EPA-420-R-78-106
n —
PROPOSED CASEOUS EMISSION REGULATIONS
FOR 1983 AND LATER MODEL YEAR
HEAVY-DUTY ENGINES:
REGULATORY ANALYSIS
PREPARED BY
OFFICE OF MOBILE SOURCE AIR POLLUTION CONTROL
APPROVED BY
Micnaei ?. wai.su, Deputy assistant Administrator tor
Mobile Source Air Pollution Control
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fgpyy
£. Suanjury P«g<
A. Overview of Proposed Maukiag 1
B. Industry Description 3
C. Iapact on the Ssvironsnt 4
D. Cost* 4
S. Alternatives 5
V. Cost Iffectiveness g
II. Introduction 7
A. Hsivf^aty Eagiae Exhaust Bdiiioa Bagalaticm Background 7
B. Description of Statutory Haavy-Duty Bagine IS and CO 9
Eoissiera Control
1. Bow Baission Teat Procedures 9
2. Rev Definition of "Useful Life1* X2
3. Bevised Certification Bequiraasnts Begerding Dura- x2
bility
13
4. Emission Standards
5. Pareaeter Adjuataent ^4
6. Anticipated Head for la-Use Progrsas 15
7. The Selective Enforcement Audit Prograa (SEA) X5
C. Organisation of the Baftslatory Analysis X6
III. Description of the Product end the Industry 17
A. Besvy-Duty Vehicles \-j
B. SeivyHJuty Vehicle Bagiaes 21
C. Manufacturers 24
1. Engine Manufacturers 25
2. Vehicle Manufacturers 30
D. Users of Eeavy-Duty Vehicles 35
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Pata
E. Coacluaioa 38
IV. Eaviroaaeatal Iapaet 41
A. Background 41
B. Priaary Xspact 50
1. Baduetioa in Heavf^atf Bagiaa Saiasioas SO
2. Baduetioa ia Urban Baiaaioaa from leawy-Buty ?«hi- 55
clea
3. Mint Mr Quality Xapact of Sagalatioa 57
C. Potential Sacoadary iBviroasiiital lapacts of This Saga- §%
latioa
1. Sulfuric Acid Saiaaioaa 51
2. Particulate Laad Boiaaioaa 53
3. Hater Pollution, Koiae Coatrola, iaergy Coaaiaptioa 53
D. Xrretrereible aad Imtrimble CoHiteat of laaources 53
1. Balatioaahip of Short-Term Uaea of thfc Eorviroaaeat to $3
Maiateaaace aad Bahaaceaaat of Loag-feni Productivity
7. Coata of Coatral $4
A. Coat to Bagiae Maaufaeturara §4
1. Baiaeioa Control System Coata 54
2. Certification Coata $7
3. Teat Facilitiea Kodificatioa 59
a. Dyaaaoaatera and Control Syateaa 73
b. Coaataat Voltan Saapliag Syateaa 75
c. Analytical Syateaa 75
d. Hew Structurea aad Beaodeliag of Exiatiag 75
Struct: urea
e. Software aad Coaputer Book-Up 75
4. Salectiva Baforcaaaat Auditing Coata (S1A) 35
a. SSA Teat Facilitiea for Gasoline-Fueled Eagiaaa . 85
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Page
b. 8SA'T®et Facilities for Dieeel Engines 35
c. SEA Teeting Coats for Gasoline-Fueled Engines 85
d. SEA Testing Costa for Dieeel Engines 90
5. Total Coat to Manufacturer 94
B. Coat to Uaera of Eeaty-Duty Vehicle a 94
1. Increaaea in Firat Coata 94
2. Maintenance Coata 94
3. Fuel Coata IQ1
4. Mandatory Inspection and Maintenance Costa 102
5. Total Coat to Oaera 102
C. Aggregate Coata: 1979 - 1983 102
D. Socio-economic Impact 105
1. Xspact on Heavy-Duty Engine and Vehicle Producers 10s
2. lap act on Oaera of Heavy-Duty Vehicles H4
3. Xspact on Fuel Coata to Caere of Other Vehiclea U£
VI. Alternate Actiona 117
A. Identification of tbt Alternative Actiona 117
B. Analyaie of the Alternative to thia Regulation 117
1. Iopliaaent Heavy-Duty iaiaaion Standards More Stria- 117
gent than thoae Proposed
2. Implement Emission Standards Which Reflect a 90 ng
Percent Seduction for EC and CO Using the Existing
Steady-State Teat Procedurea
a. Background U8
b. Meed for the Tranaient Test Procedure 121
c. Summary and Conclusions 133
VII. Coat Effectiveneee 136
Appendix A - 1969 Baseline Sales-Weighted Brake Specific 1-iaaiona.
Appendix B - 1977 Vehicle end Engine Manufacturer Informetion.
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CHAPTER I
SOWAR
A. Overview of Progoaed Rulemaking
As tha total amount of urban emissions fro® light-duty vehi-
cles cad trucks is reduced, cha portion which hesvy-duty vehicles
contribute to thoaa aadaaiona bceeMi an increasingly significant
factor. For example, it ia expected that th« fraction o£ total
mobile aourea urban hydrocarbon (HC) emissions arising from htcvf
duty vehicle operation will climb froa SZ in 1975 to 16Z in 1995.
Similarly, heavy-duty carbon monoxide (06) amissions may expand
from 9Z to 24Z in- tha same time fraae. It ia in light of thaaa
sxptetacioia that Congraaa haa mandated stricter controla on tha
gaseous - emissions from heavy-duty anginas.
Thia proposed rulemaking follova froa tha Congraaaional
requirement that EPA propoaa ragulationa to raduca by 90Z tha
emitted levala of pollutanta froa heavy-duty vehicles — both HC
and CO, relative to a baaalina of uncontrolled (pre-1970) emis-
sions. (Ozidea of nitrogen (SOx) reduction will be addressed in
aaparata regulations, though the present regulations do propose an
HOx standard such that no further control ia required under the new
teat procedures.) The purpose of thia specific document is to
preaent tha reaulta of KPA analyaea of the environmental and
ieowaie iapacta and the coat sffectivanees of the propoaad regula-
tions. Tha reader will find chapters devoted as well to the
¦taka-up of tha heavy-duty industry and to alternative actions
considered by the agency.
The proposed regulation* define preliminary leva 1a for the
Congraaaionally sat gaseous emission standards for heavy-duty
enginea. Also introduced here are requirements that the standards
be mat on a teat procedure which preeeribes tranaieat engine
exercise. Tte ahift from the steady-state procedurea completee an
SPA development program which yielded teat cycles derived fro-t-
actual in-nee vehicle operation; such tranaient teeting, it is
reaeoned, more accurately assesses on-the-road emissions than do
tha previoua procedurea. An engine teat highlighta the procedure,
which is capable of turning out mis a ion ncmbers on a useful-work-
produced baaia (i.e., grama per brafcehoraopower hour).
Since the baseline teeting program ia still toing on, it ia
net yet posaible to quote final emission levels. However, on the
basis of 12 engines, the requirements are 1.4 g/BHP-hr of hydrocar-
bons and 14.7 g/BHP-hr of carbon monoxide. Thes* levela may change
as the baseline testing is completed (about May of 1979), but the
change should not be significant. Based on a statisticsl analysis
of the baseline data, EPA has determined with reasonable confidence
that the final standards will not be less than 0.76 g/BHP-hr (HC)
and 11.4 g/BHP-hr (CO). SPA will not finalise standarda below
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th&m lover limits without reproposing the value*• Regarding
nitrogen oxides, it is not the intent o£ this rulemaking to Impose
substantially more stringent HOx mission levels than did the 1979-
1982 standards; however, there is no NOx-only standard in the
currant regulations, and the newly-proposed test procedural differ
entirely free their predecessors. EPA's course, then, will be to
present in tin final rule for 1983 a HQs standard — derived free a
baseline of currant (1979) anginas — which will not require any
control over that in the current regulations.
Additional changes appear in tin# proposed rule. First, a new
definition of "useful life" end revised certification requirements
for assuring emission control system durability will altar the face
of deterioration calculation. "Useful life" for gasoline engines
as well as diesels will be the period up to engine rebuild or
retirement, whichever cceu first, as specified by the manufacturer
and labeled on the vehicle. The manufacturers will also design
their first y©frfs entire service accumulation procedure. Accom-
panying thir procedure would be a progrem of lit-vehlcle, ia-use
service accumulation on each durability engine which would deflas
at the 30,000 mile point a smut deterioration factor, one that would
supersede the earlier factor determined at certification. The
ia-use icctsBt&l :tlon would extend from 3 months after production
begins until the fell useful life is reached.
Another change in EPA's past course involves a provision
affecting parameter adjustment* In it, the Administrator will be
allowed to require that adjustable emission-affecting parameters be
set at othas-thearracommended settings for certiflcetlon; the idea
is to encourage design of engines whose mission characteristics
are less susceptible to la-use maladjustment.
Additionally, EPA proposes la these regulations an Idle
standard for HC and CO emissions because the CAPE-21 program
demonstrated that the idle node is the'largest single mode of
heavy-duty operation. It is also important to control idle emis-
sions since Idle operation occurs in situations that involve fairly
direct exposure of people.
Also, EPA. proposes to control heavy-duty diesel crankcasm
emissions* The current HC emission regulations place controls only
on crankcaae emissions from gasoline-fueled engines. Under the
proposed changes, no crankcaae missions from heavy-duty diesel
engines will be permitted.
Finally, the implementation of an assembly line emissions
testing program known as the Selective Enforcement Audit (SEA)
program is proposed. This progrsm will eld in insuring that actual
production engines meet the emission levels to which they are
certified. SEAt are initiated by a test order fro® EPA and cover
only one engine configuration per test order. The number of SEA« a
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manufacturer most undergo each jmt is based primarily, but not
exclusively, on projected annual sales. Kit got! is an SS4 is to
ascertain whether or not Che engines tasted met a 102 Acceptable
Quality Level (AQL). This AQL would require virtually all engines
to tseet applicable stsndards after adjustnsat for deterioration
with only 10Z allowed to exceed standards to provide for test
variability end isolated instsnces of nonconformity.
Failure of m SEA aay lead to suspension or revocation of the
engine's certificate of conformity. The manufacturer would then be
permitted to sake running changes or quality control changes to the
engine and then undergo another 8M. Another possibility is for
the aaanfacturer to request a Production Compliance Audit (PCA) to
determine the compliance level of the engine configuration, and
then pay a Soneoaformane® Penalty (HCP) baaed on the "marginal
cost" of compliance between engines in compliance and the aoacoo—
forming engines.
The option of requesting a PCA after the failure of an 324
will be available only if the HCP provisions of the proposed
regulations are in foree. At this tint, EPA does not foresee the
need for the ICP provisions to b« instituted since SPA believes
that all manufacturers can meet the mandated reductions in HC sad
CO.
3. Industry Description
The "heavy-duty industry1* discussed here refers to that
collection of companies which aaaufacturars the trucks and buses
found in on~the-roed applications, specifically those whose gross
vehicle weights (G7V) «xceed 8SOO pounds, and their engines. The
rather complex picture presented by the ntaeroos msnufacturers and
their diverse produet lines is simplified somewhat by the realise*
tion that only a few of these companies are reeponeible for the
bulk of the industry's production.
General Motors, Ford, Chrysler, and International Harvester
(ISC) share 991 of the heavy-duty gasoline engine mrket; Cawas
Engine, Detroit Diesel, Mack, Caterpillar and IHC are the primery
diesel engine producers. Only CM (including Detroit Diesel) and
X8C make both typea of engines in significant quantities.
Vehicles in the industry are produced in many configurations
(single unit or trustor, gasoline or diesel, various axle arrange-
ments and load capacitiea, cstc.)by a a amber of manufacturers,
but, as with the engines, most vehicles are built by the largest
producers. @1 (Chevrolet and CMC), Ford, Chrysler (Dodge), and IHC
sake over four fifths of all U.S.-built trucks.
The applications of trucks to real-world tasks vary widely
depending on load capacity, ranging frost personal transportation
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and agriculture, to const ruction! trade, and "for hire1* uses. The
companies and individuals who purchase trucks take advantage of the
diversity of available products and choose vehicle-engine combina-
tions which econoaically fulfill their needs.
C. Impact on the Environment
The projected improvement in heavy-duty (gasoline) emissions
and the enauing decrease in total urban emissions depend heavily on
the rate of emission deterioration chosen for such an analysis.
In this document deterioration rates have been assumed for two
cases:
1. On the baais of Che limited experience of light-duty
catalyst controls, which assumes an increasing number of
failed catalyst systems over time, the resulting increaae in
vehicles which are effectively uncontrolled thus offsetting
much emission reduction; and
2. On the assumption that deterioration is minimised by
improved emissions and durability testing, less adjustable
engine parameters, assembly-line testing and a program of
inspection and maintenance of controls (so that the average
emiasion level of all vehicles just meets the 1983 standarda).
If these two cases are treated as possible extremes, then heavy-
duty gasoline vehicles will exhibit by 1995 an improvement of 2-75Z
in BC and 55—89Z in CO relative to the scenario of a continuation
of 1979 standards. The effect which this reduction would have on
total mobile source urban emissions tranalates to a 3-11Z improve-
ment in HC and 13-21Z for CO, again compared to the case of no new
heavy-duty regulations.
On the baais of further calculations SPA estimates that as a
result of the proposed rulemaking-the ambient levels of oxidant and
CO will be reduced in 1995 by 1-2Z and 4-6Z respectively.
Secondary emission effects; water, noise and energy consump-
tion effects; and commitment of scarce resources are all expected
to be negligible as a result of promulgation of the 1983 regula-
tions.
D. Costs
The increased costs which the heavy-duty engine manufacturers,
and ultimately the consumer, will have to bear as a result of the
1983 regulations consist of costs for purchase and installation
of new test facilities, for development and installation of new
emission control systems, and for certification and SKA testing.
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for the dieael aanufecturers, the new test facilities (aeinly
dynamaeters) will be the priaary coat; for gasoline aanufecturers,
the salsaion controls vill be highest. There are additional costs
falling upon the operators of gasoline engine equipped vehicles
which are addressed below.
An increaae of approximately $204 can be expected in the price
of .a gasoline engine, $171 of which is attributable to the aumufae-
turing coata of the cetelyst systea. The reaaining $33 is primar-
ily attributable to equipaent acquiaitioa and aodification coata,
amortised ever five yeara. In contraat, dieael enginea vill coat
aoae $185 aore, but aost of that increase ia traceable to dyna-
aoaeter purchaaea and procedure aodificationa. It is becauae
catalyst control vill not be required of the dieael aaanfacturere
that their production coats vill be less than for the gasoline
produeera. Certification coats for both engine types are not
expected to rise appreciably.
Ho increased operating coats are expected to fall upon
the users of diesel equipped vehicles. However, gasoline vehicle
operators vill incur the additional coats of unleaded fuel, control
systea inspections, and poaeibla catalyst replacement. Offsetting
these coata elightly is the reduced frequency of replaceMint of
apark pluga and the auffltr. The anticipated net increase in
operational costs for the gasoline vehicle user saounts to about
$1016 (present worth on January 1, 1983, aaauaing a 10Z intareat
rate).
The aggregate total costs for all heavy-duty engines produced
in the five-Tear period beginning in nodal year 1983, discounted to
the effective date of the regulationa (January 1, 1983), ia found
to. be $2*382 billion for gasoline enginea and $158 million for
dieaela. This aggregate coat includes the increaaed first cost for
each engine plua increased operating costs.
Becauae EPA expecta the 1983 heavy-duty regulations to hare
only slight iapacts on induatry-wide sales, the industry's esploy-
aent end production should not suffer. Also, users of heavy-duty
vehicles and of other vehiclea should expect no burden as a reault
of the ruleaafcing.
1. Alternative!
Because of the constraints put on EPA by the amended Clean Air
Act, only two alternativea to thia proposed rule exist: to require
aore stringent standards, or to require 90S reduction in HC and CO
aa secured on the preeent steady-state test procedures. Th« first
of these choices was not considered in depth due to tiae con-
straints and confidence that SPA and industry technology assessment
have resulted in reasonable Congressienally undated reductions.
Thus, it is the second alternete plan that is addressed here.
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The question of the second alternative, 90Z reduction on
present procedures, actually becomes a question of tr«iaient versus
steady-state emission testing requirements. EPA justifies its move
to transient procedures on the basis of several factors which have
grown out of EPA's 6-y«ar study of the probl«m. Basically the
9-tsade and 13-node steady-state teste cannot: be relied on to assure
a full 90S reduction.
It is relatively easy to design engines which display low
emissions on the simpler nodal tests because only a few of the
spectrum of engine operating nodes are stapled. Since the sew
procedures include acceleration and deceleration, a full range of
engine speeds, and cold starting, they will provide greater assur-
ance that the standards are indeed being set on the road. The
transient cycles were generated from aetual in-use data, and
therefore, their rpn versus power characteristics differ from those
of Che steady-state cycles; emission testing likewise fails to
demonstrate a correlation between the two procedures.
Although it is not presently possible to prove a quantifiable
increase in air quality by adopting the new procedures, the change
is indeed justified. In light of favorable cost effectiveness
figures, then, SPA proposes the 90S reduction in HC and CO with
certification on the new gasoline and diesel transient engine
tests.
P. Cost Effectiveness
Cost effectiveness as applied to pollution controls is the
cost of control per ton of reduction in pollutant. EPA*a calcula-
tions yield cost effectiveness numbers for g&soline engine of $300
per ton of HC and $15 per ton of CO reduction. Diesel costs are
expected to be supplied mainly toward HC control, hence the entire
cost is allocated to HC. The estimated cost effectiveness for this
diesel HC control is $162 per ton of reduction. By way of clarifi-
cation, most of the gasoline engine coat per ton arises from the
requirement for the more expensive (unleeded) fuel needed for
catalyst controls. Also noteworthy is the fact that although the
diesel cost may se€a high* most of the cost results from transient
procedure requirements. Puture regulations (notably HOx and
particulate) will require the sane equipment and procedures, so
much of their equipment costs have been absorbed in the present
regulations.
It is EPA's position, especially in light of Che benefits of
th# transient procedures, that the proposed 1983 heavy-duty regula-
tions are indeed cost effective.
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CHAPTER II
IHTBODOCTIOH
A. Heavy-Duty Engine Exhaust Emission Regulation Background
Heavy-duty angina exhaust emissions vera first regulated by
the State of California beginning in 1969 (aee Table 11-A for a
sunary of actual acandarda). The 1969 California suasion stan-
dards were expressed only in terns of exhaust gas concentration,
applied only to gasoline-fueled engines, and covered only HC and CO
amissions. EPA adopted the California standards and teat proce-
dures' for gasoline-fueled engines beginning in 1970, and imposed
exhaust and smoke emission standards for dieael engines.
The next improvement in heavy-duty engine emission measurement
techniques occurred with the introduction of revised heavy-duty
engine test procedures (for both gasoline-fueled snd diesel
enginee) by California for 1973. These regulations called for mass
measurement of the pollutants, and extended the standards to HOx
emissions by including a standard for HC ~ HOx. These procedures
mere adopted by EPA for 1974. These procedures, while different
for gasoline-fueled and diesel engines, basically required the
operation of engines on an engine dynamometer at aeveral steady-
state speeds. Ssmples of engine exhaust mere collected during the
various stagea of gasoline "9 mode" and dieael "13 mode" teats, and
quant it iea of HC, CO and HOx pollutanta mere determined, faiaaiona
vera measured as a function of the useful work performed by the
engine, and expressed in grama of pollutant emitted per engine
brake horsepower hour (g/BHP-hr). The result was that an engine
with high horsepower was allowed to pollute more than one with less
horsepower, since it performs more useful mork. These procedures
remeined in effect through 1978 with only minor technical improve-
ments.
As part of an EPA heavy-duty test procedure developawnt and
technology assessment program begun in 1972, EPA evaluated the
1974-78 ateady-state heavy-duty engine teet procedures in an
attempt to relate emissions measured on the test procedure to
actual on-the-road HDV exhaust emieeions. The data evaluated
indicated that at emission levels below the 1974-78 standards, the
results of emission testa using the 1974-78 teat procedurea were
inadequate predictors of on-the-rosd CO and HOx emissions, i.e., a
given reduce ion in emissions measured on the current teet procedure
results in a much smaller reduction in actual on-the-road emis-
sions. 1/
V "An Examination of Interim Emission Control Strategies for
Heavy-Duty Vehicles (A Regulatory Support Document)", EPA QMSAFC,
October 3, 1975.
%
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fable II-A
Siins-^y-BaCy Engine Mauct Saissioa Standards
¦Federal————— —¦- —---——Cal i foraia*
1mm
Option
1C
CO
N0»
HC+HOx
Option
1C
CO
WOx
HC*W
1969
HR
HE
IK
HR
275
1.5®
HR
HR
1970-71
275®
1.5*
HR
HR
275
1.5
HR
HR
1972
275
1.5
HE
HR
180
1 1
HR
$
1973
275
l4
HR
HI,
—
40®
1974
40S
1?
—»
40
—.
16
1973-76
—
40
—
16
30
—
10
1977-78
••
40
—
16
A
1
1.0
25
25
7.5
5
1979
A
1.5®
25
—
10®
A
1.5®
25
7.5
—
E
—
25
—
5
B
—
25
—
5
1980-82
A
1.5C
25
—
10®
A
1.0
25
—
6
B
25.
5
B
25
5
1983-84
90Id
902*
e —
0.5
25
4.5
1985
90Z
90Z
752
—
a HC ¦ pares per aillioa; CO » 1 aole voltaM. Used for Federal
Standards 1970-73 and California Standards 1969-72.
b Gram per brake horsepower-hour.
c Waasured oa 1979 teat procedure (HFID for HC). Reduced 0.5
g/BHP-br when 1978 procedure is used (HDXR for EC). HDIR is
allowed ia 1979 for all aaaufacturers, beyond 1980 only for
low voluae cuurafactarers seekiag Federal certification.
* Raductioa frota 1969 baseline for gasoliae eagiaes.
# Standard Co be chosen so as Co require no mora HO* control
than required by the 1979-1982 standard*.
f
Raductioa fro® 1973 baseline for gasoline eagiaes.
SI ¦ No requirement*
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Za 1977, EPA Char*fore adopted aodific&tiona to the 1974-78
teat proeedurea which improved the accuracy of the teat procedures
enough to allow the promulgation of warm atriegsot standards. Ihe
combination of the revised teat procedures and new at«ndarda were
applicable beginning in 1979. They were referred to as the "Ma-
teria regulations," beeauae SPA intended to adopt aora fund Men-
tally revised teat proeedurea and aore stringent atandards later.
The interiai regul&tiona allowed auuaufacturera the option of two
•eta of miesion atandards, one Mphasiiiag EC control and the other
HQs control. All manufacturers were allowed to postpone use of the
interim (aodified) test proeedurea to I960. Saall volume aanufac-
turera were allowed to retain the old teat proeedurea indefinitely
under EPA reguletiona, but not under California regulations.
California has established pregreaaively aore stringent standard*
uaing the interia test procedures. Current EPA standards do not
change beyond 1979.2/
Since 1977 EPA has continued its development of a fundi
tally new, heavy-duty engine test procedure to saake eaission
reduction!! measured in the laboratory more representative of percent
reductions one would expect to achieve iaruse. Also, the 1977
kandsrata to the Clean Air Act directed EPA to promulgate new HC
and CO emission atandards applicable in 1983 which would require e
9GZ reduction in eech pollutant Stem a baseline of 1969 heavy-duty
gasoline engines, and a new HOx standard applicable in 1985 which
would require a 75Z reduction froa a baseline of 1973 heavy-duty
gasoline engines. Baaed on ita evaluation of the 1974-78 teat
procedures, If A conaidera the current, interim teat procedures to
be incapable of ensuring reductions of theae oafsitudea in in-use
eaissions. Therefore, the proposed action consists of the promul-
gation of the statutory BC and 09 atandards for 1983 as measured on
a new transient engine teat procedure. The new teat procedure ia
the culmination of SPA'a dasfelopmant work begun in 1972. Preaul-
gation of the atatutory 1985 90k standard will be proposed at a
later date.
1. Peecription of Statutory Sea^yPutr Engine HC aad CO Eaiaaion
Control
1* Bew Emission Teat Procedures
SPA ia proposing new teat proeedurea for determining
gaseous edunat eaisaions (including HQs) froa heavy-duty engines,
ley feeturea of the new teat proeedurea, eapecially the engine
operating cycle, will likely be uaed for measuring dieael ediauat
2/ Current Federel heavy-duty engine emission standards and teat
proeedurea are contained in Che Code of Federal iegulationa, Title
40, Pert 86.
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particulates starting in a model y«ar not yet proposed. 1hen the
diesel particulate - regulations are propos«d, the need for smoke
standards will be addressed. In the manias, SPA proposes that
the current test procedures used to measure tmke exhaust from
diesel engines continue to be used after the new gaseous emission
test procedure is in effect. SPA also proposes that all manufac-
turers of heavy-duty engines be required to use the nev test
procedures for certification testing, i.e., that the current
optional use of the 1974-1978 test procedures by low volume aanu-
facturers be ended after 1982.
Like the current test procedures, the proposed procedures
measure emissions fro* engines while mounted end operating on an
engine dynamoaeter. However, the proposed procedures differ from
th« current test procedures in several areas. The three fundamen-
tal points of difference are the engine operating cycle* over which
emissions are measured, the sampling method used to collect
emissions during engine operation, and the requirement for both
cold and hot start test segments. These three differences in turn
necessitate several related changes involving engine mapping,
instrumentation, and equipment calibration. The proposed test
procedures closely resemble the current light-duty vehicle and
light-duty truck test procedures (Subpart B of CPE Title 40 Part
86) in the areas of emission sampling, instrumentation, and equip-
ment calibration. 3/
The propoaed test procedures contain two transient, engine
operating cycles, one for gasoline-fueled engines end the other for
dieivtl engines. The two cycles were developed by SPA from data on
the operating characteristics of in-uae heavy-duty engines of each
type. 4f Sach cycle is specified by a second-by-second listing of
pairs "f normalized engine speed and power veluea. Uunormaliaing
the cycle into an actual speed - power cycle requires that the
curve of engine power va. engine speed be known, deter-
mining this curve experimentally is one of the earlieat steps in
the test sequence. After this engine mepping is done end the
results are used to compile an actual speed-torque test cycle, the
test engine is allowed a long soak. It ia then started from the
cold condition, operated over the teat cycle, shut off for a brief
Zj The proposed test procedure, together with a list of supporting
r«£#rences, is contained in "Draft Recommended Practice for Deter-
mining Exhaust Emissions front Heavy-Duty Engines Under Transient
Conditions," Chester J. France and William 3. Clemmena, HDV 78-07,
June 1978, available from the Emission Control Technology Division,
SPA, Ann Arbor, Michigan.
4/ Descriptions of the surveillance project and asubsequent cycle
development can be found in the references listed in the report
cited in the previous footnote.
10
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soak, restarted in the hot condition, and operated again over the
test cycle. Tolerances on how closely the e&fitus oust follow the
test cycle are specified in the procedures.
Mass emissions for each pollutant and useful work output are
aeaaured separately for the cold start and hot start segwnts of
the test. This allows emissions froa in-use cold start trips
(i.e., trips which begin with the engine at o&ient temperature) to
be estimated separately from enissions froa in-use hot start trips.
The two are then weighted with the ratio of the frequencies of Che
tw types of in-uae trips end divided by the sisdlarly weighted
useful work output to get the brske-specific emissions froa an
"average** in-use trip.
Mass emissions froa each test sepnnt are aeasured by diluting
the hot exhaust §aa streaa with cooler air and collecting a saall,
proportional senple of this dilute eizture in a bag. The concen-
trations of pollutants in this bag are asasured using analytical
instruments suited to such measurements (a flame ionisation detec-
tor for EC, e non-dispersive infrared analyser for CO and €0.,
and a chcnilomittsscsnce analyser for HOx), the total volume of
dilute mixture ia calculated froa other asasuraente mads during
engine operation, and froa these the mass of each pollutant eaitted
during the test segoeat is calculated. EC eaiasions froa diesel
engines are an exception: these are not bagged but are continously
saapled and analysed during the test sepent using heated saaple
lines and a heated flaae ionisation detector. The test procedure
allows the use of two types of constant volume saapling (CVS)
systems known to be suitable for this type of emissions saapling,
plus otlMir systems if approved in advance.
Useful work output is aeasured via the msasuring system which
are integral parts of the dyn—raster controls.
Procedures are specified for periodic equipment calibrations,
as necessary to ensure eccurate test results.
The contrasts between the proposed cad current test procedures
highlight the iaportent features of the new procedures. The
operating cyclns ia the current procedures consist of sequences of
specified iteady-state modes (9 nodes for gasoline-fueled engines>
13 aodes for diesel engines) rether than of second-by-second
listings of speed-power pairs. The current procedures therefore
test engines et fewer points in their opereting ranges than will
the new cycles. The current procedures do not allow atasurmsnt of
(•missions during transient conditions representative of in-use
operation. The new procedures will. Since under the current
procedures emissions are not asasured during periods when exhsust
gas composition end volume are changing, dilution with air and
proportional sampling into s collection beg are not used. Instead,
pollutant concentrations in the exhaust gases axe asasured directly
U
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over a ssjII pore ion of each aoda mi combined with other measure-
sents Co calculate mass amission results. This measurement of
uadllutd azbanat pms requires somewhat different analytical
systems. Separata cold start and hot start segments ara not
performed. Calibration procadnras for aquipHat, and tolaraacas
on thti operating cycles, are correspondingly different.
EPA is also proposing test procedures Co be used to determine
amissions of H€ and GO under idle conditions. The test procedures
are new, rather than a revision of any existing procedures,
because current regulations do not include idle standards. The
test procedures are staple, and can be perforated immediately after
the tranulent test procedure. The idle test procedures will be
used for both gasoline-fueled and dlesel engines.
2. Key Definition of "Useful Life"
EPA is proposing to amend the current definition of
"useful life" for heavy-duty enginae. The amendment would bring
the periods of use specified in the definition into closer agree-
¦cat with the periods of use actually seen by heavy-duty engines
before retirement or major refurbishment (e.g., rebuilding or
major overhaul).
The amended definition would apply to the assembly line
testing, warranty, recall, and certification provisions of the
Clean Mr Act. That ie, manufacturers will be required to furnish
owners with Section 207(a) and 207(b) warranties covering the
period of use specified in the eaended definition. A manufacturer
would also be liable for recall of & category of its engines if
the 1PA Administrator determines Chat a substantial number of the
category does not conform to the emission standards during that
period. And the longer useful life definition will be incorporated
into the certification and assembly line testing procedures via
deterioration ""factors, as described' la che~tte*t~ ~ subsectXbnT
3. ievised Certification Beeuiremants Regarding Durability
SPA proposes to allow each manufacturer to design the
entire test procedure used to calculate deterioration factors for
its engines. Msnufacturars would submit deterioration factors,
based on the smsnded definition of useful life, in each case mhare
current certification procedurea require teating of a durability
data engine. SfA would not approve or disapprove a manufacturer'* s
durability teat procedurea. Manufacturers would mis© design the
procedure for breaking in emission-data engines prior to their
certification tests.
12
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The tbovi proposal will apply only to engine family-con-
trol system coablnatlons seeking Initial certification. For a
faallyaystea cosbinstioa being mmrtlfiad la nbiaqiaac years
under currsat regulations (i.e., oaa which baa sot baaa slgalfl-
caatly redesigned froa tha previous »edel year(s)), EPA proposes
that aaaafacturers be required to perform iarehiuisls, oarthe-road
service accumulation using prodactloa eaginas froa a previous
model yeer. Engines voold have to In tasted la such mmbars sad
ondar sash conditions as required by tha Administrator to ensure
tha represeatatlveaeee of tha teete. la ordar to prmat the
lntaat of Is-chassis service sccaaalatioa froa being eicoavified
through frequent, minor chaagss la engine f sally deteraiaaata, SPA
la propoalag that ths edaialatrator aska tha final decision ss to
ahathar engines froa successive aadel years should ha $?oapsd iato
tha same faaily-systsa comhiaatioa.
As a eoadltloa for certification,, ia-ase servlea sccaaalatioa
voold ha required to begia within 3 aoaths of begisaiag prodactloa.
4 alalaua of 13,000 alias par yaar would hsve to ha sccuaulstsd,
although ths aaaufaetarar coold accumulate mileage at a aora rapid
rata if desired* At tha point whara 30,000 alias -were eccumuleted,
the deterioration factors determined for laltlsl certification
would he replaced by those based upon la-use sccaaalatioa# The
resalta of tha allowed smlsslon tasting would he rmltiplicati^v
deterioration fectors for estlmstlag deterioratloa over the full
useful life. Ia aost eases these factors would hate to be extra-
polated , elace tlae eoastraiats will always aake it difficult to
representatively eecnHlate the full aaouat of service specified ia
tha defialtioa of aseful life. Deterioratloa factors would he
updated each yaar as aora la-use alias wars accumulated, up to full
uaaful life. SPA expects that eagiaes deslgaed for the 1983
stsadards will la aost casee require aodificatloae la 19IS to aeat
the statutory HOx staadard. Therefore, aeanfacturers will have the
option la 1983 and. 1984 of not beginning bnui service ecoatele-
tioa. if jthaf'chooseC ta- esttify • thelr-eaglaiuT for these 'years only*
4. galssioa gtsadards-
SPA proposes that the BC aad CO aalssloa standards
applicable to 1983 aad later aodel yeer heavy-duty engines require
90S reductions froa amissions froa a baseline of 1969 gasoline-
fueled engines, ea asasured with the proposed asw test procedures.
These reductions ere those mandated by the Clean Mr Act es eased-
ad* The new 3C and GO standards will apply to both gasoline-fusled
sad diesal heavy-duty engines#
EPA dose not Intend to require substantially aora HOx coatrol
la 1983 thee waa required by the 1979-82 standards. It is not
possible to sisply keep the 1979-82 HOx standard ia 1983, however,
since there was no HQae-only standard for 1979-82. farther, the
test procedures proposed for 1983 ere different thus those ««Bd la
1979-82. A HOx
13
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btadine of 1979 angina taatad with the nmm procadoraa will be
available wteaa the final rale on the L983 tta»dtMa la promulgated.
SPA proposes Co use this 1979 baseline to das rite a 1983 SCx staar
dard that la based on the sales weighted average of the HOx levels
from the engines in this sample.
A separate Idle standard is aleo 1 tic laded in this package for
HC and CO. Idle operation repreaents the largest single mode of
he*vy-duty trock operation (approximately 25S of the time in the
CAPE-21 program), and timss of prolonged idle can also be occasions
of high population exposure such as at crowded intereectlons,
loading docks, or pickup mod discharge of bus passengers.
EPA is testing emissions from a series of 1969 and 1979
engines using the proposed test procedure, to allow numerical
standards for EC, CO, and NOx to be included in the final rule.
In the interim B?A la sot proposing specific numerical standards.
However, besed on the testing completed at the time this draft
statement was prepared and eummarised in an appendix to this
statement, CPA's best estimates are that the final standards will
be 1.4 g/BHP-hr for EC, 14.7 g/BHP-hr for CO. The estimated idle
standards are 1400 ppmC for HC mad Q.55X for CO. These estimates
haM teas used throughout this draft statement. The final state-
ment will be revised to reflect differences between these estimates
end the final staudarda. Based upon statistical analysis of die
available baseline data EPA has estimated lower limits for each of
these standards. If the final values wexe to fall below these
lower limits EPA would have to repropose the standards. The lower
limits ere 0.76 §/BIP-hr (HC) and 11.4 g/BHP-hr (CO) for transient
operation, and 530 ppmC (EC) and 0.30 percent (GO) for idle oper-
etion*
5. Parameter Adjustment
UFA proposes to amend the certification and test proce-
dures to permit the Administrator to edjuat or require manufec-
turers to adjust engine peremeters to physically accessible set-
tings other than their recommended eettlngs prior to emission
tests of oissionrdete engines. This will encourage memtfacturers
to deslfm engines to be less susceptible to ie-use maladjustment.
Such maladjustBent is capable of causing la-use missions to be
substantially higher than ellowed by standards. The parameter
edjustment provision will help ensure that the 901 reductions in
EC and CO mandated by ststute are actuelly achieved by in-use
engines.
The specifics of the pera»ter adjustment proposal are esseir*
tielly the sne es those of the recent final rule on persmeter
adjustment for light-duty vehicles and light-duty trucks. Pour
types of parameters on gasoline-fueled engines may be liable to
EPA adjustment in 1983: idle mixture, idle speed, initial spsrk
timing, and choke velve ection peremeters. Newly introduced
14
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parameters oa either type of eagi&e may also be liable to sdjust-
wm& in the year they are introduced, la addition, exiaiag para-
meters oa either type of engine beyoad the four mentioned above say
become liable to adjustment if EPA notifies msnufacturers mad gives
sufficient lead time for compliance. Parsaeters vill be adjusted
oaly if SPA determines that they pose or are reasoaably likely to
pose significant naiad jus burnt probleat in use. Procedures are
included for asking aad appealing these determinations.
6. Anticipated Heed for InHJse Prograaa
EPA anticipates that the statutory HC aad GO standards
vill result in the use of catalyst-besed amiaaioa control techno-
logy for sow or all gaaoline-fueled heavy-duty eagines* Such
technology is susceptible to significant deterioration ia effec-
tiveness oace placed ia use. tihile the proposed parneter adjust-
sent provisioa will prevent some of this deterioration, deterio-
ration attributable to reduction in catalyst §yat«§i effectiveaess
vill still be « possible problem. EPA therefore expects that
iaspection and maintenance (I/M) pragma aig!it be found necessary
to ensure the full emission reductions called for by statute. The
regulations being analysed in this regulatory analyais do not
include propoaals for I/M for heavy-duty vehicles. However, the
saticipsted costs sad benefits from I/M pro press are considered ia
the eaalysis of the impscts of the proposed revisioas to the
certificatioa aad test procedures where appropriate.
7. the Selective Enforcement Audit Program (8EA), Produc-
tion Compliance Aaditim (PCA? and Bonconformaace Penal-
tiee (HCP)
Hie S5A progran is an assaably line emissions testing program
used to aid in insuring that the engines produced meet the emis-
sions level to which they are certified. SSAs art iaitiated by a
test order from IPA aad cover oaly one eagiae coafiguratioa per
test order* The noaber of SEAs a manufacturer aust undergo each
year ie baaed primarily, but not exclusively, on proj®ct®d annual
sales. The goal ia ea SSA ia Co aacertaia whether or not the
production engiaes tested aset s 10 pereeat Aseeptsble Quality
love! (AQL). A 10 pereeat AQL would require virtually all eagiaes
to sieet applicable standards after adjustaeat for deterioration
with oaly 10 percent allowed to exceed standards to provide for
test variability aad isolated inetancea of nonconformity.
Pailure of an SSA nay lead to suspension or revocation of the
engine's certificate of conformity. The manufacturer would then be
permitted to aake running changes or quality control changes to the
engine configuration and then undergo another SSA. Another possi-
bility is for the nanufacturer to request a Production Co^lianc®
Audit (PGA) to determine the compliance level of the engine config-
15
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uratioo, cad then pay & Nonconformance Penalty (RCP) based on ehe
"marginal cose" of c alliance between engines in compliance end the
nonconforming engines.
The option of requesting a PGA after the failure of an SEA
will be available only if the SC? provisions of the proposed regu-
let ions are in force. At this time, 1PA does not foresee the need
for the NCP provisions to be instituted sinee EPA believes that all
manufacturers can meat the mandated reductions in HG and GO.
G. Organisation of the tagulatory Analysis
This snalysis presents sn assessment of the envirosMntal and
economic impacts of the heavy-duty engine regulations SPA is pro-
posing. It provides a description of the information and analyses
used to review all reasonable alternative actions and oaks the
proposal.
The reminder of this stateaent is divided into five major
sections. Ghepter III presents a general description of heavy-duty
vehicles end engines, s brief description of the manufacturers of
this equipment, and the aarkat in which they coapete. It also will
discuss the uses to Which heavy-duty vehicles are put, and describe
the primary user groups.
Aa assessment of the primary and secondary environmental im-
pacts attributed to the proposed HDV regulations is given in Chap*
ter IV. The degree of control reflected by standards is described
and a projection of air pollutant omissions for the national IS1?
population, with the proposed standards in place through 1995, is
presented. The impsets of these regulations on urban emissions md
the expected air quality benefits are considered. Secondary affects
on other air pollutant emissions, water pollution and nois@ are
also discussed in this section.
An examination of the cost of complying with the proposed reg-
ulations is presented in Chapter V. These costs include those in-
curred to install emission control equipment on heavy-duty engines,
costs required to purchase new emission testing ceils, the costs to
certify, the costs associated with the SEA program, any increased
vehicle operating costs which night occur, and the costs of in-use
programs which might be needed to ensure continued emission control
effectiveness. Analysis is made to determine aggregate cost for
the 1983-87 time frame. Finally, the impact that this regulation
will have on industry and consumers will be reviewed.
Chapter 71 will identify and discuss the alternatives to the
proposed setion, their expected environmental impacts, and ehe rea-
sons none has been proposed instead of the actual proposed action.
Chapter 711 will present a cost effectiveness snalysis of the
proposed action and compare the results of this analysis with those
done on other mobile source control strategies.
16
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CHAPTIB IZI
DESC1IPTI0K OF THE PRODUCT ADD TEE IHBUSTSY
4. Heavy-fluty Vehicles
A heavy-duty vehicle (SI?) as s««n by SPA is one «ho«e §rose
vehicle wight (GVW) exceeds 8500 pounds. This definition differs
from that in chc mcmded Clean Air Ace vfaich specified 6000 pounds
SVW u che lower limit of HB?s. The m*$m for ehis difference is
that although E?A is required eo regulate all vehicles heavier
than 6000 pounds GVW to at least the levels dictated by the Act I/,
ligiit-duty trucks (6000-8500 pounds) are dealt with under separate
regulations. The regulations proposed here are aiaed at the
greater than 8500 pound population only.
The industry as well uses CVW as a basis for reporting produc-
tion and sales data. Their traditional categories follow:
SPA'a definition of light-duty trucks sets the division
between the LOT class and has&y-duty vehicle class at 8,500 pounds
Thus, sowe of the Class XI trucks will be included with all
of those in Glasses III through fill in the heavy-duty vehicle
class. SPA has estimated that only about 5 percent of those trucks
in weight Claases I and II have gross vehicle weights in excess of
8,500 pound*.2/ This estimate will be used in subsequent analyses
in thia impact s tat went. Table III-A gives the domestic factory
sales of all trucks for tha years 1972 throng 1977.
To look for a eoment at industry sales trends, the lighter
weight (8,501 - 14,000 pound GVWR) truck has shown a substantial
increaae in numbers. Likewise, growth trends e»»rge in the heavy
ranges (19,501 pounds GVWB and over). On the other hand, the
numbers of medium weight BSVs (14,001-19,500 pound GWR) appear to
be declining.
17 Clean Air Act aa Aatnded, August 1977; 202(b)(3)(C).
7/ Baaed on 1973 Of and Ford production data.
Class
Weiifat (Pounds - GVW)
I
II
III
If
V
?I
711
fill
0 - 6,000
6,001 - 10,000
10,001 - 14,000
14,001 - 16,000
16,001 - 19,500
19,501 - 26,000
26,001 - 33,000
33,001 and over
17
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Table III-A
U.S. Trucks and Buses
(U.S. Production) - (Exports) + (Iaports from Canada)
0- 6,000- 10,000- 14,000- 16,000- 19,500- 26,000- 33,000 Yearly
ear 6,000 10,900 14,000 16,000 19,500 26,000 33,000 and over Totals
977 1,391,506 1,754,263 30,064 3,231 4,989 160,396 32,249 148,728 3,525,426
976 1,274,523 1,398,234 43,411 69 8,920 149,293 22,918 103,098 3,000,466
(.975 961,477 933,079 19,497 6,508 13,916 152,070 24,698 74,896 2,186,141
L974 1,490,792 718,943 8,916 8,120 24,366 215,221 32,364 160,465 2,659,187
1973 1,735,758 772,394 52,558 8,744 37,043 199.481 40,816 155,814 3,002,613
1972 1,435,368 606,836 57,804 10,353 37,492 177,723 40,150 130,328 2,496,054
Total Vehicles Subject Co HD Regulations
(52 of 0-10,000 plus >10,000)
1977 537,113
1976 461,347
1975 386,311
1974 559,930
1973 619,863
1972 555,959
Source: FS—3, MVMA data.
18
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Table XII-A does not reflect that heavy-duty tracks do not
repreeent a homogeneous class of vehicles, nither in tarns of use
or of functional characteristics. While light-duty trucks are used
by-aad-large for personal tranportation, heavy-duty tracks are
almost exclusively used for conmerciel purposes. The 1972 Census
of Trsnsportation conducted by ehe Department of Cmmrca indicates
that track# are used in agriculture construction, mining, whole-
sale and retail trade, manufacturing, and Inhering and forestry,
as well as by the utility, service and "for hire" industries. Most
functional applications of HSVs are not readily transferable to
other transportation nodes such as air, rail, water or pipeline.
As Table III-B shows, the uses of heavy-duty vehicles vary
with gross vehicle weight. For the lighter trucks, those in the
8,500-20,000 pound GVWR range, we find that the primary applica-
tions are in the agriculture, construction, services, and wholesale
and retail trade markets, where the trucks sre generally used for
pickup and delivery. Personal use of trucks in this category,
while limited, consists primarily of operation of motor homes built
on truck chassis. Soma people also use "heavy" pickup trucks for
personal transportation.
HDVe in the 20,001 - 26,000 pound CVWR range find uses in the
agriculture, construction,and wholesale and retail trade markets.
Forestry, lumbering,and manufacturing account for most of the other
applications.
The heavier trucks (26,001 pounds GVWR and over) are primarily
found in the construction, wholesale and retail trade, and "for
hire" markets. tihile the number, of trucks used for mining and
manufacturing is not large, theee markets use the heavy trucks
extensively. Trucks in this category are used only to a limited
extant in the other market sectors.
Since the ultimate goal of the various commrcial enterprises
that use heavy trucks is to make a profit, trucks operated by these
businesses are designed specifically to meet particular functional
needs in an economical manner. Thus, the heavy-duty vehicles
produced for the U.S. market ere often "custom" built to satisfy
requirements of the operational environment faced by the ultimate
use. This operational esvironsnt sight be defined in terms of
economic variables (i.e., opereting costs of alternative meana of
transport, value of products to be tranaported, operating costs of
alternative types of trucks) or operational variables (i.e.,
distances to be travelled, qualities of the loed to be transported,
types of shipping procedures to be utilised, stete and federal
regulations on truck use, safety, operation).
Buses equipped with heavy-duty engines are usually in th«
19,501 - 26,000 pound GWR (Class VI) category. Uses of buses
include school transportation as well as intercity and transit
19
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Trucks: Percent Distribution of Sise
Classes by Vehicle end Operational Characteristic: 1972
10,000
10,001-
20,001-
26,001
Number
Or Less
20,000
26,000
Or More
Characteristic (Thousands)
Percent
Lbs. GVW
Lbs. GVW
Lbs. GVW
Lbs. GVW
MAJOR Oil
Agriculture
4,258
21.6Z
20.12
32.1Z
33.2Z
10.3Z
Forestry and Lumbering
187
1.0
.5
1.4
2.8
3.6
Mining
77
.4
.2
.6
.7
1.9
Construction
1,693
8.6
6.9
10.2
14.0
19.1
Manufacturing
443
2.3
1.3
3.3
4.4
8.5
Wholesale and Retail Trade
1,875
9.5
6.1
18.9
23.0
18.3
For Hire
770
3.9
.6
6.0
7.2
30.6
Personal Transportation
8,122
41.2
53.4
11.0
2.1
1.0
Utilities
505
2.6
2.5
3.1
3.8
1.9
Services
1,409
7.6
7.7
10.5
6.0
2.5
All Other
327
1.7
1.2
3.5
3.4
2.8
BODT TYPE
Pickup, Panel,
14,464
73.3Z
92.62
31.3Z
4.4Z
2.1Z
Multi-Stop,or Walk-in
Platform
1,645
8.4
2.2
27.4
28.9
21.0
Platform v/ Added Device
336
1.8
.4
5.6
7.0
4.4
Cattlerack
479
2.5
1.4
6.7
6.7
2.4
Insulated Bonrefrigerated Van
96
.5
.1
1.2
1.2
3.1
Insulated Refrigerated Van
178
1.0
.1
2.4
2.3
5.3
Furniture Van
192
1.0
.2
3.7
2.8
3.2
Open Top Van
58
.3
.1
.6
.4
1.9
All Other Van«
610
3.1
.7
6.3
7.2
18.6
Beverage Truck
87
.5
.1
1.4
3.0
1.6
Utility Truck
370
1.9
1.7
3.4
2.0
.9
Garbage and Refuse Collector
69
.4
.1
1.3
1.4
1.2
Winch or Crsna
83
.5
.1
.8
3.5
1.8
Wrecker
115
.6
.3
2.3
.6
.2
Pole .and Legging
53
.3
.1
.3
1.4
2.4
Auto Transport
30
.2
.1
.2
.1
1.4
Dump Truck
468
2.4
.3
3.1
17.3
14.0
Tank Truck for Liquid*
287
1.5
.1
2.3
9.7
9.1
Tank Truck for Dry Bulk
29
.2
—
.1
.6
1.5
Concrete Mixer
66
.4
.1
.2
.1
4.1
All Other
33
.2
.1
.6
.5
.6
ANNUAL MUSS
< 5,000
4,621
23,51
22.0Z
33,21
35.8Z
12.7Z
5 - 9,999
5,540
28.1
30.2
25.6
25.2
13.8
10-19,999
6,598
33.5
36.2
27.8
24.0
22.4
20-29,999
1,647
3.4
8.1
8.1
8.3
11.5
30-49,999
772
4.0
2.9
4.1
4.9
13.4
50-74,999
270
1.4
.5
.9
1.5
11.5
> 75,000
300
1.5
.4
.6
.5
15.1
Total Percent
100.OS
100.0Z
100.OZ
100.OZ
100.OZ
Total Trucks
19,745
14,598
2,822
828
1,500
Source: 1972 Census of Transportation, U.S. Department of Commerce.
20
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passenger service. Moat school-type buses are gasoline fueled, the
remainder being diesela.
By defining their operating inviromsant, users of heavy-duty
vehicles can tell vehicle manufacturers exactly what characteris-
tics their truck should have when it is completed. Examples of the
design pacmeters which may be specified include engine type (diesel
or gasoline), horsepower, number of cylinders, displacement,
natural aspiration vs. turbocharging, transmission, body type
(single unit, or combination), groaa vehicle weight, maxinaa load
weight, vehicle length, number of axles, axle arrangement, distance
between tandem axles, and tiresiae.
3. Heavy-Puty Vehicle Bngiaea
One of the baaic parsmeters that heavy-duty vehicle usefa muse
consider in determining what type of vehicle they need is the type
of power plant they will use. Both dieael and gasoline engines are
used to power heavy trucks* .Some tradeoffs that vehicle manufac-
turer a consider in the selection of diesel or gasoline-fueled
engines for their vehicles follow:
1. A typical diesel engine that could be used in a 27,000
lb. CSVWR vehicle hes a firat cost (sticker price) of approxi-
mately $6,000 - $10,000. This is around three times the first
cost of a gasoline-fueled engine ($2,000-3,500), for the »mm
wight vehicle.
2. Diesel enginea can exceed gasoline engines in fuel
economy by 25 to 75Z when operated in the some sise truck.
3. Gasoline-fueled engines are typically overhauled about
every 100-125,000 miles, diesel engines every 200-250,000
¦ilea.
The heavier trucks (Classes 711 and VIII) are most often
equipped with diesel engines, as shown in Tables IXI-C end XXIHD.
However, as fuel economy and fuel costs become more important to
truck operators, diesel engines may become more popular in sona of
the lighter truck claaaea. Diesel engines are more fuel efficient
and diesel fuel is cheaper then gasoline.
Manufacturers can effectively boost the power of both gasoline
and diesel engines through turbocharging, though the first cost of
the engine suffers somewhat. Because the availability of turbo-
charged engines is e further consideration of the prospective
buyer/user, we have included a brief description.
21
-------
Tabla III-C
Diesel Usage ia Heavy-Due? Vehicles
0- 6,000- 10,000- 14,000- 16,000- 19,500- 26,000- 33,000 Yearly
Imt 6 000 10,000 14.000 16,000 19,300 26,000 33,000 and over Totals
1977 2,368 975 — — — 11,142 17,997 141,244 173,794
1976 — . 1,498 — — — 6,216 10,053 93,714 111,481
1975 — 1 — 159 4,803 10,320 62,016 77,299
1974 — — — — 41 3,360 11,700 137,908 153,009
1973 — — — 246 6 3,740 16,018 137,147 157,207
1972 — — — 215 5 3,704 12,450 116,473 132,847
Source: FS-5, ifPMA data.
22
-------
Table IIX-0
Diesels sa & Psreeatags of
Total Trucks per GVW Category
8,500- 10,000- 14,000- 16,000- 19,500- 26,000- 33,000 All ED
fear 10,000 14,000 16,000 19>300 26,000 33,000 aad over Vehicles
1977 — — — — TZ 56% 951 5*
1976 — — — — 42 44% 91% 4*
1975 — — — 1Z 3Z 42Z 83Z 4Z
1974 _ — — — 2Z 36Z 86Z 6Z
1973 — — 3Z — 2Z 391 88Z 5Z
1972 — — 21 — 21 312 89Z 5Z
Data frora Tables I1X-A tad III-C.
23
-------
~ turbocharger cccfeines a turbine» driven by engine exhaust
g
-------
• Manufacturers
Engines
Vehicles
Mlis-Chaiaers
0
Caterpillar
D
Cumins
D
Deutz
D
Hinno
0
Isuzu
D
Nissan
D
Mitsubishi
D
Ferkins
D
Scania Vabis
D
Volvo
D
Freightliner
Z
Feterbilt
1
Walter
1
Duplex
1
Kenworth
X
FWD
1
Crane
x
Fabco
X
Marnon
x
Oshkosh
1
1. Engine Manufacturers
Manufacturers of engines used in heiTy-duty trucks
typically fell into one of two cetegories, those thet produce
gasoline engines and those thet produce diesels. Four cowpaniea;
Generel Motors, Xnternetionel Harvester> Chrysler end White,
produce both gasoline end diesel engines for use in on-roed heavy-
duty vehicles. (Chrysler now produces two diesel track engines,
end White aekes one gesoiine truck engine.)
the manufacturers of gesoiine engines end the engines they
produce are listed in Tehle III-S. All these sanufacturers ere
dcoMSticelly based end all also produce their own line of heavy
trucks or buses. Generel Motors (GM), Ford, Chrysler, and Aaericen
Motors (AM€) are perhaps nest widely known as producers of light-
duty passenger cars since it is from that line of business thet
they derive nost of their revenue. However, all (except White)
produce light-duty trucks and also heavy-duty vehicles in addition
to gasoline engines.
k fifth coapany producing gasoline anginas for tracks sold in
the U.S. is the International Harvester Coapany (IHC). Like the
other four, .IHC produces vehicles as well as gasoline engines
— but no pas ringer cars. Their concentration is in the heavy-duty
truck market with serae emphasis on light-duty trucks. IHC also
wakes off-the-roed vehicles for construction and industry.
25
-------
Table III-S
Manufacturers of Gasoline Engines for Use
in On-Road trucks/Buses
Manufacturer
Number of
Cylinders
Number of
Engine Types
Displacement
lunge (cu.in.)
Uses
AMC (Jeep)
6
2
232-258
T, TR, GP, Ind
8
3
304-401
T, TEt GP, Ind
Chevrolet
6
4
250-292
T
8
10
305-454
T
Chrysler
6
3
225
T, B, Ind.
8
6
318-360
T, 1» Ind.
Bodge
6
1
225
T
8
7
318-440
T
Ford
6
5
200-300
T, B| Ind.
8
17
302-534
T, Bi Ind.
GMC
6
4
250-292
T
8
10
305-454
T
ZHC
4
6
59.5-200
T, TK, Ind.
8
13
303.7-549
T, Ind.
Abbreviations:
T » Truck; TE ¦ Tractor; G2 ¦ General Purpose;
Ind. ¦ Industrial; 1 ¦ Buses
Source: Chilton'» Autoaotive IroitriM, April 1978*
26
-------
Lacking a breakdown of how many gasoline engines each manufac-
turer sells, m hmm combined information from Tablaa III-G sad
IIX-S. Truck salaa minus diesel Crack sales gives a gasoline track
tally of about 390,730. As rasing no gasoline angina salaa art made
to otbar manufacturers, tba following breakdown results which
assigns a percentage of gasoline engioe production to each major
aanufacturer:
As we turn to a discussion of diesels, it is important to
realise that their manufacture and sale is accomplished by a
different set of manufacturers than those involved in the produc-
tion of gasoline engines. Only CM, via a subsidiary Detroit Oiasel
Allison, and International Harvester manufacture both engine types
in aipilficant quantities. Together their production of diesels
accounts for something less than 25X of the total produced. The
leading producer of diasei engines used in the U.S. trucks is the
Cummins Engine Company, followed by Detroit Diesel (CM), Mack
Tracks, Caterpillar Tractor Company, IHC, Nissan, Perkins Engine,
Scania Vabis, and Allis-Chalmera Corporation. A list of the
engines made by these companies sxtd several others is given in
Table IXI-F. Table 1ZI-G presents a distribution by manufacturer
of dieael enginea used in U.S.-made trucks.
Like gaaoline engines, most diesels are produced by dosMstic
companies. Detroit Dieael and Perkins Engine and subsidiaries of
other companies, Of and Maeaey-Ferguson, Ltd., respectively.
Detroit Diesel tells both diesel engines and aircraft enginea. In
addition to Perkins* sales of diesel engines Massey-Ferguson
produces agricultural equipment, industrial and conatruction
machinery, and recreation products. (The diesels provide around
10Z of the salaa.)
Several of the other manufacturers of diesel engines, like
Maasey-Ferguson, make off-the-road vehiclea. Caterpillar's product
line includes construction, warehouse, agricultural, logging cod
petroleum equipment, accounting for 90S of total sales. Allis-
Chalmers Corporation, a relatively minor supplier of diesel engines
for on-road truck use, is better known as the manufacturer of
agricultural equipment, heavy construction equipment, mineral*
processing equipment such as grinders, crushing equipment, etc.,
and electrical generating units. Vehicle related products provided
452 of its totsl sales in 1973.
Mack Trucks produces diesel engines and the on-road trucks
that use them. Mack is a subsidiary of Signal Companies, Inc.
Chrysler(Dodge)
I1C
4UC (Jeep)
Qf
Ford
362
30Z
27*
62
12
27
-------
Table III-F»
Manufacturers of Diesel Engines for
Use In Oo-Road Vehicles
Rusher of
Rusher of
Displacement
Manufacturer
Cylinders
Engine Types
Range (cu.in.}
Uses
Alco (White)
6
1
4,008
T, R, I
8
1
5,344
T, R, I
12
1
8.016
T, R, I
16
1
10,688
T, R, I
18
1
12,024
R. I
Allis Chalaers
6
12
262-844
T, I. TR
Caterpillar
i
19
638-1473
T, B, I
8
12
636-1964
T, B, I
12
7
1649-2945
T. I
16
4
2382-3927
T. I
Chrysler
6^
3
198-331
I. T
Cumins
6
25
378-1150
T, TR, I
8
14
504-903
T, 71. I
Detroit Diesel
6
i3
318-552
T, TR, I
8
14
568-736
T, TR, I
Deuts
3
2
173
T, B, TR, I
4
2
230
T, B, TR, I
5
2
287
T, B, TR, I
6
11
345-838
T, B, TR, I
8
8
771-1118
T, B, TR, R, I
19
3
973
T, B, TR, R, I
12
10
1035-13581
T, B, TR, R, I
16
5
2473-13057
T, R, I
IHC
6
4
446
T, B, TR
8
8
461-798
T, B, TR, I
Mack
6
5
672
T, TR
8
2
866
T, TR
Mercedes-Bens
4
2
108-231
T, B, TR, I
6
2
345
T, B, TR, I
8
1
779
T, B, I
10
1
973
T, B. I
Perkins
4
1
165
T, R, TR, I
6
2
247-354
T, TR, I
8
3
540-640
T, TR, I
White
6
3
298-478
T, B, TR, R, I
Abbreviations:
T ¦ Trucks TR • Tractors B " Buses R ¦ Railroad I • Industrial
Source: Chilton's Automotive Industries, April 1973.
28
-------
Table III-C
Diesel Eagiaes Used la Trucks
From U.S. - 1977
Diesel Engine Manufacturer
Vehicle Scania
Hfr. Cue. Cummins Detroit XHC Mack Nissan Olds. Perkins Vabia Other Total
/
Chevrolet 307 736 2910 — — — 1755 — — — 5708
Dodge 0 300 — — — — — 1573 1873 — 3746
Ford 18344 11847 7176 — — — — — — — 47367
GMC 1002 6078 12639 — — ~ 637 — — — 20356
XHC 2132 21997 6798 9040 — 1128 — — — — 41275
Hack 176 1491 691 — 26874 — — — 319 — 29551
White 964 16890 2739 —— — — — — 2 20595
Kemrorth 1712 8313 2504 —— — — — — — 12529
Peterbilt 1682 8263 1440 —— — — — — — 11385
Others 373 2968 1317 —— — — — — — 4658
TOTAL 26872 78883 38214 9040 26874 1128 2312 1573 319 2 185297
(units)
Source: FS-5 1977 HVMA data.
29
-------
whose business includes aerospace tad industrial equipaent, petro-
leum and petrochemical products, and construction and fabricated
products. Sales of Mack Truck, Inc. (engines snd vehicles) ac-
counted for about 50 percent of Signal companies' sales in 1977.
The leading producer of heavy-duty diesel engines with 45Z of
the market, Cummins Engine Company, ia unique in that it doea not
manufacture any vehicles, either on-road or off-road. Nearly all
of its sales cons froa sales of engines. Cumins also produces
snd aarkets crankahafts, turbochargers, and related coaponenta.
2. Vehicle Manufacturers
It ia the vehiele manufacturers who eoabine (their own or
someone else's) engines with a chassis to fabricate the final
product needed by the heavy-duty vehicle user. This final product
is a bus, single unit truck, or a tractor for pulling trailer
units.
Tables III-H and III-J show the doasstic factory sales umbers
for trucks and buses respectively during 1977. It is clear that
sow firms concentrate on producing trucks of a certain weight
class while others produce the entire spectrua. In 1977 trucks
built by Ford, Of (Chevrolet and QIC), Dodge, and IHC appeared in
nearly every claaa. Qf and Ford dominated the market in elaoat
every category and accounted for 282 and 251 respectively of total
heavy-duty salea. Along with Dodge and IHC, they produced all but
a few of the vehicles with GVWs below 26,000 pounds. Moat of each
of theae {Manufacturer* a trucks are gasoline-powered, using their
own engines.
International Harvester is the largest producer of Class VII
and VIII (26,000 pounds GVW and above) vehicles, and overall is
fourth (behind Of, Ford, and Dodge) in the production of heavy-duty
trucks. As noted earlier, ISC alao produces both gasoline and
diesel engines.
The rest of the heavy-duty vehicle manufacturing industry
consists of firss which account for less than five percent of total
truck production. These firas concentrate on the production of the
"heavy heavies1', the Group VIII trucks (33,000 pounds GVW and over)
that are used primarily for long haul work. Duplex is a division
of the Warner and Swasey Coapany. FWD is a privately owned coapany
specialising in the production of custoa built trucks used pri-
marily by owner-operators. Duplex and FW produce an expensive
truck package that is custoa built to the buyer's specifications
and produced in limited quantities. Mack, aa aentioned in the
heavy-duty engine manufacturers description, produces heavy-duty
engines end Class VIII heavy-duty trucks. The White Motor Corpor-
ation repreaents "White", "Autocar" and "White Western Star" while
also producing agricultural and construction equipaent. Other
30
-------
Table III-H
1977 U.8. Truck Sales
8,501-
10,001-
14,001-
16,001-
19,501-
26,001-
33,001
10,000®
14,000
16,000
19,500
26,000
33,000
& over
Total
Ford
51,811
2,355
—
1,521
53,934
11,193
17,549
138,363
Chevrolet
53,935
—
—
1,795
32,908
1,031
2,997
92,666
Dodge
19,256
56,344
11,892
814
2,933
435
—
91,479
IHC
1,602
—
8
__
38,127
9,536
27,847
77,120
CMC
750
2,049
—
1,569
22,367
3,565
12,570
53,870
Mack
—
—
—
—
—
100
22,684
22,784
Kenworth
—
—
—
—
—
—
12,111
12,111
Freight liner
—
—
—
—
—¦
—
9,741
9, 741
Peterbilt
—
—
—
—
—
—
9,324
9,324
White
—
—
—
—
—
639
7,876
8,515
Jeep
6,184
—
—
—
—
__
—
6,184
Brockway
—
—
—.
—
~
—
798
798
Western Star
—•
—,
—
—
—
—
1,150
1,150
Autocar
—
.—
—
—
—
1,044
1,044
Diamond Reo a/
—
—
—
—
' —-
5
5
FWD
—
—
—
—
—
—
182
182
Miac. f
9,212
119
—•
17
1,347
396
1,662
12,753
Total
538,089
ij Diamond Reo is no longer producing trucks.
bj Miscellaneous includes imports, Divco, Oshkosh, etc.
e ° estimated
Source: Automotive Mews Market Data Book, April, 1978.
-------
GVW Bange Ho. of
Manufacturer
Type
(lb*.)
Sagine
Models
Autocar
4x2
c,
35,000
D
5
6x4
C
46,000-85,000
D
11
6x4
C
54,000-85,000
0
3
Chevrolet
4x2
C, SC, COS FC
4,900-33,000
D, 6
38
4x4
C
6,200-10,000
6
10
6x4
C, SC, COS
35,400-50,580
0, 6
21
Crane Carrier
4x2
COS
41,000-49,000
0
3
6x4
C, SC, COS
35,400-140,000
D
11
6x6
COS
65,000-134,000
D
7
Bodfg
4x2
C, V
4,600-14,500
G
17
4x4
C, CH
6,100-11,000
G
5
Fabco
6x6
Other
30,000
G
11
Ford
4x2
C, SC, COS, V
6,000-35,000
D, G
1
4x4
C
6,010-7,000
G
5
6x4
C, SC, COS
39,000-81,000
D, G
17
FWB
4x4
c
35,000-47,000
9
7
6x6
c
50,500-86,000
D
10
8x6
c
60,000-76,000
D
5
10x6
c
73,000-76,000
D
2
10x6
c
as
4x2
C, SC, COS, Van
4,900-33,080
D, G
56
4x4
C
5,350- 7,700
G
5
6x4
C, COS
39,000-81,580
D, G
17
TUG
4x2
C, SC, COS, CH
14,800-39,000
D, G
30
4x4
C, SC,
17,000-42,720
D, G
4
6x4
C, SC, COS
35,900-73,160
D, G
26
6x6
C, COS
53,200-63,720
S
3
Kemrorth
4x2
C, COS
30,000-53,200
D
2
Mack
4x2
C, SC, COS
29,000-49,000
D
6
6x4
e, SC, COS
44,500-64,000
D
Mack lejward Div.
4x2
C, COS
—
D
3
6x4
c, COS
—
0
4
Harmon
4x2
c, COS
66,000-
D
6x4
c, COS
80,000-
D
2
32
-------
GVW Range
Manufacturer
ZZES.
(lbs.)
ZSfc
M&racn
4x2
C, COS
66,000
D
6x4
C, COS
80,000
D
Oshkosh
4x2
C
31,000-44,000
D
4x4
—
46,000-50,000
D
6x4
c
34,000-80,000
D
6x6
c
57,000-88,000
J>
PeterbiIt
4x2
c, COS
37,000
D
6x4
c, COS
46,000-85,000
D
Walter
4x4
c, COS
37,320-53,800
D
White
4x2
C, SC, LC, COS
41,000
D
6x4
C, SC, LC, COS
62,000
D
Freightliner
4x2
C, CGI
41,000
D
6x4
c, COS
62,000
D
Western Star
4x2
C, LC
29,000-49,000
D
6x4
C, LC
44,000-75,000
0
No. of
Models
Abbreviations:
C ¦ Conventional SC ¦ Short Conventional
LC ¦ Long Coamtioul GGE ¦ Cab Over Ingiai
FC ¦ Forward Control V * fan
CH • Chassis
0 ¦ Diesel G • Gasoline
Scarce: Chilton's Aatonotive Industries. April 1977.
33
-------
Table III-J
1977 B.S. Bus Sales
(Including School Bus Chassis)
8,500- 10,001- 14,001- 16,001- 19,501-
10,000 14,000 16.000 19,500 26,000
26,001-
33,000
33,001
& Over
Total
Chevrolet
— — — ' —
3,810
—
—
3,810
QIC
— — — —
2,807
320
192
3,319
Ford
— — — 126
6,866
—
—
6,992
IfiG
— — — —
15,439
37
—
15,476
IM/Geaeral
1 — — — —
—
—
482
482
Dodge
— — — —
251
— .
—
251
Others
— -- — _
188
1,150
1,338
TOTAL
126
29,173
545
1,824
31,668
Source: FS-3, 1977 MVMA data.
"34
-------
manufacturers of Group* VII aid Till heavy trucks include lleaworth
(PACCAR) and Peterbilt (PACCAR). These manufacturers specialis® in
custom-built HDs which are primarily procured by individual
owner-operators Cm opposed to fleets).
Many different types of trucks are produced by the vehicle
manufacturers listed in Table III-H. Table III-I lists each of
these manufacturers and described for each the type of vehicle
produced. While the vehicles on the list represent standard
models, many of the trucks sold are "custom built", where the user
specifies to the vehicle builder the special characteristics the
vehicle vast have.
In contrast to the production of heavy-duty trucks, bus
manufacturing is limited to only larger companies in the transpor-
tation manufacturing industry. As one can see from Table III-J,
IXC, CM end Ford are the priaary producers of intercity, transit
«ad school bus ehsisis in this country. For none of these com-
panies is the tele of buses. critical to the financial success of
the firs.
4 brief look at the employment picture in Che industry shows
that 763 manufacturers of truck end but bodies (including light-
duty trucks) employed 40,796 people in 1976, and the 292 firms
building truck trsilers employed 20,697. (Appendix B gives ehe
number of eaployees in the aejor vehicle and engine manufacturers.)
D. Users of Beaw-Saty Vehicles
As Section A of this chapter notes, most heavy-duty
vehicles are used for CMMrcitl puposas. The types of trucks
used to Met the transportation needs of various enterprises are as
diverse as the needs themselves. Basically, however, these trucks
move some coamodity from one point to another.
Table III-K lists some of the types of products moved by
trucks and other mane of transport and the percentage (by weight)
that each ntans of transport carries. Though ehe data is semnwiiat
outdated, ie is interesting to see the fractional distribution of
freight and how it is transported. As of 1972 nearly half of the
commodities listed were shipped by truck, and in 1977 trucks
carried atoost 24Z of all intercity freight.3/
Trucking can be divided into two types of carriers, local and
intercity. The rule of thumb is that local carriers are those who
conduct 50Z or more of their business in a metropolitan area. The
intercity (line haul or over-the-road) carriers conduct local
pickup and delivery between metropolitan areas. Local carriers
accounted for $57.3 billion in freight transportation expenses end
intercity carriers 946.S billion in 1973.
3/ Motor Vehicle Facts and figures, 1978 MVMA data.
35
-------
Table III-K
CoMdities Shipped by Mode of Transport
Tone Tons/Hi lea
Motor
Private
Totsl
Motor
Private
Total
oup
Carrier
Truck
Truck
Rail
Other
Csrrier
Truck
Truck
Rail
Other
st ft Dairy Products
41.7%
39. 12
80.8 X
18.82
.42
54.32
17.2%
71.52
27.82
.62
nned, Frosen ft Other
20.3
23.0
43.3
50.7
6.0
18.3
9.5
27.8
66.8
5.4
ood Products
ndy, Cookies, Seversges
25.7
58.4
84.1
15.4
.4
28.8
25.8
54.6
43.1
2.2
obacco Products
sic Textiles ft Leather
61.4
27.7
89.1
9.7
1.2
61.0
21.0
82.0
16.1
1.8
roducts
parel & Related Products
69.4
15.6
85.0
8.5
6.5
67.0
9.5
76.5
13.4
10.1
per ft Allied Products
28.0
17.9
45.9
51.7
2.3
18.9
5.6
24.5
73.8
1.5
sic Chenicals,Plastics,
30.1
12.1
42.2
48.6
9.2
21.6
4.7
26.3
63.1
10.5
ynthetic Rubber & Fibers
uga,Paints § Other
38.6
15.7
54.3
37.8
7.9
32.0
8.4
40.4
44.3
15.2
henical Products
troleua ft Coal Products
16.0
8.4
24.4
9.7
65.8
3.4
1.6
5.0
7.9
87.1
bber ft Plastic Products
59.1
15.2
74.3
24.4
1.2
56.8
9.3
66.1
32.1
1.8
mber ft Hood Products,
16.2
36.3
52,5
45.8
1.6
7.6
10.7
18.3
76.8
4.9
xcept Furniture
rniture ft Fixtures
41.4
34.7
76.1
22.0
1.9
39.9
20.5
60.4
37.1
2.5
one, Clay 6 Glass
47.2
23.7
70.9
21.9
7.2
36.6
11.3
47.9
45.3
6.7
roducts
iaary Iron ft Steel
44.4
6.7
51.1
43.7
5.2
35.9
4.8
40.7
51.6
7.7
roducts
iaary Nonferrous Metal
31.4
15.1
46.5
51.6
1.9
23.4
7.7
31.1
67.2
1.6
roducts
bricated Metal Products
55.3
25.1
80.4
17.3
2.3
60.1
13.0
73.1
23.3
3.6
tal Cans ft Misc. Metal
44.1
17.8
61.9
36.8
1.3
40.3
7.1
47.4
50.5
2.1
roducts
dustrial Machinery,
59.4
18.9
78.3
19.6
2.0
75.7
8.9
84.6
12.3
3.0
xcept Electrical
chinery, Except Elec^
53.4
17.7
71.1
26.5
2.3
49.7
8.9
58.6
37.7
3.6
rical and Industrial
nminication Products
64.5
12.4
76.9
13.0
10.0
59.9
5.6
65.5
18.0
16.5
Parts
-------
Tons Tods/Milea
Motor
Private
Total
Kail
Motor
ft vate
Total
Group
Carrier
Truck
Truck
Other
Carrier
Truck
Truck
Rail
Electrical Products
49.3
14.1
63.4
35.0
1.3
46.0
8.4
54.4
43.2
& Supplies
Motor Vehicles &
37.3
3.0
40.3
59.3
.4
17.4
1.0
18.4
80.9
Equipaent
Transportation Equip-
23.9
54.8
78.7
19.5
1.8
30.3
43.1
73.4
24.0
ment Except Vehicles
Instruments, Photo
63.8
10.9
74.7
20.9
4.4
53.9
5.7
59.6
34.4
Equipaent Hatches &
Clocks
TOTAL ALL SHIPPER GROUPS
31. IX
18.31
49.4*
31. it
18.82
20.9X
6.8X
27.7%
42. OX
Total all Shipper Groups
Except Petroleua and Coal
35.7X
21.32
57.OS
38.4X
4.5%
28.6%
9. IX
37.7X
56.9X
Source:Motor Vehicle Facta and Figures, 1976
Data froa 1972 Coaaodity Transportation Survey
- 0.8. Bureau of Census.
-------
Another way of examining the trucking industry is to distin-
guish between private ownership end "for hire" trucking. The
trucks in "private11 fleets sre under the control of each particular
company for the shipment of their own goods, trucking not being
their principle business. Examples of "private" truck owners are
the various utility companies (e.g., Bell Telephone Systea)
or retail stores that own their own delivery trucks; and manufac-
turers of consumer products who sake deliveries to retail concerns
are private truck owners.
In contrast, "for hire" trucks are used by companies or
individual owner/operators whose business it is to transport
soaeona else's freight.4/ Examples of firms in this latter cate-
gory are United Parcel Service, Roadway Express, Consolidated
Freightways, and the various movers of household goods (United Van
Lines, North American Van Lines, Allied Van Lines). Some com-
panies, like Berts and Ryder, are in the business of renting trucks
for use by others.
"For hire" trucks accounted for about 4Z of the trucks in us*
in 1974. Over fifty percent of these trucks were combinations
(tractor-trailer) most with five or more axles (see Table III-L).
To remain competitive with alternative mtans of transport,
intercity carriers work on a small margin over costs. Costs for
drivers are about 30Z of the total. Cost of equipment account for
another 9.0Z of the total and operating costs (fuel/maintenance)
about 11Z. In 1974 there wire approximately 2,800 Class 1 and II
motor carriers. Finally, employment in the trucking industry
amounted to 9,052,000 people in 1973 (AXA estimate).
Heavy-duty engine exhaust emission regulations will, of
course, also apply to buses. As an example of how this segment of
the vehicle population is made up, in 1974 there were about 20,000
buses being operated in the U.S. by 950 intercity transit bus
companies, employing none 49,000 people. There were also 48,700
buses being operated by local transit companies. Most of these
transit buses are equipped with diesel engines. School buses,
however, account for the overwhelming number of buses on the roads.
In 1974 over 227,800 publicly-owned buses, and 128,500 privately-
owned buses were in operation. They accounted for almost 80
percent of all buses on the road and wire nearly all gasolina-
powered.
E. Conclusion
We have seen the picture of U.S. heavy-duty transportation to
be a complex array of vehicles and engines, of various types and
V American Trucking Trends: 1975, &XA.
38
-------
Tabla III-L
"For Hire" Tracks la Us« (1974)
Single Unit True lea
2 Axlas 361,324 39.4
3 Axles 42,063 4.6
Subtotal 403,387 SO"
Coafeiaaeion Tracks
3 Axles 66,831 7.3
4 Axles 139.216 15.2
5 or more 306,774 33.3
Subtotal 512,821 7CT
Total Trucks for Hire 916,208 l60.0
Total Trucks la Ose 23,480,577
Z Trucks Oted for Hire 3.9%
Sourc«: American Trucking Treads 1975, (AHA) based on
1972 Census of Transportation Rata, Department of CoosMrce.
39
-------
sices of manufacturers, and of end uses. The present workings of
this complicated system take advantage of public-owned roads to
move a full quarter of intercity freight and consume 41 of the
nation's energy.5/ let, since the sales, the applications, and the
products themstfves in the heavy-duty industry are ever-changing
entities, it should be no surprise to «e« the picture change as the
industry responds to the pressures of consumer needs, corporate
finances, sad government regulation.
37 Motor Vehicle Facta and Figures, M7MA, 1978.
40
-------
CH4FTE1 17
EKVIEOHMEBTAL IMPACT
A. Background
The Clean Air Act as asended in 1970 contained aany provi-
sions aimed at removing harmful pollutants from cha air we breathe.
Among other things, the Act called for the creation of Rational
Ambient Air Quality Standards, expressed as the maximum allowable
concentrationa a particular pollutant could reach in the air.
Theett levels vera to be set such that there would be no danger to
public health and welfare. 1/ To date, aabient air quality stan-
dards have been set for fwe pollutants: particulate natter,
sulfur dioxide CS©j), carbon monoxide (CO), nitrogen dioxide
(HOj) and photo chemical oxidants (of which hydrocarbons (HC)
is the sain precursor). Of these five pollutants, mobile sources
are major contributors to the total pollutants emitted for three:
EC, CO, sod !IOx.
Although sigaficant improvements have been made in air quality
since 1970, a review of air quality asnitoring data aakiis it clear
that additional reductions in EC, CO, and BOx emissions will be
necessary if msbient air quality goals set by Congress in the Clean
&ir Act are to be achieved.
Air quality monitoring data for CO show that in 1973 ft least
65 Air Quality Control legions (AQCR's) experienced violations of
the 8 hour (10 milligrams per cubic meter) CO ambient standard. In
1974, 43 AQCR'g were in violation of the standard. Since no
monitoring data are available for smaller, less urban cities, the
CO air quality problem indicated by the monitoring data may be
understated.
Bydrocarbons react with sunlight to form photo chemical
oxidants. The ambient air quality standard for oxidants is 160
microgrKS per cubic ceter (msxiana one hour concentration not to
be exceeded more than once per year). Monitoring data for 1973 and
1974 reveals that at least 79 AQCt's experienced violations of the
one hour ambient standard in one or both years.
1/ Information on the health effects of the EC, CO, and HOx
pollutants which are of concern in this Regulatory Analysis will
not be discussed in this report since chey are well documented
elsewhere. For a summary of this data* aa well aa citations to
other reports on heelth effects of EC, .CO, and HOx, see Chapter 3
of nAir Quality, Noise and Eealth," Report of a Panel of the
Interagency Task Force on Motor Vehicle Goals Beyond 1980, March
1976.
4]
-------
For NO*, air quality monitoring data freest 1972-1974 show chat
16 AQCR's experienced annual concentration in excess of the fabient
standard of 100 micrograms per cubic meter. Another 12 cities had
annual HO* concentrations of greater than 801 of the standard.
At least 4 of these cities were expected to exceed the national
standards in 1975. 2/
Current monitoring data confirms the continuing air quality
problem On March 3, 1978, EPA published ia the Federal Register a
listing on a State-by-State# pollutant-by-pollutant basis, of the
attainment status of every area of the Hation (43 FR 8962). This
information, compiled by the respective States and reviewed by SPA,
represents the most accurate picture available of the nation's air
quality status as of the adoption of the Clean Air Act Anandasnts,
That data indicates that of 3215 counties or county equivalents
covered by these designations, 607 (19Z) are classified as nonat-
tainsent for photochemical oxidant, 190 ( 62) are classified as
nonattainmeut for carbon monoxide, and 8 (0.2Z) are classified as
aonattaiament for oxides of nitrogen. Honattainment status indi-
cates that the given area fails to meet the primary national
smbieaC air quality standard (HAAQS) for the pollutant under consi-
deration.
Since the U.S. population is not uniformly distributed, but
rather is concentrated in urbanised areas, the above geographically
based figures are not representative of the proportions of popu-
lation actually exposed to excessive mbient pollutant concentra-
tions. Indeed, it is the very fact of urbanisation which haa led
to ouch of our air pollution problems. For example, the nonattain-
aent sreas for oxidant include 103 out of & total of 105 urban
areas in the U.S. with populations greater than 200,000 (the
exceptions being Honolulu, Hnraii, and Spokane, Washington). This
represents m exposure of over 100 million people.
Clearly, there is a great need to reduce pollutant (or pollu-
tant precursor in the case of oxidant) emissions in the urban areas
of the U.S. . So long as large numbers of people continue to be
exposed to concentrations in excess of the HAAQS, further emission
reductions must be sought.
Mobile sources have been recognised for soma time as major
sources of hydrocarbons (oxidant precursors), carbon nonoxide and
oxides of nitrogen. Light-duty vehicles in particular have been
the focus of considerable control work since the late I960's.
However, as light-duty vehicle emissions grow smaller, other source
categories such as heavy-duty vehicles grow in proportional signi-
ficance. The wisdom of controlling heavy duty vehicle emissions is
evident when these emissions are pieced in the context of other
sources of these sma pollutants.
2/ Ibid, p. iv.
42
-------
On a nationwide basis, nobile sources emicced an escimaced 11
million eons of hydrocarbons, 81 mil lien cons of esrbon monoxide
and 9 million cons of oxides of nicrogen ia 1975.5/ However, in
order co. properly assess nobile source missions and* their control,
it is best to look at urban areas ehere historically the IMQS
contraventions have occurred. In chit way a truer prospective of
the air quality impact of sobile sourest can be obtained, ic is in
these urban areas chat improvements are needed.
For Che purpose of this analysis, 48 urban regions were
selected for EC analysis, 26 regions for CO and 14 regions for if Ox.
While not all regions violating the standards are included, Che
selected areas are considered representative of the rsnge of urban
conditions desired. Figures IV- A, IV-E and If-C contain breakdowns
of HC, CO and HOx emissions into various source categories for the
selected regions. These figures give the 1975 emission levels
along with projected levels out to 1995.
For hydrocarbons, mobile sources represent approximately 341
of the urban amissions (Fig. IV-A). With current regulations this
percentage is expected to decline to 243 by 1995. By that tins,
some reduction in other HC sources will elso have occurred.
Mobile source carbon aonoxide emissions represent 76X of the
urban emissions. This mlount is expected to decline to 59% by
1995. $o significant changt in stationary source missions is
expected for 09. However, CO problems are often attributed to
high localised concentrations during periods of high traffic
density eo that etatioaary source* have minimal impact on these C9
air quality problems.
Figure IV-C indicates that HOx emissions will be fairly
constant for the forseeable future. Mobile sources and power
plants aske up Che major porcion of HOx emissions.
Light-duty vehicles (passenger cars) conCribuCe the major
portion of mobile source HC, CO, and HOx Missions. The 1975
emission levels from light-duty vehicle and ocher mobile sources,
and projecCions of Che fuCure urban emissions are given in Figures
IV-B, IV-E, and IV-P. The figures give a general overview of die
conCribuCion Co air pollucion chac each class of vehicles is
expecCed Co make chrough 1995, and of Che discribucion of Che
burden of control of amissions from all mobile sources. From theee
figures it can be seen chat emissions from light-duty trucks and
heevy-duty vehiclee will grow in proportion to emissions from
light-duty vehicles. This apparent inequitable distribution of the
burden for reducing mobile source emissions can be in part account-
3/ "Environmental Impact 8tatment and Economic XmpacC Analys is,
ttevised Heavy-Duty Engine Regulations for 1979 and Later Model
Tears", EPA, 8/4/77.
43
-------
SOURCE: "Air Quality Analysis of 1983 and 1985 Mandated
Heavy-Duty Vehicle Emission Standards', EPA, August 1978.
-------
28.
24.
20.
Millions
of
Tons
16-
12
a
4
MOBILE
Industrial
Other
762
12Z
11Z
\
\
73Z
142
13Z
64Z
I9Z
17Z
1975
1980
Figure IV-B
Annual Carbon Monoxide Emissions
For 26 Urban Areas
S8Z
22Z
20Z
1985
YEAR
im
5 91
22Z
20Z
93T
SOURCE; "Air Quality Analysis of 1983 and 1985 Mandated
Heavy-Duty Vehicle Emission Standards", EPA, August 1978.
-------
Figure IV-C
Annual NOx Emissions For 14 Urban Areas
4 -
O*
Millions 3
of
Tons
Mobile
Power
Plants
Fuel
Industrial
Other
391
27%
15%
J2L
15%
34%
29%
16%
JiX.
17%
29%
30%
31%
17%
M.
18%
31%
17%
tU£
17%
1975
1980
1985
YEAR
1990
1995
SOURCE: "Air Quality Analysis of 1983 and 1985 Mandated
Heavy-Duty Vehicle Omission Standards", EPA, August 1978.
-------
Figure IV-D
Mobile Source Hydrocarbon Emissions
For 48 Urban Regions
5.
Millions
of
Tons
3,
2-
HD Diesel
HI) Gas
LD Truck
22
LD Vehicle
6%
142
V-.
\\
782
\v »
1975
\
82
152
742
K
\
NX
52
\
HE
202
662
62
£
22*
mm
622
72
JUL
21Z
632
1980
1985
YEAR
1990
1995
SOURCE: "Air Quality Analysis of 1983 and 1985 Mandated
Heavy-Duty Vehicle Emission Standards", EPA, August 1978.
-------
Figure IV-E
Mobile Source Carbon Monoxide
Emissions For 26 Urban Areas
•p-
00
24
20
16j
2%
Millions
of ,
Tons
12
8 .
HO Diesel
HD Gas
LD Truck
LD Vehicle
7%
14%
77%
\
1975
2%
\
9%
16%
73%
41
20%
29%
48%
1980
1985
YEAR
1990
1995
SOURCE: "Air Quality Analysis of 1983 and 1985 Mandated
Heavy-Duty Vehicle Emission Standards", EPA, August 1978.
-------
Figure IV-F
Mobile Source NOx Emissions
For 14 Urban Areas
2H
v©
Millions
of
Tons
1 -
1975
IID Diesel
19Z
X.
HD Gas
w
23Z
LD Trucks
9Z
\
32Z
52
'¦ .
29Z
31Z
V
10Z
% *
\
. v..
7Z
'Nv
bx
7i
_ ——"
10Z
'V
10Z
11Z
'
LD Vehicle
672
62Z
54Z
51Z
•
52Z
1980
198S
YEAR
1990
1995
SOURCE: "Air Quality Analysis of 1983 and 1985 Mandated
Heavy-Duty Vehicle Emission Standards", UPA, August 1978.
-------
•d for by the past need co concentric* control efforts on the
primary sources of mobile source pollution where potential gains
were the highest.
It is evident from the figures tbat for all three pollutants
heavy-duty vehicles represent a growing proportion of emissions.
For hydrocarbons, heavy-duty vehicles go from SI of the total in
1975 to 16Z in 1995. For carbon monoxide the figures are 9Z in
1975 and 24% in 1995. Thus, control of heavy-duty engines is
extremely important in any overall strategy for reducing emissions
sufficient to meet ambient air quality standards. The remainder of
this chapter will address the environmental impact which would
result from imposition of heavy-duty engine emission control
strategies considered as part of this rulemaking.
B. Primary fagact
1. Reduction in Seavy-Duty Engine Emissions
As was noted in Chapter III, heavy-duty vehicles may be
equipped with either gasoline fueled engines or diesel engines
depending on ehe needs of the user. The use of a dieeel engine, as
opposed to a gasoline engine, in heavy-duty vehicles is also
important from an eaissions point of view because the missions
characteristics of the two engines differ. Basically diesel
engines have very low levels of HC and (X) emissions, below the
levels of the current Federal emission standards for heavy-duty
engines. HOz emissions on the other hand, for uncontrolled diesel
engines are high relative to gasoline engine HOx emissions.
Diesels also emit smoke consisting primarily of unburned carbon
present in mail particules. Gasoline engines do not. But gaso-
line engines do have higher HC and 00 emissions than do diesels.
The primary reason for the different emission characteristics
of diesel and gasoline engines is explained by the way each type of
engine functions. With gasoline engines, the fuel and air are
mixed in the carburetor prior to passing into the engine cylinder.
The ®are or less homogenous air/fuel mixture is admitted into the
cylinders via « throttle plate, which is varied in position by the
operator to control engine power, before it paases through the
intake manifold to the individual cylinders. The air/fuel ratio of
the mixture which enters the cylinder tends to vary at different
power conditions, with excess fuel under ion conditions and excess
air under others. In the engine cylinder an ignition source (spark
plug) must be provided to get the combustion started, since gaso-
line air mixtures have high minimum ignition eemperatures. The
compression ratio must be low enough to avoid detonation, (or
random auto ignition} which is another basic characteristic of
gasoline-air mixtures. The effects of these constraints on pollu-
tant emissions is that carbon monoxide and hydrocarbons tend to be
relatively high, being primarily associated with engine operating
50
-------
modes «c which Che mixtures are sanswhat on eh« nxcess fuel 3id*.
Hydrocarbons also result from "quenching** of the combustion reac-
tions because of contact between the gasoline-air mixture and
relatively cool surfaces of the combustion chamber. Nitrogen
oxides are relatively high coo, because of the high peak combustion
chaster temperatures inherent in the relatively rapid combustion
process of prasixsd gasoline and air.
Diesel engine operation differs in sany ways from that of the
gasoline engine, fuel and air are not mixed prior to entering the
engine cylinder* and there is no spark plug since the type of fuel
used has ignition characteristics such that it can be ignited by
the heat of compression as long as the compression ratio is high
«nough. Therefore, unthrottled air alone is inducted into the
engine through the intake valve. Engine power is controlled by
varying fuel flow only, with the fuel injected under pressure
directly into the' coquet ion chsaber at the proper time for igni-
tion to begin. Fuel continues to be injected and burned concur-
rently under highly stratified local air/fuel mixtures. The
overall fuel/air mixture, however, is always on the excess air sid&
to assure that enough oxygen is available near the fuel spray to
support combustion. Compression ratios to achieve spontaneous
ignition tend to be such higher than for gasoline engines, roughly
16 to 21. Becauaa of these high coapression ratios, diesel engines
have higher thermal efficiencies than gasoline engines which,
combined with the fact that there are no pressure losses associated
with having a throttle valve in the inlet system, give thsm supe-
rior fuel cof&swption characteristics. As to taissions, the excess
air conditions result inherently in relatively low carbon monoxide
and hydrocarbon emissions, but the high coapression ratio tends to
cause diesel engines to have nitrogen oxide emission characteris-
tics of roughly the sams magnitude as gasoline engines. The smoke
from diesel engines is caused by the initially unmixed nature of
the fuel and air in the diesel combustion process. This may also
result in objectionable odors in diesel exhaust that are not found
in gasoline engine exhaust*
Considerable work has been done within 1EPA in sn attempt to
determine accurate emission factors for mobile sources. This work
depends heavily on in-use vehicle testing under IPA's Emission
Fsctor Program. To answer the question of how well vehicles
perfozm in actual use, EPA has administered a series of exhaust
emission surveillance programs. Test fleets of coasmnr-owned
vehicles within various major cities are selected by model year,
sake, engine size, transmission, and carburetor in such proportion
as to be representative of both the normal production of each model
year and the contribtuion of that model fear to total vehicle miles
travelled. In the ease of heavy-duty vehicles, fuel type and gross
vehicle weight were also key items in the stratification scheme.
The data collected in thes® programs are analysed to provide
51
-------
mean rales ions by aodtl-yeir ~•hiele in each calendar year,
change in emissions vieh the accumulation of mileage, change
in emissions with the accumulation of age, percentage of vehicles
complying vieh standards, and effecc on emissions of vehicle
parameters (engine displacaent, vehicle weight, etc.). These
surveillance data, along vieh prototype vehicle test data, assembly
line test data, and technical judgment, form the basis for ehe
existing and projected mobile source emission factors. 4/
A complicating factor in assessing heavy-duty Mission factors
arises from the change in test procedure from 9 mode to transient
testing which accompanies the proposed new standards. Baseline
emiaaion factors are all derived from the existing test procedure,
sad existing test data. Since rollback calculations depend upon
ratios, the emission rates for 90% reduction in emissions used to
assess air quality impact are derived from the same baseline.
However, this means that the numbers uaed may not correspond to the
final standards derived from the transient test data. The only
significant difference this could make would arise if the transient
test data changed the sixe of heavy duty emissions notably in
relation to other mobile and stationary sources.
Preliminary baseline transient test data available at the tiae
of preparation of thia draft statement indicate that at the high
amission rates of pre-eontrolled engines, the transient and 9-aode
emissions give compatible grams per mile amission rates. 1969
emission rates used for the environmental assessment are 24.2
(HC)/274.4 (G0)/8.8 (BO*) grams per mile. Transient test results
from 12 baseline engines give sales weighted emission rates of
19.9/216/8.9 g/mi. As discussed in Chapter FI, the divergence
between 9-mode and transient data becomes important at lower
emission rates (such as those associated with the proposed stand-
arda). The tranaient test procedures will be necessary to realise
a true 90S reduction as called for by the 1977 Amendments, and as
used to develop thia environmental impact assessment.
Emission factors are intended to reflect actual emissions from
in-use vehicles, and as aucb are not, in general, the sane as the
vehicle emissions standards. Since the performance of emission
control systems will deteriorate over time, new vehicles generally
have emission levels below applicable standards to enable th«a to
mast standards ovar their entire useful life. 5/
4/ A complete presentetion of mobile source emission factors,
Including future use projections, can be found in EPA-400/9-78-006,
"Mobile Source Emission Factor* - Final Document,n March 1978.
5/ 50,000 miles or 5 years for light-duty vehicles and trucks,
?0,000 miles or 1500 hours for heavy-duty gasoline powered vehicles
and 1009000 miles or 3000 hours or 1000 hours at full load for
heavy-duty diesels.
52
-------
(In tin; other hniul, .is vehicles j:«', 3 curtain percentage wilt
be maladjusted or experience emis ion control system failures.
This means Chat although a properly :d justed vehicle will aeet the
allowable standards, the average emission rate for the whole fleet
may exceed that level. Through this process of vehicle deteriora-
tion, some of the benefit of my standard is. lost. The amount of
loss depends upon the amount of maintenance required for the
emission control system (the- more maintenance required, the more
chance .for neglect) plus the emission rate associated with malad-
justment or failure of emission controls. Implementation of an
Inspection Maintenance (I/M) program will reduce the number of
vehicles with excess emissions and thereby improve the effective-
ness of applicable standards.
To establish deterioration factors applicable to HOC engines
for the proposed 1983 standards it was necessary to extrapolate
maladjustment and failure conditions from LDV data, sines catalyst
technology has not yet been used in HOC vehicles. Data from which
to derive these rates are extremely limited. Catalyst equipped
vehicles have not been in use long enough to develop reliable
figures for their long term performance. In addition, application
in HDG vehicles could well be significantly different -in terms of
system durability. Therefore, there is a high degree of uncer-
tainty in the deterioration rates chosen. It will be important to
keep jehis fact in mind since we shall see that the deterioration
races' have a major impact on the emissions benefit to be realized
from the new regulations. Malfunction races of 52/10,000 miles and
failure rates of 3Z/10,000 miles were used. Diesel engines, being
inherently low emission engines, have no significant deterioration
factor.
•To compute an overall emission factor for any given calendar
year when deterioration factors are involved, it is necessary to
account for vehicle mileage accumulation rates and the age mix
expected in the on-the-road fleet. The appropriate emission rate
is applied- to each fraction of the fleet, and they are summed into
a composite.
To evaluate the impact of the 1983 standard we can compare the
composite emission factors for 1969 with (a) those in 1995 assuming
no new standards beyond 1979, and (b) 1995 with the new standard:
Heavy-Duty Gasoline Composite Emission Factors
1969
g/mi
Baseline
g/mi (2
79 stds
1995
below 1969)
*83 stds
HC
CO
NOx
35
301
9
10.8 (69Z)
245 (19%)
9 (02)
10.6 (702)
lil (632)
9 (02)
53
-------
lnm«*
-------
T;il» h« IV
Heavy Duty Gasoline Compote Emission Factors
1969 1995
g/ml g/oi (% below 1969)
*83 stds - 1983 stds -
Basellag '79 stds maximum deterioration optimum case
HC '35 10.8 (69Z) 10.6(70%) 2.7(921)
CO 301 245 (19Z) 111 (632) 27 (91Z)
NOx 9 9 <0Z) 9 (OZ)
It should be noted that the class of heavy-duty vehicles, as
used in the 1977 Clean Air Act Amendments, includes- a portion of
the class of vehicles analyzed in this package as light-duty
trucks. Final emission standards for light-duty trucks are being
considered in another rulemaking package, but for purposes of air
quality analysis it was necessary to estimate the degree of control
to be expected for light-duty trucks. For this purpose, standards
representing approximate equivalent stringency to light-duty
vehicle standards were used; These standards are 0.46 (HO/4.1
(C0)/1».2 (NOx) g/mi. The air quality analysis for heavy-duty
vehicles is not sensitive to small changes in these standards such
as might occur during development of final LOT standards.
2. Reduction In Urban Emissions From Heavy-Duty Vehicle#
As new heavy-duty vehicles are put into use and older
ones Retired, emissions of the average heavy-duty vehicle on the
road trill decrease. . Using sales projections, usage data, data on
average vehicle survival and emission factor data on heavy-duty
vehicles discussed above, urban emissions of HC, CO and NOx from
the total in-use populations of heavy-duty vehicles have been
projected through 1995. Figure IV-G compares the projected HC and
CO urban emissions from mobile sources for each of the three eases
of Table IV-A applied to the urban areas identified earlier.
The impact of deterioration rates is immediately evident. For
hydrocarbons, the new standards produce almost no change in emis-
sions for heavy-duty gasoline engines. However, as discussed
above, EPA anticipates several factors which will greatly reduce
deterioration, and the optimum case where the average of ail
vehicles meets the standards clearly indicates the possible gain.
It is worth noting that the optimum case does not as&utne zero
emission deterioration rates, which would be unreasonable. Since
new vehicles or engines certify well below standards, expecting the
average of all vehicles to equal the standards inherently allows
older vehicles to exceed the standards. For the optimum case, HC
emissions are reduced an additional 66Z and CO emissions 72Z
beyond the case with uncontrolled deterioration. In order to keep
55
-------
Figure IV-G
1995 Mobile Source Projected Urban HC and GO Emissions
w»
m
2 «
Millions
of
Tons
HD D
HO G
LD T
LD V
1995 Hydrocarbon
7%
102
13%
70%
*79 stds
+
LOT
Control
4%
101
14%
72Z
\ '
\\
V •
* * .1
\ v
Millions
of
Tons
v.;
V, 13%
:\
70%
7%
11%
'83 stds '83 stds
max deterior- optima case of
ation for all niDlnm deterior-
categories ation for all
categories
2 .
HD D
1© G
LD T
LD V
5%
24%
15%
57%
1995 Carbon Monoxide
\\
\
*79 stds
+
LIST
Control
SOURCE: "Air Quality Analysis of 1983 and 1985 Mandated Heavy-Duty
Vehicle Emission Standards", EPA, August 1978.
M
12%
17%
165%
\
19%
58%
11%
12%
*83 stds 1 83 stds
mx deterior- optimum case oi
ation for all minimum deterii
categories ation for all
categories
-------
heevy-duty vehicle emissions in proper prospective, end since it is
likely thet sny I/M for heavy-duty would include light-duty vehi-
cles and trucks as well, the option cess is essumed to affect
light-duty in the sane fashion as heavy-duty (the average of all
vehicles equals the standards). In the air quality analysis the
effect of light-duty snd heavy-duty vehicles will be separated.
Expressed as a percentage of the 1995 aobile source emissions
for the base case of oo new heavy-duty regulations, the iapact of
the 1983 heavy-duty stsndards is aa follows. Hydrocarbons are
reduced 3Z with full deterioration and 11Z for the optima case.
Carbon monoxide ia reduced 13Z with full deterioration and 21Z for
the optimum case.
3. Ambient Air Quality Iapact of Regulation
Using the eaission rates previously discussed* an anal-
ysis was done of the air quality iapact in each of the selected
regions.6/ The Modified Rollback aethod waa used for oxidant and
CO to project future air quality improvements for each region. In
addition, the Empirical Kinetic Modeling Approach (EXMA) was also
used for oxidant. The EXMA procedure hes been developed by EPA in
an attempt to provide an improved analysis of the relationship
between oxidant and precuraor emissions while evoiding the com-
plexity of photochsmical dispersion models.7/ There is uncertainty
over the epplicability of EXMA, so that both* EXMA and rollback were
used to provide a range of possible air quality impacts.
In preparing the eir quality projections, baseline emission
rates for verious source categories were taken froa the Rational
Emissions Data System (BEDS), sad projections for future control
stretegies plus growth rates were aade. In combination with the
mobile source projections, this data allowed aa evalutation of air
quality improvementa to be expected. With both Modified Rollback
end the EXMA approach, the relative changes from strategy to
strategy are more reliable than predictions of absolute levels of
eir quality. Therefore, the results will be expressed as percen-
tage gains over baseline between various strategies.
The average air quality improvement for the 3 cases considered
previously are given in Teble IV-B. These ceses correspond to that
of no new heavy-duty regulations, 1983 stsndards with uncontrolled
deterioration, and the 1983 optimum case of the average of all
77 "Air Quality Analysis of 1983 and 1983 Mandated Heavy-Duty
Vehicle Emission Standards", EPA August, 1978.
JJ "Uses, Liaitstions and Technical Basis of Procedures for
Quantifying Relationships Between Photochemical Oxidants snd
Precursors", EPA-450/2-77-021a, US EPA, Research Triangle Park, NC,
November 1977.
27
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Table XV-B
Average Air Quality Percent Seductions
fro® 197S Base fear
Oxidant
(Modified Linear Bolltmck/SHiA}
Strategy
Case A
Case 1
Case C
Strategy
Case A
Case £
Case C
Bote:
Case A - 1W controlled to 1979 interim standards, LDT standard of
0.46 (HO/4.1 (C0J/1.2 (HO*) g/ni.
Case 1 - HDV changed to 1983 standards with a&xisum deterioration.
Case C - Application of 1983 HD? standards for opticus case of
mieiauEt deterioration for all mobile sources.
Source: "Air Quality Analysis of 1983 and 1985 Mandated
Bsawy-Duty Vehicle Emission Standards", EPA, August 1978.
1980 1985 1990 1995
10/5 28/12 37/16 46/22
10/5 28/12 38/17 47/23
55/33
Carbon Monoxide
1980 1985 1990 1995
17 44 55 58
17 45 58 62
80
58
-------
vehicles equalling standard! by 1995, which we will call eases A,
B, and C, respectively. Ho values appear for case C before 1995
because of the assumption that the case C conditions will not be
attained until that date.
The modified linear rollback and EKMA models differ by approx-
imately e factor of 2 for oxidant reductions. However, they each
indicate nearly the aaoe percentage gain for caaes B and C over
case A. For example, both methods indicate an improvement of 1
percent in oxidant in 1995 when the 1983 regulations are imple-
mented (case B from ceee A), and a further improveaant of 8-10Z is
generated for the optimum cese when all vehicles have minimum
deterioration. By examining the emission reductions for light-
duty versus heavy-duty in Case C, the heavy-duty contribution to
the case C gain can be estimated at 1-1.3Z. Thus, overall improve-
ment in air quality for oxidant from implementing the 1983 heavy-
duty regulations will be approximately 1-2Z in 1995.
Table IV-B indicates that carbon monoxide will be improved 4Z
by the heavy-duty regulations. There is an additional 18Z for the
optimum ease affecting all sources. As above, the heavy-duty
portion for the optimum case improvement is estimated at 2.3Z.
Thus, overall improvement in air quality for carbon monoxide from
implementing the 1983 heavy-duty regulations will be approximately
4-tZ in 1995.
. The significance of a percentage gain in air quality in texms
of progress toward attainment of standards depends upon the origi-
nel levels. 7or example, a 2Z improvement in eir quality may be
sufficient to bring e region that ia already cloae to the standard
into compliance, whereas in a region experiencing very high levels
(relative to the standard) that 2Z would represent a totally
inadequate reduction. In a region already meeting the standards,
such a further gein would not be necessary. The question could
then be posed: "How many areas originally exceeding air quality
standards are brought into complience by implementing the new
emission standards?" In Table IV-C the air quality improvements
are analysed in this faahion.
Conaidering the oxidant results first, there are marked
differences between the regional analysis of Table IV-C and the
previoua percent reduction analysis of Table IV-B. Both the
modified rollback end EKMA indicate no detectable effect of imple-
menting the 1983 standards (case B) before 1995. In 1995, the two
methods differ coneiderably on the impact to be expected. EKMA,
which in terms of percent improvement had shown about one-half the
improvement of rollback, indicates no reduction in the number of
regions exceeding the HAAQS when the 1983 stsndarda are implemented
with uncontrolled deterioration ratea. On the other hand, rollback
indicatee about a 2Z improvement for this caae. For the optimum
ceae (caae C) , EKMA projects a 13Z reduction in the number of
regiona exceeding the NAAQS. Of this 13Z, 1.6Z can be attributed
9
-------
Table IV-C
Percentage o£ Regions Originally Violating
Air Quality Standards Brought Into Compliance
Strategy
Case A
Case B
Case C
Strategy
Case A
Case B
Case C
Notes:
Case A - HDV controlled to 1979 interim standards, LDT stan-
dard of 0.46 (HO/4.1 (C0)/1.2 (NOx) g/ai.
Case B - HDV changed to 1983 standards with maximum deterior-
ation.
Case C - Application of 1983 HDV standards for optimum case of
minimum deterioration for all mobile sources.
Source: "Air Quality Analysis of 1983 and 1985 Mandated Heavy-Duty
Vehicle Emission Standards," EPA, August 1978.
Oxidant
(Modified Linear lollback/EKMA)
If 80
1985
1990
1993
0/0
6/0
19/0
29/2
0/0
6/0
19/0
31/2
62/15
Carbon Monoxide
19S0 1985 1990 1995
0 40 68 68
0 40 68 72
96
60
-------
to httvy-dutf •mission reductions and 11.42 to LDV and LOT.
Rollback hen predicts a 312 gain, of which 3.72 can be attributed
to heavy-duty emission reductions. The expected overall reduction
in the number of regions exceeding the HAAQS for oxidant from
iapleaenting the 1983 heavy-duty regulations is therefore 0-62 in
1995. The implementation of X/H is the biggest factor in producing
that range. Regional analysis indicates that control of deteriora-
tion rates is more important than did the air quality percent
reduction anelysis. legional analysis also indicates thst there is
e greater potential maximum gain to be reelised from the 1983
ataadarda than did the percent redaction analysis.
Similar concluaiona can be drawn for the case of carbon
monoxide. Once again, no improvement is noted until 1995. In
1995, there is a 42 gain from implementing the standard with
maximum deterioration. Then is a further reduction of 242 for the
optimum ease, which can be broken down into 3.12 from HD and 20.92
from LEV and LOT. The expected overall redaction in the number of
regions exceeding the SMQ8 for carbon atonoxid* from implementing
the HD regulations is therefore 4*72 in 1995. This is a somewhat
greater potential gain than indicated by the percent reduction
analysis.
The 962 nduction indicated for case C merits further examina-
tion. Of the 26 regions analysed for CO, all except one were
projected as coming into compliance for the optimum caae. la that
one region (Horth Alaska, including Vairbanka), the stationary
sources alone exseed the allowable amission* which would bring the
region into compliance. Therefon, no mobile source progrsm could
produce compiifnce. However, review of the emission inventory for
this ngion indicates a clearly snosnloue situation in that thia
region is experiencing the worst air quality problem in 1995, but
has missions which are between one and two orders of magnitude
below the other urban areaa. Determining the reeaon for the
discrepancy is beyond the scope of this present study; except to
note that aside from that region the optima; case is projected ae
sufficient to eliminete ell violet ions of the CO HAAQS in 1995.
C. Potential Secondary Environmental Impacts of This Regulation
1. Sulfuric Acid Emissions
~ recent SPA report (§/) provides an ia-depth review of
the current statue of sulfate missions from mobile sources. On e
nationwide baais, mobile sources represent less then 22 of the
total saen-mede sulfur oxides. However, with the introduction of
the cetelyst/sir pump technology to control EC and CO emissions
from mobile sources, there exists the potentiel for a significant
8/ Emissions of Sulfur-leering Compounds Prom Motor Vehicles end
Aircraft Bnginee. Report to the United States Congress, IfA-600
/9-78-028, August 1978.
a
-------
source of aobile related sulfate emissions in the form of sulfuric
acid aerosol. Vhile of negligible magnitude on a regional basis,
mobile source sulfuric acid emissions could produce a significant
localised urban sulfate concentration in urban street canyons, or
congested urban freeway situations. Moreover, mobile source
sulfates differ from stationary source sulfates in that they are
asitted in the form of a fine sulfuric acid mist «nd the particles
tend to remain near ground level.
The increase in sulfate emissions due to the use of oxidation
catalyst/air pump control systems on passenger cers and light-duty
trucks has been of considerable concern to EPA. In pre-sadel year
1973 non-catalyst systems, most of the fuel sulfur leaves the
vehicle after combustion as 30^. In oxidation catalyst/air
pump systems used on recent model fear automobiles and light-duty
trucks, a small amount (less than 10Z) (§/) of the sulfur is
converted by the catalyst to SOj. The 30^ combines with
water in the exhaust to form sulfuric acid aerosol. Eeevy-duty
catalyst technology has not yet been used on in-use vehicles, and
so little is known about sulfate emissions from these engines.
Extensive efforts have been made within goversBaat and indus-
try to improve the inforaacion 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 forwmd
in catalyst/air pttmp cystomat and to develop other low sulfate
producing catalytic control system such aa the 3-way catalyst.
According to current data, the extent of sulfate emissions is much
less than early concerns bad anticipated. Major adverse health and
welfare effects fro© aobile source sulfates are unlikely.10/ Table
IY-Q indicates sulfuric acid emission rates for sever*! aobile
source categories.
Table IV-D
Approximate Mobile Source Sulfuric Acid Emission Rate*11/
Source Category
H2S04 Conversion
Sate(Z)
H2S04 (mg/siie)
lon-catalyse Car
Oxidation Catalyst Car
3-Way Catalyst Car
Light-Duty Diesel Car
Heavy-Duty Diesel Truck
Aircraft Gas Turbine
1
10
3
2
2
0.03
1
10-15
4
9
50
K/A
97 Ibid
TO/ Ibid
IT/ Ibid
62
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The use of catalyses on heavy-duty gasoline engines resulting
from implementing the new gaseous standards ia not expected to
increase present nubile source sulfate emissions significantly or
to present a future problem. Considering the Bach larger sulfate
emissions already associated with diesel trucka, plua the fact thst
equipping HD gasoline vehicles with catalysts would increaae the
number of all catalyst equipped vehicles by only approximately 22,
there eppears to be no reason to expect a significant change in
roadside sulfate levels.
2, Particulate Lead Emissions
Although no attempt will be made to quantify benefits, it
ia clear that the use of unleaded gaaoline in heavy-duty gasoline-
fueled tracks after 1983 will further reduce the ambient concen-
trations of lead particulate in urban air. Since heevy-duty
gasoline-fueled vehicles use about 10 percent of the smount of
gaaoline uaed by personal traaaportation vehicles the air quality
improvement in urban air could be significant.
3. Water Pollution, Hoise Control, Energy Consumption
Complying with the heevy-duty engine regulations is
expected to have negligible impact on water pollution, or on the
ability of the heavy-duty vehicle menufacturere to meet present and
future noise emission regulations. Implementing catalyst tech-
nology can be done with no fuel economy penalty.
D. Irreversible and Irretrievable Commitment of Resources
Assuming that catalytic converters sre used to meet the 1983
etandards, an additional committment of platinum end palladium aa
would be required over and above that needed for light-duty vehi-
cles and light-duty trucks which elreedy employ catalysts. The
incremental demand in 1990 from equipping all HD gasoline vehicles
with catalytic converters would be approximately 41,000 troy ounces
of plantimim and palladium. This would represent less then a 3.5%
increase in overall demand and should have no significant impact on
supply.
E. Relationship of Short-Term Uses of the Environment to Mainte-
nance and Enhances*.;* of Long-Term Productivity
More stringent control of heavy-duty engine emissions than
that currently imposed will result in substantial decreeaes in
hydrocarbon and carbon monoxide emissions from this source. This
reduction will be beneficiel end eid in the long-term etteinment
and maintenance of acceptable air quality.
6
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CHAPTER ¥
COSTS OF comoL
this chapter trill examine the coses of meeting the emission
standards EPA proposes for 1983 and later es'>da 1 year heavy-duty
engines. Coses of meeting Che standards are of four main types:
purchase, installation, and check out of nev teat facilities
designed for use with the proposed test procedures; development,
production, and installation of nev or redesigned emission control
systems; certification testing to assure that the standarda are
being Mt; and, the purchase and installation of SEA facilities and
SEA testing. For gasoline-fueled engines, the primary cost is that
for mission control systeas. For Diesel engines, the primary cost
is expected to b# for test facility modifications. Also, there are
costs associated with in-use inspection and maintennce programs,
which might be found necessary to ensure continued compliance of
catalyst-equipped gasoline-fueled engines, and with the anticipated
need for unleaded fuel for these engines.
The. engine manufacturer must bear the initial costs for
emission control hardware, certification, test facility modifica-
tion, and SEA facilities aid tests. These costs will be added to
the price of the engines it sells to vehicle manufacturers or uses
in its own trucks if it also produces vehicles. These costs in
turn will be passed on to its customers, the truck owners and
operators. Truck operators must also bear the costs, if any, of
increased operating (fuel/maintenance) costs which may be caused by
the emission control technology. State governments will pass the
costs of inspection and maintenance programs onto operators or
owners of gasoline-fueled heavy-duty vehicles as well, if such
programs prove necessary.
A. Cost to Engine Manufacturers
I. Emission Control System Costs
EPA anticipates that manufacturers of gasoline-fueled engines
will adopt oxidation cataiyst/EGR-based emission control systems to
comply with the 1983 standarda. Some of the components for such
systems are already present on these engines, e.g., air pumps and
Ed systems. Other components will have to be added, while some
present components will have to be upgraded. EPA estimates that
added system costs will average about 1171 per gasoline-fueled
engine. The breakdown of this cost by component is shown in Table
V-A. The coaponent cost for the catalyst and the added cost for
replacing the conventional ignition system with a high energy
ignition system has been estimated using the data and methodology
in a cost estimation report prepared under contract for EPA,1/ The
1/ "Cost Estimations for Emission Control Related Components/
Fystess and Cost Methodology Description," LeRoy B. Lindgren, H-ath
& Strong, Inc., March 1978, EPA-460/3-78-002.
64
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Table V-A
Component Costs for Gasoline-Fueled Engines
Component EPA Cost Est^^te
Pelleted Oxidation Catalyst $103 U
High Energy Ignition System 23
Exhaust System Material Improvements 25
Miscellaneous Modifications 20
3171
1/ Assumes catalyst volume equals engine CIO (450 CID taken as
near-worst case. Typical CIS ia closer to 380 cu* in.), precious
metal loading of 25 grama/cubic foot, platinum to palladium ratio
of 2:1.
65
-------
methodology vtt altered by setting vehicle (engine) aanufecturer1«
and dealer's profit markup to sero.2/ This is appropriate, since
the primary purpose of profits is to direct economic resources, end
the regulations will assuae this role. The cost for exhaust system
material improvement is the midpoint of the range estimated by EPA
ia its March 1976 Status Report.3/ the cost of miscellaneous
modifications is taken from the December 1976 Status Report.4/
Many emission control components in the Miscellaneous category can
be adopted from the mcnufacturer's own light-duty engine product
lines, at small cost. Although the costs taken from the 1976
Status Reports have not been adjusted for general inflation,
manufacturers should have achieved compensating relative cost
reductions since those estimates were made.
The $171 estimate for gasoline-fueled engines does not ex-
plicitly include an allowance for control system and calibration
development. However, EPA expects these costs to be small compared
to the $171 for hardware. Past experience with light-duty engines
should make the developsent task simpler than it wta when catalyst
systems were first placed on those engine. Further, msnufacturers
will have to develop relatively few calibrations, since they will
not have to develop optiaal calibrations for numerous combinationa
of chassis veriables (e.g., transmission, axle ratio, inertia
weight, road load), as they have had to do for light-duty vehicles
and light-duty trucks. The cost of facilities used for development
testing has been accounted for in the second section following, on
test facility modification costs.
Manufacturers * comments on gasoline-fueled engine control
costs in a California waiver proceeding before SPA generally
support the $171 estimate.5/ The proceeding concerned e set of
California standards that "would lead to about the ssea hardware
that EPA expects will be used to comply with the proposed 1983
Federal Standards. Ford said the cost of meeting the California
standards would be $130 to $300; Chrysler said $150; (21 said not
more than $500 for the final standards which included more SOx
control than contss^plated by EPA for 1983; and XBC eaid $395 to
$490. It can be expected that XHC would have the highest costs,
due to its mailer production volume.
2/ For a further discussion on the profit markup see Section D,
Socioeconomic Impact.
37 "Automobile Emission Control - The Current Status and Develop-
meat Trends Aa of March 1976," ECTD, April 1976.
4/ "Automobile Emission Control - The Development Status, Trends
and Outlook sa of December 1976," ECTD, April, 1977.
5/ "Analysis of Technical Issues Relating to California's Request
for Waiver of Federal Preemption with Respect to Exhaust Emission
Standards for 1979 and Subsequent Model Tear Heavy-Duty Vehicles,"
March 15, 1977, ECTD, Ann Arbor, Michigan.
66
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Ac present:, EPA baa less information with which co estimate
Che control system costs for diesel engines then for gesoline-
fueled engines. However* IFA believes that diesel engines ess be
brought into compliance with the proposed 1933 standards with
relatively minor changes to injectors and calibrations. For the
purpose of this cost analysis, a cost estimate of $25 per engine
has been. made.
The above estimates are based on limited testing with the
proposed test procedure, and are therefore preliminary. SPA will
reeonaider these astlaates in light of results from further testing
conducted after the publication of the HPBM and in light of rele-
vant coaMnts and - informstioa submitted to EPA during the public
cosaent period. Revisions may result from re-evaluation of either
the control technology needed to meet the standards or the cost of
specific control technologies.
2. Certification Costs
Certification is Che process in which EPA determines whether a
manufacturer's engines conform to applicable regulations. The
engine manufacturer must prove to EPA that it* engines are designed
and will be built such that they are capable of complying with
emission standards over their useful life. The certification
process begins by a manufacturer submitting to EPA aa application
for certification. Subsequently, two types of engines undergo
emission testing.
The first type of engine is the durability-data engine. 9nder
regulations proposed by SPA, each manufacturer will das if si the
entire test procedure used to calculate the deterioration factors
for it's own mgines. However, manufacturers must state that their
procedures follow sound engineering practices and specifically
account for the deterioration of ths EG! and catalyst systems snd
possibly other critical deterioration processes. The manufacturers
would submit deterioration factors, based on Che definition of
useful life, in each case where current certification procedures
require testing of a durability-date, engine. If a manufacturer
desires not to test each durability engine, but chooses to allow
the results of one durability-date engine test to be applied to a
second engine, it must be explained why the test results are
expected to be representative for both engines. Beyond these
requirements EPA would not approve or disapprove the durability
test procedures used by the manufacturers.
Eaission-data engines are Che second type. One to four of
these will be chosen for each durability-data engine. They will be
physically similar to the durability-data engine and by assumption
would deteriorate in a similar manner. In a procedure designed by
the manufacturers the emission-dsts engines will be operated for
125 hours before the emission test. The deterioretion factor from
67
-------
the durability test will be multiplied by the 125 hour emission
teat results to predict whether the emission data engines would
meet Che standards for their useful life.
Under current regulations, if a manufacturer does not change
its engine design from one year to the next, it say request that
SPA "carry over" the emission test results of the earlier year's
tests and obtain certification that way. This is done to remove
the pointless coat of recertifying the amm engine in the same way
each year when no design changea have occurred that could impact
emissions. , In 1983, however, emission atendarda, teat procedures,
and some or all engine deaigna will be changing and this will
require manufacturers to undergo a complete ^certification of all
engine models, aa outlined above.
Further, EPA. ia proposing a change to the regulations which
would reduce the subsequent use of durability data "carry-over" as
it haa been practiced in the paat. This change would apply in
cases ia which a manufacturer has not significantly changed the
design of its engines with a new model year and consequently
engine* produced in a previoua modal year are representative of
thoae that will be produced in the aew model year. Under the
change, EPA would be allowed to require the manufacturer to accu-
mulate service on enginea produced in the previoua year, rather
then on prototypes, and to do so with the enginea inatalled
in vehicles and operated on the road, rather than mounted on an
engine dynamometar in a teat cell. Enginea would have to accumu-
late; in-vehicle aerviee in auch numbers and under such conditions
aa approved by EPA. In order to prevent the poaaibility of the
ia-chassis service accumulation teats being circumvented by fre-
quent, minor changes in engine family determinants, EPA ia pro-
posing that the Administrator make the final deciaion aa to whether
engines from the suceesaive model years ahould be grouped into the
same family-system combination.
In-uae service accumulation would be required to begin within
three months of convincing production. A 15,000 miles per year
minimum would have to be accumulated although the manufacturer
could accumulate mileage at a more rapid rate if deaired. When
30,000 milea ia accuaulated the deterioration factors determined
for initial certification would be replaced by those based on
in-service accumulation. These in-sarvice' testa would continue on
a yearly baais until the useful life is reached.
For the purpot t of thia coat analysis the following assump-
tions are made. In 1983 manufacturers will certify one emission
control aystets per engine-family resulting in one durability-data
engine per family aa well. EPA will select three emission-data
engines for each gaaoline-fueled family and two for each diesel
family*6/ Since each manufacturer will develop its own initial
6/ Larger-volume manufacturers only. It will be assumed that some
imailer-voluma manufacturers of diesel engines will have only one
emission-data engine selected per engine fraily, in accordance with
paat experience.
68
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certification procedures actual coses eo each aanufaeturer will
very. As a base estiaate EPA has aaeuaed that a manufacturer will
follow the current procedures established by SPA. For a gasoline
engine this is a 1500 hour period with a test each 125 hours plus 2
tests associated with achedultd aaintenance. For a dietel engine
this covers 1000 hours with e test aech 125 hours plus 2 tests
associated with scheduled aaintenance. In-service accuaulation for
the durability-data engines will begin with a 125 hour durability
test. After this test the engines will be installed in vehicles
for mileage accumulation. For this cost estiaate we will assuae
gasoline engines accuealate aileage at 20,000 oiles per year and
hm a useful life of 100,000 ailes. Diesel engines will accusm-
late 40,000 ailes per year and have a useful life of 200,000 ailes.
After in-service aceeilatitm begins, optional durability testing
will occur at 15,000 ailes and asndatory testing at 30,000 ailes
and one test during each year thereafter until the useful life is
reached. The in-service aeeuaulation vehicles, and the costs of
operating these vehicles will not be chargeable as certification
costs since these vehicles may be operated at a profit. Finally,
this set of assuaptions ignores the real poaaibility that a chassis
-based eaission testing procedure mmj be availeble for use by 1983
thus saving the engine reaoval and replaceaent cost during in-
service accuse letion.
In order to estiaate certification coats, unit costs oust be
known for each of the following: an eaission-date engine test
including the required 125 hours of service accuaulation and the
prototype engines pre-production durability test for both gaaoline
and diesel engines; one 125 hour durability test of a production
engine prior to in-chaasis service accuaulation; and reaoval,
testing, and re-installation of a production engine at the aileage
and tine intervals specified above for in-service accumulation.
Table Y-l gives SPA estiaetes of these costs for both types of
engines. Satiaatea are in 1978 dollars.
Tablea V-C and f-0 ahow the calculation of certification costs
for each manufacturer. The mxter of test operations of eech kind
required by each aanufaeturer depends on the nuaber of engine
faeilies it will certify in 1983. Soae Manufacturers have provided
SPA with estimates of the nuaber of foiilies they will certify in
1983. These estiaetes ha^e been used except in eaaee in which the
aanufaeturer requested that EPA not aaka die estiaate public. In
these cases, EPA hea instead used 1978 or 1979 ambers. 1978 or
1979 auabers have also been used for several low-vol»e manufac-
turers. Inforaation aabaitted during the public conent period
will replace these mashers where eppropriate.
3. Teat Facilities Modification
The proposed reguletions will require that aanufecturers
reaodel end/or purchese new engine dynaaeaeters, dynmoaeter
controla, constant voluae ssapling systeas, and analytical systeas.
69
-------
Table ¥-B
Pole Costs of Certification Tests XI
Test
Caso1ine-Fueled
Diesel
123 hour eaiss ion-dee a $10K
@ngine test.2/
Pre-product ion durabiltj $761
testing.3/
125 hour test of a 1983 $6.7K
production engine prior
to in-vehicle installation.
Removal, testing, end re- $14K
installation of e produc- (5 tests)
tion engine during in-
vehicle service accuau-
lation period.;--/
$15K
$56K
$6.SK
$19.21
(6 tests)
y Includes gaseous and saoke emissions.
tj The manner in which the 125 hour break-in period is carried
" out is at the aanufacturer' discretion.
3/ Msmma aenufacturers follow current EPA procedures, but this
*** is not mandatory.
4/ Includes an optional test at 15,000 ailes plus mandatory tests
at 30,000 ailes and at one fear intervals thereafter until the
useful life is reached.
70
-------
Table V-C
Gasoline-Pueled Engine Certification Coats for MY 1983 and Following
Manufacturer
1HC
Ford
Chrysler
GM
(a)
Nuaber of 1/
Engine PaailTes
and Durability-
Data Enginea
4
8
3
4
(b)
Total
Pre-produc t ion
Durabili ty-Data
Engine Test
Costs
$304K
608K
228K
304K
(c)
Total
In-Vehicle
Service Accusu-
lation Costs
$249K
497K
187K
249K
(d)
Nuaber of
Etoi ssion-Data
Engines
12
24
9
12
(e)
Total
125-Hour
Eniasion-Data
Engine Test Coats
9120K
240K
90S
120K
(f)
Total
Certification
Coat a
$673*
1345K
505K
673K
No tea:
(b) ¦ (a) a ($76K/durability-data engine)
(c) ¦ (a) a (3 engines/fsaily) a ($6.7K/triple 125-hour teat) ~ (a) a (3 engines/faaily)
) a ($14K in-vebicle testing, etc./useful life)
(e) ¦ (d) a ($10K/eaission-data engine)
-------
Table V-D
-4
Is)
Diesel Engine Certification Costa for MY 1983 and Following
(a)
Number of _1/
Engine Families
and Durability-
Manufacturer Data Engines
-------
Sobs manufacturers will haira Co remodel or build a ev teat cells as
mil m Co accoaaodate Che new teat equipment. There will also be
coses for developing testing software and computer hook-ups. These
requirements are the result of the revisions in the test procedures
and of the increase certification load anticipated for 1983.
(a) Dynamometers and Control Systems
Manufacturers vill need engine dynamometers for two
purposes, pre-production testing and (missions testing. Dynamo-
meters used for emission testing using the new transient cycle test
procedure vill likely have to he DC-electric dynamometers with
sophisticated control systems. Dynaaoasters used for pre-produc-
tion testing can he substantially siapler in terns of their control
systems, and can be either DC-electric or eddy-current modified by
the addition of a actor to permit const ant-speed aotoring. It vill
be possible to use an emission test dynaaoaeter to accumulate
service, but not vice versa. This difference in required capabili-
ties and cost leada EPA to anticipate that manufacturers vill
dedicate dynaaoaetars for aach purpose, rather than perform both
operations on the asm sat of dynaaoasters.
The nuaber of dynaeoaeter® of each type needed by each manu-
facturer has been estinted by starting with the mafrer of engine
families estimated for 1983 or, lacking a non-confidential esti-
aate, with the neefeer of 1978 dieael families and 1979 gasoline-
fueled families. Based on conversations vith manufacturers or on
historical ratios batvean nuaber of families and nuaber of develop-
mant-plua-certification dynaaoasters, the total nuaber of dynamo-
meters needed for 1983 vas estimated. This total van split between
emission test and pre-production testing dynaaoraatera by allowing
one emission test dynaasiseter per engine family plus one, unless a
aanufacturer indicated it planned to make do with fewer. The
remaining dynamometer a were taken to be pre-production teeting
dynaaoaatera. BM believes this aethod is conservative in that it
over eatiaates the nuaber of the aore axpeoaive eaission test
dynaaoaatera.
KM then inventoried the dynenoaeters now owned by the sajor
manufacturers, to identify vhere aodificaeions or additiona
will be required to mset their 1983 needs. Small volume manufac-
turers were treated by aaauaing worst ease needs for new equipment.
Unit costs for modifications and additions were also estimated
based on EM experience.
Tebles V-B and V-F show the resulting pre-production testing
dynamometers coats by manufacturer. Ho aanufacturer will need to
buy completely new pre-production testing dynamometers, but aost
vill have to aake modification.
73
-------
Table V - E
Pre-Production Dynamometer Costs Gasoline-Fueled Engines
No. of Engine No. of Dynos No. Available Total
Manufacturer Fami1ies in 1983 Needed Without Remodeling No. Bemodeled \J Cost
IHC 4 2 0 2 $200K
Ford 8 4 4 0 0
Chrysler 3 2 0 2 $20GK
CM 4 2 2 0 0
Notes:
1/ Cost each ¦ $100K. Includes new control system and motoring capability on all eddy-current dynsooiMter.
-------
Table V-F
Pre-Production Dynamometer Coats Diesel Enginea
No. of Engine
No. of Dynos
No. Available
Total
Manufacturer
Families in 1983
Needed
Without Hemodeling
No. Remodeled 1/
Cost
CM
12
6
0
6
9600K
Cummins
22
11
0
11
HOOK
Caterpillar
9
5
0
5
500K
Mack
5
3
0
300K
IHC
4
2
0
2
200K
Duetz
1
1
0
100K
Iauzu
2
1
0
100K
Uhite
1
1
0
1
100K
Piat
1
1
0
1
100K
Nissan
1
1
0
1
100K
Mercedes
6
0
3
300K
Mitsubishi
1
1
0
1
100K
Scania-Vabis
1
1
0
1
100K
Volvo
1
1
0
1
100K
Notes:
\J Cost each ¦ $100K. Includes new control ayatem and motoring capability on old eddy-current dynamometer.
-------
Tables V-G and ?-l presaat EPA1 is estimates of the need for «nd
cost of new and aodified dynaaoaaters for eaission testing.
Manufacturers now using DC-electric dynaaoaaters vill have to
reside 1 these in either of two w«ys, depending on the dynaaoaater
aodels. If A as suae s chat all aanufacturers with a shortage of
DC-electric dynaaoaeters will purchase new DC-electric dynaao-
aaters and new control systems to fill the shortage. However, it
is possible that son* aanufacturers will be able to wroid the cost
of new DC-electric dynaaoaatera by finding a way to remodel old
eddy-current dynaaoaaters.
(b) Constant Voluaa Sampling Systems
Bo engine manufacturer presently owns any constant voluas
saapling (C7S) systeas suitable for use in testing heavy-duty
engines with the proposed test procedure. CVS systeas will be used
only for eaission testing. Sines one CVS unit can serve nore than
one eaission test dynasaneter, mm aanufacturers will need fewer
CVS units then they do eaission test dynaaoesters. Tables V-X and
V-J give SPA's estiaates of the nuaber and cost of CVS systeas that
will be required by each !i«aufacturer.
(c) Analytical Syseaas
Current analytical system uaed by engine aanufacturers
are desifgied for measuring pollutant concentrations in hot, raw
txfeaust. Under the proposed test procedure, CO, SOx, and gasoline-
fueled engine HC will be aeasured after being diluted with cool air
and collected in a sample bag. EPA anticipates that an existing
•ystea can be converted to the proposed requirements at less than
the cost of a sew systea. The cost depends on the type of ISO*
analyser in the existing systea. Also, because of the proposed
idle eaission standard, aanufacturers will need an additional raw
exhaust CO. analyser for use in the idle mission test. One new
raw C0« analyser will b* required with each analytical systea.
Tablee and V-L give the number of systma requiring conversion
and the total cost for each aanufacturer.
(d) Hew Structures and Remodeling of Existing Structures
S&m manufacturers indicated during conversations wieh
SPA that new dynaaoaaters and CVS systeas could not be accomodated
without new or reaodeled buildings. Table V-M and V-N list the
cost of new or reaodeled structures.
(a) Software and Computer look-Op
Manufacturers will need to develop new coaputer software
for use in unnoraalising engine opereting cycles, validating test
runs, and calculating test results. Soac aanufacturers now have
suitable coaputers at their facilities for this purpose, and others
76
-------
falsi# ¥~G
Emission Test Dpanosistgri and Control System Cost Gasoline-Fueled Engines
No. Remodeled 2/
No. of No. taidiled ij By Adding Computer
Manufacturer
No. of Engine
Families in 1983
Emission Test
Dynos Needed
By Adding Computer
Control System
Control
Control
-and New
Cabinet
No. Hit# 3/
Total
Coat
IHC
4
5
2
3
0
$905K
Ford
8
9
e
1
0
1035K
Chryaler
3
4
0
1
3
1495K
GH
4
5
3
0
0
SOGE
Notes:
If Cost each ¦ $10OK
2/ Cost each - $23SK
3/ Cost eech « $4201
-------
Table V-H
Emission Test Dynamometers and Control System Costa Diesel Engines
No. Remodeled 2/
No. of
No. Kemodeled lj
By Adding Ccaputer
No. of Engine
Emission Test
By Adding Computer
Control and New
Total
Manufacturer
Families in 1983
Dynos Needed
Control System
Control Cabinet
No. New 3/
Cost
GM
12
13
0
0
13
$6 HOE
Cummins
22
23
0
0
23
1OilOK
Caterpiliar
9
10
0
0
10
4700K
Mack
5
6
0
0
6
2820K
1HC
4
4
0
0
4
188 OK
Duetz
1
1
0
0
1
470K
Isuzu
2
2
0
0
2
940K
White
1
i
0
0
1
470K
Fiat
1
1
0
0
1
470K
Nissan
1
1
0
0
1
470K
Mercedes
6
7
0
0
7
3290K
Mitsubishi
1
1
0
0
1
470K
Scanis-Vabis
1
1
0
0
1
470K
Volvo
1
1
0
0
1
470K
Notes:
\J Coat each ¦ $100K
21 Coat each « $235K
2J Cost each ¦ $470K
OB
-------
Tabl V-I
Constant Voluae Sapling System Coat
Gasoline-Fueled Engines
Hunber of Rusher of 1/ Total
Snission Test CVS Systesa CVS
Manufacturer Dynos Required Coat
ISC 5 5 I60GK
Ford 9 9 1080K
Chrysler 4 4 480!
CM 5 3 360K
Notes:
1/ Cost each « $1201
79
-------
Table V-J
Constant Volum Sampling Sy»tea Coats
Diesel Engines
Number of Hu&ber o£ It Total
Emission Test CVS Systems Cfi
Manqfactorer Bynoa Required Cost
CM 13 7 112601
Cuoains 23 13 2340K
Caterpillar 10 S 900K
Mack 6 3 5401
IHC 4 2 360K
Duett 1 1 ISO!
Isuzu 2 1 laOK
White 1 1 180R
Fiat 1 1 180K
Nissan 1 1 1801
Mercedes 7 4 720K
Mitsubishi 1 1 180K
Scania-Vabis 1 1 1801
Volvo 1 1 180K
Motes:
1/ Cost each - $1801
80
-------
Table V-K
Analytical System Costa
Gasoline-Fueled Engines
00
Manufacturer
IHC
Ford
Chrysler
CM
Number of Chemilumi-
nescence Equipped J1/4/
Systems to be
Converted
Number of NDIR- 2/4/
Equipped Systems
to be Converted
Number of 3/4/
New Syatems
Total
Analytical System
Cost
5
0
0
$95K
8
0
1
216K
4
0
0
76K
3
0
0
57K
Notes:
\J Cost each " $19K
2J Cost each - $26K
3/ Cost each " $64K
4/ Coat includes $4K for a nev raw CO^ analyzer.
-------
Tabl« V-L
SB
Analytical Systn Conversion Costa
Diesel Engines
Hunker of Cheatlumi-
nescence Equipped JL/4/ Number of MDIE- 2/4/ Total
8y«t«sa to be Equipped 8ystema Number of 3/4/ Analytical System
Manufacturer Converted to be Converted Hew Systems Cost
GM 4 0 3 |3181
Cumins 0 0 13 962K
Caterpillar 0 3 0 93K
Mack 1 0 2 172R
IHC 0 2 0 62K
Duets 0 0 1 74K
Isusu 0 0 1 74K
White 0 0 1 74K
Fiat 0 0 1 74K
Nissan 0 0 1 74K
Mercedes 0 0 4 296K
Mitsubishi 0 0 1 74K
Scania-Vabis 0. 0 1 74K
Volvo 0 0 1 74K
Notes;
\f Cost each - $24K
If Cost each » $31K
3/ Cost each ¦ $74K
4/ Cost includes $4K for a new raw CO., analyser.
-------
Table V-M
Hew or lesedeled Structures Costa 1/
Gas o 1 ine-Fue led Engine;*
Manufacturer
IHC
Ford
Chrysler
CM
Costs to
Accomodate
CVS Systems
$350!
630K
280K
21 OK
Costs to
Accosmedate
Dynamometers
0
0
0
Total
Cost
S350K
630K
280K
2101
Botes:
1/ Eased on conversation with manufacturers.
83
-------
Table V-N
Hew or Besideled Structures Costs J
Ditsel Engines ~
Manufacturer
Costs to
Accmennilete
CVS Systi
Costs to
Aceonsdate
Dynaaoaaters
Total
Cost
CM
Cuanins
Caterpillar
Mack
IHC
Duets
Isusu
White
Fiat
Nissan
Mercedes
Mitsubishi
Sctnia-Vabis
Volvo
$4901
910K
350T
2101
140K
701
70K
70K
701
701
280K
70S
701
70S
$3000
0
350OK
300OK
20001
500K
1000K
SOCK
500K
500K
3500K
5001
500K
500K
$34901
910K
3850K
3210K
21401
570K
1070K
570K
570K
5701
37801
5701
5701
5701
Votes:
U Based on conversations with larger-vol
worst-case assumptions for SMaller-vol
acnufaeturer, and on
asnufacturers.
84
-------
can arrranye Cur uonsacrcial Cine shar n; service. In oither carte,
there are coses associated with coopu' »r hook-up to the test area.
Tables V-Q and V-P give EPA* s esti ites of these software and
hook-up costs.
4. Selective Enforcement Auditing Costa (SEA)
In addition to the emission standards proposed for 1983, EPA
is proposing the implementation of a production line testing
program for gasoline-fueled and diesel engines. This program,
known as Selective Enforcement Auditing, designed to ensure that
production-line engines will meet at least the emission levels to
which they are certified. This cost analysis assumes that a SEA
program for heavy-duty engines has not been implemented prior to
1983. The costs associated with the SEA program can be broken into
two main categories for both gasoline-fueled and diesel engines:
SEA test facilities and SEA test costs. In spite of the fact that
the SEA test facilities will be used for SEA testing only a small
fraction of each year, the total cost of the facilities will be
charged against the SEA program. It should be noted that this
allows the manufacturer to use these facilities for other purposes
most of each year.
(a) SEA Test Facilities for Gasoline-Fueled Engines
EM estimates that as a minimum each manufacturer will require
two completely- new dynamometer systems to meet SEA requirements if
it's «nnual sales volume surpasses 30,000. Thus, all four manufac-
turers will require at least two new dynamometer/test systems. A
dynamometer/test system, estimated to cost $1.23 million dollars,
includes a new DC-electric dynamometer, new analytical and con-
stant volume sampling systems, new structure(s) to house the entire
system and an allowance for computer hook-up costs. A cost suraaary
for SEA facility costs per manufacturer of gasoline-fueled engines
is found in Table V-Q.
(b) SEA Test Facilities for Diesel Engines
As a minimum, EPA estiamtes that each diesel engine manufac-
turer wiLl require two dynamometer/test systems if it's annual
sales volume exceeds 10,000. If the annual sales volume is less
than 10,000 then at least one dynamometer/test system will be
required. Each dynamometer/test system is estimated to cost $1.33
million dollars, and has cost allocations in the areas mentioned
for gasoline engines. Based on projected sales, EPA's estimates
for each manufacturer's SEA test facility costs are shown in Table
V-R.
(c) SEA Testing Costs for Gasoline-Fueled Engines
The actual testing costs incurred by a manufacturer are
85
-------
Table V-0
Software md Coaputer Hook-Up Costs
Gaaolins-Fualed
Software md
Manufacturer Book-Op Costs
X3C $1151
Ford 1501
Qjrysler 1251
Of 1251
86
-------
Table V-P
Software and Cosputer Iwak-Up Costs
Diesel
Software and
Manufacturer Hook-Up Costs
m $isoi
*>wint 175K
Caterpillar 1501
Mack 1231
TEC 12SK
Duets 100K
Isusu 100K
White 100K
Fiat 100K
Nissan I001
Mereedes 12SK
Mitsubishi 100K
Scaaia-Yabis 10QK
Volvo 10QK
87
-------
Table V-Q
Emission Dynamometer Costs for SEA Testing
Gasoline-Fueled Engines
Number of
Manufacturer Oynoa Required U Cose 2/
GM 2 $2.46 M
Ford 2 2.46 M
Chrysler 2 2.46 M
IHC 2 2.46 M
99.84 M
17 Each manufacturer with sales volume greater than 30,000
requires 2 dynamometers.
2/ Each dynamometer system includes a new DC-electric dynamometer,
3*tructure(s), analytical and testing equipment and coats I1.23M.
88
-------
Table V-R
Emission Dynamometer Coats for SEA Testing
Diesel Engines
Manufacturer
CuBBUU
GM
Caterpillar
Mack
IHC
Others 3/ (9)
Number of
Dynos Required \J
2
2
2
2
2
1
Cost 2/
$2.70 M
2.70 M
2.70 M
2.70 M
2.70 M
12.15 M
$25.65 M
T7 Assumes 2 new dynsmometers for each manufacturer unless total
sales volume is less than 10,000 in which case only one dynamometer
is projected.
2/ Includes costs for DC-electric dynamometer, structure(s), and
Tosts associated with analytical and testing equipment. Total cost
per dynamometer syatem is $1.35M.
37 Includes one dynamometer each for Isusu, Mitsubishi, Nissan,
Mercedes, White, Fiat, Scania Vabis, Volvo, and Deuts.
89
-------
dependent on some testing decisions mads by the manufacturer and on
the number of SEA# a manufacturer undergoes. For example, the
manufacturer decides, in advance, how many times (1-3) he vill test
each engine and the length of the break-in period prior to testing
(0 to 125 hours). The number of SEAs to which a manufacturer is
susceptible is primarily dependent on the annual sales volume. For
each 30,000 gasoline-fueled engine sold, the manufacturer is
susceptible to one SEA. The minimum number of SEA« to which a
manufacturer is susceptible is one, regardless of sales volume.
The possible number of SIM per gasolina-fueled engine manufacturer
is shown in Table V-S.
The actual cost per sudit is based on the formula:
Cost/Audit m (Cost/TestKTests/EngineKEngines/Audit)
Our cost analysis will be baaed on Che following set of assump-
tions:
(1) all audits are passed (12 engines tested);
(2) each engine is tested only once;
(3) each gasoline-fueled engine SEA test costs $1900 and each
diesel test costs $1330 (these costs cover engine selec-
tion and transport, a 24 hour break-in period, and
emissions testing);
(4) each test in the audit is completed in twenty-four hours
or less (excluding the break-in period which is assumed
to occur on mother dynamoaster, other than thoae used
for SEA testing);
(J) two full SEA tests are completed each 24 hour day (thus,
two SEA test cells are used for testing and two other
dynamometers are used for br«ak-in).
Therefore, a typical gasoline-fueled engine SEA will cost about
$22,800.
Using the cost per audit above and the "possible SEAs" shown
in Table V-S, the estimated SEA tasting costs for 1983-1987. per
manufacturer are shown in Table V-T.
(d) SEA Testing Costs for Diesel Engines
SEA testing costs for diesel engine manufacturers are for the
«ame areas as the gasoline-fueled engine manufacturers. At before,
some costs will vary, but each manufacturer is susceptible to an
SEA audit for each 10,000 engines sold or at least one audit
regardless of sales volume. The number of "possible audits" the
diesel engine manufacturers are subject to is shown in Table V-U.
The actual cost per audit ie based on the simple formula cited
previously, and the assumptions used in this cost analysis are also
90
-------
Table V-S
Huaber of "Possible SEA*" 1983-1987 1/ 2/
Gasoline-Fueled
Manufacturer
1983
1984
1985
1986
198?
GM
9
9
9
9
10
Ford
6
6
6
7
7
Chrysler
4
5
5
5
5
ISC
2
2
2
2
2
1/ Based on a projection of 1979 projected sale« and allowing one
**" audit for each 30,000 sold. Rousting of "possible audits" is
up to the next whole nsaber.
It The tesa "possible SS4#" includes only audits which are promp-
ted by sales woIum and does not include those far failure of
an 814 or other reason.
91
-------
Table V-T
Costs per Year for SEAn Testing 1983-1987 'U %j
Gasoline-Fueled "*
Total per
Manufacturer
1983
1984
1985
1936
1987
Manufacturer
GM
205.2K
205.2K
205.2K
205.2K
228 £
1,048.8 K
Ford
136.8K
136.8t
136,«
159.6K
159.6K
729.6 K
Chrysler
91.2K
114 K
114 K
114 K
114 K
547.2 K
£HC
45.6K
45.6K
45,61
45.6K
45.6K
228 K
TOTAL FEE TZAR $478.8K $501.61 $501.6K $524.4K $547.21 $2,553.6 K
ij Assumes that all "possible SEAs" are performed. This is a
worst case assumption.
2/ (12 engines/audit) x ($l,900/engine) x (possible audits froa
Table V-S).
92
-------
Table
fesfcer of "Possible SEAa" 1983-1987 1/ V
Diesel
Manufacturer
1983
1984
1985
1986
1987
Cumins
11
11
12
12
13
GM
8
8
9
9
10
Caterpillar
3
3
6
6
6
Mack
4
4
3
3
3
IHC
2
2
3
3
3
Others 2/
1
1
1
1
1
1/ Based on a projection of 1978 projected sales and allowing one
"" audit for each 10,000 sold. Hounding of "possible audits'* is
up to the next whole number.
2/ Includes one each for Isusu, Mitsubishi, listen, Mercedes,
^ White, Fiat, Scania fabis, Volvo and Oeuts.
3/ Th# ten Npossible SMs** includes only audits which are proap-
ted by sales velux* and does not include those for failure of
an SEA or other reason.
93
-------
Cke sane as for gasoline-fueled engines..- So, a diesel engine SEA
audit vill cose about $16,200.
Using a cose per audit of $16,200 and Che "possible audits"
shown in Table V-U, ehe estimated 1983-1987 SEA eeseing coses per
manufacturer are shown in Table ¥-¥.
5. Total Coses to Manufacturers
The four pares of ehe costs eo manufacturers (emission
conerol system coses, certification coats, test facility modifica-
tion costs, and SEA associated costs) are summarized in Tables V-W
and V-I. Costs are in 1978 dollars.
B. Cost to Users of Heavy-Duty Vehicles
1. Increases la First Sorts
The Added cost to engine manufacturers for control system
development and hardware, certification testing, test facility
modifications, and SEA costs will be pasned on to purchasers and
users of heavy-duty vehicles. The amount a manufacturer muse
increase the price of its engines in order to recover its expenses
depends on the timing of coses and revenues frora sales and on the
coat of capital (i.e., intereat) to the maaufacturers. Tables
V-Y and V-Z show the timing of costs that has been used to estimate
the average engine price increase. Test facility modification
costs are assuned to occur equally in 1980 and 1981. SEA facility
costs are divided evenly over 1981 and 1982. Other fixed costs in
1982 are for certification testing of prototype engines. Fixed
costs in 1983-1987 are for in-vehicle service accumulation and for
SEA testing. For simplicity, it has been assumed that the coats in
each year are incurred at the start of the year, and that revenues
from salea are received at the end of each year. EPA has also
mawmd that manufacturers face a 10Z cost of capital and that they
price their engines so as to recover their investment in five model
years, 1983-1987. Table V-M presents the expected average first
cost increases for the 1983-1987 period for both engine types under
these assumptions. The increase for gasoline-fueled engines is
$204, and $185 for diesel engines. The remainder of ehe coses
presented in ehis Costs to Users section are discounted at 10Z to
January 1, 1983 of the model year in which the vehicle is produced,
unleM stated otherwise.
2. Maintenance Costa
The use of 1983 control technology is expected to in-
crease maintenance costs only in that catalyst replacement may be
necessary during the life of gasoline-fueled heavy-duty vehicles.
The costs of catalyst replacement depend on the frequency of
detected failures and the cost of a replacement catalyst. EPA has
94
-------
Table V-V
Coses per Year for SE4a Testing 1983-1987 _1/ 2J
Diesel "~
Total per
Manufacturer
1983
1984
1985
1986
1987
Manufacturer
Cuaains
178.2K
178.2K
194.4R
194.4R
210.6R
955.8 R
Qt
129.6K
129.61
145.8K
145.8R
162 R
712.8 R
Caterpillar
81 R
81 K
97.21
97.2R
97.2K
453.6 K
Mack
64.8K
64.8R
81 R
81 R
81 K
372.6 R
HC
32.4R
32.4K
48.6K
48.61
48.6R
210.6 R
Others 3/
145.81
145.8K
145.8R
145.8K
145. M
729 R
TOTAL PER YEAR
$633.81
$631.8K
$712.8R
$712.8R
$745.2R
$3,434.4 R
IJ 4isuaes that all "possible SEA;." are performed. This is a
vorst case sasuaption.
2/ (12 engines/audit) x ($1350/engine) x ("possible audits" from
"" Table ¥-U).
3/ Aggregate of the costs if Isuzu, Mitsubishi, Nissan, Mercedes,
White, Fiat, Seania-Vsbis, Volvo and Deutc are each audited
once.
95
-------
Table V-W
Total Costs to Manufacturers Gasoline-Fueled Engines
Manufacturer
Emission Control
System Cost,
per vehicle
Certification
Costs
Test Facility
Modification Costs
for Certification
Test
Facilities
for SEA
SEA
Testing
1983-1987
IHC
Ford
Chrys ler
GM
$171
171
171
171
$673K
1345K
5G5K
673K
$2275K
311 IK
2656K
1252K
$24601
2460K
2460K
2460K
$ 228 K
729.6K
547.2K
1.048.8K
-------
Table V-X
Total Coats to Manufacturers
Diesel Engines
Emission Control
Test Facility
System Cost,
Certification
Modification Costs
Test Facilities
SEA Tests
Msnufsecurer
per vehicle
Costs
for Certificstion
for SEA
1983-1987
CH
$25
$1958K
$11,928K
$2.7 M
$712.8K
Cummins
25
3589K
16.297K
2.7 M
955.8K.
Csterpiliar
25
1468K
10.193K
2.7 M
453.6K
Msck
25
816K
7.167K
2.7 M
372.6K
1HC
25
653K
4.767K
2.7 M
210.6K
Duetz
25
149K
1.494K
1.35M
81 K
Isuzu
25
32 7K
2.464K
1.35M
81 K
White
25
149K
1,494k
1.35M
81 K
Fiat
25
149K
1.494K
1.35M
81 K
Nissan
25
149K
1.494K
1.35M
81 K
Mercedes
25
979K
8.511K
1.35M
81 K
Mitsubishi
25
149K
1.494K
1.35M
81 K
Scsnia-Vsbis
25
149K
1.494K
1.35M
81 K
Volvo
25
149K
1.494K
1.35M
81 K
-------
Table V-Y
Costs to Manufacturers by Period - Gasoline-Fueled \J
Fixed Costs
Manufacturer
1980 3/
1981 4/
1962 5/
1983 6/
1984-85 7/
1986 7/
1987 7/
Hardware Cost
per Vehicle
1983-1987
IHC
1138K
2368K
1654K
159.6K
79.6K
79.6K
79.61
$171
Ford
15561
2786K
2078K
364.8K
204.8K
227.6K
227.6K
$171
Chrysler
1328K
2558K
1548K
177.2K
140 K
140 K
140 K
$171
Of
626K
1856K
1654K
319.2K
239.21
239.2K
262 K
$171
TOTALS
$4648K
$9568K
$6934K
$1020.8K
$663.6K 2/
$686.4K
$709.2K
$171
TJ See text at B.l) for explanation.
2/ Per year.
3/ One-half of certification test facility modification costs.
4/ One-half of certification test facility modification costs plus one-half of SEA faclity costs,
5/ Includes total pre-production durability testing coats, emission-data engine coats plus
one-half of the SEA facility costs.
6/ Includes cost of 125 hour production engine test plus one in-vehicle test at 15,000 miles.
Each in-vehicle test is $2.8K. Also includes 1983 SEA test costs.
?/ Includes an in-vehicle test at 30,000 miles and at one year intervals thereafter, plus
SEA test costs.
-------
Table V-Z
Costs to Manufacturers by Period - Diesel If
Fixed Costa
Hardware Cost
per Vehicle
Manufacturer
1980 2/
1981 3/
1982 4/
1983 5/
1984 6/ 1985-86 6/
ifS? 6/
1983-19
CM
$5964K
$7314K
$2382K
$594.6K
$245.6K
$261.8K
$278 K
$25
Cumins
8149k
9499K
3242K
1030.2K
390.2K
406.4K
422.6K
25
Caterpillar
5097K
6447K
2124K
403 K
168 K
184.2K
184.2K
25
Mack
3584K
4934K
1780K
258.8K
112.8K
129 K
129 K
25
I1C
2384K
3734K
1694K
187.4K
71.4K
87.6K
87.6K
25
fieuts
747K
1422K
746K
55.2K
26.2K
26.2K
26.2K
25
Isusu
1232K
1907K
847K
94.2K
36.2K
36.2K
36.2K
25
White
747K
1422K
746K
55.2K
26.2K
26.2K
26.2K
25
Fiat
747K
1422K
746K
55.2K
26.2K
26.2K
26.21'
25
Nissan -
747K
14221
746K
55.2K
26.2K
26.2K
26.2K
25
Mercedes
4256K
493 IK
119 IK
249.2K
74.2K
74.2K
74.2K
25
Mitsubishi
747K
1422K
746K
55.2K
26.2K
26.2K
26.2K
25
Scaaicn Vabis
747K
1422K
746K
55.2K
26.2K
26.2K
26.2K
25
Volvo
747K
1422K
746K
55.2K
26.2K
26.2K
26.2K
25
TOTALS
$35895K
$487201
I18482K
$3203.8K
$1281.8K
$1362.8K7/ $1395.2K
$25
T7 8ee text at B.l) for explanation.
2/ One-half of certification test facility modification coats.
3/ One-half of certification teat facility modification coats plue one-half of 81A Caclity coats.
4/ One-half of SEA facility costs plus total pre-production durability testing coata and emission-
data engine coats.
5/ Includes cost of 125 hour production engine test plus one in-vehicle test at 15,000 miles.
Each in-vehicle test is $3.2K. Also includes 1983 SEA test costs.
1/ One in-vehicle test per year and SEA test costs.
JJ Per year.
-------
Table V-AA
Average Increases is First Coat
of 1983-1987 Model Tear Engines
Engine Type
Increase in First Cost J7
Gasoline-fueled
$ 204
Diesel
$ 185
Hotes:
y Aasuaes: equal first cost increases for all engines of a type
~ produced during 1983-1987 node! fears; emortixation of all
costs froat Tables V-T ad V-Z during 1983-1987 at 10Z interest;
cost incurred J an. 1 of year; revenues received Dec. 31 of
year; 1983-1987 sales fro* Table V-BB.
100
-------
estimated the frequency of detected failures and subsequent re-
placement conservatively, by assuaing (1) that the EPA's estimated
emission control "failure" rate of 3 percent per 10,000 mile
interval (see section (B)(1) of Chapter IV of this statement and
Reference 7J) is due entirely to catalyst failure, (2) that fail-
ures are detected immediately through inspection and maintenance
programs, and (3) the failure rate does not decrease as a result of
such programs, as it might if failures were caused by misfueling or
tampering. EPA has previously estimated the total life of a
gasoline-fueled heavy-duty vehicle to be 160,000 miles. It can be
shown that with the failure pattern from the emission factor
document and this total life, the number of replacement catalysts
needed to keep functioning catalysts on all of a group of vehicles
during their life is about 60Z of the number of vehicles in the
group. (Some vehicles need more than one replacement while others
need none, both by random chance.) The average truck or bus owner
or operator will then have to spend 60S of the replacement cost
during the working life of the vehicle. The replacement cost is
assumed to equal the cost of the original catalyst, about $103,
giving an average replacement expense of $36 per vehicle, discoun-
ted to January 1 of the model year.
The use of unleaded gasoline, combined with material improve-
ments in the exhaust system, will reduce maintenance costs associ-
ated with spark plug and muffler replacement. For light-duty
vehicles this savings has been estimated at roughly $81, expressed
in 1971 dollars.8/ For the purposes of this analysis roughly the
same cost savings will be assumed, or about $73 over the 14-year
life of a vehicle, discounted to January 1, of the model year.
3. Fuel Costs
EPA does not expect an increase in fuel consumption for
either gasoline-fueled or Diesel engines. Based on experience with
light-duty catalyst technology, there may be a reduction in fuel
consumption for gasoline-fueled engines. However, catalyst-equip-
ped gasoline engines will require unleaded gasoline, which can be
expected to cost more than leaded gasoline. Estimating a total
life of 160,000 miles, an average fuel economy of 4.6 miles per
gallon, and a price differential of 3 cents per gallon between
leaded and unleaded gasoline, lifetime fuel costs will increase
about $1739 (undiscounted). This is about a 1 cent/mile increase,
compared to a base fuel cost of 15 cents/mile when leaded gasoline
is 70 cents per gallon. It should be noted that while 5 cents per
gallon is reaaonably typical of the current leaded versus unleaded
7/ "Mobile Source Emission Factors - Final Document," March 1978,
EPA-400/9-78-006, Appendix E.
8/ "An Aasessment of the Effects of Lead Additives in Gasoline on
Emission Control Systems Which Might be Used to Meet the 1975-76
Motor Vehicle Emission Standards," Aerospace Corporation, November
5, 1971.
101
-------
price differencial, it is more Chan Che actual refining cost
differential. If market conditions change so as to force the prise
differential closer to the cost differential, the lifetime fuel
cost increase will he smaller than estimated here. The discounted
lifetime fuel cost increase is $1013.
4. Mandatory Inspection and Maintenance Coats
As explained in section (B)(1) of Chapter IV, it is
possible that in-use inspection and maintenance progress may be
needed to ensure the continued effectiveness of catalyst-based
emission control systems on gasoline engines. Such program would
be administered by the states and funded by fees charged to opera-
tors of heavy-duty vehicles in need of inspection. The purpose of
such program* would be to detect failed and badly deteriorated
catalysts and EGH systems and force their replacement. EPA esti-
mates that a program with this objective could he financed with a
$5 inspection fee. Assuming the worst case of annual inspection
over a fourteen-year useful life, the total cost to a truck or hue
owner would be $40 discounted to January 1, of the model year. The
cost of replacement catalysts has been discussed above.
5. ' Total fescs to Psers
To sunaarise, users of heavy-duty vehicles equipped with
diesel engines can, as a result of the statutory eaission standards
«nd accompanying procedure changes, expect to pay about $185 more
for 1983 eodei year vehicles than for comparable models bought in
1982, in 1978 dollars. Ko increase in operating costs for these
vehicles will occur. Assuming a 436,000 mile total life, the first
cost increase translates to an increase in operating costs of 0.043
cents per mile (undiscouated).
For vehicles powered by gasoline engines, the first cost will
increase by $204. Added fuel costs, catalyst replacement, and
inspection and maintenance fees, less savings on spark plug and
muffler replacement, will total $1016 (discounted) over the useful
life. The sum of first costs plus operating costs is equivalent to
about 1.2 cents per mile (undiscounted).
C. Aggregate Costs - 1979-1983
The aggregate cost to the nation of complying with the 1983
Federal heavy-duty engine mission regulations and the SEA program
consist of the sum of increased costs for new emission control; new
and modified test equipment and facilities; additional certifica-
tion costs; SEA facilities and testing; and unleaded fuel, replace-
ment catalysts, snd inspection fees for gasoline-fueled engines.
These costs will be calculated for a, five year period (1983-1987)
of compliance, but will include increased operating costs incurred
after 1987 by engines produced in the five year period.
102
-------
It oust be noted that calculating aggregate costs based oa a
five year period distorts the cost impact of the proposed regula-
tions. At the end of that five fear period, part of the initial
investment in new engine designs, nev certification, sad new and
remodeled teat facilities vill still exi®t and still be productive.
As just one example, the nev dynamometers required by manufacturers
have an expected life of about 20 years. The "salvage value" of
the 1983 investesnt could reasonably be subtracted free the five-
year aggregate costs. It vill not be, since the exact value of the
still-intact investment at the end of 1937 vill depend on the
maaufacturers ¦ product plans at that time, which are uncertain now.
It must also be noted that aggregate costs will be calculated
without considering the mors stringent HOx standard expected to be
promulgated for 1985. That standard will likely foree redesign and
recertification of at least soma engines. The cost of this has not
been considered here. When the 1985 HOx standard is proposed, its
cost impact vill be taken to be the cost increaae it cauaes over
the costs calculated here.
Finally, an mentioned earlier, the price differential between
leaded and unleaded gasoline used in this draft statement (5 centa
per gallon) is larger than the actual refining cost differential.
Therefore, part of the aggregate costs estimated here is actually
only a, transfer of income from vehicle operators to the petroleum
industry, rather than a cost burden on the nation as a whole. This
qualification is important, since the fuel cost penalty is a
substantial part of the estimated aggregate costs.
The five year costs of compliance are dependent, of course, on
the number of heavy-duty vehicles sold during that period with
either gasoline or diesel engines, and also on the mix of sales
between gasoline engine or diesel engine-equipped vehicles. The
accuracy and validity of projecting vehicle sales as far into the
future as 1987 is problematical, so cost estimates based on such
projections are also subject to considerable qualification.
For the purpose of this draft statement, growth rates of 2.6X
for sales of gasoline-fueled heavy-duty engines and 51 for sales of
diesel engines will be assumed. The resulting sales weighted
growth rate is approximately 3%. The higher rate for diesel
engines reflects the trend towards use of diesel engines over
gasoline-fueled engines. For the purposes of the projection, the
base sales period will be the average sales for the best four of
the past five years (1973-1977). Table V-EB shows the projected
sales under these assumptions.
The various costs associated with the proposed regulations
will occur in different periods. In order to make all costs
comparable, the present value at the start of 1983 of the aggregate
coats has been calculated, based on m discount rate of 10 percent.
103
-------
Table V-BB
Estimated Sales of Heavy-Duty Engines
1983-1987
Diesel Gasoline
(51 growth) (2.6% growth)
Base Sales U
15383S
390730
Sales by Calendar Year 1978-82 (total) 892S3S
2111419
1983
1984
1985
1986
1987
1983-1987 (total)
206153
216461
227284
238648
150581
1139127
455786
467636
479795
492269
505068
2400554
1/ Base Sales ¦ Average of (Domestic Factory Sales ~ Imports from
Canada) for the best four of the past five years,
assuming that (a) 5Z of domestic trucks < 10,000
GVW are heavy-duty (i.e., > 8500 GVW), and (b) nil
buses > 26,000 GVW are powered by diesel engines.
MVMA data.
1 04
-------
086 of a discount race emphaaises chat a cost incurred soon is no re
of a burden on the nation than an equal cost incurred later,
because of the foregone investment and growth.
The calculation of the present value in 1983 of the aggregate
costs, with the assumptions required for the calculation, is shown
in Table VHIC. It is estiaated that the aggregate cost of comply-
ing with the new regulations for the five year period is the
equivalent of a luap-sua investment of about $2.5 billion (1978
dollars) made at the start of 1983. Expressed in other terms, the
aggregate coat of compliance is equivalent to investments of $162
per diesel engine made at the start of the year the engine is
produced and $1201 per gasoline-fueled engine, also made at the
start of the year the engine is produced. Overall, the aggregate
cost is equivalent, to $867 per heavy-duty engine.
For ease of reference, the components of the cost of compli-
ance and the different ways of expressing it are summarised in
Tables V-DD, V-EE and V-FF.
D. Socio - Economic Impact
1. Impact on Heavy-Duty Engine and Vehicle Producers
The promulgation of the 1983 heavy-duty engine emission
regulations will cause the manufacturers of these engines to spend
about $95 million dollars for the test facilities modifications and
engine certification, an additional average $88 million a year
for production of emission control systeaw and $41 million for the
SEA program over and above those required to meet current stan-
dards. These costs will be initially paid for by individuals or
companies that buy heavy-duty vehicles and ultimately by the
consumers of the products carried by those vehicles. In-vehicle
service accumulation and SEA teating costs are an exception,
but moat of the compliance coata are incurred by engine manufac-
turers before they realise any revenue from sales of engines for
which this money is expended. This regulation, therefore, will
require manufacturers to generate additional capital between
promulgation of the final rule and 1983 either internally or from
the capital marketa, sufficient Co meet each year's costs.
Tables V-W and V-X showed the costs of test facility modifica-
tions certification and SEA coats by company. (Of and IHC are the
only companies appearing in both tables.) Tables V-Y and V-Z show
their total costs including control system production costs, by
year. Cost are first incurred in 1980 as facility modifications
begin on a large scale. The first opportunity to recover coats via
price increases will be in 1983, aaauming that competitive pres-
sures keep manufacturers from raising prices on earlier engines
beyond what they would do without these regulations.
105
-------
Table V-CC
Present Value in 1983 of
Aggregate Cost of Compliance
For 1983-1987 Model fears
Present Value 3/
Year 1j Coat 2/ in 1983
Diesel (1,139,127 engines)
1980
$35,895K
347.776K
1981
48,7021
58,95IK
1982
18,482k
20,330K
1983
8,358K
8,358K
1984
6,6931
6,085K
1985
7,045K
5.822K
1986
7.329K
5,506K
1987
7.660K
5.232K
Subtotal 158,060K
Gaao1iae-fueled (2,400,554)
$6,187K
11.577K
7,6271:
135,774K
177.942K
212,897k
241.270K
263.846K
1,177,197K 5/
63.828K
44.079K
27.052K
12.453K
Subtotal 2,381,729K
1983 Present Value of Aggregate Coats 6/:
GRAND TOTAL $2,539,789K
Notes: See next page.
1980
4,648K
1981
9,568K
1982
6,934K
1983
135,774K
1984
195.734K
1985
257,620K
1986
321,137K
1987
386,305K
1988-1996
299.229K 4/
1997
242,4151
1998
184,125K
1999
124.318K
2000
62.958K
106
-------
U Costs are assumed to occur st the Start of the year indicated:
Cost
Test facility nodifications
Certification other than
in-vehicle service accumu-
lation
SEA test facilities
Emission control systems
In-vehicle service accumu-
lation end SKA testing
Inspection fees for gaso-
line-fueled
Catalyst replacement for
gasoline-fueled
Unleaded fuel for gasoline-
fueled
2/ Test facility modification costs from Tables V-W and V-Z.
Certification costs from Tables V-W and V-Z. SEA costs from
Tables V-W and V-Z.
fisission control system costs froa section (A)(1) of this
chapter.
Inspection fees from section (B)(4).
Catalyst replacement costs from section (B)(2).
Unleaded fuel costs from section (B)(3).
1983-1987 production from Table V-BB.
3/ 10% discount rate. Present value at start of 1983.
4/ Cost for each year.
5/ Sum for years indicated.
6/ 1978 price levels assumed throughout.
I£££
1/2 in 19807T/2 in 1981
1982
1/2 in 1981; 1/2 in 1982
Same calendar year as model
year
1983-1987
Each of 14 years of vehicle
life
Divided evenly among 14
years
Divided evenly among 14
years and 160,000 miles
107
-------
Tabla V-DD
Undiscounted Coses of Compliance Par Engine
for Engines Produced 1983-1987
Gasoline-Fuelad
Costs Affecting Sailing Price
Test Facility Modifications $ 3.87
for Certification
Certification Tasting 1.33
Manufacturing 171.00
SEA Test Facilities 4.10
SEA Tasting 1.06
Operating Costs
Unleaded Fuel
Inspection Fees
Catalyst Baplacenent
Meffler and Spark Plugs
$1739.00
70.00
62.00
-126.00
Undiscountsd Cost per Engine $1926.36
Diesel
$ 63.02
9.53
25.00
22.52
3.01
0.00
0.00
0.00
0.00
$ 123.08
108
-------
Tabis f-Sl
Discounted Cose® of Compliance Per Engine
for Engines Produced 1983-1987
(10% Discount to January 1, of the model year)
Costa Affecting Selling Price
Test Facility Modifications
for Certification
Certification Testing
Manufacturing
SEA Test Facilities
SKA Testing
Operating Costs
Unleaded Fuel
Inspection Fees
Catalyst Replace
Muffler and Spark Plugs
Gasoline-Fueled
$ 5.92
1.66
171.00
4.73
.88
$1012.90
40.46
35.84
- 72.78
Diesel
$ 97.30
11.63
25.00
26.01
2.49
$ 0.00
0.00
0.00
0.00
Cost per Engine at Start of
Production Beceasary to Pay
for Coats of Compliance
$1200.61
$ 162.43
109
-------
Table V-FF
Aggregate Cost of Compliance
for Engines Produced 1983*1987
(10% Discount to January 1, 1983)
Test Facility Modifications
for Certification
Certification Testing
Manufacturing
SEA Testing Facilities
SEA Testing
Unleaded Fuel
Inspection Fees
Catalyst Replacement
Muffler and Spark Plugs
Gasoline^Pueled
$ 11.8M
3.3M
340.7M
11.41
2. IK
2005.6M
80.7M
71.5M
-145.3M
Diesel
$ 91.2M
10.9M
23.5M
29. GM
2.8M
0.0M
0.0M
0.0M
0.0M
TOTAL
$2381.8M
$ 158 M
Sub of Totals
$2.5398 Billion
110
-------
It can be said with confidence ' me the engine manufacturers
will have little difficulty finaneg the required investment,
barring a post-1980 recession. Curaaic ; can be expected to have the
most difficulty, n» the 1980-1982 investment represents about 31
percent of its 1977 corporate profits. For Mack, Caterpillar,
White, IHC, and Chrysler,, the investment ranges from about eight to
one percent of 1977 profits. For Gi and Ford it is much less than
one percent.-The foreign manufacturers should also have no problem
financing the required investment, which will likely be well below
the worst-case estimates presented here.
Payments on recurring costs (emission control system produc-
tion and in-vehicle service accumulation costs) will occur closer
to the time revenues are received (via sales of controlled engines)
than do the payments required before 1983 production begins.
Assuming manufacturers can pass on 1002 of their costs, then they
should be able to finance most of production and installation of
control equipment from current revenues.
As stated in section A.l of this chapter,, engine manufacturers
and retail dealers were permitted no profit on the-emission control
system hardware. On a 450 CIO gasoline-fueled engine, a profit
allowance would increase the cost by $34 ($171 to $205); the first
cost increase for gasoline-fueled engines wouLd be the same amount
($204 Co S238). .For a typical gasoline-fueled engine (380 CID) the
increase would be $31. -Considering the role played-by the emission
Control system, and the fact that its use is-' prompted by govern-
mental regulation and not direct consumer demand, EPA does not feel
that a- manufacturer or dealer profit is justified. The cost
methodology in the Rath and Strong report (see footnote 1/) does
not pepmit profit on research and development. At this time, EPA
believes 'diesel engine manufacturers will be able to bring their
engines into conformity with the proposed-standards by making-only
minor changes to injectors and calibrations. Since this will
require primarily a research and development effort, thir should be
considered a cost of doing business .and not subject to a profit
markup. Manufacturer's comments on this philosophy for both gaso-
line-fueled and diesel engine are invited.
Changing the prices and operating costs of beavy-duty engines
may, of course, impact the sales of engine manufacturers. Both
total sales and sales mix between diesel and gasoline-fueled
engines may be affected. EPA knows of no estimate of the cross-
elasticities of ^demand 9/ for gasoline-fueled-and diesel engines.
When considering the change in sales mix, the increased cost of
ownership, as well as the increased first cost, may cause a demand
shift. Based on the average first cost increase ($204 gasoline-
9? A cross-elasticity of demand is a measure of the effect of
price changes for one product (e.g., diesel engines) on the demand
of another product (e.g., gasoline-fueled engines). ¦
111
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fueled, $185 diesei) and Che increaj-d coats of ownership ($1016
gasoline-fueled, $0 diesei) 10/,. Che kraand shift would appear Co
be coward diesei engines. This coulc' occur when Che greaCer oper-
ating and maintenance coses of a gasoline-fueled vehicle offset Che
greater inicial purchase price of a diesei vehicle. However, the
existing price difference between comparable diesei and gasoline-
fueled vehicles (as much as a factor of three) will allow this
demand 'shift Co occur for only a smalL fraction of heavy-duty
sales. In addition Co first costs and operating cost, other
factors are considered by purchasers of heavy-duty vehicles.
Gasoline-fueled vehicles usually give better overall performance.
Diesel-powered vehicles have lower maintenance and fuel costs, a
longer useful life, and give better fuel economy. One other very
important factor is that diesei engines are currently not available
in medium-weight trucks (10,000-19,500 pounds GVWR).I1/ Because
the difference in initial selling price is usually so large, and
diesei engines are not available in medium-duty trucks, the impact
of the proposed regulations on the selling price and operating
costs of each should not cause any significant change in the heavy-
duty market, split between diesei and gasoline-fueled vehicles.
EPA's Office of Noise Abatement Control has estimated the
overall price elasticity of demand for new trucks to be in the
range of -0.9 to -0.5. 12/ Assuming a mid-range elasticity of
-0.7, and a- range of $10,000 to $50,000 for the selling price of
heavy-duty vehicles, the added coat of compliance with the proposed
1983 regulations will reduce - stiles by 0.3Z to 1.4Z. If manufac-
turers and retailers are permitted a profit, the sales reduction
will be from 0.3Z to 1.7Z. 13/ Manufacturers of heavy-duty engines
and vehicles withstood & much larger drop in sales around 1975 due
Co general economic conditions, but sales are now recovering well®
The snail decrease in total industry sales from the proposed
regulations will be more than overcome by normal sales growth, and
thus can be expected to have no noticeable effect on any manufac
turer's growth.
EPA does not' expect heavy-duty vehicle sales or the trucking
industry in generaL to suffer because of a shift in the mode of
freight transportation used. Rail and air are not reasonable
TO/ See Table V-EE for explanation: .
11/ For further information, see Chapter III of this Regulatory
Analysis.
12/ Background Document for Medium and Heavy Truck Noise. Control
Regulations, Appendix C (1976), EPA, Office of Noise Abatement
Control.
13/ The price elasticity of demand used here considers only the
average first cost increase and does not consider the effect of the
increased cost of ownership of gasoline-fueled vehicles. EPA knows
of- no- elasticity of demand model which incorporates both increased
first costs and increased costs of ownership.
112
-------
alternatives for intercity freight movement. The vast majority of
nover-the-roadM freight movement is done by heavy-duty diesel
trucks. The purchase price and operating costs of heavy-duty
diesels are not effected by a sufficient amount to warrant anything
but a alight increase in intracity freight hauling costs.
Total bus sales and the bus transportation industry as a whole
should suffer no loss in sales or ridership. The cost increases
due to these proposed regulations will not offset the fact that
buses are the bust option for the transportation of school children
and intercity transport. The intracity but ridership should show
no decrease because the per passenger cost of these regulations is
a negligible amount when compared to other factors in the total
ticket price.
Sales by some individual manufacturers of heivy-duty diesel
engines may decline more than predicted by overall demand .pric#
elasticity. This could result from small volume manufacturers
having to spread their costs for test facility modifications
and certification over their smaller sales. These costs depend
primarily on the number of engine families certified, not on the
sales of engines within those families. Thus smaller volume,
primarily foreign manufacturers like Deuts, White, Nissan, Perkins,
Scania Vabis, and others will have larger price rises than larger
volume, domestic manufacturers like Mack, Detroit Diesel (GM),
Cummins, and Caterpillar. Smaller volume diesel engine manufac-
turers may find the dieael engine market less profitable as a
result.
EPA cannot present manufacturer-specific estimates of how
serious this reduction in profitability will be* Such estimates
would require projections of each manufacturers's sales through
1987, an impossible task. EPA does have available manufacturer's
own sales projections for recent model years, but these are provid-
ed by manufacturers under a confidentiality agreement. EPA has
used these projections and the coat figures from Table V-Z to
estimate Che increase in engine price needed to recover each diesel
manufacturer's costs. These estimates are shown in Table V-GG, in
scrambled order and without manufacturer identification. General-*
ly, the higher increases are for manufacturers with low U.S. sales.
It should be' emphasised that this cost analysis has assumed the
worst case (i.e., higher costs) for small volume manufacturers.
Therefore, the cost figures in Table VHSG will probably exceed the
actual cost increases for these manufacturers. The spread in the
estimates is considerable, and in some cases represents a sisable
fraction of total engine cost. It should be noted, however, that
the manufacturers with the highest increases produce heavy-duty
diesel engines for use in motor vehicles sold in the U.S. as only
one small part of their large, and often multinational, operations.
Some presently enjoy a price advantage over the larger manufac-
turers, which will offset part of all of the differential in price
113
-------
increases. Based oa corporate size, produce diversification,
assets, and total worldwide sales, each of the manufacturers with
the larger price increases could Absorb the cost of these regula-
tions without any threat to its corporate survival. For example,
the corporation with Che largest per engine price increase in Table
7-06 had 1974 corporate sales of about $1.39 billion, and corporate
profits of approximately $6.5 million. The total five year cost
for this corporation, using the fixed costs from Table V-Z plus
$25.00 per engine produced in the 1983-1987 period, is about $3.2
million. This is less than 50% of cms year's net income. Any or
all could withdraw from the market without any threat to its
survival and with little impact on the remaining manufacturers or
on competition in the market. If any or ail of the small voluae
manufacturers were to withdraw free the heavy-duty diesel market,
engine availability would be unaffected • nd no significant cost
increase would occur as a result of less competition. This is true
becuase the U.S. sales market is heavily dominated by the large
volume domestic producers. The annual U.S. sales of the first six
corporations in Table V-GG comprise less than 3Z of the total U.S.
heavy-duty diesel sales per year.
Although White appears in the list of smaller-volume manufac-
turers, it is not in competition with the larger-volume engine
manufacturers in the same way m the others in the list. In the
past several years Vhite has usually certified only military
engines, which do not compete in the civilian engine market.
Small volusa truck and bus manufacturers should not experience
any disadvantage, since most use engines produced by several engine
manufacturers.
It is not expected that the promulgation of the proposed
regulations will have any long tern impact on employment or produc-
tivity in the heavy-duty engine or vehicle industries, since
industry-wide sales will be affected little.
2. Impact on Users of Ha«vy-Suty Vehicles
Users of heavy-duty vehicles will be affected by the higher
costs for the vehicles they use to transport goods, and this
in turn will affect the prices consumers pay for the products
transported by trucks.
The expected first cost increases of $185 for vehicles equip-
ped with diesel engines and $204 for those with gasoline engines
should not substantially impact either fleet owners' or an indivi-
dual owner operator's ability to pay for new heavy-duty vehicles,
since these costs represent at most 2% of a vehicle's sales price.
The proposed regulations will add only about one cent per mile
of gasoline-fueled vehicle operation (undiscounted operating cost
114
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Table V-CG
Increases in Priee Needed for Individual Dieaal
Engine Manufacturers Co Recover Their Coses of Compliance
Mmiifactwer 1/
Price Increase 2/
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
$3100
2075
1782
764
640
464
179
201
179
138
106
101
83
84
IJ The order of manufacturers has bean changed from Table V-Z,
and the names oaicted to protect the confidentiality of sales
projections.
Zf Approximated by dividing the non-recurring costs of Table ?-Z
"* by five timri the Manufacturer's own 1978 sales projection,
and adding the recurring 1983-1987 costs per year per vehicle.
Effect of interest rate has not been included as it would not
significantly affect ¦anufaeturer-to-ikanttfaeturer comparison*.
The reader is cautioned that the manufacturer's projections
are known to be optimistic; if the degree of optimism is not
uniform, distortion in the ccmparisons results.
115
-------
increases divided by total life mileage). All operators of gaso-
line- fueled vehicles vill incur these cost increases, so no sub-
group will be at a disadvantage. To vehicle operators as a group,
this cost should not add significantly to their current vehicle
operating costs, and therefore should not significantly impact
either the dessand for their transport services or their profit
oargins.
3. Impact on Fuel Costs to Users of Other Vehicles
The need for unleaded fuel by gasoline-fueled heavy-duty
vehicles vill increase the demand for that fuel. However, the
increase will be relatively small, since these vehicles presently
consume less than 10Z as much gasoline as vehicles used for per-
sonal transportion. 14/ Also, the increase will come slowly.
The price difference between leaded wad unleaded fuel should not be
changed significantly. Consequently, there will be no significant
impact on fuel costs Co users of other vehicles.
14/ Comparing Table VM-l of 1975 Highway Statistics with Table 39
of "Trucking Activity and Fuel Consumption - 1973, 1980, 1985, and
1990," FEA, July 1976, PB-263035.
116
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Chapter VI
ALimuim mttiohs
A. Identification of the Alternative Action#
The identification of alternative actions is a basic step in
regulatory development. It is mcmsuty to consider all reasonable
alternatives and arrive at that approach which is most cost
effective in attaining the desired goals. In determining which
alternatives are reasonable, SPA has traditionally examined such
factors as magnitude of mission reductions, economic consider"
ations, expected adverse impacts and irreversible commitment of
resources. Only when all these factors have be«n balanced can aa
effective non-disruptive strategy for the control of missions be
selected.
In the broadest tense, the options open to SPA as alternative
actions to the heavy-duty engine regulations being proposed are:
implementation of more stringent control of emissions from heavy-
duty vehicles (with either the existing test procedures or the
proposed transient test procedure) or iaplaMntation of emission
standards reflecting a 90S reduction in EC md CO using the exis-
ting test procedures for emission measurement.
Less stringent control of emissions was not considered as m
alternative since the Clsan Air Act Amendments of 1977 mandated at
least a 90X reduction in HC and CO for 1983. Alternatives invol-
ving less stringent standards may only be considered if SPA deter-
mines that the provisions under Section 202(a)(3)(C) of the Clean
Air Act apply. In such a case» proceedings to revise the mandated
standards would have had to been initiated per 202(a)(3)(B).
Bowtver, SPA has determined that sufficient lead time exists, that
no fuel economy penalty need occur, and that the mandated standards
with the new transient test procedures art cost affective.
B. Analysis of the Alternatives to This Regulation
1. Implement Heavy-Duty Emission Standards Mora Stringent
Than Those Proposed.
SPA did not seriously consider standards more stringent
than the 90Z reductions because Congress had determined that these
levels were the maximum reductions achievable* with current control
technology. Both SPA and the heavy-duty manufacturers provided
Congress with the information necessary to arrrive at these man-
dated reductions. Also, the extremely short timetable for prosul-
117
-------
gating the new standards hindered EPA's ability to fully examine
the alternative of acre stringent standards.
EPA will continue looking into the feasibility of promulgating
more stringent standards if deemed necessary. As mentioned in the
pre .able to the KPBM, the HD manufacturers are invited to consent
on the feasibility of meeting sore stringent standards, 951 reduc-
tion in particular, these consents will aid IfA in determining if
such standards, or others, are appropriate in the future. SPA has
determined that the 90Z reduction in EC and CO are achievable at a
reasonable cost, and is therefore a cost effective action at this
time.
2. Implement Emission Standards Whieh Reflect a 90% Seduc-
tion for HC and CO Psing the Existing Steady-State Test
Procedures.
During the rulemaking process for the 1933 heavy-duty
emission regulations, SPA did consider the option of proposing the
Clean Air Act mandated SOX reduction in EC and CO using the exis-
ting test procedures. The real difference between this alternative
and the proposed action it the test procedures used for assessing
emission reductions (i.e., steady-state or transient). The ques-
tion of the need for the proposed new trusient test procedures
becoms the pivotal issue for this alternative. The reasons that
EPA did not select this alternative and decided to propose tran-
sient test procedures for HD emission measurement will be discussed
in detail below.
A brief history of EPA's transient cycle development effort
will be given first to provide the reader the proper perspective of
the issue. Following the background section, the need for a
tranaient test procedure will be evaluated. A summary end conclu-
sion section completes the analysis of this alternative.
(a) Background
The current test cycles being used for mission testing
of heavy-duty engines consist of a series of steady-state modes.
BPM and power levels are varied from mode to mode. Tables VI-A and
VI-B list the gasoline "9-iaode" cycle and the diesel "13-modeM
cycle, respectively. The w9-modeK and "13-^ode" test cycles were
developed by the heavy-duty industry (the "fHaode" by MVMA and the
"13-m0den by EKA) and initially promulgated by the State of Cali-
fornia. These HD test cycles were later adopted by EPA in 1974.
IPA made sose minor technical improvements to the test cycles in
the 1979 Interim Eeavy-Duty Engine Emission Regulations. These
test cycles are relatively easy to run and require unsophis-
ticated engine dynamometers. They do have several serious short-
comings. The most important problems with these steady-state test
procedures will be discussed later.
118
-------
Table VI-A
Current Gasoline-Fueled Engine Test Cycle
(9-Mode Test Cycle)
Observed torque
Cycle Mode (percent of max- Time in Cumulative Weighting
Number Number Node - imum observed) Mode-Seconds Time-Seconds Factors
1
Idle
60
60
0.232
2
Cruise
25
60
120
.077
3
Part Throttle Accel.
55
60
180
.147
4
Cruise
25
60
240
.077
5
Part Throttle Decel.
10
60
300
.057
6
Cruise
25
60
360
.077
7
Full Load
90
60
420
.113
8
Cruise
25
60
480
.077
9
Closed Throttle
60
540
.143
10
Cruise
25
60
600
.077
11
Part Throttle Accel.
55
60
660
.147
12
Cruise
25
60
720
.077
13
Part Throttle Decel.
10
60
780
.057
2
14
Cruise
25
60
840
.077
2
IS
Full Load
90
60
900
.113
2
16
Cruise
25
60
960
.077
2
17
Closed Throttle
60
1020
.143
2
18
Idle
60
1080
.232
-------
Table VI-B
Current Diesel Engine Test Cycle
(13-Mode Test Cycle)
&
o
Test Mode
Segment Number
1
2
3
5
6
7
Engine Speed
Curb-Idle..®,,
Intermediate
Intermediate
Intermediate
Intermediate
Intermediate
Curb-Idle....
Observed torque
(percent of max-
imum observed)
2
25
50
75
100
Mode (Minutes) Cumulative
Minimum Maximum Time (Minutes)
4.5
4.5
4.5
4.5
4.5
4.5
4.5
6.0
6.0
6.0
6.0
6.0
6.0
6.0
- 42
2
2
2
2
2
2
8
9
10
U
12
13
Sated
Rated
Sated
Bated
Rated
Curb-Idle.
100
75
50
25
2
4.5
4.5
4.5
4.5
4.5
4.5
6.0
6.0
6.0
6.0
6.0
6.0
- 36
-------
EPA has been involved for several years in Che development of
test procedures that are sore representative of urban truck usage.
These new procedures are intended to make emission reductions
measured in the laboratory aore representative of percent reduc-
tions one would expect to achieve in actual use. 4 brief summary
of this effort is given below.
Heavy-duty vehicle operational data were collected in New fork
City and Los £agei@s. This progras effort was titled "CAPE-2I*
Truck Driving Patterns and Use Survey." In the CAPE-21 survey
forty-four (44) trucks and three (3) buses were surveyed in Los
Mgeles (LA) aad forty-four (44) trucks and four (4) buses were
surveyed in New fork City (NT). Speed (mph), engine rpo, engine
power, engine temperature, and various road and traffic descrip-
tions were recorded on tape at approximately one second intervals.
The vehicles performed their normal daily functions while these
data were collected. The total data sample included 290 truck-days
and 21 bus-days of operation (1365 hours of vehicle operation).^/
From this data base, Olson Laboratories (EPA's HD cycle development
contractor) generated numerous S minute (approximate) long tran-
sient engine and chassis cycles using the Monte Carlo technique,2/
SPA Chen developed a cycla arrangement chat had proper HD tr?p
characteristics.3/ These trip characteristics included non-
freeway/freeway weighting, city weighting, hot operation/cold
operation, and trip length. The final emission test cycles can be
found in Appendix XI of the NP8M or in the EPA technical report,
"Transient Cycle Arrangement for Heavy-Duty Engine and Chassis
Emission Testing," EDV78-04, by C. France, July 1978. These cycle
arrangements exhibit trip characteristics supported by the CAPS-21
date base and EPA considers them representative of S3 transient
operation.
A complete bibliography of ill available EPA reports concer-
ning Che HD cycle development effort can be found in EPA's "HD
Recommended Practice for the Measurement of Emissions using a
Transient Test Procedure," HDV78-07, August 1978.
(b) Need for the Transient Test Procedure
The need for 'the new transient test procedure is the
basic issue of this proposed action. If the current sceady-stace
test procedures were retained, EPA would probably encounter little
resistance in implementing the Clean Air Act mandated 90S reduc-
11 "Heavy-Duty Vehicle Cycle Development," EPA 460/3-78-008,
July 1978.
2/ Ibid.
3/ "Transienc Cycle Arrangement for Heavy-Duty Engine and Chassis
Emission Testing," by C. France, EPA HDV78-04, July 1978.
121
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Table VI-C
12 3 4
X Cruise % Decel. Z Accel. 1 Idle
Steady-State Cycles:
9-Mode 76.8 0 9 23.2
13-Mode 80.0 0 0 20.0
EPA Transient
HD Engine Cycles:
Gas 20.4 25.4 26.4 26.6
Diesel 11.5 26.8 25.8 36.5
GAPE-21 Data:
LA. Gas 25.6 28.4 30.2 15.8
NT Gas 15.4 24.0 24.2 36.4
LA Diesel 18.8 30.7 33.1 17.8
NT Diesel 15.2 30.0 30.0 24.8
Gas (LA & NT) 20.5 26*2 27.2 26.1
Diesel (LA & NT) 17.0 30.4 31.6 21.3
1 The percent of operation when no change occurs in rpa and
power.
2 The percent of operation Involving a negative change (de-
crease) in rpa or power.
3 The percent of operation involving a positive change (in-
crease) in rpa or power.
4 The percent of operation when power equals zero and engine rpa
equals idle rpa.
122
-------
Figure Vl-A
* f DPM ggg Z «!•««...
5 Rattd 8PM - Idle BFM
123
-------
50
40
30 f
20-
10 -
CAFE-21 DM* Density Function
Los Angeles Diesel Trucks
Non-Freewty
50
40.
30-
20-
10'
60
50
40
30
20-
10"
Los tegeles Diesel Trucks
Fteewey
-14
0 3
^^^3*^82 lb6
t mm
Hew York Diesel Trucks
Ron-Freeway
106 '
Haw York Dieael Trucks
Freeway
* XBFM -
BPM - Idle DM
Sated DM - Idle BPM
124
-------
40 f
30
20
10
Motor
(neg)
CAPE-21 XPOWER* Density Function
10 20 30
Los Gasoline Trucks
Non-Freeway
*
40 50 60
XPOWER
70 80 90 100
30 < i
20 .
Los Angeles Gasoline Trucks
Freeway
50
40 ,
Z 30 ,
20 •:
10 "
Motor 0
(neg)
t 1 i ' ' 1 i
40 50 60 70
XPOWER
Hew York Gasoline Trucks
Bon-Freeway
t i » | I
T
H—
70
80
90
100
Motor 0
(nag)
50 •-
40 "
30
10 20
30 . 40 50 60
XPOWER
Hew York Gasoline Trucks
Freeway
20 <
10 «
. , .
Motor 0
(neg)
10 20 30
40 50 60 70
XPOWER
80 90 100
* XPOWER equals the percent of the maximum power at the RPM
In question.
125
-------
50 -
CAPE-21 ZPGHE&* Density Function
40 •
30 •
Los Angeles Diesel Trucks
Non-Freeway
20
10
Motor 0 10 20 30 40 50 60 70 80 90 100
(nag) ZFOHER
40
30
20
10
Los Angeles Diesel Trucks
Freeway
+
*-
Motor 0
(neg)
10 20 30
40 50 60
ZPOWER
70
40
30
X 20
10
New York Dies«l Trucks
Freeway
Motor 0 10 20 30 40 50 60 70 80 90 100
neg)
JPOHEE
50
40
Hew York Diesel Trucks
Non-Freeway
30
% 20
10
,
80 90 100
•>
, r i , i i i , i , i , 1—
Motor 0 10 20 30 40 50 60 70 80 90 100
(neg) SPGHER
* %PGWEE equals the percent of the mmrtmim power at the RPM
in question.
126
-------
Figure VI-E
Noraaiized Z.JfflM varans Z-Power Maerix
for Gasolln* Trsaaieat EoglxM Cyela
Otol#® approxi-afce location of 9-oodo BFH aatf pewar
tast Ltvala.
100
90.1-99.9
80.1—90
70.1—80
60.1—70
50.1—60
40.1—50
30.1—40
20.1- 30
10.1— 20
0.1—10
0
Motoring
ox
.2
.4
.8
:4
.9
.1
.4
2.3
.9
a
.5.
0
.1
.2
.1
0
f
.1
• 1
.3
.1
.1
.2
1.0
.4
.7
»>
.8
.4
.3
.3
a
.2
.3
.5
.2
• H
1.7
.4
1.2
.1
.1
0
.5
0
0
.1
.4
• ^
.5
2.0
.7
.3
.2
.2
0
0
.1
.3
.1
• J
<
)
1.0
.1
.2
.1
.1
.1
.9
.1
.2
•
1.1
.8
.7
.3
.1
0
a
.2
.3
.1
.5
1.0
.3
.7
.3
.2
.1
.1
a
.6
.1
.3
.5
1.5
>
.3
.3
0
.3
a
.9
.2
.1
.6
• J
r
>
.2
.1
.1
.3
a
2.4
.8
.3
.9
• /
1>
.1
.1
.2
0
0
.3
0
.3
• X
0
.1
0
0
0
0
0
1.8
3.6
2.1
2.2
2.2
)•
.6
.2
.5
.6
.3
0
0.1-
10
i
• o
O CM
H
20.1-
30
30.1-
40
40.1-
50
S HFM
50.1-
60
60.1-
70
70.1-
80
80.1-
90
90.1-
99.9
100
-------
Figure VI-F
Normalized Z RPM versus Z Power Matrix
for Diesel Transient Engine Cycle
100
90.1-99.9
80.1-90
70.1-80
60.1-70
50.1-60
40.1-50
30.1-40
20.1-59
10.1-20
0.1-10
0
Motoring
o
Denotes approximate location of 13-oode RPM
and Power test levels.
0Z
.2
.2
.2
.1
.8
1.8
36.0
.9
.2
.2
.3
.2
.2
.2
.2
1.3
.2
.7
.2
.2
.7
.1
.8
.2
.2
.2
.6
.2
.8
.3
.1
.1
.2
.5
n
.5
EI
.1
.6
.2
.2
a
.2
n
1.2
1.8
5
2.3
.8
.6
2.1
1.1
1.0
1.1
2.1
1.8
1.2
.9
.2
.2
2.4
.4
.2
.9
1.4
.6
.5
.5
.2
.7
1.0
1.2
.1
2.1
? ^
.1
J
r—r
.6
.3
.8
.6
Lj
.8
.2
1.0
_ 0.1- 10.1- 20.1- 30.1- 40.1- 50.1- 60.1- 70.1- 80.1- 90.1- lflfl
0 10 20 30 40 50 60 70 80 90 99.9 1W
Z RPM
128
-------
tions &a SC and CO for 1983. However, EPA consider* Che steady-
state procedures inadequate for assuring that ESS vehicles achieve a
90S reduction in on-road emissions. The express purpose of the new
transient test procedures is to provide a means of assuring true
en-road Mission reductions.
To date, the existing teat procedurea hm been considered
adequate for assessing IB vehicle emissions at the current levels
of stringency. IfA is concerned that the incentive to design to
the test procedure will be greatly increased as emission standards
become ooia stringent. EPA's pest experience in ail aepects of
Mobile source regulation indicate that the industry will narrowly
define their job as one of designing strictly to the limits of the
test procedure. Flexibilities and loop-holes in the systea hsve
been used to their fullest advantage by the manufacturers. Maximi-
zing of fuel econesy numbers and the uae of defeat devices are
prime examples.
Both the gasoline snd diesel steady-state procedures are
easily designed around. The manufacturers can design their emis-
sion control system to function during the steady-state cycles snd
thus show an apparent emission reduction. However, in real life
the engine 'may not be achieving the amission reductions required on
the steady-state cycle. The reason for this ia that key modee of
operation, including tranaient modes (acceleration and decelera-
tion) are not tested during the steady-state tests.
Several of the deficiencies of the steady-state test proce-
dures are listed and diacuaaed below. The proposed trensient
procedure substantially rectifiea these shortcomings of the current
procedures.
1} The steady-state eye lea lack tranaient operating modes.
Actual urban truck usage contains a large amount of tranaient
operation including both acceleratona end decelerationa.
Table FI-C deacribea the amount of various types of operation
(S eruiae, X deceleration, X acceleration, and 2 idle) for the
steady-state cycles, the CAFS-21 data base, and the EPA
transient engine cycles derived from the C&P1-21 data. This
table illuetratea that transient modes (eceeieretions and
decelerations) are dominate modes of urban truck operation.
In fact, in exeeaa of SOS of a trucks total operation ia
tranaient in neture. The eteady-atete cycles are totelly
deficient of transient maneuvers. Consequently, emissions are
not meeaured during chase potentislly critical modea.
2) The gasoline 9-mode is conducted at only two speeds
(idle and 2000 rpm) and the diesel 13-mode is conducted at'
three speeds (idle, 60 to 75% of reced speed, and rated
speed).
129
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Th« GAFE-21 data base indicates that HD engine* (gas©-
line and diesel) operate regularly over their full rp® range
(idle Co rated speed plus). Figures 7I-A and 71-3 illustrate
the rpm density functions for the gasoline and diesel trucks
surveyed in CAPE-21. For completeness, the CAPE-21 power
density functions are also shown in Figures VI-C and 7I-D.
The steady-state eyeles only include a very limited number of
rpm levels (and power levels, also). Therefore, it would not
be surprising if neither eyela accurately assessed emissions
as they occur in the reel world.
3) The current test procedures do not include cold start
ogerat ion. ¦
The CAP8-21 data base indicates that trucks have one cold
start trip 4/ and six hot start trips per day.5/ The very
first trip of the day is Che only cold start drip for a Hi
vehicle. Based on this information, it is apparent that any
emission test cycle should accurately assent cold start
eniisions. The current steady-state procedures do not essess
cold start emissions. (Both steady-state teats begin after
the engine is fully warned up.) Accurate mmsamm of cold
start emissions is particularly important should 10 gasoline
engines be equipped with catalyst ssission control systems. A
cold start test is less important for diesel engines since
their cold start emissions are not then different than their
stabilised emissions.
4) The modes and mode weighting factors for the 9-mode end
13-mode test cycles have questionable relationships to actual
HD vehicle urban operation.
The various modes and their weightings for both the
gasoline and diesel test cycles do not correspond well to the
key modes of operation for the CAPE-21 trucks. Figures VI-E
and ¥X-F show percent rpm versus percent power matricies for
the gasoline and diesel cycles which ware derived from the
CAFS-21 data base. Overlayed on these matrices are the
approximate locations of the 9-mode and 13-oeda rpm ##4 power
levels. It is quite obvious fro* thses figures that large
areas of common ED engine operations are not accounted for in
the steady-state cycles. This fsct easts further doubts on
the effectiveness of the current procedures to assess urban
emissions.
4/ A trip is defined as «ngine~on to engine-off.
"Transient Cycle Arrangement for Heavy-Duty Engine and Chassis
Emission Testing,1* by C. France, EPA HDV78-04, July 1978.
130
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5) EPA h«» bean enable to derive a correlation betveaa data
froa "trucks teated on varioua tram lent driving cycles anil
Itultoi the saae trucks eg thm testa.
Recently, E?A undertook a prograi to evaluate the current
teat procedure* ability to sssms on-road 19 vehicle eais-
sions. Southwest tesearch Institute (SwRX) conducted the
actual data aaalyeis under contract for SPA.6/ The purpose of
this contract wm two-folds (1) to detesaieflMNhether a steady-
atate BD eaission teat cycle (i.e., current steady-state
teat cycles, rewcighted wrntaim* of Cheat, or slightly modified
cycles) would givs eaissions rtiulct coaparable to chose
obtained from traaaient driving eyelea; and (2) To investigate
the degree of correlation batmen brake specific fuel couustap-
tion (B3FC) measured on the steady-atate teat and fual eeonoey
of HD vehiclea in actual use.
Data from 18 gaaoline and 12 diesel trucks tested trader
EPA Contract 68-08-2147 were used in the analysis.7/ 9-moda
and 13-noda tests, in Addition to mtavrous types of transient
driving cycles were run on each truck. Fuel eonsuaption and
exhaust eaissions ware aeasured during all testing.
SwRX concluded from their analysis that the current
9-onde (or variations of the test) could not be expected to
adequately predict actual ie-use Missions of 19 gasoline
vehicles. They alao deteraicad thae the 9-aode test proce-
dure doea not predict changes in eaissions during actual
transient driving cycles m ths levels of mission control
are changed.8/
With regard Co the diesel 13-aoda test procedure, Swtl
concluded that, in general, thia test does not adequately
predict Missions that would be produced in actual use either,
the one exception to this is that the 13-«@de 10k Missions
may be useful in predicting missions produced during actual
driving conditions.
ffA perforaed further analysia of the data and closely
«xaained SwEl*s results and conclusions. In general, SPA
agreed with SwfiX conclusions. If A further concludes that for
the levels of eaissions control exsained, transient tests are
definitely required for both power systeas to accurately
—' "Heavy-Duty Fuel Beonoay Prograa - These I, Specific Analysis
of Certain Sxisting Data," EPA-460/3-77-001, Hay 1976.
Tj *'gtady of missions froa Besvy-Duty Vehicles," EPA-460/3-76
-012, Msy 1976.
131
-------
predict urban performance of GO and 80s for gasoline end EC
asd CO for dLie*el> .9/
le should be pointed out that in tbeir anal?*!*, Sw&I
only laeluded 1969 through 1975 HD nMeki. The degree of
control tanged fro* prercontrollsd engines to essgiaes con-
trolled to 1975 California Staadarde of 10 §/BHP-BR HC +
HOx sad 30 g 00. So current technology or edvanced technology
eoatrollad engines were iaeluded ia their snalysie. The
iaiplieatioa of this is that ia order to draw iafereaeea
about th& relationship batmen the steady-state procedures end
the transient procedures it is eesiaed that aore stringent
controls will not alter the relationships found ia the
SwftI analysis.
As tsdssions standards becomi eore stringent the aore
sophisticated emissions control technology becoees* If a
stoady-state test procedure is used for caaplience teeting the '
HD engine aannfacturers will be design.lag their ttnginee to
Bset esissions standards using these procedures* Conse-
quently, there will be a high probability that the control
techniques used to obtain low ealesion levels on the steady-
state procedures will not achieve the swe degree of control
on the transient teet procedure nor in the reel world. The
aotivatlou to beat the procedure also iaeressee as etanderds
beco«s aore stringent, sad the HD engine asnufacturers aay opt
to design their eagiaes to be clean only on the steady-state
procedure.
Under mother progrsa, evaluations of missions and fuel
economy performance of various advanced emission control
technology systeas «u recently completed by SwBl.10/ All
work wai performed on a CSwvrolet 330-m HD gasolie# engine.
'Significant emission * eductions below' canent levels were
obtained with various coatrol systeas on both 9-mode and
tranaieat procedures. The results from this teet progrsa
indicate that reduction in eaissions (end fuel coasiaption)
ware generally aach greater ia the 9-oode evaluations than in
the transient cycle evaluations*
While the need for the transient test has been dearly deMir-
strated for gasoline-fueled engines, the ease is not so obvious for
dlesel engines* SPA concedes thet dlesel HC and GO levels ere
already quite Iw relative to gasoline engines* In fact, most
17 Inter-office memoreada free J. Becker to G. Koesow, deted
9/28/76 and 10/13/76.
10/ "Heavy-Duty Fuel Economy Progrsa Phase III - Transient Cycle
Bvalutione of the Advanced Balesions Control Technology
Engine," 1PA-460/3-78-005, May 1978.
132
-------
dieael engines produce HC mi CO tare La quite clom to the 90Z
reduction level derived tram uncontrolled gasoline engines. This
situation alone raiaea a question of the need for ehe transient
procedure for dieael enginaa in 1983. However, m part of another
program, SPA ia developing regulationa for the control of particw
late emsaiona fro® dieael «agines (as required by Section 202
(a)(3)(A)(iii)). These procedure* are planned to be implemented
in 1983 and will require a, transient teat. Finally, the require-
aant for a 75 pereent reduction in Sftc for 1985 will be a very
difficult requireaent for dieael enginaa eo meet. At this level of
control, traaaient test procedures will be eaaential to insure that
engines are deeigaed to be clean in representative on-road use and
not sisply on a steady-state teat cycle.
Soaie of the above defieienciea might be overcome to soae
degree with more aoderate chcages to the teat procedure reaulting
in a cheaper end eimpler procedure. However, there ia no time
remaining to consider further teat procedure ehaages, and it ia
expected that auch compromises in the teat procedure would not gain
appreciable coat eavinga.
c) Sumaary and Conclusions
If this Alternative were choaan, no change in teet
procedures or etaiaaion aaaipling equipment would result. The
current teat procedures would be kept intact. The only substantive
change would be the emission standards. Consequently, manufac-
turers would not be required to purchase new dynamoaster equipment
and analytical eysteas, ehieh would result in e coet increeae of $6
per vehicle for gasoline engines end $97 per vehicle for diesel
engines. However, the current steady-state teat procedures have
aeveral serioue deficienciee thet aek* thai ineffective in eesee-
eing accurate emission reductions.
Among the steedy-stete cycle defieienciea are: (1) uo tran-
sient operating sodas, (2) unrepresentative and insufficient number
of rpm and power teet levels, (3) no cold stert operation, (A)
questionable sode weighting factora, and (5) poor correlation with
treneient emi salons. These deficiencies contribute to the steedy-
stete procedures' lack of correspondence to on-roed emissions.
Based on detailed dete enalysis, IPA haa concluded thet the 9-aode
and 13-mode test procedures do not provide accurate assessannts of
HD urban emissions.
To eliminate these deficienciee, EPA haa developed treneient
engine eyelee representative of the way HD vehicles actually
operate in the urban environment. These test procedures are
designed to provide en accurate estimate of actual in-use HO
emission levels and to sinisise the possibility of designing to the
test procedure. These attributes becoas very important particu-
larly at the low eaieeion standards proposed in thie regulatory
133
-------
package. Without « teat procedure which accurately relate## to
urban aaissions, it would ba difficult to quantify the effect* of
nore stringent standards for HS vehicles.
The need for a transient test procedure for gasoline-fueled
engines is well substantiated. For diesel engines the need is not
as evident. Diesel engine HC and CO levels are already close to
the 90Z reduction l«vels froa uncontrolled gasoline engines. This
fact easts eoae doubt on the need for a transient procedure for
diesel engines in 1983. However, EPA is developing a diesel
particulate test procedure for 1983 using u transient test cycle.
11/ The ease cyclea would be used for both particulate and emis-
sion testing. Also, the requireewt for a 75Z reduction in HOx
for 1985 will b# a very stringent requireaent for dieael engines to
meet. It is anticipated that at such low HOs levels, a transient
test procedure will be required to insure that engines are designed
to be clean in the laboratory test cell and in actual use.
It is not possible, at this tiae, to quantify the air quality
iapect associated with the use of e transient test procedure. All
that can ba said ia that the proposed procedures will give 1PA
substantially Mra confidence that the required HC and CO reduc-
tions are achieved in the real world. The existing steady-stats
procedures are deficient in this regard.
The increase in vehicle cost that can be attributable to the
change to transient test procedures aaounts to $6 per vehicle for
HD gasoline-fueled vehicles and $97 per vehicle for HC diesel
vehicles.12/ BPA's analysis indicates that this cost is necessary
to insure that IS vehiclee achieve a 90S reduction in HC and CO
emissions in the urban environasnt. When ccapered to other costs
associated with thia proposed action (i.e., eaission control systea
costs, fuel costs) this cost is insignificsnt end should not pose e
burden on the aenufecturers coaplying with this regulation.
As required by the Clean Air Act A»md!aents of 1977, Section
202(a)(3)(A)(iii).
— Present worth on January 1, 1983 at a 10Z interest rate. See
Chapter V section C and Table V-EI for a further explanation.
135
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Chapter VII
COST EFFECTIVENESS
Cose effectiveness is a statistic which measures the economic
efficiency of undertaking mm action to achieve a certain goal.
In the context of iaproviog air quality, the goal is to reduce
•missions of harmful pollutants, and the cost affectivenass of the
alternatives used to net the goal is expressed in terns of the
dollar cost to control one ton of pollutant. Ia the case of aobile
sources sobs mission control equipment impacts the level of
emissions for «»re than one pollutant. In such eases, if4 has
ellocated the control costs to the pollutants controlled by a
particular component, but this practice it admittedly subjective.
The equation for cost effectiveness is expressed as follows:
Coat Effectiveness ($/ton) - _
STssToBs Keauccioii vtonlTl!WSfTrB5!Sl LITST
Control costs include several factors. Usually the largest
factor is the cost for developing, producing, and installing
pollution control equipment on vehicles or engines ao that they
comply with applicable emission regulations. The expected "first
cost* increase, or change ia purchase price of a vehicle or engin*
to the consumer, is normally used as the per vehicle cost. low-
aver, the "first cost** includes more than just the cost of the
control hardware. It also includes soas allocated portions of the
cost of certifying the engine or vehicle with SPA. In addition,
for this proposed action, the incremental change in "first cost1*
will also include the amortised cost of modifications made to the
engine manufacturers' test cells.
The second type of cost increase soosetimes attendant to new
regulations is « change in vehicle operating costs which can be
directly attributed to the imposition of these regulations. An
axaaple is maintenance cost (or savings) associated with repair or
replacesnnt of parts which would not have been present on these
vehiclee prior to implementetion of th new regulationa, or repair
or replacement of parts which were affected by the operation of the
emission control components required to meet a given emission
standard (i.e., catalyst replacement). Incrementel operating coats
else would include costs (or savings) associated with changes in
fusl type (leaded or unleaded) end consumption caused by the
regulations.
Totel incremental control costs [equipment (including develop-
ment costs and other amortised costs associated with complying with
136
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Federal emission regulations) glue maintenance caeca plus fuel
coses] ere totalled for the expected life of the vehicle. The
other half of the cost-effectiveness equation, lifetime mis*ions
redaction, is then determined by subtracting the post regulation
aissions (gs/aile) fron the pro-regulation emissions levels and
multiplying this factor by the nuaber of miles the vehicle is
expected to travel in its lifetime. This gives the total grins of
pollutant controlled over the life of the vehicle, which is then
converted to tons of pollutant.
In a multi-faceted program such is the proposed regulations of
this heavy-duty package, it would be desirable to analyse separate-
ly the coats and environmental benefits of each aspect of the
package. In this way a decision could be made on -each element as
to its cost effectiveness and whether it should be incorporated
into the final regulations. Unfortunately, for an integrated
control strategy such as the present package, this is not possible
because the individual elements are inter-related and benefits
cannot be isolated for each eleaent. ieaoving One element might
seriously jeopardise the effectiveness of other elements. Also,
while the overall benefits of the package have been evaluated, EM
has an insufficient data base from which to quantify the benefits
of each element separately. Therefore, separate cost benefits haw,
not been attempted. Bather, the overall cost effectiveness for the
total complianctt strata;*? is evaluated as a whole.
Total lifetime miles have bsen calculated by computing scrap-
page rates U and average annual miles 2/ as & function of vehicle
age. The Tifetime miles used in the cost-effectiveness calcula-
tions are:
LDVs 100,000 miles
LDTs 100,000 miles
HDVs - gaa 160,000 miles
HDfs - Diesel 436,000 sailes
Table 71I-A presents costs, emission reductions, and cost
effectiveness for the proposed actions (i.e., ispleswntation of
emission standards reflecting 90Z reduction in HC and CO using
transient test procedures). No emission reductions and conse-
quently no cost effectiveness values can be presented for the other
alternative EPA considered; namely implementation of emission
stsndards reflecting 90S reduction in HC and CO using current
y "Automobile Exhaust Eaisaion Surveillance Analysis of the FT 72
Emission Factor Program", 1PA Report No. 460/74/001, February,
1974.
2/ "Truck Inventory and Use Survey", 1972 Census of Transpor-
tation, U.S. Department of Commerce, October, 1973.
137
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steady-state east procaduras. Siaca SPA is uncertain about the
degree of eaisaioa reductions achievable with the steady-state
procedures, no reductions are quoted. Chapter VI, Alternate
Actions, thoroughly discusses the deficiencies and ineffectiveness
of the steady-state procedures in quantifying eaissions froa HD
vehicles in the urban enviroaaent.
The tons reduction listed in Table VII-A ore based on optimum
control of BC and 00 which depends on effective inspection and
maintenance (I/M) progress. Without such progrsms the fulleet
possible control of HC end CO might not be realised. In particu-
lar, an I/M program would be expected to identify feiled cetelysts
on gasoline vehicles. Costs of such a program are included in the
gasoline-fueled engine cost figures.
The costs of control are equally divided ssong HC and CO for
gasoline vehicles and allocated to BC only for diesel engines. The
coses in Teble VII-A reflect costs associated with certification
testing, ia-vehicle service accumulation, and emission control
systems. Additionally, the gaeoline-fueled engine costs include
catalyat replacement costs 3/ and the increased cost of unleaded
fuel.
The costs in Table VII-A include the coats of test facility
modificationa required by the chsnged to a transient test proce-
dure. For gasoline-fueled engines these costs can be considered
minor ($6 per engine) especially when compared to the additional
cost of unleaded fuel. For diesel engines they are more substan-
tial (approximately $97 per engine). However, the benefits of e
trsnsient teat procedure (discussed in Chapter VII) justify these
additional costs. The moat importsnt justification is that the
transient test procedure insures that emission reductions measured
in the laboratory are actually achieved in the urban environment
for both gasoline-fueled end dieeel engines.
Included in the Table VII-A costs, ere the costs of performing
assembly-line testing, namely Selective Enforcement Auditing (SBA).
The discounted costs for SEA test facilitiea amount to $5 per
vehicle for gaeoline-fueled engines and $26 per vehicle for diesel
engines. SBA testing eosts are estimated to be $1 per vehicle for
gasoline-fueled engines and $2.30 per vehicle for diesel enginee.
For gasoline-fueled engines the mejor cost associated with
thia proposed action, regardless of test procedure, is the cost of
unleaded fuel. More then 80% of the total per vehicle cost is
attributable to unleaded fuel. Unleaded fuel is required since the
emission levela proposed are low enough to require the use of
catalyst control technology. It is possible that fuel econony
3/ It is assumed that 60S of in-use catalysts will required
replacement. Chapter V presents a more detailed discussion
concerning this topic.
138
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Table VI'-A
Coat Effectiveness of Emission Standards Reflecting 90%
Reduction in HC and CO Using Transient Test Procedures
Gasoline-Fueled Engines:
Lifetime Reduction per
Vehicle (tons)
Costs of Control per Vehicle^
Cost Effectiveness ($ per ton)
Pollutant
KC CO
39
$600 $600
$300
$ 15
NOx
Diesel Engines:
Lifetime Reduction per
Vehicle (tons)
Costs off Control per Vehicle*
Cost Effectiveness ($ per ton)
1
$162**
$162
& Discounted costs of compliance per engine (10% discount to
January 1, of the model year.)
** Full cost of control is charged to HC control since no addi-
tional CO control is expected.
139
-------
increases may be realised with catalyst usage and these fuel
savings nay offset sent of the additional cost of ehe unleaded
fuel. However, for ehis analysis potential fuel savings were not
recognised.
M Motioned earlier, the cost of control for diesel tngines
is allocated totally to HC. This was done even though sons- of
these costs (e.g., test facility modifications required by the
transient test procedure) could be transfered to other future
regulatory actions. for exnple, the diesel particulate regula-
tions (forthcoming in the near future) will require the use of the
proposed transient diesel procedure. Also, the. sore stringent 10x
standard required by the Clean Mr Jet Amendments of 1977 lor 1985
and later model year HD vehicles further justifies the use of a
transient test procedure for diesel engines. Both of these future
actions could absorb a portion of the 197 per vehicle cost asso-
ciated with the change in test procedures. Since this BFHf is
preceding the other HD regulatory actions mentioned above, it was
decided to charge the full cost for diesels to SC.
The cost effectiveness numbers associated with this proposed
action and the cost effectiveness of other mobile sources control
strategies are given in Table VII-I. It should be pointed out that
the comparisons batmen strategies is not strictly vslid because
each represents average cost effectiveness over varying sised
increments of emission reduction. M the totel emissions decrease
the cost of removing an additional increment of pollutant in-
creases. The most desirable comparison among control strategies
would compare the cost effectiveness of removing the last increment
of missons in each of the different control strategies. If this
incremental cost data was available the cost effectiveness of the
different control strategies could be easily compared. Such
data is, however, not aveilable. With this limitation in mind, it
appeers that the proposed action is quite cost-effective when
compared to other strategies. The change to a transient test
procedure causes some additional expense resulting froa equipment
end facility modifieations. However, the increased costs are
justified by the benefits realised from the transient procedure.
1 &n
-------
Table VII-B
Control Progri
LDV StatuCory
Standards b/
LDT Iacerin
Standards c/
LDV I/M f/
Cost Effectiveness ($/ton)
Data for Mobile Sourea Saigaion Coatrol Strategies
Baseline missions a/
EC - 1.5
00-15
KOx - 3.1
1) 10 » 2.0, 00
WOx - 3.1 d/
20
2) EC - 4.3, 00-44
H0x ¦ 5.2 e/
Motorcycle Standards gf
1978/1979 EC - 9,
00 - 34.67
1980+ EC - 8-22.5,
CO • 27.4
Proposed Action if
EC - 1.5, 00-25
EC * NOz - 10
Bnissions After
Control Prograxa
Initiated a/
EC « 0.41
CO - 3.4
HQ* ¦ 0.4
EC - 1.7
00-18
EC - 8-22.5 h/
00 - 27.4 ~
EC - 8
00 - 19.3
EC » 1.5 ±/
00 - 14.8 $f gas
Cost Effectiveness
(l/ton)
00
EC
470
41
NOx
2300
297
78
29
7.7
109
2763
364 (negative) -
365 (negative) -
HOx » k/
300
diesel 162
15
a/ LOV, LDT, LDV/LDT, IM, and Motorcycle emission levels in
™ gn/mile. ED emission levels in ps/BHP-br.
b,f Report: Interagency Task Force on Motor Vehicle Goals Beyond
1980, March 1976.
c/ "Environmental Impact Statement - Emission Standards for
Light-Duty Trucks," November 29, 1976.
d/ Trucks 0-6000 lbs. GVUR.
e/ Trucks 6001-8500 lbs. GWR.
T/ Inspection and Maintenance Programs for LDV. From "Cost
Effectiveness Estimates for Mobile Source Emission Control,"
Vector Research, Inc. for EPA, January 1978.
j/ "Environmental and Economic Impact Stateoent - Exhaust and
Cranksase Regulations for the 1978 and later Model Tear Motor-
cycles.
h/ Sliding scale based on engine displacement (cubic centimeters).
T/ Emission standards reflecting 902 reductions from 1969 gasoline
' ~~ baseline levels for EC mad CO. Emission measur«aaats are made
using new transient test procedures.
jj These standards reflect a 90% reduction from 1969 baseline
leve Is.
k/ A level equivalent to current levels of HQs will be established
in final rulemaking.
143.
-------
APPENDIX A
Table 1
1969 Baseline
Sales-Weighted Brake Specific Emissions
(grama/BHP-hr)
X Total Weightiag
Sales
Weighted
Sales
Weighted
Sales
Weighted
Sales Weighted Baseline Total
90Z Seduction from Baseline:
14.00
1.40
Engine 1
69 Sales
Factors
HC
HC
CO
00
NOx
HOx
Dodge 225
1
9
.033
6
91
.228
51.17
1.69
8.89
.293
XHC ¥-392
2
7
.047
6
35
.298
178.47
" 8.39
4.23
.199
Ford 391
1
9
.033
13
26
.438
182.25
6.01
5.75
.190
lie V-304
6
5
.113
11
64
1.315
127.40
14.40
6.07
.686
Ford 330
6
9
.120
28
13
3.376
157.10
18.85
7.89
.947
GH 351C
3
7
.064
9
73
.623
111.51
7.14
8.80
.563
Ford 330
6
9
.120
35
07
4.208
228.27
27.39
6.07
.728
Chev. 350
7
0
.121
9
57
1.158
169.70
20.53
4.90
.593
Dodge 318
1
6
.028
7
96
.223
86.97
2.44
7.60
.213
XHC V-345*
7
7
.133
6
64
.883
80.99
10.77
6.40
.851
Chev. 350
7
0
.121
6
21
.751
115.0
13.92
5.36
.649
Ford 300
3
57
9
7
.068
1.00
7
35
.500
231.14
15.72
4.79
.326
147.25
14.73
6.24
* Tentative
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APPENDIX A
Table 2
1969 Baseline
Sales-Weighted Idle Emissions
Sales Sales Sales
Z Total Weighting HC Weighted CO Weighted NOx Weighted
Engine
'69 Sales
Factors
(ppm)
HC
(ppm)
CO
(ppm)
NOx
Ford 391
1.9
.04185
15624
653.86
12303
514.89
67.8
2.837
IHC V-304
6.5
.14317
42381
6067.69
101995
14602.82
50.9
7.287
Ford 330
6.9
.15198
21942
3334.75
74755
11361.39
53.2
8.080
GM 351C
3.7
.08150
4842
394.62
35656
2905.89
46.6
3.800
Ford 330
6.9
.15198
7521
1143.04
40257
6118.41
26.7
4.063
Chev. 350
7.0
.15419
6447
994.06
43378
6688.19
28.4
4.384
Dodge 318
1.6
.03524
7895
276.46
1304
45.96
45.9
1.618
Ford 300
3.9
.08590
6384
548.39
71748
6163.38
29.4
2.523
Chev. 350
7.0
.15419
4107
633.26
44631
6881.38
50.3
7.750
45.4 1.00
Sales Weighted Baseline Totals: 14046.12
90% Reduction from Baseline: 1404.6
55252.3
5528.2
42.34
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APPENDIX B
1977 Vehicle and Engine Manufacturer Information
Company
Total Sales ($)
Ret Income ($)
No. of Employees
Allis Chalmers
1,527,670,046
67,003,243
27,038
American Motors
2,236,896,000
8,266,000
29,519
Caterpillar
3,848,900,000
445,100,000
78,565
Chrysler
16,708,300,000
124,800,000
250,833
Cuna ins Engine
1,263,814,000
67,000,000
22,119
Ford Motor
37,841,000,000
1,673,000,000
479,300
General Motors
34,961,300,000
3,337,500,000
747,000
International
Harvester
4,016,915,000
203,737,000
93,160
Signal Companies
(Mack is about 1/2)
2,964,439,000
101,507,000
46,100
White Motor
1,253,670,000
14,558,000
9,703
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