EPA-420-S-77-100
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 Year Heavy Duty Vehicles
Emission Control Technology Division
March 15, 1977

-------
Introduction
This document provides technical information and analysis in support
of the decision regarding California's request for a waiver of Federal
preemption with respect to exhaust emission standards for 1979 and
subsequent model year heavy duty vehicles. Three technical issues
discussed and analyzed are: (1) stringency of.standards, (2) availability
of technology and lead time available for implementation, and (3) cost
of compliance. Assuming there are no legal problems involved, EPA is
required to grart the waiver unless it finds that the California standards
are equal to or less stringent than Federal standards, that insufficient
lead time is available for compliance, or that costs of compliance are
excessively high.
References to the transcript, "Public Hearing on-California's
Request for Waiver of Federal Preemption with Respect to Emission Standards
and Test Procedures for 1979 and Subsequent Model Year Heavy Duty Motor
Vehicles and Application of SHED Evaporative Test Procedures for 1978
and Subsequent Model Year Motor Vehicles" are recorded throughout this
document as [TR at (page)] meaning transcript at the page being referenced.
Conclusions
As a result of the analysis that follows, the EPA technical staff
concludes:
1. The California standards are more stringent than applicable
Federal standards.

-------
-2-
2.	There are three separate conclusions regarding lead time.
(i)	There is not sufficient lead time remaining to permit
mandatory certification under the new test procedures included
in California's 1979 regulation.
(ii)	Technology is generally available for compliance with
California's 1980 standards and sufficient lead time remains
for application of that technology to heavy duty engines.
There is some risk that fuel efficient technology cannot be
applied to some gasoline engines used in high weight vehicles.
However, several manufacturers were reasonably optimistic
regarding their ability to overcome potential problems within
the available lead time.
(iii)	Technology which can readily be applied to heavy duty
engines for compliance with California's 1983 standards is not
currently available; however, it cannot be established that
acceptable technology cannot be developed within the available
lead time.
3.	No arguments have been presented indicating costs of compliance
are excessive.
Stringency of Standards
EPA technical staff conclude and the record of the hearing supports
that the standards for which a waiver has been requested (see table 1)

-------
-3-
duty engines (40 g/BHP-hr of CO, 16 g/BHP-hr of HC +N0x)
Table 1
Proposed California Standards for
Heavy Duty Engines
Model Year
1979
or
1980	-
1982
or
1983
HC*
(g/BHP-hr)
1.5
1.0
.5
CO
(g/BHP-hr)
25
25
25
25
25
NOx
(g/BHP-hr)
7.5
HC + NOx*
(g/BHP-hr)
5
6.0
5
4.5
* HC standard based upon measurement using a heated flame ionization
detector.
No evidence was presented at the public hearing indicating that the
proposed California standards are not more stringent that current Federal
standards. The only discussions pertaining to relative stringency were:
comments made by the CARB representative arguing that their proposed
standards for 1979 were more stringent than proposed Federal standards
for 1979 (see TR at 12); and comments made by General Motors claiming
that California's standards for 1979 were more stringent than California's
standard for 1978 (see TR at 86-87).
The point regarding relative stringency between the 1979 CARB
standards and proposed Federal standards for 1979 is not pertinent to
the waiver decision since the Federal standards have not been adopted.

-------
-4-
When such standards are adopted, EPA will have to consider the relative
stringency of California standards and decide if it will be necessary
for the new Federal standards to preempt any existing California standards
for which a waiver has been granted.
The comments made by General Motors are relevant to the waiver
decision only to the extent that they reinforce the point that the
proposed California standards for 1979 are indeed more stringent than
current Federal standards. This is the case since EPA has already
granted a Waiver for California's 1978 standards as they were determined
to be more stringent than current Federal standards, and since General
Motors has claimed that California has made their standards for 1979
even more stringent.
Lead Time
Lead Time Available for Compliaiice with the 1979 Standard: With regard
to the 1979 California standards and accompanying test procedures,
various manufacturers stated that they would have a lead time problem in
meeting the 1979 model year California test requirements associated with
instrumentation acquisition, set-up, and check-out. In response to lead
time concerns, the CARB indicated that it had adopted the October 5,
1976 heavy duty vehicle regulation in order to be consistent with the
proposed corresponding Federal test requirements [TR at 191], and that
it had only acted in this matter in order to achieve a mutually acceptable

-------
-5-
cransltion to these anticipated Federal test requirements. In adopting
these regulations, the CARB indicated that it had relied to some extent
on EPA's judgment with respect to the requisite amount of lead time [TR
at 31]. The CARB indicated it would defer implementation of the new
test procedure until such, time as they also became effective Federally
[TR at 14, 22, 32], In the event that Federal regulations were subse-
quently promulgated which permitted a manufacturer to certify under the
present Federal test procedures for the 1979 model year, the CARB in-
dicated it would adopt a similar approach [TR at 32-33].
Several manufacturers indicated that it may be possible to comply
with the new test procedures in 1979, if the final Federal test procedures
are published and if subsequent revisions expected by California are
completed in the Spring of 1977 [TR at 44, 67-68, 90, 119-120, 184-185].
However, there were other situations in which some manufacturers indicated
it would not be possible to implement the new procedures by 1979 even if
the procedures were immediately finalized. General Motors stated that
the changes in the California heavy duty test procedures would require
extensive revisions to the existing diesel test facilities in addition
to the procurement of new instrumentation, and thus, it would not be
able to meet the 1979 model year test requirements [TR at 89-90]. While
Ford indicated it could acquire the necessary instrumentation in time
for two test cells, enough to certify California engines for 1979, [TR
at 161, 185], it devoted a considerable portion of its testimony add-
ressing the need for clarification and correction of the new test
procedures before they could be implemented [TR at 163-165, 170-178].

-------
-6-
The analysis performed within EPA in support of its own decisions
regarding implementation of the new test procedures at the Federal level
for the 1979 model year resulted in the conclusion that the procedure
could not be implemented on a mandatory basis for 1979. It was concluded
that some manufacturers could comply given an early definition of final
procedures, but not all manufacturers could be expected to be able to
comply [see the lead time analysis issue in DRAFT - "Summary and Analysis
of Comments to the NPRM: Revised Heavy Duty Engine Regulations for 1979
and Later Model Years", dated March 4, 1977].
Except for the instrumentation and test procedures issue, the
record clearly indicates that emission control technology is available
for compliance with the 1979 standard [TR at 165, 205].
Considering both the testimony presented at the hearings and the
analysis that EPA has performed independently in support of its own
proposed 1979 regulations, it is concluded that there is not sufficient
lead time for compliance with California's 1979 standard. This leaves
EPA with basically two options regarding the granting of a waiver for
1979:
(1)	deny the waiver, in which case the California 1978 standards
would carry over through 1979; or
(2)	grant the waiver on the basis that the standards and test
procedures be implemented only on an option basis, leaving the
manufacturer the option of certifying under the 1978 standards.

-------
-7-
The second alternative is recommended as it would be most consistent
with the approach which has been recommended at the Federal level [see
draft final regulations package for heavy duty vehicles, dated March 4,
1977].

-------
-8-
Lead Time Available for Compliance with the 1980-82 Standards: With
regard to the 1980-1982 California heavy duty standards and test procedures,
the lead time issues focus upon technology availability rather than test
procedures. The record generally indicates that the new procedures can
be implemented for 1980 and this is supported by the analysis performed
independently within EPA regarding its own proposed standards.
Chrysler, Ford and General Motors all indicated, with qualifications,
that the 1980 standards were technologically feasible. Ford indicated:
"As stated during the October 5, 1976 CARB public hearing, Ford
anticipates that the proposed standards for '80-'82 could result in
fuel economy penalties of about 5-10 percent over the '77 California
levels, mainly because of the lower hydrocarbon and NOx standards
which will require more EGR flow and less spark advance. Of course,
some of this fuel economy loss could be recovered with application
of catalysts on all of Fords' heavy duty engines, but Ford lacks
data at present to quantify the overall fuel economy effects, if
such catalyst sytems were used.
"Ford does not currently have final and proven design assumptions
for the emission control systems needed to meet the '80 and '83
standards. However, Ford does have sufficient experience with
light truck catalyst technology to provide reasonable assurance
that such systems can be employed to meet the proposed California
standards. Our experience with catalysts on the larger trucks is
so limited that Ford is not able to quantify the technical problems
that must be resolved for these vehicles. Thus, the key issues as
far as Ford is concerned, are in the areas of lead time, procedural
clarification, and consistency.11
[TR at 165].
In clarifying Fords statements regarding lead time for 1980 the following
discussion took pl^ce:
MR. JACKSON (EPA): "So there is no question of technology?"
MR. MAUGH (FORD): "Not for 1980."

-------
-9-
MR GRAY (EPA): "To follow up on that, you did make some quali-
fication regarding possible use of catalysts to minimize fuel
economy penalties. Do you have any judgement as to what percent of
the Ford heavy duty engines would require catalyst packages at this
point?
MR. MAUGH (Ford): "We do not. We have as you know, two heavy duty
engine families that were certified in '77 with catalysts, but
those were light duty trucks - not heavy duty trucks. In other
words they were under 10,000 GVW trucks. We have no experience
with catalysts on the high GVW trucks and certainly there have been
a number of problems raised today by other manufacturers with
respect to catalyst application on that type of vehicle.
"We don't have enough experience at this point in time to even
indicate that we have defined those problems. On the other hand,
we also don't have the basis on which to project that we can't
resolve them when we do find them. So we can't make any statement
with respect to our ability or inability in that particular area."
[TR at 195-196]
Chrysler indicated that:
"The proposed 1980-82 standards will require the addition of
catalysts to the system and, of course, require the use of unleaded
fuel. Additional exhaust gas recirculation and spark control to
meet the hydrocarbon and NOx standard will result in approximately
a 10 percent fuel economy penalty. The cost of the systems will
increase approximately $150. The only real question marks at this
time involve durability, but those problems should be solved by
1980." [TR at 205]
Further questioning illustrated that Chrysler's projected fuel economy
penalties may be pessimistic:
MR GRAY (EPA):' "With regard to the 1980 levels, you mentioned that
in addition to a catalyst, those engines probably would also
require EGR and spark control to meet the HC + NOx standards. And
you are projecting a 10 percent fuel economy penalty.
"Do you feel that once you add the catalyst over the '77 certified
vehicles, that supposedly . . . have some spark retard, I guess,
that you won't be able to recover some of that penalty and maybe
end up with a net change oŁ perhaps not that great for the penalty?"

-------
-10-
MR. WAGNER: "That's possible of course, but this is our best
estimate at this time." [TR at 206-207]
General Motors stated that the requisite technology was not available
to most effectively meet the hydrocarbon standard in effect in the
optional set of standards, for model years 1980-1982 in. its full product
line, {TR at 91] , "but did indicate that it could meet an emission
standard slightly less stringent than the 1980-1982 standard one year
earlier than the effective date of these standards [TR at 85]. Furthermore,
General Motors stated that its heavy duty gasoline engines for vehicles
with a gross vehicle weight rating (GVWR) of less than 18,000 pounds
could meet the 1980 standards through application of catalyst technology
developed for light duty trucks [TR at 93, 102]- It was pointed out
that these vehicles represented 70% of General Motors' heavy duty product
line above 85C0 pounds GVHR [TR. at 1G2] . On the other hencl> General
Motors contended that the requisite catalyst technology -was not presently
available to permit tae remaining 30% of its gasoline-powered heavy duty
product line to meet the 1980-1982 California standards [TR at 1Q2J, but
still had not definitely concluded that it could not meet these standards
¦witln a non-catalyst emission-control system [TR at 105J. They indicated,
that this 30 percent of its product line would require the use of a
catalyst emission control system in order to meet the 1980-1932 California
standards, and that its concerns with the use of such a system lie in
the area of customer satisfaction criteria and durability [TR 106-108].
With respect to its diesel-powered heavy duty engines and vehicles.
General Motors stated that these vehicles and engines could meet tho

-------
-11
1980 standards with a four percent increase in fuel consumption and an
increase in exhaust smoke. [TR at 96, 132, 135]. The increase in exhaust
smoke would not hinder these vehicles and engines in meeting the Federal
smoke standard [TR at 125].
International Harvester was the only manufacturer that indicated
that requisite technology was not presently available to meet the 1980-
1982 California standards:
"in. summary, 1R is convinced that California's proposed 1980-19S2
standards will require the use of converters on gasoline engines.
Lead time is not sufficient to design and test acceptable conclusion
converter equipped exhaust systems. To allow for the necessary
development and lead time for application of converters to engines
used in heavy duty service, we request that the standards be estab-
lished no earlier than for the 1983 model year." [TR at 48-49].
International Harvester did indicate that the standards could be
met t/ithout a converter at a significant fuel penalty (34%) and that
they consider that basically to be a non-option [TR at 55, 65]. However,
it was indicated that it was not impossible that International Harvester
would market a non-catalyst engine in 1980 [TR at 55]. Also, if the
waiver was granted, they could concentrate efforts on some undertermined,
but restricted product line and probably perfect a catalyst system for
use in that line by 1980 [TR at 70-75]. International Harvester indicated
at present it was not selling a diesel engine in California as their
engine had failed to meet the 1977 certification. However, they could
not project what the situation would be in 1980 [TR at '68],

-------
-12-
While no diesel manufacturers (i.e., manufacturers of diesels
only - General Motors and International Harvester produce diesel and
gasoline engines) testified at the hearing, the CARB presented information
in its statement indicating that Cummins had expressed confidence in
having its engines meet the 1980 standards, and Caterpiller had already
certified six 1977 engine models to the level of the 1980-1982 California
standards [TR at 16, 34].
Considering the above information, it is concluded that there is
not sufficient reason to deny the waiver requested for 1980 based upon
lead time considerations.
Lead Time Available for Compliance with the 1983 Standards: With regard
to the 1983 California standards, very limited information pertaining to
available technology and lead time for implementation was presented at
the hearings.
In its statement regarding the 1983 standards, the CARB testified
that of the 1977 model year engines certified in California:
"... seven gasoline and 12 diesel [engines], manufactured by
eight heavy duty engine manufacturers which in 1977 certified at or
below California's 1983 hydrocarbon standard of .5 grams per brake-
horsepower hour. The change in HC instrumentation may affect the
certification levels of some of the gasoline models. Of these 19
engine models, 10 also met the 1980 California standard of 6 grams
brakehorsepower hour for HC + NOx combined. In fact, two of these
engines — one gasoline and one diesel — met the 1983 standards of
0.5/25/4.5.

-------
-13-
"We do not mean to imply that just because the 1983 California
standards have been met by two 1977 models, Che technology is
currently available to make all heavy duty engines achieve these
levels. We do believe, however, that the fact that technology
exists to allow some heavy duty engines to achieve the 1983 stan-
dards today, combined with the six year lead time available to
heavy duty manufacturers, satisfies, the requirements of Section
202(a) of the Clean Air Act as interpreted above by the Admin-
istrator." [TR at 18-19],
The testimony by Ford regarding the ability to comply with the 1983
standards is best summarized by the following interchange:
MR. JACKSON(EPA): "So for 1983, technology is available?"
MR. MAUGH (Ford): "We can't say that we have the technology to
meet those standards in practice. On the other hand, we believe
that the technology that we have today will meet those standards,
and that the problems we encounter will be resolved, but we have no
basis to do that other than judgement. Pt is a judgemental position."
Chrysler was cautiously optimistic regarding its ability to develop
technology for the 1983 model year:
MR. GRAY (EPA): "Regarding the '83 standards, is it your best
estimate then that there is lead time remaining; that it is reasonable
to expect that technology might come along although you haven't
seen the technology demonstrated this date?"
MR. WAGNER (Chrysler): "Well, that's six years from now and
certainly we would expect that there would be time for any number
of advances in technology. I think it has to be recognized that we
are in the realm of speculation, however. I think we have proven
in the past that we have been able to perform a number of miracles
in six years." [TR at 207]
and;
MR. JACKSON (EPA): "And the assumption Łor '83 is that technology
appears to be there but there is some speculation - 1 think you

-------
-14-
said - with regard to the exact outcome of the application of that
technology."
MR. WAGNER (Chrysler): "That is a hard one, Ben. We say that
technology exists. You usually like to have some test behind you;
at least on some equipment that says that you are going to make it
before you can say that technology actually exists. We are all
working with three-way catalysts, electronic controls and elec-
tronic fuel metering. They all have possibilities. We have yet to
generate test results that indicate that we really have a functional,
system. Will we be able to do that in six years? I am fairly
optimistic." [TR at 208-209]
Likewise, General Motors exhibited a qualified optimism regarding
the 1983 standards:
"Our gasoline and diesel engines will be able after additional
development, to comply with the 1983 hydrocarbon standard, but we
presently project a catalyst change as necessary.
"Engine studies performed to date have failed to demonstrate ability
to comply with the 4.5 HC + NOx standard. It appears some new, and
yet untried system will be required to achieve compliance.
"Our experience to date has shown an increasing fuel economy penalty
as we bring our gasoline engines below 6 grams.NOx, and that the
fuel economy benefits from the addition of the catalytic converter
for hydrocarbon control, will be small, because at very low NOx
levels, we find the Brake Specific Fuel Consumption to be almost
totally dependent on the NOx level achieved.
"We presently have inhouse, an outside contracted diesel research
and development programs which are and have been targeted at
compliance with a five gram HC + NOx standard level. And that five
gram target has been on the existing instrumentation so that the
hydrocarbon component is at the lesser level. It may be necessary
to derate diesel engines in order to achieve a 4.5 gram per horse-
power hour standard.
"In summary of our position with respect to 1983 and subsequent
year standards, General Motors does not have, at this time, the
technology required to comply with the 1983 California standards.
Neither can we predict when technology will be available to allow
compliance." [TR at 98,99].

-------
-15-
However, General Motors did indicate it thought it would be able to
sell trucks in California in 1983, although they may have to have derited
engines:
MR. JACKSON (EPA): "Aside from the avilability of the Detroit
diesels to qualify, do you still believe that you will be able to
sell trucks in California in 1983 — heavy duty trucks?"
MR. HANLEY (GM): "Yes. They may have derated engines."
MR. JACKSON: "Which engines are you talking about?"
MR. HANLEY: "Both gasoline and diesel. If we can't meet it with a
fully rated engine, then the alternative is to begin to compromise
the power of the engine."
MR. JACKSON: "And that is Detroit diesel engines?"
MR. HANLEY: "And gasoline engines."
MR. HANSON (GM): "They wouldn't be derated; they would have other
compromises made. Possibly more in the fuel consumption and
driveability areas." [TR at 148]
International Harvester was the only manufacturer to be completely,
pessimistic regarding the 1983 standards, stating that:
"The 1983 proposed standards of 0.5 hydrocarbon and 4.5 HC + NOx
combined do not appear technologically feasible at this time. . ."
[TR at 49].
Based upon the above information, it is concluded that technology
which can be readily applied to heavy duty engines is not currently
available. However, the chances of extending light duty vehicle technology
or of developing new technology appear to be feasible within the remaining
lead time.

-------
-16-
Cost oŁ Compliance
Very little specific information was provided at the hearing
regarding the cost of compliance. The cost estimates varied over a wide
range reflecting the unknowns regarding the final control system types
that would be employed and reflecting the unresolved trade-off decisions
regarding initial control system cost versus fuel economy.
The estimates provided by Ford were based upon the assumption that
catalyst technology will be used on gasoline engines. Ford's estimate
of the incremental cost of a catalyst system beyond the cost of current
(1977 through 1979) California systems was $130 to $300. [TR at 197].
The applicability of these costs to the various levels of standards was
clarified by the following discussion:
MR. JACKSON (EPA): "So what it really comes down to is that on one
end of it you would say that the cost of meeting the 1983 standards
may not be greater than meeting the 1980 standards?"
MR. MAUGH (Ford): "No. I think that we would project that we will
be able to meet the 1980 standards on many of our engines without
catalysts and on none of them in 1983, so that 1983 clearly will
cost substantially more than 1980 on an average truck basis." [TR
at 198],
Ford also anticipated that the 1980-82 standards could result in
fuel economy penalties of about five to ten percent over 1977 California
.levels, but indicated some undetermined amount of fuel economy loss
could be recovered with the use of catalyst emission control systems (TR at
166].

-------
-17-
Chrysler estimated that control systems required to meet the 19S0
standards would increase vehicle costs by approximately $150 arid would
result in approximately a 10 percent fuel economy penalty fTR at 205J.
Chrysler further indicated that another $200 in control system costs and
an increase in fuel penalties to as high as 25 percent could result if
electronic timing and fuel controls with three-way catalysts are required
to meet the 1983 standards {TR at 206]* However, Chrysler's uncertainty
regarding the magnitude of fuel penalties which may occur was reflected
by the following discussion:
MR. GRAY (EPA); "With regard to the 1980 levels, you mentioned
that in addition to a catalyst, those engines probably would also
require ŁGR and spark control to. meet the HC 4- NOx standard. And
you are projecting a 10 percent fuel economy penalty.
"Do you feel that once you add the catalyst over the '77 certified
vehicles, tbat supposedly have bad to already help, have some spark
retard. , . that you won't be able to recover some of that penalty
and maybe end up with a net change of perhaps not that- great for
the penalty?"
MR. WAGNER (Chrysler): "That's possible of course, but this is our
best estimate at this time."
General Motors stated that the cost associated with meeting the
1980-82 standards would not exceed 500 dollars [TR at 134]. Mr. Hanley
from General Motors offered the following as his reason for not being
prepared to discuss cost impact in detail:
"We did not address cost in our statement because we don't have
firm hardware on which to estimate and because we did not see that
viable ar&uments could be made from a cost "benefit analysis that
would influence the decision on the waiver." fTR at 133].

-------
-18-
With regard to fuel penalties, General Motors estimated that a 10
percent penalty could occut under the 1980-82 standards if catalysts
cannot be used [TR at 129, 130], and that a 15 to 20 percent penalty was
expected under the 1983 standards [TR at 138].
International Harvester estimated cost increases for 1980-82
vehicles to be $395 to $490 per truck [TR at 48]. No estimate was given
for control systems required for 1983 as International Harvester claimed
those standards are not technologically feasible at this time [TR at
49].
The cost estimates made by CARB were included in its staff report,
number 76-20-2, "Public Hearing on Proposed Changes to Regulations
Regarding Exhaust Emission Standards and Test Procedures for 1979 and
Subsequent Model Heavy Duty Engines," dated October 5, 1976. For
gasoline engines, CARB estimated that:
". . . a 1.0 HC and 6.0 HC + NOx standard in 1980 would cost less
than $50 for gasoline engines on the average, requiring all gaspline
engines to have air injection and EGR. ... A catalyst system
used for a 1.0 gram HC and 4.5 gram HC + NOx standard would add
approximately another $150 to that cost.
"For (d)iesel engines, a 6.0 gram HC + NOx standard is estimated to
add about $300 more to 1977 model costs;.a 4.5 gram HC + NOx
standard would add another $300." [See page 8 of staff report].
The CARB report further estimated that at. the 6.0 HC + NOx level,
no fuel penalty was expected even without catalysts and at the 4.5
HC + NOx level, no fuel penalty was expected with the use oŁ catalysts.

-------
-19-
Engine testing sponsored by EPA at Southwest Research Institute, on
a 350 CID Chevrolet; gasoline engine, indicated that substantial emission
reduction can be achieved without fuel penalties if some advanced
emission control systems presently used on light duty vehicles are
adapted to the heavy duty gasoline engine. The following table indicated
soiae of the potential gains in 9-mode fuel economy associated with
various control technologies.
Table 2
9-Mode Test Results with Prototype Emission
Control Hardware
BSFC
(lbs/
% BSFC
improve-
nc + r»x
(gm/
CO
(gm/
HC
(gm/
System
BHP-hr.)
meat
BHP-hr.)
BHP-hr.)
BHP-hr
Baseline
.740
-
13.3
25.4
4.2
EFI-EGRtPL-
Fuel-Off
- 651
12.0
4. 6
26.1
.9
EFG-EGR-PL-
Decel
.704
4.8
5.1
25.4
1.0
AI-EGR-TR-
Decel
.676
8.6
4.9
5.2
.2
EFI-TR
.682
7.7
10.2
12.7
.8
EFI-TR-A1
.682
7.7
10.4
2.2
.1
BL W/lgn.
.641
13.3
17.0
32.1
5.8
Legend





EFI - Electronic Fuel
Injection



PL - Port: Liners
EGR - Exhaust: Gas Recirculation
AT - Air Injection
BL - Baseline
TR - Thermal Reactor
Fuel-off - Fuel Shut Off on Close Throttle Protion of Test
Decel - Fuel on During Closed Throttle (EFI)

-------
-20-
Considering the magnitude and uncertainty of the cost estimates
associated with the proposed standards for both 1980 and 1983, there
appears to be no basis for denying a waiver based upon excessive costs.
Of greatest concern are the estimated fuel penalties, for if penalties
on the order of 10 to 20 percent should occur, the cost associated with
the additional fuel consumed would over shadow projected increases in
initial control system costs. Based upon the full record of testimony
presented, it appears unlikely that substantial fuel penalties will
occur as a result of the 1980 standards. Information presented regarding
the 1983 standards in highly speculative. Considering the degree of
speculation of all of the estimates, the favorable indications of the
data in Table 2, and the available lead time, there appears to be no
basis for denial of a waiver for the 1983 standards because of excessive
cost through fuel penalties.

-------