ENVIRONMENTAL IMPACT STATEMENT
EMISSION STANDARDS POR NEW
LIGHT DUTY TRUCKS
PREPARED BY
OFFICE OF MOBILE SOURCE AIR POLLUTION CONTROL
APPROVED BY
Eric 0. Stork, Deputy Assistant Administrator
for Mobile Source Air Pollution Control
Date:
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SUMMARY SHEETS
FOR
FINAL ENVIRONMENTAL IMPACT STATEMENT
PREPARED BY
OFFICE OF MOBILE SOURCE AIR POLLUTION CONTROL
ENVIRONMENTAL PROTECTION.AGENCY
1. Title of Action: Emission. Standards for New Light Duty
Trucks. This is an administrative action.
2. Description of Action: The EPA has set more stringent
emission standards for new light duty trucks, and has enlarged
the current light duty truck class to include trucks up to 8500
pounds gross vehicle weight rating (GTCR). The emission standards
which apply to trucks up to 8500 poimd3 GVWR are 1.7 grams/mile (g/m)
hydrocarbons (HC), 18 g/a carbon monoxide (CO) and 2.3 g/m oxides of
nitrogen (NOx). The EPA has set these standards for 1979 and
later model year light duty trucks.
3. Environmental Impact: This action will affect the air
quality of the nation as a whole, and in particular will improve air
quality in those areas of the country projected to have problems
in meeting air quality standards. About one-third of the U.S.
population now lives in those areas. In those areas the
action will, in 1990, result in a six percent oxidant air quality
improvement, a five percent carbon monoxide air quality improvement
and a three to four percent reduction in the expected air quality
degradation for nitrogen dioxide.
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There is the. potential for an. increase in sulfuric acid
emissions from trucks in the new light duty truck.class, although
such increase at most would he slight. Sulfuric acid emissions
from mobile sources have been extensively examined by EPA, and
there is no indication at this time that current levels of mobile
source sulfate emissions represent an immediate hazard to the public
health or welfare. EPA's examination of the sulfuric acid, emissions
from mobile sources is continuing.
h. Economic Impact: The sticker price of new light duty
trucks is expected to increase slightly for trucks currently
regulated as light duty trucks (0 to 6000 pounds GVWR), and could
increase as much as §219 for those heavier trucks being added to
the new light duty truck class. Fuel economy of- all light duty
trucks should not be adversely affected.
5. Alternatives Considered:
A. Taka no action.
B. Further control of emissions from stationary sources.
C. Further control of emissions from mobile sources other
than light duty trucks.
D. Alternative means for control of light truck emissions.:
I. Impose emission standards of 1.7 g/m. HC, 18 g/m
CO and 2.3 g/m NOx, but do not change the light
duty truck class definition.
II. Impose emission standards of 1.7 g/m HC, 18 g/m
CO and 2.3 g/m NOx, but limit the enlarging of
the light duty truck class to 7000 pounds GVWR.
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6. Availability: Copies of the final EIS were made available
to tYke. Covtaci-l o-rv xxsTjaeatal Quality and t>ie piiblic .
Single copies of the final EIS axe available upon request from the
Public Infon&ation Center (PM-215), U.S. Environmental Protection
Agency, 401 ]tf S.treetf 3.W,, Washington, D.€. 20460;
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TABLE OF CONTENTS
Page
I. Introduction
A. Background 1
B. Description of this Action 3
C. Light Duty Truck Class Structure 3
D. Environmental Impact 4
E. Economic Impact 5
F. Alternative Actions Considered 6
G. Organization of the Report 7
II. Light Duty Truck Characterization
A. Introduction 9
B. Design Characteristics 12.
C. Usage Characteristics 13
D. Selection of Light Duty Truck Class Definition 21
E. Emission Characteristics of Trucks in the
New Light Duty Truck Class 24
F. Growth of the New Light Duty Truck Class 28
III. Environmental Impact
A. Background 31
B. Primary Impact 39
1. Emission Reductions for Light Duty Trucks 39
2. Air Quality Impact of this Action 43
C. Potential Secondary Environmental Impacts of
the Final Regulations 47
1. Sulfuric Acid Emissions 47
2. Water Pollution, Noise Control and Energy
Consumption 51
IV. Economic Impact
A. Economic Backgrotuxu. 53
1. Description of Light Duty Trucks 53
2. Descriptions of the Manufacturers 54
B. Cost of Implementing the Final Regulations 55
C. Economic Impact 62
D. Cost Effectiveness 67
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V. Other General Considerations
A. Irreversible and Irretrievable Commitment of
Resources
B. Relationship of Short-term Uses of the Environment
and Maintenance and Enhancement of Long-term
Productivity
VI. Alternative Actions
A. Identification of Alternative Actions
B. Analysis of Impacts of the Alternatives to the Proposed
Action
1. Take No Further Action to Reduce Light Duty Truck
Emissions
2. Implement Alternative Emissions Standards for
Light Duty Trucks
VII. Problems and Objections Raised by Federal, State and Local
Agencies, and the Public
Appendix A - Selection of a Breakpoint Between LDTs and HDVs
Appendix B - Light Duty Vehicle and Light Duty Truck Emission
Factors
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Chapter I
INTRODUCTION
A. Background
Light duty trucks have been Federally regulated since 1968. From
that time until model year 197.5, light duty trucks were tested on the
same test procedure and subjected to the same emission standards as
light duty vehicles. Over those years, both the standards and test pro-
cedures for light duty vehicles and light duty trucks underwent several
modifications. Current test procedures for light duty vehicles and
light duty trucks involve operation of test vehicles on a simulated
urban driving cycle, and measurement of exhaust emissions during that
driving cycle. The current emission standards for both types of vehicles
are based on testing of those vehicles on the urban driving cycle, and
hence characterize the vehicles' expected urban emissions.
Since model year 1975 light duty trucks have been subjected to
standards differing in stringency from light duty vehicles. As the
result of a court decision , EPA was required to base emission
standards for light duty trucks on section 202(a) of the Clean Air
Act which specifies that EPA should set emission standards for any
class of vehicles (in this, instance, light duty trucks) which causes
or contributes to air pollution, or is likely to cause or contribute
to air pollution which endangers the public health or welfare.
1/ International Harvester vs. Ruckelshaus, 478 F. 2d 615 (D.C.
Cir. 1973).
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Section 202(a) further specifies that EPA must consider both the cost of
compliance with the regulation, and provide adequate time to comply with
the regulation.
As a further result of that court decision, EPA established a class
of vehicles differing from light duty vehicles for the purpose of setting
emission standards. That class, the light duty truck class, was defined
to include all trucks less than 6000 pounds gross vehicle, weight rating.
(GVWR). In the same regulatory action which defined the light duty truck
class —EPA sat emission standards for light duty trucks of 2.0 grans
per mile (g/m) HC, 20 g/m CO and 3.1 g/n NOx. Since modal year 1975, the
light duty truck class definition and emission standards have not been
changed.
In contrast, light duty vehicles are being subjected to increasingly
more stringent emission standards. Beginning in model year 1975, light
duty vehicles are required to meet emission standards of 1.5 g/m HC,
15 g/m CO and 3.1 g/m NOx. In model year 1977, as currently required
by the Clean Air Act, the light duty vehicle NOx .emission standard will
be lowered to 2.0 g/m. Further development of vehicles to meet much
lower emission standards scheduled to be imposed in the future is
progressing in the light duty vehicle area.
2/ 38 FR 21362, August 7, 1973. Current emission regulations for light
duty vehicles, light duty trucks and heavy duty engines are set forth
at 40 FR 27593, June 30. 1975.
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B. Description of this Action.
EPA lias both enlarged the current light duty truck class,
and has imposed more stringent emission standards for all trucks in
the resulting new light duty truck class.
The upper weight limit for the light duty truck class definition,
has been raised from 6000 to 8500 pounds GVWR. Addition of these
higher capacity trucks to the light duty truck class will enlarge the
class by approximately 80 percent.
Standards which have been promulgated for the new light duty truck
class, 1.7 g/m KG, IS g/m CO and 2.3 g/m NOx, will result in moderate
emission reductions for those trucks currently regulated as light duty
trucks (0 to 6000 pounds GVWR), and will achieve significant emission
reductions, for those trucks formerly tested tinder the heavy duty engine
regulations (6000 to 8500 pounds GVWR).
Both these actions have been made effective beginning in the 1979
model year.
C- Light Duty Truck Class Structure
Truck design and usage characteristics have been examined to
provide a basis for selecting a new light duty truck class definition
which would result in similar trucks being regulated under standards
and test procedures most appropriate for those trucks. Trucks with
like design characteristics have been grouped together, so that emission
standards can be imposed in a cost-effective manner. Trucks with like
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usage patterns have also been included in the new light duty truck
class, so that a test procedure which simulates urban light duty truck
(and passenger car) usage can be applied to predict actual urban
emissions from trucks in the new light duty truck class.
While the new light duty truck class is structured to minimize
truck overlap (or one model line with trucks both above and below
8500 pounds GVWR), complete elimination of this overlap is not possible.
To account for such overlap, EPA has included an optional- category (up
to 10,000 pounds GVWR) in which manufacturers may choose to certify trucks
under the light duty truck procedure.
As a further limitation of the cross-over of body styles, and to
exclude where possible trucks which are clearly used for commercial
purposes from the light duty truck class, trucks with frontal areas
greater than 46 square feet have been, excluded from the new light duty
truck class. This inclusion of high frontal area trucks in the heavy
duty class will eliminate certain delivery vans and other large
vehicles from the light duty truck class, on the basis that usage
characteristics of these trucks do not warrant their inclusion in
the light duty truck class.
D. Environmental Impact
This regulation will reduce urban emissions from trucks in the
new light duty truck class in 1990 by 0.51 million tons per year of
hydrocarbons, 3.0 million tons per year of carbon monoxide and 0.25
million tons per year of oxides of nitrogen. The projected reductions
are those which can be expected to occur in areas having the most
serious air quality problems in the near term and through the 1980's.
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The urban emission reductions obtained from imposition of this
regulation will result, in 1990, in a six percent improvement in
oxidant (hydrocarbons) levels, a five percent improvement in carbon
monoxide levels, and a three to four percent reduction in expected
nitrogen dioxide air quality degredation. Similar improvements can
be expected as a result of this regulation in regions other than those
analyzed in this report.
There are no anticipated secondary environmental impacts in the
areas of truck fuel consumption, noise pollution control, water or solid
waste pollution. Fuel economy of trucks currently regulated as light
duty trucks (0 to 6000 pounds GVWR) should not be affected by this
regulation, as no design changes should be necessary to meet the stan-
dards. For the heavier trucks to be added to the new light duty truck
class, imposition of these standards may result in slight fuel economy
improvements. There is the potential that sulfuric acid emissions from
the new light duty truck class could increase as a result of this regu-
lation, but the increase is not considered major. This potential
problem has been examined in connection with the ongoing work within EPA
directed towards development of a sulfuric acid emission standard for
application on light duty vehicles and light duty trucks. Such a stan-
dard is not at this time deemed necessary to protect the public health.
E. Economic Impact
Five domestic manufacturers dominate the light duty truck industry.
Ford and General Motors account for 75 percent of all trucks in the
enlarged light duty truck class which are sold domestically, with Chrysler,
American Motors and International Harvester selling about 18 percent.
Imports account for only about 7 percent of the total U.S. domestic
sales of trucks in the enlarged light duty truck clas9.
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Estimatea of the cost of achieving the 1979 standards have been,
developed. Analysis done by EPA has led to the conclusion that a
sticker price increase of $219 would be necessary to install a catalyst
emission control system capable of meeting the final standards on those
truckB being added to the class.
As most manufacturers have already elected to equip current light
duty trucks with catalyst systems and the existing emission control
systems will meet the new emission standards with slight modification,
the real cost of this regulation is the cost of installing $219 worth of
control equipment on those vehicles which were formerly classed as heavy
duty vehicles (6CG0 to 3500 pounds GVTJR) and which have become light
duty trucks under the new class definition. These costs are estimated
to represent between 3.8 and 6.0 percent of the sales price of typical
6000 to 8500 •pound GWR. light duty trucks. The aggregate cost to
install control equipment on all 1979 model year light duty trucks
is estimated to be about $309.2 million, of which about $8.7 million is
the expense of certifying the vehicles with EPA.
Consumer demand, employment and competition in the light duty truck
industry are not expected to be permanently impacted, as the long run
growth in production is expected to increase significantly and will help
to decrease any short term market instability caused by this regulation.
F. Alternative Actions Considered
The principle alternative actions considered were (a) Take no
action, (b) Set alternative light duty truck standards and (c) Control
other sources of SC, CO and ISOx. The alternative of taking no action
was rejected because major population centers are projected hot to meet
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air quality standards through the 1980's and control of trucks in the
new light duty truck class provides measurable improvements in air
quality at reasonable cost. The second alternative was rejected because
it did not. provide as much emission control for light duty trucks as did
the final approach selected.
The third alternative considered, control other sources of HC, CO
and NOx, was rejected primarily due to the fact that even with imple-
mentation of all identified control strategies, many of the Nation's
areas will be unable to meet the National Ambient Air Quality Standards.
G. Organization of the Report
This report presents an assessment of the environmental and a
summary assessment, of the economic impact of the light duty truck regu-
lations EPA is promulgating. It provides a description of the iaforxsation
and analyses used to review all reasonable alternative actions and to make
the final selection.
The report haa been, divided into, six major sections plus this
introduction. Chapter II presents a general description of the present
in-use population of trucks, a description of the rationale for the
selection of the new light duty truck class definition, a projection
of growth in the sales of new light duty trucks, and a characterization
of emissions from trucks in the new light duty truck class.
As assessment of the primary and secondary environmental impacts
attributed to these regulations is given in Chapter III. The degree
of control reflected by the standards is described and a projection of
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air pollutant emissions for the national light duty truck population
with and without the regulation through 1990 is presented. The
impacts of these regulations on urban emissions and the expected air
quality benefits are described. Secondary effects on other air
pollutant emissions, water pollution, noise, and energy consumption
are also discussed in this section.
Chapter IV presents an assessment of the economic impact of the
regulations. Included is an assessment of the impact of these regulations
on producer and consumer costs (operating and first cost), and the
growth and structure of the light do.ty truck industry.
Chapter V discusses irreversible commitments of resources, and
reviews the relationship of short term uses of the environment to long
term productivity.
Chapter VI presents an evaluation of the environmental, social,
and economic impacts of alternative actions including no further
regulation of light duty truck emissions, alternative emission standards
for light duty trucks and the additional reduction of emissions from
other mobile sources and from stationary sources.
Chapter VII sunmariges the comments EPA has received on the proposed
regulation and on the Draft EIS. Also included in this chapter is EPA's
disposition of the. major consments.
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Chapter II
LIGHT DUTY TRUCK CHARACTERIZATION
A. /Introduction
In the area of mobile source air pollution control, EPA's
primary concern in the near term is the reduction of urban
emissions, since air quality problems are most acute in urban
areas. Trucks of all types operate in urban areas, and hence
contribute to urban, air pollution. To effectively reduce the
truck contribution to urban air pollution, these trucks must
be subjected to regulations controlling emissions from each
individual truck. However, unlike passenger cars, trucks
differ widely in their design and use characteristics. This
wide difference in truck design and use characteristics makes
it impractical to subject all trucks to the same emission.
standards, and to require that all trucks be tested (for
compliance with emission standards) using the same test procedure.
Because trucks do differ so widely, EPA has in the past
divided trucks into light and heavy duty truck classes —The
first class, light duty trucks, has been, defined as all trucks
less than 6GC0 pounds GVTvR. These trucks have been subjected
to emission standards similar to light duty vehicles (although
slightly less stringent) and have been tested on the same
test procedure as light duty vehicles. The second class,
heavy duty trucks, has been defined as all trucks above 6000
pounds GVWR. Engines employed in these heavier trucks have
been subjected to emission standards not nearly as stringent
1./ Current light duty truck and heavy duty engine emission control
regulations are contained at 40 FR 27593, June 30, 1975.
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as light duty vehicles, and have been, tested art a test procedure
which accounts for a wide variety of commercial use applications.
In order for a regulation for the reduction of truck emissions
to be effective, two concerns must be satisfied by.that regulation.
First, the test procedure on which the emission standard is based
should, to a reasonable degree, predict the actual emissions of
the truck when the truck ia operated in the environment where air
quality problems are acute, in this instance in urban environments.
Second, the emission standard imposed by the regulation should
achieve reductions in emissions which are technically feasible for
all trucks subject to the regulation, with due consideration of
the cost-effectiveness of the control and the lead time necessary to
develop and implement the control.
The first concern arises due to the fact that emission
characteristics of vehicles differ depending on the operating
patterns of the vehicles. For instance, a vehicle operated at
a constant speed of 50 miles per hour would be expected to have
different emission characteristics than a vehicle operated in
stop and go traffic. The test procedure on which the emission
standard is based would be meaningless if it did not accurately
model the operating pattern of vehicles in the area of interest,
ia this case urban operation.
The Becond concern arises from the widely varying design of
trucks. Trucks are produced with different design capacities,
and even are produced in markedly different manners. Because
of these vast differences in truck design all trucks cannot
successfully achieve the same absolute levels of emission control.
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To Impose emission standards effectively, trucks must be grouped
so that similar trucks may be subjected to similar standards.
The imposition of emission standards can then be done in a
cost-effective manner.
Tha. current grouping of trucks (light duty trucks below
6000 pounds GVWR and heavy duty trucks above 6000 pounds GVWR)
fails to adequately satisfy the two concerns discussed above.
The 6000 pound GVWR division does not result in trucks being
tested using the most appropriate test procedure, and does
not allow the imposition of emission standards on similar
trucks. "For example, under the current division of trucks,
two pickup trucks within the same model line, designed and
produced in a similar manner and operated in urban areas in
a similar manner, may be subjected to different emission
control regulation (light and heavy duty truck) simply because
one is less than 6000 pounds GVWR and one is more than 6000
pounds GVWR.
To make the light duty truck regulations more effective,
EPA has grouped trucks with like operating characteristics
in one class. This grouping will allow the emissions of
trucks in urban areas to be accurately assessed, and will
result in urban emission reductions being achieved by trucks in
the new light duty truck class. For the purpose of choosing
a group of trucks which are amenable to the same ievel of
emission control, EPA has also grouped trucks with like design
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characteristics in one class. This chapter examines truck design
and usage characteristics, with a view toward outlining the consi-
derations EPA has in grouping trucks into classes and imposing
emission standards based on those considerations.
Following this examination of truck design and usage
characteristics and the rationale for EPA's selection of light
duty truck class definition, emission characteristics of trucks
in the new light duty truck class are discussed, and growth of
the new light duty truck class is projected. These further
discussions concerning light duty truck enission characteristics
and growth are presented to form the bases for the examination
in the remainder of this, statement of the environmental, economic
and social .impacts of EPA's final regulation..
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B. Design Characteristics
The industry has traditionally grouped trucks into eight classes
based on gross vehicle weight rating (GVWR). These classes are:
Class Weight (lbs GVWR) Class Weight (lbs GVWR)
Class I 0 - 6000 Class V 16,001 - 19,500
Class II 6001 - 10,000 Class VI 19,501 - 26,000
Class III 10,001 - 14,000 Class VII 26,001 - 33,000
Class IV 14,001 - 16,000 Class VIII over 33,000
Table II-l shows data collected by the MVMA. which details the
levels of factory sales of trucks in these eight classes over the
past several years. These data indicate clearly that of all trucks
sold in the U.S. in recent years, the majority (over eighty percent)
are less than 10,000 pounds GVWR. Few Class III vehicles are
made though the volume did grow significantly between 1969 and
1973. Most trucks over 10,000 pounds GVWR are in Classes V
through VIII, i.e. over 16,000 pounds GVWR.
Table II-2 offers a more detailed look at the composition of
truck Classes I, II, and III. These data show that almost all trucks
in these classes are less than 10,000 pounds GVWR with only two
percent of factory sales falling in Class III. Ninety percent of
the trucks in Class III are multistop trucks, primarily
incomplete vehicles used for mobile homes. Hultistop trucks less
than 10,000 pounds GVWR are also produced but account for only
two percent of factory sales in Classes I and II. Other types
of incomplete vehicles [cab chassis, etc] make up four percent
of sales in Classas I and II and ten percent in- Class III.
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Another observation is that almost all of the types of
vehicles which make up the current light duty truck class
[less than 6,000 pounds GVWR] are also manufacturered in larger
versions up to 10,000 pounds GVWR. Approximately one half
of all passenger vans, about one third of regular vans and
pick up trucks, and one fifth of station wagons built on
truck chassis are between 6,000 and 10,000 pounds GVWR. Also
noteable is the fact that all of these truck types are less
than 10,000 pounds GVWR. Thus only multistop vehicles and
other incomplete trucks are produced in truck Class III as
well as Classes I and II.
The main item that all trucks up to 14,000 pounds GVWR
have in common is the engines. All domestic trucks in this
GVWR range use essentially the same engines as current 0 to
6000 pound GVWR light duty trucks. In most cases, these engines
are identical to those used in passenger cars or are close
derivatives of passenger car engines. The engines differ in
emission controls since some have been tested as light duty
trucks and others as heavy duty vehicles. These differences
amount to different carburetor and distributor settings and
differences in the "add-on" emission control devices. For
example-most of the engines certified for heavy duty use do not
have exhaust gas recirculation, air injection, evaporative
emission controls, transmission controlled spark settings, or
catalysts.
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In summary the major conclusions that can be drawn
concerning the present truck fleet are:
1) In terms of sales, the largest group of trucks is found
in the range of 0 to 10,000 pounds GVWR, with the re-
maining majority of trucks concentrated above 16,000
pounds GVUR.
2) Most of the trucks sold in the current light duty truck
class [pickup, vans, station wagons on truck chassis] are
also produced between 6,000 and 10,000 pounds GVWR though
none are greater than 10,000 pounds GVWEL
3) Few trucks are produced in Class III. Class III consists
exclusively cf nultistcp trucks and other incomplete
vehicles that are used primarily for mobile homes.
4) Engines found in all domestic trucks up to 14,000 pounds
GVWR are similar to the engines used in 0 to 6000 pound
GVWR trucks, and in most cases are also similar to those,
used in passenger cars.
These conclusions imply that the breakpoint between heavy
duty vehicles and light duty trucks, if based solely on truck
design characteristics, should be no higher than 10,000 pounds
GVWR.
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Table II-l
FACTORY SALES OF TRUCKS
FACTORY SALES OF TRUCKS AND BUSES BY GROSS VEHICLE WEIGHT; POUNDS
6.000
6.001-
10,001-
14.001-
16,001-
19.501-
26,001-
Over
& Less
10,000
14,000
16,000
19,500
26,000
33,000
33,000
TOTAL
TOTAL.
1975
982.511
962,987
14,342
1.129
10,582
174.218
27,310
99.031
2,272150
1.974
1.536,778
731.529
9.094
4.318
13.071
224.499
34.432
173,592
2.727.313
1973
1.735,645
761,481
44,724
7.477
18.941
203,300
42.200
165,920
2.979.638
1972
1.414,551
584,612
44,221
9.945
28,080
182.058
42,213
141,127
2.446,807
1971
1.196.544
486,388
17.928
14,871
58,042
132.197
36,441
110.735
2.053.146
1970 ..
950 2"
401.592
7 "SO
/ . o ^
9.979
59,205
124.554
33.45 1
101.054
1.692.440
1969 . .
1.121.222
405,108
7,161
13,491
78,105
147.405
33,304
117.383
1.923,179
1968 ....
1.136,059
385.803
4.646
17,495
79,436
143.264
41.814
89.561
1.896,078
1967 . . .
899,986
289,835
5,207
16.499
88,213
123.934
37.960
77,828
1.539,462
1966. . . ..
1,020,158
296.957
7.485
21.286
125,473
124,361
44,337
91,027
1,731.034
1965
1.058.211
294,178
5.020
25,751
144,449
109,625
39.968
74,603
1.751.805
1964., ..
919,663-
250,204.
5,804
24,234-
142.277
104.499'
29,613
64,159-
1.540,453
1963J.....
836,129
246.65a-
5,679'
28,450*
145.298
109.570
32.186-
58,746
1.462.708
1962. .. ..
677;804
213.05(1
8.503'.
27.495
142.163,
93.138
35.153-
42,862
1.240.168-
DOMESTIC ' ' "
1975
897,292
853,310
13,914-
917
5,718
139,769-
21.555
70.283
2.002,753
1974.. .
1.409.586
660,312
8,911
3,220.
10,271
197,450
29.091
150,785
2.469,626
1973
1.639.663
713,210:
44;272
6,443>
15.543:
180,345
37,834-
149.503
2,786.813
1972
1.339.226,
549,52a
43,898
8.661
24,826:
163,266
37,727
127,244
2,294-, 371.
1971. ... .
1,133;911.
453.98E
1'7>796
12,602
52,03a
1.10,587
32,795
100;598
1,914,308?
19705. j
895.238s
373:595:
6.510>
8T,357!
52;466E>
103-.31S
34,751
91,4341
r. 565,669-
1969-.
1.052.057
379,492
6,525
11.272
68.517
125,9i0
30.858
106,446-
1,781,17 7
1968*.....
1.069,422
365,785
4,338
14,690
67,381
123.059
37,882
82.534
1,765.091
1967
836,512
269.273
4,850
14,236
76.874
107,972
33.911
70.810
1.414,£38
1966
957,227
278,099
5,805
18.711
109.696
110.523
41.158
85,302
1.606.526
Sourcer MVMA Motor" Vehicle Facts: and' Figures- T6
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;'^pie 11 - 2
Domestic Factory Sales - 1973 Calender Year
Under
§0GPtf GVWR
6rlQQ00#
10-14000//
Total Ufider
10,000# CVWR
Tota1 Under
14,000// GVWK
j pickup
1,067,908
(637.)
<1671307
(62Z)
1,535,215
(66%)
1,535,215
(63%)
Multlstop
<0 oJ
2,603
(0%)
34r?S2
J57.)
39,659
(907.3
37,685
(27.)
77,344
(37.)
Othpr: ?4|B Chassis
Chggsjjs v/cab
Chsssfs w/coul
5,253
tlW
88fQ68
(H7->
A,613
(107.)
94,32;
96,934
(4X>
==\i Van
204,348
(1W
1(^,553
um
305,901
(1370
305,901
(13%)
It £ \ : \ „
J 1 Pes9enger Van
*-0
49,501
(3%)
4^,480
(6%)
93,981
(4%)
93,981
(47.)
^¦=^/ ^ Section Wagon
80,842
?Of713
CW
101,555
(4%)
101,555
(4?.)
3,213
(07.)
3,213
(07.)
3,213
(07.)
¦ ¦— '¦ .-i^Jv. yi
O Ol Ceneral cy
161,602
(10Z)
161,602
(7%)
161,602
(77.)
1973 Sale3 Total
1,576,470
757,003
44,272
2,333,473
2,377,745
Source: MYMA Data Sheecs FS 20 and FS 3
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-18-
C. Usage Characteristics
Since the physical characteristics o£ trucks up to 10,000
pounds GVWR are basically similar, with truck design in transition
from 10j000 to 16,000 pounds GVWR, an. optinum division between
light duty trucks and heavy duty trucks would be one which
separates those trucks on the basis of usage characteristics.
This would allow trucks to be.tested using the most appropriate
test procedure, or one which most accurately characterizes the
expected usage patterns of trucks in actual urban operation.
Examination of Census data for the eight MVMA truck classes
indicates that truck use varies according to weight. Trucks
in classes I and IX are primarily used for personal transportation
and agriculture, those in classes IV, V and VI are used primarily
in support of agriculture, manufacturing and construction, and
class VII and VIII trucks are used in construction, wholesale and
trade for hire. 2/
About 53 percent of trucks under 10,000 pounds are used
for personal transportation and 21 percent, for agricultural
purposes. Use of trucks for personal transportation declines
significantly for Classes III, IV and V for which only 11
percent of trucks in these categories are used in that maimer.
Agricultural uses increase to 32 percent, however, while
commercial uses follow a similar pattern. Only 14.9 percent
of trucks under 10,000 pounds GVWR are used in support of
manufacturing, construction, the wholesale and retail trades,
and "for hire." In classes III, IV and V 38.4 percent of trucks
27 1972 Census of Transportation - "Truck Inventory anH Use
Survey"
-------
-19-
are used to support these enterprises, 48.6 in class VI. and 76.5
in classes VII and VIII.
The data considered unus rat xena aaamionaj. support to tne
conclusion that- a breakpoint between light duty trucks and heavy
duty vehicles should be no higher than 10,000 pounds GWR„ EPA
conducted additional analysis 3/, however, to examine the
physical and usage characteristics of trucks below 10,000 pounds
GWR so as to identify a cut-off point for the new light duty
truck definition that would minimize the inclusion of trucks
used for commercial purposes in the new light duty truck class.
One result of that analysis indicates that personal transportation
is the dominant use for trucks up to 8000 pounds GTOR, percentage
of personal transportation is in transition in the gross vehicle
weight range 8000 to 16,000 pounds, and personal transportation
accounts for only two percent of the usage in trucks 16,000 to
26,000 pounds GVWR. When considering this data alone, indepen-
dent of other usage data, 8000 pounds GVWR appears to separate
light duty trucks from heavy duty vehicles on the basis of
personal use versus cctcnercial use.
Cn further examination of usage characteristics of trucks
less than 10,000 pounds GVWR by truck type (see Appendix A), it
can be seen that pickups in that weight range are primarily
personal usage trucks and that panels, cab chassis and multistop
37 The EPA analysis, "Selection of a Breakpoint Between Light
Duty Trucks and Heavy Duty Vehicles" is included as Appendix A
to this report.
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-20-
trucks are primarily commercial use vehicles. This would
indicate that an appropriate divisor between light duty trucks
and heavy duty vehicles would be one which maximizes inclusion
of pickup trucks in the light duty truck class, and which
minimizes inclusion of panels, cab chassis and multistop trucks.
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-21-
Selection of a Light Duty Truck Class Definition
There is no one criterion that can be established to completely
separate light duty trucks from heavy duty vehicles which will
completely eliminate cross-over of vehicle body styles and vehicle
usage. From the discussion of truck design and usage characteristics
presented above, it is apparent that a optimum divisor between
light and heavy duty trucks is one which satisfies the following
concerns:
1) Design characteristics
So that trucks included in the new light truck class are
amenable to the. same absolute degree of emission control, and
*- - — .. T- -i -_J -* 3 3 '-J -U -a —
mJL e cm u c ouujcllcu lv wuu.aaj.uu j- tc.uuai.uo ^ v j. \a o
cost-effective urban emission reductions, trucks of similar
design should be grouped in one class. Examination of truck
design characteristics has led to the following conclusions:
a) The largest sales volume of trucks is found under 10,000
pounds GVWR, with the remaining majority of truck sales
being concentrated above 16,000 pounds GVWR.
b) Most of the trucks sold less than 6000 pounds GVWR have
counterparts which are also sold between 6000 and 10,000
pounds GTOR, although none of these truck types are sold
above 10,000 pounds GTOR,
c) Engines are similar in all trucks up to 14,QC0 pounds
GVlvR and in most cases those engines are. similar to
passenger car engines.
2) Usage characteristics
To be able to adequately characterize actual emissions from
trucks operated in urban areas, where urban vehicle operation is
simulated by the cj.sc procedure currently used on light duty
vehicles and light duty trucks less than 6000 pounds CVWR, trucks
of similar use should be grouped in one class. Truck use
characteristics discussed earlier lead to the following conclusions:
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-22-
1) The light duty truck c2ass should be structured to
maximize inclusion of pickup trucks, since in the
weight ranges under consideration aiaost all pickup
trucks are used primarily for personal transportation.
2) The light duty truck class should sinimize.inclusion
of multistop trucks, panels, vans and cab chassis,
since thase types ox trucks are used primarily for
commercial purposes.
3) The weight limit division between light and heavy
duty trucks should not be less Chart SOOO pounds GVWR,
since the percentage of trucks used for personal
transportation up to 8000 pounds is consistently above
50 percent.
Considering all these concerns, and examining truck sales
distribution (see Appendix A, Figures 3 and 4), 3500 pounds GVWR appears
the optimum minimum cutpoint between light and heavy duty trucks. In
addition, trucks above 6000 pounds curb weight which are often built to
carry permanently installed equipment used for commercial and recrea-
tional purposes have been excluded from the new class. As a further
limitation, of the cross-over of body styles, and to exclude where
possible trucks which are clearly used for commercial purposes from the
light duty truck class, trucks with frontal areas greater than 46 square
feet have been excluded f.ron the new light duty .truck class. This
inclusion of high frontal area trucks in the heavy duty class will
eliminate certain delivery vans and other large vehicles from the light
duty truck class, on the basis that usage characteristics of these
trucks do not warrant their inclusion in the light duty truck class.
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-23-
To further eliminate cross-over of body styles and vehicle usage
(and to eliminate the current situation in which one type of truck may
be required to be certified under both the light and heavy duty truck
regulations) EPA has included an optional light duty truck category
for trucks up to 10,000 pounds GVWR. Trucks in this class may, at
the manufacturer's option, be certified as light or heavy duty trucks.
This arrangement will allow vehicles in the 8,500 to 10,000 pound
GVWR range to be certified under regulations which best reflect their
design and usage characteristics and will minimize the number of
vehicles vhich -culd be (and ^re cirrenclv) certified under two
procedures.
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-24-
E. Emission Characteristics of Trucks in the New Light Duty Truck
Glass
Trucks in the new light duty truck class, having been historically
subjected to two separate regulatory requirements, currently have widely
differing emission characteristics. Those trucks which have previously
been regulated as light duty trucks (0 to 6C00 pounds GVWR) have been
subjected since 1975 to standards of 2.0 grams per mile (g/m)
hydrocarbons, 20 g/m carbon monoxide and 3.1 g/m oxides of nitrogen
(2.0 g/m in California). Actual emission levels of trucks subjected
to those standards vary with vehicle age and the deterioration
associated with the particular emission control system used on the
individual truck. For a typical light duty truck which has been
subjected to a 2.0 g/m hydrocarbon standard, actual performance
emission levels would be expected to vary from 1.6 g/m during the
truck's first year of operation to 7.6 g/m at the end of the truck's
in-use life. Similar ranges would be expected for carbon monoxide
and oxides of nitrogen under a 20 g/m and 3.1 g/m standard
(respectively), with carbon monoxide performance levels ranging
from 20 g/m to 99 g/m, and oxides of nitrogen performance levels
ranging from 2.5 g/m to 3.9 g/m.
The remainder of the trucks in the new light duty truck class,
those in the GVWR range 6000 to 8500 pounds, have been subjected
since 1974 to heavy duty engine standards and have been tested
using heavy duty engine test procedures. Initial (first year)
emission performance levels for a typical 6000 to 8500 pound
GVWR truck were established in an EPA testing program 5/ at 4.3
5J EPA in-house testing, and "Technical Evaluation of Emission Control
Approaches and Economics of Emission Reduction Requirements for Vehicles
Between 6,000 and 14,000 Pounds Gross Weight", Calspan Corp. November
1973, EPA-460/3-73-005.
-------
g/m hydrocarbons, 44 g/m carbon monoxide and 5.2 g/m oxides of nitrogen.
Based on the similarity of these vehicles in terms of vehicle and engine
design to light duty vehicles for which emission control deterioration
rates have been determined 6/, the initial performance levels for a
typical 6000 to 8500 pound GVWR light duty truck, regulated under
current heavy duty standards, would be expected to deteriorate from
5.7 to 11.4 g/m hydrocarbons, 67.8 to 128.9 g/m carbon monoxide and remain
at 5.4 g/m oxides of nitrogen at the end of the truck's in-use life.
Composite emission rates for trucks in the new light duty truck
class have been developed by weighting the emission characteristics
discussed above for both the 0 to 6000 and 6000 to 8500 pound GVwR
light duty truck groupings. This weighting assumes that 55 percent
of the new' light duty truck class will be comprised of 0 to 6000
pound GVWR trucks, and that the remaining 45 percent will be 6000
to 8500 pound gross vehicle weight trucks. (The bases for this
assumption are further discussed in Chapter IV of this statement.)
Table II-3 examines the emission rates (obtained through this weighting
process) for an average truck in the new light duty truck class.
Table II-3 is provided as a base case, as it assumes that no further
control is imposed on trucks in the new light duty truck class. Table
II-4 presents similar emission rates for a typical truck in the new
light duty class when controlled under this regulation. These emission
rates form a basis for the examination in Chapter III of this state-
ment of the air quality impacts of EPA's proposed action.
6/ See Appendix B.
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-26-
Table II-3
EMISSION RATES FOR AN. AVERAGE TRUCK I1T TEE
HEW LIGHT DUTY TRUCK CLASS - NO FURTHER CONTROL
Base Case 0-6000 GVWR 2.0/20/3.1
6000-8500 GVWR 4.3/44/5.2
Vehicle Age Emission Rates'* {0-S500 GVWR)
(years)
RC
CO
NOx
1
3.4
41.7
3.8
2
4.1
49.6
3.9
3
/. o
T s W
C** /.
it
A
T •
4
5.4
65.3
4.0
5
6.1
73.2
4.1
6
6.7
81.0
4.2
7
7.4
88.9
4.3
8
8.0
96.7
4.4
9
8.7
L04.6
4.5
10
9.3
112.5
4.6
11
9.3
112.5
4.6
12
9.3
112.5
4.6
13+
9.3
112.5
4.6
"grozis per vehicle mile
NOTE: Excessive emission levels during a vehicle's later years of operation
indicate a lack of proper nain'tenancs. This trend tcvards excessive
emission levels can be slowed if proper maintenance practices are
followed throughout the vehicle's life. Imposition of requirements
concerning proper maintenance practices by vehicle users is the subject
of another program under development within EPA, the Inspection and
Maintenance program.
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-27-
Table II-4
EMISSION JUICES FOR AH AVERAGE TRUCK II? TEE
NEW LIGHT DUTY TRUCK CLASS - FINAL STANDARDS
0-8500 GTOR 1.7/13/2.3
hicle Age
(year
HC
Emission Rates*
CO
NOx
1
1.4
18.3
1.9
2
1.9
26.1
2.0
3
2.5
33.9
2.1
f.
n r\
> * w
41,7
2 = 2
5
3.6
49.5
2.3
6
4.2
57.4
2.4
7
4.7
65.2
2.5
8
5.3
73.0
2.7
9
5.9
80.8
2.8
10
6.4
88.6
2.9
11
6.4
88.6
2.9
12
6.4
88.6
2.9
13+
6.4
88.6
2.9
*grama per vehicle mile
NOTE: Excessive emission levels during a vehicle's later years of operation
indicate a lack of proper maintenance. This trend towards excessive
emission levels can be slowed if proper maintenance practices are
followed throughout the vehicle's life. Imposition cf requirements
concerning proper maintenance practices by vehicle users is the subject
of another program under development within EPA, the Inspection and
Maintenance program.
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-28-
F. Growth o£ the New Light Duty Truck Class
At the current time 110 known econometric models for estimating
light duty truck sales are available for EPA use. Since limitations
in time and availability of personnel do not permit internal development
of such model, simple least square regression analysis 7/ was used
to determine the pattern of light duty truck sales over a 15 year
period (1960-1974). From this data an average yearly growth rate
in sales was calculated. Estimated factory sales tor light duty
trucks for 1975 to 1990 were then made by applying the growth
rate to production figures, using 1S74 production as a base year.
Figure 2-1 shows the recent growth in the sales of light duty
trucks. Between I960 and 1974 light duty truck sales grew at ail-
average rate of 4.1 percent per year. Over the same time period,
automobile sales grew at the rate of only 3.8 percent per year.
The current (1974) population of registered light duty trucks is
approximately 17.4 million. 8/ Table II-5 projects annual new sales
and total population of light duty trucks through 1990 assuming an
annual growth rate of 4.1 percent.
7J The "least squares method" is a statistical technique for fitting
a straight line through several data points.
8/ Commercial Car Journal estimate based on data from U.S. Census of
Transportation, Bureau of Census.
-------
Figure 2-1
ANNUAL TRUCK SALES FOR
THE NEW LIGHT DUTY TRUCK CLASS
Model Year
Source: Motor Vehicle Manufacturers Association> 1974 Motor
Truck Facts
-------
-30-
TABLE II-5
PROJECTED SALES AND REGISTRATIONS OF TRUCKS
IN THE NEW LIGHT DUTY TRUCK CLASS THROUGH 1990
Sales Total Registrations 2/
Year
(millions of units)
(millions of units)
1974
1.97 y
17.4
1975
2.05
18.3
1976
2.13
19.2
1977
2.22
20.2
1978
2.31
21.3
1979
2.40
22.3
1980
2.50
23.4
1981
2.61
24.8
1982
2.71
26.0
1983
2.82
27.0
1984
2.94
27.7
1985
3.06
28.8
1986
3.18
29.9
1987
3.2
31.1
1988
3.45
32.3
1989
3.59
33.6
1990
3.74
35.0
If Figure (1.97 million) represents actual factory 3ales of light duty-
trucks in the weight range 0-10,000 pounds GVWR, adjusted by 5
percent to account for vehicles estimated to be between 8,500-10,000
pound GVWR.
2/ Based on. data from U.S. Census of Transportation, and assuming constant
growth of the light duty truck class over the period of interest (1960
to 1990).
-------
Chapter III
ENVIRONMENTAL IMPACT
A. Background
On March 5, 1975, EPA Administrator Russell Train announced the
interim automotive emission, standards for the 1977 model year and
recommended the delay of statutory HC, CO and NOx automotive emission
standards until 1980 in light of uncertanties regarding automotive sulfuric
acid emission levels. Because of continuing difficulties in achieving
the oxidant, carbon monoxide and nitrogen dioxide air quality standards
in major urban areas and the fact that the more stringent automotive
0miss"* OH S t T*1** n /4q1 i.3 cr.T I »-s V
potential for further reduction of other sources of emissions of
hydrocarbons, carbon monoxide and oxides of nitrogen.
During the same March 5th press conference, Administrator Train
announced several actions designed to provide additional reductions
in emissions of hydrocarbons, carbon monoxide and oxides of nitrogen
from other sources. The actions included:
1. More stringent emission standards will be proposed for
heavy duty vehicles.
2. A new evaporative emission standard for automobiles will
be proposed for the 1978 model year.
3. Motorcycle emission standards will be set for the 1978
model year.
4. Existing standards requiring a 90 percent reduction in
hydrocarbon emissions during vehicle refueling must
result in use of the most effective control devices
which are available or can be developed.
5. EPA will re-examine current regulations providing
for hydrocarbon control from paints, solvents, dry-
cleaning liquids, and refineries with a view to
tightening them.
-------
-32-
All of these actions, including the reduction of emissions from
light duty trucks, are a part of EPA's overall strategy for achiev-
ing ambient air quality standards. When examined individually,
emission reductions from any one of the several actions may appear
to be marginal. However, when examined in the aggregate, they provide
for substantial reductions in mobile source emissions.
Hydrocarbon emissions from all mobile sources in 1972 totalled
approximately 13 x 10^ tons. As a result of the various control actions
expected to be implemented by EPA in the near future and described in
part aheve. hydrocarbon emissions in 199C are projected to be reduced
to below 6 x 10^ tons. Similar reductions are expected to occur for
carbon monoxide, with emissions of carbon monoxide falling from 87 x
10^ tons per year in 1972 to under 50 x 10^ tons per year in 1990.
Emissions of oxides of nitrogen from mobile sources are expected, ta
remain, through 1990 at about 9 to 10 x 10® tons per year. 1/
The aggregate mobile source emissions are examined individually
by class in Tables III-A, III-B and III-C. The major classes of mobile
sources, light duty vehicles, light duty trucks and heavy duty vehicles
are presented and emission projections are given for each class from
1972 to 1990. The class "other mobile sources" includes motorcycles,
aircraft, and uncontrolled mobile sources such as tractors, vessels,
locomotives, miscellaneous off-highway vehicles and lavnmowers and
other utility engines.
1/ EPA staff analysis, September 1976.
-------
-33-
The projections of total mobile source emissions by class of vehicle
given in Tables III-A, III'-B and III-C allow for a general overview of
the contribution, to air pollution that each class of vehicles makes
through 19S0, and of the distribution of the burden of control of
emissions from all mobile sources. From these tables it can be seen
that emissions from the class "other mobile sources," and to a lesser
extent those from heavy duty vehicles, grow in proportion to emissions
from light duty vehicles and light duty trucks. This apparent inequitable
distribution of the burden for reducing mobile source emissions can
be in part accounted far by the lack of author iz?lng legislation for
the control of emissions from the bulk of the category "other mobile
sources" (excluding motorcycles and aircraft), and due to the fact that
for heavy duty vehicles, no emission reduction credit is given for
the planned long term heavy duty vehicle emission regulation. 2/
This chapter examines the impact of one of the actions in EPA's
overall strategy to reduce mobile source related emissions. The contribu-
tion of light duty trucks to total mobile source emissions is examined,
and projections are given for the improvements in air quality which can
be attributed to the light duty truck regulation in those areas which are
not expected to meet ambient air quality standards.
2/ The planned long term heavy duty vehicle emission regulations
include the development of an urban-based test procedure, and the
imposition of stringent emission standards for heavy duty vehicles.
-------
-34-
Table III - A
Nationwide KC Emissions
10^ tons per year (percent of total regulated mobile source emissions)
Source 1972 1975 1980 1985 1990
LDV Exhaust 4.8 (41%) 4.9 (45%) 3.4 (41%) .1.7 (38%) 1.0 (31%)
Evap + Crank-
case 3.1 (27%) 2.6 (24%) 1.8 (22%) 0.7 (16%) 0.3 (9%)
LDV Total 7.9 (68%) 7.5 (69%) 5.3 (65%) 2.4 (53%) 1.3 (44%)
LDT Exhaust 0,8 (7%) 0,8 (7%) 0.9 (11%) 0.3 (1S%) 0.3 (25%)
Evap + Crank-
case 0.6 (5%) 0.5 (5%) 0.4 (5%) 0.2 (4%) 0.1 (3%)
LDT Total 1.4 (12%) 1.4 (13%) 1.3 (16%) 1.0 (22%) 1.0 (31%)
KDV Exhaust 1.7 (15%) 1.4 (13%) 1.1 (13%) 0.7 (16%) 0.6 (19%)
Evap 0.6 (5%) 0.6 (6%) 0.4 (5%) 0.4 (9%) 0.3 (9%)
HOT Total 2.3(20%) 2.0(18%) 1.6(20%) 1.1(24%) 0.9(28%)
Total Regulated
Mobile Sources 11.6 10.9 8.2 4.5 3.2
Other Mobile
Sources 1.3 1.4 1.7 2.0 2.3
Total Mobile
Sources 12.9 12.3 9.9 6.5 5.5
Source: Revised Esmitates of Total.. Nationwide Emissions for Various
Regulatory Alternatives, internal EPA memorandum, January, 1976,
as amended October, 1976.
*NOTE: Totals may not add due to rounding errors.
-------
-35-
Table III - B
Nationwide CO Emissions
106 tons per year (percent of total regulated mobile source emissions)
Source
1972
1975
1980
1985
1990
LDV
57.2
(73%)
58.5
(73%)
40.8
(65%)
19.5
(47%)
11.3
(32%)
IDT
9.4
(127=)
10.0
(12%)
10.0
(16%)
9.8
(24%)
10.6
(30%)
HDV
12.0
(15%)
12.0
(15%)
12.1
(19%)
12.3
(30%)
13.2
(38%)
Total Regulated
Mobile Sources
78.5
80.5
62.9
41.6
35.1
Other Mobile
Sources
8.3
9.1
10.6
12.3
14.4
Total Mobile
Sources
86.9
89.6
73.5
53.9
49.5
Source: Revised Estimates of Total Nationwide Emissive j.m Various
Regulatory Alternatives, internal EPA memorandum, January, 1976,
as amended October, 1976.
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-36-
Table III - C
Nationwide NGzi "missions
10 tons per year (percent of total regulated mobile source emissions)
Source
1972
1975
1980
1985
1990
LDV
5,0 (647.)
5.1 (61%)
3.5 (49%)
1.5 (26%)
0.9
(16%)
LDT
0.8 (10%)
o.9 (iiro
0.9 (13%)
0.8 (14%)
O.S
(16/0
.HBV
2.0 (26%)
2.4 (29%)
2.8 (297.)
3.4 (60%)
3.9
(70%)
Total Regulated
Mobile Sources 7.8
3.4
7.2
5.7
5.6
Other Mobile
Sources
2.3
2.5
2.9
3.3
3.9
Total Mobile
Sources
10.1
10.9
10.1
9.0
9.5
Source: Revised Estimates
of Total Nationwide Emissions
for Various
Regulatory Alternatives, internal EPA memorandum, January, 1976,
as amended Octover, 1976.
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-37-
ASSUMPTIONS FOR TABLES III-A, III-B, and III-C
- Light duty vehicles will be controlled to
statutory emission levels (.41 HC, 3.4 CO,
.4 NOx) beginning in 1978 as required by
the current language of the Clean Air Act.
- Light duty trucks will be controlled to levels
comparable in stringency to the 1977 interim
light duty vehicle standards (1.7 HC, IS CO,.
2.3 *!0:c) beginning in 1979.
- Both light duty vehicle and, light duty truck
evaporative emissions will be controlled to
more stringent levels using a new test procedure
beginning in 1978. as has been promulgated by
EPA, 41 FR 35626, 8/23/76.
- Heavy duty vehicle exhaust einissions will be
controlled to interim levels of 10 g/bhp-h
HC + NOx and 25 g/bhp-h CO beginning in 1978
as has been proposed by EPA, 41 FR 21292,
5/24/76. More stringent standards are planned
for 1983 but are as yet undefined and have
not been considered in the above tables.
-------
-38-
Also, a stringent evaporative emission standard
for EDVs is planned for the 1983-1985 time frame
but has not yet been defined and is not considered
in the above tables.
The category "other mobile sources" is defined
to include motorcycles, aircraft, tractors,
vessels, locomotives, miscellaneous off-
Tri.s 5md X^T.rn-rrpT-py3 snd otlisir
utility engines.
-------
39-
B. Primary Impact
1. Emissions Reductions for Light Duty Trucks
As shown in Table III-D the exhaust emissions standards will decrease
hydrocarbon, carbon monoxide and oxides of nitrogen emissions from light
duty trucks sold in model year 1979 and subsequent model years by 38
percent, 29 percent and 42 percent respectively on a per truck, basis.
Evaporative emission standards for light duty trucks, part of the final
regulations, currently apply to light duty trucks under 6000 pounds CYUK.
The primary impact of the final evaporative, emission standards occurs
for those light duty trucks which have been added to the light duty truck
class (6000 to 8500 pounds GVWR). These heavier rated trucks are currently
controlled under the heavy duty engine regulations, and are not subject
to an evaporative emission standard except in the state of California.
For these trucks, imposition of the final evaporative emission standard
results in a 28 percent decrease in evaporative emissions from each
truck sold in model year 1979 and subsequent model years.
As new light duty trucks are put into use and older ones are scrapped,
emissions of the "average" light duty truck on the road will decrease.
Using sales projections, usage data, data on annual mileage 3/ and emission
3/ Annual mileage data on light duty trucks is contained in the preliminary
edition of Supplement No. 5 for compilation of Air Pollutant Emission
Factors (AP-42), U.S. Environmental Protection Agency, April 1975.
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-40-
factor data on. light duty trucks contained in Appendix 3 to this report,
urban emissions of HC, CO and NOx from the total in-use population
of light duty trucks have been projected through 1990 with and with-
out the regulations in effect (Table III-E). One can see that the
control standards will be effective in reducing the absolute urban
light duty truck emissions of HC, CO and NOx.
-------
-CI-
TABLE III-D
Estimated. Incremental Degree of Control for
Final Emission Standards
Less Than 6000 6000 to 8500 Overall3,
Vehicle Weight Category Pounds GTOR Pounds GTCR Incremental
Exhaust HC 15% 53% 38%
Exhaust CO 10% 44% 29%
Exhaust iSOx 251 55% 42%
Evaporative KC NAb 28% 10
Crankcase HC • NAC — :
a. Weighted by vehicle miles traveled, and based on change in lifetime
emissions of a typical truck resulting from the proposed standards.
b. Evaporative emission standards currently apply to light duty trucks
in the weight range 0 to 6000 pounds GWR therefore no further control
is assumed.
c. Gasoline engines, under the current light and heavy duty vehicle regu-
lations, have no crankcase emissions.
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-42-
Strategy
t!o Action
Proposal
No Action.
Proposal
No Action
Proposal
Table III-E
Comparison of Light Duty Truck Urban
Emissions With and Without the
Proposed Action
1972 1975 1980 1985
Hydrocarbons (10 tons per year)
79
79
.79
.75
.85
.76
.95
.60
Carbon Monoxide (10^ tons per year)
.6.05
6.05
6.58
6.58
7.40
6.83
8.84
6.73
Oxides of Nitrogen (10^ tons per year)
.35
.35
.38
.38
.44
.39
.52
.34
1990
1.08
.57
10.30
7.32
.61
.37
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2¦ Air Quality Impact of the Action
The reductions in urban emissions in 1990 discussed above, 0.51
million tons per year of hydrocarbons, 3.0 million tons per year of
carbon monoxide and 0.25 million tons of oxides of nitrogen, will
result in measurable air quality improvements. Table. III-F presents
those air quality improvements, and allows for a comparison with the
alternative of taking no action. Table III-F is a summary of &e
results of an EPA analysis 4/ which examined the impact of this
regulation on the expected air quality of thirty-six Air Quality
Control Regions. The analysis was performed using emission factors
presented in Appendix B to this report for light duty vehicles
and light duty trucks, and in Supplement No. 5 for the compilation
of Air Pollutant Emission Factors (AP-42), U.S. EPA, April 1975,
and using a computer simulation model 5/ to predict the future air
quality impact of various growth and control situations.
Oxidants, the most pervasive air quality problem, will be
reduced six percent in 1990. as a direct result of this regulation.
This .reduction in ambient oxidant levels will occur in those 29 Air
Quality Control Regions failing to meet the ambient air quality
standard for oxidants which have been included in the analysis.
Similar improvements in oxidant levels, although not quantified
here, can be expected to occur in other areas of the country.
4/ Analysis of Alternative Standards for Light Duty Trucks, EPA,
November 1976.
5/ N. deNevers and R. Morris, "Rollback Modeling - Basic and Modified,"
presented at the annual meeting of the Air Pollution Control Association,
June 24-28, 1973- Chicago, Illinois, paper no. 73-139.
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-44-
Data available to EPA 6/ show that about 60 urban areas currently
fail to meet the ambient oxidant air quality standard. In addition,
some rural regions in the midwest and throughout the East coast are
experiencing widespread violations of the oxidant standard. It
seems likely then, that additional violations of the oxidant standard
will be discovered as the air quality monitoring network throughout
the country is enlarged, and that this regulation will have a more
broadly basea impact on the oxidant problem than indicated by
examining the 29 regions included in. the analysis.
Twenty-six urban areas were analyzed for carbon monoxide.
Carbon monoxide, unlike hydrocarbons (oxidant precursors) and oxides of
nitrogen,.is almost uniquely a motor vehicle problem. This is due to
the fact that locations which experience violations of the carbon monoxide
standard are most always those locations with high traffic densities.
This regulation will, in 1990, reduce the carbon monoxide concentrations
an average of five percent in those twenty-six urban areas.
For oxides of nitrogen, this regulation will slow the increase in
ambient concentrations by three to four percent in 1990. Since the
ambient nitrogen dioxide air quality probLen appears to be one of
containing growth in emissions of oxides of nitrogen rather than
rolling back current levels, and since future growth of stationary
source oxides of nitrogen emissions will be the major air quality
problem, emission limitations for new stationary sources will form
jj/ Air Quality Impact of Alternative Emission Standards for Light
Duty Vehicles, Environmental Protection Agency, Office of Air and
Waste Management, Revised March 12, 1975.
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-45-
the bulk of the control of oxides of nitrogen necessary to maintain
current ambient levels. EPA's action in promulgating revised light
duty truck regulations contributes to this effort to maintain current
ambient levels, in that it slows the increase in nitrogen dioxide
ambient concentrations.
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-46-
Table III - F
Urban Air Quality Impact of the Proposed Action
Average Percent Improvement in CO Air Quality
Concentration From Base Year (1S70) (CBD Growth)
1980
19S5
1990
No Action
Proposal
25
25
50
54
58
63
Average Precent Improvement in Oxidant Air Quality
Concentration From Base 1'ear (1970)
1980
1985
1990
CBD*
MET**
Proposal
CBD
MET
No Action
CBD
MET
Proposal
CBD
MET'
15
16
12
25
31
28
26
24
32
30.
Average Percent Depredation in NOjj Air Quality
Concentration From Base Year (1972)
1980
1985
7
9
5
6
1990
12
14
9
10
*CBD = Central business district growth assumed for mobile sources.
*MET = Metropolitation area growth assumed for mobile sources.
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C. Potential Secondary Environmental Impacts of This- Regulation
1. Sulfuric Acid Emissions
Historically* stationary sources have been the major contributors,
to sulfate concentrations in urban environments, contributing 99 percent
of the total sulfate air burden. 7/ With the introduction of the current
catalyst/air pump technology applied to mobile sources, there exists
the potential for a significant source of mobile related sulfate
emissions in the form of sulfuric acid aerosol. While of negligible
magnitude on a regional basis, mobile source sulfuric acid emissions
could produce a significant localized urban sulfate concentration ia
urban street canyons or congested urban freeway situations. Moreover,
mobile source sulfates differ from stationary source sulfates in that
they are emitted near the ground and in the form of a fine sulfuric
acid mist.
The increase sulfate emissions due to the use of oxidation
catalyst/air pump combination has been of considerable concern to EPA.
In pre-model year 1975 non-catalyst systems, most of the fuel sulfur
leaves the vehicle after combustion as S02- In oxidation catalyst/air
pump systems used on 1975 model year automobiles and light duty trucks,
more of the sulfur leaves the combustion chamber as SO3. The SO3
combines with water in the exhaust to form sulfuric acid aerosol.
JJ Communication with M. Williams, OMSAPC, EPA, June 1975.
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Extensive efforts have been made ifithin government and industry to
improve the information about mobile source sulfate emission factors,
sulfate air quality modeling techniques and sulfate health effects as. a
function of exposure level. In addition technology assessment work is
proceeding to identify how sulfates are formed in catalyst/air pump
systems, and to develop other low sulfate producing catalytic control
systems such as the 3-way catalyst. The work in these areas is directed
toward development of a sulfuric acid emission standard for light
duty vehicles and light duty trucks should such a standard become
necessary. This effort is designed to insure that mobile source sul-
fate levels in real-life localized problem areas will not result in
situations hazardous to human health.
Although work is progressing within EPA directed towards develop-
ment of a sulfuric acid emission standard, current data indicate
that such a standard will not be needed in the near term. EPA's
decision not to propose a sulfuric acid emission standard was announced
April 12, 1976, by Dr. Thomas Murphy 8/, at which time Dr. Murphy
presented EPA's rationale and future plans in. this area:
"...[0]ur decision not to propose a standard at this time does not
mean that a standard may not be needed and promulgated in the future.
Rather, it means that EPA is not today in a position to determine with
8/ Opening Remarks by Thomas A. Murphy, Deputy Assistant Administrator,
Air, Land and Water Use, U.S. Environmental Protection Agency at the
Symposium "The General Motors/Environmental Protection Agency Sulfate
Dispersion Experiment," Research Triangle Park, North Carolina,
April 12, 1976.
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reasonable certainty whether, arid if so at what level, establishment
of a sulfuric acid emission standard for automobiles may be required
or prudent to protect the public health. We are continuing vigorously
to investigate the current areas of uncertainty, including health effects
and exposure estimates, and will continue to monitor vehicle sulfuric
acid emission rates and the development of sulfuric acid control techniques
by industry. Moreover, we will monitor ambient sulfuric acid levels
in the vicinity of roadways. These programs will provide us the
capability to identify the potential hazard of sulfuric acid emissions
to "oublic snd slXow us to ts.lcs 'D^rsvsntstivs 3.cti.cn 2.
real danger could develop."
These light duty truck emission standards are not expected to
increase present mobile source sulfate emissions significantly or to
present a future problem. Current data indicate that there is no
substantial difference in the sulfuric acid emission levels of catalyst/
non-air pump and non-catalyst vehicles. 9/ In contrast, sulfuric acid
emissions of catalyst/air pump vehicles do appear to be at levels
generally higher than those for either catalyst/non-air pump or non-
catalyst vehicles. Estimates of 1975 light duty truck sales show that
the light duty truck manufacturers may be expected to equip about 60
percent of their production units with catalysts (approximately 830,000
vehicles).
9J Test Report, Automotive Sulfuric Acid Baseline Program, Environmental
Protection Agency, Emission Control Technology Division, January 1976.
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-50-
By 1978 this figure is expected to increase significantly. Of those
trucks manuf-actured in 1975, about twenty percent were equipped with a
catalyst in combination with an air pump (approximately 280,000 vehicles).
This compares with 1975 light duty vehicle sales figures for catalyst/air
pump vehicles of 2.5 to 3.0 million units.
The final light duty truck emission standards were set. at levels
which do not require the application of catalyst technology, and in no
case should the standards require the application of catalyst/air pump
technology. Even though these standards do not require the use of
catalyst/air pump technology, some manufacturers may choose to employ
such technology on some trucks to increase fuel economy and driveability.
In worst case 10/, the incremental increase in catalyst/air pump vehicles
in 1979 as a result of the proposed regulation would be 760,000 vehicles
per year. This worst case situation would represent a annual increase
in all catalyst/air pump vehicles of less than seven percent.
.10/ Internal EPA projections based on trends in 1975-1977 catalyst
usage.
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2. Water Pollution, Noise Control and Energy Consumption
Control of light duty truck emissions is expected to have negligible
impact either on water pollution, or on the ability of manufacturers to
meet present and future noise emission standards for light duty trucks.
Fuel economy of light duty trucks is not expected to be adversely
impacted by this regulation. At the emission levels promulgated, most
light duty truck manufacturers are expected to equip light duty trucks
with catalyst emission control systemsr resulting in no fuel economy
change for those vehicles currently regulated as light duty trucks (0 to
6000 pounds-GVWIO. For those vehicles added to the light duty truck
class (oOOO to 8500 pounds GVWR) which are currently experiencing a zero
to five percent fuel economy penalty compared to uncontrolled vehicles 11/,
application of catalyst technology is expected to result in fuel economy
comparable to that of uncontrolled vehicles.
Even though the emission standards promulgated for light duty trucks,
1.7 g/m HC, 18 g/m CO and 2.3 g/m NOx, require a reduction in NOx emissions
from the current 3.1 g/m NOx emission standard for light duty trucks, fuel
economy of trucks in the new light duty truck class is not expected to be
adversely affected. Analysis of the 1977 model year light duty vehicle
fuel economy results obtained in EPA's certification program .12/ has
shown that 1977 model year light duty vehicles are 2.8 percent better in
fuel economy than comparable 1976 model year vehicles.. In 1976, the light
11/ An Examination of Interim Emission Control Strategies for Heavy
Duty Vehicles, QMSAPC, EPA October 3, 1975.
12/ Fuel economy of the 1974-1977 Models, Draft SAE paper September 1976.
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-52-
duty vehicle emission standards were 1.5 g/m EC, 15 g/m CO and 3.1 NOx.
In 1977, the light duty vehicle emission standards remained the sane
for HC and CO, and changed to 2.0 g/m for £iOx. Because EPA projects
that light duty vehicle emission control technology will be employed
on light duty trucks subject to this regulation, and because the final
light duty truck emission standards have been adjusted to account for
differences in weight between cars and trucks, it is concluded that
light duty trucks which employ emission control technology similar to
that employed on 1977 light duty vehicles will not experience a fuel
penalty due to more stringent 'amission control. As indicated by the
improvement accomplished by the light duty vehicle industry in model
year 1977, there appears to exist the potential for improvements in
light duty truck fuel economy in the 1979 model year. It should be
noted that the fuel economy improvements for light duty vehicles in
the 1977 model year are a result of engineering improvements in
emission control systems, and are not due to reduced vehicle weight.
The referenced analysis estimates that an overall improvement in fuel
economy (which includes the benefits due to reduced vehicle weight)
of 6 percent occurred in the 1977 model year.
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Chapter IV
ECONOMIC IMPACT 1/
A. Economic Background
1. Description of Trucks in the New Light Duty Truck Class
The new light duty truck class consists of many different styles
of trucks intended for various types of operation. Included in the
class are pickup trucks, van trucks, panel trucks, station wagons
built on pickup truck chassis, multistop trucks (e.g., bakery and
milk trucks), and off-road and utility vehicles (e.g., four wheel
drive vehicles). Some trucks in the new light duty truck class are
sold as cab chassis combinations tc special body builders who
complete the construction of the vehicle (e.g., some mobile homes).
Most of these trucks are equipped with V-8 engines essentially
the same as those used in light duty vehicles. The major differences
are in the carburetor and distributor settings with minor differences
in basic engine specifications like valve diameters and bearing load
ratings. The similarities between light duty vehicle and light duty
truck engines should allow adaptation of light duty vehicle emission
control systems for use on trucks in the new light duty truck class.
Factory sales of light duty trucks less than 6000 pounds GVWR
was about 977,000 vehicles in 1975. Approximately 874,000 trucks
between 6000 and 8500 pounds GWR were produced in 1975. These 874,000
vehicles, which, were certified as heavy duty vehicles in 1S75, will be
Xj This chapter consists of data and conclusions extracted from a more
detailed analysis entitled "Economic Assessment of the Revised Light
Duty Truck Regulations for 1979 and Later Model Year Light Duty Trucks,"
prepared by the Office of Mobile Source Air Pollution Control.
Information in this chapter not specifically referenced may be found
in that document.
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classified as light duty trucks under these regulations. Factory sales
over the past tea years grew at a 4.1 percent annual rate, though in
1974 and 1975 sales fell nearly 12 and 20 percent respectively from 1973
levels. 1976 sales have again picked up and, if sales for the first
six months are repeated, will exceed 1973 sales by 230,000 units.
2. Description of the Manufacturers
Under the redefinition of the light duty truck class there will
be five primary domestic manufacturers of light duty trucks. Ford and
General Motors (Chevrolet and GMC) currently dominate the market, producing
over 70 percent of all trucks in the new light duty truck class which
. _ _ _ 1 * 1 "t_ m. . w _ /T.I-* . • n e*i _ - _ _ * \ » . 1
cijlc; 3u^.u u.s_c-£j.j-y- cuLe jLOiio^^u oy ^niysj.vt-'Ougtt.s v£lcii
percent, American Hctors/Jeep with 4 percent, and International Harvester
with 2 percent. Part of the U.S. production is exported for sale in
foreign markets. Imports only account for about 7 percent of total U.S.
domestic sales. 2/
The wholesale value of all trucks and buses produced.in the U.S.
in 1974 was approximately $10.1 billion. Total domestic factory sales
of trucks and buses in that year was 2.46 million vehicles of which
approximately 1.9 million would have been classified as light duty trucks
under the 1979 light duty truck regulations. 3/
None of the five domestic producers derives much of its total
revenue from the sale of trucks in the new light duty truck class.
Except for International Harvester, all produce passenger vehicles.
International Harvester produces heavy duty trucks as do Ford and GM.
Most have wholly owned subsidiaries, or divisions which manufacture
2J Motor Vehicle Manufacturers Association.
3/ Automotive News Almanac, April 1975.
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-55-
many of the parts needed to construct the vehicle and to supply the
replacement parts market. All have diversified into some non-trans-
portation related enterprises such as electronics, appliances or
plastics,, though non derive more than around five percent of total
revenue from these lines of businesses.
B. Cost of Implementing the LPT Regulations
Analysis done hy EPA has indicated that it would cost about $211
to install in LDTs a catalyst emission control system capable of meeting
the emission standards. This is. based on the assumption that the same
equipment which can be used on light duty vehicles to meet the current
1977 light duty vehicle Federal emission standards also could be used
to meet the 1979 light duty truck standards. The cost of the equipment
is given in Table IV-A. During the public comment manufacturers
provided their estimates of the costs of the control equipment necessary
to meet the new standards. This data is summarized in Table IY-B.
In addition to equipping trucks with pollution control equipment
manufacturers will have to expend financial resources to develop control
systems and calibrations and to certify with EPA that their trucks are
capable of meeting the standards. EPA estimates that the industry will
spend about $17 million for development during model years 1979 to
1983. This is about $6 per truck sold during that period. Certification
costs will be higher during the 1979 and 1980 models than during the
period 1981 to 1983 assuming that the standards do not change. That is
because manufacturers will be able to "carry over" results of
certification tests from one year to the next if no changes are made
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Table IV-A
Cost of Cataly3t Control System
A. System Required to Meet 1974 LDV Cost (1975 dollars)
Federal Standards (3.1, 39, 3.1) U
Evap. Control $ 15
Transmission Control Spark 3
Anti-Dieseling Solenoid 3
Intake Air Heater 5
Port Exhaust Gas Recirculation (EGR) 20
Modulation Valves 5
Miscellaneous Modifications 20
Air Pump 15
Total Cost: 1974 Fed. System. $ 86
B. System Required to Meet 1977 LDV
Federal Standards (1.5, 15, 2.0)
1974 Federal System 86
Oxidation Catalyst 100
Improved Exhaust System 25
Total Cost: § 211
1) Standard using 1972 FTP. Using 1975 FTP Standards will be
(3.0, 28, 3.1)
Source: Automobile Emission Control - The Technical Status and
Development Trends as of March 1976. A Report to the
Administrator prepared by the Emission Control Technology
Division, Mobile Source Pollution Control Program.
April 1976.
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TABLE IV-B
Manufacturers' Estimates of Costs
(Per Vehicle)
for Control Equipment
Manufacturer
GM —
Ford ^
Chrysler (Dodge) SJ
IRC &
AMC/Jeep
Toyota —
Volksvagon
SALES 1-,LIGHTED AVERAGE
Truck Category
0-6,000 lb
minimal
$12
n. a.
$7.60 - $122
3l00 - 3150
3% of sales price
$3.64 - $16.67
(GVWR)
6,001—8,500 lb
$165 - $210
$402
$260
$400
SK0 - $175
n. a.
n. a.
$243.70 - $264.63
a. Minimum system would be catalyst, EGR, and evaporative controls (EVAP).
b. Costs are for a catalyst system. A few 0 - 6,000 pound trucks may
require the installation of this system. Costs also include $37 far
engineering, test facility construction* and changes in operating
costs.
c. Some current LDTs may require EGR timer, air pump, catalyst, and heat
shields. 6,000 to 8,500 pound trucks will need equipment such as
catalyst heated air, exhaust system improvements, air pump, proportional
EGR. Cost includes amortised development, certification, retooling and
expansion expenses.
d. Cost includes cost for catalyst, air injection, EVA?, and carburetor and
EGR revisions. Cost also includes $127 for exhaust system changes.
e. CJ 5/7 will require catalysts, transmission controlled spark (TCS), and
improved exhaust systems. The high, cost estimate is for a system that
includes catalyst, TCS, and air injection" for Cherokee Wagoneers and
truck models.
f. Costs for either a thermal reactor or catalyst which may be required
on some models to meet standards.
g. Assumes that costs for all importers will be the same as those for Toyota.
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to vehicles which could impact emissions. EPA estimates that the
total certification costs in. 1979 will be 58.7 million. In subsequent
years this total will decline substantially as carry over applies.
EPA estimates per vehicle certification costs over the period 1979 Co
1983 to be about $2.
An advantage of using a catalyst system is that it does not
impose a fuel economy penalty on the- vehicle. This occurs because
the operation of the catalyst is basically independent of the operation
of the engine. Use of catalyst technology pemits manufacturers' sore
freedom to adjust the engine for fuel economy while maintaining a con-
tinued high level of emission control. A non-catalyst centre! cystan,
though its initial.cost may be $30 less than a catalyst system, is often
accompanied by a 10 to 15 percent fuel econony penalty, kj
Maintenance costs are not expected to change as a result of
these regulations although if any maintenance costs change, those require-
ments should decrease. Unleaded fuels which sust be used on catalyst
equipped vehicles cause less damage to exhaust systems and spark plugs,
increasing the amount of time between replacement of these parts. Since
emissions can be controlled by and large in the catalyst, fr&quent
tuneups may be less crucial to emissions control. Decreases in main-
tenance requirements should offset the slightly higher cost of unleaded
fuel.
The incremental cost of implementing these regulations aa-y be calcu-
lated by estimating the number of trucks which must meet the standard and
kj Trade-Offs Associated with Possible Auto Emissions Standards,
Emission Control Technology Division, K'SAPC, February 1975.
-------
applying a cost of control factor to that estimate. Combining sticker
price increases and changes in operating costs (if any) the following
incremental costs (per vehicle) of meeting the emission standards were
derived;
Trucks Previously Certified Trucks in
as Heavy Duty Vehicles Current Light
Duty Truck Class
Sticker- Price: Equipment $211 $0
Development 6 6
Certification 2 2
Operating Costs: Kaintenance 0 0
Fuel 0 0
Total $219 $8
Mdtiy rftsnufacizurar-s are plaimzng to use catalyst ^ ~ <~r. ccritzrwl
systems on light duty trucks less than 6CC0 pounds GFWR prior to the
1979 model year. For the purposes of calculating the aggregate incre-
mental cost of this regulation EPA assumed that all truck.3 currently
defined as light duty trucks were so equipped. Trucks between 6000
and 8500 pounds GVWR are considered to have essentially no emission
control devices and so the full §219 expense would he required. The
aggregate Incremental costs are £iven in Table DT-C.
For the years 1979-1983 the total cost of implementing this regulation
will be $1.67 billion. The calculations made in preparing Table I7-C
assume that light duty truck sales will continue to expand, at 4.1
percent per year. It was also assumed that the sales split between
0-6000 pound trucks and 6,000-8,500 pound trucks will be the sane
during the 1979-19B3 period as it was in 1975 and 1976. In these
years, the first where light trucks were considered a class of
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Table IV-C
Incremental Cost of Implementing
the 1979 Light Truck Regulations
U.S. Truck Sales
Incremental Cost
0 — 6000 6000 - 8500 of Control
1974 1,616,319 639,689 0
1975 1,204,259 895,758 0
1976 e 1,255,000 f/ 1,287,000 f/ 0
1977 e 1,306,000 1,340,000 0
1978 e 1,360,000 1,394,000 0
0 - 3500
1979 e
1980 e
1981 e
1982 e
1983 e
2,724,000
2,336,000
2,952,000
3,073,000
3,199,999
309,174,000 £-/
321,886,000
335,052,000
348,785,000
363,086,000
a/ Estimate made on the basis of actual six month production being
repeated in last six months of 1976.
b/ Cost estimates are based on 1 to 1 split between 0 - 6,000 and
6,001 to 8,500 pound trucks with $8 and $219 costs for each
category respectively.
e = estimated
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vehicle separate from passenger cars with separate standards,, the
ratio between these two categories of trucks approached 1 to 1.
Just one year before, in 1974, trucks with GWR's less than 6,000
pounds out numbered trucks with GVURs between 6001 and 8500 pounds
two to one. This two to one ratio is one that had been relatively
stable for many years. Since 1975 sales of the heavier trucks have
increased (doubled between 1974 and 1976) while sales of the lighter
trucks have decreased. 1975 saw a dramatic increase in the sales of
van trucks which mostly have GWB.S of greater than 6,000 pounds. 1975
also saw the advent of che 6*050 pound GVwn truck which several msriU-
facturers introduced to replace models which previously had GVWRs of
less than 6,000 pounds. What ever tha reason for this shift, the result
is to significantly increase the costs of this action over what it would
have been had the historical 2 to 1 split persisted. Tor example the
first year (1979) costs would have been S211.2 million and total five
year costs $1.15 billion had this historical split continued.
As a result of implementing new light duty truck regulations govern-
ment expenditures .will increase. Two additional man years for labora-
tory and data technicians will be required at a cost of $45,000. Costs
for testing vehicles at EPA is expected to increase since the number of
durability and emission data vehicles will go up by 11 and 55 vehicles
respectively. Total costs to the government for increased testing and
two additional positions will be $160,000 for the 1979 model year.
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C. Economic Impact
If manufacturers elect to pass the entire $219- cost of this regu-
lation 011 to the consumer this would increase typical 1975 list prices
of light duty trucks with GVWRs between 6000 and 8500 pounds by approxi-
mately 3.8 to 6.0 percent. Assuming that the relationship between
changes in price and the resultant changes in demand for the light duty
truck market is the same as that in the light duty vehicle market, the
implementation of the proposed regulations could cause as much as a 3-8
to 6.0 percent decrease in unit sales for these heavier trucks. A six
oercent decrease in sales, of 6,000 to -8,500 pounds is ecuivilsr.t tc a
3.0% decrease demand for all trucks in the new light duty truck class.
Manufacturers would be expected to experience similar losses in sales
revenue and profits.
This impact should be considered a worst case situation. In
performing this analysis EPA has attempted to provide a very conservative
estimate of the impact of these regulations on light truck demand by
assuming that the price elasticity of LDTs was -1.0. If this is true,
then a one percent increase in sales price would yield a one percent
decrease in sales. However, there is no economic data to support a
conclusion that a -1.0 price elasticity is realistic for LDTs. Industry
and academic studies done on passenger car price elasticities have
yielded values between -0.3 and -1.0. Thus on the low side a $219
price increase in 6000 to 8500 pound GVWR. LDTs may result in only a 1%
to 1.8% decrease in sales of those trucks.
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Since no econometric studies to determine LDT price elasticities
have been conducted EPA must be satisfied by concluding that sales
decreases resulting from the light duty truck regulations may lie
anywhere within a 0.5 to 3 percent range. Exactly where within that range
the potential decrease in sales will fall is impossible to say with any
certainty. Some consumers may react to the $219 price increase for the
heavier trucks by electing to purchase a lighter truck. This would
increase the demand for these vehicles and mitigate the effects of the
lower demand for heavier trucks. In addition, any significant improve-
ments in general economic conditions resulting in increases in dis-
posable income or improvement in credit availability would increase the
demand for light trucks and probably overshadow the small negative
effects of the price increase.
It is not anticipated that this regulation will so adversely
affect consumer demand that any of the approximately 22 LDT
production facilities will be closed down. There may be
temporary production slow downs at some plants as consumers
re-evaluate their needs for specific light duty trucks and demand
patterns shift between the competing types, sizes, and styles of
trucks. But long run consumer demand for light duty trucks is
expected to continue to grow and so no permanent unemployment
of the industry's 36,036 5/ employees is anticipated. Changes in
5/ Data obtained from U.S. Department of Commerce, County Business
Patterns 1973.
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the product mix of light: duty trucks sold may cause decreases in .
demand, and therefore employment, at some plants which may be made
up by increased output at other plants.
Competition in the light duty truck industry is unlikely to
be significantly affected by this regulation. Table IV-D shows
the percentage of the light duty truck market, total truck market,
and passenger car market held by each firm. The numbers have
historically been quite consistent with GM and Ford being the dominant
market forces.
The low volume producers may be sore hard prasssd, hc.raver, to
bear the costs of certification and any costs to develop a control
system for use on light duty trucks. Dodge, AMC/Jeep and International
Harvester may be placed at a disadvantage because they have smaller
production runs over which to spread costs of developing, and testing
control systems they, will eventually use in production trucks.
Further, at least IHC will experience some disadvantage because it has
certified only heavy duty engines since 1975 and therefore has very
limited facilities and experience for developing LDV type control
systems for their products that will be LDTs after 1979.
The smaller volume manufacturers may be subject to intensified
price competition in some markets after the 1979 regulations are
promulgated. Larger manufacturers who can spread cost increases
out over several markets, may increase prices in selected markets
or of selected trucks by less than the actual costs. Smaller
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Table I7-D
Market Sales: Trucks in, the New Light Duty Truck Class 1/
Light Truck Sales
% of Light as a.% of total % of Motor
Truck Market 2/ Truck Salea by Co. Truck Market
Chevrolet 36.7
GMC 6.7
Ford 31.5
Chrysler (Dodge) 12.1
AMC/Jeep 4-0
IHC 2.1
Other Truck Manufac-
tures 0.0
Other Manufac-
turers of Passenger
Cars
90
84
84
84
100,0
37
0.0
34
7.1
31.2
11.9
3.5
4.6
1.9
% of Passenger
Car Market
21.2 1/
23.0
11.7
Imports
6.9
5.8
22.2
18.2
100.0
100.0
100.0
1/ Light Truck defined as 0-8,500 GVWR.
2/ Based on U.S. Truck Sales (1975) as contained in Automotive.Neva
1976 Market Data Book.
.3/ GM's total market share for passenger car3 was 43.4%.
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taanufacturers who cannot spread out costs and recoup losses by increa-
sing prices in other markets may get caught in a cost-price squeeze.
The most susceptable to this type of predicament would be IHC since it
concentrates in the utility truck market and has estimated its costs
to comply at $400 per vehicle, well above the industry average of
about $250. Dodge, though it does compete in several LDT markets
may also have difficulty in recouping all its estimated $260 in costs.
AMC/Jeep, though a small producer, has estimated a cost increase of
only $140 to $175 ana thus should be able to regain competitive in
terns of price.
Whether or not a particular manufacturer will be priced out of a
particular market is impossible to tell since it will depend upon how
the low cost manufacturers decide to price their products. This is a
corporate decision which must take into consideration many factors of
which one is the possibility of legal action being taken against cer-
tain firms if there is evidence of predatory pricing. To date there
is. little evidence to support the conclusion that the price leaders of
the light truck industry have priced, or will price, their products so
as to intentionally drive competion out of business.
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D. Cost Effectiveness
Cost effectiveness is a statistic which measures the economic
efficiency of undertaking some action to achieve a certain goal. In
the context of controlling the emissions from mobile sources cost
effectiveness is measured in terms of cost per ton of pollutant
controlled. To calculate this number the costs of controlling each
pollutant must be determined. The allocation of control costs to
each pollutant is somewhat arbitrary. EPA has attempted to allocate
control costs in Table IV-E, based on the effect each component may
have on emissions. The cost effectiveness of the 1979 light duty truck
regulations for 6000 to 8500 pound GVWl vehicles is also shown in Table
IV-E.
One alternative to the new 1979 light duty truck regulations was to
reduce the standards but leave the definition of a light truck unchanged.
For those vehicles in the class (0 - 6,000 pounds.GVWR) the cost would
be $8 for development and certification while the incremental amount of
control would be 0.3g/mi - HC, 2.0g/mi - CO, and 0.8g/mi - N0X. The
resulting cost effectiveness numbers are, for the respective pollutants,
$Sl-/ton - KC, $12/ton - CO, and $30/ton - N0X.
In combination with this a cost effectiveness for leaving 6,000-
8,500 pound GVUR trucks in the heavy duty vehicle class should be
determined. The cost effectiveness numbers calculated for the heavy
duty engine Notice of Proposed Rule Making (See Draft Environmental
and Inflationary Impact Statement - Interim Heavy Duty Engine Regulations
for 1979 and Later Model Years, dated 4/21/76) are not appropriate
-------
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TABLE IV-E
Cost Effectiveness - 1979
LD*I Exhaust Emissions Regulations
6000 to 8500 Pound GVWR Trucks
Transmission Controlled Spark
Anti Diesel Solenoid
Intake Air Heater
Proportional EGE
Modulation Valves
Miscellaneous Mods
Air Pump
Oxidation Catalyst
Improved Exhaust Material
Development and Certification
Cost Allocation ($)
HC CO
3
2
7
8
50
12
2
7
7
50
13
3
\Qx
20
86,
83
35 = 204
a/
Base line Emissions (g/mi)
LBT 1979 Standard (g/mi)
Seduction (g/rax)
Lifetime Reductions (tons/100,000
Cost Effectiveness
A.3 44 5.2
- 1.7 18 2.3
2.5 26 2.9
miles) .29 2.86 .32
$297 $29 $109
a/ Cost of evaporative controls, $15, is not included in these, calcu-
lations since these controls are not used for the control of exhaust
emissions.
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as a comparison because they were based on equations developed for an
"average" heavy duty vehicle which was considered to have a GW3. o£
26,000 pounds. Emissions factors for such a vehicle are much different
than a typical 6,000 to 8,500 pound GVWR truck. EPA. does not have data
which indicate in grams per mile how a lighter truck would, perform under
the 1979 heavy duty truck regulations (the results of which are expressed
in grams per brake-horsepower hour) and it is impossible to accurately
extrapolate the relationship from the data based on an average truck of
26,000 pounds GVWR.
To T5rcvida a rough sstitnats cf the cost effectiveness of ie^vine
6,000 to 8,500 pound trucks in the HDV class it is necessary to assume that
emissions of these trucks will be equal to the gras-per-mile equivalent to
the proposed 1979 heavy duty engine standards. (1.6g/mi - HC, 69g/ai - CO,
and 6.3 g/mi - NOx). The resulting analysis shown in Table IV~? shows
that only control of HC would be gained. Emissions of CO and NGx sight
well get worse. The costs associated with this increase in pollution
have not been factored into the $227/ton cost effectiveness number .for
HC which is obtained. It should be remembered, however, that this
analysis is based on the assumption that gram-per-nile equivalents of a
26,000 pound GVWR truck can he extrapolated to obtain a value for
6,000 to 8,500 pound GVWR trucks, an assumption which, is highly tenuous
and may potentially lead to a highly inaccurate number.
The cost effectiveness of the 1979 light duty truck regulations can
be seen in comparison with other mobile source cost effectiveness numbers
in Table IV-G. A review of this data indicates that except for the
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-70-
Table IV-F
Cost Effectiveness of 6000 - 8500 Pound.
GVWR Trucks to Meet HDE Regulations
HC CO NOx
Air Pump 15
Miscellaneous Modifications 20
Modulation Valves 5
Heated. Air 5
EGR 20
Certification 3
$68
Baseline Emissions (g/'mi) 4.3 44 5.2
Proposed 1979 KDE Regulations 1.6 69 6.3
Reduction (g/mi) 2.7 (-25) (-.9)
Lifetime Reduction (tons/
100,000 miles) .3 -
Cost Effectiveness $227/ton
-------
proposed 1979 heavy duty vehicle interim standards, the 1979 light duty
truck regulations are the most cost effective in controlling HC, CO
and NOx emissions. Further control of light duty vehicles becomes
increasingly costly as standards get more stringent than existing
standards. However, additional control of light duty truck emissions
is possible without having to spend as much per ton of pollutant
controlled.
-------
Table IV-G
Cost Effectrveness of Selected Proposed Federal Emissions Contol Programs
Control Program
Base line Emissions
Frogtara Emission Level 1/
Emissions /ifter Control
Program Initiated
Cost of Control ($/ton)
lie CO HOx
Option 1
LDT Interim
Standard
LDV 1975
California
Standards
LDV Fed.
Statutory Stds.
1974 L13T
Standard 2.0/20/3.1
HEV
Currant
Levels
1&75 Ted.
LDV
Standards 1.5/15/3.1
1975 Fed.
LDV
Standards 1,5/13/3,1
1.7/13/2.3
.9/9.0/2.0
¦ 61/3.4/0.6
200
30 3
470
21
73 —
155
N>
kl
2300
HDV Ted.
Interim
Etand-ard
LDV/LDT It] 3/
2/
2*9
61-414
4-29
i "i
s i>v.
1/ All emissions factors in groins per mile RC/CO/^Ox except Car
2} He-avy Duty Vehicle (KDV) scissions Jewels based on J.S74 vs, proposed 1978 H2V
emissions standards.
1974 Standards; 16 grams/fchp-hr (HC+N0x), AO grams/bhp-hr (CO).
1973 Proposse Standards: 1.5 grans/bhp-^r (1!C) t 25,0 grams/blip-lir (CO), 10^0
3/ 1Y- Cost fc'ffectivaness calculations asa'Jme a 30E failure race.
£/ O'a tailed fcy \jeigTatlaa 0-6DOCi GWS wd 60QQ-85DQ* GVWR ca&z-cfEfictiveassa values,
grams/bbp/lir HOx.)
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CHAPTER V
Other General Considerations
A. Irreversible and Irretrievable Commitment of Resources
The major commitment of natural resources associated with this
regulation relates to the approach taken by the manufacturer to achieve
the standards. Although this cannot be accurately determined at this
time, analogies to automotive control and current light duty truck con-
trol will provide, some evidence of potential commitment of resources.
In general, any resource commitment is expected to be negligible.
If catalytic converters are used exclusively to meet the 1979
standards, an additional commitment of platinum, palladium and steel
would be required over and above that needed for light duty vehicles
and current light duty trucks which already employ catalysts. The total
light duty truck demand for platinum and palladium might be as high as
18 percent of the automotive demand in 1990, or somewhat less than
180,000 troy ounces per year if all light duty trucks were to employ
catalysts. Should trends established for catalyst usage in 1975 on
light duty trucks 1/ continue through 1990, and should all heavier
trucks added to the light duty truck class employ catalyst, the
Incremental demand in 1990 (the amount which can be attributed to
this regulation) would be approximately 60,000 troy ounces per year.
An increase of this size would not strain world production capabilities.
1/ 62 percent of the 0 to 6000 pound gross vehicle weight light.duty
trucks used catalysts in 1975 and no 6000-8500 pound gross vehicle
weight trucks used catalysts.
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-74-
Commitments of other resources such as steel, aluminum, etc.,
are so small as to be over-shadowed fay normal market fluctuations.
There is the potential that the 1979 standards could.result
in an increase in gasoline consumption in comparison to uncontrolled
light duty trucks. However, fuel economy relative to an uncontrolled
light duty truck, is not expected to decrease if manufacturers esrploy
catalyst technology as is expected. As such, no increase in gasoline
consumption is forecast.
3. Relationship of Short-Term Uses of the Environment and
Maintenance and SnhanceTTjertt of Ion,'terra Productivity
Regulation of light duty truck emissions results in a substantial
decrease in hydrocarbon, carbon monoxide and oxides of nitrogen emissions
from this source. This reduction will be beneficial and aid in the long-
term attainment and maintenance of acceptable air quality levels.
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-75-
Chapter VI
ALTERNATIVE ACTIONS
A. Identification- of the Alternative Actions
EPA's procedures for the voluntary preparation of Environmental
Impact Statements state that EPA will "...[d]escribe and objectively
weigh reasonable alternatives to the proposed action, to the extent such
alternatives are permitted by law." 1/ In determining which alternatives
are reasonable, EPA has traditionally examined such factors as magnitude
of emission reductions, economic considerations, expected adverse impacts
and irreversible commitment of resources. Only when all these factors
have been balanced can an effective, non-disruptive strategy for the
control of emissions be selected.
The final regulations for the control of emissions from light duty
trucks achieves this balance, in that it will result in a nationwide
reduction in HC, CO and NOx emissions at reasonable cost and with
negligible adverse impacts- A wide range of possible alternative
actions exist to achieve similar reductions in emissions, with varying
costs and varying adverse impacts. This wide range of possible alter-
natives includes emission control strategies for the.many different
types of stationary sources (i.e., power plants and industrial sources),
emission control strategies for other mobile sources, limitations on
growth or use of emission sources, and of course different strategies
for the control of light duty trucks.
Tj 39 FR 37419, October 21, 1974, section 3(c)(2).
-------
-76-
The two categories o£ man-made sources of EC, CO and NOx pollution
are stationary sources and mobile sources. In 1972,. the stationary
source contribution to nationwide emissions of EC and NOx was roughly
equal to the mobile source contribution (see Chapter III, Tables III-A,
III-B and III-C), but mobile sources accounted for almost all the CO
emissions in.areas encountering violations of the National Ambient Air
Quality Standards (NAAQS). Thus it could be concluded that HC and NOx
emission control strategies, on balance, should be apportioned, equally
among stationary and mobile sources, and that CO emission control should
bs boms almost exclusively by mobile sources. In practice however, and
due to the statutory framework of the Clean Air Act, emission reductions
for significant mobile sources have been accoEplished much more quickly
than, those for stationary sources.
In comparing any mobile or stationary source emission control
strategy as a reasonable alternative to this regulation, consideration
must be given to the purpose for the control of emissions from both
mobile and stationary sources. The Clean. Air Act as amended June 1974
requires that NAAQS be met in all regions of the nation by 1977. This
goal, while unlikely to be achieved by a number of urban areas of the
country in 1977 2/, requires large reductions in the emissions of HC, CO
and NOx. To be able to substitute one emission control strategy tor
another implies that the goal of meeting the NAAQS can'be achieved by
2/ Announcement of the Administrator of the EPA, May 30, 1975-
-------
-77-
the majority of the nation by implementing a few of the available
strategies. For example, if a goal is to move people from one city to
another, i.e., commuters from Washington to Baltimore, and there exist
three possible means of meeting that goal, then the three means are
reasonable alternatives. If however, the three means fails to meet the
goal, either individually or in combination, the three cannot be consi-
dered as alternatives. Consider the following:
Alternative A can move 22% of the required people.
Alternative B can move 36% of the required people.
Alternative C can move 18% of the required people.
Implementing all three "alternatives" results in moving only 76%
of the required amount of people between Washington and Baltimore. Thus
the three "alternatives" are not in actuality alternatives since even
if all three were implemented the goal would not be attained.
Much the same situation exists for the case of reducing nationwide
emissions of HC, CO and NOx in order to meet the NAAQS. Calculations
performed for a long-range Federal government planning effort 3j indicate
the need for substantial emissions reductions in large areas of the
nation. The following chart, based on measured air quality data for
1971 through 1973, represents the emission reductions needed to meet
NAAQS from sources which existed during the 1971-1973 time period. When
growth is considered, the needed degree of control is increased (i..ev,
more control than is indicated by the chart is needed today simply due
to growth in the number of both mobile and stationary sources).
37 Panel Report on Air Quality, Noise and Health, Interagency Task
Force on Mobile Vehicle Goals Beyond 1980, March 1976.
-------
-78-
Nuaber of AQCRS
Where Required Control
Pollutant Exceeds 50 Percent
Maximum
Control
Reauired
CO
20
82%
Ox
22
88%
NO2
00
32%
The same long-range planning study examined all available mobile
and stationary source emission control strategies, both as to their
cost and emission reduction potential. Tables VI-A and VI-B (from that
study) are presented and allow an examination of all currently available
emission reduction strategies with a view towards selecting the most
cost-effective approach to achieve any total amount of emission reduc-
tion. Because CO is almost entirely a mobile source-related pollutantt
stationary source controls were considered as alternatives only for the
control of NOx and EC (which is a precursor to oxidant formation).
It can be seen from Table VI-A that there is an extensive range
of sources and control strategies for TLC emissions. Recalling, however,
that reductions totaling.more than 88% are needed if all areas in the
nation are. to achieve the NAAQS, and that there are 22 AjQCRs where the
degree of hydrocarbon control required exceeds 50%, it can be seen from
Table VI-A that, emissions reductions totaling only 54% are currently
identified as being available. Thus there will continue to be. areas of
the nation which are unable to meet the NAAQS for oxidants in the
future, even with all stationary and mobile source controls imple-
mented. To forego one emission control strategy in favor of imple-
menting another would therefore be a dereliction of EPA's statutory
mandate to assure that NAAQS are met.
-------
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A different situation exists for controlling NOx. The first four
and perhaps the fifth emission control strategy presented in Table VI-B
could be implemented to assure that all areas of the nation met the
NAAQS for N02- Unlike the case for HC, there appear to be adequate
means for meeting the NO2 standard and thus what becomes important is
to examine the merits of individual NOx emission control strategies to
assure that the NAAQS for NO2 is met in the most efficient manner.
Table VI-B also presents cost-effectiveness data for the various mobile
and stationary source emission control strategies. Recalling from
Chapter IV that the cost-effectiveness for NOx emission control for this
regulation is $73 per ton of NOx, it can be seen that this regulation
ranks with the most cost-effective emission control strategies (both
mobile and stationary source) identified as available by the Agency.
Thus the Agency finds no reason to further examine alternative
mobile or stationary source emission control strategies in its examina-
tion of reasonable alternatives to this regulation. For HC emission
control strategies, there do not appear to be an adequate number of
individual alternative control strategies sufficient to achieve the
NAAQS for oxidants in substantial, portions of the country. For this
reason all reasonable HC emission control strategies are planned to.be
implemented. For CO, which is almost entirely a mobile source-related
pollutant, comparison of the relative merits of several mobile source
emission control strategies made in Chapter IV shows that this regula-
tion is cost-effective in relation to other available mobile source CO
-------
-80-
emission reduction strategies. Finally, there has been no further
consideration of alternative NOx emission reduction strategies, since
this regulation is as cost-effective as a wide range of mobile and
stationary source NOx emission reduction strategies.
In addition to considering control of other mobile and stationary
sources of HC, CO and NOx emissions, two alternative strategies in
addition to the one selected were considered. These alternatives arie:
-Take no action to reduce light duty truck emissions.
-Implement alternative emission standards for light
duty trucks.
-------
Table Vl-A
AVAILABLE HC EMISSION CONTROL STRATECIES
Control Strategy
(Zcontrol before strategy-% control
HC Removed
CunjJacive %
Cost-Effectiveness
Annual Coat
Cumulative
after strategy)
(millions of tons)
Percentage of Baseline
of iiasollne
($/ton)
(million of $)
(millions
Degreasing 0-40
0.30
1.1
1.1
-210
-61
-61
Cravurc 0-98
0.22
0.8
1.9
-50
-11
-72
Cas Terminal 0-67
0.91
3.4
5.2
0
0
-72
Acrylonitrile 0-35
0.10
.5
5.5
0
0
-72
Polyethylene 0-95
0.19
.7
6.2
0
0
-72
Charocoal 0-99
0.34
1.2
7.4
0
0
-72
Miscellaneous Chemicals 0-35
0.60
2.2
9.6
.0
0
-72
Dry Cleaning 0-80
0.48
1.7
1.3
10
5
-67
Industrial Finishing 0-75
1. U2
6.3
7.8
10
18
-49
Carbon lilack 0-95
0.14
.5
8.3
10
1
-48
Formaldehyde 0-95
0.06
.2
(3.5
1.0
1
-47
Refining 0-67
1.53
5.7
4.0
13
20
-27
Arch. Coatings 0-100
1.00
3.7
7.6
15
15
-12
GHDV Evap. 5.8 - 0.5 gni/iai
0.58
2.1
9.7
18
10
- 2
Open Burning 0-25
0.30
1.1
0.8
20
6
4
Ethylene Oxide 0-95
0.44
1.6
2.4
20
9
13
Acrylonitrile 36-99
0.17
0.6
3.0
37
6
19
Ethylene Dichloride 0-95
0.16
0.6
3.6
40
6
25
Paint 6 Varnish 0-70
0.09
0.3
3.9
50
5
30
Degreasing 41-90
0.36
1.3
5.2
85
31
61
Industrial Finishing 76-97
0.55
2.0
7.2
100
55
116
Gasoline Handling 16-50
0.57
2.0
9.2
100
57
173
Cyclohexanone 0-95
0.19
0.7
9.9
120
23
196
Ketal Decorating 0-90
0.14
0.5
0.4
150
20
216
**** Proposed Action 0-38
0.94
3.5
* * A
200
188
***
Miscellaneous Chemicals 35-53
0.30
1.1
1.5
200
60
276
Gasoline Distribution 67-99
0.43
1.5
3.0
270
115
391
Coke Ovens 0-80
0.24
.9
3.9
435
105
496
LDV Exhaust 0.9 - 0.41 gn/ni
0.93
3.5
7.2.
4 70
440
936
LDT & CHDV Exhaust 2.9 - 0.8 gm/nl
0.84
3.1
0.2
470
395
1330
Foundries 0-60
0.15
0.5
D. 7
500
75
1410
Letterpress & Lithography 0-90
0.27
1.0
1.7
700
190
1600
Cas Handling 51-91
0.68
2.5
;.i
7 00
475
2.080
SOURCE: Ai'r Quality, Noise and Health, Interagency Task Force on Motor Vehicle
Coals Beyond 1980, March 1.976.
**** Not in original, added for illustrative purposes.
-------
Table VI-B
AVAILABLE NOx EMISSION CONTROL STRATEGICS
Control Strategy
(Z control before strategy-% control
control after strategy)
**** Proposed Action
From 0% to 41X
Control
NOx Removed
(tr.illion of tons)
0.58
Percentage of Cumulative. 7. Cost-Effectiveness Annual Cost Cumulative
Baseline of Baseline ($/ton) (billion $) (billion $)
73
0.042
Ncvr Utility Boilers
Froo 257. to 50Z
Control
3.-52
11
11
100
0.35
0.35
Industrial Boilers
From 252 to 65%
Control
2.46
18
150
0,37
0.72
Exist. Util. Boilers
Froa 25X to 50%
Control
0.62
20
225
0.14
0.86
Sta. IC Engines
Fruui 252 to 75Z
Control
Other Mobile
Froa 10 j;c;/ioile
to 80% Control
2.87
2.9
29
38
340
450
0.98
1.3
1.84
3.14
l.DV From 2.0 to
1.0 gm/mile
Util. Bollera From
50% to OOZ Control
1.91
6. 62
20
44
64
450
1200
U. 06
7.94
4.0
11.94
Stav IC Engines
From 75Z to 90X
Control*
0.86
67
Z7GQ
1.46
3.43
LDV to 0.4 gm/mile
1.15
* STA IC ENG Control Does Not Include Snail Knair.es
SOURCE: Air quality, Koiec and Health, Interagency Task Force on Motor Vehicle
Coals Beyond 1980, March 1976.
70
2300
2.65
16.08
**** Not in original, added for illustrative purposes.
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-83-
B. Analysis of Impacts of the Alternatives to this Regulation
Economic impacts of the alternatives to this regulation are
summarized in this chapter, and are more fully described in "Economic
Assessment of the 1979 Light Duty Truck Emission Standards," Office
of Mobile Source Air Pollution Control, EPA.
1. Take No Further Action to Reduce Light Duty Truck Emissions
Total light duty truck emissions, if no further control is
imposed, are expected to increase between now and 1990 to the extent
that they comprise over 14 percent of the total mobile source emissions.
Between now and 1990 emissions of other sources will be significantly
curtailed as attainment of acceptable air quality is pursued, and the
importance of light duty truck emissions in finally achieving the air
quality standards will be increasingly evident. A large number of
the regions presently exceeding the air quality standards for oxidants,
carbon monoxide and nitrogen dioxide will continue to have difficulties
in achieving or maintaining these standards in the 1980's. Emissions
from light duty trucks will add to this burden.
Under the alternative of taking no action, costs to the
industry and the consumer would appear to be less than those incurred
under this regulation. As indicated in Chapter IV, the aggregate
costs to the consumer and to the industry are expected to reach 830
million dollars for the five year period 1979 to 1983. These costs,
would not be incurred by the public directly should no further action
be taken to reduce light duty truck emissions. Since additional
reductions in emissions from mobile sources are necessary to meet
and maintain ambient air quality standards.in many regions 4/, costs
4/ See Chapter III, Section A.
-------
-84-
would be Incurred by the public for those additional reductions in
emissions when obtained from emission sources other than light duty
trucks. As shown in Table IV-4, the costs per pound of pollutant
removed from the ambient air. for several selected mobile sources are
all higher than those costs for light duty trucks (with the exception
of the planned 1979 Federal interim heavy duty vehicle emission standards).
This indicates that obtaining equal reductions in emissions from other
sources would be more costly to the consumer than obtaining, those
reductions from light duty trucks.
2* Implement Alternative Emission Standards .for Light Duty Trucks
Several alternative emission levels were considered by EPA in
the context of selecting the emission levels that were proposed 5/.
These alternative emission levels included emission standards of equi-
valent stringency to the 1975 California interim light duty vehicle
standards (0.9 g/m HC, 9.0 g/m CO, 2.0 g/m NOx), and emission levels
based on a sliding scale according to vehicle weight. Alternatives
for the light duty class boundary (e.g., up to 8500 pounds GVWR) were
not examined as to their environmental, economic and social impacts,
but were rejected on technical bases. Discussion of these alternatives
considered by EPA in its selection of the proposed action can be
obtained by consulting the Draft Environmental Impact Statement for
this regulation, dated February 12, 1976.
Although the analysis of the alternative emission levels
for light duty trucks presented in the Draft EIS will not be reprinted
here, two different alternative regulatory approaches that have been
suggested during the public comment period on the proposed regulation
5/ 41 FR 6279, February 12, 1976.
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-85-
will be examined. Those alternatives, suggested by Chrysler Corporation,
Ford Motor Company and the Council on Wage and Price Stability are
described in Table VI-C and are examined below.
a. Alternative I - Impose More Stringent Standards, But Do
Not Change the Light Duty Truck Class Definition
b. Alternative II ~ Impose More Stringent Standards, and Change
the Definition to Include Trucks up to 7000 Pounds GVWR
EPA has proposed to implement in model year 1979 more stringent
emission standards for heavy duty engines 6/, which are currently used
in trucks greater than 6000 pounds GWR. It has been argued that
including the 6000 to 8500 pound GWR trucks in the light duty truck
class Is urui.5.c£ssary, since in model yzzr 1979 these trucks will be
subjected to EPA's more stringent heavy duty engine emission standards.
Commenters further claimed that since the cost-effectiveness of the
proposed heavy duty engine emission control strategy is greater than
for this regulation (i.e., fewer dollars per ton of pollution controlled),
it would appear to be a more cost-effective strategy overall to leave
the 6000 to 8500 pound GVWR trucks in the heavy duty engine class
and to impose more stringent heavy duty engine emission standards
on those trucks 7/.
Alternative II has been suggested by Ford and Chrysler as a
means of minimizing the adverse impacts perceived by those compaines
due to enlarging the light duty truck class to 8500 pounds GVWR. Ford
and Chrysler contend that the number of individual.truck configurations 8/,
Tj 41 FR 21292,. May 24, 1976.
7/ See, e.g., Council on Wage and Price Stability, April 12, 1976,
page 20.
8/ A vehicle configuration is a specific combination of vehicle
weight, engine transmission, axle ratio and tire. size.
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each requiring a different amission control system calibration, increase
dramatically for trucks above 7000 pounds GVWR. This proliferation of
truck, configurations in the weight range 7000 to 8500 pounds GVWR occurs
because more trucks in this range are special order trucks, built at
the request of the truck buyer to satisfy his individual needs.
Ford and Chrysler also contend that above 7000 pounds GVWR,
trucks begin to take on truly heavy duty characteristics, such as
components of greater weight and durability than passenger car components,
rougher ride, and slower acceleration capabilities.
Cost-effectiveness data for the proposed heavy duty engine
.emission control regulation were developed by considering the amount
of emission control achieved by, and the cost for such control, for a
"typical" heavy duty truck. "Typical" in this instance is a heavy
duty vehicle with the following characteristics 9/:
Gasoline-Fueled
24,000 pounds GVWR
16,000 miles per year
10 year life
4.6 mpg
Diesel
55,000 pounds GVWR
43,600 miles per year
10 year life
4.6 mpg
It is not appropriate to conclude that costs for control of 6000
to 8500 pound GVWR trucks under the 1979 heavy duty engine, emission
standards would be the same as the costs to control a "typical" heavy
duty truck as described above. Further, the predicted emission
reductions for a "typical" heavy duty truck when subjected to the
1979 heavy duty engine emission control regulations can be expected
9/ Draft Environmental and Inflationary Impact Statement, Interim
Heavy Duty Engine Regulations for 1979 and Later Model Years,
EPA, April 21, 1976.
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to be different than, those which would be predicted for a 6000 to 8500
pound GVWR truck subjected to the same control strategy. This is the most
important distinction to be made when examining the merits of continuing
to classify 6000 to 8500 pound GVWR trucks as heavy duty vehicles.
The heavy duty engine emission test cycle is a steady-state cycle
which exercises an engine over a range of speeds and engine loads.
These different speed and load conditions (e.g., 2000 rpm and 75 percent
of rated power) were selected to be representative of the type of
operation that, heavy duty vehicles encounter ia-use. Emission results
obtained frcia each of the steady-state niedqs of operation on the test
cycle (13 for gasoline-fueled engines and 9 for Diesel engines) are
weighted proportionately to approximate the amount of time each of the
engine types experience in that steady-state condition in-use. The
results of these heavy duty engine testing cycles and the subsequent
weighting of the test values to obtain one emission level allow EPA to
predict the actual in-use emission rates for heavy duty vehicles. This
technique of predicting in-use vehicle emission rates based on the
results of an engine test cycle is a valid technique for heavy duty
vehicles since the engine test cycle has been designed to model the
types of operation that the vehicle typically experiences in actual
use on the road. Further changes to the heavy duty vehicle emission
measurement procedures are being investigated by EPA in connection
with its long term heavy duty vehicle program.
Because the usage pattern that a vehicle experiences influences
its actual on-the-road emissions, the vehicle must be tested on a
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cycle that adequately represents those usage patterns. EPA has
determined (see Chapter II of this statement) that the actual usage
patterns of light duty trucks up to 8500 pounds GVWR, when operated
in urban environments, closely approximate those of passenger cars.
This characteristic of light duty truck operation, personal transpor-
tation, is highly transient in nature. Personal usage in urban areas
is characterized by stop and go operation, or by the type of operation
experienced, by the typical commuter. Steady state testing, as is per-
formed in EPA's heavy duty engine test procedure, is incapable of
accurately modeling this transient operation. Analysis performed 10/
of data obtained for EPA indicates that transient operation cannot be
adequately simulated by the heavy duty engine steady-state test procedure,
or by any modification of that steady-state procedure for the purpose
of assessing the emissions from vehicles. Thus, to accurately assess
the in-use emission performance of vehicles that are typically operated
on transient cycles, the heavy duty engine test procedure cannot be
used.
The light duty vehicle and truck test cycle, however,.does
adequately assess the in-use vehicle emission performance of cars and
light duty trucks, since that test cycle is a simulation of an urban
communter-type trip. The light duty cycle contains transient operation,
which exercises the vehicle over a range of accelerations and decelera-
tions. Since light duty trucks up to 8500 pounds GVWR are operated a
substantial portion of the time as personal use transportation vehicles,
use of the light duty test cycle is appropriate for these vehicles.
10/ Transient vs. Steady-State Test Procedures for Measuring Emissions
of Heavy Duty Diesel Trucks, Internal EPA Memorandum, September 28,
1976, and Prediction of Heavy Duty Gasoline Trucks' Transient Emissions
from Steady-State or Sinusoidal Test Procedures, Internal EPA Memoran-
dum, October 13, 1976.
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-89-
A further consideration in examining whether 6000 to 8500
pound GVWR trucks should be regulated by EPA as light duty trucks
or as heavy duty trucks involves the cost of each regulatory approach.
Regulating those trucks as heavy duty vehicles involves, less
cost, since the heavy duty procedure is an engine test procedure.
This means that one engine can be designed and tested to demonstrate
conformity with Federal emission standards, and then be used by the
truck industry in a wide variety of trucks. To require that these
6000 to 8500 pound GTOR trucks be regulated as light duty trucks would
mean that each truck configuration (as opposed to each engine) would
have to be designed to meet emission standards. There are substan-
tially more truck configurations than engines.
Although a more costly approach, EPA has rejected the alternative
of leaving the 6000 to 8500 pound GVWR trucks in the heavy duty class.
The approach taken by EPA, that of requiring that 6000 to 8500 pound
GVWR trucks be included in the light duty truck class, was selected
because of the increased emission reductions available from this class
of vehicles when tested under the light duty test cycle. Even
though this approach is more costly than either of the alternatives
discussed above, the Agency has determined that the emission reduc-
tions to be realized by this regulation are both necessary and
cost-effective in comparison with a wide range of other mobile and
stationary source emission control strategies.
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-90-
Table 71-G
ALTERATIVE LIGHT DUTY TRUCK.
EMISSION REGULATIONS
Base Case - So further control is imposed; the light
duty truck class continues to be subject
to the current standards of 2.0 g/m EC,
20 g/m CO and 3.1 g/m NOx. The light
duty truck class definition is unchanged
at 0 to 6000 pounds GVWR, and the 60C0
to 3500 pound GVTvR vehicles continue
to he regulated as heavy duty vehicles.
Final Regulations - Light duty tracks are controlled "beginning
in model year 1979 to emission level3 of
1.7 g/m HC, 18 g/m CO and 2.3 g/m. }30x.
The light duty truck class is enlarged
to include all trucks up to 8500 pounds
GTOR and 6000 pounds curb weight..
Alternative I - Light duty trucks are controlled
beginning in model year 1979 to emission
levels of 1.7 g/m HC, 18 g/m CO and
2.3 g/m NOx. The light duty truck
class definition is unchanged at 0 to
6000 pounds GTOR. Trucks 6000 to 8500
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Table VI-c (cont'd) ....2.
-91-
pounds GVWR are regulated as heavy duty
vehicles, and are subjected in. model year
1979 to emission standards of 1.5 g/BHP-hr
HC, 25 g/BHP-hr CO and 10 g/BEP-hr HC + NOs.*
Alternative II - light Duty trucks are controlled beginning
in nodel year 1979 to emission levels of
1.7 g/m KG,- 18 g/m CO and 2.3 g/n HOx.
The light duty truck class is enlarged
to include all trucks up to 7000 pounds
CtTrtR and 6000 pounds curt weight,.
* As has been proposed for trucks greater than 8500 pounds GVWR, 41 FR 21292,
May 24, 1976.
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-9 2-
Chapter VII
PROBLEMS AND OBJECTIONS RAISED BY FEDERAL, STATE AND
LOCAL AGENCIES, AND BY THE PUBLIC
A. Introduction
This chapter summarizes the comments received in response to the
Notice of Proposed Rulemaking and the Draft Environmental Impact
Statement. The summarized comments, and EPA's disposition of those
comments are grouped according to the basic issues raised by the
commenters..
A complete summary and analysis of comments is not included with
this final EIS due to the volume of comments received. Single copies
of that document, "Summary and Analysis of Comments to the NPRM,"
are available in the Public Information Center, PM-215, U,S. Environmental
Protection Agency, 401 M Street, S.W., Washington, D.C. 20460.
B. List of Commenters
1.
American Farm Bureau Federation
2.
American Motors Corporation
3.
Kenneth A. Burkhclder
4.
Chrysler Corporation
5.
The Council on Wage and Price Stability
6.
Department of Defense
7.
Department of Transportation
8.
Energy Research and Development Administration
9.
Ford Motor Company
10.
General Motors Corporation
11.
International Harvester Company
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-93-
12. Motor Vehicle Manufacturers Association
13. Perkins Engines
14. State of New York, Department of Environmental Conservation
15. Volkswagen of America, Inc.
C. Summary
1. Lead Time - The vehicle manufacturers have indicated that they
cannot achieve compliance with the proposed regulations in 1978. EPA's
analysis supports this argument and results in a'recommendation to delay
implementation until the 1979 model year.
2. Fuel Economy - Most manufacturers have claimed that a fuel
economy penalty will be incurred as a result of the proposed action.
EPA's subsequent analysis of the additional data presented by the
commenters reaffirms that there need not be a fuel penalty as a result
of the proposed regulations.
3- Cost - A wide range of cost data inputs were received from the
manufacturers. Analysis of these data has lead to minor revisions in
EPA's original estimate. The estimated cost for 0 to 6000 pound GVT7R
vehicles is now $8 per vehicle and the estimated cost for 6000 to 8500
pound GVWR vehicles has been increased slightly to $219 per vehicle
(including $15 for evaporative emission control equipment).
4. Stingency of Standards - Some manufacturers claimed that the
standards were more stringent than the 1977 LDV standards because of the
added payload and higher road load proposals. The higher payload re-
quirements were reassessed and it has been recommended that they be
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-94-
deleted (see issue #7). In addition, the analysis of the latest road
load horsepower data has lead to a reduced road load horsepower, require-
ment (see issue #9). The net effect of these revisions has been to
assure that the proposed standards are not more stringent than the
1977 LDV standards. No change in the proposed standards has been
recommended.
5. Class Definition - Comments were divided over the issue of an
appropriate class definition with some support for the EPA proposal and
some alternative suggestions ranging from no change to the current LDT
(6000 pounds GVWR) class definition to enlarging the IDV class to include
vehicles up to 10,000 pounds GVWR.- Some manufacturers argued chat
vehicle design parameters should be the basis for distinguishing light
duty trucks from heavy duty vehicles. The EPA position has been that the
primary use of vehicles should govern their classification for emission
testing purposes, and the majority of trucks under 8500 pounds GVWR are
used primarily for personal transportation. Only those design features
which would largely preclude personal transportation have been selected
as criteria for allowing heavy duty certification. To this end EPA has
accepted the contention that delivery vans which can carry only property,
and are.characterized by much larger frontal areas than pickup trucks and
conventional vans, are properly regulated as heavy duty.
The recommendation is to exclude vehicles with frontal areas of
greater than 46 square feet. The other aspects of the class definition,
i.e., 6000 pound curb weight and 8500 pound GVWR (optional to 10,000
pound GVWR.) should remain unchanged from the NPRM. The 10,000 pound GWR
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-9-5-
option remains to allow for common certification of a manufacturers
product line which may extend beyond the 8500 pound GVWR limit.
6. Incomplete Vehicles - Several manufacturers have argued that
incomplete vehicles are generally finished as commercial or recreational
use vehicles whose final configurations would meet the criteria for
inclusion in the heavy duty vehicle class. They have further argued that
the proposed procedure for certifying Incomplete vehicles is overly
restrictive. EPA has partially concurred with these arguments.
The recommendation is to allow the primary manufacturer to classify
incomplete trucks either as LDTs or as HBVs based on their intended
completed vehicle configuration. The maximum curb weight and frontal
area which the manufacturer intends to allow as a certified configuration
would be attached to the vehicle in the form of a label for all LDTs.
Incomplete HDVs under 8500 pounds GVWR would be labeled with a minimum
curb weight of 6000 lbs. or a minimum frontal area of 46 square feet..
Subsequent manufacturers completing these vehicles would be responsible
for purchasing and completing vehicles in a certified configuration.
7. Payload - The NPRM proposed that a 500 pound simulated payload
be substituted for the 300 pound payload in the existing regulation.
Comments received were largely negative and indicated that the use of
the higher payload was inconsistent with the personal use concept which
is the basis for the revised class definition. EPA concurs, and
therefore It Is recommended that the 300 pound payload be retained.
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-96-
8. Baseline Emissions of Trucks in the 6000 to 8500 Pound
GVWR Range - American Motors and General Motors have claimed
lower current baseline emissions than reported by EPA, and thus, argue
that EPA has overstated the benefits of the proposed action. On the
other hand, Chrysler has reported a baseline higher, than EPA's. Further
analysis of the original baseline data by EPA has lead to a reduction in
the calculated baseline emissions, but not to the extent suggested by
AMC and GM. The baseline has been decreased from, 5.5 grams per mile
for HC, 58 grams per mile for CO, and 6.3 grams per mile for NOx to 4.3
grams per mile, 44 grams per mile, and 5.2 grams per mile HC, CO and
NOx, respectively. This revised baseline has been used in computing
rr : CC~C C, cI'V* OnHVo1"! w 2.-L 2JHU2C r i^.3. •
9. Road Load Horsepower - The NPRM proposed values of road load
horsepower substantially higher than the existing requirements. Manu-
facturers submitted data indicating these values were too high aind EPA
collected additional data confirming that contention. A new table of
road load power requirements has been developed. These power settings,
although lower than those proposed, are higher than the current regulation
requires and will result in a more accurate measurementof emissions and
fuel economy from LDTs.
10. Cost Effectiveness - The Council on Wage and Price Stability
(CWPS) has requested expansion of the cost effectiveness analysis in the
regulatory support documentation so as to evaluate separately the actions
of expanding the LDT class and then reducing the standards. Both COTS
and General Motors have argued that an evaluation of the alternative of leaving
-------
the 6000 to 8500 pound GVTvR vehicles in the KDV class under the proposed
interim 1979 HDV standards is necessary. The cost effectiveness analysis
has been revised to respond to these comments.
11. Optional Equipment Listing - This list of equipment would
have provided data on options affecting frontal area of the vehicle
which in turn can influence the road load and subsequently emissions and
fuel economy. However, the requirement as stated in the IIPRH was too general
and would have required manufacturers to report a myriad of options that would
not affect the road load power. Therefore the recommendation has been
made to delete the proposed optional equipment listing requirement, and
to "C£T>lacG it with a r6ouzrsnent to cs. 1 cu 12.t^ v^h-icls frontal 2.T-3. by
including the frontal area cf optional equipment that is scld or. acre than
33% of a given model line.
12. Disadvantages of Catalysts - Three basic disadvantages of
catalysts were claimed by several commenters. These were: (1). fire
danger; (2) unavailability of unleaded fuel in rural areas; and (3)
sulfate emissions. EPA has concluded on the basis of recent studies
that the fire danger from catalyst-equipped vehicles is. no greater
than that from existing non-catalyst vehicles already in widespread
use in rural areas. EPA has also concluded chat adequate amount's of
unleaded fuel will be available in all areas of the country by 1979
as a result of increasing numbers of light duty vehicles requiring its
use. Finally, the Administrator has decided not to propose standards
for sulfate emissions control at this tine. If in the future it is
determinedthat sulfate emissions from catalyst vehicles represent a
significant hazard then an independent action will be taken.
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-9 8-
13. Engine Calibrations - It has been argued that the expanded
class definition will greatly expand the number of engine calibrations
required for those vehicles previously certified as HDV. EPA has
agreed that numbers of calibrations will increase and has recognized
this as an additional cost of the action.
14. Four Wheel Drive - In response to comments from American
Motors, the recommendation is made to include specific procedures for
the certification testing of four wheel drive vehicles.
15. Consistency o£ California Regulations - Differences now exist:
between California and EPA proposed regulations in regard to aspects
of class definition and test procedure. It is recommended that such
differences be resolved as part of the California waiver proceedings.
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-99-
Appendix A
Selection of a Breakpoint Between LDTs and HDVs
A. Design Characteristics:
Examination of the physical characteristics of all trucks
in the HDV class leads to the observation that the vehicles between
6000 and 10,000 pounds GVWR more closely resemble LDTs than HDVs.
MVMA sales data (See Chapter II) show that about 60% of all HDVs lie
within the 6000 to 10,000 pound GVWR range. Based on 1973 sales, this
represents 761,000 vehicles. (For purposes of comparison, roughly
1.7 million LDTs were sold in 1973.) Nearly 85% of the 6000 to 10,000
pound GVWR vehicles are pickup trucks, vans, ana station wagons built
on a truck chassis. These vehicles differ from their LDT counterparts
only in having slightly higher capacity chassis components, including
tires, suspension systems, frames and brakes. All of the vehicles in
the 5000 to 10,000 pound GVWR range use the same engines as LDTs, differing
-only j-it oiu 133icTi contiiroi. tn£S.3uXGS Sucl* s.s c3.bur6tor and cijLSuiTj-DviuOjr
calibrations, and in some cases, lack of "add-on" emission controls
(EGR., air pumps, evaporative emission controls) . JL/
The 10,000 to 16,000 pound GVWR range represents a transition
range where significant changes in vehicle design occur. Less than 2%
of all vehicles in thecurrent HDV class fall within this range. Approxi-
mately 90 to 95% of the vehicles in the 10,000 to 14,000 pound GVWR
range are motor homes built by over 100 manufacturers on bare chassis,
sold by the four major light truck manufacturers. The vast majority of
these are built on Dodge chassis. According to 1973 MVMA sales data,
over 39,999 of the 44,000 vehicles sold within the 10,000 to 14,000
pound GVWR range were motor homes on Dodge chassis. Some of the vehicles
in the 14,000 to 16,000 pound GVWR range are also motor homes, but in general,
the vehicles in this range (6300 in 1973 according to MVMA) appear to
be working type vehicles with engines and chassis more like heavier
vehicles than LDTs.
B. Usage Characteristics:
Since the physical characteristics of 'trucks are basically
similar up to about 10,000 pounds GVWR, a decision on a breakpoint is
largely dependent upon usage data. The most appropriate GVWR outpoint
would be one which maximally separates those truck types which are
basically used for personal transportation from those truck types which
basically have commercial applications. The 1972 Department of Commerce
Truck and Bus Survey data 2/ and the 1973 Department of Transportation
Weigh.Station Survey data 3/ were used to investigate the usage character-
istics of vehicle models by GVWR.. The histogram in Figure 1 summarizes
the responses of truck owners who were asked to specify the primary
usage application for their vehicle. The histogram shows the percent of
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-100-
vehicles used primarily for personal usage as a function of GVW. In
determining trends of personal usage with GVWR, special attention should
be given to the 5000, 6000, 8000, 10,000 and 16,000-26,000 pound GVWR
points since most of the truck sample is concentrated at these points.
(The sample was selected to represent the distribution of trucks in the
field.) With this in mind., the percent of personal usage vehicles tends
to remain stable at about 50% through 8000 pounds GVWR, remain stable at
about 2% for 16,000-26,000 pound vehicles, and be in transition between
8000 and 16,000 pounds GVWR. These data support a lower GVWR limit of
8000 pounds.
Figure 2 expands the lower GVW range of Figure 1 examining the
percent of vehicles used primarily for personal transportation by
vehicle type: pickups, panels and vans, multistops. Within each of
these body styles, the percentage of personal usage is fairly constant
with GVWR although it should be noted that the percent of. 10,000 pound
GVWR pickups used primarily for personal usage is significantly less
than the percent of under 10,000 pound GVWR pickups used primarily for
personal usage. Averaged over all GVWR ranges, these data indicate that
53.5 percent o£ pickup trucks are used primarily for personal usage,
23.6 percent of panels and vans are used for personal usage, and only
6.3 percent of nultistop vehicles are used for.personal usage. Usage
data on cab chassis are not available, but it can be reasonably
assumed that these vehicles are basically non-personal usage vehicles,
since incomplete vehicles are typically finished with cargo carrying
bodies or permanent motor home equipment. Therefore an analysis of
Figure 2 indicates that not only do pickups account for the largest
percentage of trucks under 14 ,-000 pounds GVWR, but they are the vehicles
which are used, to.a very large extent, for personal transportation.
C. Sales Distribution:
A selection of the specific cutpoint requires an examination
of the sales distribution of vehicles by body type and GVWR. Figures
3 and 4 present 1973 sales data from Ford and Chevrolet respectively.
(Chrysler has informally indicated that their vehicles are distributed
similary to their competitors.) Examination of the Ford data indicates
that a cutpoint at 8500 pounds GVWR maximizes the overall percentage of
pickups included in the IDT class. A cutpoint below 8500 pounds GVWR
would omit a significant number of pickups. The range between 8500
and 9500 pounds GVWR is not heavily populated. Within, this range, the
Chevrolet and Ford data indicate that the number of cab chassis and
multistop vehicles are about equal to the number of pickups.
D. Cutpoint Selection
All trucks up to about 10,000 pounds GVWR have similar design
characteristics. Functional usage data indicate that the majority of
trucks below a lower limit of 8000 pounds GVWR are used primarily for
personal transportation. In terms of body styles, pickups dominate the
GVWR range up to 10,000 pounds GVWR and are consistently used primarily
-------
for personal transportation, while multistop vehicles are used to a much
lesser extent for personal transportation. Therefore, the cutpoint
desired is the one which maximizes the number of pickup trucks, minimizes
the number of multistop trucks and cab chassis, does not exceed 95C0
¦pounds GVWR, and if possible, is greater- than 8000 pounds GVWR. Consider!
sales distribution to achieve this objective, 8500 pounds appears, as the
optimum minimum cutpoint. Selection of an 8500 pound GVWR cutpoint
would expand the present LDT class from approximately 1.8 mil lion
vehicles per model year to approximately 2.5 million vehicles per model
year (based on 1973 MVMA sales figures).
There is no one breakpoint that can be established to separata
LBTs from HDVs which will completely eliminate cross-over or potential
cross-over of vehicle body styles and vehicle usage. Cases where some
models straddle the 8500 pound cutpoint will still exist. Therefore, it
is proposed that the cutpoint be defined as shown in Figure 6* All
vehicles with GVWR at or below 8500 pounds must be certified with the
LDT test procedure. All vehicles at. or above 10,000 pounds GVWR must
be certified with the HDV test procedure. Manufacturers of vehicles
between 8500 and 10,GC0 pounds GVWR can submit a request with their Part
certification app.i-.LCs.trL.cns stating which certi.m-ca.ticn procedure they
wish to apply. This arrangement will allow vehicles in this "usage
overlap" GVWR range to be certified with the regulations which best
reflect their usage characteristics and will minimize the number of
vehicles which would be ciertified under two test procedures.
Figure 6
LDT Outpoints
IDT or HDV
LDT HDV
Certification Certification
7500 8000 8500 9000 9500 10000 10500 11.000
Gross Vehicle Weight Rating, pounds
Two incentives would exist for manufacturers to certify these
vehicles in the optional range by the HDV test procedure rather than
the LDV test procedure. The current HDV test procedure is an engine test
procedure and involves a smaller sample of engines than is the case
under LDT certification, since the range of chassis options does act
increase the sample size. In addition, the current HDV standards are not
of equivalent stringency-to the LDT standards for an equivalent vehicle.
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The relative thoroughness of the two test procedures and the relative
stringency of the two standards will be subject to modification: (1)
if interim HDV regulations are promulgated and/or (2) when the "final"
HDV test procedures and standards are promulgated. Therefore, since
these incentives are sore than likely short term, it would probably not
be cost effective for a manufacturer to redesign large groups of vehicles.
In addition, 95% of the under 10,000 pound GVWR trucks are currently
at or below 8500 pounds GVWR. Therefore, a relatively small percentage
of trucks fall into the optional category. There is little indication
that the percentage of trucks in this optional GVWR range will increase
in order to avoid LDT certification. Unless an entire model-line can be
pushed over the 8500 pound cutpoint, the result would be a two procedure
certification situation wich is not cost effective for a manufacturer,
especially considering the low model-line sales volumes in this GVWR
range. Major design changes would be required to move entire model
lines over the 8500 pound cutpoint. It is doubtful whether consumers
who are using LDTs primarily for personal transportation would be
willing to pay the additional costs which would occur as the result of
ridded weight. Thereforei it is more likely that when a model extends
from the LDT range into the optional range, the manufacturer will choose
to certify the entire model with the LDT procedure to avoid the costs
of dual certification. This viewpoint has been supported in informal
discussions with several manufacturers. On the other hand, efforts
to move the commercially used multistop or cab chassis vehicles over
the 8500 pound cutpoint (where the majority of them are currently
located) would essentially support the contention that those vehicles
should in fact be regulated as KDVs. This is also likely to happen .
based on informal discussions with manufacturers.
E. Alternative Cutpoints:
Previous attempts to define a cutpoint between LDTs and
HDVs have considered the following options:
1. The cutpoint defined at 14,000 pounds GVWR. The 14,000
pound limit represents the point of minimum cross-over for currently
produced vehicles and also represents the point of minimum cross-over
in the future if manufacturers choose to "beef-up" some vehicles to
get them out of a LDT class. However, a 14,000 pound cutpoint includes
a large porportion of all multistop vehicles and incomplete motor
home chassis as well as a large number of incomplete cab chassis.
These vehicles tend to be used strictly for commerical or recreational
purposes and are not expected to drive like the current LDTs within
the urban environment.
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-10 3-
2. The cutpoint defined at 10,000 pounds GVWR.. The 10,000
pound limit is used by the Department of Transportation to define light,
trucks, and it currently includes all standard pickups, vans, and station
wagons. However, this cutpoint splits the multistop vehicles and motor
homes and cab chassis production which increases markedly arcuna 10,000
pounds GVWR. Thus, these non-personal usage vehicles would have to
be. certified under both the light duty and heavy duty certification
programs. This results in increased cost to the manufacturer and the
EPA, The.10,000 pound cutpoint would result in a class which is mostly
composed of personal usage trucks with similar payload characteristics;
however, a small fraction of the class would have substantially different
usage and payload characteristics.
3. The cutpoint defined in terms of body styles. A body
style definition would define, a LDT class to include all pickups, vans
and station wagons. Other vehicles such as motor homes, multisnop
vehicles, stake trucks, box vans, and tow trucks would be excluded..
This approach is, however, virtually unworkable since, it is not possible
to clearly define some of the applicable body styles. For example,
« J .'££.* 1 4. J - _ a. ~ _—-~-t, c - -• r
o. .nOcui. lioiuc j_o ui. lcu u. J.A. j- to. _i» l. co uxoL-Luiuxoix j.iuiu a, ve.il. uvea -3--~ '.ucoc
body styles could be adequately defined based on current vehicle design,
it is not possible to predict future design.developments. As a result
of this problem, a body style definition has not been deterained reasonable
in this analysis nor has it been received well by the manufacturers.
Footnotes
1/ Technical Evaluation of Emission Control Approaches and
Economics of Emission Reduction Requirements for Vehicles
Between 6,000 and 14,000 pounds GVW, by Bogdan, Burke and Reif,
Calspan Corp., Nov. 1973, EPA-460/3-73-005.
2/ "Truck Inventory and Use Survey," 1972 Census of Transportation,
U.S. Department of Commerce, October, 1973.
3/ 1973 Truck Weigh Station Survey Data, U.S. Department of
Transportation, Federal Highway Administration.
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FIGURE 1
PERCENT OF TRUCKS USED FOR PERSONAL TRANSPORTATION AS A FUNCYION OF GROSS VEHICLE WEIGHT RATING
70
60
50
40
30
20
10
3 4
f-*
0
¦p-
1
10 U 12 13 14
Cross Vehicle
15 16 17 18 l<
Weight. Rating y L0'
20 21 22 23 24 25 26
Source:: 197 2 Ccnun;; of T m ii.ipor U-a c ion
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Figure 2
Percent of all Pickup, Panel Van, Multistop Truck? Used Cor Personal Transportation
as a Function of Registered Gro.«s Vehicle Weight
GVWK x 10?
Source: 1972 Census of Transportation
-------
10
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20
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30
0
Ford 1973 Truck Sale?
Vehicle Sale:: by GVTvR
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Figure 4
Chevrolet 1973 Truck Salts
(10, 20, 30 series)
Percent of Sales by CVIJR
Percent
of •*las
Plcfcsip & Clxnta Cab (C&K-101
Station Wa.-ona (C&K»10)
FVD Utility Vehicle'
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-------
-103-
Appendix I! - Light Duty Vehicle and Light Duty
Truck Emission Factors
Section I of this appendix presents Light duty vehicle
emission, factors in a format similar to that used in the
"Compilation of Air Pollutant Emission Factors," (AP-42). The
emission factors are preliminary factors derived from EPA's
annual program to examine the acutal in-use emission rates of
light duty vehicles and light duty trucks. These factors
have been compiled based on the latest test results from
that program and are currently, being.further screened within
the Agency for inclusion in a future edition of AP-42. The
factors assume that the emission standards for light duty
vehicles which, are currently mandated by the Clean Air Act
will be in effect (i.e^, 1978 model year standards of .41
grams per mile (gym) EC, 3.4 g/m CO and .4 g/m NOx).
Section II of this appendix contains light duty truck
emission factors, both for the case of taking no further action,
and for the case of imposing emission standards associated
with this regulation (i.e., 1979 model year standards of
1.7 g/m HC, 18 g/n CO and 2.3 g/m NOx). These emission
factors are also preliminary factors based on data from EPA's
latest emission factors testing program, and are currently
undergoing additional review within the Agency for inclusion
in AP-42.
-------
-10 9-
Section I - Light Duty Vehicle Emission Factors
-------
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-12 2-
Secticra II - Light Duty Truck Emission Factors
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