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The original documents are located in Box 4, folder "Auto Emissions (7)" of the James M.
Cannon Files at the Gerald R. Ford Presidential Library.
Copyright Notice
The copyright law of the United States (Title 17, United States Code) governs the making of
photocopies or other reproductions of copyrighted material. Gerald Ford donated to the United
States of America his copyrights in all of his unpublished writings in National Archives collections.
Works prepared by U.S. Government employees as part of their official duties are in the public
domain. The copyrights to materials written by other individuals or organizations are presumed to
remain with them. If you think any of the information displayed in the PDF is subject to a valid
copyright claim, please contact the Gerald R. Ford Presidential Library.
[Aug 1975]
TA
GERALD R. LIBRARY FORD
1818
Digitized from Box 4 of the James M. Cannon Files at the Gerald R. Ford Presidential Library
TAB 1
CHRONOLOGY OF AUTOMOBILE EMISSION LEVELS
The statutory standards for automobiles have become
progressively more stringent since 1968. Whereas ambient
standards are established by the Administrator of EPA
as a regulatory action, automobile emission standards are
set statutorily in the Clean Air Act. The following table
shows the emission standards by model year. The
Administration has made two legislative recommendations
to relax the statutory standards. These are footnoted
below:
Model Year
Automobile Emission Standard
United States (Clean Air
(grams/mile)
Act)
HC
CO
NOX
Uncontrolled
8.7
87
3.5
1970
4.1
34
No standard
1972
3.0
28
No standard
1973-1974 1/
3.0
28
3.1
1975-1976 2/
1.5
15
3.1
1977 3/
1.5
15
2.0
1978
State of California (State law)
1975
.9
9.0
2.0
1/
In December 1973, the Administration proposed a three
year freeze of the standards at the 1975 interim levels.
The Congress adopted this proposal for two years
(1975 and 1976.)
2/
The Administration, in the Energy Independence Act of
1975, proposed adopting the standards for HC and CO
currently in force in the State of California, but
proposed keeping the NOX standard frozen at their
present levels through 1981.
FORD LIBRARY
2
3/ After public hearings, Administrator Train, as a
regulatory action, has retained the current HC and
CO standard through model year 1977. He had no
regulatory responsibility over NOX, however, and
therefore, the lower NOX level reflects current law.
At the same time, EPA made its recommendation for the
next five years. This recommendation is Option 2.
TAB
2
TAB 2
AIR QUALITY IMPACTS DUE TO LESS STRINGENT
AUTOMOBILE STANDARDS
The following tables show the direction and magnitude of
change in ambient concentration levels for CO, HC and NOX
which would result from adopting standards which are less
stringent than those proposed in the Energy Independence
Act. Two additional 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. Secondly, because the
concentration levels are projected through modeling techniques
marginal changes in the concentration levels, whether increases
or decreases, are often within the margin of statistical
error.
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 all have little
effect on CO air quality. The following table shows 1985
projected concentration levels for twenty-six regions for
each of the options presented. The most important conclusion
is that older uncontrolled cars are being replaced by newer
controlled cars and therefore, air quality is improving
rapidly and will continue to improve until 1985 under all
of the emission control options presented. The under-
lined regions are those which would exceed the ambient
standard if a CO standard less stringent than proposed
in the Energy Independence Act were adopted.
2
Predicted Ambient CO Concentration Levels
1985
(9 ppm = ambient standard)
CO Automobile Emission Standard*
(in PPM
1974 and
EPA
Canadian Stds
Current Stds
Recommended
President's
Region
through 1981
through 1981
Standards
Proposal
Birmingham
6
5
5
5
North Alaska
11
11
11
11
Clark-Mohave
6
6
5
5
Phoenix-Tucson
16
14
14
13
Los Angeles
13
12
11
11
Sacramento Valley
7
6
6
6
San Diego
5
5
5
5
San Francisco
6
6
6
6
San Joaquin
4
3
3
3
Denver
11
11
9
9
Hartford-New
Haven
9
9
7
7
NY-NJ-Connecticut
15
13
13
13
Philadelphia
9
8
8
8
National Capitol
7
6
6
6
E. Washington
7
7
6
6
N. Idaho
Chicago
7
6
6
5
Indianapolis
5
4
4
4
Kansas City
6
5
5
5
Baltimore
7
7
7
7
Boston
6
5
5
5
Minneapolis-St.
Paul
9
8
8
7
Central New York
5
4
4
4
Portland
10
8
8
8
S.W. Penn.
7
6
6
6
Wasatch Front
15
13
13
13
Puget Sound
10
8
8
8
*
Assumes statutory standards are in force after 1981 model year.
3
The chart reveals several observations. First, there is
only a limited difference in ambient concentration levels
at any of the standards represented, but the difference is
particularly small when comparing either the President's
proposed vehicle standard (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. In fact by 1985, the average ambient
levels for this pollutant will have been reduced about
70 percent over 1970 levels with all five options.
Secondly, the choice of option will not significantly
affect any single area's ability to achieve or maintain
the standard by 1985. When comparing the President's
proposed standard for carbon monoxide with EPA's recommended
standard or with the current standard extended through 1981,
with the sole exception of Denver, those areas below the
ambient standard in 1985 will be below it regardless of
the automobile emission standard chosen. The adoption of
the Canadian standard would mean that two additional areas
(Portland and Puget Sound) would violate the ambient
standard by 1985, but only by a marginal amount.
Hydrocarbons
Only 25 percent of total hydrocarbon emissions are generated
by automobiles. Therefore, hydrocarbon ambient air concen-
trations tend to be much less sensitive than carbon monoxide
to the level of vehicle emission control.
The following chart displays the limited differential impact
that more stringent vehicle hydrocarbon standards would have
on ambient air quality by 1985 in those areas considered
to have a hydrocarbon problem.
(Table appears on following page.)
The conclusions are essentially the same for hydrocarbons
as they are for carbon monoxide. All of the twenty regions
that are projected to exceed the ambient standard in 1985
will be above the standard regardless of the automobile
emission level chosen. Conversely, all of the regions
projected to have concentration levels below the ambient
standard in 1985 at the stricter vehicle limitation are
also projected to be below the ambient standard if any of
the older automobile emission standards shown is chosen instead.
4
Predicted Ambient Oxidant Concentration Levels
1985
(Ambient Standard - .08 ppm) *
HC Automobile Emission Standard
(in grams/mile)
Current Stds
EPA
Canadian Stds
Extended thru
Recommended
President's
Region
through 1981
1981
Standards
Proposal
Birmingham
.12
.12
.11
.11
Mobile-Pensacola
.04
.04
.04
.04
Clark-Mohave
.13
.12
.12
.12
Phoenix-Tucson
.16
.16
.16
.16
Los Angeles
.43
.42
.42
.41
Sacramento
Valley
.21
.20
.20
.20
San Diego
.20
.20
.20
.19
San Francisco
.23
.23
.23
.23
San Joaquin
.22
.21
.21
.21
S.E. Desert
.32
.32
.32
.32
Denver
.17
.16
.16
.16
NY-NJ-Conn.
.14
.13
.13
.13
Philadelphia
.10
.10
.10
.10
National Capitol
.26
.26
.25
.25
Cincinnati
.12
.11
.12
.11
Indianapolis
.08
.08
.08
.08
S. Lou.-S.E. Tex.
.20
.20
.19
.19
Boston
.11
.10
.10
.10
Toledo
.07
.07
.07
.07
El Paso-Las
Cruces
.06
.06
.05
.05
Genessee- Finger
Lakes
.08
.08
.08
.08
Dayton
.13
.12
.12
.12
Portland
.08
.08
.08
.08
S.W. Penn.
.12
.12
.11
.11
Austin-Waco
.07
.07
.07
.07
Corpus-Christi
.14
.14
.14
.14
Dallas-Ft.Worth
.05
.05
.05
.05
Houston-Galveston
.27
.27
.27
.27
San Antonio
.07
.07
.07
.07
Puget Sound
.08
.08
.08
.08
*The projected concentration levels assume the continuance of historic
growth rates for the central business districts in each region.
5
Nitrogen Oxides
Federal Government and independent scientists have all
predicted that a steady increase in ambient nitrogen dioxide
concentrations will occur in metropolitan areas over the next
ten years. Because controls on existing stationary sources
are very limited, the EPA feels that a more stringent auto-
mobile standard will reduce that rate of increase. At the
3.1 grams/mile automobile emission limitation, a 32 percent
average increase in air quality concentration is anticipated
by 1985, compared to a 22 percent increase if the 2.0 grams/
mile limitation were adopted.
Though the more stringent standard would have a significant
effect on the overall predicted increase, the differential
effect of the more stringent automobile standard on the
actual concentration levels in those areas with nitrogen
dioxide problems, is much less pronounced. This is shown
in the following table which displays actual projected
concentration levels in the ten problem areas for 1980
and 1985 and for both automobile emission standards.
Projected NOx Air Quality Concentrations
(Ambient standard is 100 ug/m³)
NOx Automobile Standard
(in grams/mile)
1980
1985
Region*
3.1 g/m
2.0 g/m
3.1 g/m
2.0 g/m
Phoenix
97
92
111
100
Los Angeles
173
163
194
173
San Francisco
93
88
102
92
Denver
119
115
135
125
NY/NJ/Conn
124
125
144
136
Philadelphia
107
104
121
117
National Capital
104
100
116
107
Chicago
133
129
152
145
Baltimore
99
96
116
109
Wasatch Front
121
116
137
124
* Projected concentration levels assume the continuance of historic
growth rates for central business districts in each region.
LIBRARY
6
By 1980, seven of the ten potential problem regions will
exceed the ambient air quality standard if the 3.1 grams/
mile automobile emission standard is maintained. All of
those seven regions, however, would exceed the ambient
standard even if the 2.0 grams/mile automobile emission
level were adopted. In addition, the three potential
problem regions which have projected concentration levels
below the ambient standard at the 2.0 grams/mile vehicle
limitation also will not exceed the ambient standard at
3.1 grams/mile.
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/mile limitation is
placed on automobiles. San Francisco would remain below the
standard if the more stringent emission limitation is
adopted and, in fact, California currently has the more
stringent limitation in force as a State regulation.
Two additional aspects of the above analysis should be noted.
First, the projected air quality data for the ten regions
assumes that the historic growth rates of industrial develop-
ment and vehicle miles traveled in each metropolitan area
will continue through 1985. No consideration, for example,
was given for possible reductions in future vehicle miles
traveled (and, therefore, reductions in pollutant emissions)
which result from higher gasoline prices.
Secondly, the projected increases in nitrogen dioxide cannot
be stopped without major technological innovations in
stationary source control. Therefore, 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. As
a result, EPA's desire for a more stringent vehicle standard
essentially reflects concern with total ambient concentration
levels and does not address the relative degree of control
exercised over stationary and mobile sources.
TAB
3
TAB 3
HEALTH IMPACTS OF SULFURIC ACID EMISSIONS
FROM AUTOMOBILES
Though ambient carbon monoxide and concentration levels
are not significantly affected by the range of automobile
emission 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.
The catalyst emission system generally used to meet the
1975 interim standards produces less sulfuric acid than the
system needed to meet more stringent emission standards.
Current estimates indicate that with existing automobile
emission technology, the President's proposed emission
standard for hydrocarbons and carbon monoxide (.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 non-catalytic technologies which
can meet the stricter emission limitations and which do not
produce sulfuric acid there is little production potential
for using these non-catalytic systems before the 1981 model
year.
While all scientists agree that sulfuric acid is a toxic
and potentially dangerous pollutant, there is still dis-
agreement on the quantities of emissions needed to pose
a health risk and on how long it would take for the
build-up in concentration levels to occur. Because new
data is currently under review and the state of knowledge
is in flux, specific calculations or final judgments on
sulfuric acid emission levels or the air quality or health
impacts of the options presented cannot be made.
The following table therefore represents our best estimates
of the years in which the sulfuric acid emission levels from
automobiles could pose a serious threat to public health.
2
Model Year 1/ in which Sulfuric Acid
could pose a serious health problem
Average Meteorological Adverse Meteorological
Standard
Conditions
Conditions 2/
1975 Interim Standards
1981
1979
1975 California Standards
In 49 States
1979
1977
In California 3/
1978
1977
1/ 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.
2/ Adverse meteorological conditions would occur in large metropolitan
areas on an average of 6-7 days a year.
3/ The dates for reaching a critical problem are earlier in California
than the remaining 49 States because California utilizes higher
sulfur gasoline.
3
The potential health effect of sulfuric acid emissions from
automobiles is complicated by two additional factors.
First, data available to date do not take into account
"background" emissions of sulfates from stationary sources,
e.g., coal-fired generating plants. These data represent
only the potential health effects of emissions from mobile
sources. The extent to which sulfate emissions from station-
ary sources add to the potential health risk associated
with sulfuric acid emissions from automobiles is not known
at this time. However, most analyses are tending toward a
separation of the two pollutants from a health perspective.
This is primarily because the particle size of sulfates is
much larger than sulfuric acid mist and is not absorbed
as deeply into the respiratory system. Also the toxicity
of sulfate emissions from stationary sources is generally
much less than sulfuric acid and finally, emissions from
stationary sources do not occur in the breathing zone as
do automobile emissions.
It is generally agreed that reducing nitrogen oxide
emissions will result in an increase in emission of hydro-
carbons from engines. To reduce that increment, manu-
facturers may increase the use of the air-injected oxidation
catalyst -- even to meet the less stringent HC and CO
standards. If this were the case, then nearly twice as
much sulfuric acid would be generated as projected for
the table above. However, at this time it is not known
definitely whether manufacturers could achieve reductions
of the HC increment through the use of engine modifications
instead of the air-injected catalysts.
CAB
TAB
- 4
TAB 4.
ECONOMIC IMPACT OF AUTOMOBILE OPTIONS
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.
NOX
Consumers will face sticker price and operating cost increases
over the 1975 model vehicles if EPA's recommended 2.0 grams/mile
limitation is imposed. Estimates range from $10-25 for
front-end costs per vehicle and from $0-15 in operating
costs over 50,000 miles. However, not included are the
additional costs of increased fuel consumption associated
with this lower standard, which rough estimates place at
$1.7 million per day.
HC and CO
The costs of maintaining the more stringent hydrocarbon and
carbon monoxide standards (.9 and 9.0) as proposed by the
President 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. However, not included are estimates
of operating costs which would result from the increased
consumption of gasoline that maintaining this option
implies. Rough estimates place this cost at $1.7 million
per day.
G
TAB 5
ENERGY IMPACTS OF OPTIONS
The options presented will have differential fuel economy
impacts and therefore different impacts on manufacturers'
ability to meet the 40 percent fuel economy goal. EPA dis-
agrees with the fuel economy penalties here. The agency
firmly believes that there are no technological barriers
to reducing emission standards without a fuel penalty.
However, a recent Columbia University study supports an
even larger NOX penalty than the one used in this analysis.
A. Impact on 40 Percent Fuel Economy Goal
% Over
Shortfall (-)
1974
or excess (+)
Over President's
Options
Goal
Energy Independence Act
40%
EPA Propsoal
36%
- 4%
1975 Stds. thru 1981
46%
+ 6%
Canadian and 1974 Stds. thru 1981
50%
+10%
B. Energy Impacts*
Options
Barrels per day (in 1980)
Energy Independence Act
85,000 (loss)
EPA Proposal
137,000 (loss)
1975 Stds. thru 1981
0
Canadian and 1974 Stds. thru 1981
27,000 (gain)
*
Base is 1975 model year automobiles meeting 1975 interim
emission standards.
TAB 6
SUMMARY OF REPORTS ON AUTOMOBILE
EMISSION STANDARDS
Two noteworthy reports have been published which address an
entire range of automobile options and their impacts on air
quality, health, energy and costs.
National Academy of Sciences
At the request of the committee on Public Works, the National
Academy of Sciences submitted a report entitled "Air Quality
and Automobile Emission Control (August, 1973).
Air Quality
The NAS concluded that -
a. Federal ambient air quality standards for carbon monoxide
(CO) could be met by 1990 even with some relaxation of
the present automobile emission standards - but only if
heavy vehicle and stationary sources were reduced to the
same degree as emissions from automobiles.
b. The statutory emission standard of .4 grams for NOx may be
more stringent than needed but only if stationary emissions
are reduced to the same extent as automobile emissions.
C. The impact of HC emissions from automobiles varies greatly
among geographical regions. In general, however, the
statutory standard of .41 grams/mile is not sufficiently
2
stringent to assure compliance with the ambient air quality
standard for oxidant. Present analyses, therefore, are
inadequate to justify changes in the Federal motor vehicle
emission standard for hydrocarbons at this time.
Role of Auto Emissions in Total Health Problem
The NAS concluded that between one-tenth and one-forth of the
air pollution hazard is a result of automobile emissions.
For the whole U.S. population, effects of this magnitude might
represent as many as 4,000 deaths and 4 million illness
restricted days per year.
Columbia University
In a more recent study funded by the NSF, Columbia University
has published The Automobile and the Regulation of its Impact
on the Environment. This report has concluded that:
a. The ultimate success of a strategy placing major reliance
on emission controls in new vehicles depends on the
availability of a durable and maintainable control technology.
The development of such a technology would be best promoted
by delaying the 1975/1976 standards for HC and CO until
the 1980 model year.
b. The availability of control technology limits the degree
of NOx emission reduction which can be achieved. Because
of errors in ambient NOx concentration measurements, (the
eventual reductions) the eventual reductions in automobile
3
NOx emissions required to meet ambient air quality standards
are still in question.
C. While recognizing a fuel economy penalty of 5 percent, it
is recommended that an emission level of 2.0 grams/mile
for NOx be adopted for at least five years.
d. To induce advanced technologies, it is recommended that a
schedule for NOx emission standards for the next ten years
be developed and promulgated.
[Aug .1975]
MEMORANDUM FOR: THE PRESIDENT
FROM:
Menn
SUBJECT:
Automobile Emission Standards
we discuss need
Background
to
Pursuant to the Clean Air Act, the Administrator of EPA has
mtq
established national ambient air quality standards which each Whe
region must achieve and maintain to protect health and welfare.
The three regulated pollutants affecting automobiles are
hydrocarbons (HC), carbon monoxide (CO), and nitrogen oxide
(NOX) X Though ambient standards for these pollutants are
set by the Administrator of EPA as a regulatory action, auto-
mobile emission levels are set statutorily. Therefore, changes
in automobile standards require legislation.
The primary purpose of controlling pollutants from automobiles
is to help air quality regions throughout the nation reduce
ambient pollution levels caused by both stationary source
emissions and automobile emissions.
The levels established for ambient standards are themselves
controversial. However, the National Academy of Science
has recommended their retention pending further analysis.
Such analysis may lead to change (more or less strict than
present) but for purposes of this memo we have no choice but
to use the present standards as a criterion to determine the
0
contribution of mobile source controls toward protecting public
health.
The Clean Air Act imposes increasingly more stringent auto-
mobile emission standards. (Tab 1 shows chronology of
statutory standards.) At current standards, emissions for
two of the pollutants (HC and CO) have already been reduced
83 percent and emissions of NOX have been reduced 11 percent
from uncontrolled cars. The existing law, however, requires
that these automobile emissions be reduced even further
beginning with model year 1977 for NOX and model year 1978
for HC and CO.
As a part of reaching
In return Afor a voluntary agreement by automobile manufacturers
to increase fuel economy 40 percent by 1980, the Administration's
Energy Independence Act proposed amending the Clean Air Act
to allow standards for HC and CO which are less stringent
than the law would require through 1981, but more stringent
than standards currently in force. It also proposed that the
NOX standard be frozen at its current level until 1981 rather
than become more stringent as present law requires. (Tab 1
also shows Administration positions on automobile standards
since 1973.)
Subsequent to submitting the Energy Independence Act to Congress,
the Environmental Protection Agency held public hearings on a
regulatory action related to five-year emission levels. The
hearings publicized that the catalytic converter, used to
meet the HC and CO standards for 1975 and 1976 models, produces
potentially harmful quantities of sulfuric acid. Furthermore,
emissions of sulfuric acid would double if the more stringent
HC and CO standards proposed in the Energy Independence Act
are imposed for 1977 and subsequent model years. The
Administrator has concluded, in public announcements, that
the HC and CO standards should be kept at their current 1975
levels through model year 1979. However, since even current
levels present some potential health risk from converter-
produced sulfuric acid, EPA has recommended that a sulfuric
acid standard be established for model year 1979 vehicles.
At the same time, EPA did not concur with the Administration!s
position on nitrogen oxides and called for making the NOx
standard more stringent in model year 1977. (See Tab 1).
The Administration could avoid conflict on this matter by not
making another recommendation for automobile emission levels,
and let the Congress grapple with the problem. However, both
public credibility and the need of the automobile industry for
resolution by August of this year to design, certify and place
orders for 1977 model vehicles argue for strong leadership by
the Administration. Furthermore, there is a real risk that
the voluntary fuel economy approach (40 percent improvement
by 1980) may be jeopardized by decisions or delays in decisions
on this issue.
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 than those prevailing in 1970 when
the Clean Air Act was passed. Inflation, unemployment, added
costs to automobiles for safety requirements, and especially the
cost and availability of energy, suggest the possibility
of Congressional reassessment of the relative weights accorded
to various factors other than measures necessary to health.
The agreement by all health scientists that sulfuric acid from
?
the catalytic converter is either a present or potential threat
to public health requires that we reconsider our previous
position on automobile emission levels, which to a large extent
are premised on the use of the converter at least until model
year 1981. The two important questions to be addressed are:
a. Does the reduction in automobile emission standards
to the levels imposed on 1975 and subsequent model
No
The
years (all of which require the use of the converter)
(a) is our how a threet hard that Sin dud
have a significant impact on the ability of air
quality regions to achieve ambient air standards?
Data presented in this memorandum indicate that the present
(0)hm th this is the
range of options does not have a significant impact on
air quality.
heilth tride MCVCD,
b. Are automobile standards becoming stricter so quickly
that technology presently identified to meet them
creates other pollutants or hazards which are more
dangerous, or potentially more dangerous, than the
pollutants the technology is designed to reduce? This
memorandum indicates that the answer may be yes in the
short term at least until catalytic converters can
be significantly modified or abandoned in favor of
new engine technology.
Issue
What should be the Administration recommendation to Congress
on automobile emission levels for 1977-81?
Options
The feasible range of options is:
HC
CO
NOX
(grams/mile)
1.
Energy Independence Act
.9
9.0
3.1
(January 1975)
2. EPA Proposal (March 1975)
1977-1979
1.5
15.0
2.0
1980-1981
.9
9.0
2.0
3. 1975 Standards
1.5
15.0
3.1
4.
1974 Standards
3.0
28.0
3.1
5. Canadian Standards
2.0
25,0
3.1
6.
Standard thru 1981 if
present law is not amended:
1977
1.5
15.0
2.0
1978-1981
.41
3.4
.4
Analysis
Over the next ten years the quality of the nation's air with
respect to automotive pollutants is, with few exceptions, virtually
independent of the particular option chosen within the above
identified feasible range. For hydrocarbons (HC) and nitrogen
oxide (NOX) the marginal reductions in emissions from auto-
mobiles will be greatly exceeded by increased emissions from
(relatively uncontrollable) stationary sources. In other words,
the problem area is primarily stationary sources and not the
automobile insofar as HC and NOX are concerned. With respect
to carbon monoxide (CO), ambient conditions are improving
rapidly as older uncontrolled vehicles are being replaced
by newer controlled vehicles. This trend will continue
irrespective of the option chosen. Tab 2 identifies those
regions which will exceed ambient limitations for each pollutant
as a direct result of adopting less stringent standards than
proposed in the Energy Independence Act. All other regions
in the country will be below or above the ambient standard
regardless of the choise of option presented.
Option 1 (Energy Independence Act)
(HC) i$9 (CO) i 3.1 (NOX) through 1981)
a
9.0
A
Opposed by all agencies because the more stringent HC and CO
levels (relative to the other options ) will result in a
much greater release of sulfuric acid and therefore a greater
potential health hazard. However, at least EPA and certainly
the environmentalists will oppose not adopting a stricter NOX
level. Some environmentalists may even dispute the relaxation
of the HC and CO standard. (Tab 3 details the sulfuric acid
risk associated with catalytic converters.) This option will
also increase automobile costs by $50 per vehicle over current
sticker prices (Tab 4) and impose a 3 to 5 percent fuel penalty
(85,000 barrels of oil per day). (See Tab 5.)
7
Option 2 (EPA)
(1977-1979 - 1.5 (HC) ; 15 (CO) ; 2.0 (NOX)
(1980-1981 - .9 (HC) ; 9 (CO) 2.0 (NOX)
Freezing the HC and CO standards at present levels through
model year 1979 are intended to prevent the increases in
sulfuric acid emissions that would come from tighter standards.
This may be negated, however, by the more stringent NOX limi-
tation for 1977 and subsequent model years because with given
technology, manufacturers will likely choose to use the air-
injected catalyst to meet this combination of limitations,
are
particularly since more stringent HC and CO standards/projected
under the EPA proposal for 1980-1981. (See Tab 3.) This
option will increase cost by $15 to $25 per vehicle over
current sticker prices (Tab 4), and will impose a 3 to 5 percent
fuel economy penalty (85,000 barrels of oil per day). (See Tab 5.)
Option 3 (Current standards extended through 1981
(1.5 (HC) 15 (CO) ; 3.1 (NOX)
Freezing HC and CO standards at present levels would prevent
the increase in emissions of sulfuric acid that would result
from tighter standards in 1980 if technology isn't improved.
But even present standards may involve a sulfuric acid health
risk. (See Tab 3.) By definition no cost increases would
result (Tab 4) and rather than their being a fuel economy
penalty, fuel economy will continue to improve. (See Tab 5.)
Environmentalists will strongly object and Congressional
acceptance would be difficult.
FORD & LIBRARY GERALD
Options 4 and 5 (Canadian standards or 1974 standards)
(2.0 HC; 25 (CO) ; 3.1 NOX - 3.0 HC; 28.0 (CO) ; 3.1 NOX
respectively)
The difference between the Canadian standards and the 1974
standards is not significant, but the former are slightly
more stringent. Adoption of either would eliminate the problem
presented in Options 1-3, i.e., significantly reduce emissions
,C.,He through
of sulfuric acid, because either can be achieved without the
use of the converter. In fact, the use of catalytic converters
P.
would decrease (Tab 3) and result in cost savings (Tab 4) and
energy savings (Tab 5).
There is substantial evidence that by model year 1981 new
"lean-burn" or "stratified charge" engines would permit
meeting the lower (2.0) NOX standard. Thus a variant of
options 4 and 5 would be to propose lowering the NOX standard
for 1981 models. Even with such a variant, however, the
environmentalists would be very much opposed if either
Option 4 or 5 were adopted, and chances of Congressional
FORD & LIBRARY GERALD
acceptance is quite slim.
The reason is that these options mean steps backward from the
current standards for HC and CO. Even though there is now
substantial evidence that the Canadian or 1974 standards do
not adversely change the possibilities of attaining our clean
air ambient air quality standards for HC and CO, and there is
also now at least a serious question of sulfuric acid health
risks from converters, claims will be made that we "sold out"
to Detroit. The problem is compounded by comparison to your
proposed Energy Independence Act, which was 180 degrees in the
9
opposite direction, with respect to HC and CO, less than
three months ago. Although you were apparently not apprised
of the potential sulfuric acid problem in connection with
those decisions -- apparently because the experts were not
then as concerned as now as to possible risk -- critics
will point to a reversal as showing we are in "disarray. II
If either Option 4 or 5 is chosen, mechanism for reviewing the
situation annually to weigh the sulfuric acid risks, technology
advances, and new ways to attack the stationary source problem
should be stressed.
Agency Positions
EPA
DOT
TREASURY
DOI
HEW
DOC
CEQ
FORD LIBRARY j GERALD
FEA
ERDA
OMB
TAB 1
CHRONOLOGY OF AUTOMOBILE EMISSION LEVELS
The statutory standards for automobiles have become
progressively more stringent since 1968. Whereas ambient
standards are established by the Administrator of EPA
as a regulatory action, automobile emission standards are
set statutorily in the Clean Air Act. The following table
shows the emission standards by model year. The
Administration has made two legislative recommendations
to relax the statutory standards. These are footnoted
below:
Model Year
Automobile Emission Standard
United States (Clean Air
(grams/mile)
Act
HC
CO
NOx
Uncontrolled
8.7
87
3.5
1970
4.1
34
No standard
1972
3.0
28
No standard
1973-1974 1/
3.0
28
3.1
1975-1976 2/
1.5
15
3.1
1977 3/
1.5
15
2.0
1978
State of California (State law)
1975
.9
9.0
2.0
1/ In December 1973, the Administration proposed a three
year freeze of the standards at the 1975 interim levels.
The Congress adopted this proposal for two years
(1975 and 1976).
2/ The Administration, in the Energy Independence Act of
1975, proposed adopting the standards for HC and CO
currently in force in the State of California, but
proposed keeping the NOx standard frozen at their
present levels through 1981.
After public hearings, Administrator Train, as a
regulatory action, has retained the current HC and
CO standard through model year 1977. He had no
regulatory responsibility over NOx, however, and
therefore, the lower NOx level reflects current law.
At the same time, EPA made its recommendation for the
next five years. This recommendation is Option 2.
TAB 2
AIR QUALITY IMPACTS DUE TO LESS STRINGENT
AUTOMOBILE STANDARDS
The following tables show the direction and magnitude of
change in ambient concentration levels for CO, HC and NOx
which would result from adopting standards which are less
stringent than those proposed in the Energy Independence
Act. Two additional 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. Secondly, because the
concentration levels are projected through modeling techniques
thing
marginal changes in the concentration levels, whether increases
or decreases, are often within the margin of statistical error.
Carbon Monoxide
Carbon monoxide levels in the atmosphere are much more sensi-
tive 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 on CO
air quality. The following table shows 1985 projected con-
centration levels for twenty-six regions for each of the options
presented. The most important conclusion is that older un-
controlled cars are being replaced by newer controlled cars
and therefore, air quality is improving rapidly and will
continue to improve until 1985 under all of the emission control
2
options presented. The underlined regions are those which
would exceed the ambient standard if a CO standard less
stringent than proposed in the Energy Independence Act
were adopted.
Predicted Ambient CO Concentration Levels
1985
(9 ppm = ambient standard)
CO Automobile Emission Standard*
(in PPM
1974 and
EPA
Canadian Stds
Current Stds
Recommended
President's
Region
through 1981
through 1981
Standards
Proposal
Birmingham
6
5
5
5
North Alaska
11
11
11
11
Clark-Mohave
6
6
5
5
Phoenix-Tucson
16
14
14
13
Los Angeles
13
12
11
11
Sacramento Valley
7
6
6
6
San Diego
5
5
5
5
San Francisco
6
6
6
6
San Joaquin
4
3
3
3
Denver
11
11
9
9
Hartford-New
Haven
9
9
7
7
NY-NJ-Connecticut
15
13
13
13
Philadelphia
9
8
8
8
National Capitol
7
6
6
6
E. Washington
7
7
6
6
N. Idaho
Chicago
7
6
6
5
Indianapolis
5
4
4
4
Kansas City
6
5
5
5
Baltimore
7
7
7
7
Boston
6
5
5
5
Minneapolis-St.
Paul
9
8
8
7
Central New York
5
4
4
4
Portland
10
8
8
8
S.W. Penn.
7
6
6
6
Wasatch Front
15
13
13
13
Puget Sound
10
8
8
8
*
Assumes statutory standards are in force after 1981 model year.
3
The chart reveals several observations. First, there is only
a limited difference in ambient concentration levels at any
of the standards represented, but the difference is particularly
small when comparing either the President's proposed vehicle
standard (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. In fact by 1985, the average ambient levels for this
pollutant will have been reduced about 70 percent over 1970
levels with all five options.
Secondly, the choice of option will not significantly affect
any single area's ability to achieve or maintain the standard
by 1985. When comparing the President's proposed standard
for carbon monoxide, with EPA's recommended standard or
with the current standard extended through 1981, with the sole
exception of Denver, those areas below the ambient standard
in 1985 will be below it regardless of the automobile emission
standard chosen. The adoption of the Canadian standard would
mean that two additional areas (Portland and Puget Sound) would
violate the ambient standard by 1985, but only by a marginal
amount.
4
Hydrocarbons
Only 25 percent of total hydrocarbon emissions are generated
by automobiles. Therefore, hydrocarbon ambient air concen-
trations tend to be much less sensitive than carbon monoxide
to the level of vehicle emission control.
The following chart displays the limited differential impact
that more stringent vehicle hydrocarbon standard would have
on ambient air quality by 1985 in those areas considered
to have a hydrocarbon problem.
(Table appears on following page.)
The conclusions are essentially the same for hydrocarbons
as they are for carbon monoxide. All of the twenty regions
that are projected to exceed the ambient standard in 1985
will be above the standard regardless of the automobile
emission level chosen. Conversely, all of the regions projected
to have concentration levels below the ambient standard in
1985 at the stricter vehicle limitation are also projected to
be below the ambient standard if any of the other automobile
emission standards shown is chosen instead.
5
Predicted Ambient Oxidant Concentration Levels
1985
(Ambient Standard 18 .08 ppm) *
HC Automobile Emission Standard
(in grams/mile)
Current Stds
EPA
Canadian Stds
Extended thru
Recommended
President's
Region
through 1981
1981
Standards
Proposal
Birmingham
.12
.12
.11
.11
Mobile-Pensacola
.04
.04
.04
.04
Clark-Mohave
.13
.12
.12
.12
Phoenix-Tucson
.16
.16
.16
.16
Los Angeles
.43
.42
.42
.41
Sacramento
Valley
.21
.20
.20
.20
San Diego
.20
.20
.20
.19
San Francisco
.23
.23
.23
.23
San Joaquin
.22
.21
.21
.21
S.E. Desert
.32
.32
.32
.32
Denver
.17
.16
.16
.16
NY-NJ-Conn.
.14
.13
.13
.13
Philadelphia
.10
.10
.10
.10
National Capitol
.26
.26
.25
.25
Cincinnati
.12
.11
.12
.11
Indianapolis
.08
.08
.08
.08
S. Lou.-S.E. Tex.
.20
.20
.19
.19
Boston
.11
.10
.10
.10
Toledo
.07
.07
.07
.07
El Paso-Las
Cruces
.06
.06
.05
.05
Genessee- Finger
Lakes
.08
.08
.08
.08
Dayton
.13
.12
.12
.12
Portland
.08
.08
.08
.08
S.W. Penn.
.12
.12
.11
.11
Austin-Waco
.07
.07
.07
.07
GERALD FORD LIBRARY
Corpus-Christi
.14
.14
.14
.14
Dallas-Ft.Worth
.05
.05
.05
.05
Houston-Galveston
.27
.27
.27
.27
San Antonio
.07
.07
.07
.07
Puget Sound
.08
.08
.08
.08
The projected concentration levels assume the continuance of historic
growth rates for the central business districts in each region.
6
Nitrogen Oxides
Federal Government and independent scientists have all
predicted that a steady increase in ambient nitrogen dioxide
concentrations will occur in metropolitan areas over the next
ten years. Because controls on existing stationary sources
are very limited, the EPA feels that a more stringent auto-
mobile standard will reduce that rate of increase. At the
3.1 grams/mile automobile emission limitation, a 32 percent
average increase in air quality concentration is anticipated
by 1985, compared to a 22 percent increase if the 2.0 grams/mile
limitation were adopted.
Though the more stringent standard would have a significant
effect on the overall predicted increase, the differential
effect of the more stringent automobile standard on the
actual concentration levels in those areas with nitrogen
dioxide problems, is much less pronounced. This is shown
in the following table, which displays actual projected
concentration levels in the ten problem areas for 1980 and
1985 and for both automobile emission standards.
7
Projected NOx Air Quality Concentrations
(Ambient standard is 100 ug/m³)
NOx Automobile Standard
(in grams/mile)
1980
1985
Region*
3.1 g/m
2.0 g/m
3.1 g/m
2.0 g/m
Phoenix
97
92
111
100
Los Angeles
173
163
194
173
San Francisco
93
88
102
92
Denver
119
115
135
125
NY/NJ/Conn
124
125
144
136
Philadelphia
107
104
121
117
National Capital
104
100
116
107
Chicago
133
129
152
145
Baltimore
99
96
116
109
Wasatch Front
121
116
137
124
* Projected concentration levels assume the continuance of historic
growth rates for central business districts in each region.
By 1980, seven of the ten potential problem regions will
exceed the ambient air quality standard if the 3.1 grams/
mile automobile emission standard is maintained. All of
those seven regions, however, would exceed the ambient
standard even if the 2.0 grams/mile automobile emission
level were adopted. In addition, the three potential problem
regions which have projected concentration levels below the
ambient standard at the 2.0 grams/mile vehicle limitation
also will not exceed the ambient standard at 3.1 grams/mile.
8
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/mile limitation is
placed on automobiles. San Francisco would remain below the
standard if the more stringent standard is adopted and, in
fact, California currently has the more stringent standard
in force as a State regulation.
Two additional aspects of the above analysis should be noted.
First, the projected air quality data for the ten regions
assumes that the historic growth rates of industrial develop-
ment and vehicle miles traveled in each metropolitan area
will continue through 1985. No consideration, for example,
was given for possible reductions in future vehicle miles
traveled (and, therefore, reductions in pollutant emissions)
which result from higher gasoline prices.
Secondly, the projected increases in nitrogen dioxide cannot be
stopped without major technological innovations in stationary
source control. Therefore, 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. As a result, EPA's desire for
a more stringent vehicle standard essentially reflects concern
with total ambient concentration levels and does not address
the relative degree of control exercised over stationary and
mobile sources.
TAB 3
HEALTH IMPACTS OF SULFURIC ACID EMISSIONS
FROM AUTOMOBILES
Though ambient carbon monoxide and oxidant concentration levels
are not significantly affected by the range of automobile
emission standards presented, they do have varying impacts
on the concentrations of sulfuric acid.
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.
The catalyst emission system generally used to meet the 1975
interim standards produces less sulfuric acid than the system
needed to meet more stringent emission standards.
Current estimates indicate that with existing automobile
emission technology, the President's proposed emission
standard for hydrocarbons and carbon monoxide (.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 non- catalytic technologies which can
meet the stricter emission limitations and which do not produce
sulfuric acid there is little production potential for using
these non-catalytic systems before the 1981 model year.
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 how long it would take for the build-up in concentration
levels to occur. Because new data is currently under review
and the state of knowledge is in flux specific calculations
or final judgments on sulfuric acid emission levels or the
air quality or health impacts of the options presented can-
not be made.
The following table therefore represents our best estimates
of the years in which the 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 Meteorological Adverse Meteorological
Standard
Conditions
Conditions 2/
1975 Interim Standards
1981
1979
1975 California Standards
In 49 States
1979
1977
In California 3/
1978
1977
FORDO : LIBRARY GERALD
1/ 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.
2/ Adverse meteorological conditions would occur in large metropolitan
areas on an average of 6-7 days a year.
3/ The dates for reaching a critical problem are earlier in California
than the remaining 49 States because California utilizes higher
sulfur gasoline.
The potential health effect of sulfuric acid emissions from
automobiles is complicated by two additional factors. First,
data available to date do not take into account "background"
emissions of sulfates from stationary sources, e.g., coal-
fired generating plants. These data represent 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.
However, most analyses are tending toward a separation of the
two pollutants from a health perspective. This is primarily
because the particle size of sulfates is much larger than
sulfuric acid mist and is not absorbed as deeply into the
respiratory system. Also the toxicity of sulfate emissions
from stationary sources is generally much less than sulfuric
acid and finally, emissions from stationary sources do not
occur in the breathing zone as do automobile emissions.
It is generally agreed that reducing nitrogen oxide
emissions will result in an increase in emission of hydro-
carbons from engines. To reduce that increment, manufacturers
may increase the use of the air-injected oxidation catalyst --
even to meet the less stringent HC and CO standards. If
this were the case, then nearly twice as much sulfuric acid
would be generated than is projected above. However, at
this time it is not known definitely whether manufacturers
could achieve reductions of the increment through the use
of engine modifications instead of the air-injected catalysts.
TAB 4
ECONOMIC IMPACT OF AUTOMOBILE OPTIONS
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.
NOx
Consumers will face sticker price and operating cost increases
over 1975 model vehicles if EPA's recommended 2.0 grams/mile
limitation is imposed. Estimates range from $10-25 for
front-end costs per vehicle and from $0-15 in operating
costs over 50,000 miles. However, not included are the
additional costs of increased fuel consumption associated
with this lower standard, which rough estimates place at
$1.7 million per day.
HC and CO
The costs of maintaining the more stringent hydrocarbon and
carbon monoxide standards (.9 and 9.0) as proposed by the
President 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. However, not included are estimates of operating
costs which would result from the increased consumption of
gasoline that maintaining this option implies, Rough
estimates place this cost at $1.7 million per day.
TAB 5
ENERGY IMPACTS OF OPTIONS
The options presented will have differential fuel economy
impacts and therefore different impacts on manufacturers'
ability to meet the 40 percent fuel economy goal. EPA dis-
agrees with the fuel economy penalties here. The agency firmly
believes that there are no technological barriers to reducing
emission standards without a fuel penalty. However, a recent
Columbia University study supports the findings shown and in
some cases predicts even larger penalties for lowering the
NOX level than is assumed in this analysis.
A. Impact on 40 percent Fuel Economy Goal
% Over
Shortfall (-)
1974
or excess (+)
Over President's
Options
Goal
Energy Independence Act
40%
-----
EPA Proposal
36%
- 4%
1975 Stds. thru 1981
46%
+
6% GERALD FORD LIBRARY
Canadian and 1974 Stds. thru 1981
50%
+10%
B. Energy Impacts*
Options
Barrels per day (in 1980)
Energy Independence Act
85,000 (loss)
EPA Proposal
137,000 (loss)
1975 Stds. thru 1981
0
Canadian and 1974 Stds. thru 1981
27,000 (gain)
*
Base is 1975 model year automobiles meeting 1975 interim
emission standards.
aug 1975
TO: JIM CAVANAUGH
FROM: GLENN Jen SCHLEEDE
SUBJECT: AUTO EMISSIONS
Here is a copy of the file on auto emissions.
As I promised you earlier, I have discussed
it with Russ Train and started talking with
people on the Hill at the staff level. Briefly:
Russ Train (He was out of town when Dick
Dunham tried to get his vote on the option
paper) Russ says he does not know what to
do on this issue but has the following
comments:
- He believes the proposed letter would
serve to harden positions even more.
- He thinks Muskie and Baker are looking
for a way to handle the issue that doesn't
look like capitulation bo the auto industry,
that gives some relief, that keeps the
pressure on the auto industry to do better,
and which saves face for Muskie.
- He thinks that a meeting with the President and
Randolph, Baker, Muskie and Buckley may have
some merit -- but he warns that Muskie and
Buckley are very well informed on the issue
and he believes it would be difficult to bring
the President up to speed.
- He is willing to talk with Baker, Domenici or
others on the issue if we want him to.
- He recognizes the advantages to the Administzation
of splitting of the auto emissions part of the
clean air act amendments -- since other amendments
are likely to be intolerable, but he doubts that
the committee will go along since they recognize
that auto emissions is their ace in the hole for
getting the President to sign all the amendments.
Mike Hathaway (Assistant to Senator McClure).
Mike likes the idea of splitting off the auto
emissions. He recognizes that the only hope now
FORD & LIBRARY GERALD
of getting the committee to move ***** off its
current position is to bring publicity to bear. He
indicates, however, that this should emphasize
economic impact and jobs, that energy alone isn't
having much effect on the committee. He urges that
somebody other than FEA testify on job and economic
impact if hearings are held, that testimony on
small health impact of tighter standards be
reemphasized. He points out hhat we will have to
do more than hearings to get publicity favoring the
President's position since Muskie will be
controlling the hearings and probably the
publicity from them.
Baker's staff people have been on leave.
House Commerce staff familiar with the issue
are also out of town.
At present my recommendations would be:
1. Proceed with a letter like the one attached
to the option paper.
2. Also arrange for a meeting with Randolph, Baker,
Muskie and Buckley, to be followed by a
briefing by Zarb, Train and somebody on economic
impact -- if we can get something credible.
3. A concerted background briefing effort on energy
and economic impact.
If we are to make this work, we'd need help from Seidman's
staff, FEA and OMB.
OUTSTANDING PHONE CALLS
from Tuesday, August 5, 1975
Jamie MeLean
212/559-0779
John Hill
302/539 4415
Senator Baker
224 4944
Senator Domenici
224 6621
REMINDER: You wanted to call Hal Bruno this week
654 3337
DOMESTIC COUNCIL CLEARANCE SHEET
DATE Aug. 4, 1975
JMC action required by:
TO :
JIM CANNON
VIA:
DICK-DUNHAM
of
JIM CAVANAUGH
FROM =
SUBJECT : Auto Emission Standards -- Response to
Senators Baker and Randolph Letter
COMMENTS:
DATE:
RETURN TO:
Material has been:
.
Signed and forwarded
Changed and signed (Copy attached)
Returned per our conversation
Noted
Jim Cannon
Drd
THE WHITE HOUSE
DECISION
WASHINGTON
Augu 75
MEMORANDUM FOR THE PRESIDENT
FROM:
JIM CANNON
SUBJECT:
Auto Emission Standards - Response
to Senators Baker and Randolph Letter
Background
On July 26 you asked Congress to reopen hearings
on the auto emission portion of the Clean Air Act
and submitted a draft bill carrying out your proposal
to extend 1975-76 auto emission standards through
model year 1981. (See Tab A for additional background.)
Senators Baker and Randolph responded on July 29,
saying, in effect, that they are not enthusiastic
about reopening hearings because it would mean a
several month delay in reporting out the Clean Air
Act. (See Tab B.)
Your letters requesting hearings and transmitting
legislation are at Tab C.
Recommendations
There are three possible ways of responding:
Alternative 1:
amendments
Concede the argument in the Senators' letter
and react to the Clean Air Act when it is passed.
The argument for this option is in the expectation
that the Clean Air Act, both in its industrial and
auto emission features, will be so onerous in its
impact on the economy that a veto is clearly
indicated and can be sustained.
2
The danger in this option, however, is that
the auto emission standards now in the Clean
Air Act for 1977 involve a 3-5% gasoline
mileage penalty, and standards due to go into
effect for 1978 models are so extreme that
the auto industry could not meet them and still
produce cars.
A new auto emission law would take time,
probably several months, to work its way through
Congress, and in the meantime, the auto industry
must begin to make the design and engineering
changes to meet whatever standards are to be.
Alternative 2:
Attempt to negotiate with Committee members or
staff during the month of August.
Because of known views of most of the Senate
Committee members [and staff it is quite unlikely
that a satisfactory compromise would be reached.
Alternative 3:
Respond formally, urging that hearings be held
and that auto emissions be handled in a separate
bill. Proposed letter at Tab D.
The principal arguments for this are: (1) The
approach outlined in the letter is a reasonable
one for minimizing delay, and (2) if successful,
it would permit more time to deal with Clean Air
Act amendments on matters other than auto
emissions which may be even more difficult to
accept. Also, experience with the Committee
indicates that formal communications are the
most effective way of getting consideration
of Administration views. It permits the Committee
to share with you some blame for potential
delay--which appears to be one of their objectives.
The principal argument against it is that others
affected by the amendments may object to singling
out the auto industry for special attention.
Also, a letter rather than informal communication
will attract more attention to an Administration
position that has gained little public support so far.
3
Recommendations and Decision
Alternative #1: Do not press further with
hearings; deal with the
bill when it arrives.
Alternative #2:
Open negotiations with the
Committee or staff seeking
acceptable standards. (Russ
Peterson favors this option.)
Alternative #3:
Respond with a letter urging
hearings and splitting off of
auto emissions from the other
Clean Air Act Amendments.
(Letter for your signature at
Tab D.)
(Robert T. Hartmann, Jack Marsh,
Bill Seidman, Rog Morton, Frank
Zarb, Phil Buchen, Jim Lynn,
and I support this option. Phil
Buchen would modify it to allow
for two weeks of negotiations
with the Committee before It is
sent.)
THE WHITE HOUSE
DECISION
WASHINGTON
July 24, 1975
MEMORANDUM FOR
THE PRESIDENT
FROM:
JIM CANNON
SUBJECT:
AUTO EMISSIONS AND OTHER
CLEAN AIR ACT PROBLEMS
The Rogers Subcommittee of House Commerce and Muskie
Subcommittee of Senate Public Works are continuing work
on Clean Air Act Amendments -- with the goal of reporting
bills to their full committees before the recess. The
outlook is bleak for all of the Administration's major
amendments and the Subcommittees are considering how
requirements would be troublesome.
The Current Issue
The issue for your consideration at this time is whether
additional actions should be taken in an attempt to improve
chances of getting acceptable auto emission standards.
Specifically:
Do you wish to send up a bill now which would carry out
your June 27 proposal to extend 1975-76 auto emission
standards through model year 1981?
Do you wish to request formally that House and Senate
Committees reopen Clean Air Act Hearings so that Zarl
and others can testify?
GERALD FORD
Background
On June 27 you sent a message to Congress asking that present
auto emission standards be continued for five years. Both
the House and Senate Subcommittees completed hearings on
auto emissions before your proposal was transmitted. The
proposal has attracted very little favorable attention in
the Congress or the Press. It has had virtually no visible
impact on Subcommittees' actions. A bill proposed by Senator
McClure in Subcommittee to extend standards for five years
lost by a vote of eight to one. Neither Subcommittee has
indicated any intention of reopening hearings to consider
findings that led to your June 27 proposals.
2
While neither Subcommittee's actions are final, both have
voted to adopt standards much more rigid than you proposed.
Tab A contrasts their decisions with your proposal. In the
House, there is some chance that standards will be loosened
in full Committee. In the Senate, the full Committee is
unlikely to change the final Subcommittee action, particu-
larly since only three members (Randolph, Burdick and Baker)
of the full Committee are not members of the Subcommittee.
The other major amendments to the Clean Air Act which you
proposed on January 30 in your Energy Independence Act are
also running into trouble. The status of these amendments
and several new problems -- including a requirement for land
use plans approved by EPA -- are summarized briefly at Tab B.
Alternatives for Actions Now on Auto Emissions
Alt #1. No Additional Presidential Action now. Continue
and expand efforts by Zarb and others to get
Subcommittees to adopt Administration proposals.
Reconsider situation after final Subcommittee
action.
The principal arguments for this are that your
position is already clear, that additional
actions are unlikely to get favorable actions
and may expose you to even more criticism from
environmentalists and the Press.
The principal arguments against it are that the
outlook for acceptable standards is now bleak
and additional actions by you may make a dif-
ference; and the economic consequences of the
issue are critical.
Alt #2
Transmit bill to implement 5-year extension and/or
formally request Committees to hold hearings on
your June 27 proposal. Supplement this action
with (a) Zarb personal contacts with Committee
members as soon as possible, (b) concerted effort
to inform the public about the merits of the
proposal.
The principal arguments for this are that a
Presidentially-proposed bill would provide a
rallying point for members who would support
your proposal; and another communication from
you would provide the basis for additional
publicity to help gain support.
3
-
The principal arguments against this are the
potential for additional negative reaction to
your proposal; and the slim chances for getting
acceptable standards because the issue is
complex and difficult to explain to Congress or
the public; there is wide disagreement among
experts on air quality and health impacts, and
it is difficult to document the negative auto
sales and job impacts of tighter standards.
Recommendations and Decision
Alt. #1. No additional Presidential action now.
Peterson
Hartmann - believes your position is already clear and
Congress should. take the heat if it disregards
your position.
Train - believes additional actions could be counter
productive, particularly in the Senate.
Alt. #2. Prepare the following for my signature:
Zarb
Transmittal letter and bill to
Lynn
extend standards through 1981.
Morton
Seidman
Letters to Committee Chairmen
Greenspan
asking for hearings.
Cannon
COMPARISON OF ALTERNATIVE EMISSION STANDARDS
NOW UNDER CONSIDERATION
(grams per mile)
Model Year
HC
CO
NOX
Current Law
1975-76
1.5
15.0
3.1
1977
1.5
15.0
. 2.0
1973 on
.41
3.4
.4
President's Proposal
1977-81
1.5
15.0
3.1
House Commerce Subcommittee (Rogers)
1977
1.5
15.0
- 2.0
-
1978-79
.9
9.0
2.0
1980 on
.41
3.4
.4
Senate Public Works Subcommittee (Muskie)
1977
1.5
15.0
3.1
1978
.41*
3.4*
1.0*
1979
.41*
3.4*
1.0*
1980
.41
3.4
1.0
1981
.41
3.4
1.0
*The Administrator of EPA would have authority to waive
these standards for up to 50% of the production of each
manufacturer in 1978 and 1979. Cars covered by waiver
would have to meet 1.5, 15.0 and 3.1 standards.
The Senate subcommittee has under consideration other actions
which would, in fact, make the standards more difficult to
meet, including:
Warranty covering 100,000 miles (rather than current 50,000)
with "normal" maintenance (apparently as contrasted with
current manufacturer prescribed, EPA approved maintenance)
Assembly line testing in addition to the current prototype
certification process.
STATUS OF MAJOR CLEAN AIR ACT AMENDMENTS PROPOSED BY THE
ADMINISTRATION AND POTENTIAL NEW PROBLEMS IN ACTIONS TAKEN
THUS FAR BY THE SUBCOMMITTEES
Status of Major Proposals
1.
Intermittent Controls
Proposal to allow power plants in isolated areas to
use intermittent controls (fuel switching, tall stacks,
or load changing) through 1985 -- if health standards
are not violated, rather than requiring permanent
controls (scrubbers or low sulfur fuel)
House subcommittee is considering a 1980 deadline.
Senate subcommittee is opposed to intermittent controls.
2.
Coal Conversion Amendments
Administration proposal to broaden and extend the
coal conversion program is not being accepted in the
House subcommittee. Senate subcommittee has not yet
acted.
3.
Significant Deterioration
The Congress is moving in the direction of strengthening
the role of the Federal Government in preventing "signifi-
cant deterioration" of air quality.
4.
Auto Emissions - Covered in Tab A.
New Requirements Being Added by Subcommittees (Examples)
1.
Adding an emissions fee of up to $5,000 per day for
stationary pollution sources that do not meet State
implementation plan requirements. Works against
intermittent control proposal. (House Subcommittee)
2.
Heavy duty trucks and busses would be required to meet a
90% reduction in emissions by 1979. EPA would have authority
to require retrofit of existing fleet. (Senate Subcommittee)
3.
New comprehensive air quality planning requirements would
require land use plans covering but not limited to (1)
assuring air quality is maintained, (2) indirect pollution
sources such as shopping centers, etc. Requirement that
plans have EPA approval would involve Federal Government
in local land use planning. Liberal planning grants for
COG's appears designed to get political support for proposal.
Allegedly viewed by Senator Muskie as substitute for
Land Use Bill. (Senate Subcommittee)
TAB B
JENNINGE - W. VA., CHAIRMAN
7-15
ECIVEND = MUSKIE. MAINE
HOWARD 14. BAKER, JR., TEA
29 PM-1 18
JOSZPH M. MONTOTA, N. NEX.
JAMES L. BUCKLEY, N.Y.
RIKE GRAVEL ALASKA
ROBERT T. STAFFORD, vr.
JAMES A. MCCLURE. IDAHO
HAND DELIVERED
LLOYD BENTSEN. TEX
CUENTIN N. SURDICK, N. DAK
PETE V. DOMENICI, N. MEX.
JOHN C. CULVER. IOWA
UNIT
Senate
POSERT MORGAN, NC
CARY HART, cola
M. BARRY MEYER, CHIEF COUNSEL AND CHIEF CLERK
WORKS
BAILEY GUARD, MINORITY CLERK
20510
9
Honorable Gerald R. Ford
The President
The White House
Dear Mr: President:-
Weshave discussed your-July 26, 1975 request for a hearing on
automobile emissions with the Members of the Committee on Public
4"
Works. There is agreement that a hearing could be held if you desire
it. We believe, however, that there is certain information which you
should have before you.
If such a hearing is held, undoubtedly private and public groups
would also desire to be heard on the information presented. We
would be constrained to honor those requests. Such a situation would
entail postponing further Committee consideration of other issues in-
volved in the Clean Air Act. It had been our hope to begin Full
Committee consideration of the Clean Air Act during the week of Sep-
tember 8 so that during that week and the following week, we could
develop and report the legislation for Senate consideration.
By reason of service on the Budget Committee, Senator Muskie,
Chairman of the Subcommittee, Senator Buckley, the Ranking Minority
Member and Senator McClure and Senator Domenici, two important
participants in the consideration of Clean Air Act Amendments, will
be required to address themselves to the Second Budget Resolution
which must be considered by the Congress by mid-October. If the
hearings you request are held, it is a reasonable certainty that the
Public Works Committee could not conclude its deliberations on the
Clean Air Act until late October or early November. This delay,
would, we suggest; cause severe problems for those who are regulated
by the Act, including the automobile industry.
FORD is LIBRARY GENALD
The Honorable Gerald R. Ford
July 29, 1975
Page 2
Mr. President if you have further counsel to give us in this
matter, we shall be pleased to receive it.
Truly,
ford Ranking Howard H. Minority 18 Pm Baker, Member Jr. Jennings Chairman Tennings Randolph Randolph
- - -
IMMEDIATE RELEASE
July 28, 1975
Office of the White House Press Secretary
THE WHITE HOUSE
TEXT OF LETTERS FROM THE PRESIDENT TO THE
SPEAKER OF THE HOUSE OF REPRESENTATIVES
AND THE PRESIDENT OF THE SENATE
July 26, 1975
Dear Mr. Speaker: (Dear Mr. President:)
On June 27, 1975, I transmitted a special message to
the Congress which described the complex problem of
setting automobile emission standards which strike
the best possible balance among our air quality, public
health, energy, consumer cost and other economic
objectives.
As indicated in that message, I have concluded that
automobile emmission standards should not be more rigid
than those applied to 1975 and 1976 model cars because
more rigid standards unnecessarily would increase car
prices, reduce gasoline mileage, and increase energy
demands. There is also the potential that tighter
standards would require emission controls that result
in new pollutants with serious health impact.
I am enclosing a draft of a bill which would implement
the recommendations described in detail in my June 27th
message. I urge prompt passage of this bill.
Sincerely,
GERALD R. FORD
#
#
41=
=132
A BILL
To amend the Clean Air Act to continue 1975-76 Federal
automobile emission standards through the 1981
model year to permit at balance among the important
objectives of improving air quality, protecting
public health and safety, and avoiding unnecessary
increases in consumer costs for automobiles,
decreases in gasoline mileage, and increases in
the Nation's dependence on imported oil.
Be it enacted by the Senate and the House of
Representatives of the United States of America in
Congress assembled,
Sec. 2. The Clean Air Act, as amended, is amended as
follows:
(a) Section 202 (b) (1) (A) is amended to delete therefrom
"1977" and insert in lieu thereof "1982."
(b) Section 202 (b) (1) (A) is further amended to delete
the last sentence therefron and insert the following
sentence in lieu thereof:
"The regulations under subsection (a) applicable to
emissions of carbon monoxide and hydrocarbons from light-
duty vehicles and engines manufactured during model years
1975 through 1981, inclusive, shall contain standards
which are identical to the interim standards which were
prescribed (as of December 1, 1973) under paragraph (5) (A)
of this subsection for light-duty vehicles and engines
manufactured during model year 1975.
(c) Section 202 (b) (1) (B) is amended to read as
follows:
"The regulations under subsection (a) applicable to
emission of oxides of nitrogen from light-duty vehicles
and engines manufactured during model years 1975 through
1981 inclusive shall contain standards which are identical
to the standards prescribed (as of December 1, 19,73) under
subsection (a) for light-duty vehicles and engines manu-
factured during model year 1975. The regulations under
subsection (a) applicable to oxides of nitrogen from
light-duty vehicles and engines manufactured during or
after model year 1982 shall be established at such level
as the Administrator determines is appropriate considering
air quality, energy efficiency, availability of technology,
cost, and other relevant factors. The Administrator shall
publish for public comment no later than July 1, 1977,
proposed standards for 1982 model year light-duty vehicles
and engines and his tentative conclusions with respect to
the matters he is required to consider under this paragraph
and shall publish his final standards and his findings no
later than July 1, 1978. Such standards may be revised
after appropriate notice following such date based upon
substantial changes in any of the factors the Administrator
is required to consider under this paragraph-
FORD & WIDNARY GERALD
IMMEDIATE RELEASE
July 28, 1975
Office of the White House Press Secretary
THE WHITE HOUSE
TEXT OF LETTERS FROM THE PRESIDENT TO
THE CHAIRMAN, SENATE WORKS COMMITTEE
AND
THE CHAIRMAN, HOUSE INTERSTATE
AND FOREIGN COMMERCE COMMITTEE
July 26, 1975
Dear Mr. Chairman:
On June 27th, I transmitted to the Congress a
special message which described the conclusions
from a detailed executive branch review of the
air quality, health, energy, and consumer cost
implications of alternative automobile emission
standards. I recommended that 1975-76 standards -
for automobile emissions be extended by the
Congress through model year 1981.
I believe it important that the Congress and the
public have a full opportunity to hear in detail
the findings of our studies and the basis for my
conclusions that existing standards should be con-
tinued. I recognize that the hearings held by your
subcommittee on auto emissions ended before our
studies were completed. I urge you to hold another
hearing on this matter so Administration witnesses
can present the findings.
Sincerely,
GERALD R. FORD
The Honorable Jennings Randolph The Honorable Harley O. Staggers
Chairman
Chairman
Public Works Committee
Interstate and Foreign
United States Senate
Commerce Committee
Washington, D.C. 20510
House of Representatives
Washington, D.C. 20515
#
#
=He
##
Xthd
DRAFT 1
Dear Senator Randolph (Senator Baker)
Thank you for your prompt consideration of my request
that your Committee hold additional hearings on the
matter of automobile emission standards particularly
to consider the bill I have proposed to extend current
Federal standards through the 1981 model year].
The review that has been completed within the executive
branch considered the implications of alternative automobile
emission standards for 1977 and future years on air quality,
health, consumer costs, gasoline mileage and other energy
goals. I believe a discussion of our findings by
Administration witnesses would be an important addition
to the hearings held previously by your Subcommittee on
Environmental Pollution.
I understand and fully support your view that witnesses
in addition to those from the Administration should be
heard if you decide to hold hearings. Your decisions
will have an Efect on many Americans and a full public
discussion of all points of view is necessary if we
are to find the best possible balance among
objectives
for improving environmental quality, protecting public
health and safety and avoiding unnecessary increases in
consumer prices, decreases in gasoline mileage and
increases in dependence on imported oil.
I also understand your concern about the potential
problems that a delay in action on Clean Air Act
Amendments would have on the automobile manufacturers
and others who are regulated by the Act. We must work
together toward final action on legislation so as
to avoid the need for changes in design or production
that result in higher consumer costs or in production
delays that result in unemployment.
2
I would like to suggest for your consideration an
approach that should minimize and possibly avoid delay
in completing action on amendments. My suggestion is
that you consider (1) proceeding on your original
schedule for Committee and full Senate action on all
necessary amendments, except those dealing with automobile
emissions; (2) scheduling hearings, limited only to
the issue of auto emissions, for the earliest. practicable
dates to hear Administration, public and private witnesses
and (3) handling auto emission standards in a separate
bill, perhaps on an expedited basis, because of the
special importance of early, final action on these standards
Please be assured that members of my AdmirEstration and I
are prepared to cooperate fully to assure action and
to work with 13 finding the best possible balance
among the important objectives that are affected by
the decision on auto emission standards.
Jour your
Sincerely,
Rob THE som du us stow - Aop can and orn are
he dow put
wrat work out
Can but act two
Hourthy feat
y
we person review
vat be
by Personts
FORDO & LIBRARY GERALD
propost
THE WHITE HOUSE
WASHINGTON
August 1, 1975
MEMORANDUM FOR:
PHIL BUCHEN
MAX FRIEDERSDORF
ALAN GREENSPAN
ROBERT T. HARTMANN
JIM LYNN
JACK MARSH
ROG MORTON
RUSS PETERSON
BILL SEIDMAN
RUSS TRAIN
FRANK
ZARB
FROM:
SUBJECT:
AUTO JIM CANNON EMISSION June
STANDARDS - RESPONSE
TO SENATORS AND BAKER
May we have your comments, changes and votes on the
attached draft decision paper by noon, Monday,
August 4, so that it can be presented to the
President when he returns. Thanks for your help.
Enclosure
CC: Paul Theis
GERALD
DRAFT August 1, 1975
THE WHITE HOUSE
DECISION
WASHINGTON
MEMORANDUM FOR THE PRESIDENT
FROM:
JIM CANNON
SUBJECT:
Auto Emission Standards - Response to
Senators Baker and Randolph Letter
The purpose of this memorandum is to propose a response
to the attached July 29 letter to you and to discuss
alternative approaches that you should consider before
you agree to a course of action on this issue.
Background
You asked Congress to reopen hearings on the auto emission
portion of the Clean Air Act and submitted a draft bill
carrying out your proposal to extend 1975-76 auto emission
standards through model year 1981. (See Tab A for your
July 24 memo.)
Senators Baker and Randolph responded on July 29 saying,
in effect, they are not enthusiastic about reopening hearings
because it would mean a several month delay in reporting out
the Clean Air Act. (See Tab B.)
A complicating factor to be taken into consideration in
responding to this letter is that the auto emission section
is only one of the features of the Clean Air Act amendment
package which are likely to be objectionable to the
Administration. Therefore, the response to this letter
will affect your options in dealing with the whole Clean
Air Act.
Your letters requesting hearings and transmitting legislation
are at Tab C.
- 2 -
Recommendations
There are three possible ways of responding:
Alternative 1:
Concede the argument in the Senators' letter
and react to the Clean Air Act when it is passed.
The argument for this option is in the expectation
that the Clean Air Act, both in its industrial and
auto emission features, will be so onerous in its
impact on the economy that a veto is clearly indicated
and can be sustained.
The danger in this option, however, is that the
auto emission standards now in the Clean Air Act
for 1977 involve a 3-5% gasoline mileage penalty
and standards due to go into effect for 1978 models
are so extreme that the auto industry could not meet
them and still produce cars.
A new auto emission law would take time, probably
several months, to work its way through Congress,
and in the meantime, the auto industry must begin
to make the design and engineering changes to meet
whatever standards are to be.
Alternative 2:
Attempt to negotiate with Committee members or staff
during the month of August.
Because of known views of most of the Senate Committee
members and staff, it is quite unlikely that a
satisfactory compromise would be reached.
Alternative 3:
Respond formally urging that hearings be held and
that auto emissions be handled in a separate bill.
Proposed letter at Tab D.
- 3 -
The principal arguments for this are (1) the
approach outlined in the letter is a reasonable
one for minimizing delay, and (2) if successful,
it would permit more time to deal with Clean Air
Act amendments on matters other than auto emissions
-- which may be even more difficult to accept.
Also, experience with the Committee indicates that
formal communications are the most effective way
of getting consideration of Administration views.
It permits the Committee to share with you some
blame for potential delay -- which appears to be
one of their objectives.
The principal argument against it is that others
affected by the amendments may object to singling
out the auto industry for special attention.
Also, a letter rather than informal communication
will attract more attention to an Administration
position that has gained little public support
so far.
Recommendations and Decision
Alternative #1:
Do not press further for
hearings; deal with the
bill when it arrives.
Alternative #2:
Open negotations with the
Committee or staff seeking
acceptable standards.
Alternative #3:
Respond with a letter urging
hearings and splitting off
of auto emissions from the
other Clean Air Act Amendments.
(Letter at Tab D.)
GEBALO FORD LIBRARY
THE WHITE HOUSE
DECISION
WASHINGTON
July 24, 1975
MEMORANDUM FOR
THE PRESIDENT
FROM:
JIM CANNON
SUBJECT:
AUTO EMISSIONS AND OTHER
CLEAN AIR ACT PROBLEMS
The Rogers Subcommittee of House Commerce and Muskie
Subcommittee of Senate Public Works are continuing work
on Clean Air Act Amendments -- with the goal of reporting
bills to their full committees before the recess. The
outlook is bleak for all of the Administration's major
amendments and the Subcommittees are considering how
requirements would be troublesome.
The Current Issue
The issue for your consideration at this time is whether
additional actions should be taken in an attempt to improve
chances of getting acceptable auto emission standards.
Specifically:
Do you wish to send up a bill now which would carry out
your June 27 proposal to extend 1975-76 auto emission
standards through model year 1981?
Do you wish to request formally that House and Senate
Committees reopen Clean Air Act Hearings so that Zarb
and others can testify?
Background
On June 27 you sent a message to Congress asking that present
auto emission standards be continued for five years. Both
the House and Senate Subcommittees completed hearings on
auto emissions before your proposal was transmitted. The
proposal has attracted very little favorable attention in
the Congress or the Press. It has had virtually no visible
impact on Subcommittees' actions. A bill proposed by Senator
McClure in Subcommittee to extend standards for five years
lost by a vote of eight to one. Neither Subcommittee has
indicated any intention of reopening hearings to consider
findings that led to your June 27 proposals.
2
While neither Subcommittee's actions are final, both have
voted to adopt standards much more rigid than you proposed.
Tab A contrasts their decisions with your proposal. In the
House, there is some chance that standards will be loosened
in full Committee. In the Senate, the full Committee is
unlikely to change the final Subcommittee action, particu-
larly since only three members (Randolph, Burdick and Baker)
of the full Committee are not members of the Subcommittee.
The other major amendments to the Clean Air Act which you
proposed on January 30 in your Energy Independence Act are
also running into trouble. The status of these amendments
and several new problems -- including a requirement for land
use plans approved by EPA - are summarized briefly at Tab B.
Alternatives for Actions Now on Auto Emissions
Alt #1. No Additional Presidential Action now. Continue
and expand efforts by Zarb and others to get
Subcommittees to adopt Administration proposals.
Reconsider situation after final Subcommittee
action.
The principal arguments for this are that your
position is already clear, that additional
actions are unlikely to get favorable actions
and may expose you to even more criticism from
environmentalists and the Press.
The principal arguments against it are that the
outlook for acceptable standards is now bleak
and additional actions by you may make a dif-
ference; and the economic consequences of the
issue are critical.
Alt # 2
Transmit bill to implement 5-year extension and/or
formally request Committees to hold hearings on
your June 27 proposal. Supplement this action
with (a) Zarb personal contacts with Committee
members as soon as possible, (b) concerted effort
to inform the public about the merits of the
proposal.
The principal arguments for this are that a
Presidentially-proposed bill would provide a
rallying point for members who would support
your proposal; and another communication from
you would provide the basis for additional
publicity to help gain support.
3
The principal arguments against this are the
potential for additional negative reaction to
your proposal; and the slim chances for getting
acceptable standards because the issue is
complex and difficult to explain to Congress or
the public; there is wide disagreement among
experts on air quality and health impacts, and
it is difficult to document the negative auto
sales and job impacts of tighter standards.
Recommendations and Decision
Alt. #1. No additional Presidential action now.
Peterson
Hartmann - believes your position is already clear and
Congress should take the heat if it disregards
your position.
Train - believes additional actions could be counter
productive, particularly in the Senate.
Alt. #2. Prepare the following for my signature:
Zarb
Transmittal letter and bill to
Lynn
extend standards through 1981.
Morton
Seidman
Letters to Committee Chairmen
Greenspan
asking for hearings.
Cannon
FORD
COMPARISON OF ALTERNATIVE EMISSION STANDARDS
NOW UNDER CONSIDERATION
(grams per mile)
Model Year
HC
CO
NOX
Current Law
1975-76
1.5
15.0
3.1
1977
1.5
15.0
2.0
1978 on
.41
3.4
.4
President's Proposal
1977-81
1.5
15.0
3.1
House Commerce Subcommittee (Rogers)
1977
1.5
15.0
- 2.0
1978-79
.9
9.0
2.0
1980 on
.41
3.4
.4
Senate Public Works Subcommittee (Muskie)
1977
1.5
15.0
3.1
1978
.41*
3.4*
1.0*
1979
.41* *
3.4*
1.0*
1980
.41
3.4
1.0
1981
.41
3.4
1.0
*The Administrator of EPA would have authority to waive
these standards for up to 50% of the production of each
manufacturer in 1978 and 1979. Cars covered by waiver
would have to meet 1.5, 15.0 and 3.1 standards.
The Senate subcommittee has under consideration other actions
which would, in fact, make the standards more difficult to
meet, including:
Warranty covering 100,000 miles (rather than current 50,000)
with "normal" maintenance (apparently as contrasted with
current manufacturer prescribed, EPA approved maintenance).
Assembly line testing in addition to the current prototype
certification process.
STATUS OF MAJOR CLEAN AIR ACT AMENDMENTS PROPOSED BY THE
ADMINISTRATION AND POTENTIAL NEW PROBLEMS IN ACTIONS TAKEN
THUS FAR BY THE SUBCOMMITTEES
Status of Major Proposals
1.
Intermittent Controls
Proposal to allow power plants in isolated areas to
use intermittent controls (fuel switching, tall stacks,
or load changing) through 1985 -- if health standards
are not violated, rather than requiring permanent
controls (scrubbers or low sulfur fuel)
House subcommittee is considering a 1980 deadline.
Senate subcommittee is opposed to intermittent controls.
2.
Coal Conversion Amendments
Administration proposal to broaden and extend the
coal conversion program is not being accepted in the
House subcommittee. Senate subcommittee has not yet
acted.
3.
Significant Deterioration
The Congress is moving in the direction of strengthening
the role of the Federal Government in preventing "signifi-
cant deterioration" of air quality.
4.
Auto Emissions - Covered in Tab A.
New Requirements Being Added by Subcommittees (Examples)
1.
Adding an emissions fee of up to $5,000 per day for
stationary pollution sources that do not meet State
implementation plan requirements. Works against
intermittent control proposal. (House Subcommittee)
2.
Heavy duty trucks and busses would be required to meet a
90% reduction in emissions by 1979. EPA would have authority
to require retrofit of existing fleet. (Senate Subcommittee)
3.
New comprehensive air quality planning requirements would
require land use plans covering but not limited to (1)
assuring air quality is maintained, (2) indirect pollution
sources such as shopping centers, etc. Requirement that
plans have EPA approval would involve Federal Government
in local land use planning. Liberal planning grants for
COG's appears designed to get political support for proposal.
Allegedly viewed by Senator Muskie as substitute for
Land Use Bill. (Senate Subcommittee)
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JOHN C. COLVER. IOWA
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tales Senate
CARY MART. COLO.
M. BARR? MEYER. CHIEF COUNSEL AND CH:
IN PUBLIC WORKS
SAILEY CUARD, MINORITY CLEPK
JN. D.C. 20510
9, 1975
Honorable Gerald R. Ford
The President
The White House
Dear Mr. President:
We have discussed your July 26, 1975 request for a hearing on
} automobile emissions with the Members of the Committee on Public
Works. There is agreement that a hearing could be held if you desire
it. We believe, however, that there is certain information which you
should have before you.
If such a hearing is held, undoubtedly private and public groups
would also desire to be heard on the information presented. We
would be constrained to honor those requests. Such a situation would
entail postponing further Committee consideration of other issues in-
volved in the Clean Air Act It had been our hope to begin Full
Committee consideration of the Clean Air Act during the week of Sep-
tember 8 so that during that week and the following week, we could
develop and report the legislation for Senate consideration.
By reason of service on the Budget Committee, Senator Muskie,
Chairman of the Subcommittee, Senator Buckley, the Ranking Minority
Member and Senator McClure and Senator Domenici, two important
participants in the consideration of Clean Air Act Amendments. will
be required to address themselves to the Second Budget Resolution
which must be considered by the Congress by mid-October. If the
hearings you request are held, it is a reasonable certainty that the
Public Works Committee could not conclude its deliberations on the
Clean Air Act until late October or early November. This delay,
would, we suggest, cause severe problems for those who are regulated
by the Act, including the automobile industry.
The Honorable Gerald R. Ford
July 29, 1975
Page 2
Mr. President, if you have further counsel to give us in this
matter, we shall be pleased to receive it.
Truly,
Ranking Minority 180 Baker, Member Jr. Jennings Chairman Randolph Randolph
FORD
June
IMMEDIATE RELEASE
July 28, 1975
Office of the White House Press Secretary
THE WHITE HOUSE
TEXT OF LETTERS FROM THE PRESIDENT TO
THE CHAIRMAN, SENATE WORKS COMMITTEE
AND
THE CHAIRMAN, HOUSE INTERSTATE
AND FOREIGN COMMERCE COMMITTEE
July 26, 1975
Dear Mr. Chairman:
On June 27th, I transmitted to the Congress a
special message which described the conclusions
from a detailed executive branch review of the
air quality, health, energy, and consumer cost
implications of alternative automobile emission
standards. I recommended that 1975-76 standards
for automobile emissions be extended by the
Congress through model year 1981.
I believe it important that the Congress and the
public have a full opportunity to hear in detail
the findings of our studies and the basis for my
conclusions that existing standards should be con-
tinued. I recognize that the hearings held by your
subcommittee on auto emissions ended before our
studies were completed. I urge you to hold another
hearing on this matter so Administration witnesses
can present the findings.
Sincerely,
GERALD R. FORD
The Honorable Jennings Randolph
The Honorable Harley O. Staggers
Chairman
Chairman
Public Works Committee
Interstate and Foreign
United States Senate
Commerce Committee
Washington, D.C. 20510
House of Representatives
Washington, D.C. 20515
#
#
#
#
IMMEDIATE RELEASE
July 28, 1975
Office of the White House Press Secretary
THE WHITE HOUSE
TEXT OF LETTERS FROM THE PRESIDENT TO THE
SPEAKER OF THE HOUSE OF REPRESENTATIVES
AND THE PRESIDENT OF THE SENATE
July 26, 1975
Dear Mr. Speaker: (Dear Mr. President:)
On June 27, 1975, I transmitted a special message to
the Congress which described the complex problem of
setting automobile emission standards which strike
the best possible balance among our air quality, public
health, energy, consumer cost and other economic
objectives.
As indicated in that message, I have concluded that
automobile emmission standards should not be more rigid
than those applied to 1975 and 1976 model cars because
more rigid standards unnecessarily would increase car
prices, reduce gasoline mileage, and increase energy
demands. There is also the potential that tighter
standards would require emission controls that result
in new pollutants with serious health impact.
I am enclosing a draft of a bill which would implement
the recommendations described in detail in my June 27th
message. I urge prompt passage of this bill.
Sincerely,
GERALD R. FORD
# # # #
A BILL
To amend the Clean Air Act to continue 1975-76 Federal
automobile emission standards through the 1981
model year to permit a balance among the important
objectives of improving air quality, protecting
public health and safety, and avoiding unnecessary
increases in consumer costs for automobiles,
decreases in gasoline mileage, and increases in
the Nation's dependence on imported oil.
Be it enacted by the Senate and the House of
Representatives of the United States of America in
Congress assembled,
Sec. 2. The Clean Air Act, as amended, is amended as
follows:
(a) Section 202 (b) (1) (A) is amended to delete therefrom
"1977" and insert in lieu thereof "1982."
(b) Section 202 (b) (1) (A) is further amended to delete
the last sentence therefrom and insert the following
sentence in lieu thereof:
"The regulations under subsection (a) applicable to
emissions of carbon monoxide and hydrocarbons from light-
duty vehicles and engines manufactured during model years
1975 through 1981, inclusive, shall contain standards
which are identical to the interim standards which were
prescribed (as of December 1, 1973) under paragraph (5) (A)
of this subsection for light-duty vehicles and engines
manufactured during model year 1975.
(c) Section 202 (b) (1) (5) is amended to read as
follows:
"The regulations under subsection (a) applicable to
emission of oxides of nitrogen from light-duty vehicles
and engines manufactured during model years 1975 through
1981 inclusive shall contain standards which are identical
to the standards prescribed (as of December 1, 1973) under
subsection (a) for light-duty vehicles and engines manu-
factured during model year 1975. The regulations under
subsection (a) applicable to oxides of nitrogen from
light-duty vehicles and engines manufactured during or
after model year 1982 shall be established at such level
as the Administrator determines is appropriate considering
air quality, energy efficiency, availability of technology,
cost, and other relevant factors. The Administrator shall
publish for public comment no later than July 1, 1977,
proposed standards for 1982 model year light-duty vehicles
and engines and his tentative conclusions with respect to
the matters he is required to consider under this paragraph
and shall publish his final standards and his findings no
later than July 1, 1978. Such standards may be revised
after appropriate notice following such date based upon
substantial changes in any of the factors the Administrator
is required to consider under this paragraph.
X
the
DRAFT #1
Dear Senator Randolph (Senator Baker)
Thank you for your prompt consideration of my request
that your Committee hold additional hearings on the
matter of automobile emission standards ,particularly
to consider the bill I have proposed to extend current
Federal standards through the 1981 model year].
The review that has been completed within the executive
branch considered the implications of alternative automobile
emission standards for 1977 and future years on air quality,
health, consumer costs, gasoline mileage and other energy
goals. I believe a discussion of our findings by
Administration witnesses would be an important addition
to the hearings held previously by your Subcommittee on
Environmental Pollution.
I understand and fully support your view that witnesses
in addition to those from the Administration should be
heard if you decide to hold hearings. Your decisions
will have an affect on many Americans and a full public
discussion of all points of view is necessary if we
are to find the best possible balance among
objectives
for improving environmental quality, protecting public
health and safety and avoiding unnecessary increases in
consumer prices, decreases in gasoline mileage and
increases in dependence on imported oil.
I also understand your concern about the potential
problems that a delay in action on Clean Air Act
Amendments would have on the automobile manufacturers
and others who are regulated by the Act. We must work
together toward final action on legislation so as
to avoid the need for changes in design or production
that result in higher consumer costs or in production
delays that result in unemployment.
2
I would like to suggest for your consideration an
approach that should minimize and possibly avoid delay
in completing action on amendments. My suggestion is
that you consider (1) proceeding on your original
schedule for Committee and full Senate action on all
necessary amendments, except those dealing with automobile
emissions; (2) scheduling hearings, limited only to
the issue of auto emissions, for the earliest practicable
dates to hear Administration, public and private witnesses;
and (3) handling auto emission standards in a separate
bill, perhaps on an expedited basis, because of the
special importance of early, final action on these standards.
10
Please be assured that members of my Administration and I
are prepared to cooperate fully to assure action and
to work with you in finding the best possible balance
among the important objectives that are affected by
the decision on auto emission standards.
Sincerely,