cost
Change in Fuel Cost
per Percent Change in
Fuel Economy
+$150
+$754
-------
-195-
Table V-Z
Discounted Costs of Compliance per Engine
for Engines Produced 1985-1989 1/
Costs Affecting Selling Price
Research, Development & Testing
Certification
In-Use Durability Testing
Allowable Maintenance
Emission Control Hardware
Gasoline-Fueled Diesel
$6.46 $17.35
1.31 2.15
2.86 4.57
6.66
267.00 716.67
$284.29 $740.74
Operating Cost 2/
Change in Fuel Costs +$129 -*-$638
per Percent Change
in Fuel Economy
1/ 10 percent discount to January of the modeL year.
7/ 5 percent discount to January of the model year.
-------
-196-
Table V-AA
Aggregate Cost of Compliance
for Engines Produced 1985-1989
(10 Percent Discount to January 1985)
Gasoline-Fueled
Research, Development, & Testing $13,279 K
Certification 2,699 K
In-Use Durability Testing 5,891 K
Allowable Maintenance 13,709 K
Emission Control Hardware 549,244 K
Change in Aggregate Cost +$284 M
per 1 Percent Change in
Fuel Economy :_1/
T7 Five percent discount rate used.
Diesel
$32,607 K
4,112 K
8,586 K
1,691,109 K
+$1,289 M
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-197-
Th e effect of fuel economy changes on the aggregate costs of
this package could be substantial. For every 1 percent change in
the fleetwide fuel economy of gasoline-fueled engines the aggregate
cost changes by $284 million dollars. For every 1 percent change
in the fleetwide fuel economy of diesel engines the aggregate cost
changes by $1289 million dollars.
4. Socio-Economic Impacts
a. Impacts on Manufacturers
i. Capital Expenditures
The proposed regulations and emission standards for 1985 and
later model year heavy-duty engines will cause the manufacturers of
these engines to spend considerable sums in capital costs.
For purposes of this analysis capital costs will be defined as
any funds expended before a return on investment is received. In
this case all pre-1985 expenditures fall into this category.
Some of the more obvious capital expenditures have been
discussed previously. For example, research, development and
testing, certification, and research aimed at increasing the
lifetime of oxygen sensors and electronic engine controls.
However, there are some other pre-production research and
tooling costs which are much more difficult to estimate.
For gasoline-fueled engines there are tooling costs for
catalysts, electronic engine controls, feedback carburetors and
oxygen sensors. There costs may not have as large an impact on the
manufacturer primarily because they are vendor produced. However,
the manufacturer may have some small retooling costs during vehicle
or engine assembly to account for new or redesigned components.
EPA's estimate of the capital costs for gasoline engine
manufacturers and their vendors is shown in Table V-BB. For
gasoline-fueled heavy-duty engines all of the capital investments
identified sum to to $172 million dollars. However, these costs
may not have as large an impact as the dollar amount might other-
wise indicate. The figures presented here cover a four-year period
(1981-1984) and are spread over the entire industry (four manu-
facturers and numerous vendors). In some cases these costs do not
represent a pure incremental increase in expenditures. Manufac-
turers are always making expenditures for recertification, product
improvement and expendable tooling.
The capital requirements for heavy-duty diesel manufacturers
is also very difficult to estimate. The R&D and certification
costs discussed previously would qualify as capital expenditures
and are included. Manufacturers would also have tooling costs
associated with the combustion chamber/injector redesign antici-
-------
-198-
Table V-BB
Heavy-Duty Gasoline Engine
Pre-1985 Capital Expenditures
(1980 Dollars Undiscounted)
Development and Testing $ 10,000 K
Certification 2,281 K
Allowable Maintenance Intervals 15,000 K
Vendor Related R&D $144,448 K
Tooling and equipment for
production of catalysts,
closed loop electronic
controls, and other emission
related hardware
$171,729 K
Table V-CC
Heavy-Duty Diesel Engine
Pre-1985 Capital Expenditures
(1980 Dollars Undiscounted)
Research and Development $ 25,000 K
Certification 3,477 K
Tooling and Equipment $100,000 K
Combustion Chamber
EGR
High Pressure Injection
Electronic Engine Controls
$128,477 K
-------
-199-
pated and the addition of EGR. EPA also anticipates manufacturers
will spend substantial R&D funds developing electronic engine
controls for diesel engines. At this point, these costs are
difficult for EPA to estimate. As a first estimate an industry-
wide cost of $100 million dollars seems reasonable. This would be
primarily combustion chamber/injector redesign costs (development
and tooling) plus tooling aimed at the addition of EGR, inter-
cooling/ aftercooling and electronic engine controls. This cost
represents only the most preliminary of estimates and probably
overestimates the amount in dollars. EPA believes this to be true
because much of the projected capital cost is related to the
combustion chamber/ injector redesign, which will already have
undergone some work in relation to the 1984 heavy-duty HC and CO
standards.
The total capital expenditures estimated for the heavy-duty
diesel industry sum to $128 million dollars over the four year
period 1981-1984. These costs are spread over the entire heavy-
duty diesel industry and will probably have the greatest dollar
impact on the manufacturers with the largest number of engine
families. Currently, sixteen manufacturers certify 54 heavy-duty
diesel families.
EPA would like to be able to identify these costs on a manu-
facturer by manufacturer basis, but does not believe that suf-
ficient data is available at this time to warrant that degree of
detail. EPA requests manufacturers data on their expected capital
requirements relating to this proposed emission standard. The
current level of data available to EPA is insufficient to allow any
meaningful apportionment of these capital costs on a manufacturer
by manufacturer basis. At this point, any preliminary analysis on
the ability of manufacturers to finance the required investment
would have little meaning primarily because capital expenditure
costs cannot be accurately apportioned to each manufacturer.
ii. Effects on the Demand for Heavy-Duty Engines
Changing the prices and potentially changing the operating
costs of heavy-duty engines may impact the sales of engine manu-
facturers. Both total sales and the sales mix between diesel and
gasoline-fueled engines may be affected. EPA knows of no estimate
of the cross elasticities of demand for gasoline-fueled and diesel
engines. When considering the change in sales mix, the cost of
ownership, as well as the increased first cost, may cause a demand
shift. Based on the average first cost increase ($284 gasoline-
fueled and $741 diesel) the demand shift would appear to be toward
gasoline engines. This demand shift may be increased by the
projection that the average heavy-duty gasoline engine will proba-
bly have a small fuel economy gain, and the average heavy-duty
diesel engine may have a fuel economy loss.
The impact of the proposed regulations on the sales mix
between gasoline and diesel engines must be viewed in the total
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context of the gasoline/diesel engine picture. The existing price
difference between gasoline-fueled and diesel engines, (as much as
a factor of three) may make gasoline engines more attractive. In
addition, the potential fuel economy impacts will have the same
effect. However, there is more to the buyers decision than these
facts. Even with the potential changes in fuel economy gasoline
engines still will be substantially less fuel efficient than
diesels. In addition gasoline engines have higher maintainence
costs and are less durable. It appears that the major impact of
these proposed regulations might be a slowing of the increased
dieselization expected over the next decade.
EPA's Office of Noise Abatement Control has estimated the
overall price elasticity of demand for new trucks to be in the
range of -0.9 to -0.5.16/ If the mid-range elasticity (-0.7) is
used, and a range of $10,000 to $60,000 is assumed for the selling
price of heavy-duty vehicles, the added cost of compliance with the
proposed 1985 regulations would reduce sales from .7 percent to 5.2
percent.25/ Manufacturers of heavy-duty engines and vehicles
withstood a much larger drop in sales around 1975 due to general
economic conditions, but sales have since recovered well. The
small decrease in total industry sales which might occur as a
result of the proposed regulations will be more than offset by
normal sales growth, and thus can be expected to have no noticeable
effect on any manufacturer's growth.
EPA does not expect heavy-duty vehicle sales or the trucking
industry in general to suffer because of a shift in the mode of
freight transportation used. Rail and air are not reasonable
alternatives for intracity freight movement. The vast majority of
"over-the-road" freight movement is done by heavy-duty diesel
trucks. This is expected to continue unless substantial industry
and government initiatives are made to shift some freight movement
to other modes. The purchase price of heavy-duty diesels are not
affected by a sufficient amount to warrant anything but a slight
increase in intracity freight hauling costs.
Total bus sales and the bus transportation industry as a whole
should suffer no loss in sales or ridership. The cost increases
due to these regulations will not offset the fact that buses are
the best option for the transportation of school children and
intracity transport. The intercity bus ridership should show no
decrease because the per passenger cost of these regulations is a
negligible amount when compared to other factors in the total
ticket price.
Sales by some individual manufacturers of heavy-duty diesel
engines may decline more than predicted by overall demand price
elasticity. This could result from small volume manufacturers
having to spread their costs for research and development and
certification over their small sales. These costs depend primarily
on the number of engine families certified, not on the sales of
engines within those families. Thus smaller volume, primarily
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foreign manufacturers like Deutz, Volvo, Hino, Fiat, Scania Vabis,
and others will have larger price rises than larger volume, domes-
tic manufacturers like Mack, Detroit Diesel (GM), Cummins, and
Caterpillar. Smaller volume diesel engine manufacturers may find
the diesel engine market less profitable as a result.
b. Impact on Users of Heavy-Duty Vehicles
Users of heavy-duty vehicles will be affected by the higher
costs for the vehicles they use to transport goods, and this
in turn will affect the prices consumers pay for the products
transported by trucks.
The expected first cost increases of $741 for vehicles
equipped with diesel engines and $284 for those with gasoline
engines should not substantially impact either fleet owners' or an
individual owner/operator's ability to pay for new heavy-duty
vehicles, since these costs represent at most 6 percent of a
vehicle's sales price.
There is of course the operating cost impact of potential
changes in fuel economy. Discounted operating costs change by 12
cents per mile for heavy-duty gasoline-powered vehicles and .+ .13
cents per mile for heavy-duty diesel vehicles for each one percent
change in fuel economy.
c. Effects on Energy Use
Gasoline-powered heavy-duty vehicles will probably experience
a net fuel economy gain as a result of these regulations. Fuel
economy improvements available from reduced air injection require-
ments, efficiently burned evaporative emissions and more precise
control of the air/fuel ratio may be partially offset by the first
time need for EGR on approximately one-half of the fleet.
Heavy-duty diesel engines may experience a net fuel economy
loss. Fuel economy gains from electronic engine controls, inter-
cooling/ aftercooling, and combustion chamber redesign will could be
offset by the fuel economy losses due to the addition of EGR and
retarded injection timing.
In neither case can these gains or losses be accurately
quantified on a fleetwide basis. Each one percent gain or loss in
the heavy-duty gasoline engine fleets means a lifetime per vehicle
change in fuel consumption of about 110 gallons of gasoline. Each
one percent gain or loss in the heavy-duty diesel fleet means a
change of about 670 gallons of diesel fuel consumption over the
vehicle lifetime.
d. Balance of Trade Effecta
The implementation of these regulations will have a small
impact on the U.S. balance of trade.
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American manufacturers who sell gasoline-fueled and diesel
heavy-duty engines overseas will build these engines to comply with
the emission standards of the importing country. Therefore, no
loss in foreign sales is expected as a result of these regulations.
The stringency of the proposed NOx emission standard and the
expected difficulty and cost of achieving compliance may lead one
or more small volume foreign manufacturers to withdraw from the
American market. If this were to happen there would of course an
impact on the balance of trade. Any small volume manufacturer
could withdraw from the market with little or no effect on compe-
tition resulting.
The use of three-way and three-way plus oxidation catalysts on
heavy-duty gasoline engines will cause an increase in the imports
of noble metals. The incremental change in these imports is shown
below, for the 1985 model year.
Annual Noble Metal Imports Due to HDG(Troy oz)
1985 1985
No Revised NOx Standard Revised NOx Standard
Platinum 89,840 111,267
Palladium 44,920 20,618
Rhodium 0 7,861
At current market prices these figures translate into an
annual increase of $6.9 million for platimum and $4.8 million
dollars for rhodium, and a decrease of $4.2 million dollars for
palladium. The net annual increase in imports comes to an average
of $7.5 million dollars per annum.
Finally the potential fuel economy impact of these regulations
could have a large impact on the baLance of trade. Since the
actual fleetwide gains and losses cannot be accurately quantified
at this time no attempt will be made to estimate the aggregate
impact on the balance of trade. Each 1 percent change in fuel
economy for heavy-duty gasoline engines over the vehicle life means
110 gallons of fuel or about 2.6 barrels of oil. At $30 per barrel
this comes to $78. For heavy-duty diesel engines each one percent
change in fuel economy means 670 gallons of diesel fuel or about
$479 dollars.26/ With expected sales of 2.246 million gasoline
heavy-duty engines and 2.283 million diesel heavy-duty engines it
is easy to see how even small gains or losses in fuel economy could
have a very large positive or negative impact on the balance of
trade.
c. Local and Regional Effects
The domestic heavy-duty engine manufacturers currently operate
assembly plants in ten different states, with the majority in the
upper midwest states of Michigan, Illinois and Indiana. Other
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plants are located in Ohio, Oklahoma, California, Pennsylvania,
and Kentucky.
Manufacturers which produce only heavy-duty vehicles operate
assembly plants in California, Indiana, Missouri, New York, Ohio,
Oregon, Pennsylvania, Tennessee, Texas, Utah, Virgina, Washington,
and Wisconsin.
It is reasonable that any minor sales decrease caused by these
regulations would be spread evenly over these states. Conversely
expenditures for R&D, tooling, and production of emission related
hardware would create or sustain jobs in many of these same states.
For example, heavy-duty catalytic converters could probably be
supplied from plants in Michigan, Pennsylvania, Oklahoma, New
Jersey, and other states. Research and development jobs would be
sustained or created at the major corporate technical centers
located primarily in Michigan, Indiana, and Illinois.
Based on the widespread production of heavy-duty engines and
the expected increase in production expected over the five year
period, EPA expects there will be little if any localized impacts
on employment. Sales of heavy-duty engines should continue to
increase slowly over the five year period thus preserving current
production jobs, and additional jobs in research, certification
testing, and production of emission-related components will be
created.
C. Urban and Community Impacts
Under both of the preceeding major sections of this chapter
(Section A, Light-Duty Trucks; Section B, Heavy-Duty Engines), we
have looked in some depth at the broad effects which might result
from this rulemaking. In this section, we will summarize some of
those conclusions (found in Sections A.4 and B.4, "Socio-Economic
Impacts") and use them as a basis for looking at possible impacts
on individual communities. It is clear from our analysis that such
impacts will in most cases be minimal.
We will consider LDTs and HDEs together dien it is possible.
1. Effects of Shifts in Production
If these regulations were to cause a shift in the demand
characteristics of the LDT or HDE markets, production shifts (both
in numbers and in location) could result. Such shifts would
certainly affect the employment in communities where major manu-
facturing facilities operate.
However, the conclusions of Secions A.4.a.ii. and B.4.a.ii. of
this chapter are that the amount of shifting in sales of both LDTs
and HDEs is likely to be "washed out" by normal sales growth.
Thus, since there will not be a noticeable effect on any single
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manufacturer1 s sales, there should also negligible effect on
employment patterns in the industry.
2. Effects of Increased R&D and Production of Emission
Control Technology
As the earlier sections of this chapter make clear, imple-
mentation of this rulemaking will require new expenditures for
research, development, tooling, and production. The nature and
anticipated magnitude of the pre-production costs are presented
in Sections A.4.a.i. and B.4.a.i. of this chapter. From the
perspective of employment impacts, it is important to note that
these costs—and the production costs themselves—will be widely
distributed among a number of manufacturers. In the case of
gasoline engines and vehicles, an even larger number of independent
vendors will also be spending money researching and devloping
three-way catalysts, electronics, and feedback carburetors. As a
result of the greater industry expenditures, many communities will
see a small increase in research and production jobs and/or an
extension for several years of existing jobs. Because of the wide
distribution of the spending, however, we believe that there will
not be any significant effect on the employment in any single
community.
3. Effects of Increased Product Costs
We discussed above how the demand patterns for 1985 LDTs and
HDEs—on which consumer cost is a primary influence—are not likely
to change appreciably as a result of these regulations. We will
now consider the direct effect of increased retail prices of
engines and vehicles on consumers. In this discussion we will
treat HDEs and LDTs separately.
i. Heavy-Duty Engines
Because of the commercial nature of HDEs, increased buyer
costs arc generally passed along in the cost of products hauled by
the trucks. Since the price of the average HDE will probably rise
by less than $750, the subsequent increase in the price of products
over the life of the truck will be hardly perceptible. Hence,
buyers of those products, whoever they are, will not feel any
effects from the increased engine price.
ii. Light-Duty Trucks
Buyers of LDTs, on the other hand, are usually private in-
dividuals, and they will be directly affected by the $50-$300
increase in vehicle cost (Table V-H, presented earlier in this
chapter). Clearly, the increased price will affect buyers nation-
wide, and hence, significant localized impacts should be few.
The expected average price increase of $153 per LDT amounts to
2 percent or less of the cost of a new vehicle. A cost increase of
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this magnitude will probably not have a significant effect on
buyers, although low-income people who buy LDTs will find the
increase to represent a larger fraction of their income than most
buyers.
4. Fuel-Related Effects
Buyers of 1985 gasoline-powered LDTs and HDEs will probably
see an improvement in fuel economy over earlier models. On the
other hand, diesel LDTs and HDEs may experience a loss in fuel
economy. In neither case are we able today to quantify the degree
of improvement or deterioration in fuel economy.
However, we can make some observations. The anticipated
increase in heavy-duty gasoline engine fuel economy, for example,
will offset to some degree any fuel-related increase in diesel
transportation costs. Because gasoline and diesel engines are
affected differently in this respect, consumers buying products
which are largely transported by gasoline-powered trucks will
benefit from lower product costs compared to buyers of goods which
are primarily diesel-transported. Dense urban areas are more
heavily served by local-delivery gasoline trucks than are other
areas, and it may be that this pattern will result in a relative
benefit to urban consumers. There is no reason to believe, how-
ever, that any particular urban area will be more or less affected
than any other.
Looking now at LDTs, increased or decreased fuel costs here
will directly affect owners. Buyers of gasoline-power LDTs will
experience lower operating costs with the 1985 models, and this
savings will at least partially offset the increased price tag.
Low-income buyers of LDTs will preferentially choose gasoline LDTs
over more expensive diesels and, hence, will tend to benefit
from the fuel-cost savings. Again, these effects should be geo-
graphically dispersed around the country.
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References
"Cost Estimations for Emission Control Related Components/
Systems and Cost Methodology Description," Rath & Strong Inc.,
March 1978, EPA-460/3-78-002.
An inflation rate of 8 percent per annum was used for the
period 1977-1980 inclusive. This is to be compared to the
composite CPI and new car CPI over the same period.
3 Year
1977 1978 1979 Compounded
EPA Analysis 8% 8% 8% 1.26
Composite CPI 6.8% 9% 13.3% 1.32
New Car CPI 7.2% 6.2% 7.4% 1.22
Because of the large difference between the new car CPI and
the composite CPI EPA believes the use of the 8 percent per
annum inflation rate gives a conservative evaluation of cost
increases in the motor vehicle industry for the three year
period 1977-1979.
A figure of 29 percent was used as the markup to cover
corporate and dealer overhead and profit. See page 328,
Summary and Analysis of Comments to the NPRM: 1983 and Later
Model Year Heavy-Duty Engines, December 1979, US EPA, OMSAPC,
ECTD.
See "Regulatory Analysis and Environmental Impact of Final
Emission Regulations for 1984 and Later Model Year Light-
Duty Trucks," US EPA, OMSAPC, ECTD, June 1980 and "Summary
and Analysis of Comments to the NPRM: 1983 and Later Model
Year Light-Duty Trucks," June 1980, US EPA, OMSAPC, ECTD.
The 40 percent/60 percent split is based on 1980 LDT certifi-
cation data.
"Regulatory Analysis of the Light-Duty Diesel Particulate
Regulations for 1982 and Later Model Year Light-Duty Diesel
Vehicles," US EPA, OANR, OMSAPC, February 1980, page 115.
SAE Technical Paper 800853, page 63.
EPA estimate based on costs for light-duty vehicles.
Based on GM and VW submittals for 1981 light-duty diesel NOx
waiver applications.
EPA memo, Light-Duty Vehicle Certification Costs, D. Hardin
Jr. to E. Brune, D. Kimball, and J. Marzen, March 13, 1975.
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11 / The calculation for gasoline-powered LDTs assumes a 120,000-
raile useful life, a 5 percent discount rate, a fleetwide fuel
economy of 20 miles per gallon, and an unleaded fuel price of
$1.30 per gallon. For LDDTs the same lifetime and discount
rate was used, and a fuel economy of 22 miles per gallon at a
cost of $1.10 per gallon.
12/ Environmental Impact Statement - Emission Standards for
Light-Duty Trucks, US EPA, OMSAPC, ECTD, November 1976.
13/ Estimated from reference 1/ above, and adjusted by a factor of
1.4 for each doubling of capacity. For example, an increase
in capacity from 50,000 to 200,000 would require an investment
and tooling increase of 1.96. The same would work in the
converse if capacity were decreased. The 1.4 factor was
estimated from reference 27/.
14/ Price increase rate was based on new car CPI for past five
years.
15/ "Economic Analysis of Selective Enforcement Auditing Regula-
tions," US EPA, Thomas J. Alexander, December 22, 1975.
16/ "Background Document for Medium and Heavy Truck Noise Emission
Regulations," Appendix C, EPA Office of Noise Abatement
Control, March 1976, EPA-550/9-76-008,
17/ Econometric model of new car sales presented by Ford Motor
Company in submission to the 1977 Suspension Hearing Panel,
inter-office memo of January 27, 1976, J.V. Deaver to D.A.
Jensen.
18/ Preliminary Impact Assessment of the Non-Passenger Automobile
Fuel Economy Standards for Model Years 1980 and 1981, DOT,
NHTSA, Planning and Evaluation Office of Program Analysis,
November 29, 1977.
19/ Automotive News Market Issue Databook, April 1980 and Wards
Automotive Yearbook 1979.
20/ "Regulatory Analysis and Environmental Impact of Final Emis-
sion Regulations for 1984 and Later Model Year Heavy-Duty
Engines," US EPA, 0MSAPC, December 1979.
21/ Based on in-house EPA testing detailed in "Summary and Analy-
sis of Comments to the NPRM 1983 and Later Model Year Heavy-
Duty Engines Proposed Gaseous Emission Regulations," US EPA,
OMSAPC, ECTD, December 1979.
22/ Regulatory Analysis for the Proposed Evaporative Emission
Regulation for Heavy-Duty Vehicles (3.0 g/test standard for
1983) US EPA, OMSAPC, ECTD,
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23/ "Average Lifetime Periods for Light-Duty Trucks and Heavy-Duty
Vehicles," US EPA, OMSAPC, ECTD, SDSB 79-24, Glenn W. Passa-
vant, November 1979. A 5 percent discount rate was used, as
suggested by the Council on Wage and Price Stability.
24/ See "Preliminary Regulatory Analysis of Light Truck Fuel
Economy Standards Model Years 1982-1985," DOT, NHTSA, Plans
and Programs Office of Program and Rulemaking Analysis,
December 1979.
25/ The price elasticity of demand used here considers only the
average first cost increase and does not consider the effect
of the cost of ownership of gasoline-fueled vehicles. EPA
knows of no elasticity of demand model for trucks which
incorporates both increased first costs and increased costs of
ownership.
26/ Assuming 42 gallons of fuel per barrel of oil.
27/ "Cost Estimations for Emission Control Related Components/
Systems and Cost Methodology Description: Heavy-Duty Trucks",
EPA-460/3-80-001.
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CHAPTER VI
ALTERNATE ACTIONS
This proposed rulemaking for 1985 heavy-duty engines and
light-duty trucks consists primarily of new oxides of nitrogen
(NOx) standards, new durability procedures, and new allowable
maintenance provisions. It was in these areas that alternatives to
the actual proposal were considered. Prior to final rulemaking,
these and other alternatives generated by the commenters will be
evaluated.
A. The Standard/The Standard-Setting Process
The Clean Air Act Amendments of 1977 gave EPA the authority to
establish new NOx standards, and directed that these be established
by specific methodologies. The Agency's interpretation of these
methodologies and all relevant scenarios possible under this
methodology are presented in Table VI-A.
The scenarios presented in Table VI-A are not mutually
exclusive; they represent parts of the overall derivation method-
ology. They are broken down here for illustrative purposes:
1. Scenario 1 portrays an immediate and permanent standard
derived from at least a 75 percent reduction from the baseline
levels. (This scenario presumes technological feasibility and no
standard changes per 202(a)(3)(E).)
2. Scenario 2 portrays an initial relaxation of the 75
percent standard to a revised level. This revised standard
must reflect the maximum reductions achievable with available
technology. Incremental increases in standard stringency can
occur at three year intervals, again to the limits of avail-
able technology, until the full 75 percent reductions are achieved.
3. Scenario 3 portrays a change from either the 75 per-
cent reduction, or from the lowest standard achievable by avail-
able technology. This change may be made in 1980 and every three
years thereafter, based upon data pertaining to the health effects
of the applicable pollutant and their relationship with the level
of the standard. The wording of the law is ambiguous (perhaps
intentionally) to the extent that the direction of the change
in standard (i.e., upward or downward) is not specified.
Under this overall methodology, EPA is required to derive
a standard based upon a reduction of at least 75 percent from the
baseline levels. Once this derivation has occurred, a revision
and/or a change to the standard is allowed by the Act. First of
all, if a 75 percent reduction is technologically infeasible, the
standard would be initially set at the limits of cost-effective
technology, and thereafter incrementally tightened over the years
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Table VI-A
Standard Promulgation Methodology as Mandated
by the 1977 Clean Air Act Amendments
Model Year
Scenario 1
Promulgation of a NOx standard 1985
based upon 75 percent reduction; [202(a)
(3)(A) (ii)l; Applicable for 1985;
presuming technogical feasibility and
no future change based upon health
effects.
No Change. 1988,
And each
third year
thereafter.
The End Result
A full 75 percent reduction per
202(a)(3)(A)(ii).
Scenario 2
Promulgation of a NOx standard based
upon a temporary (i.e. not to exceed 3
years) relaxation of the 75 percent
standard due to limitations of cost-
effective technology. [202(a)(3)(B) and
(C)]; applicable for 1985.
1985
At the end of Che first 3 year
period after the initial four years, and
each period thereafter, the standard
originally applicable for 1985-87
terminates, at which time the Admini-
strator must promulgate the full 75
percent reduction, or again promulgate a
revised standard based upon technology
limitations, applicable for 1988, 91,
etc. Such a revised standard is also not
to exceed 3 years, and must be more
stringent than the previous standard.
1988
And each
third year
thereafter.
The End Result
A full 75 percent reduction per
202(a)(3)(A)(ii)(presuming compliance
technology will eventually become avail-
able).
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Table VI-A (cont'd)
Standard Promulgation Methodology or Mandated
by the 1977 Clean Air Act Amendments
Scenario 3
Model Year
Promulgation of a UOx standard based
upon either an upward or downward "change"
from either of the two possible initial
standards (i.e. the full 75 percent, or
the relaxed standard due to feasibility
problems). This change is based upon the
relationship between the level of the
standard and health effects associated
with the particular pollutant.[202(a)(3)(E)]
At the end of the first 3 year
period after the initial four years, and
each period thereafter, any standard may-
but is not required to be - changed again
to reflect the findings of future health
effects studies. These changes may be
be to any level of stringency the
Administrator deems appropriate, be it
very stringent or very loose, as long as
the stringency is relatable to the health
effects findings.
1985
1988
And each
third year
thereafter.
The End Result
A standard whose stringency is based
upon health effects.
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as compliance technology becomes available until the full 75
percent reductions are achieved. Furthermore> once the 75 percent
standard has been derived, and at each 3 year interval thereafter,
EPA may change it or the aforementioned limit-of-technology stan-
dard based upon an analysis of the health effects as they relate
to the level of standard stringency. This change may be downward,
i.e., greater than 75 percent or to a level where compliance
technology is more expensive but where added compliance costs
can be justified on the basis of health. This change may also be
upward, to the extent that no increased health risks or problems
ensue, as determined by violations of National Ambient Air Qual ity
Standards (NAAQS) or quantification of other adverse environmental
impacts.
It is EPA's judgement that the initial step in the overall
process is the derivation of the 75 percent standard. EPA has
interpreted the Clean Air Act Amendments to legally empower EPA to
propose the full 75 percent reduction in this Notice of Proposed
Rulemaking. This proposal is the first step of the process fore-
seen by Congress. The options of standard revision and change will
be evaluated during the period of Public Comment. At the time of
this proposal, they remain unexercised and available. For example,
it is possible that a standard revision may occur based upon the
feasibility limitations of heavy-duty diesel engines. Finally,
evaluation of the Health Effects change option will follow.
Aside from the standard derivation methodology, other ques-
tions and alternatives arise which pertain to the standard but
which are generally independent of its numerical level.
First of all, large reductions in NOx emissions from heavy-
duty diesel engines will be more difficult to achieve than equiva-
lent reductions from heavy-duty gasoline engines. (See Chapter
III of this Draft Regulatory Analysis.) This fact raises the
question of separate standards should standard revisions be made
for gasoline and diesel engines, per 202(a)(3)(B) and (C). This is
to some extent an issue of equity in the marketplace and it
is not the Agency's desire to render one engine uncompetetive with
the other. The most equitable alternative may be to base the final
standards on the relative costs of compliance between gasoline and
diesel engines. The differential between gasoline and diesel
engine NOx standards could be set such that the average percent
increase in purchase price due to compliance costs (on a dollars
per engine basis) would be comparable for both engine types.
The issue of alternate NOx sampling systems for heavy-duty
engines must also be addressed. The 75 percent reduction standard
was derived from gasoline engines whose emissions were measured by
collection in sample bags. It has been observed for diesel engines
that bag-sampled NOx values are consistently lower than measure-
ments made on identical engines using a different sampling tech-
nique: continuous dilute integration. The observed ratio of
integrated/bagged measurements is approximately 1.2, and it is due
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entirely to the measurement technique, i.e., engine emissions are
the same. In short, the measurement technique has a direct in-
fluence on standard stringency and must be addressed. The Agency
considers the 75 percent standard of 1.7 g/BHP-hr to be an appro-
priate bag-sampled standard for both gasoline and diesel engines.
Should a manufacturer desire to certify an engine using the. inte-
grated method, it is appropriate that the bias error be reflected
in the standard, i.e., an integrated standard for diesel engines
would be approximately (1.7K1.2) ¦ 2.0 g/BHP-hr. The Agency is
not aware of similar bias errors between the two sampling tech-
niques for any other pollutant except diesel HC, for which allow-
ances have already been made.
The remaining alternative relateable to standard strin-
gency is the concept of emission "averaging" over a manufac-
turer's product line. The concept will not be discussed here
except to say that it is undergoing extensive review within
the Agency, and a specific strategy is under discussion. EPA
expects to pursue the development of averaging in a separate
rulemaking action.
To summarize alternative actions relating to the proposed
standards, the Agency has decided to propose the full 75 percent
reductions. Other alternatives specified by the Clean Air Act
remain unexercised and available at this time, in accordance with
Congressional intent. Other alternatives pertaining to standard
stringency are being examined and are discussed here for solici-
tation of public comment.
Finally, a question yet to be resolved by the Agency is the
relationship of the LDT NOx standard to the LDV NOx standard,
i.e., is it consistent with Congressional intent to establish
a LDT standard lower than one for passenger vehicles? The Agency
believes that the Congress did indeed intend a full 75 percent
reduction, but with the understanding that the final standard
would be comparably stringent to the LDV standard. (A limited
analysis indicates a LDT NOx standard of approximately 1.2 g/mile
is "comparably stringent.") As discussed above, however, in the
absence of data indicating that a 75 percent reduction standard
is infeasible or unwarranted, the Agency has elected to propose
the full 75 percent reduction as derived from the uncontrolled
baseline.
B. Durability Testing Procedures
An in-use durability procedure is proposed with this NPRM
for heavy-duty engines and light-duty trucks. The proposed
form of the procedure for heavy-duty engines was derived largely
from public comments received when the infuse, procedure was
originally proposed on February 13, 1979. Revisions proposed with
this present NPRM include a small volume engine waiver which limits
the number of engine families required for testing to those of
higher sales, a revised method of df calculation, revised time and
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tnileage restrictions, and overall clarification of "typical"
vehicle and application requirements.
Alternatives considered to the in-use program for heavy-
duty engines were two-fold: a revised dynamometer durability
test and a test track in-vehicle test. The Agency has for some
time believed that a dynamometer test is simplistic; modifications
to a dynamometer test to increase its representativeness increase
the cost well above that of the in-use program. For these reasons
the dynamometer testing option was abandoned. (An issue paper,
plus the complete Summary and Analysis of Comments with Recom-
mendations for the original February 13, 1979 in-use proposal are
available. These discuss the in-use vs. dynamometer options in
greater detail).
The test track procedure has also been proposed for both
heavy-duty engines and light-duty trucks as an option. It will
provide manufacturers with some degree of flexibility and control
over test conditions if desired.
C. Allowable Maintenance Provisions
Under consideration by the Agency were three basic options:
1. Follow the current 1984 Heavy-Duty Engine FRM (i.e.,
exclude the demonstration of in-use performance provisions).
2. Include the in-use performance provisions as written
in the 1983 HDV and LDT NPRMs so that the industry must demonstrate
the likelihood of in-use maintenance.
3. Modify alternative 2. above so that "non-critical
emission-related maintenance" be excluded from the requirements of
in-use maintenance demonstration. "Critical" items under this
redefinition would be items such as catalysts and oxygen sensors.
Exempted "non-critical" items would be spark plugs, wires, hoses,
etc.
An issue paper is available which explains each option in
detail. In short, the Agency believes that 1. is deficient in
the sense that there are no assurances that critical in-use
maintenance will be performed, presenting a risk to air quality.
Option 2. eliminates this problem to a reasonable degree, but
raises legal questions pertaining to EPA's authority to make the
manufacturer responsible for in-use performance of items not
designed exclusively for emission control (e.g., plugs, points,
etc.). Option 3. relaxes the criteria to include only hardware
designed exclusively for emission control.
Option 3. is within EPA's authority under the Act, pro-
vides greater assurance that maintenance-related in-use emission
deterioration will be minimized, and is proposed in this NPRM as
being the best option available to the Agency.
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CHAPTER VII
COST EFFECTIVENESS
A. Introduction and Summary
Cost effectiveness is a measure of what might be termed the
economic efficiency of some action directed toward achieving some
goal. Expressed as cost per unit of benefit achieved, cost effec-
tiveness can be used to compare various alternative methods of
achieving the same goal. In the context of improving air quality,
the goal is to reduce emissions of harmful pollutants, and cost
effectiveness is expressed in terms of the dollar cost per ton of
pollutant controlled.
To evaluate cost effectiveness, two pieces of information on
the alternative being evaluated are needed. These are the cost of
the alternative and the benefits to be gained. Costs to be used in
this chapter will be total identified costs expressed on a per
engine basis, including both costs to the manufacturer and costs to
the operator (all discounted to January 1 of the model year in
which the vehicle is produced). These costs will be allocated
equally among the pollutants being controlled. The benefits will
be computed as total lifetime emission reductions per vehicle.
In addition to the cost effectiveness of the overall proposal,
analysis of the cost effectiveness of both the allowable mainte-
nance and in-use durability elements of the proposal will be done.
In all cases, light-duty gasoline-fueled trucks, light-duty diesel
trucks, heavy-duty gasoline-fueled engines and heavy-duty diesel
engines will be presented separately.
B. Overall Proposal
Lifetime emissions for vehicles built to conform to this
proposal have been developed in Chapter IV. These were presented
in Table IV-I. Also presented in that table are emissions repre-
sentative of 1984 model year vehicles, vftich serve as a reference
for measuring incremental benefits. The emissions in Chapter IV
were computed separately for California vehicles, high-altitude
vehicles and low-altitude non-California vehicles. These values
can be weighted according to their respective estimated sales
fractions to produce average emission reductions for each type of
vehicle. Using data on truck sales from Ward's 1979 Automotive
Yearbook, the sales weighting fractions are estimated as 8.8
percent California, 6.9 percent high-altitude, and 84.3 percent
low-altitude non-California. Weighted average emission reductions
are given in Table VII-A.
Overall costs of the proposal have been estimated in Chapter
V. First price increases for the various vehicle categories are
reproduced in Table VII-A. Combining the costs with the emission
reductions yields the cost effectiveness values shown. For com-
parison, the cost effectiveness values for other NOx control
regulations are also presented in Table VII-A.
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Table VII-A
Overall Cost Effectiveness
Vehicle Class
Light-duty truck
(gas)
Light-duty truck
(diesel)
Heavy-duty vehicle
(gas)
Heavy-duty vehicle
(diesel)
NOx Benefit Cost Cost-Effectiveness***
(tons) ($) ($/ton)
0.17
0.17
0.87
N.A.*
153
47
284
741**
900
276
326
N.A.**
* Since the standard may not be feasible for heavy-duty dieBels
with the technology assumed for cost purposes, it is not appro-
priate to use the calculated emission benefits in a cost effective-
ness presentation.
** For every 1 percent change in fuel economy this cost changes
by $638. For example, with a 4 percent fuel economy penalty cost
would become $3293.
*** For comparison, the cost-effectiveneBS value for the 90%
performance standard for utility boilers is $l,200/ton (Interagency
Task Force on Motor Vehicle Goals Beyond 1980, March 1976).
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C• Allowable Maintenance
1• Benefits
Two key aspects of the allowable maintenance provisions
provide a means of estimating emissions reductions. These are the
extended maintenance interval for oxygen sensors and other trans-
ducers, and the requirement for full-life electronic engine con-
trols (EECs). The effect of these changes on emissions will be to
reduce the average deterioration rate of the in-use fleet. Diesels
are basically unaffected by these allowable maintenance provisions,
so that no cost effectiveness values will be computed for diesels.
When the oxygen sensor or the EEC fails on a 3-way catalyst
system, the engine will normally fail to a rich running mode. The
primary effect of such failures is to produce greatly increased HC
and CO emissions. These would also be accompanied by a reduction
in NOx emissions, but that reduction would be quite small. There-
fore, the benefit of increased transducer and EEC performance will
be assessed by examining HC and CO emissions.
In order to make a quantitative estimate of the allowable
maintenance benefits, it is necessary to review the basis for
deriving the in-use HC and CO deterioration rates to be expected
when 3-way systems are applied to light- and heavy-duty trucks.
The benefit expected is in this area (reduced in-use deteriora-
tion), rather than in any lowering of new vehicle emission rates.
The expected in-use deterioration rates were developed by modeling
the in-use fleet as being made up of the average emissions from
several sub-fleets.^/ The sub-fleets were established based upon
the state of performance of the emissions control system. For HC
and CO there are three categories of sub-fleets. The first cate-
gory is those vehicles in which closed loop operating capacity is
lost or severely restricted (the "primary" category). This would
be due to oxygen sensor failure, EEC failure, other sensor failure,
or tampering. For this category there are three choices of pos-
sible emissions depending on the type of closed loop system em-
ploye ed . The first represents 3-way catalysts with no oxidation
catalyst. The remaining two represent 3-way plus oxidation cata-
lyst systems. The first of these represent systems typical of
those used in current General Motors light-duty vehicles. The
other represents the type of system employed on Ford light-duty
vehicles.
The second ("secondary") sub-fleet category includes vehicles
having excess emissions which do not stem from a loss of closed
loop capacity (e.g., tnisfueling, malmaintenance, etc.). The final
category ("ok") is made up of well maintained, properly functioning
vehicles.
The in-use model assumes that each of the three categories
represents a certain fraction of the overall fleet. The fractions
start at an initial value in the new fleet and then grow (for the
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primary and secondary categories) or shrink (for the ok category)
as the fleet accumulates mileage. The average fleet-wide emission
rate at any mileage point is found by computing the emission rate
of each category at that mileage and weighting those rates accord-
ing to the fraction of the fleet in each category. Through this
process, the average fleet-wide emissions as a function of mileage
can be computed. The slope of a line fitted to the emissions by
the method of least squares will correspond to the expected in-use
deterioration rate.
"Hie in-use model uses an initial composition of the fleet of 3
percent primary, 3 percent secondary and 94 percent ok. These
percentages change at rates per 10,000 miles of 3 percent, 3
percent and -6 percent respectively. Thus, at 20,000 miles the
fleet would be 9 percent primary, 9 percent secondary and 82
percent, ok. Recalling that the primary category includes those
vehicles with failures of oxygen sensors, EEC failures, or other
sensor failures, the effect of longer lived sensors and EECs will
be evaluated by reducing both the initial size and the growth rate
of the primary category from three percent to one percent. The
results of doing this are given in Table VII-B.
In Table VII-B, results are presented for all 3 types of 3-way
systems of the "primary" category. For each type, the net change
of the in-use deterioration rate is computed. To combine these
into an overall benefit, the results for each system type are
weighted according to the percent of sales which that system type
represents.
2. Cost
Developing more durable oxygen sensors and EECs will require
extra development costs and extra material costs. The great
majority of such costs will be focused on the oxygen sensor. The
increase will be offset by elimination of the need to install a new
oxygen sensor at 50,000 miles. For both light- and heavy-duty
trucks the saving will amount to $12 (discounted to year of sale).
The increased cost associated with more durable initial components
is $2.26 for light-duty gasoline-fueled trucks and $6.66 for
heavy-duty gasoline-fueled trucks. Thus there is a net savings to
the owner.
3. Cost Effectiveness
The cost effectiveness calculations are given in Table VII-C.
Since the cost is negative, the values in Table VII-C show that
emission reductions are associated with a reduction in cost (nega-
tive cost effectiveness).
D. In-Use Durability
This program will require demonstration of adequate in-use
durability of emission-related components. As such, it can be
expected to reduce in-use deterioration rates. For gasoline-fueled
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Tsble VII-B
Estimated Benefits for Allowable Maintenance
HC Projected In-Use Deterioration Rates (g/mi/10,000 mi)
3-Way + 3-Way +
Ox. Cat. Ox. Cat.
3-Way Systems (Type 1) (Type 2)
Initial model 0.26 0.20 0.23
Reduced primary category 0.19 0.13 0.14
Net change 0.07 0.07 0.09
Weighted lifetime HC benefit:
Light-duty gas truck ¦ 0.07 x .505 + 0.07 x .27 + 0.09 x
.22 * 0.074 g/mi/10,000 mi * 0.06 ton
Heavy-duty gas vehicle ¦ 0.07 x 0.1 + 0.07 x .54 + 0.09 x
.36 • 0.077 g/mi/10,000 mi ¦ 0.06 ton
CO Projected In-Use Deterioration Rates (g/mi/10,000 mi)
3-Way + 3-Way +
Ox. Cat. Ox. Cat.
3-Way Systems (Type 1) (Type 2)
Initial model 4.98 2.36 4.35
Reduced primary category 2.37 1.21 1.88
Net change 2.61 1.15 2.47
Weighted lifetime CO benefit:
Light-duty gas truck ¦ 2.61 x .505 + 1.15 x .27 + 2.47 x
.22 ¦ 2.17 g/mi/10,000 mi ¦ 1.7 ton
Heavy-duty gas vehicle ¦ 2.61 x 0.1 + 1.15 x .54 + 2.47 x
.36 ¦ 1.77 g/mi/10,000 mi ¦ 1.3 ton
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Table VII-C
Cost Effectiveness of Allowable Maintenance
Cost Effectiveness
Cost Benefit (tons) ($/ton)
Vehicle Class ($) HC CO HC CO
Light-duty truck -9.74 0.06 1.7 -81 -3
(gas)
Heavy-duty vehicle -5.34 0.06 1.3 -44 -2
(gas)
Note: Costs and cost effectiveness are negative. That is, there
is a net savings associated with allowable maintenance.
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engines, the benefit of such a change may be estimated by a proce-
dure similar to that done for allowable maintenance. Other methods
will apply to diesel engines.
In the evaluation of allowable maintenance, the model used to
evaluate expected fleet in-use deterioration rates for HC and CO
was described and used to estimate benefits. The same model can be
used here. To estimate benefits of the in-use durability program,
the "secondary" category (Which has excess emissions due to causes
other than failure of the 3-way system) will be reduced in initial
size and growth rate from 3 percent to 1 percent. The estimated
benefits are given in Table VII-D.
Also given in Table VII-D are estimated NOx benefits. The
approach used for NOx follows that for HC and CO, except that there
are four categories rather than three. The first category is those
vehicles having inoperative EGR systems. The second category
includes vehicles having non-EGR problems which stil result in high
NOx emissions (e.g., spark timing maladjusted, three-way catalyst
tnisfueling, etc.). The third category includes low NOx emitters
since some engine problems (i.e., those resulting in running rich)
will reduce NOx emissions. The final category for NOx is those
vehicles representing well maintained, properly functioning vehi-
cles. NOx benefits of the in-use durability program will be
estimated by reducing the incidence of malfunctioning categories.
The initial and changed values for both initial incidence and
growth in each category are listed below:
Initial Values
Starting
Starting
Incidence
Growth
Incidence
Growth
Category
U)
(X)
CO
(X)
EGR
7
2
3
1
Non-EGR
7
2
3
1
Low
3
2
1
1
OK
83
-6
93
-3
Unlike the allowable maintenance case, the in-use durability
program will affect diesel engines. For light-duty diesel trucks,
adequate data on actual in-use deterioration rates is not available
for estimating benefits. However, current light-duty diesel trucks
have similar certification deterioration factors to light-duty
gasoline-fueled trucks. Therefore, EPA estimates that the benefit
of the in-use durability program will be similar for both types of
engines, and the same values will be used for diesels as are
estimated for gasoline-fueled engines.
Deterioration rates for heavy-duty diesel engines were esti-
mated in connection with the 1984 heavy-duty engine gaseous emis-
sion regulations.2/ The values used were 0.007 g/mi/10,000 miles
for HC, 0.11 g/mi7l0,000 miles for CO and 0.0 for NOx. These were
based upon certification values, and in-use deterioration, although
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Table VII-D
Estimated Benefits for In-Use
Durability for Gasoline-Fueled Engines
HC Projected In-Use Deterioration Rates (g/mi/10,000 mi)
3-Way + 3-Way +
Ox. Cat. Ox. Cat.
3-Way Systems (Type 1) (Type 2)
Initial model 0.19 0.13 0.14
Reduced secondary category 0.11 0.10 0.11
Net change 0.08 0.03 0.03
Weighted lifetime HC benefit:
Light-duty gas truck ¦ 0.08 x .505 + 0.03 x .27 + 0.03 x
.22 ¦ 0.055 g/mi/10,000 mi ¦ 0.04 ton
Heavy-duty gas vehicle ¦ 0.08 x 0.1 + 0.03 x .54 + 0.03 x
.36 ¦ 0.035 g/mi/10,000 mi ¦ 0.03 ton
CO Projected In-Use Deterioration Rates (g/mi/10,000 mi)
3-Way + 3-Way +
Ox. Cat. Ox. Cat.
3-Way Systems (Type 1) (Type 2)
Initial model 2.37 1.21 1.88
Reduced secondary category 1.95 0.91 1.57
Net change .42 .30 .31
Weighted lifetime CO benefit:
Light-duty gas truck ¦ 0.42 x .505 + 0.30 x .27 + 0.31 x
.22 ¦ 0.36 g/mi/10,000 mi ¦ 0.28 ton
Heavy-duty gas vehicle * 0.42 x 0.1 + 0.30 x .54 + 0.31 x
.36 ¦ 0.32 g/mi/10,000 mi ¦ 0.23 ton
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Table VII-D (cont'd)
NOx Projected In-Uae Deterioration Rates (g/mi/10,000 mi)
All 3-Way Systems
Initial model 0.06
Reduced malfunctions 0.04
Net change 0.02
Lifetime NOx benefit:
Light-duty gas truck ¦ 0.02 g/mi/10,000 mi ¦ 0.02 ton
Heavy-duty gas vehicle ¦ 0.02 g/mi/10,000 mi ¦ 0.01 ton
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still small, is probably greater than these levels. In the absence
of an in-use durability testing program, it will be estimated that
these deterioration rates would increase to 0.03 g/mi/10,000 miles
for HC and 0.2 g/mi/10,000 miles for CO. NOx will be estimated as
remaining near zero deterioration and no benefit will be computed.
The resulting lifetime emission reduction for an average heavy-duty
diesel engine is 0.29 tons of HC and 1.1 tons of CO.
Costs associated with the in-use durability program have been
developed in Chapter V. From that chapter, the costs are $0.84 for
light-duty trucks (gas or diesel), $2.86 for heavy-duty gasoline-
fueled vehicles and $4.57 for heavy-duty diesel vehicles. These
costs are combined with the benefits to produce cost effectiveness
values in Table VII-E.
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Table VII-E
Cost Effectiveness of
In-Use Durability Program
Cost
Vehicle Class ($)
Light-duty truck 0.84
(gas or diesel)
Heavy-duty gasoline- 2.86
fueled vehicle
Heavy-duty diesel 4.57
vehicle
Note: For light-duty trucks and heavy-duty gasoline-fueled vehi-
cles costs are divided 3 ways. For heavy-duty diesel vehicles
costs are divided 2 ways.
Benefit (tons)
HC CO NOx
0.04 0.28 0.02
0.03 0.23 0.01
0.29 1.1
Cost Effectiveness ($/ton)
HC CO NOx
7 1 14
32 4 95
8 2 -
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References
[in-use emission factor model]
Regulatory Analysis and Environmental Impact of Final Emission
Regulations for 1984 and Later Model Year Heavy-Duty Engines,
EPA, OMSAPC, December, 1979.
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