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The original documents are located in Box 6, folder "Auto Emissions (4)" of the James M.
Cannon Files at the Gerald R. Ford Presidential Library.
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Digitized from Box 4 of the James M. Cannon Files at the Gerald R. Ford Presidential Library
THE WHITE HOUSE
Pat home
WASHINGTON
June 2, 1975
4
MEMORANDUM FOR
JIM CANNON
Review wrining
FROM:
MIKE DUVAL
novb
SUBJECT:
AUTO EMISSIONS
for
Attached is a rough draft of a memorandum to the President.
You already have the latest draft statement. We are working
on a Fact Sheet with OMB.
Vern Loen and Pat O'Donnell are gathering viewpoints from
the Hill. Pat reports that Senator Baker (ranking Minority
on Senate PWC) recommends that the President hold off taking
any action at this time. He thinks the President should wait
until the Subcommittee marks up a bill.
I talked to Frank Zarb and he thinks you should call a meeting
to discuss this in the context of the other key energy matters
facing Congress -- the strip mining and import fee vetoes,
decontrol, etc.
I recommend that you call a meeting for tomorrow and invite:
Morton
Zarb
Train
Coleman
Marsh
Friedersdorf
Seidman
Greenspan
Lynn
An alternative is for you to meet just with Zarb, Marsh and
Friedersdorf.
FORD it LIBRARY GENALD
FURL
MEMORANDUM FOR
FROM:
JIM CANNON
LIBRARY
SUBJECT:
AUTO EMISSIONS
In response to your decisions based on our memorandum
of May 19 (see Tab A), we have prepared the following:
1) A statement of the whole problem with emphasis on
the environment-energy-costs trade-offs; and
2) A Fact Sheet which elaborates on the statement.
The Senate (Muskie Subcommittee) and House (Rogers
Subcommittee) auto emission hearings have concluded. Both
Subcommittees are in markup.
[insert Congressional summary]
We expect any announcement of your decision to support
a five-year freeze at the current standards to draw considerable
criticism from environmentalists. The timing of any action
must be measured in terms of its impact on other key Congressional
votes, e.g., override attempts on your veto of the bill sus-
pending your authority to impose the import fees and the strip
mining bill. [insert timing assessment + views of advisors ]
There are three basic options available to you:
1) Send a message to Congress (see Tab B).
Sub-option: Submit legislation now that the
hearings are over.
Pro:
Con:
2
2) Have one of your advisors (e.g., Secretary Morton
as Chairman of the ERC) send the substance of the
draft message to the appropriate Committee Chairman.
Pro:
Con:
3) Delay any action until after Congressional action
on other controversial energy matters.
Pro:
Con:
Jim spramine
DRAFT 5/31/75
STATEMENT BY THE PRESIDENT
Several Congressional committess, both in the House and
in the Senate, are considering legislation affecting the
automobile which will have a profound impact on the Nation's
ability to achieve several very significant National objectives.
Several committees are considering legislation to redefine
Federal automobile pollution requirements and separate legis-
lation designed to increase automobile fuel efficiency is also
under consideration.
Final decisions by the Federal Government concerning the
automobile will have a profound impact on our Nation's ability
to achieve our goals concerning public health, energy, consumer
prices, unemployment and improved air quality. Government
decisions must reflect a balancing of these conflicting
National goals.
I therefore urge Congress to consider how Federal laws mad/
dating automobile fuel efficiency and emission control might
work against each other and how cumulatively they will impact
on other National objectives such as public health and main-
taining a strong economy.
In responds to recently disclosed information concerning
potential health hazards from automobile pollution control devices,
I ordered a major review within the Executive Branch which has
just now been completed. I asked my advisors to consider the
various alternatives concerning automobile fuel efficiency and
emissions on public health, energy goals, consumer prices and
environmental objectives.
2
Based on this intensive review, I have concluded that
we should maintain the current automobile emission standards
for five years and impose strict requirements on increased
automobile fuel efficiency. This will enable us to obtain
the following objectives:
Maintain strict control over the health impacts of
automobiles by not increasing unknown but potentially
dangerous pollutants and maintaining strict control
over known health hazards, such as carbon monoxide
and hydrocarbons.
Achieve at least a 40% increase in automobile fuel
efficiency by 1980.
Achieve
% of the environmental objectives envisioned
by the Clear Air Act of 1970.
Minimize the inflationary impact of Federal regulations
on the cost of automobiles to consumers.
I recognize that this position modifies the auto emission
standards contained in my proposed Energy Independence Act of 1975
which I transmitted to Congress on January 30. However, as
pointed out in recent testimony during Congressional hearings,
the Administrator of the Enivronmental Protection Administration
is
y
to
announced in March that a lossening the strict emission
standards that I proposed. was necessary. Administrator Train
concluded after hearings conducted by EPA that sulfuric acid
mist is emitted from cars equiped with a catalytic convertor
3
which all new cars have in order to meet the EPA emission
standards. Mr. Train and the Secretary of Health, Education
and Welfare, concluded that this is a potentially serious
health hazard. Evidence brought out at the EPA hearings
and by
government reports shows that current
catayltic convertors on all cars in the U.S., except those
sold in California, do not emit sufficient sulfuric acid s AS
to constitute any immediate danger. However, if the auto
emissions standards are lowered, as is required under current
law, then a different catalytic convertor must be used
which produces substantially more sulfuric acid. This
would pose a health risk which my advisors conclude the
FORD LIBRARY
country should not accept.
Accordingly, I have decided to carefully balance the
health findings of the EPA hearings along with the energy
objectives which the Nation must achieve and have concluded
that I must modify the strict pollution standards I proposed
to the Congress in January.
The Nation does need a long-termautomobile fuel and
pollution policy in order that the private manufactors can begin
to build these cars which will meet these energy and environmental
requirements. It may very well be that additional government
standards, such as regulating the sulfuric acid emissions,
may be required in future years. This is something that EPA
and other government agencies are working on closely with the
appropriate committees of Congress.
4
Nothing could be more intolerable than delay and
continuing conflict between Federal energy and environ-
mental policies and laws. This will cause further
economic disruption of the U.S. automobile industry and
continuing unacceptable levels of unemployment. Furthermore,
lack of a comprehensive and balanced policy will allow one
objective to go forward at the expense of other critical
National goals.
In order to demonstrate the difficulty of this decision
and the interrelationships involved, the following information
summarizes the result of the Executive Branch review.
Background
The Clean Air Act amendments of 1970 set very rigid
standards and deadlines for the reduction of hydrocar-
bons (HC) , carbonmonoxide (CO) and oxides of nitrogen (NOX)
from automobiles. It proved impossible to meet the orig-
inal requirements and changes have been made. The current
statutory requirements are:
HC
CO
NOX
1977
1.5
15.0
2.0
1978 and future years
.41
3.4
.4
There is broad agreement that the current statutory
standards applicable to 1978 would be extremely difficult
and perhaps impossible to meet, would involve increased
therefore
costs and decreased mileage, and will have to be changed.
These requirements as well as the 1977 requirements are now
being subjected to Cogressional review.
Alternatives
The review by Executive Branch agencies considered the
implications of a range of alternative automobile emission
requirements which might be applied to 1977 through 1981
model automobiles. Specifically, the following standards
- 4 -
applicable to hydrocarbons (HC) # carbonmonoxide (CO) and
oxides of nitrogen (NOX) emissions have been considered:
Emissions in grams per mile
HC
CO
NOX
My January 30
recommendations covering
1977-81 model years
0.9
9.0
3.1
Mr. Train's March 5
conclusions
- for 1977-79 models
1.5
15.0
2.0
- for 1980-81 models
.9
9.0
2.0
Continue standards
applicable to 1975-76
models for 1977-81
1.5
15.0
3.1
Adopt Canadian 1975-76
standards for 1977-81
models
2.0
25.0
3.1
Reimpose standards
applicable to 1973-74
models for 1977-81
3.0
28.0
3.1
Important Factors
There are a number of significant factors that need to
be considered in evaluating the automobile emission problem:
1. Controls on auto emissions have produced significant
benefits and will continue to do so in those areas that
have an auto-related pollution problem. Lower pollutant
levels in these areas can reduce adverse health effects and
reduce photochemical oxidants (smog) which is aesthetically
unpleasant and a serious respiratory irritant.
2. Automobile related pollutants are a problem in a number
of metropolitan areas but are not a problem in many
parts of the country. Auto emission standards, however,
- 5 -
have been applied nationwide (except in California which
may have more stringent standards) and the added costs
for pollution control equipment, maintenance, and lower
gasoline mileage are paid by drivers in all areas of the
country -- including those areas that do not have a problem.
3. Controlling automobile pollutants is a technologi-
cally complex problem as illustrated by the fact that steps
taken to control some pollutants from internal combustion
engines have had the effect of increasing other pollutants
or creating new ones. For example, controls to reduce
hydrocarbons (HC) tend to increase emissions of oxides of
nitrogen (NOX) -- and the reverse is also true. The most
recent example is the potentially serious problem of sulfuric
acid mist from cars equipped with catalytic converters
installed to meet 1975-76 hydrocarbon (HC) and carbonmon-
oxide (CO) standards. Also, experts now indicate that
reduction of NOX standards below the current standards (3.1
grams per mile) could require the use of larger catalysts
or catalysts with air pumps which increase sulfuric acid
emissions.
4. Considerable progress has been made on automobile
emissions since the 1970 Clean Air Act Amendments were
passed. In the case of HC and CO, the standards applied to
1973 74 model cars reflect a 65% reduction in emission from
below pre-cential levels.
- 6 -
the
pre control levels (and 1975-76 standards reflect an 83 per-
cent reduction) In the case of NOX, EPA determined subsequent
to the 1970 amendments that earlier assessments of NOX con-
centrations in air were in error and that a 90 percent re-
duction in NOX emissions was not necessary to meet ambient
air quality standards. However, NOX emissions have been
reduced by 12 percent from uncontrolled levels and work is
underway to find more effective ways of controlling NOX
emissions from stationary sources. Stationary sources con-
tribute more NOX than automobiles in most of the 10 metro-
politan areas that could have concentrations exceeding the
national standard over the next 10 years.
5. Tighter or looser auto emission standards for HC,
CO or NOX within the range of alternatives available make
little difference in the air quality in the areas that have
an auto-related pollution problem. This little known fact
is true because: (a) of progress already made in controlling
and
emissions of (b) automobiles are not the principal source of
the pollutant involved. The contribution of HC, CO and NOX
from automobiles will continue to decline as more and more cars
meeting existing or past standards replace older models in the
Nation's fleet of automobiles. In the case of carbonmonoxide,
concentrations in metropolitan areas around the country have
* Substitute parenthetic phrase if decision is to
maintain current (1975-76) standards.
- 7 -
been declining steadily. Hydrocarbon emissions (which are an
ingredient of photochemical oxidants or smog) have been de-
clining but less rapidly than carbonmonoxide because auto-
mobile exhaust emissions account for only about 25 percent
of the hydrocarbons that comes from other than natural sources.
In the case of NOX, three metropolitan areas in the country
experience concentrations at this time which exceed national
air quality standards and this number may increase to 9 or 10
areas in the next 10 years. The growth would be due primarily
to stationary sources. Tightening standards for automobiles
below the current levels could produce slightly lower con-
centrations in the future, but such tightening would not
assure meeting national ambient air quality standards in the 9
or 10 metropolitan areas expected to have a problem. As
indicated above, tightening of HC, CO or NOX standards is
expected to increase the emission of sufuric acid.
In addition, a reduction in vehicle miles traveled due
to energy conservation actions or growth in vehicle miles
traveled that is less than EPA has projected will further
minimize projected auto-related pollutant problems.
6. Experts believe there is little or no health impact
that can be attributed with the small margin of change in
ambient air quality that would result from tighter or looser
- 8 -
HC, CO or NOX auto emission standards within the range being
discussed. This is the case principally because tightening
standards beyond 1973 74 levels (1975-76 levels will have
very little impact on concentrations of these pollutants in
the areas that have an auto-related pollution problem.
7. There is uncertainty concerning the health impact
of sufuric acid mist emissions from catalyst equipped cars
because of insufficient data and divergent estimates of the
importance of the problem among the various interests concerned.
The seriousness of the sulfuric acid emissions problem will
depend upon (a) the amount of emissions from catalyst
equipped cars, (b) the extent to which concentrations of
surfuric acid buildup in areas that impact the public, and (c)
whether there is a threshold below which sulfuric acid is not
injurious to health. While there is uncertainty, the Admin-
istrator of EPA and the Secretary of HEW have made it clear to
me that they believe there is the potential for a significant
health risk that cannot be dismissed with information now
available. This assessment led the Administrator of EPA
to conclude on March 5 that HC and CO standards should not be
tightened at this time because tighter standards would, with
technology now available, force use of catalysts and air pumps
thus measing subfuris accd
on many cars nationwide in 1977 Because of the potential risk,
the Administrator also announced that he is proceeding to set
an emission standard covering sufuric acid applicable to 1979
model cars.
*
Substitute parenthetic phrase if decision is to
maintain current (1975-76) standards.
- 9 -
8. Auto emission standards have had a significant
impact on miles per gallon of gasoline and on our Nation's
total petroleum demands and reliance on foreign sources.
Emission controls applied to automobiles between
the years 1968 and 1974 caused a very significant reduction
in miles per gallon of gasoline. It is true, however, that
the use of catalytic converters on 1975 cars manufactured
to meet 49-State emission standards permitted engine adjust-
ments which helped regain some lost gasoline mileage. The
higher levels of pollution created in the retuned engines
were captured and changed chemically in the catalytic con-
verters. Cars which must meet the tighter emission standards
applied in California generally get poorer gasoline mileage
than similar model cars produced for other states.
for
An additional impact on petroleum demands comes
from the need for unleaded gasoline for catalyst-equipped
cars. The production of unleaded gasoline required changes
[slightly J
in refinery processes which h increase the quantity of
crude oil required to produce each gallon of gasoline at the
required octane level.
&
While there is some disagreement among Executive
Branch agencies, the best information now available indicates
that for the next few years emission standards tighter than
current levels will involve significant gasoline mileage
- 10 -
=
penalties. Specifically, with technology now available,
there would be a fuel economy penalty associated with tightening
the NOX standard from 3.1 to 2.0 grams per mile and there
would be an additional penalty associated with tighter HC
and CO standards.
GERALD FORD VIBRARY
There is also general agreement that technology
is available to permit increases in fuel economy over the next
few years compared to 1974 levels if 1975-76 standards are
maintained through 1971. Even greater fuel economy im-
provements could be achieved within a few years if either the
1973-74 standards were reestablished or Canadian standards
were adopted.
9. In addition to poorer fuel economy, increased
consumer costs resulted from higher initial car costs for
emission control equipment and associated maintenance costs.
Tightening of HC, CO or NOX standards from 1975-76 levels would
involve additional consumer costs. Actions to reduce sulfuric
acid emissions from catalyst equipped cars would involve
large additional costs.
10. Less stringent auto emission within the range now
available would open up technological options for meeting
standards that would not be available with tighter standards
(e.g., the so-called stratified charge and diesel engines,
"lean-burn" technologies and other internal combustion engine
modifications). These technological options will permit
fuel economy improvements that are not possible with
tighter standards.
- 11 -
11. The basic philosophy and approach that has been
used to bring about auto emission controls needs to be
reconsidered in light of current conditions.
a. We should be clear about the philosophy that has
been applied in the Clean Air Act auto emissions standards
and the rationale behind that philosophy. Briefly, the
philosophy has been that automobile companies do not have
market incentives to develop technology to reduce auto
emissions and would not develop such technology unless
forced to do so by progressively rigid standards backed
up by law and regulation. It would be difficult to contend
that progress achieved so far in controlling auto emissions
would have been achieved if this approach had not been used.
On the other hand, hindsight suggests we may now be faced
with a potentially serious sulfuric acid problem which
might not have occurred had more time been allowed to
develop and assess technology before it was put into use.
The wisdom of continuing a rapid "technology forcing"
approach is open to question.
b. Auto emission standards have been changed frequently
in recent years, allowing little time for developing and
assessing alternative technologies. As standards have
become more stringent, the technological changes required
- 12 -
have become more extensive and more sophisticated. More
time is required to develop and assess improved technology
and bring it to a stage where it can be used on production
line cars. These factors, the current economic status of
the automobile industry, and the demands being placed on
the industry simultaneously to meet safety standards and
to improve fuel economy need to be kept in mind when the
Congress considers the question of whether standards should
be held stable for more years than has been the case in the
recent past.
12. Prompt Congressional action is needed on auto
emission standards. This matter warrants thorough dis-
cussion by the Congress and the public because of the far
reaching implications. The matter also requires an early
decision by the Congress. Specifically, the Administrator
of EPA adivses me that in order to meet deadlines for
emission testing and certification of 1977 model cars, the
automobile industry will need to know 1977 emission standards
by early August 1975 so that there will be time to complete
design and engineering, build prototypes, complete emissions
testing such as 50,000 mile endurance tests, and finally
to produce new cars in adequate quantity to meet demand
from the American public.
- 13 -
13. The broader economic implications of the auto
emission decision must also be kept in mind. There
undoubtedly has been some contribution to inflationary
and recessionary pressures in the economy from the
increased consumer costs, and poorer gasoline mileage
(and greater reliance on foreign oil) resulting from
emission control requirements. Inflationary and recession-
ary conditions have both contributed to and resulted
from sharply lower sales and employment in the auto
industry. Of course, any costs associated with auto
emission controls must be balanced against the health,
aesthetic and economic benefits that are gained from
improved air quality.
14. Actions to reduce auto emissions must take into
account other sources of the same pollutants. In cases
where stationary sources of the same pollutants are
significant contributors to a problem in the metropolitan
areas of concern, it may be far more cost effective to place
greater reliance on reducing pollution from stationary
sources. The problem of other sources is complicated
by a growing body of opinion that natural sources of
pollutants -- which cannot be controlled -- may be
sufficiently important in some areas to prevent attaining
- 14 -
national air quality standards regardless of what is done
to control man-made sources.
Legislative Recommendations
Based upon the information and data that have been
developed during the Executive Branch review of the auto
emissions issue, I have today recommended to the Congress
that the Clean Air Act be amended to set standards of
grams per mile for HC,
for CO, and
for NOX.
I have further recommended that these standards be kept in
force for
years. These standards would be equivalent
to those in effect for
model year cars. My conclusions
are based on an evaluation of air quality, health, consumer
cost, fuel economy, and other energy and economic considera-
tions.
First, the principal reason for my recommendation of
less stringent HC and CO requirements than I recommended
earlier is the unknown but potentially serious health
effects associated with sulfuric acid emitted from catalyst
equipped vehicles, and the fact that this problem is
exacerbated by the use of air pumps which would be needed
on most cars to meet those standards. In the absence of
better data and greater agreement among experts, the
potentially serious health effects must take precedence
over the known but very small potential health effect
- 15 -
associated with the slight changes in HC and CO concentra-
tions if HC and CO standards tighter than I have proposed
were established.
Second, I have concluded that tightening of the NOX
standard from 3.1 to 2.0 grams per mile would be undesirable
because the probable fuel economy loss and the probable
need to use air injected catalyst systems to meet the
2.0 standard, which would increase sulfuric acid emissions.
These potential costs are not balanced by the benefits of
the very small change in ambient air quality and the im-
perceptible impact on health that could result from the
tighter standards.
Third, the marginal benefits in a few metropolitan
areas which might result from tighter nationwide standards
are very small. Based upon the information now available,
those benefits do not appear to justify the additional
consumer and energy requirements costs, that would be
imposed nationwide. Furthermore, the standards I have
proposed preserve technological approaches to pollution
control that are cheaper in terms of fuel requirements and
consumer costs which would not be available under tighter
standards.
- 16 -
Fourth, I have proposed that the standards remain
constant for
years so that the industry is not
distracted unnecessarily from efforts to improve safety
and fuel economy. A pause for this period will not have
significant adverse effects on our progress in improving
air quality. It will also provide time for industry
and the Government to help avoid costly errors and
increase the chances of meeting fuel economy, safety
and consumer cost objectives.
Administrative Actions
Because of the far reaching impact that automobile
emission standards can have on all of the factors I have
discussed, I feel very strongly that we should have known
a great deal more about their impact before standards were
set.
I believe the Nation should not be subjected to far
reaching Federal actions such as establishment of auto
emission standards which required the catalyst without
far better information than was available before this
action was taken.
Current law requires that an Environmental Impact
Statement be prepared showing the expected environmental
impact of major Federal actions significantly affecting
the quality of the human environment. Somewhat ironically,
- 17 -
that requirement has not applied to Federal pollution
control actions, such as the setting of auto emission
standards which led to the catalyst technology. If such
a requirement had been followed we might have known in
advance of the health, environmental and economic impli-
cations of auto emission standards which led to the
installation of catalytic converters.
Because of my concern over the potentially unforeseen
results of Federal actions, I have directed previously
that inflationary impact statements be prepared on
significant Federal actions affecting the economy. I
intend to continue pursuing that basic approach to Federal
decision making.
THE WHITE HOUSE
WASHINGTON
June 17, 1975
MEMORANDUM FOR:
DICK DUNHAM
FROM:
JIM CANNON am
SUBJECT:
Auto Emissions
On the June 14 draft of Auto Emissions: This draft does
not spell out precisely what has changed since the
President's previous decision to warrant our asking him
for a new decision.
Would you ask Mike to redraft, and spell out on the first
page, in a direct and crisp way, what has changed that
requires the President to take a different action from
the previous action.
I also think this should be staffed more widely to
Hartmann, Marsh, Friedersdorf and Buchen.
It seems to me that Auto. Emissions is an issue on which
we should say what is necessary, but only what is necessary.
If we want to transmit a message that includes technical
elements, which Mike's draft does, perhaps it should be
authored by Zarb or someone who has the technical capability
in this field, and not the President.
FORD LIBRARY is GERALD
THE WHITE HOUSE
WASHINGTON
June 14, 1975
MEMORANDUM FOR
JIM CANNON
FROM:
MIKE DUVAL
SUBJECT:
AUTO EMISSIONS
Attached is the auto emission package.
Tab A - Draft memo to the President and draft
Message to Congress.
Tab B - Draft Fact Sheet
Tab C - I and A format which OMB is preparing as
a possible cover for the Fact Sheet.
If the President intends to raise this issue at Tuesday's
Leadership meeting, I recommend that Tab A go to him Monday
at 4:00 p.m. This means we should send it to the senior
White House staff, plus Zarb, Coleman and Weinberger, for
their comments and votes first thing Monday morning. I
recommend that any copy taken outside the White House
complex be hand-carried.
I will be available (reachable by the White House Operators)
tomorrow except during church - 10-11:30 a.m.
FORD
TIBRARY
DRAFT
THE WHITE HOUSE
DECISION
WASHINGTON
June 14, 1975
MEMORANDUM FOR
THE PRESIDENT
FROM:
JIM CANNON
SUBJECT:
AUTO EMISSIONS
BACKGROUND
Just prior to your departure for Western Europe, you made
two decisions concerning auto emissions.
1.
Send to Congress a detailed statement of the environ-
mental, energy, health and cost trade-offs concerning
23
automobile emissions, but hold off making a specific
recommendation for legislation until after committee
hearings have been completed (this has not yet been
implemented) ; and
2. On the substance of the issue, you indicated a pref-
erence for a five-year extension of the current emis-
sion standards.
The House Health and Environment Subcommittee (Rogers) and
what
the Senate Environmental Pollution Subcommittee (Muskie) have
both concluded their hearings on the auto emissions question,
and neither committee reopened hearings after the recess to
changed.
consider the trade-off between environment and energy. Both
subcommittees are in the process of marking up an auto emis-
sions bill and apparently will not consider the impact of
auto emissions on fuel efficiency.
and air Direct and
As you know, the House has included in the Ullman energy bill,
a provision requiring a 50% improvement in automobile effi-
ciencies by model year 1980, enforced by a relatively mild
tax on automobiles which do not meet the goal.
juni
any
ank
2
ISSUES FOR DECISION
The purpose of this memorandum is to present two issues for
your decision.
A. Should you now transmit to Congress a statement on
the auto emissions issue, along with legislative
recommendations?
B. If so, what form should it take?
If the auto emissions issue is to be discussed at your meeting
with the Leadership on Tuesday, I recommend that you hold off
any final decision on these two questions until after the
meeting.
DISCUSSION
1.
Should you transmit a Message on auto emissions, along
with legislative recommendation, to continue the present
standards for five years?
Arguments in Favor
It appears clear that neither the Senate nor the House
will hold hearings at the subcommittee or committee
level (as we had urged) on the difficult trade-offs
involved between environment and energy. In both
cases, they have discussed the health impact, and to
a lesser extent, cost. Nevertheless, both committees
appear headed towards recommending much tighter emis-
sion standards. We understand that the Rogers Committee
may recommend
The Muskie Committee, according to our information, is
likely to recommend that we adhere to the 1978 statu-
tory standards.
If final Congressional action is anywhere near these
positions, it will seriously jeopardize your energy
goal of a 40% improvement in auto efficiency by 1980.
Furthermore, such a decision raises substantial health
questions concerning the emission of sulfuric acid mist.
(See Tab A for draft Presidential Message which develops
these arguments in some detail. This has not yet been
reviewed by the speechwriters.)
If you are to have any influence on the auto emission
legislation, it appears that now is the time to present
your views to Congress. Submission at this time of a
3
Statement of Facts only, without a legislative recom-
mendation, probably would not be viable because it
would raise more questions than it would answer. If
the committees are not going to hold additional hearings,
in which they consider the energy impact of their emis-
sion decisions, there would be no forum to debate your
Statement of Facts. Furthermore, Administration spokes-
men could expect to be barraged with questions as to
where you come out on the issue, and we could not make
the response that you wanted to wait until additional
evidence was heard by Congress. As a practical matter,
a statement by you, along with a specific recommendation,
is probably necessary if we are to have any influence
on the final outcome.
You must also consider the potential adverse political
impact if Congress does not provide legislative relief
from the stricter standards and, as a result, injuries
occur because of the sulfuric acid mist or other toxic
pollutants which may result from pollution devices which
the automobile manufacturers adopt to meet the strict
standards.
Arguments Against
EPA's John Quarles (Russ Train is out of the country),
argues that you should endorse the Train announcement
of March 5, which would impose a set of standards which
are stricter than the existing levels, but less strict
than your "modified California" proposal in January.
In essence, EPA is reraising the issue you decided
prior to going to Europe. They argue that Congress
is more likely to respond to the Administration recom-
mendation if you and Train are together. However, Frank
Zarb, Jim Lynn, and others, feel strongly that the Train
position will prevent us from achieving our energy ob-
jectives.
We must consider how you are perceived by environmenta-
lists and those who support their objectives. The
Hathaway nomination, your strip mine veto, and position
on the utilities bill have resulted in substantial criti-
cism of your policies from environmentalists. There is
no doubt that your decision on the auto emission question
will be extremely controversial -- perhaps eclipsing the
strip mine veto. Therefore, you may wish to separate
yourself from this decision as much as possible by just
issuing a generalized Statement of Facts and leaving
specific recommendations up to other Administration
officials.
4
2.
If you decide to send a Message to Congress with
specific recommendations, what form should it take?
This issue really raises two questions.
First, should you issue a statement personally, or
should this be done by a subordinate?
Arguments That You Should Issue the Statement
This subject is of enormous importance to all Americans,
as it touches their lives directly on a familiar issue.
It involves the trade-off between conflicting national
objectives, none of which fall under the sole responsi-
bility of a subordinate official within your Adminis-
tration. In short, this is exactly the type of inter-
related decision involving many trade-offs which should
be made by the President.
Arguments Against a Presidential Message
This is going to be a controversial decision, regardless
of which way you come down. This matter involves a
great deal of technical data and conclusions, much of
which is in controversy, and much of the subject matter
is simply unknown. Therefore, any Statement of Facts
and conclusions are bound to be attacked as to their
accuracy.
Second, if you decide to send a Message, should it be
brief or detailed?
Arguments for a Detailed Message
If you issue a Message on this subject, the attack is
likely to follow the line taken on your position con-
cerning strip mining. Your position will be characterized
as a cave-in to Detroit, based in part on bad information
from your advisers. The best way to meet this is by
showing the Members of Congress and the Press, the steps
you went through and analysis you have made in reaching
your decision. This is an extremely complex subject,
but an understanding of the facts does lead logically
to the conclusion you have made. The reaction to your
statement should be one of recognition that you have
gone through all the complex data and analysis and
were driven to your decision on the basis of a detailed
substantative review.
5
This is similar to your energy decision and involves
a massive amount of conflicting and highly technical
information which must be developed into a policy
decision involving the balancing of conflicting
national objectives. You should seek to make the
point that you did not duck the complexities of this
issue, but got into it personally and reached your own
conclusion based on the best information available.
Arguments for a Brief Message Followed by Detailed
Backup Information Released by Another Administration
Official
Some will argue that, as President, you should not get
into the details of a highly technical and scientific
subject, especially when there is little agreement among
the experts on the facts involved. Others should be
required to defend the specifics, and you just take
the higher road by issuing a Message based on final
conclusions.
There is a great deal of conflicting scientific informa-
tion, including a recent study under the aegis of the
National Academy of Scientists, which concludes that
stricter standards should be adopted than you have
proposed. If you issue a detailed statement in this
area, you will be taking on many in the scientific
community who feel we should go to the statutory
standards.
DECISION
1.
Transmit Message to Congress with Statement of Facts
and legislation freezing the current standards for
five years.
Recommend: Cannon, Lynn
Approve
Disapprove
Transmit Message without recommended legislation.
Recommend: EPA (Quarles)
Approve
Disapprove
FURD
HIBBARY
6
2. Transmit package as Presidential Message.
Recommend:
Approve
Disapprove
Transmit from the appropriate Cabinet official.
Recommend:
Approve
Disapprove
3. Use detailed format.
Recommend:
Approve
Disapprove
Use summary Message with details issued by the appro-
priate subordinate official.
Recommend:
Approve
Disapprove
DRAFT
MASTER
6/11/75
1:00 p.m.
MESSAGE to congress
Four and a half months ago, I sent to Congress my pro-
posed Energy Independence Act of 1975. As a part of that
comprehensive legislative proposal, I recommended that the
Congress modify the Clean Air Act of 1970, concerning emis-
sions from automobiles. I proposed strict pollution levels
which would still permit this Nation to achieve one of my
energy goals, which is a 40% improvement in automobile fuel
efficiency within four years.
Since that time, information has been disclosed concerning
potential health hazards from automobile pollution control
devices. In response to the serious issues raised by even
the possibility of any such hazards, I ordered a majar review
of the questions raised within the Executive Branch. I asked
my advisers to consider the various impacts of a range of
emission alternatives on public health, energy goals, consumer
prices and environmental objectives.
This review has now been completed. We have surveyed this
entire subject matter, with many scientists and other experts,
and find regrettably little agreement on the data or conclusions.
There is, however, general agreement that we really cannot
with precision which
predict what adverse impacts are likely to result if we move
to stricter automobile pollution standards. Most of the experts
also agree that there is an interrelationship between the
levels of pollutants emitted by our cars and their fuel effi-
ciency and cost to the consumer.
PORD LIBRARY N
2
It is relatively easy to state the problem. As the
automobile manufacturers are required by government regula-
tion to remove certain some pollutants from the car's exhaust,
other pollutants with potentially serious health implications
are being produced. Some of the devices which would help to
correct some air pollution problems result in the creation or
aggravation of others. Some of these same devices result in
serious reductions in the automobile's fuel efficiency. The
result of government-mandated changes to our automobiles could
further
their price
then be substantial increasesin its prica tag, without
substantial environmental benefits and with possible risk to
the Nation's health.
As a result of actions already taken, we are well on the
road to cleaning the Nation's air. A major part of our task
is behind us but, unfortunately, it was also the easiest part.
We have now reached the point where the further incremental
progress we all want can only be achieved very slowly, and at
higher great cost, under any of the possibilities reviewed. The
MOST
relatively short distance remaining is a very rough road indeed.
I therefore urge Congress to consider how Federal laws
mandating automobile fuel efficiency and emission control might
work against each other, and how, cumulatively, they will impact
on other national objectives such as public health and maintaining
a strong economy.
3
In view of all of these considerations, I have decided
that oven the position my Administration has already taken
in the Energy Independence Act must be revised. We simply
cannot afford to be wrong, or hesitant, where such serious
issues are at stake. I have concluded that we should maintain
the current automobile emission standards for five years. This
ashieve
will enable us to cbtain the following objectives:
Maintain strict control over the potential adverse
health impacts of automobile emission devices by
retaining current controls on known health hazards,
such as carbon monoxide and hydrocarbons, without the
risk of increasing imperfectly understood but potentially
dangerous other pollutants.
Achieve at least a 40% increase in automobile fuel
efficiency by 1980.
Achieve almost all the environmental objectives we
would have achieved by going to the stricter standards
I proposed in January.
Minimize the inflationary impact of Federal regulations
on the cost of automobiles to consumers.
I recognize that this position modifies the auto emission
standards contained in my proposed Energy Independence Act
of 1975 which I transmitted to Congress on January 30. However,
as pointed out in recent restimony during Congressional hearings,
the Administrator of the Environmental Protection Administration
has already noted that it is necessary to adjust the strict
emission standards that I proposed. Administrator Train con-
4
cluded after hearings conducted by EPA that sulfuric acid
mist is emitted from cars equipped with a catalytic converter,
most
which all new cars have in order to meet the EPA emission
The Administrator
standards. Mr. Train and the Secretary of Health, Education
and Welfare, concluded that this is a potentially serious
health hazard.
Evidence brought out at the EPA hearings and by govern-
levels of Emitsions from,
ment reports, shows that current catalytic mufflers -
in
do
not
emit sufficient sulfuric acid so as to constitute any
immediate danger. However, if the auto emission standards
are further lowered, as would be required if no change is
made in the current law, then a different catalytic muffler
is likely to have to be used. That device would produce
substantially more sulfuric acid, and other possibly dangerous
emissions as well. This would pose a health risk which my
advisers conclude we should not accept.
The Nation needs a long-term automobile fuel and pollution
policy so that we can begin to build cars which will meet
responsible energy and environmental standards. By getting
on with the job of replcing the current fleet, with these new
cars, we will be making substantial progress towards our goals
of better fuel efficiency, less pollution and economic recovery.
Nothing could be more intolerable than delay and continuing
conflict between Federal energy and environmental policies and
laws. Such delays will only contribute to further economic
disruption and continuing unacceptable levels of unemployment.
FORD LIBRARY
5
Furthermore, lack of a comprehensive and balanced policy
would allow one objective to go forward only at the expense
of other critical national goals.
It may very well be that additional government standards,
such as regulating the sulfuric acid emissions, will be
required in future years. This is something which I have
specifically directed the EPA and other government agencies to
work on closely with the appropriate committees of Congress.
However, it is clear that we cannot duck our responsibility
to make decisions now that establish realistic ground rules.
sulfate
We cannot afford to ignore the sulfur problem, but our response
must be more than simply another government decree, setting
another standard, that could create -
another problem.
We have a positive obligation to ensure that the steps we
take today do not aggravate this potentially serious health
hazard.
Our review demonstrates the difficulty of this decision and
the interrelationships involved. I would like to briefly dis-
cuss some of the important background that went into this
difficult decision.
At the outset, I think it is important to note that most
of our current difficulties were not foreseeable when the
Clean Air Act Amendments of 1970 set rigid standards and dead-
lines for the reduction of hydrocarbons, carbon monoxide and
oxides of nitrogen. It has proved impossible to meet the
original requirements, and the changes provided for the in
6
the Act have already been made. But the 1978 Statutory
Standards still remain in the law, and will go into effect
unless Congress acts.
The Executive Branch review considered the implications
of a broad range of alternative automobile emission require-
ments which could be applied over the next five years. The
following chart illustrates the alternatives considered:
Emissions in grams per mile
HC
CO
NOX
Retain the statutory standards
for 1978 models
0.41
3.4
0.4
Energy Independence Act proposal
covering 1977-81 models
0.9
9.0
3.1
EPA's March 5 conclusions
- for 1977-79 models
1.5
15.0
2.0
- for 1980-81 models
.9
9.0
2.0
Continue standards applicable to
1975-76 models through 1977-81
1.5
15.0
3.1
Adopt Canadian 1975-76 standards
for 1977-81 models
2.0
25.0
3.1
Reimpose standards applicable
to 1973-74 models through
1977-81
3.0
28.0
3.1
I have chosen the middle road of continuing the 1975-76
standards for the following reasons:
The principle reason for my recommendation regarding hydro-
carbons and carbon monoxide is that there are unknown but
potentially serious health effects associated with sulfuric
FORD LIBRARY is GERALD
7
acid emitted from catalytic catalyst equipped vehicles, and
this problem may be exasperated by the use of the more sophis-
ticated catalysts necessary to reach the levels of stricter
standards. In the absence of better data and agreement among
the experts, any such potentially serious health effects must
take precedent over the known but very small health effects
that might result from the [slight] changes between my current
the STATATORY standards
recommendations and[my proposal of January 30%
Second, I have concluded that the nitrogen oxide standard
should be retained at the current level because of the probable
SigNiFiCaNT
major fuel economy loss which would result from a tighter
standard. In addition, a stricter NOX standard may require
the use of air injected catalyst systems, which also would
linely TO
increase sulfuric acid emissions. These potential results
are not balanced by the benefits of the very small change in
the air quality and the imperceptible impact on health that
could result from a tighter NOX standard.
(of improved ambient air quintity
Third, the marginal benefits in a few metropolitan areas
which result from tighter nationwide standards are very small.
Based on the information now available, those benefits do
not appear to justify the additional consumer and energy costs,
from catalyst generated emissions,
not to mention the potential health danger, Furthermore, the
standards I have proposed would preserve our options to adopt
technological approaches to pollution control that are cheaper
in terms of cost and fuel requirements. These alternatives
would not be available if we have to adopt technology to reach
J,
statutory
stricter standards now.
8
There are as many myths about auto pollution as there are
generally accepted facts. The following are some of the
significant factors which I considered as I reached my deci-
sion in this matter.
1. Existing controls on automobile emissions have produced
significant benefits and will continue to do so in
those areas that have auto-related pollution problems.
Lower pollutant levels in these areas can reduce
adverse health effects and reduce smog and other
esthetically unpleasant atmospheric conditions.
Automobile related pollutants are a problem in a
number of metropolitan areas, but the majority of the
country does not have this problem. Nevertheless,
the strict auto emission standards currently in the
law apply to all parts of the country. Thus consumers
everywhere must pay the cost of cleaning up a few
heavily polluted cities. These added costs for pollution
control show up not only in the initial price tag of
the car, but in maintenance costs and lower gasoline
mileage as well.
Considerable progress has already been made on auto-
mobile emissions since the 1970 Clean Air Act Amendements
were enacted into law. In the case of hydrocarbons
and carbon monoxide, the current standards reflect
FORD & LIBRARY. 07V870
9
an 83% reduction below pre-control levels. In
the case of oxides of nitrogen, it is generally
believed that stationary sources contribute more
to this problem than automobiles, and there has
been a 12% reduction already, compared to uncon-
trolled levels.
10
Importantly, it makes very little difference in terms
of air quality based on hydrocarbons, carbon monoxide
and oxides of nitrogen which alternative, among the
ranges I considered, is ultimately selected over the
next five years. This is because of the progress that
has already been made in controlling these pollutants
from automobiles, and because the automobile is not
the principle source of the pollutants involved. The
contributions of HC, CO and NOX from automobiles will
continue to decline as more and more cars meeting
existing standards replace older models. In the case
of carbon monoxide, concentrations in metropolitan areas
around the country have been declining steadily. Hydro-
carbon emissions, which are a major ingredient of the
photochemical oxidents which produce what is commonly
called smog, have also been declining, but less rapidly
than carbon monoxide. This is because automobile exhaust
emissions account for only about 25% of the hydrocarbons
in the atmosphere. Most hydrocarbons come from natural
sources, such as
In the case of oxides of nitrogen, three metropolitan
areas in the country experience concentrations which
exceed National air quality standards. This number
may increase to nine or ten in the next decade, but that
growth will be due primarily to stationary sources --
not the automobile.
FORD LIBRARY is GERALD
11
Significatnly, if our energy conservation steps
result in less driving by Americans, the benefits
in terms of auto pollution could far exceed anything
obtainable by a tightening of standards.
2.
Controlling automobile pollutants is a technologically
complex problem. The fact is that steps taken to
reduce certain pollutants result in creating or
increasing other pollutants. For example, controls
to reduce hydrocarbons tend to increase emissions of
oxide nitrogen,
and the reverse is also true, The
sulfuric acid mist is another example of unforeseen
consequences, and if the tougher 1978 standards are
imposed along with the sulfuric acid standard, we may
end up with an anti-pollution device which, under
abnormal conditions, could emit such toxic pollutants
as hydrogen sulfide, carbon disulfate and hydrogen
cyanide.
Concerning the sulfuric acid mist problem, it is clear
that these is a divergence of opinion among the scientific
community. There is, however, general agreement that
there could be an adverse and potentially serious health
impact because of the sulfuric acid mist that is emitted
from catalyst equipped cars. The seriousness of this
problem will depend on the amount of emissions per car,
the extent to which they disperse or concentrate in areas
which could impact on the public, and whether or not there
is a threshold below which sulfuric acid is not injurious
12
While there is uncertainty in this area, the
Administrator of EPA and the Secretary of HEW have
made it clear to me that they believe there is a
potential for a significant health risk that cannot
based ilpon,
be dismissed wash information now available. This
assessment led the Administrator of EPA to conclude
on March 5, that hydrocarbons and carbon monoxide
standards should not be tightened at this time because
modifical
tighter standards would likely force the use of new
catalysts which will increase the amount of sulfuric
acid emitted.
One of the reasons for concern in this area is the
lack of knowledge of just what kind of technological
devices will be realistically available for automobile
manufacturers to use in meeting stricter standards.
Our current testing shows that more sulfuric acid mist
is emitted from catalytic equipped cars sold in California,
which are designed to meet the tougher pollution standards
which exist in that State compared to the rest of the
country. Thus we know that there is a strong possibility
that as the pollution standards are made tougher, our
sulfuric acid problem may substantially increase.
3. Our auto emission laws have had a significant negative
impact on fuel economy. Emission controls applied
to automobiles between the years 1968 and 1974 caused
FORD LIBRARY &
a very significant reduction in miles per gallon of
13
gasoline. The use of the catalytic mufflers on
1975 cars permitted engine adjustments which helped
regain some of this loss in gasoline mileage. The
higher levels of pollution created by the retuned
engine (which gets better mileage) are captured and
changed chemically by the catalytic mufflers.
However, there continue to be some offsets in this
area. Cars which must meet the tighter emission
standards applied in California generally get lower
mileage than similar models produced for other States.
An additional impact on petroleum demands comes from
the need to use unleaded gasoline for catalyst equipped
cars. The production of unleaded gasoline requires
changes in the refinery process which slightly increases
the quantity of crude oil required to produce each
gallon of gasoline, at the required octane level.
4.
[Insert impact on cost to consumer paragraph.]
5. Maintaining the current automobile emission standards
will open up a range of technological alternatives
available to meet pollution and fuel efficiency require-
ments. For example, the so-called stratified charge and
diesel engines, "leas-burn" technologies and other
internal combustion engine modifications will be
possible. Under the stricter 1978 statutory standards,
14
many alternatives to the catalytic muffler will be
climinated.
Other technical information was brought to my attention as
I reached my automobile emissions decision. In addition to
a Statement of Facts, which I am making public today, I have
asked my key advisers in this area to consult with the appro-
priate members of Congress, particularly the abcommittees now
considering legislation in this field. They will be available
to discuss these complex and interrelated issues and to provide
all the detailed information available to the Executive Branch.
I urge the Congress to carefully consider all the issue involved
in the potential conflict that one national objective, attaining
clean air, might have on our efforts to reach other goals.
FORD is LIBRARY
Mr. Davar
6/13/75
EMBARGOED FOR RELEASE
UNTIL 1:00 P.M. EDT
June
, 1975
Office of the White House Press Secretary
THE WHITE HOUSE
FACT SHEET
The President today recommended legislation to the Congress which
would amend the Clean Air Act by extending the current automobile
emission standards from 1977 until 1981.
While this action will have no significant impact on our attempt
to achieve the objectives of the Clean Air Act, the proposed
modifications are necessary to (1) avoid certain recently
recognized potential health risks associated with the catalytic
converter and (2) permit substantially greater fuel efficiencies
over the next five years.
Background
FORD LIBRARY
This proposal supercedes Section 503, Title V, of the President
Energy Independence Act of 1975 which he sent to Congress on
January 30, 1975. At that time, the President proposed emission
standards based on a modification of the current California
standards.
After submitting the Energy Independence Act to the Congress, the
Environmental Protection Agency held public hearings related to
five-year emission levels. The hearings established that the
catalytic converter, used to meet the HC and CO standards for
1975 and 1976 model year vehicles, produces sulfuric acid in
amounts that can pose a significant public health risk.
In addition, because of the technology likely to be used to
achieve these tighter standards, automobile emissions of sulfuric
acid may double if the more stringent HC and CO standards
proposed in the Energy Independence Act are imposed for 1977
and subsequent years.
Accordingly, the President directed an interagency task force
to undertake a major review of the public health, energy and
consumer cost implications of several widely discussed levels
of automobile emission standards.
The President's decision is based upon this review. Some of
the more significant considerations which led to the President's
recommendation are contained in his statement released today.
Additional information on those considerations is outlined below.
The Interagency Review
The review by Executive Branch agencies considered the implications
of a range of alternative automobile emission requirements which
might be applied to 1977 through 1981 model automobiles.
Specifically, the following standards, applicable to hydrocarbons
(HC), carbon monoxide (CO) and oxides of nitrogen (NOX) emissions,
have been considered:
Emissions in grams per mile
HC
CO
NOX
Retain statutory standards which
will apply to 1978 models
0.41
3.4
0.4
Energy Independence Act proposal
covering 1977-81 models
0.9
9.0
3.1
Mr. Train's March 5 conclusions
- for 1977-79 models
1.5
15.0
2.0
- for 1980-81 models
.9
9.0
2.0
Continue standards applicable to
1975-76 models for 1977-81
1.5
15.0
3.1
Adopt Canadian 1975-76 standards
for 1977-81 models
2.0
25.0
3.1
Reimpose- standards applicable to
1973-74 models for 1977-81
3.0
28.0
3.1
Based upon this review, the following conclusions were reached:
1.
Controls on automobiles necessary to meet the current standards
have reduced ambient concentration levels in those areas that
have auto-related HC and CO problems; and have reduced the
rate at which NOX concentrations have increased.
2.
Through the year 1985, tighter or looser standards, in the
range being considered, for HC, CO and NOX will make little
difference in the air quality in those areas that have an
auto-related pollution problem, although many parts of the
country have no auto-related pollution problem.
3. Present data are not sufficient to make specific calculations
or final judgments on what sulfuric acid emission levels
would be safe from a public health perspective. However,
it is known that sulfuric acid emissions could prove to be
a significant public health risk and that emissions could
double if standards more stringent than the 1975 interim
standards are adopted.
4. Further mandated reductions in emissions from internal com-
bustion engines may have the effect of increasing or
creating pollutants other than CO, HC and NOX.
5. Auto emission standards have had an impact on fuel economy
and, therefore, on our nation's total petroleum demands
and reliance on foreign sources. Standards tighter than the
1975 interim will result in higher initial car costs and
higher operating costs.
6. The basic philosophy and approach to future auto' emission
controls need to be reconsidered in light of current
conditions.
(a) Significantly tighter standards at this time may
preclude continued development of some technologies.
(b) Actions to reduce auto emissions must take into
account other sources of the same pollutant.
7. Prompt Congressional action is needed on auto emission
standards in order to establish a five year emission
program which is compatible with a strict fuel efficiency
program.
DISCUSSION
1.
Controls on automobiles necessary to meet the current standards
have reduced ambient concentration levels in those areas that
have auto-related HC and CO problems; and have reduced the
rate at which NOX concentrations have increased.
2.
Many parts of the country have no auto-related pollution problem.
Through the year 1985, tighter or looser standards for HC, CO
and NOX in the range being considered, will make little difference
in the air quality in those areas that have an auto-related
pollution problem.
The Clean Air Act has imposed increasingly more stringent automobile
emission limitations. 1973-74 vehicles produce about 65 percent
less HC and CO than uncontrol (pre-1968) vehicles. 1975 vehicles,
meeting the current standards, produce 83 percent less HC and CO and
11 percent less NOX than uncontrolled vehicles. The existing law,
however, requires that these automobiles emissions be reduced even
further beginning with model year 1977 for NOX and model year 1978
for HC and CO.
The attached tables show the direction and magnitude of change
in ambient concentration levels for HC, CO, and NOX which would
result from adopting standards which are less (or more) stringent
than those proposed in the Energy Independence Act. The ambient
standards are used as criteria because they are the health-
related pollutant limits in each air quality region, toward
which reductions in both automobile and stationary emissions
contribute. Thus the levels shown are the result of mobile and
stationary source emissions. Three points should be noted:
- First, though the tables assume that the statutory standards
will be in force after the 1981 model year, if any. of the
options were kept through model year 1990, the concentration
levels for each region would change very little and the
conclusions reached remain basically the same.
- Second, because the concentration levels are projected through
modeling techniques marginal changes in the concentration levels,
whether increases or decreases, are often within the range of
statistical error.
- Third, the estimates of total auto pollution emitted are based
on historical growth rates for vehicle miles traveled and auto
fuel economy. No compensation has been assumed for the higher
cost of gasoline and the higher price of standard automobiles -
both of which have already affected total pollutants through
reductions in vehicle miles traveled and through changes in the
mix of new cars on the road in favor of smaller cars which emit
less pollutants per mile. The auto-caused ambient pollution
levels are therefore likely to be overstated in 1981 - 1985.
hydrocarbons
Out of the thirty regions considered to have an HC problem,
twenty are projected to exceed the ambient standard in 1985,
regardless of the automobile emission level chosen. More
importantly, all of the regions projected to have concentration
levels below the ambient standard in 1985 at the statutory
vehicle limitation level are also projected to be below the
ambient standard if any of the other less stringent automobile
emission standards shown is chosen instead.
Only 25 percent of total hydrocarbon emissions are generated by
automobile exhaust. Therefore, hydrocarbon ambient air concen-
trations tend to be much less sensitive than carbon monoxide to
the level of vehicle emission control.
Attachment 1 shows the limited differential impact that
vehicle hydrocarbon limitations more stringent than the 1975
(Interim) standard would have on ambient air quality by 1985 in
those areas considered to have a hydrocarbon problem. The
measure of air quality is photochemical oxidants to which hydro-
carbons are converted and in which form HC most adversely affects
air quality.
Carbon Monoxide
Carbon monoxide levels in the atmosphere are much more sensitive
to changes in automobile emission controls than either HC or NOX.
Unlike those pollutants, the growth of stationary sources over
the next ten years will have little effect on CO air quality.
Attachment 2 shows 1985 projected concentration levels for twenty-
six problem regions for each of the alternatives presented. The
most important conclusion is that air quality is improving rapidly
and will continue to improve until 1985 under all of the emission
control options presented. This is because older uncontrolled
cars are being replaced by newer controlled cars. The asterisked
regions are those which would still exceed the ambient standard if
an automobile CO standard were adopted that was less stringent than
either the statutory standard or the one proposed in the Energy
Independence Act.
First, there is only a limited difference in ambient concen-
tration levels for all of the standards presented, but the
difference is particularly small when comparing the statutory
standard (3.4 grams/mile) with either the Energy Independence
Act proposal (9.0 grams/mile), EPA's recommended standard (15
grams/mile until 1979 and 9.0 grams/mile from 1979 to 1981),
or the current standard (15 grams/mile) extended until 1981.
By 1985, the average ambient levels for this pollutant will
have been reduced about 70 percent below 1970 levels regard-
less of which option is chosen.
Second, the choice of option will not significantly affect any
single area's ability to achieve or maintain the ambient standard
by 1985. When comparing all the alternatives (except the 1974
or Canadian Standards), those areas below the ambient standard
in 1985 will be below it regardless of the automobile emission
standard chosen, with the sole exception of Denver. The adoption
of the Canadian Standard would mean that only two additional areas
(Portland, Oregon and Puget Sound) would still be above the
ambient standard in 1985 by a marginal amount.
Nitrogen Oxides
Federal Government and independent scientists predict that a
steady increase in ambient nitrogen dioxide concentrations will
occur in metropolitan areas over the next ten years regardless
of the auto emission limit chosen. This is because stationary
sources emit most NOX pollution and the technology for control-
ling stationary sources is very limited. Attachment 3 (B) shows
the average percentage increases in NO2 ambient concentration
levels that will occur for each of the auto emission alternatives
studied (3.1, 2.0 and 0.4 grams/mile) under varying assumptions
about the auto standard after 1981.
When comparing the 2.0 and 3.1 auto emission alternatives, Chart
3 (B) shows that as long as the 2.0 NOX standard were implemented
after 1981, no significant difference in the predicted increases
of NO2 concentration levels would occur in either 1980 or 1985,
as a result of maintaining the 3.1 grams/mile standard through
the 1981 model year (columns 2 and 3).
Though the statutory standard would have a significant effect on
the overall predicted increase, the differential effect of a more
stringent automobile standard than currently in force on the ambient
concentration levels in those areas with nitrogen dioxide problems
is much less pronounced. This is shown in Attachment 3(A), which
displays ambient projected concentration levels in the ten problem
areas for 1985 under various automobile emission standards.
With the exception of San Francisco, by 1985 all ten regions are
predicted to have concentration levels above the ambient standard
if either the 3.1 or 2.0 grams per mile limitation is placed on
automobiles through the year 1990 (columns 1 and 3). San Francisco
would remain below the standard if the more stringent emission
limitation is adopted and, in fact, California has the more stringent
limitation in force as a State regulation.
It should also be noted that regardless of whether the 3.1 or
the 2.0 limitation is imposed through 1981, and even if the
statutory standard (.4) is imposed after 1981, only one addi-
tional region (Phoenix) would be brought into compliance with
the ambient standard (columns 4 and 5). In fact, implementing
the statutory standard in 1978 would result in only two addi-
tional areas (Phoenix and Baltimore) meeting the standard
(column 6).
It is thus clear that the projected increases in nitrogen dioxide
cannot be stopped without major technological innovations in
stationary source control. Therefore, regardless of how stringent
the automobile standard, the future concentration levels in major
metropolitan areas will primarily be a function of stationary
source emissions.
6
health
3. With present data expects generally agree that standards
which are tighter or looser than those currently in force
would have minimal differentlal/impacts-especially for
HC and CO. However, present data are not sufficient to
make specific calculations on final judgements on what
sulfuric acid emission levels would be safe from a public
perspective. It is only known that sulfuric acid emissions
could prove to be a significant public health risk and
that emissions could double if standards more stringent
than the 1975 interim standards are adopted.
4. Further mandated reductions in emissions from internal
combustion engines may have the effect of increasing
existing pollutants or creating other pollutants.
Based upon existing air quality data, there are no measurable
health risks associated with the application of HC and CO
emission standards (within the range of options presented)
which are less stringent than those in the Energy Independence
Act or the statutory standards.
The application of the 3.1 NOX level will not greatly increase
health risks nationwide. With an ambient air quality standard
of 100 ug/m3 health data suggests that the level at which people
would have an increased risk for excess respiratory disease is
200 ug/m3. Los Angeles is the only area which is expected to
approach the 200 ug/m3 level by 1985, and California has the
lower 2.0 grams/mile level in effect as a State regulation.
Though ambient carbon monoxide and hydrocarbon concentration
levels are not significantly affected by the range of automobile
emmission standards presented, the concentrations of sulfuric
acid are affected.
Gasoline contains sulfur which, after combustion, is released
as sulfur dioxide. In the process of removing other pollutants
the catalytic converter changes some of the sulfur dioxide into
sulfuric acid mist.
Current estimates indicate that with existing automobile emmission
technology, emission standards for hydrocarbons and carbon
monoxide of .9 and 9.0, will require the use of an air-injected
oxidation catalyst. This catalyst results in a doubling of
sulfuric acid emissions. Though there are several catalytic
and non-catalytic technologies which can potentially meet the
stricter HC, CO and NOX emission limitation without significant
sulfuric acid emissions, there is little production potential
for using these systems in the near term. (See discussion
below
While all scientists agree that sulfuric acid is a toxic and
potentially dangerous pollutant, there is still disagreement on
the quantities of emissions needed to pose a health risk and on
how long it would take for the buildup in concentration levels
to occur.
Major studies by government and industry have already begun in
order to resolve some of these uncertainties. Much of the un-
known about sulfuric acid results from our current inability to
precisely measure how much sulfuric acid is being emitted by
vehicles and our inability to precisely measure how much emitted
sulfuric acid is being concentrated in the breathing zone.
FORD
GERALD
LIBRARY
7
To improve vehicle measurements, EPA is developing a new test
driving cycle which will more accurately reflect emission of
sulfuric acid and is jointly working with private industries on
the relationship of catalysts and other control options to sulfuric
acid. To improve our knowledge of the disposition of sulfuric
acid once emitted into the air, EPA has instituted a long run
trend study on one major highway and has jointed with State
government agencies to measure roadside concentrations on other
highways as well. EPA is also working with the State agencies
to determine the change in sulfuric acid emissions catalyst
equipped vehicles age and accumulate mileage.
Until these and other studies are completed no final judgements
on the potential health impacts of sulfuric acid emissions can
be made. However, recent information presented in EPA's
"Estimated Public Health Impact as a Result of Equipping Light
Duty Motor Vehicles With Oxidation Catalysts" (January 30,
1975) suggested the following estimates of the years in which
sulfuric acid emission levels from automobiles could pose a
serious threat to public health.
Model Year 1/ in which
Sulfuric Acid could pose
a serious health problem
Average
Adverse
Meteorological
Meteorological
Standard
Conditions
Conditions 2/
1975 Interim Standards
1981
1979
1975 California Standards
In- 49 States
1979
1977
In California
1978
1977
The data assumes that there are no emissions of sulfates
from stationary sources, and that 70 percent and 90 percent
of the fleet in 1975 and 1976 respectively will utilize
catalysts.
Adverse meteorological conditions would occur in large
metropolitan areas on an average, of 6-7 days a year.
The dates for reaching a critical problem are earlier in
California than the remaining 49 States because California
utilizes higher sulfur gasoline.
In interpreting the preceding table the following factors should
be noted. Data available to date do not take into account
"background" emissions of sulfates from stationary sources, e.g.,
coal-fired generating plants. Therefore, the table represents
only the potential health effects of emissions from mobile
sources. The extent to which sulfate emissions from stationary
sources add to the potential health risk associated with sulfuric
acid emissions from automobiles is not known at this time. How-
ever, most health analyses treat stationary and mobile emissions of
sulfates independently. This is primarily because (1) the particle
size of sulfates from stationary sources is much larger than
sulfuric acid mist and is not absorbed as deeply into the
8
respiratory system; (2) the toxicity of sulfate emissions
from stationary sources is generally much less than sulfuric
acid; and (3) emissions from stationary sources do not occur
in the breathing zone as do automobile emissions.
Short Term Actions-Available for Localized Sulfuric Acid Problems
Under certain adverse meteorological conditions localized
sulfuric acid problems could occur. There are two short-term
actions available to offset this possibility. While possibily 1
feasible, both have drawbacks,
- Gasoline blending - catalyst equipped vehicles could be
provided with lead-free low-sulfur fuel. This would reduce
emissions of sulfuric acid, but would impose an allocation
problem on the industry. Refiners have also indicated that
sufficient quantities would not be available to meet wide-
spread problems beyond 1977 or 1978.
- Desulfurization of oil - technically possible at this time.
Desulfurization would require substantial additional capital
investment, at a time when refiners are attempting to expand
domestic capacity. It would also require an increase in crude
oil consumption due to additional refining. Increases in
the price of gasoline would occur. Nationwide, the capital
cost of desulfurization would range between $2 and $4 billion,
crude oil consumption would increase .5 percent and the price
of gasoline would increase by 1 to 2 cents per gallon.
It is generally agreed that reducing NOX emissions will result
in an increase in the emissions of HC from engines. To reduce
that increment manufacturers may increase the use of the air-
injected oxidation catalyst -- even to meet the Federal Interim
HC and CO standards. If this were the case, then nearly twice
as much sulfuric acid would be generated as projected. At this
time it is not known definitely whether manufacturers could
achieve reductions 'of the HC increment through the use of engine
modifications or modified catalyst equipment instead of the
air-injected catalysts in 1977-78. However, if the HC and CO
standards are also lowered after model year 1978 there is a
high probability that the air-injection catalyst would be re-
tained throughout the entire period:
There are other anecdotal problems with the converters such as
potential fire hazards, hydrogen sulfide emissions and the
creation of other potentially hazardous compounds, but none of
these has been proven a significant risk.
Mandated reductions in the automobile emission standard will
also narrow the choice of technological options to abate the
three regulated pollutants. For example, if a sulfuric acid
standard were set for model year 1979, implementation of the
statutory standards for HC, CO and NOX in 1978 would, in
essence, dictate the use of either 2 "dual" or "three-way" catalyst
technologies on most vehicles, While these catalysts have promise
as abatement technologies they are still in the early stages of
development and their premature implementation could possibily
have adverse health effects far in excess of the benefits of
reducing HC, CO and NOX.
Based on existing data, the dual catalyst system appears to be the
most promising technology for meeting the statutory emission
standards. However, its ability to limit sulfuric acid emissions
to low concentrations, and thus meet a sulfuric acid, standard, is
still in question since an integral component of the dual catalyst
system is an oxidation catalyst like those currently in use for
1975 model vehicles. Sulfuric acid emissions would increase if,
to meet the statutory HC and CO standards, an air-injected
oxidation catalyst were used.
If the statutory standards are in effect in 1978, along with a
sulfuric acid standard in 1979, then it appears that the most
likely technology to be used is the three-way catalyst -- a single
retrofit device that simultaneously abates HC, CO and NOX.
However, to achieve these simultaneous reductions, extensive
redesign and control of the carburetion system must be undertaken
because the three-way catalyst must be operated at stoichiometric
(no excess air) conditions. In fact, the permitted margin of error
is so narrow (on the order of + 0.25 percent of the exact air to
fuel ratio needed, as compared to normal production variations of
+ 7 to 10 percent) that the use of an oxygen sensor and a feedback
system are required to regulate the air mixture for either a
carburetor or fuel-injection process.
When operating at the stoichiometric conditions, sulfate emissions
would be no greater than emissions from non-catalyst cars.
However, if variations from that condition occur, severe adverse
health effects may be generated. Three-way catalysts applied to
exhausts from engines operated outside the carburetion design
limits (variations greater than + 0.25 percent from stoichiometric)
have a potential for emitting dangerous quantities of such toxic
pollutants as hydrogen sulfide, carbonly disulfide, carbon
disulfide and hydrogen cyanide.
It should be emphasized that only the most preliminary data exists
on the total emissions from three-way catalysts and no firm judgment
can be made on whether or not such emissions will occur in normal
use, or in what quantities they will occur. However, they must be
treated as potential risks until there is firm evidence that
demonstrates otherwise. The development of this technology has not
progressed to the stage where firm conclusions on their long run
health impacts are possible.
The long run durability of this technology is also unproven at this
time and several more years of testing and development seem needed
before full scale introduction of three-way catalysts should be
undertaken regardless of the emission standard mandated.
It seems clear, that given the limited health benefits derived
from instituting the statutory standards (see #2 above) and
given the unknown but potentially adverse health effects of
introducing a technology which has not been thoroughly tested,
the wiser choice is to avoid forcing either of these catalyst
technologies into mass production at this time.
5. Auto emission standards have had an impact on fuel economy
and, therefore, on our Nation's total petroleum demands
and reliance on foreign sources.
The options presented will have differential fuel economy
impacts. A recent Columbia University study indicates that
the fuel economy penalty caused by reducing NOX will be even
larger than the one used in the table below.
Impact on 40 percent fuel economy goal
Shortfall (-)
or excess (+)
% over
over President's
1974
goal
Alternatives
Energy Independence Act
40%
---
EPA Recommendation
36%
- 4%
1975 Standards thru 1981
46%
+ 6%
Canadian and 1974 Standards thru 1981
40%
+10%
Statutory Standards after 1977
30%
-10%
Alternatives*
Barrels per day (in 1980)
Statutory Standards after 1977
208,000 (loss)
Energy Independence Act
85,000 (loss)
EPA Recommendation
137,000 (loss)
1975 Standards thru 1981
0
Canadian and 1974 Standards thru 1981
27,000 (gain)
*
Base is 1975 model year automobiles meeting 1975 interim
emission standards.
Energy implications for lowering NOX to 2.0 grams/mile
It is generally agreed that a reduction in the NOX emission
levels from 3.1 to 2.0 grams/mile will require a variety of
engine modifications. It is estimaed that these modifications
will cause a fuel economy penalty of 3-4 percent on the average
in 1980. If a 3 percent fuel penalty is assumed, an additional
requirement of 85,000 barrels of oil per day will occur nation-
wide in 1980.
This estimated fuel penalty figure is the subject of debate,
however, on two grounds. First, it has been argued that fuel
penalties in 1980 assume that certain advanced engine tech-
nologies will be introduced over the next five years. However,
these advanced technologies would not be available in the first
two years. Therefore, at the year of introduction, initial fuel
penalty resulting from lower NOX emission standards would be
substantially greater. A range of between 5 and 7 percent,
i.e., from 120,000 to 150,000 barrels per day is estimated,
the 2.0 grams/mile standard were adopted.
if FORD LIBRARY
The second argument revolves around the very sensitive relation-
ship that exists between fuel economy and NOX emissions at more
stringent NOX standards than currently required. For a given
level of HC emissions a dramatic drop in fuel economy is required
to meet a NOX standard below 2.0 grams/mile. Because of mass
productive variations, to ensure that emission standards are
met, manufacturers must design their emission systems well
below the Federal standards -- about 23 percent lower. Thus,
to meet a 3.1 gram/mile limitation, vehicles are designed to
achieve 2.4 grams/mile and to achieve a 2.0 level, vehicles are
designed to emit not more than 1.3 to 1.5 grams/mile. (To meet
the statutory .4 grams/mile vehicles would have to be designed
to meet about .3 grams/mile.) Thus, designing vehicles to meet
even the 2.0 standard places the fuel economy loss well within
the sensitive range at which fuel economy begins to drop most
rapidly. Attachment 4 (A) illustrates the general relationship
between fuel economy and NOX emissions for all spark ignition
engines while 4 (B) shows the situation for a specific class
of V-8. engines.
Energy implications of HC and CO standards tighter than
those currently in force.
Assuming a 3.1 gram/mile NOX standard, a fuel economy penalty
of 3 to 5 percent is associated with emission standards for
hydrocarbons and carbon monoxide of .9 and 9.0 grams/mile when
compared to extending the current standards of 1.5 and 15
(i.e., 85 barrels of oil per day in 1980). Retention of the
1.5 (CO) and 15 (HC) levels until 1979 would avoid most of the
penalty. Retention of the current standards through 1981 would
allow continued fuel economy improvements as would the adoption
of the Canadian standards.
Energy implications of the statutory standards for
HC, CO, and NOX
With either the dual or 3-way catalyst, a single retrofit system
is used to abate all three regulated pollutants. Thus, at the
statutory standards the energy impacts are not measured separately
for NOX and HC/CO. On the average, the adoption of the statutory
standard in 1978 would result in a fuel penalty of about 7% by
1980 over 1975 vehicles. This would mean an energy loss of 208,000
barrels of oil per day in 1980.
Attachment 5 shows the specific fuel economy losses (or gains)
associated with each of the options presented (and the antici-
pated costs) with respect to model year 1974.
Standards tighter than the 1975 interim will result in
higher initial car costs and higher operating cost due
to associated fuel penalties.
The options presented will impose varying cost burdens on the
consumer. Also, separate costs are associated with actions
on NOX and actions on HC and CO, except for meeting the statu-
tory standards with a dual or 3-way catalyst system.
NOX:
Consumers will face sticker price and operating cost increases
over the 1975 model vehicles if a 2.0 gram/mile limitation is
imposed. Estimates range from $10-25 for front-end costs per
vehicle and from $0-25 in operating costs over 50,000 miles. In
addition, the consumers will pay the costs of increased fuel
consumption associated with this lower standard, which rough
estimates place at $1.7 million per day, or over 600 million
dollars per year.
HC and CO:
The costs of adopting the more stringent hydrocarbon and carbon
monoxide standards (.9 and 9.0) as proposed in the Energy
Independence Act is estimated to be $50 per vehicle over 1975
automobiles. This would represent the additional costs of using
the air-injected oxidation catalyst. Additional operating
costs which would result from the increased consumption of gaso-
line that maintaining this option implies are estimated at $1.7
million per day, or over 600 million dollars per year.
Adoption of the statutory standards would result in a sticker
price increase of $230 to $270 per vehicle over 1975 model cars.
This would represent the average costs of using a mix of the
dual DE 3-way catalyst systems, Operating costs resulting from
the associated fuel penalties of this alternative would roughly
be $4 million per day or over $1.5 billion per year.
6. The basic philosophy and approach to future auto emission
controls needs to be reconsidered in light of current
conditions.
While the choice of emission standards must represent a balance
among public health, air quality, esthetic, energy and cost
considerations, the problems currently confronting the Nation
are different from those prevailing in 1970 when the Clean Air
Act was passed. Inflation, unemployment, and the added cost and
reduced availability of energy call for reassessment of the
relative weights accorded to various factors other than measures
necessary to health. The high cost and fuel penalties caused by
further tightening of the standards; and the emergence of the
sulfuric acid problem, compared to the marginal improvement in
ne, CO and NOX air quality also call for careful reconsideration.
(a) Significantly tighter standards at this time may
preclude continued development of some technologies.
There is substantial evidence that by model year 19 1 new
"lean-burn" or "stratified charge" engines would permit meeting
the lower (2.0) NOX standard. However, standards more stringent
than 2.0 would preclude introduction of those technologies. In
fact, unless application of the current statutory NOX standard
(.4 grams/mile) is delayed through at least 1990, the industry
will not (and cannot) shift to a lean-burn or stratified charge
engine, as far as can be foreseen.
(b) Actions to reduce auto emissions must take into
account other sources of the same pollutant.
Only 25 percent of total HC emissions are generated by auto-
mobiles. Therefore, HC ambient air concentrations tend to be
much less sensitive to the level of vehicle emission control
than is carbon monoxide.
The projected increases in NOX cannot be stopped without major
technological innovations in stationary source control. There-
fore, regardless of how stringent an automobile standard is
applied, the future concentration levels in major metropolitan
areas will primarily be a function of stationary source emissions.
CO levels in the atmosphere are much more sensitive to changes
in automobile emission controls than either HC or NOX. Unlike
those pollutants, the growth of stationary sources over the
next ten years all have little effect onnCO air quality.
7. Prompt congressional action is needed on auto emission
standards.
In order to meet deadlines for emission testing and certification
of 1977 model cars, the automobile industry will need to know
1977 emission standards by. early August so that there will be
time to complete designing and engineering, build prototypes,
complete emissions testing such as 50,000 endurance tests, and
finally to produce new cars in adequate' quantity to meet the
demand from the American public.
Attachment 1
Predicted Ambient Oxidant Concentration Levels in 1985
(In parts per million)
Ambient Standard = .08 ppm*
HC Automobile Emission Standard
1974 and
Current
EPA's
Energy
Canadian
Stds
Recom-
Independ-
Statutory
Standards
through
mended
ence Act
Stds
Base
Region
through 1981
1981
Stds
Proposal
1977-1990
1971-73
Birmingham
.12
.12
.11
.11
.11
.22
Mobile-Pensacola
.04
.04
.04
.04
.04
.11
Clark-Monave
.13
.12
.12
.12
.12
.22
Pnoenix-Tucson
.16
.16
.16
.16
.16
.19
Los Angeles
.43
.42
.42
.41
.41
.62
Sacramento Valley
.21
.20
.20
.20
.20
.24
San Diego
.20
.20
.20
.19
.19
.30
San Francisco
.23
.23
.23
.23
.23
.30
San Joaquin
.22
.21
.21
.21
.21
.26
S.E. Desert
.32
.32
.32
.32
.32
.28
Denver
.17
.16
.16
.16
.16
.28
NY-NJ-Conn.
.14
.13
.13
.13
.13
.26
Philadelphia
.10
.10
.10
.10
.10
.20
National Capital
.26
.26
.25
.25
.25
.38
Cincinnati
.12
.11
.11
.11
.11
.17
Indianapolis
.08
.08
.08
.08
.08
.14
S. Lou.-S.E. Texas
.20
.20
.19
.19
.19
.32
Boston
.11
.10
.10
.10
.10
.21
Toledo
.07
.07
.07
.07
.07
.14
E1 Paso-Las Cruces
.06
.06
.05
.05
.05
.13
Genessee-Finger
6
Lakes
.08
.08
.08
.08
.07
.15
Dayton
.13
.12
.12
.12
.12
.18
Portland, Oregon
.08
.08
.08
.08
.08
.14
S.W. Penn.
.12
.12
.11
.11
.11
.21
Austin-Waco
.07
.07
.07
.07
.07
.16
Corpus-Christi
.14
.14
.14
.14
.14
.19
Dallas-Ft. Worth
.05
.05
.05
.05
.04
.13
Houston-Galveston
.27
.27
.27
.27
.26
.32
San Antonio
.0,7
.07
.07
.07
.06
.15
Puget Sound
.08
.08
.08
.08
.08
.16
* The projected concentration levels assume the continuance of historic grwoth rates in the
central business districts in each region.
Attachment 2
Predicted Ambient Carbon Monoxide Concentration Levels in 1985
(In parts per million)
Ambient standard = 9 ppm
CO Automobile Emission Standard
1974 and
Current
EPA's
Energy
Canadian
Stds
Recom-
Independ-
Statutory
I
Standards
through
mended
ence Act
Stds
Base
Region
through 1981
1981
Stds
Proposal
1977-1990
1971-73
3irmingham
6
5
5
5
4
18
North Alaska
11
11
11
11
11
35
Clark-Mohave
6
6
5
5
5
15
Pnoenix-Tucson
16
14
14
13
12
42
Los Angeles
13
12
11
11
10
41
Sacramento Valley
7
6
6
6
5
22
San Diego
5
5
5
5
4
15
san Francisco
6
6
6
6
6
18
San Joaquin
4
3
3
3
3
13
Denver*
11
11
9
9
8
33
Hartford-New
Haven
9
9
7
7
7
27
NY-NJ-Conn.
15
13
13
13
11
51
Philadelphia
9
8
8
8
8
32
National Capital
7
6
6
6
6
20
E. Washington-
X. Idano
7
7
6
6
6
18
Cnicago
7
6
6
5
5
23
Indianapolis
5
4
4
4
4
15
Kansas City
6
5
5
5
4
15
Baltimore
7
7
7
7
6
18
Boston
6
5
5
5
4
18
Minneapolis-
St. Paul
9
8
8
7
7
22
Central New York
5
4
4
4
4
15
Portland, Oregon**
10
8
8
8
7
26
S.W. Penn.
7
6
6
6
5
22
Wasaton Front
15
13
13
13
11
41
Puget Sound**
10
8
8
8
7
24
*Would not meet the ambient standard in 1985 if the Current Interim, 1974 or Canadian CO
standard for venicles were adopted through 1981
**Would neet the ambient standard under all options except the 1974 or Canadian vehicle
00 seardard
Attachment 3
Chart A displays ambient concentration levels in 1985 for NO2 in the ten problem regions
under various NOX auto-emission standards. For example, column 1 shows that if a 3.0
gr/mile auto-NOX standard were in force from 1977 to 1990, Philadelphia's ambient NO2
concentration levels in 1985 are predicted to be 121 ug/m³. Column 5 shows that if an
NOX standard of 2.0 gr/mile were adopted for the 1977-1981 period, followed by the
statutory (.4) standard until 1990, then Philadelphia's ambient NO2 level in 1985 is
predicted to be 113 ug/m³.
Chart B shows the average percentage increases in NO2 concentration levels for all ten
regions for each alternative NOX level. For example, column 2 shows that if the NOX
emission level were 3.1 gr/mile from 1977-1981 and 2.0 gr/mile from 1982-1990, the
NO2 concentration levels are predicted to increase by 16% in 1980 and by 26% in 1985.
Column 3 shows that if the NOX standard were 2.0 from 1977 to 1990, NO2 levels are pre-
dicted to increase by 12% and 22% in 1980 and 1985 respectively.
A. Predicted Ambient Nitrogen Dioxide Concentrations in 1985
(In micrograms per cubic meter)
Ambient standard is 100 micrograms per cubic meter*
(NOX Emission Standard (in grams per mile)
Effective Date of Standard
(1)
(2)
(3)
(4)
(5)
(6)
1977-1981
3.1
3.1
2.0
3.1
2.0
0.4(1978
1982-1990
3.1
2.0
2.0
.4
.4
0.4
Region
Phoenix
111
105
100
98
93
87
Los Angeles
194
183
173
167
157
145
San Francisco
102
96
92
89
83
77
Denver
135
129
125
123
117
112
NY-NJ-Conn.
144
139
136
132
129
124
Pniladelphia
121
119
117
115
113
109
National Capital
116
111
107
105
101
96
Chicago
152
148
145
143
139
134
Baltimore
116
112
109
107
103
99
Wasaten Front
137
131
124
121
115
108
B. Increases in Concentration Levels in 1980 and 1985
Average per-
1980
16
16
12
16
12
6
cent increase
in air quality
1985
32
26
22
19
14
8
concent rations
projected concentration levels assume the continuance of historic growth rates for
the central business districts in each region
Attachment 4A
MAXIMUM FUEL ECONOMY POTENTIAL VERSUS EMISSIONS
FOR 1980 ENGINES UNDER OPTIMAL CONTROL
CURRENT
MPG
*
AVERAGE ENGINE
HC
DECREASING
HYDROCARBONS
KNEE
FUEL
ECONOMY
MPG
#
- DENOTES OPTIMUM
FUEL ECONOMY POINT
FOR ANY ENGINE
NO:
X
OXIDES OF NITROGEN - NO X
NOTE: 1. CURVE SHAPES ARE REPRESENTATIVE OF MOST ALL
SPARK IGNITION ENGINES.
2. STATUTORY NOₓ STANDARD IS BELOW THE "KNEE"
FOR ALL ENGINES CAPABLE OF LARGE SCALE PRO-
DUCTION THROUGH THE MID 1980's'
3. THE OPTIMUM-MPG* AND RESULTING NO AND HC
ARE SIGNIFICANTLY GREATER THAN THE ENGINE
OUT PERFORMANCE OF 1975 CARS.
FORD LIBRARY is GERALD
Attachment 4B
FUEL-ECONOMY-NOX EMISSION TRADE OFF
Miles/Gallon
Design standard
on automobiles
14
for a perfor-
mance standard
of 3.1 gr/mile.
2.0
13
Design standards
on automobiles
for a perfor-
mance standard
of 2.0 gr/mile.
1.4
12
1.25
11
1.1 Hc Gr/Mile
10
9
0
1
1.4
2
2.4
3
4
NOx Gr/Mile
Attachment 5
LIBRARY
FORD
1980 New Car Fuel Economy and Cost
Versus Emission Standards
Cost Per New Car
New Car Average Fuel Economy
For Emission Controls
in 1980
Emission Standards
Compared to 1974 Cars
Uncertainty Range in %
For 1977-1981
Over 1974 Due to
% Over
Engine
Cost
Uncertainty
MPG
1974
Technology
Sales Mix
1. Statutory Standards after 1977
(three-way catalyst or
dual catalyst)
$350
$215-$450
18.0
30%
-4% to + 8%
-4% to +7%
2. Bast - /15/2.0 or
19/9.0/3.1
With Catalysts
120
$ 90-$150
19.6
40%
-3% to + 3%
No Catalysts
50
$ 40-$100
18.4
31%
-4% to + 8%
-4% to +7%
3. EPA Proposal
-
With Catalysts
135
$100-$170
19.0
36%
-5% to + 8%
No Catalysts
65
$ 50-$110
17.8
27%
-4% to +12%
-4% to +7%
4. 1975 Standards
With Catalysts
95
$ 70-$110
20.4
46%
-2% to + 2%
No Catalysts
35
$ 25-$ 65
19.2
37%
-3% to + 7%
-4% to +7%
5. Canadian or 1974 Standards
With or Without
Catalysts
25
$ 5-$ 35
20.8
50%
-2% to + 1%
-4% to +7%
QUESTION AND ANSWERS
An Amendment to Title V of the Proposed
Energy Independence Act of 1975
1. What did the President announce today?
The President announced that he was proposing that
the Congress change existing law with respect to
auto emission standards so as to continue existing
1975 standards through the model year for 1981.
These standards require emission levels not greater
than:
Hydrocarbons
Carbon Monoxide
Nitrogen Oxide
(Grams/Mile)
1.5
15.0
3.1
2. What are hydrocarbons, carbon monoxide, and nitrogen
oxides?
Hydrocarbons (HC) are
High levels of HC emissions can result in
Carbon monoxide (CO) is
High levels of CO emissions can result in
Nitrogen oxides (NOX) are
High levels of NOX emissions can result in
3. How do HC, CO and NOX relate to EPA's "Ambient Air
Quality Standards"?
Under the Clean Air Act of 197 , the Environmental
Protection Agency (EPA) is required to promulgate
these standards prescribing the amount of HC, CO "and NOX in
such air by 19 and 19 While most of the CO in the
air is the result of auto emissions, only 25% of HC and
& of NOX that is emitted comes from automobiles.
Accordingly, although the Clean Air Act of 1970 prescribes
the amounts of HC, CO and NOX that automobiles are
permitted to emit in various years, there is no assurance,
without comparable control on stationary sources, that the
ambient air standards for HC and NOX can be met.
4. Isn't the President changing a recommendation he made
six months ago?
Yes. On January , 1975, the President proposed emission
levels throughout the model year for 1981 not greater than
Hydrocarbons
Carbon Monoxide
Nitrogen Oxide
(Grams/Mile)
.9
9.0
3.1
Without any change, existing law wou-ld require
1977
1.5
15.0
2.0
1978-1981
.41
3.4
.4
In January the President emphasized that a change was
necessary in existing law because
5. Why has the President modified his January proposals
for changes in the requirements?
The President has modified his January proposals because
of increasing concern with the problem of sulfuric acid
emission. Changes in catalytic convertors required to meet the
standards the President proposed in January have now been
found to result in doubling the current emission rate of
sulfuric acid. While the precise effect of such increased
sulfuric acid emissions is not yet known, health
authorities are agreed that such emissions can cause
a very serious danger to
Pending the receipt of detailed information concerning
the sulfuric emission problem, the President decided not
to increase sulfulic acid emission levels.
6. Won't the change the President has proposed prevent
communities from meeting EPA's ambient air quality
standards?
Generally speaking, the changes the President has proposed
will have very little effect on the ability of
communities to meet EPA's ambient air quality air
standards.
(insert detail)
7. Isn't it possible to develop a catalytic convertor
which does not increase sulfuric acid emissions or change the
sulfur content in the gasoline burned?
(State the problem of 3-way catalyst)
State problem with gasoline blending and
desulfurization of oil.
8.
Didn't the National Academy of Sciences issue a report
urging retention of the statutory standards in stating
that the sulfuric acid emissions were not a problem?
The National Academy of Sciences
...
However, the Academy report
...
9. Would the President's proposal have any effect on
consumer costs or energy conservation?
Yes ...
10. How much have the current 1975 auto emission standards
reduced pollutants from 1968, uncontrolled levels?

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    "ocrText": "The original documents are located in Box 6, folder \"Auto Emissions (4)\" of the James M.\nCannon Files at the Gerald R. Ford Presidential Library.\nCopyright Notice\nThe copyright law of the United States (Title 17, United States Code) governs the making of\nphotocopies or other reproductions of copyrighted material. Gerald Ford donated to the United\nStates of America his copyrights in all of his unpublished writings in National Archives collections.\nWorks prepared by U.S. Government employees as part of their official duties are in the public\ndomain. The copyrights to materials written by other individuals or organizations are presumed to\nremain with them. If you think any of the information displayed in the PDF is subject to a valid\ncopyright claim, please contact the Gerald R. Ford Presidential Library.\nDigitized from Box 4 of the James M. Cannon Files at the Gerald R. Ford Presidential Library\nTHE WHITE HOUSE\nPat home\nWASHINGTON\nJune 2, 1975\n4\nMEMORANDUM FOR\nJIM CANNON\nReview wrining\nFROM:\nMIKE DUVAL\nnovb\nSUBJECT:\nAUTO EMISSIONS\nfor\nAttached is a rough draft of a memorandum to the President.\nYou already have the latest draft statement. We are working\non a Fact Sheet with OMB.\nVern Loen and Pat O'Donnell are gathering viewpoints from\nthe Hill. Pat reports that Senator Baker (ranking Minority\non Senate PWC) recommends that the President hold off taking\nany action at this time. He thinks the President should wait\nuntil the Subcommittee marks up a bill.\nI talked to Frank Zarb and he thinks you should call a meeting\nto discuss this in the context of the other key energy matters\nfacing Congress -- the strip mining and import fee vetoes,\ndecontrol, etc.\nI recommend that you call a meeting for tomorrow and invite:\nMorton\nZarb\nTrain\nColeman\nMarsh\nFriedersdorf\nSeidman\nGreenspan\nLynn\nAn alternative is for you to meet just with Zarb, Marsh and\nFriedersdorf.\nFORD it LIBRARY GENALD\nFURL\nMEMORANDUM FOR\nFROM:\nJIM CANNON\nLIBRARY\nSUBJECT:\nAUTO EMISSIONS\nIn response to your decisions based on our memorandum\nof May 19 (see Tab A), we have prepared the following:\n1) A statement of the whole problem with emphasis on\nthe environment-energy-costs trade-offs; and\n2) A Fact Sheet which elaborates on the statement.\nThe Senate (Muskie Subcommittee) and House (Rogers\nSubcommittee) auto emission hearings have concluded. Both\nSubcommittees are in markup.\n[insert Congressional summary]\nWe expect any announcement of your decision to support\na five-year freeze at the current standards to draw considerable\ncriticism from environmentalists. The timing of any action\nmust be measured in terms of its impact on other key Congressional\nvotes, e.g., override attempts on your veto of the bill sus-\npending your authority to impose the import fees and the strip\nmining bill. [insert timing assessment + views of advisors ]\nThere are three basic options available to you:\n1) Send a message to Congress (see Tab B).\nSub-option: Submit legislation now that the\nhearings are over.\nPro:\nCon:\n2\n2) Have one of your advisors (e.g., Secretary Morton\nas Chairman of the ERC) send the substance of the\ndraft message to the appropriate Committee Chairman.\nPro:\nCon:\n3) Delay any action until after Congressional action\non other controversial energy matters.\nPro:\nCon:\nJim spramine\nDRAFT 5/31/75\nSTATEMENT BY THE PRESIDENT\nSeveral Congressional committess, both in the House and\nin the Senate, are considering legislation affecting the\nautomobile which will have a profound impact on the Nation's\nability to achieve several very significant National objectives.\nSeveral committees are considering legislation to redefine\nFederal automobile pollution requirements and separate legis-\nlation designed to increase automobile fuel efficiency is also\nunder consideration.\nFinal decisions by the Federal Government concerning the\nautomobile will have a profound impact on our Nation's ability\nto achieve our goals concerning public health, energy, consumer\nprices, unemployment and improved air quality. Government\ndecisions must reflect a balancing of these conflicting\nNational goals.\nI therefore urge Congress to consider how Federal laws mad/\ndating automobile fuel efficiency and emission control might\nwork against each other and how cumulatively they will impact\non other National objectives such as public health and main-\ntaining a strong economy.\nIn responds to recently disclosed information concerning\npotential health hazards from automobile pollution control devices,\nI ordered a major review within the Executive Branch which has\njust now been completed. I asked my advisors to consider the\nvarious alternatives concerning automobile fuel efficiency and\nemissions on public health, energy goals, consumer prices and\nenvironmental objectives.\n2\nBased on this intensive review, I have concluded that\nwe should maintain the current automobile emission standards\nfor five years and impose strict requirements on increased\nautomobile fuel efficiency. This will enable us to obtain\nthe following objectives:\nMaintain strict control over the health impacts of\nautomobiles by not increasing unknown but potentially\ndangerous pollutants and maintaining strict control\nover known health hazards, such as carbon monoxide\nand hydrocarbons.\nAchieve at least a 40% increase in automobile fuel\nefficiency by 1980.\nAchieve\n% of the environmental objectives envisioned\nby the Clear Air Act of 1970.\nMinimize the inflationary impact of Federal regulations\non the cost of automobiles to consumers.\nI recognize that this position modifies the auto emission\nstandards contained in my proposed Energy Independence Act of 1975\nwhich I transmitted to Congress on January 30. However, as\npointed out in recent testimony during Congressional hearings,\nthe Administrator of the Enivronmental Protection Administration\nis\ny\nto\nannounced in March that a lossening the strict emission\nstandards that I proposed. was necessary. Administrator Train\nconcluded after hearings conducted by EPA that sulfuric acid\nmist is emitted from cars equiped with a catalytic convertor\n3\nwhich all new cars have in order to meet the EPA emission\nstandards. Mr. Train and the Secretary of Health, Education\nand Welfare, concluded that this is a potentially serious\nhealth hazard. Evidence brought out at the EPA hearings\nand by\ngovernment reports shows that current\ncatayltic convertors on all cars in the U.S., except those\nsold in California, do not emit sufficient sulfuric acid s AS\nto constitute any immediate danger. However, if the auto\nemissions standards are lowered, as is required under current\nlaw, then a different catalytic convertor must be used\nwhich produces substantially more sulfuric acid. This\nwould pose a health risk which my advisors conclude the\nFORD LIBRARY\ncountry should not accept.\nAccordingly, I have decided to carefully balance the\nhealth findings of the EPA hearings along with the energy\nobjectives which the Nation must achieve and have concluded\nthat I must modify the strict pollution standards I proposed\nto the Congress in January.\nThe Nation does need a long-termautomobile fuel and\npollution policy in order that the private manufactors can begin\nto build these cars which will meet these energy and environmental\nrequirements. It may very well be that additional government\nstandards, such as regulating the sulfuric acid emissions,\nmay be required in future years. This is something that EPA\nand other government agencies are working on closely with the\nappropriate committees of Congress.\n4\nNothing could be more intolerable than delay and\ncontinuing conflict between Federal energy and environ-\nmental policies and laws. This will cause further\neconomic disruption of the U.S. automobile industry and\ncontinuing unacceptable levels of unemployment. Furthermore,\nlack of a comprehensive and balanced policy will allow one\nobjective to go forward at the expense of other critical\nNational goals.\nIn order to demonstrate the difficulty of this decision\nand the interrelationships involved, the following information\nsummarizes the result of the Executive Branch review.\nBackground\nThe Clean Air Act amendments of 1970 set very rigid\nstandards and deadlines for the reduction of hydrocar-\nbons (HC) , carbonmonoxide (CO) and oxides of nitrogen (NOX)\nfrom automobiles. It proved impossible to meet the orig-\ninal requirements and changes have been made. The current\nstatutory requirements are:\nHC\nCO\nNOX\n1977\n1.5\n15.0\n2.0\n1978 and future years\n.41\n3.4\n.4\nThere is broad agreement that the current statutory\nstandards applicable to 1978 would be extremely difficult\nand perhaps impossible to meet, would involve increased\ntherefore\ncosts and decreased mileage, and will have to be changed.\nThese requirements as well as the 1977 requirements are now\nbeing subjected to Cogressional review.\nAlternatives\nThe review by Executive Branch agencies considered the\nimplications of a range of alternative automobile emission\nrequirements which might be applied to 1977 through 1981\nmodel automobiles. Specifically, the following standards\n- 4 -\napplicable to hydrocarbons (HC) # carbonmonoxide (CO) and\noxides of nitrogen (NOX) emissions have been considered:\nEmissions in grams per mile\nHC\nCO\nNOX\nMy January 30\nrecommendations covering\n1977-81 model years\n0.9\n9.0\n3.1\nMr. Train's March 5\nconclusions\n- for 1977-79 models\n1.5\n15.0\n2.0\n- for 1980-81 models\n.9\n9.0\n2.0\nContinue standards\napplicable to 1975-76\nmodels for 1977-81\n1.5\n15.0\n3.1\nAdopt Canadian 1975-76\nstandards for 1977-81\nmodels\n2.0\n25.0\n3.1\nReimpose standards\napplicable to 1973-74\nmodels for 1977-81\n3.0\n28.0\n3.1\nImportant Factors\nThere are a number of significant factors that need to\nbe considered in evaluating the automobile emission problem:\n1. Controls on auto emissions have produced significant\nbenefits and will continue to do so in those areas that\nhave an auto-related pollution problem. Lower pollutant\nlevels in these areas can reduce adverse health effects and\nreduce photochemical oxidants (smog) which is aesthetically\nunpleasant and a serious respiratory irritant.\n2. Automobile related pollutants are a problem in a number\nof metropolitan areas but are not a problem in many\nparts of the country. Auto emission standards, however,\n- 5 -\nhave been applied nationwide (except in California which\nmay have more stringent standards) and the added costs\nfor pollution control equipment, maintenance, and lower\ngasoline mileage are paid by drivers in all areas of the\ncountry -- including those areas that do not have a problem.\n3. Controlling automobile pollutants is a technologi-\ncally complex problem as illustrated by the fact that steps\ntaken to control some pollutants from internal combustion\nengines have had the effect of increasing other pollutants\nor creating new ones. For example, controls to reduce\nhydrocarbons (HC) tend to increase emissions of oxides of\nnitrogen (NOX) -- and the reverse is also true. The most\nrecent example is the potentially serious problem of sulfuric\nacid mist from cars equipped with catalytic converters\ninstalled to meet 1975-76 hydrocarbon (HC) and carbonmon-\noxide (CO) standards. Also, experts now indicate that\nreduction of NOX standards below the current standards (3.1\ngrams per mile) could require the use of larger catalysts\nor catalysts with air pumps which increase sulfuric acid\nemissions.\n4. Considerable progress has been made on automobile\nemissions since the 1970 Clean Air Act Amendments were\npassed. In the case of HC and CO, the standards applied to\n1973 74 model cars reflect a 65% reduction in emission from\nbelow pre-cential levels.\n- 6 -\nthe\npre control levels (and 1975-76 standards reflect an 83 per-\ncent reduction) In the case of NOX, EPA determined subsequent\nto the 1970 amendments that earlier assessments of NOX con-\ncentrations in air were in error and that a 90 percent re-\nduction in NOX emissions was not necessary to meet ambient\nair quality standards. However, NOX emissions have been\nreduced by 12 percent from uncontrolled levels and work is\nunderway to find more effective ways of controlling NOX\nemissions from stationary sources. Stationary sources con-\ntribute more NOX than automobiles in most of the 10 metro-\npolitan areas that could have concentrations exceeding the\nnational standard over the next 10 years.\n5. Tighter or looser auto emission standards for HC,\nCO or NOX within the range of alternatives available make\nlittle difference in the air quality in the areas that have\nan auto-related pollution problem. This little known fact\nis true because: (a) of progress already made in controlling\nand\nemissions of (b) automobiles are not the principal source of\nthe pollutant involved. The contribution of HC, CO and NOX\nfrom automobiles will continue to decline as more and more cars\nmeeting existing or past standards replace older models in the\nNation's fleet of automobiles. In the case of carbonmonoxide,\nconcentrations in metropolitan areas around the country have\n* Substitute parenthetic phrase if decision is to\nmaintain current (1975-76) standards.\n- 7 -\nbeen declining steadily. Hydrocarbon emissions (which are an\ningredient of photochemical oxidants or smog) have been de-\nclining but less rapidly than carbonmonoxide because auto-\nmobile exhaust emissions account for only about 25 percent\nof the hydrocarbons that comes from other than natural sources.\nIn the case of NOX, three metropolitan areas in the country\nexperience concentrations at this time which exceed national\nair quality standards and this number may increase to 9 or 10\nareas in the next 10 years. The growth would be due primarily\nto stationary sources. Tightening standards for automobiles\nbelow the current levels could produce slightly lower con-\ncentrations in the future, but such tightening would not\nassure meeting national ambient air quality standards in the 9\nor 10 metropolitan areas expected to have a problem. As\nindicated above, tightening of HC, CO or NOX standards is\nexpected to increase the emission of sufuric acid.\nIn addition, a reduction in vehicle miles traveled due\nto energy conservation actions or growth in vehicle miles\ntraveled that is less than EPA has projected will further\nminimize projected auto-related pollutant problems.\n6. Experts believe there is little or no health impact\nthat can be attributed with the small margin of change in\nambient air quality that would result from tighter or looser\n- 8 -\nHC, CO or NOX auto emission standards within the range being\ndiscussed. This is the case principally because tightening\nstandards beyond 1973 74 levels (1975-76 levels will have\nvery little impact on concentrations of these pollutants in\nthe areas that have an auto-related pollution problem.\n7. There is uncertainty concerning the health impact\nof sufuric acid mist emissions from catalyst equipped cars\nbecause of insufficient data and divergent estimates of the\nimportance of the problem among the various interests concerned.\nThe seriousness of the sulfuric acid emissions problem will\ndepend upon (a) the amount of emissions from catalyst\nequipped cars, (b) the extent to which concentrations of\nsurfuric acid buildup in areas that impact the public, and (c)\nwhether there is a threshold below which sulfuric acid is not\ninjurious to health. While there is uncertainty, the Admin-\nistrator of EPA and the Secretary of HEW have made it clear to\nme that they believe there is the potential for a significant\nhealth risk that cannot be dismissed with information now\navailable. This assessment led the Administrator of EPA\nto conclude on March 5 that HC and CO standards should not be\ntightened at this time because tighter standards would, with\ntechnology now available, force use of catalysts and air pumps\nthus measing subfuris accd\non many cars nationwide in 1977 Because of the potential risk,\nthe Administrator also announced that he is proceeding to set\nan emission standard covering sufuric acid applicable to 1979\nmodel cars.\n*\nSubstitute parenthetic phrase if decision is to\nmaintain current (1975-76) standards.\n- 9 -\n8. Auto emission standards have had a significant\nimpact on miles per gallon of gasoline and on our Nation's\ntotal petroleum demands and reliance on foreign sources.\nEmission controls applied to automobiles between\nthe years 1968 and 1974 caused a very significant reduction\nin miles per gallon of gasoline. It is true, however, that\nthe use of catalytic converters on 1975 cars manufactured\nto meet 49-State emission standards permitted engine adjust-\nments which helped regain some lost gasoline mileage. The\nhigher levels of pollution created in the retuned engines\nwere captured and changed chemically in the catalytic con-\nverters. Cars which must meet the tighter emission standards\napplied in California generally get poorer gasoline mileage\nthan similar model cars produced for other states.\nfor\nAn additional impact on petroleum demands comes\nfrom the need for unleaded gasoline for catalyst-equipped\ncars. The production of unleaded gasoline required changes\n[slightly J\nin refinery processes which h increase the quantity of\ncrude oil required to produce each gallon of gasoline at the\nrequired octane level.\n&\nWhile there is some disagreement among Executive\nBranch agencies, the best information now available indicates\nthat for the next few years emission standards tighter than\ncurrent levels will involve significant gasoline mileage\n- 10 -\n=\npenalties. Specifically, with technology now available,\nthere would be a fuel economy penalty associated with tightening\nthe NOX standard from 3.1 to 2.0 grams per mile and there\nwould be an additional penalty associated with tighter HC\nand CO standards.\nGERALD FORD VIBRARY\nThere is also general agreement that technology\nis available to permit increases in fuel economy over the next\nfew years compared to 1974 levels if 1975-76 standards are\nmaintained through 1971. Even greater fuel economy im-\nprovements could be achieved within a few years if either the\n1973-74 standards were reestablished or Canadian standards\nwere adopted.\n9. In addition to poorer fuel economy, increased\nconsumer costs resulted from higher initial car costs for\nemission control equipment and associated maintenance costs.\nTightening of HC, CO or NOX standards from 1975-76 levels would\ninvolve additional consumer costs. Actions to reduce sulfuric\nacid emissions from catalyst equipped cars would involve\nlarge additional costs.\n10. Less stringent auto emission within the range now\navailable would open up technological options for meeting\nstandards that would not be available with tighter standards\n(e.g., the so-called stratified charge and diesel engines,\n\"lean-burn\" technologies and other internal combustion engine\nmodifications). These technological options will permit\nfuel economy improvements that are not possible with\ntighter standards.\n- 11 -\n11. The basic philosophy and approach that has been\nused to bring about auto emission controls needs to be\nreconsidered in light of current conditions.\na. We should be clear about the philosophy that has\nbeen applied in the Clean Air Act auto emissions standards\nand the rationale behind that philosophy. Briefly, the\nphilosophy has been that automobile companies do not have\nmarket incentives to develop technology to reduce auto\nemissions and would not develop such technology unless\nforced to do so by progressively rigid standards backed\nup by law and regulation. It would be difficult to contend\nthat progress achieved so far in controlling auto emissions\nwould have been achieved if this approach had not been used.\nOn the other hand, hindsight suggests we may now be faced\nwith a potentially serious sulfuric acid problem which\nmight not have occurred had more time been allowed to\ndevelop and assess technology before it was put into use.\nThe wisdom of continuing a rapid \"technology forcing\"\napproach is open to question.\nb. Auto emission standards have been changed frequently\nin recent years, allowing little time for developing and\nassessing alternative technologies. As standards have\nbecome more stringent, the technological changes required\n- 12 -\nhave become more extensive and more sophisticated. More\ntime is required to develop and assess improved technology\nand bring it to a stage where it can be used on production\nline cars. These factors, the current economic status of\nthe automobile industry, and the demands being placed on\nthe industry simultaneously to meet safety standards and\nto improve fuel economy need to be kept in mind when the\nCongress considers the question of whether standards should\nbe held stable for more years than has been the case in the\nrecent past.\n12. Prompt Congressional action is needed on auto\nemission standards. This matter warrants thorough dis-\ncussion by the Congress and the public because of the far\nreaching implications. The matter also requires an early\ndecision by the Congress. Specifically, the Administrator\nof EPA adivses me that in order to meet deadlines for\nemission testing and certification of 1977 model cars, the\nautomobile industry will need to know 1977 emission standards\nby early August 1975 so that there will be time to complete\ndesign and engineering, build prototypes, complete emissions\ntesting such as 50,000 mile endurance tests, and finally\nto produce new cars in adequate quantity to meet demand\nfrom the American public.\n- 13 -\n13. The broader economic implications of the auto\nemission decision must also be kept in mind. There\nundoubtedly has been some contribution to inflationary\nand recessionary pressures in the economy from the\nincreased consumer costs, and poorer gasoline mileage\n(and greater reliance on foreign oil) resulting from\nemission control requirements. Inflationary and recession-\nary conditions have both contributed to and resulted\nfrom sharply lower sales and employment in the auto\nindustry. Of course, any costs associated with auto\nemission controls must be balanced against the health,\naesthetic and economic benefits that are gained from\nimproved air quality.\n14. Actions to reduce auto emissions must take into\naccount other sources of the same pollutants. In cases\nwhere stationary sources of the same pollutants are\nsignificant contributors to a problem in the metropolitan\nareas of concern, it may be far more cost effective to place\ngreater reliance on reducing pollution from stationary\nsources. The problem of other sources is complicated\nby a growing body of opinion that natural sources of\npollutants -- which cannot be controlled -- may be\nsufficiently important in some areas to prevent attaining\n- 14 -\nnational air quality standards regardless of what is done\nto control man-made sources.\nLegislative Recommendations\nBased upon the information and data that have been\ndeveloped during the Executive Branch review of the auto\nemissions issue, I have today recommended to the Congress\nthat the Clean Air Act be amended to set standards of\ngrams per mile for HC,\nfor CO, and\nfor NOX.\nI have further recommended that these standards be kept in\nforce for\nyears. These standards would be equivalent\nto those in effect for\nmodel year cars. My conclusions\nare based on an evaluation of air quality, health, consumer\ncost, fuel economy, and other energy and economic considera-\ntions.\nFirst, the principal reason for my recommendation of\nless stringent HC and CO requirements than I recommended\nearlier is the unknown but potentially serious health\neffects associated with sulfuric acid emitted from catalyst\nequipped vehicles, and the fact that this problem is\nexacerbated by the use of air pumps which would be needed\non most cars to meet those standards. In the absence of\nbetter data and greater agreement among experts, the\npotentially serious health effects must take precedence\nover the known but very small potential health effect\n- 15 -\nassociated with the slight changes in HC and CO concentra-\ntions if HC and CO standards tighter than I have proposed\nwere established.\nSecond, I have concluded that tightening of the NOX\nstandard from 3.1 to 2.0 grams per mile would be undesirable\nbecause the probable fuel economy loss and the probable\nneed to use air injected catalyst systems to meet the\n2.0 standard, which would increase sulfuric acid emissions.\nThese potential costs are not balanced by the benefits of\nthe very small change in ambient air quality and the im-\nperceptible impact on health that could result from the\ntighter standards.\nThird, the marginal benefits in a few metropolitan\nareas which might result from tighter nationwide standards\nare very small. Based upon the information now available,\nthose benefits do not appear to justify the additional\nconsumer and energy requirements costs, that would be\nimposed nationwide. Furthermore, the standards I have\nproposed preserve technological approaches to pollution\ncontrol that are cheaper in terms of fuel requirements and\nconsumer costs which would not be available under tighter\nstandards.\n- 16 -\nFourth, I have proposed that the standards remain\nconstant for\nyears so that the industry is not\ndistracted unnecessarily from efforts to improve safety\nand fuel economy. A pause for this period will not have\nsignificant adverse effects on our progress in improving\nair quality. It will also provide time for industry\nand the Government to help avoid costly errors and\nincrease the chances of meeting fuel economy, safety\nand consumer cost objectives.\nAdministrative Actions\nBecause of the far reaching impact that automobile\nemission standards can have on all of the factors I have\ndiscussed, I feel very strongly that we should have known\na great deal more about their impact before standards were\nset.\nI believe the Nation should not be subjected to far\nreaching Federal actions such as establishment of auto\nemission standards which required the catalyst without\nfar better information than was available before this\naction was taken.\nCurrent law requires that an Environmental Impact\nStatement be prepared showing the expected environmental\nimpact of major Federal actions significantly affecting\nthe quality of the human environment. Somewhat ironically,\n- 17 -\nthat requirement has not applied to Federal pollution\ncontrol actions, such as the setting of auto emission\nstandards which led to the catalyst technology. If such\na requirement had been followed we might have known in\nadvance of the health, environmental and economic impli-\ncations of auto emission standards which led to the\ninstallation of catalytic converters.\nBecause of my concern over the potentially unforeseen\nresults of Federal actions, I have directed previously\nthat inflationary impact statements be prepared on\nsignificant Federal actions affecting the economy. I\nintend to continue pursuing that basic approach to Federal\ndecision making.\nTHE WHITE HOUSE\nWASHINGTON\nJune 17, 1975\nMEMORANDUM FOR:\nDICK DUNHAM\nFROM:\nJIM CANNON am\nSUBJECT:\nAuto Emissions\nOn the June 14 draft of Auto Emissions: This draft does\nnot spell out precisely what has changed since the\nPresident's previous decision to warrant our asking him\nfor a new decision.\nWould you ask Mike to redraft, and spell out on the first\npage, in a direct and crisp way, what has changed that\nrequires the President to take a different action from\nthe previous action.\nI also think this should be staffed more widely to\nHartmann, Marsh, Friedersdorf and Buchen.\nIt seems to me that Auto. Emissions is an issue on which\nwe should say what is necessary, but only what is necessary.\nIf we want to transmit a message that includes technical\nelements, which Mike's draft does, perhaps it should be\nauthored by Zarb or someone who has the technical capability\nin this field, and not the President.\nFORD LIBRARY is GERALD\nTHE WHITE HOUSE\nWASHINGTON\nJune 14, 1975\nMEMORANDUM FOR\nJIM CANNON\nFROM:\nMIKE DUVAL\nSUBJECT:\nAUTO EMISSIONS\nAttached is the auto emission package.\nTab A - Draft memo to the President and draft\nMessage to Congress.\nTab B - Draft Fact Sheet\nTab C - I and A format which OMB is preparing as\na possible cover for the Fact Sheet.\nIf the President intends to raise this issue at Tuesday's\nLeadership meeting, I recommend that Tab A go to him Monday\nat 4:00 p.m. This means we should send it to the senior\nWhite House staff, plus Zarb, Coleman and Weinberger, for\ntheir comments and votes first thing Monday morning. I\nrecommend that any copy taken outside the White House\ncomplex be hand-carried.\nI will be available (reachable by the White House Operators)\ntomorrow except during church - 10-11:30 a.m.\nFORD\nTIBRARY\nDRAFT\nTHE WHITE HOUSE\nDECISION\nWASHINGTON\nJune 14, 1975\nMEMORANDUM FOR\nTHE PRESIDENT\nFROM:\nJIM CANNON\nSUBJECT:\nAUTO EMISSIONS\nBACKGROUND\nJust prior to your departure for Western Europe, you made\ntwo decisions concerning auto emissions.\n1.\nSend to Congress a detailed statement of the environ-\nmental, energy, health and cost trade-offs concerning\n23\nautomobile emissions, but hold off making a specific\nrecommendation for legislation until after committee\nhearings have been completed (this has not yet been\nimplemented) ; and\n2. On the substance of the issue, you indicated a pref-\nerence for a five-year extension of the current emis-\nsion standards.\nThe House Health and Environment Subcommittee (Rogers) and\nwhat\nthe Senate Environmental Pollution Subcommittee (Muskie) have\nboth concluded their hearings on the auto emissions question,\nand neither committee reopened hearings after the recess to\nchanged.\nconsider the trade-off between environment and energy. Both\nsubcommittees are in the process of marking up an auto emis-\nsions bill and apparently will not consider the impact of\nauto emissions on fuel efficiency.\nand air Direct and\nAs you know, the House has included in the Ullman energy bill,\na provision requiring a 50% improvement in automobile effi-\nciencies by model year 1980, enforced by a relatively mild\ntax on automobiles which do not meet the goal.\njuni\nany\nank\n2\nISSUES FOR DECISION\nThe purpose of this memorandum is to present two issues for\nyour decision.\nA. Should you now transmit to Congress a statement on\nthe auto emissions issue, along with legislative\nrecommendations?\nB. If so, what form should it take?\nIf the auto emissions issue is to be discussed at your meeting\nwith the Leadership on Tuesday, I recommend that you hold off\nany final decision on these two questions until after the\nmeeting.\nDISCUSSION\n1.\nShould you transmit a Message on auto emissions, along\nwith legislative recommendation, to continue the present\nstandards for five years?\nArguments in Favor\nIt appears clear that neither the Senate nor the House\nwill hold hearings at the subcommittee or committee\nlevel (as we had urged) on the difficult trade-offs\ninvolved between environment and energy. In both\ncases, they have discussed the health impact, and to\na lesser extent, cost. Nevertheless, both committees\nappear headed towards recommending much tighter emis-\nsion standards. We understand that the Rogers Committee\nmay recommend\nThe Muskie Committee, according to our information, is\nlikely to recommend that we adhere to the 1978 statu-\ntory standards.\nIf final Congressional action is anywhere near these\npositions, it will seriously jeopardize your energy\ngoal of a 40% improvement in auto efficiency by 1980.\nFurthermore, such a decision raises substantial health\nquestions concerning the emission of sulfuric acid mist.\n(See Tab A for draft Presidential Message which develops\nthese arguments in some detail. This has not yet been\nreviewed by the speechwriters.)\nIf you are to have any influence on the auto emission\nlegislation, it appears that now is the time to present\nyour views to Congress. Submission at this time of a\n3\nStatement of Facts only, without a legislative recom-\nmendation, probably would not be viable because it\nwould raise more questions than it would answer. If\nthe committees are not going to hold additional hearings,\nin which they consider the energy impact of their emis-\nsion decisions, there would be no forum to debate your\nStatement of Facts. Furthermore, Administration spokes-\nmen could expect to be barraged with questions as to\nwhere you come out on the issue, and we could not make\nthe response that you wanted to wait until additional\nevidence was heard by Congress. As a practical matter,\na statement by you, along with a specific recommendation,\nis probably necessary if we are to have any influence\non the final outcome.\nYou must also consider the potential adverse political\nimpact if Congress does not provide legislative relief\nfrom the stricter standards and, as a result, injuries\noccur because of the sulfuric acid mist or other toxic\npollutants which may result from pollution devices which\nthe automobile manufacturers adopt to meet the strict\nstandards.\nArguments Against\nEPA's John Quarles (Russ Train is out of the country),\nargues that you should endorse the Train announcement\nof March 5, which would impose a set of standards which\nare stricter than the existing levels, but less strict\nthan your \"modified California\" proposal in January.\nIn essence, EPA is reraising the issue you decided\nprior to going to Europe. They argue that Congress\nis more likely to respond to the Administration recom-\nmendation if you and Train are together. However, Frank\nZarb, Jim Lynn, and others, feel strongly that the Train\nposition will prevent us from achieving our energy ob-\njectives.\nWe must consider how you are perceived by environmenta-\nlists and those who support their objectives. The\nHathaway nomination, your strip mine veto, and position\non the utilities bill have resulted in substantial criti-\ncism of your policies from environmentalists. There is\nno doubt that your decision on the auto emission question\nwill be extremely controversial -- perhaps eclipsing the\nstrip mine veto. Therefore, you may wish to separate\nyourself from this decision as much as possible by just\nissuing a generalized Statement of Facts and leaving\nspecific recommendations up to other Administration\nofficials.\n4\n2.\nIf you decide to send a Message to Congress with\nspecific recommendations, what form should it take?\nThis issue really raises two questions.\nFirst, should you issue a statement personally, or\nshould this be done by a subordinate?\nArguments That You Should Issue the Statement\nThis subject is of enormous importance to all Americans,\nas it touches their lives directly on a familiar issue.\nIt involves the trade-off between conflicting national\nobjectives, none of which fall under the sole responsi-\nbility of a subordinate official within your Adminis-\ntration. In short, this is exactly the type of inter-\nrelated decision involving many trade-offs which should\nbe made by the President.\nArguments Against a Presidential Message\nThis is going to be a controversial decision, regardless\nof which way you come down. This matter involves a\ngreat deal of technical data and conclusions, much of\nwhich is in controversy, and much of the subject matter\nis simply unknown. Therefore, any Statement of Facts\nand conclusions are bound to be attacked as to their\naccuracy.\nSecond, if you decide to send a Message, should it be\nbrief or detailed?\nArguments for a Detailed Message\nIf you issue a Message on this subject, the attack is\nlikely to follow the line taken on your position con-\ncerning strip mining. Your position will be characterized\nas a cave-in to Detroit, based in part on bad information\nfrom your advisers. The best way to meet this is by\nshowing the Members of Congress and the Press, the steps\nyou went through and analysis you have made in reaching\nyour decision. This is an extremely complex subject,\nbut an understanding of the facts does lead logically\nto the conclusion you have made. The reaction to your\nstatement should be one of recognition that you have\ngone through all the complex data and analysis and\nwere driven to your decision on the basis of a detailed\nsubstantative review.\n5\nThis is similar to your energy decision and involves\na massive amount of conflicting and highly technical\ninformation which must be developed into a policy\ndecision involving the balancing of conflicting\nnational objectives. You should seek to make the\npoint that you did not duck the complexities of this\nissue, but got into it personally and reached your own\nconclusion based on the best information available.\nArguments for a Brief Message Followed by Detailed\nBackup Information Released by Another Administration\nOfficial\nSome will argue that, as President, you should not get\ninto the details of a highly technical and scientific\nsubject, especially when there is little agreement among\nthe experts on the facts involved. Others should be\nrequired to defend the specifics, and you just take\nthe higher road by issuing a Message based on final\nconclusions.\nThere is a great deal of conflicting scientific informa-\ntion, including a recent study under the aegis of the\nNational Academy of Scientists, which concludes that\nstricter standards should be adopted than you have\nproposed. If you issue a detailed statement in this\narea, you will be taking on many in the scientific\ncommunity who feel we should go to the statutory\nstandards.\nDECISION\n1.\nTransmit Message to Congress with Statement of Facts\nand legislation freezing the current standards for\nfive years.\nRecommend: Cannon, Lynn\nApprove\nDisapprove\nTransmit Message without recommended legislation.\nRecommend: EPA (Quarles)\nApprove\nDisapprove\nFURD\nHIBBARY\n6\n2. Transmit package as Presidential Message.\nRecommend:\nApprove\nDisapprove\nTransmit from the appropriate Cabinet official.\nRecommend:\nApprove\nDisapprove\n3. Use detailed format.\nRecommend:\nApprove\nDisapprove\nUse summary Message with details issued by the appro-\npriate subordinate official.\nRecommend:\nApprove\nDisapprove\nDRAFT\nMASTER\n6/11/75\n1:00 p.m.\nMESSAGE to congress\nFour and a half months ago, I sent to Congress my pro-\nposed Energy Independence Act of 1975. As a part of that\ncomprehensive legislative proposal, I recommended that the\nCongress modify the Clean Air Act of 1970, concerning emis-\nsions from automobiles. I proposed strict pollution levels\nwhich would still permit this Nation to achieve one of my\nenergy goals, which is a 40% improvement in automobile fuel\nefficiency within four years.\nSince that time, information has been disclosed concerning\npotential health hazards from automobile pollution control\ndevices. In response to the serious issues raised by even\nthe possibility of any such hazards, I ordered a majar review\nof the questions raised within the Executive Branch. I asked\nmy advisers to consider the various impacts of a range of\nemission alternatives on public health, energy goals, consumer\nprices and environmental objectives.\nThis review has now been completed. We have surveyed this\nentire subject matter, with many scientists and other experts,\nand find regrettably little agreement on the data or conclusions.\nThere is, however, general agreement that we really cannot\nwith precision which\npredict what adverse impacts are likely to result if we move\nto stricter automobile pollution standards. Most of the experts\nalso agree that there is an interrelationship between the\nlevels of pollutants emitted by our cars and their fuel effi-\nciency and cost to the consumer.\nPORD LIBRARY N\n2\nIt is relatively easy to state the problem. As the\nautomobile manufacturers are required by government regula-\ntion to remove certain some pollutants from the car's exhaust,\nother pollutants with potentially serious health implications\nare being produced. Some of the devices which would help to\ncorrect some air pollution problems result in the creation or\naggravation of others. Some of these same devices result in\nserious reductions in the automobile's fuel efficiency. The\nresult of government-mandated changes to our automobiles could\nfurther\ntheir price\nthen be substantial increasesin its prica tag, without\nsubstantial environmental benefits and with possible risk to\nthe Nation's health.\nAs a result of actions already taken, we are well on the\nroad to cleaning the Nation's air. A major part of our task\nis behind us but, unfortunately, it was also the easiest part.\nWe have now reached the point where the further incremental\nprogress we all want can only be achieved very slowly, and at\nhigher great cost, under any of the possibilities reviewed. The\nMOST\nrelatively short distance remaining is a very rough road indeed.\nI therefore urge Congress to consider how Federal laws\nmandating automobile fuel efficiency and emission control might\nwork against each other, and how, cumulatively, they will impact\non other national objectives such as public health and maintaining\na strong economy.\n3\nIn view of all of these considerations, I have decided\nthat oven the position my Administration has already taken\nin the Energy Independence Act must be revised. We simply\ncannot afford to be wrong, or hesitant, where such serious\nissues are at stake. I have concluded that we should maintain\nthe current automobile emission standards for five years. This\nashieve\nwill enable us to cbtain the following objectives:\nMaintain strict control over the potential adverse\nhealth impacts of automobile emission devices by\nretaining current controls on known health hazards,\nsuch as carbon monoxide and hydrocarbons, without the\nrisk of increasing imperfectly understood but potentially\ndangerous other pollutants.\nAchieve at least a 40% increase in automobile fuel\nefficiency by 1980.\nAchieve almost all the environmental objectives we\nwould have achieved by going to the stricter standards\nI proposed in January.\nMinimize the inflationary impact of Federal regulations\non the cost of automobiles to consumers.\nI recognize that this position modifies the auto emission\nstandards contained in my proposed Energy Independence Act\nof 1975 which I transmitted to Congress on January 30. However,\nas pointed out in recent restimony during Congressional hearings,\nthe Administrator of the Environmental Protection Administration\nhas already noted that it is necessary to adjust the strict\nemission standards that I proposed. Administrator Train con-\n4\ncluded after hearings conducted by EPA that sulfuric acid\nmist is emitted from cars equipped with a catalytic converter,\nmost\nwhich all new cars have in order to meet the EPA emission\nThe Administrator\nstandards. Mr. Train and the Secretary of Health, Education\nand Welfare, concluded that this is a potentially serious\nhealth hazard.\nEvidence brought out at the EPA hearings and by govern-\nlevels of Emitsions from,\nment reports, shows that current catalytic mufflers -\nin\ndo\nnot\nemit sufficient sulfuric acid so as to constitute any\nimmediate danger. However, if the auto emission standards\nare further lowered, as would be required if no change is\nmade in the current law, then a different catalytic muffler\nis likely to have to be used. That device would produce\nsubstantially more sulfuric acid, and other possibly dangerous\nemissions as well. This would pose a health risk which my\nadvisers conclude we should not accept.\nThe Nation needs a long-term automobile fuel and pollution\npolicy so that we can begin to build cars which will meet\nresponsible energy and environmental standards. By getting\non with the job of replcing the current fleet, with these new\ncars, we will be making substantial progress towards our goals\nof better fuel efficiency, less pollution and economic recovery.\nNothing could be more intolerable than delay and continuing\nconflict between Federal energy and environmental policies and\nlaws. Such delays will only contribute to further economic\ndisruption and continuing unacceptable levels of unemployment.\nFORD LIBRARY\n5\nFurthermore, lack of a comprehensive and balanced policy\nwould allow one objective to go forward only at the expense\nof other critical national goals.\nIt may very well be that additional government standards,\nsuch as regulating the sulfuric acid emissions, will be\nrequired in future years. This is something which I have\nspecifically directed the EPA and other government agencies to\nwork on closely with the appropriate committees of Congress.\nHowever, it is clear that we cannot duck our responsibility\nto make decisions now that establish realistic ground rules.\nsulfate\nWe cannot afford to ignore the sulfur problem, but our response\nmust be more than simply another government decree, setting\nanother standard, that could create -\nanother problem.\nWe have a positive obligation to ensure that the steps we\ntake today do not aggravate this potentially serious health\nhazard.\nOur review demonstrates the difficulty of this decision and\nthe interrelationships involved. I would like to briefly dis-\ncuss some of the important background that went into this\ndifficult decision.\nAt the outset, I think it is important to note that most\nof our current difficulties were not foreseeable when the\nClean Air Act Amendments of 1970 set rigid standards and dead-\nlines for the reduction of hydrocarbons, carbon monoxide and\noxides of nitrogen. It has proved impossible to meet the\noriginal requirements, and the changes provided for the in\n6\nthe Act have already been made. But the 1978 Statutory\nStandards still remain in the law, and will go into effect\nunless Congress acts.\nThe Executive Branch review considered the implications\nof a broad range of alternative automobile emission require-\nments which could be applied over the next five years. The\nfollowing chart illustrates the alternatives considered:\nEmissions in grams per mile\nHC\nCO\nNOX\nRetain the statutory standards\nfor 1978 models\n0.41\n3.4\n0.4\nEnergy Independence Act proposal\ncovering 1977-81 models\n0.9\n9.0\n3.1\nEPA's March 5 conclusions\n- for 1977-79 models\n1.5\n15.0\n2.0\n- for 1980-81 models\n.9\n9.0\n2.0\nContinue standards applicable to\n1975-76 models through 1977-81\n1.5\n15.0\n3.1\nAdopt Canadian 1975-76 standards\nfor 1977-81 models\n2.0\n25.0\n3.1\nReimpose standards applicable\nto 1973-74 models through\n1977-81\n3.0\n28.0\n3.1\nI have chosen the middle road of continuing the 1975-76\nstandards for the following reasons:\nThe principle reason for my recommendation regarding hydro-\ncarbons and carbon monoxide is that there are unknown but\npotentially serious health effects associated with sulfuric\nFORD LIBRARY is GERALD\n7\nacid emitted from catalytic catalyst equipped vehicles, and\nthis problem may be exasperated by the use of the more sophis-\nticated catalysts necessary to reach the levels of stricter\nstandards. In the absence of better data and agreement among\nthe experts, any such potentially serious health effects must\ntake precedent over the known but very small health effects\nthat might result from the [slight] changes between my current\nthe STATATORY standards\nrecommendations and[my proposal of January 30%\nSecond, I have concluded that the nitrogen oxide standard\nshould be retained at the current level because of the probable\nSigNiFiCaNT\nmajor fuel economy loss which would result from a tighter\nstandard. In addition, a stricter NOX standard may require\nthe use of air injected catalyst systems, which also would\nlinely TO\nincrease sulfuric acid emissions. These potential results\nare not balanced by the benefits of the very small change in\nthe air quality and the imperceptible impact on health that\ncould result from a tighter NOX standard.\n(of improved ambient air quintity\nThird, the marginal benefits in a few metropolitan areas\nwhich result from tighter nationwide standards are very small.\nBased on the information now available, those benefits do\nnot appear to justify the additional consumer and energy costs,\nfrom catalyst generated emissions,\nnot to mention the potential health danger, Furthermore, the\nstandards I have proposed would preserve our options to adopt\ntechnological approaches to pollution control that are cheaper\nin terms of cost and fuel requirements. These alternatives\nwould not be available if we have to adopt technology to reach\nJ,\nstatutory\nstricter standards now.\n8\nThere are as many myths about auto pollution as there are\ngenerally accepted facts. The following are some of the\nsignificant factors which I considered as I reached my deci-\nsion in this matter.\n1. Existing controls on automobile emissions have produced\nsignificant benefits and will continue to do so in\nthose areas that have auto-related pollution problems.\nLower pollutant levels in these areas can reduce\nadverse health effects and reduce smog and other\nesthetically unpleasant atmospheric conditions.\nAutomobile related pollutants are a problem in a\nnumber of metropolitan areas, but the majority of the\ncountry does not have this problem. Nevertheless,\nthe strict auto emission standards currently in the\nlaw apply to all parts of the country. Thus consumers\neverywhere must pay the cost of cleaning up a few\nheavily polluted cities. These added costs for pollution\ncontrol show up not only in the initial price tag of\nthe car, but in maintenance costs and lower gasoline\nmileage as well.\nConsiderable progress has already been made on auto-\nmobile emissions since the 1970 Clean Air Act Amendements\nwere enacted into law. In the case of hydrocarbons\nand carbon monoxide, the current standards reflect\nFORD & LIBRARY. 07V870\n9\nan 83% reduction below pre-control levels. In\nthe case of oxides of nitrogen, it is generally\nbelieved that stationary sources contribute more\nto this problem than automobiles, and there has\nbeen a 12% reduction already, compared to uncon-\ntrolled levels.\n10\nImportantly, it makes very little difference in terms\nof air quality based on hydrocarbons, carbon monoxide\nand oxides of nitrogen which alternative, among the\nranges I considered, is ultimately selected over the\nnext five years. This is because of the progress that\nhas already been made in controlling these pollutants\nfrom automobiles, and because the automobile is not\nthe principle source of the pollutants involved. The\ncontributions of HC, CO and NOX from automobiles will\ncontinue to decline as more and more cars meeting\nexisting standards replace older models. In the case\nof carbon monoxide, concentrations in metropolitan areas\naround the country have been declining steadily. Hydro-\ncarbon emissions, which are a major ingredient of the\nphotochemical oxidents which produce what is commonly\ncalled smog, have also been declining, but less rapidly\nthan carbon monoxide. This is because automobile exhaust\nemissions account for only about 25% of the hydrocarbons\nin the atmosphere. Most hydrocarbons come from natural\nsources, such as\nIn the case of oxides of nitrogen, three metropolitan\nareas in the country experience concentrations which\nexceed National air quality standards. This number\nmay increase to nine or ten in the next decade, but that\ngrowth will be due primarily to stationary sources --\nnot the automobile.\nFORD LIBRARY is GERALD\n11\nSignificatnly, if our energy conservation steps\nresult in less driving by Americans, the benefits\nin terms of auto pollution could far exceed anything\nobtainable by a tightening of standards.\n2.\nControlling automobile pollutants is a technologically\ncomplex problem. The fact is that steps taken to\nreduce certain pollutants result in creating or\nincreasing other pollutants. For example, controls\nto reduce hydrocarbons tend to increase emissions of\noxide nitrogen,\nand the reverse is also true, The\nsulfuric acid mist is another example of unforeseen\nconsequences, and if the tougher 1978 standards are\nimposed along with the sulfuric acid standard, we may\nend up with an anti-pollution device which, under\nabnormal conditions, could emit such toxic pollutants\nas hydrogen sulfide, carbon disulfate and hydrogen\ncyanide.\nConcerning the sulfuric acid mist problem, it is clear\nthat these is a divergence of opinion among the scientific\ncommunity. There is, however, general agreement that\nthere could be an adverse and potentially serious health\nimpact because of the sulfuric acid mist that is emitted\nfrom catalyst equipped cars. The seriousness of this\nproblem will depend on the amount of emissions per car,\nthe extent to which they disperse or concentrate in areas\nwhich could impact on the public, and whether or not there\nis a threshold below which sulfuric acid is not injurious\n12\nWhile there is uncertainty in this area, the\nAdministrator of EPA and the Secretary of HEW have\nmade it clear to me that they believe there is a\npotential for a significant health risk that cannot\nbased ilpon,\nbe dismissed wash information now available. This\nassessment led the Administrator of EPA to conclude\non March 5, that hydrocarbons and carbon monoxide\nstandards should not be tightened at this time because\nmodifical\ntighter standards would likely force the use of new\ncatalysts which will increase the amount of sulfuric\nacid emitted.\nOne of the reasons for concern in this area is the\nlack of knowledge of just what kind of technological\ndevices will be realistically available for automobile\nmanufacturers to use in meeting stricter standards.\nOur current testing shows that more sulfuric acid mist\nis emitted from catalytic equipped cars sold in California,\nwhich are designed to meet the tougher pollution standards\nwhich exist in that State compared to the rest of the\ncountry. Thus we know that there is a strong possibility\nthat as the pollution standards are made tougher, our\nsulfuric acid problem may substantially increase.\n3. Our auto emission laws have had a significant negative\nimpact on fuel economy. Emission controls applied\nto automobiles between the years 1968 and 1974 caused\nFORD LIBRARY &\na very significant reduction in miles per gallon of\n13\ngasoline. The use of the catalytic mufflers on\n1975 cars permitted engine adjustments which helped\nregain some of this loss in gasoline mileage. The\nhigher levels of pollution created by the retuned\nengine (which gets better mileage) are captured and\nchanged chemically by the catalytic mufflers.\nHowever, there continue to be some offsets in this\narea. Cars which must meet the tighter emission\nstandards applied in California generally get lower\nmileage than similar models produced for other States.\nAn additional impact on petroleum demands comes from\nthe need to use unleaded gasoline for catalyst equipped\ncars. The production of unleaded gasoline requires\nchanges in the refinery process which slightly increases\nthe quantity of crude oil required to produce each\ngallon of gasoline, at the required octane level.\n4.\n[Insert impact on cost to consumer paragraph.]\n5. Maintaining the current automobile emission standards\nwill open up a range of technological alternatives\navailable to meet pollution and fuel efficiency require-\nments. For example, the so-called stratified charge and\ndiesel engines, \"leas-burn\" technologies and other\ninternal combustion engine modifications will be\npossible. Under the stricter 1978 statutory standards,\n14\nmany alternatives to the catalytic muffler will be\ncliminated.\nOther technical information was brought to my attention as\nI reached my automobile emissions decision. In addition to\na Statement of Facts, which I am making public today, I have\nasked my key advisers in this area to consult with the appro-\npriate members of Congress, particularly the abcommittees now\nconsidering legislation in this field. They will be available\nto discuss these complex and interrelated issues and to provide\nall the detailed information available to the Executive Branch.\nI urge the Congress to carefully consider all the issue involved\nin the potential conflict that one national objective, attaining\nclean air, might have on our efforts to reach other goals.\nFORD is LIBRARY\nMr. Davar\n6/13/75\nEMBARGOED FOR RELEASE\nUNTIL 1:00 P.M. EDT\nJune\n, 1975\nOffice of the White House Press Secretary\nTHE WHITE HOUSE\nFACT SHEET\nThe President today recommended legislation to the Congress which\nwould amend the Clean Air Act by extending the current automobile\nemission standards from 1977 until 1981.\nWhile this action will have no significant impact on our attempt\nto achieve the objectives of the Clean Air Act, the proposed\nmodifications are necessary to (1) avoid certain recently\nrecognized potential health risks associated with the catalytic\nconverter and (2) permit substantially greater fuel efficiencies\nover the next five years.\nBackground\nFORD LIBRARY\nThis proposal supercedes Section 503, Title V, of the President\nEnergy Independence Act of 1975 which he sent to Congress on\nJanuary 30, 1975. At that time, the President proposed emission\nstandards based on a modification of the current California\nstandards.\nAfter submitting the Energy Independence Act to the Congress, the\nEnvironmental Protection Agency held public hearings related to\nfive-year emission levels. The hearings established that the\ncatalytic converter, used to meet the HC and CO standards for\n1975 and 1976 model year vehicles, produces sulfuric acid in\namounts that can pose a significant public health risk.\nIn addition, because of the technology likely to be used to\nachieve these tighter standards, automobile emissions of sulfuric\nacid may double if the more stringent HC and CO standards\nproposed in the Energy Independence Act are imposed for 1977\nand subsequent years.\nAccordingly, the President directed an interagency task force\nto undertake a major review of the public health, energy and\nconsumer cost implications of several widely discussed levels\nof automobile emission standards.\nThe President's decision is based upon this review. Some of\nthe more significant considerations which led to the President's\nrecommendation are contained in his statement released today.\nAdditional information on those considerations is outlined below.\nThe Interagency Review\nThe review by Executive Branch agencies considered the implications\nof a range of alternative automobile emission requirements which\nmight be applied to 1977 through 1981 model automobiles.\nSpecifically, the following standards, applicable to hydrocarbons\n(HC), carbon monoxide (CO) and oxides of nitrogen (NOX) emissions,\nhave been considered:\nEmissions in grams per mile\nHC\nCO\nNOX\nRetain statutory standards which\nwill apply to 1978 models\n0.41\n3.4\n0.4\nEnergy Independence Act proposal\ncovering 1977-81 models\n0.9\n9.0\n3.1\nMr. Train's March 5 conclusions\n- for 1977-79 models\n1.5\n15.0\n2.0\n- for 1980-81 models\n.9\n9.0\n2.0\nContinue standards applicable to\n1975-76 models for 1977-81\n1.5\n15.0\n3.1\nAdopt Canadian 1975-76 standards\nfor 1977-81 models\n2.0\n25.0\n3.1\nReimpose- standards applicable to\n1973-74 models for 1977-81\n3.0\n28.0\n3.1\nBased upon this review, the following conclusions were reached:\n1.\nControls on automobiles necessary to meet the current standards\nhave reduced ambient concentration levels in those areas that\nhave auto-related HC and CO problems; and have reduced the\nrate at which NOX concentrations have increased.\n2.\nThrough the year 1985, tighter or looser standards, in the\nrange being considered, for HC, CO and NOX will make little\ndifference in the air quality in those areas that have an\nauto-related pollution problem, although many parts of the\ncountry have no auto-related pollution problem.\n3. Present data are not sufficient to make specific calculations\nor final judgments on what sulfuric acid emission levels\nwould be safe from a public health perspective. However,\nit is known that sulfuric acid emissions could prove to be\na significant public health risk and that emissions could\ndouble if standards more stringent than the 1975 interim\nstandards are adopted.\n4. Further mandated reductions in emissions from internal com-\nbustion engines may have the effect of increasing or\ncreating pollutants other than CO, HC and NOX.\n5. Auto emission standards have had an impact on fuel economy\nand, therefore, on our nation's total petroleum demands\nand reliance on foreign sources. Standards tighter than the\n1975 interim will result in higher initial car costs and\nhigher operating costs.\n6. The basic philosophy and approach to future auto' emission\ncontrols need to be reconsidered in light of current\nconditions.\n(a) Significantly tighter standards at this time may\npreclude continued development of some technologies.\n(b) Actions to reduce auto emissions must take into\naccount other sources of the same pollutant.\n7. Prompt Congressional action is needed on auto emission\nstandards in order to establish a five year emission\nprogram which is compatible with a strict fuel efficiency\nprogram.\nDISCUSSION\n1.\nControls on automobiles necessary to meet the current standards\nhave reduced ambient concentration levels in those areas that\nhave auto-related HC and CO problems; and have reduced the\nrate at which NOX concentrations have increased.\n2.\nMany parts of the country have no auto-related pollution problem.\nThrough the year 1985, tighter or looser standards for HC, CO\nand NOX in the range being considered, will make little difference\nin the air quality in those areas that have an auto-related\npollution problem.\nThe Clean Air Act has imposed increasingly more stringent automobile\nemission limitations. 1973-74 vehicles produce about 65 percent\nless HC and CO than uncontrol (pre-1968) vehicles. 1975 vehicles,\nmeeting the current standards, produce 83 percent less HC and CO and\n11 percent less NOX than uncontrolled vehicles. The existing law,\nhowever, requires that these automobiles emissions be reduced even\nfurther beginning with model year 1977 for NOX and model year 1978\nfor HC and CO.\nThe attached tables show the direction and magnitude of change\nin ambient concentration levels for HC, CO, and NOX which would\nresult from adopting standards which are less (or more) stringent\nthan those proposed in the Energy Independence Act. The ambient\nstandards are used as criteria because they are the health-\nrelated pollutant limits in each air quality region, toward\nwhich reductions in both automobile and stationary emissions\ncontribute. Thus the levels shown are the result of mobile and\nstationary source emissions. Three points should be noted:\n- First, though the tables assume that the statutory standards\nwill be in force after the 1981 model year, if any. of the\noptions were kept through model year 1990, the concentration\nlevels for each region would change very little and the\nconclusions reached remain basically the same.\n- Second, because the concentration levels are projected through\nmodeling techniques marginal changes in the concentration levels,\nwhether increases or decreases, are often within the range of\nstatistical error.\n- Third, the estimates of total auto pollution emitted are based\non historical growth rates for vehicle miles traveled and auto\nfuel economy. No compensation has been assumed for the higher\ncost of gasoline and the higher price of standard automobiles -\nboth of which have already affected total pollutants through\nreductions in vehicle miles traveled and through changes in the\nmix of new cars on the road in favor of smaller cars which emit\nless pollutants per mile. The auto-caused ambient pollution\nlevels are therefore likely to be overstated in 1981 - 1985.\nhydrocarbons\nOut of the thirty regions considered to have an HC problem,\ntwenty are projected to exceed the ambient standard in 1985,\nregardless of the automobile emission level chosen. More\nimportantly, all of the regions projected to have concentration\nlevels below the ambient standard in 1985 at the statutory\nvehicle limitation level are also projected to be below the\nambient standard if any of the other less stringent automobile\nemission standards shown is chosen instead.\nOnly 25 percent of total hydrocarbon emissions are generated by\nautomobile exhaust. Therefore, hydrocarbon ambient air concen-\ntrations tend to be much less sensitive than carbon monoxide to\nthe level of vehicle emission control.\nAttachment 1 shows the limited differential impact that\nvehicle hydrocarbon limitations more stringent than the 1975\n(Interim) standard would have on ambient air quality by 1985 in\nthose areas considered to have a hydrocarbon problem. The\nmeasure of air quality is photochemical oxidants to which hydro-\ncarbons are converted and in which form HC most adversely affects\nair quality.\nCarbon Monoxide\nCarbon monoxide levels in the atmosphere are much more sensitive\nto changes in automobile emission controls than either HC or NOX.\nUnlike those pollutants, the growth of stationary sources over\nthe next ten years will have little effect on CO air quality.\nAttachment 2 shows 1985 projected concentration levels for twenty-\nsix problem regions for each of the alternatives presented. The\nmost important conclusion is that air quality is improving rapidly\nand will continue to improve until 1985 under all of the emission\ncontrol options presented. This is because older uncontrolled\ncars are being replaced by newer controlled cars. The asterisked\nregions are those which would still exceed the ambient standard if\nan automobile CO standard were adopted that was less stringent than\neither the statutory standard or the one proposed in the Energy\nIndependence Act.\nFirst, there is only a limited difference in ambient concen-\ntration levels for all of the standards presented, but the\ndifference is particularly small when comparing the statutory\nstandard (3.4 grams/mile) with either the Energy Independence\nAct proposal (9.0 grams/mile), EPA's recommended standard (15\ngrams/mile until 1979 and 9.0 grams/mile from 1979 to 1981),\nor the current standard (15 grams/mile) extended until 1981.\nBy 1985, the average ambient levels for this pollutant will\nhave been reduced about 70 percent below 1970 levels regard-\nless of which option is chosen.\nSecond, the choice of option will not significantly affect any\nsingle area's ability to achieve or maintain the ambient standard\nby 1985. When comparing all the alternatives (except the 1974\nor Canadian Standards), those areas below the ambient standard\nin 1985 will be below it regardless of the automobile emission\nstandard chosen, with the sole exception of Denver. The adoption\nof the Canadian Standard would mean that only two additional areas\n(Portland, Oregon and Puget Sound) would still be above the\nambient standard in 1985 by a marginal amount.\nNitrogen Oxides\nFederal Government and independent scientists predict that a\nsteady increase in ambient nitrogen dioxide concentrations will\noccur in metropolitan areas over the next ten years regardless\nof the auto emission limit chosen. This is because stationary\nsources emit most NOX pollution and the technology for control-\nling stationary sources is very limited. Attachment 3 (B) shows\nthe average percentage increases in NO2 ambient concentration\nlevels that will occur for each of the auto emission alternatives\nstudied (3.1, 2.0 and 0.4 grams/mile) under varying assumptions\nabout the auto standard after 1981.\nWhen comparing the 2.0 and 3.1 auto emission alternatives, Chart\n3 (B) shows that as long as the 2.0 NOX standard were implemented\nafter 1981, no significant difference in the predicted increases\nof NO2 concentration levels would occur in either 1980 or 1985,\nas a result of maintaining the 3.1 grams/mile standard through\nthe 1981 model year (columns 2 and 3).\nThough the statutory standard would have a significant effect on\nthe overall predicted increase, the differential effect of a more\nstringent automobile standard than currently in force on the ambient\nconcentration levels in those areas with nitrogen dioxide problems\nis much less pronounced. This is shown in Attachment 3(A), which\ndisplays ambient projected concentration levels in the ten problem\nareas for 1985 under various automobile emission standards.\nWith the exception of San Francisco, by 1985 all ten regions are\npredicted to have concentration levels above the ambient standard\nif either the 3.1 or 2.0 grams per mile limitation is placed on\nautomobiles through the year 1990 (columns 1 and 3). San Francisco\nwould remain below the standard if the more stringent emission\nlimitation is adopted and, in fact, California has the more stringent\nlimitation in force as a State regulation.\nIt should also be noted that regardless of whether the 3.1 or\nthe 2.0 limitation is imposed through 1981, and even if the\nstatutory standard (.4) is imposed after 1981, only one addi-\ntional region (Phoenix) would be brought into compliance with\nthe ambient standard (columns 4 and 5). In fact, implementing\nthe statutory standard in 1978 would result in only two addi-\ntional areas (Phoenix and Baltimore) meeting the standard\n(column 6).\nIt is thus clear that the projected increases in nitrogen dioxide\ncannot be stopped without major technological innovations in\nstationary source control. Therefore, regardless of how stringent\nthe automobile standard, the future concentration levels in major\nmetropolitan areas will primarily be a function of stationary\nsource emissions.\n6\nhealth\n3. With present data expects generally agree that standards\nwhich are tighter or looser than those currently in force\nwould have minimal differentlal/impacts-especially for\nHC and CO. However, present data are not sufficient to\nmake specific calculations on final judgements on what\nsulfuric acid emission levels would be safe from a public\nperspective. It is only known that sulfuric acid emissions\ncould prove to be a significant public health risk and\nthat emissions could double if standards more stringent\nthan the 1975 interim standards are adopted.\n4. Further mandated reductions in emissions from internal\ncombustion engines may have the effect of increasing\nexisting pollutants or creating other pollutants.\nBased upon existing air quality data, there are no measurable\nhealth risks associated with the application of HC and CO\nemission standards (within the range of options presented)\nwhich are less stringent than those in the Energy Independence\nAct or the statutory standards.\nThe application of the 3.1 NOX level will not greatly increase\nhealth risks nationwide. With an ambient air quality standard\nof 100 ug/m3 health data suggests that the level at which people\nwould have an increased risk for excess respiratory disease is\n200 ug/m3. Los Angeles is the only area which is expected to\napproach the 200 ug/m3 level by 1985, and California has the\nlower 2.0 grams/mile level in effect as a State regulation.\nThough ambient carbon monoxide and hydrocarbon concentration\nlevels are not significantly affected by the range of automobile\nemmission standards presented, the concentrations of sulfuric\nacid are affected.\nGasoline contains sulfur which, after combustion, is released\nas sulfur dioxide. In the process of removing other pollutants\nthe catalytic converter changes some of the sulfur dioxide into\nsulfuric acid mist.\nCurrent estimates indicate that with existing automobile emmission\ntechnology, emission standards for hydrocarbons and carbon\nmonoxide of .9 and 9.0, will require the use of an air-injected\noxidation catalyst. This catalyst results in a doubling of\nsulfuric acid emissions. Though there are several catalytic\nand non-catalytic technologies which can potentially meet the\nstricter HC, CO and NOX emission limitation without significant\nsulfuric acid emissions, there is little production potential\nfor using these systems in the near term. (See discussion\nbelow\nWhile all scientists agree that sulfuric acid is a toxic and\npotentially dangerous pollutant, there is still disagreement on\nthe quantities of emissions needed to pose a health risk and on\nhow long it would take for the buildup in concentration levels\nto occur.\nMajor studies by government and industry have already begun in\norder to resolve some of these uncertainties. Much of the un-\nknown about sulfuric acid results from our current inability to\nprecisely measure how much sulfuric acid is being emitted by\nvehicles and our inability to precisely measure how much emitted\nsulfuric acid is being concentrated in the breathing zone.\nFORD\nGERALD\nLIBRARY\n7\nTo improve vehicle measurements, EPA is developing a new test\ndriving cycle which will more accurately reflect emission of\nsulfuric acid and is jointly working with private industries on\nthe relationship of catalysts and other control options to sulfuric\nacid. To improve our knowledge of the disposition of sulfuric\nacid once emitted into the air, EPA has instituted a long run\ntrend study on one major highway and has jointed with State\ngovernment agencies to measure roadside concentrations on other\nhighways as well. EPA is also working with the State agencies\nto determine the change in sulfuric acid emissions catalyst\nequipped vehicles age and accumulate mileage.\nUntil these and other studies are completed no final judgements\non the potential health impacts of sulfuric acid emissions can\nbe made. However, recent information presented in EPA's\n\"Estimated Public Health Impact as a Result of Equipping Light\nDuty Motor Vehicles With Oxidation Catalysts\" (January 30,\n1975) suggested the following estimates of the years in which\nsulfuric acid emission levels from automobiles could pose a\nserious threat to public health.\nModel Year 1/ in which\nSulfuric Acid could pose\na serious health problem\nAverage\nAdverse\nMeteorological\nMeteorological\nStandard\nConditions\nConditions 2/\n1975 Interim Standards\n1981\n1979\n1975 California Standards\nIn- 49 States\n1979\n1977\nIn California\n1978\n1977\nThe data assumes that there are no emissions of sulfates\nfrom stationary sources, and that 70 percent and 90 percent\nof the fleet in 1975 and 1976 respectively will utilize\ncatalysts.\nAdverse meteorological conditions would occur in large\nmetropolitan areas on an average, of 6-7 days a year.\nThe dates for reaching a critical problem are earlier in\nCalifornia than the remaining 49 States because California\nutilizes higher sulfur gasoline.\nIn interpreting the preceding table the following factors should\nbe noted. Data available to date do not take into account\n\"background\" emissions of sulfates from stationary sources, e.g.,\ncoal-fired generating plants. Therefore, the table represents\nonly the potential health effects of emissions from mobile\nsources. The extent to which sulfate emissions from stationary\nsources add to the potential health risk associated with sulfuric\nacid emissions from automobiles is not known at this time. How-\never, most health analyses treat stationary and mobile emissions of\nsulfates independently. This is primarily because (1) the particle\nsize of sulfates from stationary sources is much larger than\nsulfuric acid mist and is not absorbed as deeply into the\n8\nrespiratory system; (2) the toxicity of sulfate emissions\nfrom stationary sources is generally much less than sulfuric\nacid; and (3) emissions from stationary sources do not occur\nin the breathing zone as do automobile emissions.\nShort Term Actions-Available for Localized Sulfuric Acid Problems\nUnder certain adverse meteorological conditions localized\nsulfuric acid problems could occur. There are two short-term\nactions available to offset this possibility. While possibily 1\nfeasible, both have drawbacks,\n- Gasoline blending - catalyst equipped vehicles could be\nprovided with lead-free low-sulfur fuel. This would reduce\nemissions of sulfuric acid, but would impose an allocation\nproblem on the industry. Refiners have also indicated that\nsufficient quantities would not be available to meet wide-\nspread problems beyond 1977 or 1978.\n- Desulfurization of oil - technically possible at this time.\nDesulfurization would require substantial additional capital\ninvestment, at a time when refiners are attempting to expand\ndomestic capacity. It would also require an increase in crude\noil consumption due to additional refining. Increases in\nthe price of gasoline would occur. Nationwide, the capital\ncost of desulfurization would range between $2 and $4 billion,\ncrude oil consumption would increase .5 percent and the price\nof gasoline would increase by 1 to 2 cents per gallon.\nIt is generally agreed that reducing NOX emissions will result\nin an increase in the emissions of HC from engines. To reduce\nthat increment manufacturers may increase the use of the air-\ninjected oxidation catalyst -- even to meet the Federal Interim\nHC and CO standards. If this were the case, then nearly twice\nas much sulfuric acid would be generated as projected. At this\ntime it is not known definitely whether manufacturers could\nachieve reductions 'of the HC increment through the use of engine\nmodifications or modified catalyst equipment instead of the\nair-injected catalysts in 1977-78. However, if the HC and CO\nstandards are also lowered after model year 1978 there is a\nhigh probability that the air-injection catalyst would be re-\ntained throughout the entire period:\nThere are other anecdotal problems with the converters such as\npotential fire hazards, hydrogen sulfide emissions and the\ncreation of other potentially hazardous compounds, but none of\nthese has been proven a significant risk.\nMandated reductions in the automobile emission standard will\nalso narrow the choice of technological options to abate the\nthree regulated pollutants. For example, if a sulfuric acid\nstandard were set for model year 1979, implementation of the\nstatutory standards for HC, CO and NOX in 1978 would, in\nessence, dictate the use of either 2 \"dual\" or \"three-way\" catalyst\ntechnologies on most vehicles, While these catalysts have promise\nas abatement technologies they are still in the early stages of\ndevelopment and their premature implementation could possibily\nhave adverse health effects far in excess of the benefits of\nreducing HC, CO and NOX.\nBased on existing data, the dual catalyst system appears to be the\nmost promising technology for meeting the statutory emission\nstandards. However, its ability to limit sulfuric acid emissions\nto low concentrations, and thus meet a sulfuric acid, standard, is\nstill in question since an integral component of the dual catalyst\nsystem is an oxidation catalyst like those currently in use for\n1975 model vehicles. Sulfuric acid emissions would increase if,\nto meet the statutory HC and CO standards, an air-injected\noxidation catalyst were used.\nIf the statutory standards are in effect in 1978, along with a\nsulfuric acid standard in 1979, then it appears that the most\nlikely technology to be used is the three-way catalyst -- a single\nretrofit device that simultaneously abates HC, CO and NOX.\nHowever, to achieve these simultaneous reductions, extensive\nredesign and control of the carburetion system must be undertaken\nbecause the three-way catalyst must be operated at stoichiometric\n(no excess air) conditions. In fact, the permitted margin of error\nis so narrow (on the order of + 0.25 percent of the exact air to\nfuel ratio needed, as compared to normal production variations of\n+ 7 to 10 percent) that the use of an oxygen sensor and a feedback\nsystem are required to regulate the air mixture for either a\ncarburetor or fuel-injection process.\nWhen operating at the stoichiometric conditions, sulfate emissions\nwould be no greater than emissions from non-catalyst cars.\nHowever, if variations from that condition occur, severe adverse\nhealth effects may be generated. Three-way catalysts applied to\nexhausts from engines operated outside the carburetion design\nlimits (variations greater than + 0.25 percent from stoichiometric)\nhave a potential for emitting dangerous quantities of such toxic\npollutants as hydrogen sulfide, carbonly disulfide, carbon\ndisulfide and hydrogen cyanide.\nIt should be emphasized that only the most preliminary data exists\non the total emissions from three-way catalysts and no firm judgment\ncan be made on whether or not such emissions will occur in normal\nuse, or in what quantities they will occur. However, they must be\ntreated as potential risks until there is firm evidence that\ndemonstrates otherwise. The development of this technology has not\nprogressed to the stage where firm conclusions on their long run\nhealth impacts are possible.\nThe long run durability of this technology is also unproven at this\ntime and several more years of testing and development seem needed\nbefore full scale introduction of three-way catalysts should be\nundertaken regardless of the emission standard mandated.\nIt seems clear, that given the limited health benefits derived\nfrom instituting the statutory standards (see #2 above) and\ngiven the unknown but potentially adverse health effects of\nintroducing a technology which has not been thoroughly tested,\nthe wiser choice is to avoid forcing either of these catalyst\ntechnologies into mass production at this time.\n5. Auto emission standards have had an impact on fuel economy\nand, therefore, on our Nation's total petroleum demands\nand reliance on foreign sources.\nThe options presented will have differential fuel economy\nimpacts. A recent Columbia University study indicates that\nthe fuel economy penalty caused by reducing NOX will be even\nlarger than the one used in the table below.\nImpact on 40 percent fuel economy goal\nShortfall (-)\nor excess (+)\n% over\nover President's\n1974\ngoal\nAlternatives\nEnergy Independence Act\n40%\n---\nEPA Recommendation\n36%\n- 4%\n1975 Standards thru 1981\n46%\n+ 6%\nCanadian and 1974 Standards thru 1981\n40%\n+10%\nStatutory Standards after 1977\n30%\n-10%\nAlternatives*\nBarrels per day (in 1980)\nStatutory Standards after 1977\n208,000 (loss)\nEnergy Independence Act\n85,000 (loss)\nEPA Recommendation\n137,000 (loss)\n1975 Standards thru 1981\n0\nCanadian and 1974 Standards thru 1981\n27,000 (gain)\n*\nBase is 1975 model year automobiles meeting 1975 interim\nemission standards.\nEnergy implications for lowering NOX to 2.0 grams/mile\nIt is generally agreed that a reduction in the NOX emission\nlevels from 3.1 to 2.0 grams/mile will require a variety of\nengine modifications. It is estimaed that these modifications\nwill cause a fuel economy penalty of 3-4 percent on the average\nin 1980. If a 3 percent fuel penalty is assumed, an additional\nrequirement of 85,000 barrels of oil per day will occur nation-\nwide in 1980.\nThis estimated fuel penalty figure is the subject of debate,\nhowever, on two grounds. First, it has been argued that fuel\npenalties in 1980 assume that certain advanced engine tech-\nnologies will be introduced over the next five years. However,\nthese advanced technologies would not be available in the first\ntwo years. Therefore, at the year of introduction, initial fuel\npenalty resulting from lower NOX emission standards would be\nsubstantially greater. A range of between 5 and 7 percent,\ni.e., from 120,000 to 150,000 barrels per day is estimated,\nthe 2.0 grams/mile standard were adopted.\nif FORD LIBRARY\nThe second argument revolves around the very sensitive relation-\nship that exists between fuel economy and NOX emissions at more\nstringent NOX standards than currently required. For a given\nlevel of HC emissions a dramatic drop in fuel economy is required\nto meet a NOX standard below 2.0 grams/mile. Because of mass\nproductive variations, to ensure that emission standards are\nmet, manufacturers must design their emission systems well\nbelow the Federal standards -- about 23 percent lower. Thus,\nto meet a 3.1 gram/mile limitation, vehicles are designed to\nachieve 2.4 grams/mile and to achieve a 2.0 level, vehicles are\ndesigned to emit not more than 1.3 to 1.5 grams/mile. (To meet\nthe statutory .4 grams/mile vehicles would have to be designed\nto meet about .3 grams/mile.) Thus, designing vehicles to meet\neven the 2.0 standard places the fuel economy loss well within\nthe sensitive range at which fuel economy begins to drop most\nrapidly. Attachment 4 (A) illustrates the general relationship\nbetween fuel economy and NOX emissions for all spark ignition\nengines while 4 (B) shows the situation for a specific class\nof V-8. engines.\nEnergy implications of HC and CO standards tighter than\nthose currently in force.\nAssuming a 3.1 gram/mile NOX standard, a fuel economy penalty\nof 3 to 5 percent is associated with emission standards for\nhydrocarbons and carbon monoxide of .9 and 9.0 grams/mile when\ncompared to extending the current standards of 1.5 and 15\n(i.e., 85 barrels of oil per day in 1980). Retention of the\n1.5 (CO) and 15 (HC) levels until 1979 would avoid most of the\npenalty. Retention of the current standards through 1981 would\nallow continued fuel economy improvements as would the adoption\nof the Canadian standards.\nEnergy implications of the statutory standards for\nHC, CO, and NOX\nWith either the dual or 3-way catalyst, a single retrofit system\nis used to abate all three regulated pollutants. Thus, at the\nstatutory standards the energy impacts are not measured separately\nfor NOX and HC/CO. On the average, the adoption of the statutory\nstandard in 1978 would result in a fuel penalty of about 7% by\n1980 over 1975 vehicles. This would mean an energy loss of 208,000\nbarrels of oil per day in 1980.\nAttachment 5 shows the specific fuel economy losses (or gains)\nassociated with each of the options presented (and the antici-\npated costs) with respect to model year 1974.\nStandards tighter than the 1975 interim will result in\nhigher initial car costs and higher operating cost due\nto associated fuel penalties.\nThe options presented will impose varying cost burdens on the\nconsumer. Also, separate costs are associated with actions\non NOX and actions on HC and CO, except for meeting the statu-\ntory standards with a dual or 3-way catalyst system.\nNOX:\nConsumers will face sticker price and operating cost increases\nover the 1975 model vehicles if a 2.0 gram/mile limitation is\nimposed. Estimates range from $10-25 for front-end costs per\nvehicle and from $0-25 in operating costs over 50,000 miles. In\naddition, the consumers will pay the costs of increased fuel\nconsumption associated with this lower standard, which rough\nestimates place at $1.7 million per day, or over 600 million\ndollars per year.\nHC and CO:\nThe costs of adopting the more stringent hydrocarbon and carbon\nmonoxide standards (.9 and 9.0) as proposed in the Energy\nIndependence Act is estimated to be $50 per vehicle over 1975\nautomobiles. This would represent the additional costs of using\nthe air-injected oxidation catalyst. Additional operating\ncosts which would result from the increased consumption of gaso-\nline that maintaining this option implies are estimated at $1.7\nmillion per day, or over 600 million dollars per year.\nAdoption of the statutory standards would result in a sticker\nprice increase of $230 to $270 per vehicle over 1975 model cars.\nThis would represent the average costs of using a mix of the\ndual DE 3-way catalyst systems, Operating costs resulting from\nthe associated fuel penalties of this alternative would roughly\nbe $4 million per day or over $1.5 billion per year.\n6. The basic philosophy and approach to future auto emission\ncontrols needs to be reconsidered in light of current\nconditions.\nWhile the choice of emission standards must represent a balance\namong public health, air quality, esthetic, energy and cost\nconsiderations, the problems currently confronting the Nation\nare different from those prevailing in 1970 when the Clean Air\nAct was passed. Inflation, unemployment, and the added cost and\nreduced availability of energy call for reassessment of the\nrelative weights accorded to various factors other than measures\nnecessary to health. The high cost and fuel penalties caused by\nfurther tightening of the standards; and the emergence of the\nsulfuric acid problem, compared to the marginal improvement in\nne, CO and NOX air quality also call for careful reconsideration.\n(a) Significantly tighter standards at this time may\npreclude continued development of some technologies.\nThere is substantial evidence that by model year 19 1 new\n\"lean-burn\" or \"stratified charge\" engines would permit meeting\nthe lower (2.0) NOX standard. However, standards more stringent\nthan 2.0 would preclude introduction of those technologies. In\nfact, unless application of the current statutory NOX standard\n(.4 grams/mile) is delayed through at least 1990, the industry\nwill not (and cannot) shift to a lean-burn or stratified charge\nengine, as far as can be foreseen.\n(b) Actions to reduce auto emissions must take into\naccount other sources of the same pollutant.\nOnly 25 percent of total HC emissions are generated by auto-\nmobiles. Therefore, HC ambient air concentrations tend to be\nmuch less sensitive to the level of vehicle emission control\nthan is carbon monoxide.\nThe projected increases in NOX cannot be stopped without major\ntechnological innovations in stationary source control. There-\nfore, regardless of how stringent an automobile standard is\napplied, the future concentration levels in major metropolitan\nareas will primarily be a function of stationary source emissions.\nCO levels in the atmosphere are much more sensitive to changes\nin automobile emission controls than either HC or NOX. Unlike\nthose pollutants, the growth of stationary sources over the\nnext ten years all have little effect onnCO air quality.\n7. Prompt congressional action is needed on auto emission\nstandards.\nIn order to meet deadlines for emission testing and certification\nof 1977 model cars, the automobile industry will need to know\n1977 emission standards by. early August so that there will be\ntime to complete designing and engineering, build prototypes,\ncomplete emissions testing such as 50,000 endurance tests, and\nfinally to produce new cars in adequate' quantity to meet the\ndemand from the American public.\nAttachment 1\nPredicted Ambient Oxidant Concentration Levels in 1985\n(In parts per million)\nAmbient Standard = .08 ppm*\nHC Automobile Emission Standard\n1974 and\nCurrent\nEPA's\nEnergy\nCanadian\nStds\nRecom-\nIndepend-\nStatutory\nStandards\nthrough\nmended\nence Act\nStds\nBase\nRegion\nthrough 1981\n1981\nStds\nProposal\n1977-1990\n1971-73\nBirmingham\n.12\n.12\n.11\n.11\n.11\n.22\nMobile-Pensacola\n.04\n.04\n.04\n.04\n.04\n.11\nClark-Monave\n.13\n.12\n.12\n.12\n.12\n.22\nPnoenix-Tucson\n.16\n.16\n.16\n.16\n.16\n.19\nLos Angeles\n.43\n.42\n.42\n.41\n.41\n.62\nSacramento Valley\n.21\n.20\n.20\n.20\n.20\n.24\nSan Diego\n.20\n.20\n.20\n.19\n.19\n.30\nSan Francisco\n.23\n.23\n.23\n.23\n.23\n.30\nSan Joaquin\n.22\n.21\n.21\n.21\n.21\n.26\nS.E. Desert\n.32\n.32\n.32\n.32\n.32\n.28\nDenver\n.17\n.16\n.16\n.16\n.16\n.28\nNY-NJ-Conn.\n.14\n.13\n.13\n.13\n.13\n.26\nPhiladelphia\n.10\n.10\n.10\n.10\n.10\n.20\nNational Capital\n.26\n.26\n.25\n.25\n.25\n.38\nCincinnati\n.12\n.11\n.11\n.11\n.11\n.17\nIndianapolis\n.08\n.08\n.08\n.08\n.08\n.14\nS. Lou.-S.E. Texas\n.20\n.20\n.19\n.19\n.19\n.32\nBoston\n.11\n.10\n.10\n.10\n.10\n.21\nToledo\n.07\n.07\n.07\n.07\n.07\n.14\nE1 Paso-Las Cruces\n.06\n.06\n.05\n.05\n.05\n.13\nGenessee-Finger\n6\nLakes\n.08\n.08\n.08\n.08\n.07\n.15\nDayton\n.13\n.12\n.12\n.12\n.12\n.18\nPortland, Oregon\n.08\n.08\n.08\n.08\n.08\n.14\nS.W. Penn.\n.12\n.12\n.11\n.11\n.11\n.21\nAustin-Waco\n.07\n.07\n.07\n.07\n.07\n.16\nCorpus-Christi\n.14\n.14\n.14\n.14\n.14\n.19\nDallas-Ft. Worth\n.05\n.05\n.05\n.05\n.04\n.13\nHouston-Galveston\n.27\n.27\n.27\n.27\n.26\n.32\nSan Antonio\n.0,7\n.07\n.07\n.07\n.06\n.15\nPuget Sound\n.08\n.08\n.08\n.08\n.08\n.16\n* The projected concentration levels assume the continuance of historic grwoth rates in the\ncentral business districts in each region.\nAttachment 2\nPredicted Ambient Carbon Monoxide Concentration Levels in 1985\n(In parts per million)\nAmbient standard = 9 ppm\nCO Automobile Emission Standard\n1974 and\nCurrent\nEPA's\nEnergy\nCanadian\nStds\nRecom-\nIndepend-\nStatutory\nI\nStandards\nthrough\nmended\nence Act\nStds\nBase\nRegion\nthrough 1981\n1981\nStds\nProposal\n1977-1990\n1971-73\n3irmingham\n6\n5\n5\n5\n4\n18\nNorth Alaska\n11\n11\n11\n11\n11\n35\nClark-Mohave\n6\n6\n5\n5\n5\n15\nPnoenix-Tucson\n16\n14\n14\n13\n12\n42\nLos Angeles\n13\n12\n11\n11\n10\n41\nSacramento Valley\n7\n6\n6\n6\n5\n22\nSan Diego\n5\n5\n5\n5\n4\n15\nsan Francisco\n6\n6\n6\n6\n6\n18\nSan Joaquin\n4\n3\n3\n3\n3\n13\nDenver*\n11\n11\n9\n9\n8\n33\nHartford-New\nHaven\n9\n9\n7\n7\n7\n27\nNY-NJ-Conn.\n15\n13\n13\n13\n11\n51\nPhiladelphia\n9\n8\n8\n8\n8\n32\nNational Capital\n7\n6\n6\n6\n6\n20\nE. Washington-\nX. Idano\n7\n7\n6\n6\n6\n18\nCnicago\n7\n6\n6\n5\n5\n23\nIndianapolis\n5\n4\n4\n4\n4\n15\nKansas City\n6\n5\n5\n5\n4\n15\nBaltimore\n7\n7\n7\n7\n6\n18\nBoston\n6\n5\n5\n5\n4\n18\nMinneapolis-\nSt. Paul\n9\n8\n8\n7\n7\n22\nCentral New York\n5\n4\n4\n4\n4\n15\nPortland, Oregon**\n10\n8\n8\n8\n7\n26\nS.W. Penn.\n7\n6\n6\n6\n5\n22\nWasaton Front\n15\n13\n13\n13\n11\n41\nPuget Sound**\n10\n8\n8\n8\n7\n24\n*Would not meet the ambient standard in 1985 if the Current Interim, 1974 or Canadian CO\nstandard for venicles were adopted through 1981\n**Would neet the ambient standard under all options except the 1974 or Canadian vehicle\n00 seardard\nAttachment 3\nChart A displays ambient concentration levels in 1985 for NO2 in the ten problem regions\nunder various NOX auto-emission standards. For example, column 1 shows that if a 3.0\ngr/mile auto-NOX standard were in force from 1977 to 1990, Philadelphia's ambient NO2\nconcentration levels in 1985 are predicted to be 121 ug/m³. Column 5 shows that if an\nNOX standard of 2.0 gr/mile were adopted for the 1977-1981 period, followed by the\nstatutory (.4) standard until 1990, then Philadelphia's ambient NO2 level in 1985 is\npredicted to be 113 ug/m³.\nChart B shows the average percentage increases in NO2 concentration levels for all ten\nregions for each alternative NOX level. For example, column 2 shows that if the NOX\nemission level were 3.1 gr/mile from 1977-1981 and 2.0 gr/mile from 1982-1990, the\nNO2 concentration levels are predicted to increase by 16% in 1980 and by 26% in 1985.\nColumn 3 shows that if the NOX standard were 2.0 from 1977 to 1990, NO2 levels are pre-\ndicted to increase by 12% and 22% in 1980 and 1985 respectively.\nA. Predicted Ambient Nitrogen Dioxide Concentrations in 1985\n(In micrograms per cubic meter)\nAmbient standard is 100 micrograms per cubic meter*\n(NOX Emission Standard (in grams per mile)\nEffective Date of Standard\n(1)\n(2)\n(3)\n(4)\n(5)\n(6)\n1977-1981\n3.1\n3.1\n2.0\n3.1\n2.0\n0.4(1978\n1982-1990\n3.1\n2.0\n2.0\n.4\n.4\n0.4\nRegion\nPhoenix\n111\n105\n100\n98\n93\n87\nLos Angeles\n194\n183\n173\n167\n157\n145\nSan Francisco\n102\n96\n92\n89\n83\n77\nDenver\n135\n129\n125\n123\n117\n112\nNY-NJ-Conn.\n144\n139\n136\n132\n129\n124\nPniladelphia\n121\n119\n117\n115\n113\n109\nNational Capital\n116\n111\n107\n105\n101\n96\nChicago\n152\n148\n145\n143\n139\n134\nBaltimore\n116\n112\n109\n107\n103\n99\nWasaten Front\n137\n131\n124\n121\n115\n108\nB. Increases in Concentration Levels in 1980 and 1985\nAverage per-\n1980\n16\n16\n12\n16\n12\n6\ncent increase\nin air quality\n1985\n32\n26\n22\n19\n14\n8\nconcent rations\nprojected concentration levels assume the continuance of historic growth rates for\nthe central business districts in each region\nAttachment 4A\nMAXIMUM FUEL ECONOMY POTENTIAL VERSUS EMISSIONS\nFOR 1980 ENGINES UNDER OPTIMAL CONTROL\nCURRENT\nMPG\n*\nAVERAGE ENGINE\nHC\nDECREASING\nHYDROCARBONS\nKNEE\nFUEL\nECONOMY\nMPG\n#\n- DENOTES OPTIMUM\nFUEL ECONOMY POINT\nFOR ANY ENGINE\nNO:\nX\nOXIDES OF NITROGEN - NO X\nNOTE: 1. CURVE SHAPES ARE REPRESENTATIVE OF MOST ALL\nSPARK IGNITION ENGINES.\n2. STATUTORY NOₓ STANDARD IS BELOW THE \"KNEE\"\nFOR ALL ENGINES CAPABLE OF LARGE SCALE PRO-\nDUCTION THROUGH THE MID 1980's'\n3. THE OPTIMUM-MPG* AND RESULTING NO AND HC\nARE SIGNIFICANTLY GREATER THAN THE ENGINE\nOUT PERFORMANCE OF 1975 CARS.\nFORD LIBRARY is GERALD\nAttachment 4B\nFUEL-ECONOMY-NOX EMISSION TRADE OFF\nMiles/Gallon\nDesign standard\non automobiles\n14\nfor a perfor-\nmance standard\nof 3.1 gr/mile.\n2.0\n13\nDesign standards\non automobiles\nfor a perfor-\nmance standard\nof 2.0 gr/mile.\n1.4\n12\n1.25\n11\n1.1 Hc Gr/Mile\n10\n9\n0\n1\n1.4\n2\n2.4\n3\n4\nNOx Gr/Mile\nAttachment 5\nLIBRARY\nFORD\n1980 New Car Fuel Economy and Cost\nVersus Emission Standards\nCost Per New Car\nNew Car Average Fuel Economy\nFor Emission Controls\nin 1980\nEmission Standards\nCompared to 1974 Cars\nUncertainty Range in %\nFor 1977-1981\nOver 1974 Due to\n% Over\nEngine\nCost\nUncertainty\nMPG\n1974\nTechnology\nSales Mix\n1. Statutory Standards after 1977\n(three-way catalyst or\ndual catalyst)\n$350\n$215-$450\n18.0\n30%\n-4% to + 8%\n-4% to +7%\n2. Bast - /15/2.0 or\n19/9.0/3.1\nWith Catalysts\n120\n$ 90-$150\n19.6\n40%\n-3% to + 3%\nNo Catalysts\n50\n$ 40-$100\n18.4\n31%\n-4% to + 8%\n-4% to +7%\n3. EPA Proposal\n-\nWith Catalysts\n135\n$100-$170\n19.0\n36%\n-5% to + 8%\nNo Catalysts\n65\n$ 50-$110\n17.8\n27%\n-4% to +12%\n-4% to +7%\n4. 1975 Standards\nWith Catalysts\n95\n$ 70-$110\n20.4\n46%\n-2% to + 2%\nNo Catalysts\n35\n$ 25-$ 65\n19.2\n37%\n-3% to + 7%\n-4% to +7%\n5. Canadian or 1974 Standards\nWith or Without\nCatalysts\n25\n$ 5-$ 35\n20.8\n50%\n-2% to + 1%\n-4% to +7%\nQUESTION AND ANSWERS\nAn Amendment to Title V of the Proposed\nEnergy Independence Act of 1975\n1. What did the President announce today?\nThe President announced that he was proposing that\nthe Congress change existing law with respect to\nauto emission standards so as to continue existing\n1975 standards through the model year for 1981.\nThese standards require emission levels not greater\nthan:\nHydrocarbons\nCarbon Monoxide\nNitrogen Oxide\n(Grams/Mile)\n1.5\n15.0\n3.1\n2. What are hydrocarbons, carbon monoxide, and nitrogen\noxides?\nHydrocarbons (HC) are\nHigh levels of HC emissions can result in\nCarbon monoxide (CO) is\nHigh levels of CO emissions can result in\nNitrogen oxides (NOX) are\nHigh levels of NOX emissions can result in\n3. How do HC, CO and NOX relate to EPA's \"Ambient Air\nQuality Standards\"?\nUnder the Clean Air Act of 197 , the Environmental\nProtection Agency (EPA) is required to promulgate\nthese standards prescribing the amount of HC, CO \"and NOX in\nsuch air by 19 and 19 While most of the CO in the\nair is the result of auto emissions, only 25% of HC and\n& of NOX that is emitted comes from automobiles.\nAccordingly, although the Clean Air Act of 1970 prescribes\nthe amounts of HC, CO and NOX that automobiles are\npermitted to emit in various years, there is no assurance,\nwithout comparable control on stationary sources, that the\nambient air standards for HC and NOX can be met.\n4. Isn't the President changing a recommendation he made\nsix months ago?\nYes. On January , 1975, the President proposed emission\nlevels throughout the model year for 1981 not greater than\nHydrocarbons\nCarbon Monoxide\nNitrogen Oxide\n(Grams/Mile)\n.9\n9.0\n3.1\nWithout any change, existing law wou-ld require\n1977\n1.5\n15.0\n2.0\n1978-1981\n.41\n3.4\n.4\nIn January the President emphasized that a change was\nnecessary in existing law because\n5. Why has the President modified his January proposals\nfor changes in the requirements?\nThe President has modified his January proposals because\nof increasing concern with the problem of sulfuric acid\nemission. Changes in catalytic convertors required to meet the\nstandards the President proposed in January have now been\nfound to result in doubling the current emission rate of\nsulfuric acid. While the precise effect of such increased\nsulfuric acid emissions is not yet known, health\nauthorities are agreed that such emissions can cause\na very serious danger to\nPending the receipt of detailed information concerning\nthe sulfuric emission problem, the President decided not\nto increase sulfulic acid emission levels.\n6. Won't the change the President has proposed prevent\ncommunities from meeting EPA's ambient air quality\nstandards?\nGenerally speaking, the changes the President has proposed\nwill have very little effect on the ability of\ncommunities to meet EPA's ambient air quality air\nstandards.\n(insert detail)\n7. Isn't it possible to develop a catalytic convertor\nwhich does not increase sulfuric acid emissions or change the\nsulfur content in the gasoline burned?\n(State the problem of 3-way catalyst)\nState problem with gasoline blending and\ndesulfurization of oil.\n8.\nDidn't the National Academy of Sciences issue a report\nurging retention of the statutory standards in stating\nthat the sulfuric acid emissions were not a problem?\nThe National Academy of Sciences\n...\nHowever, the Academy report\n...\n9. Would the President's proposal have any effect on\nconsumer costs or energy conservation?\nYes ...\n10. How much have the current 1975 auto emission standards\nreduced pollutants from 1968, uncontrolled levels?"
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