Ask the Scholar

Document scope · 1 page
doc
Scholar
Ask about this object, its catalog metadata, its source description, or the page inventory. For page-specific OCR and visual context, open one of the page chats.

Scholar Source Context

Document identity
localId
120360845
label
Mobile Source Provisions
core
doc
dtoType
document
pageCount
1
Source metadata
Source extras
naId
120360845
levelOfDescription
fileUnit
otherTitles
42-t-7432005-20120769F-Seg2-037-007-2018
recordType
description
ocrSource
nara-archive
Single page context
seq
1
pageIndex
0
type
document
mediaId
51d01dccd8cd297f
ocrText
FOIA Number: 2012-0769-F FOIA MARKER This is not a textual record. This is used as an administrative marker by the William J. Clinton Presidential Library Staff. Collection/Record Group: Clinton Presidential Records Subgroup/Office of Origin: Council on Environmental Quality Series/Staff Member: Kathleen (Katie) McGinty Subseries: OA/ID Number: 2897 FolderID: Folder Title: Mobile Source Provisions Stack: Row: Section: Shelf: Position: S 61 6 3 1 WAGNER COMMUNICATIONS 23 February 1990 Ms. Katy McGinty c/o Senator Gore 393 Russell SOB Washinton, D.C. 20515 Dear Katy, Enclosed are the two proposed amendments EMA and Cummins desire incorporated into S.1630: a provision providing for three years of stability between regulatory modification to emmission standards and a clarification of 5.0gbh Nox as the regulatory standard between 1991-1997. These amendments are important primarily because of their impact on the industries ability to develop captial investment and R & D programs. Your help is much appreciated in incorporating these considerations into the clean air bill. Kind Caml Regards Carl R. Wagner Enclosures Engine One Illinois Center ema Manufacturers 111 East Wacker Drive Chicago. Illinois 60601 Association 312/644-6610 PROPOSED AMENDMENT TO ) OXIDES OF NITROGEN TITLE II OF S. 1630 ) Position: The Committee Bill should be clarified to specifically indicate its intent to retain EPA's 5.0 gbh. NOx standard for heavy-duty truck engines until the statutorily mandated 4.0 gbh. standard is imposed. Rationale: Without a clarification as to the intent of S. 1630, EPA must revisit, and possibly revise, the NOx standard for heavy-duty engines in 1994 and 1997. Inasmuch as the 1991 NOx standard was promulgated under EPA's revision authority, EPA is obligated to revisit the NOx standard every three years and determine whether it can be reduced further. Such a requirement conflicts with what we believe is the Committee's intent to maintain the 5.0 gbh. NOx standard until the statutorily mandated reduction to 4.0 gbh. takes effect. The heavy-duty diesel engine industry needs the certainty and stability of the time periods established for NOx reduction and particulate reduction in order to commit their limited resources to meeting the technological challenge of stringent reductions in either NOx or particulate emissions already scheduled for 1991 and 1994 and, thereafter, as mandated by S. 1630. In order to avoid the imposition of an unnecessary review process on EPA or a costly interim regulation on the industry, Congress should add to Table 2 in Section 201 a specific reference to the 5.0 gbh. NOx standard beginning in 1991. Alternatively, Congress should clearly express its legislative intent that EPA maintain the currently promulgated heavy-duty emission standards until the proposed statutory standards go into effect. Proposal: On page 283 of S. 1630, the heavy-duty trucks portion of Table 2 is amended by inserting a new NOx provision: NOx 1991-1997 5.0 gbh. ? / table says 4.0 1996- Engine One illinois Center cma Manufacturers 111 East Wacker Drive Chicago. Illinois 60601 Association 312/644-6610 PROPOSED AMENDMENT TO ) PERIOD OF STABILITY TITLE II OF S. 1630 ) Position: The Committee Bill should provide for a minimum three-year period of stability between the imposition of the statutorily mandated 4.0 gbh. NOx standard, and any possible future revisions. Rationale: Under Section 202 (a) (3) (B) of the Clean Air Act, EPA is allowed to impose new NOx emission standards as often as it likes. In fact, EPA is compelled to review, and possibly revise, the NOx standard at least every three years. EPA should not be forced to undertake what may be a costly and unnecessary review process. And, the industry should not be jeopardized by too frequent incremental changes in standards. It is critical to the well-being of the U.S. economy that there be a strong, competitive domestic heavy-duty engine industry. Since 1979, that industry has been faced with five serialized reductions in emission standards, including a major change in test requirements. As a result, manufacturers have committed capital expenditures of approximately $1 million per test cell. Moreover, the costs of compliance have escalated from tens of millions of dollars in the early 1980's to hundreds of millions of dollars for compliance with EPA's 1991 emission control program. These costs must be absorbed by an industry characterized by mature markets, fierce foreign and domestic competition, financial realignment and restructuring, and cost-conscious customers. The last decade has left the industry financially exhausted. The heavy-duty engine industry cannot survive another decade of too frequent, serial reductions in emissions. Adequate time and resources must be dedicated to ensure the production of reliable and durable products that meet the Nation's emission goals. It is critical that the industry be given time to recover its resources before being required again to spend hundreds of millions of dollars on incremental emission control. Proposal: The Clean Air Act should be amended to provide for a minimum three-year period of stability between the statutorily mandated 4.0 gbh. NOx standard and any subsequent change in the NOx standard. Section 202 (a) (3) (B) of the Clean Air Act should be amended to read: " The Administrator may, after notice and opportunity for a public hearing, promulgate emission regulations revising any standard prescribed as provided in subparagraph (A) (ii) for any class or category of heavy-duty engines or vehicles. Such standard shall apply only for a minimum the period of three model years beginning four model years after the model year in which such revised standard is promulgated." R SSDA SERVICE STATION DEALERS OF AMERICA AMY R. LITTLEFIELD Director of Government Affairs 499 SOUTH CAPITOL STREET. SW WASHINGTON, DC 20003-4013 TELEPHONE: (202) 479-0196 THE DASKAL LAW FIRM DIMITRI G. (JIM) DASKAL Attorney & Counselor at Law General Counsel- - Service Station Dealers of America Tennessee Retual basoline Dables Asso, 325 PENNSYLVANIA AVENUE S.E. WASHINGTON, DC 20003 TELEPHONE: (202) 675-6300 107(b)(2) - rod back to SEVERE m-Co OPW Wheston } nozzles * are sure they High COn @ aut get the rolled } talked to back (wld Dr. demorrated like u Wid ratter have on bd Controls = or is expensive as are said Mr denguars 5 Bristo' SULLIVAN HANCOCK MONTGOMERY CLAY CLAIBORNE HAWKINS Kingsport PICKETT JOHNSON MACON STEWART Clarksville ROBERTSON SUMMER SCOTT CAMPBELL Johnson City JACKSON FENTRESS CARTER LAKE OBION OVERTON UNION HENRY rr ORANGEAMBLEN Morristown WEAKLEY HOUSTON SMITH GREENE Nashy TROUSDALE ANDERSON WASHINGTON UNICO! Davidson DICKSON PUTNAM MORGAN WILSON KNOX JEFFERSON DYER 8 BENTON DAVIDSON 6 CUMBERLAND DE KALB Knoxville COCKE HUMPHREYS Oak WHITE CARROLL GIBSON WILLIAMSON CROCKETT HICKMAN RUTHERFO 4 Ridge ROANE SEVIER ORD CANNON VAN LOUDON BLOUNT LAUDERDALE WARREN BUREN HENDERSON PERRY RHEA DECATURE Ciliumbia Jackson HAYWOOD LEWIS MADISON MAURY BEDFORD COFFEE TIPTON MEIGS 2 MCMINN CHESTER GRUNDY MONROE SHELBY FAYETTE HARDEMAN WAYNE MOORE MARION POLK 9 MARDIN GILES MCNAIRY LINCOLN FRANKLIN LAWRENCE HAMILTON /3 BRADLEY Tennessee JOESPH L. KOACH, CAE Executive Director Affiliates: SSDA ALABAMA SERVICE STATION DEALERS ASSN. SERVICE STATION DEALERS OF AMERICA ARIZONA UNITED SERVICE STATION DEALERS ASSN. SERVICE STATION DEALERS OF ARIZONA SERVICE STATION DEALERS January 19th, 1990 499 South Capitol St., SE, Suite 407 Washington, DC 20003 OF ARKANSAS CALIFORNIA SERVICE STATION (202) 479-0196 & AUTO. REPAIR ASSN. NORTHERN CALIFORNIA PETROLEUM RETAILERS ASSN. SOUTHERN CALIFORNIA SERVICE STATION ASSN. COLORADO SERVICE STATION DEALERS ASSN. CONNECTICUT-RHODE ISLAND GASOLINE RETAILERS & Dear Senator : GARAGE OWNERS ASSN. SERVICE STATION DEALERS OF FLORIDA FLORIDA GASOLINE RETAILERS On behalf of your local service station dealers, we are writing to & GARAGE OWNERS ASSN. HAWAII AUTO. & RETAIL express our strong opposition to the mandate of Stage II vapor GASOLINE DEALERS recovery in S. 1630, The Clean Air Act Amendments. IDAHO SERVICE STATION ASSN. ILLINOIS GASOLINE These radical provisions would extend Stage II to many small DEALERS ASSN. INDIANA AUTOMOTIVE rural and urban areas in your state. If passed as written, the bill SERVICE ASSN. MIDWEST SERVICE would force thousands of dealers nationwide, including many of STATION ASSN. KENTUCKY GASOLINE your constituents, to close their businesses. DEALERS ASSN. BAYOU STATE GASOLINE Stage II currently costs at least $2,000-5,000 per nozzle to put in RETAILERS ASSN. GREATER WASHINGTON/ and $4500 per year to maintain. These costs will only increase due MARYLAND SERVICE STATION to equipment and labor shortages caused by the widespread & AUTO. REPAIR ASSN. BAY STATE GASOLINE installation of Stage II. RETAILERS ASSN. MINNESOTA SERVICE Unfortunately, the report accompanying this bill is totally STATION ASSN. PRO AUTOMOTIVE ASSN. OF divorced from reality. Claims that Stage II reduces the risk of station MISSOURI & KANSAS AUTOMOTIVE TRADES OF fires is ludicrous at best. The only accurate statement is "The station MONTANA NEVADA GASOLINE RETAILERS owner or operator is subject to penalties for failure to implement a TRI-STATE GASOLINE & AUTO. DEALERS ASSN. OF MAINE. Stage II system." Let's look at some of the "Senate Report Myths" NEW HAMPSHIRE & VERMONT SERVICE STATION DEALERS ASSN. OF NEW MEXICO Myth #1: Stage II is Cheap and Cost Effective NEW YORK STATE ASSN. OF SERVICE STATIONS The Committee assumed Stage II costs $12-18,000 to install NORTH CAROLINA SERVICE STATION ASSN. at a typical 12 nozzle station. The actual costs are DOUBLE that NORTH DAKOTA RETAIL GASOLNE DEALERS ASSN. ($24-36,000) and these costs will only increase. OHIO CONFERENCE OF SERVICE STATION DEALERS ASSNS. The $700-1,000 per ton VOC reduction cost-effectiveness OREGON GASOLINE number is based on this long-outdated installation cost. It also DEALERS ASSN. PETROLEUM RETAILERS & AUTO. assumes a 92% efficiency rate which is a laboratory, not a real REPAIR ASSN. OF PENNSYLVANIA world number. It disregards that fact that consumers do not properly SERVICE STATION & AUTO. REPAIR ASSN. OF use Stage II, which requires that you hold the nozzle in for about 10 PENNSYLVANIA/DELAWARE SOUTH CAROLINA SERVICE seconds after you finish pumping gas. California studies show that STATION DEALERS ASSN. TENNESSEE RETAIL GASOLINE the vast majority (over 90%) of motorists do not do this. DEALERS ASSN. TEXAS SERVICE STATION ASSN. It disregards the fact that the equipment breaks down with LONE STAR SERVICE STATIONS ASSN. clockwork regularity. PETROLEUM RETAILERS It disregards the fact that consumers can easily defeat the ORANIZATION OF UTAH VIRGINIA GASOLINE & AUTO. nozzle by holding the boot with their fingers. It also assumes that REPAIR ASSN. VIRGINIA SERVICE STATION & delivery drivers will hook up vapor return lines to carry vapors to the AUTO. SERVICES ASSN. AUTOMOTIVE UNITED TRADES terminals. ORGANIZATION WEST VIRGINIA GASOLINE In sum, the numbers you have been given in the Senate Report DEALERS & AUTO. REPAIR ASSN. are completely unrealistic. The implications for your constituents WISCONSIN RETAIL GASOLINE & AUTO. TRADES ASSN. could not be greater. OFFICERS EMMETT PROBUS DENNIS HEIL DENNIS DeCOTA DON JOHSTONE MARY ANN RAGONA President First Vice President Second Vice President Third Vice President Treasurer Louisville, KY Wausau, WI San Anselmo, CA Indianapolis, IN Patchogue, NY Myth #2: The Consumer Acceptance Problems with Stage II Have Been Solved The Committee bases this statement on a 1984 statement by a prominent auto industry contractor. This is again, ludicrous. We invite you to see the "latest and greatest" Stage II equipment here in D.C. "User Friendly" Stage II equipment just installed in New York and New Jersey has moved comedians David Letterman and Andy Rooney to comment on just how "user friendly" it is. The inconvenience costs alone to your constituents amount to $4,106.25 per nozzle per year. This does not include the costs of gasoline spills on clothes, shoes, car finishes, and skin caused by the nozzle. Clearly, requiring Stage II would be viewed as an unfriendly act by your constituents. Myth #3: Stage II Can Be Installed In All These Areas Within 3 Years This is the biggest misconception of all. For example, in New York and New Jersey, even under a two-year, court imposed deadline, Stage II is not fully in place due to shortages of both equipment and qualified personnel. A program on the scope proposed by S. 1630 will take at least 5-7 years. We must ask, where does this Committee expect a dealer to get the money from? Our members have an average net worth of $81,000. Stage II will eat half of that up. Banks won't lend to us due to fear of inheriting environmental liability. We are already spending tens of thousands of dollars on 7 other environmental initiatives, including underground storage tanks. Our well is now dry. Neither your consumers nor your dealers can afford to put good money into a program that former EPA administrator Lee Thomas called "A costly technological redundancy that will do little to solve the ozone non-attainment problem." We urge you to vote against mandatory Stage II vapor recovery. Sincerely, Joseph Joseph L. Koach, L. Roach. CAE D.G.Dasked Jim Daskal, Esq. Executive Director General Counsel amyR Littlefille Amy R. Littlefield Director of Government Affairs Center for Auto Safety 2001 S Street N w_ Suite 410 Washington D.C. 20009 (802) 328-7700 March 20, 1987 Lee Thomas, Administrator U.S. Environmental Protection Agency 401 M St., SW Washington, DC 20460 Dear Mr. Thomas: In an effort to combat serious ozone problems plaguing many regions of the country and the dangerous health effects of benzene, the Environmental Protection Agency (EPA) is currently considering methods of reducing evaporative emissions, which consist primarily of gasoline fumes generated during motor vehicle refueling. While EPA analysis shows that modification of existing, so-called "onboard", emission controls on automobiles would yield the greatest reductions in evaporative emissions, automobile manufacturers have argued the changes would be dangerous. These "safety" arguments are overstated and EPA should not delay requiring vitally needed onboard controls. If anything, EPA's combined package of fuel volatility and onboard controls will reduce the risks of fire incidents in automobiles. Crash Fire Safety A central argument put forward by those opposing onboard controls is that the proposed changes would make vehicles more susceptible to post-collision fires. Post-collision fires have already been reduced in vehicles made subsequent to the September 1, 1976 effective date of the National Highway Traffic Safety Administration's (NHTSA's) Federal Motor Vehicle Safety Standard (FMVSS) 301, for post-collision fuel system integrity. This improvement in crash fire safety is all the more significant since it was made on vehicles with onboarc evaporative emission controls similar to those proposed by EPA. This assessment is based on review of automobile defect investigations conducted by the NHTSA, consumer complaints received by NHTSA and the Center, and attorney information requests received by the Center. A 1981 Society of Automotive Engineers technical report shows that only "one in every 15 reported burn injuries associated with motor vehicles results from a crash. [1] By these indicators, FMVSS 301 has been effective in preventing post-collision fires. The emissions cont: modifications EPA proposes are not new and in fact are quite S1 Car to what has been used on cars since 1971. Vehicles current use a system consisting primarily of 1/4 inch lines which transport fuel vapors to a charcoal canister used to absorb the vapors. In a submission to the NHTSA, General Motors indicated that major modifications to this system would 1: "Motor Vehicle Non-Crash Fires, Peter Cooley, SAE No. 810012 (1981) include enlarging the current vapor lines to about 5/8 inches, increasing the capacity of the canister and adding a valve to separate the gas tank and vapor lines. Thus GM's main post- collision safety concerns seem to be with slightly enlarging components which currently meet NHTSA's fuel system integrity standard FMVSS 301. In a May 12, 1986, letter to you, NHTSA Administrator Diane Steed wrote: FMVSS 301 is a performance standard that does not dictate the design of an automobile's fuel system. FMVSS 301 requires a vehicle to withstand frontal, side, and rear impacts without subsequent substantial fuel leakage in simulated post-crash rollover positions. Most of the vapor control systems that we reviewed do not appear to require "exotic" changes to the vehicle. A March 27, 1986 letter from Ms. Steed to Congressman John Dingell also pointed out that FVMSS 301 was: a performance standard and, assuming current crash test compliance can be met by the particular on- board system a manufacturer may choose, may simply mean that the costs and benefits of the vapor controls can be assumed at a constant level of crash safety. Rigorous NHTSA testing for compliance with FMVSS 301 will assure continuance of present levels of crash fire safety. Crash fire safety in the future depends not upon this EPA rulemaking but upon NHTSA's efforts to upgrade FMVSS 301. Technology exists to prevent fires in barrier collisions up to 50 MPH as opposed to the present 30 MPH requirement. In addition to gas tank and fuel line placement, such technology includes: fuel bladders, expanded mesh within the tank, self-sealing breakaway valves at critical locations within the fuel system, and reinforcement of fuel lines. (For a complete summary of advanced fuel systems that would sharply reduce even the present low levels of auto crash fires, see Attachment A, "Fuel-Fed Vehicle Fires, by Center for Auto Safety staff.) Fire Safety Improvements From Fuel Volatility Controls Aside from post collision fires, automakers have also described the potential I I fuel tank overflow and fuel spitback during refueling. Fuel overflow describes the potential failure of the automatic nut-off mechanism used to stop the flow of gas when the fuel tank is full. While, as occasionally occurs on today's cars, fuel spit: involves overpressurized fuel spurting from the filler neck when the pump nozzle is removed after refueling. The Center agrees with EPA that these potential problems can be addressed by straight forward engineering solutions. General Motors, for example, appears to have already developed overfill protection and a method of providing indication of overfill for both liquid and mechanical filler neck seals. [2] In addition to vehicle changes, EPA has proposed several non-vehicle requirements to control factors which will reduce fire hazards. These include reducing gasoline volatility and improving fuel pumps. Fuel spitback, especially, can be mitigated both by limiting pump flow rates and setting stricter volatility limits. The need for volatility limits is graphically exemplified by a serious fuel-spurting defect currently affecting 1984-86 Ford ambulances and vans. Ford has repeatedly indicated that higher vapor pressure contributes to the fuel-spurting problem. [3] Since 1970, the Center for Auto Safety has been an outspoken advocate of safer vehicles and critic of designs which compromise safety. In the matter of requiring onboard controls, full implementation of the safeguards described above will not reduce safety and, if stricter volatility limits are set, will actually result in safety improvements. We have no doubt that onboard controls will reduce the serious health problems associated with evaporative emissions. Sincerely Clarence Chou M. Ditlow Executive Director Robert Dewey Vehicle Safety Staff 2. Attachment B is an excerpt from a March 24, 1986 letter to NHTSA from General Motors summarizing industry progress on onboard technology. 3. Attachment C is documentation describing the impact of high volatility gasoline on the Ford ambulance and van problem. KIMBRO SERVICE COMPANY LIGHTING SERVICE PETROLEUM SERVICE P.O. BOX 23089 NASHVILLE, TENNESSEE 37202 (615) 320-1343 January 25, 1990 Don Saddler 5025 Charlotte Ave. Nashville, Tennessee 37209 Re: Stage 2 Vapor Recovery System. Dear Mr. Saddler: Kimbro Service Company proposes for your review, to install Stage 2 Vapor recovery system on four multihose dispensers. This price includes retrofiting four multihose dispensers and necessary underground piping. PRICING Kimbro Service Company's fee to provide the necessary equipment, materials and labor to install a Stage 2 vapor recovery system will be: Price $29,877.34 (plus applicable sales or use taxes) Note: The utilities will be notified before the work is to begin. However, Kimbro Service Company will assume no liability for damage done to unknown underground obstructions or damage caused by acts of nature. William Sincerely, G. Vaughar. William G. Vaughn Jr. Operations Manager 12 nozzles - Petroleum Division Kimbro Service Company Nashville NISSAN Nissan Motor Manufacturing Corporation U.S.A. Jerry L. Benefield President and Chief Excentive officer March 5, 1990 The Honorable Albert Gore, Jr. United States Senate 393 Russell Senate Office Building Washington, DC 20510 Dear Al: It looks like the automotive fuel economy issue will soon -- perhaps as soon as tomorrow -- be taken up by the Senate. Although the Senate leadership compromise on Clean Air would delete any fuel economy provision from S. 1630, Senator Bryan nevertheless says he intends to offer an amendment imposing dramatically higher, discriminatory fuel economy standards along the lines of S. 1224. It is hard for me to imagine that Senator Bryan can succeed in thwarting the will of the leadership of both parties, but the threat that his percentage improvement approach to fuel economy poses to us is SO great that we must take his effort very seriously. We realize that addressing the threat of global warming is among your highest priorities and we understand that you are also concerned about our nation's energy security. I am confident -- between my testimony before the Consumer Subcommittee in September, my letter to you of January 22 (copy attached), and my staff's several conversations with yours -- that you understand how great a problem a discriminatory approach to fuel economy regulation is for us. We are gratified to know that you are working on an alternative approach to fuel economy regulation that will be neutral in its competitive consequences. Until your efforts bear fruit and you are in a position to put forward a better approach for the Senate's thorough consideration, we both are confronted with Senator Bryan's amendment. We hope you can find a way to voice your advocacy of prompt congressional action on the issues of global warming and energy security while taking a position against the Bryan amendment as the wrong approach. Nissan Drive Smyrna, Tennessee 37167 (615) 159 The Honorable Albert Gore, Jr. Page 2 March 5, 1990 In one of our conversations with your staff, they raised the question of a possible conflict between Nissan and Saturn on this fuel economy issue. I can assure you that on the matter of the Bryan amendment, we and the Big Three are of one mind. The entire industry is vigorously urging its defeat. I know this issue puts you in a tough spot, Al. It puts us in a pretty tough spot, too. I hope you can help. Sincerely, Juny Burfald Jerry L. Benefield JLB: jd Enclosure NISSAN Nissan Motor Manufacturing Corporation U.S.A. Jerry L. Benefield President and Chief Executive Officer January 22, 1990 The Honorable Albert Gore, Jr. United States Senate 393 Russell Senate Office Building Washington, DC 20510 Dear Al: I am writing on the eve of Senate debate on the Clean Air Act to ask for your help on a matter of the greatest importance to our company. After hearing my testimony last September, and I hope hearing reports of the several meetings my staff has had with yours in the months since, I don't think my message will surprise you. In the coming debate, Senators concerned about the impact of S. 1630 on the auto industry will raise strong objections to a number of provisions in the bill. These will include the very presence of co₂ (fuel economy) standards, the stringency of "tier two" tailpipe standards, the problems that "on board" vapor recovery presents, and a number of others. Naturally we share some of these concerns. While these concerns are not a matter of indifference to us, an overwhelming threat that confronts us is the specter of discriminatory fuel economy standards. That threat comes in the form of S. 1224, which Senator Bryan may offer as a substitute for the CO₂ standards of S. 1630. Our position in the coming debate is straightforward. We oppose S. 1224 and discriminatory fuel economy standards in whatever guise they may arise. We are asking you to oppose them. We are not asking you to take a position on any other issue in the Senate floor debate. In my testimony in September, I explained how S. 1224 would put our company at a severe competitive disadvantage. You grasped our predicament immediately; I will not repeat here what you already know. We were heartened by the reservations you voiced at the hearing about the percentage-improvement approach and encouraged by your search for an alternative. We believe that search holds promise but every indication we now have suggests that the only choice you will face in the Clean Air Act debate will be between the uniform co, standards of S. 1630 and the discriminatory approach of S. 1224. We urge you to support uniform standards as opposed to the percent improvement approach. Nissan Drive Smyrna, Tennessee 37167 (615) 459-1433 The Honorable Albert Gore, Jr. Page 2 January 22, 1990 I do want to take this opportunity to summarize the public policy case against S. 1224. S. 1224 is bad regulatory policy. Setting different standards for different companies would constitute a dramatic departure from our Government's traditional, even-handed regulatory philosophy. The bill would send an unambiguous signal to every company subject to government regulation: never exceed standards because of the risk that superior performance will be used against you. S. 1224 is bad competitiveness policy. You yourself have voiced the concern that this attempt to put high mileage manufacturers at a competitive disadvantage could ultimately boomerang on the Big Three by creating strong incentives for only high mileage; i.e., foreign- based, manufacturers to push the pace of technological progress to the maximum. S. 1224 is bad trade policy. Discriminatory standards would violate U.S. international obligations under both the GATT and the GATT Standards Code. In a year when the highest U.S. trade policy priority is bringing to a successful conclusion the Uruguay round of trade negotiations which we hope will impose new obligations on other countries in areas of the greatest importance to the United States such as intellectual property protection, it makes no sense for the United States to ignore its own existing obligations. These considera- tions persuaded the Senate Environment and Public Works Committee not to take up an amendment to S. 1630 to adopt discriminatory co₂ standards. S. 1224 would be self-defeating. The near certain effect of the bill would be to shift market share from high-mileage to low mileage manufacturers. The reason is that since high mileage manufacturers already utilize existing fuel saving technologies, to meet the bill's standards, they would have to offer for sale even smaller vehicles which consumers may not accept or adopt unproven and highly expensive technologies. Low mileage manufacturers, on the other hand, could downsize at lesser risk of consumer disfavor and could make greater use of existing fuel saving technologies. The point is that it is by no means clear that S. 1224 would result in lower total fuel consumption. We cannot confidently anticipate how the Clean Air debate will proceed. We assume that Senator Bryan now plans to offer S. 1224 as a floor amendment. We are confident Senator Bryan would carefully The Honorable Albert Gore, Jr. Page 3 January 22, 1990 consider your views on this matter. You are, after all, the Senate's leader on the issue of global warming. If you are in a position to discourage Senator Bryan from offering his bill as an amendment, we would certainly urge you to consider doing that. If S. 1224 nevertheless comes to a vote, we hope you will speak and vote against it. Your vote and your leadership will be critical to the outcome. Of course, the issue may never come to vote until a consensus compromise has been informally negotiated. At that point the vote will be pro forma. We understand that Senator Nickles and Senator Levin are working on a comprehensive substitute for the mobile source provisions of S. 1630 and that the Big Three and some others will endorse it. Among other things, the amendment would propose to delete any fuel economy standards from S. 1630. We have good reason to think that this amendment will not come to a vote, however. Its purpose will be to persuade the Majority Leader to broker a compromise. In such a negotiation, S. 1224 may be put forward. Discriminatory CO, 2 standards might be suggested as an alternative. We ask you to take an active role opposing the adoption of discriminatory fuel economy standards if such a negotiation takes place. Al, we understand the depth of your commitment to raising the consciousness of the Nation to the problem of global warming and your determination to fashion public policies to begin to address the threat global warming presents. We also understand your concerns about competitiveness. We are not asking you to compromise the integrity of your position on either issue. We never would. We have not often asked for your help but we need it on this one. We hope you can give it. Very truly yours, Jerry Jerry L. J JLB:jd United States Senate WASHINGTON, DC 20510 February 6, 1990 Dear Colleague: The health and welfare of Americans in virtually every state in the Nation is at risk because of air pollution. The simple act of breathing threatens the health of 3 out of every 5 citizens. Motor vehicles are the biggest culprit. An amendment expected to be offered by Senators Levin and Nickles would eliminate or make discretionary the second round of motor vehicle emission reductions and improved gas mileage required by S.1630. This would be a giant step backwards in the effort to reduce smog and prevent global warming. The vote on the Levin-Nickles amendment will be one of the most important environmental votes in memory. We urge you to join with us and vote against urban smog and global warming by voting against the Levin-Nickles amendment. The Levin-Nickles amendment may adopt the deal on motor vehicle emissions engineered by Congressman Dingell in the House. We do not believe that the "Dingell-Waxman" approach, or any similar approach, should be adopted by the Senate. That approach would not ensure motor vehicle emission reductions that are both needed and achievable. Under the Dingell-Waxman approach, even if the EPA found that the second round's standards were available, cost effective, and necessary, the Agency would not have to require these standards. The Agency could promulgate standards less stringent than called for by the second round, or adopt no new standards at all. The experience of the past 20 years suggests that EPA would not exercise discretionary authority to adopt the second round standards. For example, heavy-duty truck standards ordered by the 1970 Clean Air Act still have not gone into effect because EPA has been unable to overcome existing administrative hurdles. Many cities will continue to violate clean air standards without a second round of tailpipe standards. According to an analysis of the Office of Technology Assessment, even if all other pollution controls in S.1630 are fully implemented, 55 million Americans will still live in areas violating ozone health standards. ("Catching Our Breath"). Furthermore, it is questionable in many areas whether reductions comparable to those achieved by the second round of auto standards -2- are even feasible from other sources. Many consumer products, ranging from lawnmowers to all-purpose cleaners, might have to be banned entirely in order to achieve the hydrocarbon reductions available from the second round of auto standards. The smog problem in some cities is so severe that an ambitious alternative fuels program is essential. But alternative fuels are not a substitute for a second round of nationwide motor vehicle controls. Instead, alternative fuels are a useful supplement to the second round to enable the most polluted cities to achieve safe air. In addition, for the many cities not targeted by the alternative fuels programs which have been proposed, alternative fuels cannot replace the pollution reduction benefits available from the second round. For these cities, the cleanest conventional cars feasible are necessary in order to meet, rather than continue to miss, clean air attainment deadlines. Achievement of better gas mileage is one of the most significant steps we can take to slow the greenhouse effect. Carbon dioxide (CO2) is the major contributor to global warming, accounting for almost half of the global warming problem. Transportation sources are responsible for 30 percent of CO2 emissions. The 40 miles-per- gallon fuel efficiency standard required by S.1630 in 2000 is an important step Congress can take right now to combat global warming. This standard can be met with existing technology. Furthermore, improved gas mileage will lessen America's dependence on foreign oil, reduce our trade deficit, and help prevent further destruction of pristine areas. With your support for the required second round of auto emission reductions and fuel efficiency improvements offered by S.1630, Congress can make a down payment toward controlling global warming and deliver on the promise made to the American people in 1970 - safe air to breathe. Sincerely, Timothy L'. Wuth state J Ala Granton Marrymkeid Broel Adams J hile -3- 41.Ay Bill Patel Leahy Clairta Max Baucus Clina DM JimJufford BobPackwood P.d Kundy THE WASHINGTON POST THURSDAY, MARCH 1, 1990 A5 Senate, White House Negotiators Compromise on Auto Pollution Controls By Michael Weisskopf ation on the Senate floor on legislation that week, Mitchell threatened to take a bill to years that further emissions controls are the standards to remain intact for 100,000 Washington Post Staff Writer has deeply split Congress regionally and the floor by today whether or not a broad not worth the high price. miles. ideologically for a decade. agreement had been reached. Yesterday, he Instead, the administration proposed an The greatest change is in the second Senate and administration negotiators Only final agreement on acid rain has repeated the threat but said he was unsure ambitious program of alternative motor phase, which was automatic in the commit- struck a compromise yesterday on a com- eluded the "Group of 15," led by Senate Ma- if enough time remained for bill drafting. fuels that burn more cleanly than gasoline. tee bill. In the compromise, tougher tailpipe plex package of auto pollution controls as jority Leader George J. Mitchell (D-Maine), The auto agreement emerged yesterday The proposal called for 1 million cars that cutbacks would only kick in nationwide if 12 they neared completion of a broad agree- Senate Minority Leader Robert J. Dole (R- after two days of negotiation in a confer- could use alternative fuels to be made an- of the nation's 27 "seriously" polluted areas, ment designed to assure smooth and swift Kan.) and Roger Porter, President Bush's ence room off the Senate chamber. As many nually by 1997 and sold in the nine smog- including Washington, failed to achieve passage of clean air legislation in the Sen- domestic policy adviser. But Senate leaders as 10 car industry lobbyists at a time giest cities. By the year 2000, the fuels health standards for smog by the year ate. and Bush favor similar solutions to the prob- camped out in the marbled hallway until would have to burn as cleanly as pure meth- 2000. The cutbacks would be required by The breakthrough on tailpipe emissions lem and just began focusing on it yesterday early Tuesday and Wednesady mornings, anol, which is made of natural gas. 2004. A category of even smoggier cities resolved a major issue dividing the cost-con- to win the support of senators from pollut- ready to review the latest proposal brought No alternative fuels provision was ap- would have to implement a second phase in scious Bush administration, its Republican ing states. to them by Sen. Carl Levin (D-Mich who proved by the Senate committee, which their regions if they exceeded smog stan- dards by 25 percent. loyalists in the Senate and members of the Early Senate passage of a clean air bill is joined administration efforts to water down viewed them as helpful but no substitute for considered vital to intensify pressure on the the committee bill. tighter tailpipe standards. The committee The alternative fuels proposal was weak- key Senate committee that seeks more far- House, which has failed to move legislation Although emissions of the two ingredi- voted for stricter and earlier tailpipe cut- ened earlier. The compromise ensures the reaching controls. The agreement calls for beyond a subcommittee. ents of smog-hydrocarbons and nitrogen backs than the administration-39 percent continued use of gasoline by setting a stan- less stringent cutbacks in smog-forming Mitchell opened the talks Feb. 2 after oxides-have been dramatically reduced by for hydrocarbons and 60 percent for nitro- dard for alternative fuels weaker than pure emissions than the committee proposed for deciding that the bill reported by the En- the auto industry, they are still the primary gen oxides by 1993. And it called for anoth- methanol. 1993 cars, but it allows for the possibility of vironment and Public Works Committee source of the unhealthy pollution shrouding er 50 percent cut in each pollutant and car- Negotiators sought to offset the weaker more cutbacks, which had been opposed by faced too much opposition to survive a fil- nearly every U.S. city. bon monoxide by the year 2003. alternative fuel standard by requiring a the administration. ibuster by a coalition of Republicans who The administration originally proposed a Yesterday's compromise picks up the larger number of cars to run on the fuels— Together with other agreements nego- share the administration's concerns over single phase of tailpipe cutbacks by 1995- committee standards for the first phase but all new cars sold in the smoggiest nine tiated in recent days on alternative motor cost and senators afraid of the impact on 39 percent for hydrocarbons and 30 percent slows down the implementation, requiring a cities starting in 1994, instead of 1 million a fuels and industrial sources of smog and utilities and the coal, oil, steel and auto in- for nitrogen oxides. Administration officials 1993-1995 phase-in. And cars with 50,000 year by 1997. That assuages Detroit's fears airborne toxics, the auto accord helps as- dustries in their states. said that so much pollution already has been miles or more on them would not have to that it would be unable to sell alternative sure a large measure of bipartisan cooper- With negotiations bogging down late last squeezed out of the tailpipe in the past 15 run as cleanly. The committee bill called for fuel-cars in cities where there was a choice. QUENTIN N BURDICK NORTH DAKOTA CHAIRMAN DANIEL PATRICK MOYNIHAN NEW YORK JOHN H CHAFEE RHODE ISLAND GEORGE J MITCHELL MAINE ALAN K SIMPSON WYOMING MAX BAUCUS MONTANA STEVE SYMMS. IDAHO FRANK R LAUTENBERG NEW JERSEY DAVE DURENBERGER. MINNESOTA JOHN 8 BREAUX LOUISIANA JOHN W WARNER VIRGINIA HARRY REID NEVADA JAMES M JEFFORDS VERMONT BOB GRAHAM FLORIDA GORDON J HUMPHREY, NEW HAMPSHIRE JOSEPH I LIEBERMAN CONNECTICUT United States Senate DAVID M STRAUSS STAFF DIRECTOR ROBERT F HURLEY. MINORITY STAFF DIRECTOR COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS WASHINGTON, DC 20510-6175 February 26, 1990 Dear Colleague: I intend to offer an amendment to modify Section 218 of the pending Clean Air legislation, which now mandates the use of gasohol in areas that do not meet clean air goals. Section 218 could drain the Highway Trust Fund of at least $1 billion desperately needed to meet our nation's infrastructure needs. At the same time, it fails to appropriately address environmental needs. The provision as written has no place in the bill. My amendment has the support of the State and Territorial Air Pollution Program Adminstrators, the Associated General Contractors, Consumers for Competitive Fuels, and the Associated Builders and Contractors. I seek your support. Areas of the country that do not meet Clean Air standards -- so-called "nonattainment areas" -- are required by the bill to take special steps to reduce pollution. Some of these measures focus on reducing auto emissions, specifically carbon monoxide. Using fuels with added levels of oxygen -- so-called oxygenated fuels -- can help reduce carbon monoxide exhaust. Carbon monoxide reductions can be maximized without creating other environmental problems by setting an oxygen content of 2.7%. However, section 218 sets the required oxygen content of fuels in non-attainment areas at the unnecessarily high level of 3.1%. The only fuel that can meet that level of oxygen is gasohol. While achieving no meaningful increase in carbon monoxide reduction, the gasohol mandate would result in other forms of environmental damage. Gasonol is a highly volatile fuel. When used, it releases harmful hydrocarbons into the air. It thereby worsens the ozone non-attainment problems of many communities. Section 218 -- by legislatively mandating wide use of gasohol -- would result in a loss to the Federal Highway Trust Fund (HTF) of at least $1 billion annually, according to the Department of Transportation. The loss results from the deep tax subsidies favoring gasohol. Gasohol is subsidized through several sources, including an exemption from six cents of the nine cent Federal gas tax. This exclusion already costs the HTF almost $500 million in revenues annually and has cost more than $2.5 billion in transportation revenues over the last decade. With the gasohol mandate in section 218, the HTF could lose over $1.5 billion a year. At a time when infrastructure needs are so pressing, that loss of revenue would be devastating. Page 2 In addition to reducing support for highway construction, repair and rehabilitation, the gasohol mandate would reduce HTF support of mass transit. At the same time that the Clean Air act requires local governments to expand mass transit usage, to reduce auto emissions, section 218 would deprive local governments of needed federal mass transit assistance. That makes no sense. My amendment would require an oxygen content of fuels during winter months at 2.7%. This would achieve our carbon monoxide reduction goals without bleeding the HTF. It would allow other fuels, such as methanol-based methyl-tertiary-butyl-ether (MTBE), to be used in non-attainment areas. MTBE is not exempt from the gas tax, and therefore does not drain public transportation and highway spending. And, unlike gasohol, MTBE also can reduce hydrocarbons, and does not contribute to the ozone problem. The goal of an oxygenated fuels provision should be to enhance the condition of our environment, not to promote or mandate the use of any particular fuel. This view is shared by the State and Territorial Air Pollution Program Administrators (STAPPA), those charged with implementing clean air programs in the states. STAPPA has stated that any oxygenated fuels requirement should be "fuel-neutral, not favoring the use of one beneficial fuel over another. Unfortunately, section 218 does not meet this test. This amendment would result in comparable reductions in carbon monoxide levels throughout this country, while avoiding the devastating impacts on transportation funding that the provision now in S. 1630 would bring. As you know, there have been ongoing discussions off the floor to resolve a variety of concerns about the pending bill. I am hopeful that this problem can be worked out in these discussions. However, if it cannot, I intend to offer my amendment to section 218, and I urge your support. If you have any questions, please let me know, or have your staff contact Jeff Morales at 4-9721. Sincerely, Frank R. Lautenberg Suburbs polluting; Air pollution in the Metro area XEROX Emissions of volatile organic compounds in Nashville and the auto tests needed? surrounding counties. Figures are in tons per dry. Davidson 156 By J. Patrick Willard reducing emissions would be an Ruthoriord 45.6 Banner Staff Writer 2/15 expanded or enbanced auto emis- sions inspection program like the Summer 37.9 The seven suburban counties one now in effect in Davidson surrounding Davidson County pro- Williamson 24.67 County through MARTA. duce about as much air pollution "The possibility is there. It de- Wilson 20.27 as Nashville, according to a Uni- pends on the percentage reduction versity of Tennessee study. needed," Stephens said. Robertson 15.97 The study will be used to deter- The study, required under the federal Clean Air Act, estimated Dickson 13.25 mine if automobile inspection pro- grams need to be expanded into volatile organic compound emis- Cheatham 9.85 2-14-90; the suburban counties, according sions for Davidson County totaled to Barry Stephens of the state's 156 tons for a summer day when Source: University of Tennossee study air pollution control division. the ozone standard was exceeded "This is the first big burdle that In 1988. The seven neighboring counties accounted for a total of comply with the Clean Air Act. 5:08 bad to be covered," Stephens told in a non-attainment area for ozone the state Air Pollution Control by the U.S. Environmental Protec- The study showed that mobile 167.5 tons during the same period. Board on Wednesday. He said the Those neighboring counties are tion Agency. The "nen-attain- sources, including automobiles ment" label means that the area and other vehicles, were responsi- board will next determine the em- Rutherford (45.6 tons), Summer issions reductions needed and then (37.9), Williamson (24.67), Wilson does not meet EPA standards. ble for about 54 percent of the vol- Under federal law the state atile organic compound emissions adopt regulations to meet those (20.27). Robertson (15.97), Dickson reduction goals. (13.25) and Cheatham (9.85). must take action in non-attain- He said among the options for The eight counties are included ment areas to reduce emissions to lease see AIR, page A-10 7365781 THOISST -ura reduce 01 moq mo dn umurp eq 10 am a next year. Regulations will then 0) experiments Surgapow cust County accounts for 47 percent use II childrent pue sq: -1100 mm MOU a assess the Nashville area. Davidson those with breathing difficulties, periments should be completed by Stephens said University of Ten- of carbon monoxide is emitted in Ozone poses a health hazard to -xa am pues Statements percent of the total. It showed that 892.4 tons per day "SUOZO шлор of 143mg in emissions needed in the area. Davidson County accounts for 43.5 pollution in the eight-county area. 01 read SOOA FOLL "30020 to cope mine the percentage of reductions emitted in the metropolitan area. bon monoxide and nitrogen oxide cre- equal of Supeaf e modeling experiments will deter- tons per day of nitrogen oxides The report also looked at car- are 10 pollutants in the area. He said the are There are an estimated 269.03 also lead to potential lung dam- Stephens said volatile organic in the Nashville area. 3122241867573 Air Wynn's International, Inc. 2600 EAST NUTWOOD AVENUE BOX 4370 FULLERTON, CALIFORNIA 92634 (714) 992-2000 TELECOPIER (714) 525-3392 CABLE ADDRESS WYNNS February 6, 1990 The Honorable Al Gore Senate Office Building Washington, D. C. 20510 Dear Al: It is my understanding the Senate Environment and Public Works Committee has approved a bill, S. 1630, which, if passed by Congress, could have disastrous consequences for the automotive business and ultimately the people of Tennessee because of the growing number of automotive-related jobs in our State. We at Wynn's support a responsible revision of the Clean Air Act, including motor vehicle emissions standards tougher than those currently in force. However, S. 1630 goes much too far. It would provide minimal benefits to the environment with a potential for a huge loss of jobs in Tennessee. I am informed that Senators Carl Levin (D-MI) and Don Nickles (R-OK) are developing a bipartisan approach to address the onerous motor vehicle provision in S. 1630. It is a more sensible approach to the problem. I urge you to support the Levin/Nickles approach to modify S. 1630 when the bill is taken up on the Senate floor. In the same vein, you should be aware that our Wynn Oil Company subsidiary has developed and patented a fuel supplement, WYNN'S EMISSION CONTROL, which reduces hydrocarbon and monoxide exhaust emissions. As you can see from the technical data enclosed, the results have been remarkable. Very truly yours, WYNN'S INTERNATIONAL, INC. Bml James Carroll President and Chief Executive Officer JC:jm Enclosures Clinton Presidential Records Digital Records Marker This is not a presidential record. This is used as an administrative marker by the William J. Clinton Presidential Library Staff. This marker identifies the place of a publication. Publications have not been scanned in their entirety for the purpose of digitization. To see the full publication please search online or visit the Clinton Presidential Library's Research Room. SAE The Engineering Society For Advancing Mobility Land Sea Air and Space ® 400 COMMONWEALTH DRIVE WARRENDALE, PA 15096 SAE Technical Paper Series 890828 Diesel Particulate Emission Control Without Engine Modifications- A Cost-Effective Fuel Supplement Mark S. Filowitz and Marcel Vataru Wynn Oil Co. International Congress and Exposition Detroit, Michigan February 27-March 3, 1989 Clinton Presidential Records Digital Records Marker This is not a presidential record. This is used as an administrative marker by the William J. Clinton Presidential Library Staff. This marker identifies the place of a publication. Publications have not been scanned in their entirety for the purpose of digitization. To see the full publication please search online or visit the Clinton Presidential Library's Research Room. STOP Wynn's® ® EMISSION CONTROL* Increase Fuel Economy Improve Engine Performance Reduce Black Smoke EPA Registered Emissions U.S. Patent No. 4,684,373 (additional patents pending) JOSEPH I. LIEBERMAN SENATE OFFICE BUILDING WASHINGTON, DC 20510 CONNECTICUT (202) 224-4041 COMMITTEES: STATE OFFICE: ENVIRONMENT AND PUBLIC WORKS ONE COMMERCIAL PLAZA GOVERNMENTAL AFFAIRS United States Senate 21st FLOOR HARTFORD, CT 06103 SMALL BUSINESS 203-240-3566 WASHINGTON, DC 20510 TOLL FREE: 1-800-225-5605 February 5, 1990 Dear Democratic Colleague: I appreciated the opportunity to talk with you at the Caucus STATES IN-> last week about the need for the second round of automobile tailpipe controls. I wanted to provide you with copies of the is SCreeked AD charts I used and briefly summarize the key points. grys First, transportation is the major source of our ozone and carbon monoxide pollution problems. Second, the contention by industry representatives that pollution from the tailpipes of cars has been reduced by 96 percent since 1970 presents a faulty picture. Unfortunately, while a car tested in the laboratory will show a 96 percent reduction, in reality the cars on the road only attain a 20 percent reduction in emissions from the 1970 levels. This is because cars actually on the road do not use the "ideal" fuel of testing conditions; the average person does not drive a vehicle in the same manner and under the same conditions as used during the test procedures; and the test procedures do not reflect the conditions during a hot summer day when the maximum ozone problems occur. The number of cars on the road and the number of miles driven continue to grow, offsetting much of the gain that has occurred. There are 140 million cars on the nation's highways today -- over 50 million more than in 1970, driving 140 million more miles per year. While many of these cars are on the road for 100,000 miles, under the current law they are only required to meet the cleaner air quality standards for 50,000 miles. The emissions from cars increase significantly after the first 50,000 miles. Third, it is misleading to claim that the reduction from the second round of standards is only two percent. That figure fails to take into account: * Stricter controls result not only in a reduction of hydrocarbons, but also reductions in oxides of nitrogen (NOx), a principal component of smog and carbon monoxide. Both of these pollutants pose severe health threats. -2- * Increases in both the number and use of automobiles will occur. Currently, Americans drive 25 billion miles each year, and this number is growing. The attached charts demonstrate that the impact of the second round is substantially greater in the years after 2004 because the stricter controls offset increased emissions from growth in vehicle miles traveled. In terms of the emissions from the tailpipe of the automobile alone when compared with today's levels, the second round of standards in S. 1630 will achieve a 52 percent greater reduction in hydrocarbons alone than the President's proposal. Moreover, the reductions in terms of tons of emissions eliminated from cars and light trucks are dramatic when compared with the President's proposal: over time, the reductions will be 1 million more tons of hydrocarbons per year, 1.2 million more tons of NOx per year, and 10.2 million more tons of carbon monoxide per year removed from the air. Fourth, the evidence before the Environment and Public Works Committee from the California Air Resources Board, the leading expert in this area and supported by the manufacturers of this equipment, establishes that the cost of these standards will be between $122-$132 per car. This cost is extremely cost-effective when compared with strategies states might have to adopt in the absence of emission reductions from the second round. According to the states, some of them might be forced to consider options such as eliminating all dry cleaners or some iron and steel manufacturers. Thank you for taking the time to review this issue. I would be glad to discuss the matter with you in further detail at any time. Sincerely, Joseph I. Lieberman Attachments (6) EXCESS CAR AND LIGHT TRUCK EMISSIONS FROM BUSH PROPOSAL OXIDES OF NITROGEN 2.4 2.2 BUSH 2 1.8 MILLION TONS PER YEAR 1.6 1.4 1.2 1 S.1630 0.8 0.6 0.4 0.2 0 2000 2005 2010 2015 2020 CALENDAR YEAR EXCESS CAR AND LIGHT TRUCK EMISSIONS FROM BUSH PROPOSAL HYDROCARBONS 3 2.8 BUSH 2.6 2.4 MILLION TONS PER YEAR 2.2 2 1.8 1.6 1.4 1.2 S.1630 1 0.8 0.6 0.4 0.2 0 2000 2005 2010 2015 2020 CALENDAR YEAR EXCESS CAR AND LIGHT TRUCK EMISSIONS FROM BUSH PROPOSAL CARBON MONOXIDE 21 20 BUSH 19 18 17 16 MILLION TONS PER YEAR 15 14 13 12 11 10 9 8 S.1630 7 6 5 4 3 2 1 0 2000 2005 2010 2015 2020 CALENDAR YEAR 0.5 0.4 HYDROCARBONS PERCENT 0.3 0.2 0.1 OXIDES OF NITROGEN 0 Fuel Combustion Sold Waste Disposal MISOELLANEOUS AREA Industrial Process TRANSPORTATION Additional Area 0.8 0.5 MOTOR VEHICLES REMAIN THE PERCENT 0.4 0.8 DOMINANT SOURCE 0.2 OF POLLUTION 0.1 0 Puel Contration Sold Waste Disposal MISCELLANEOUS AREA Industrial Process TRANSPORTATION Additional Area COST PER TON OF HC REMOVAL CURRENTLY IDENTIFIED STRATEGIES $26 $24 SOURCE: $22 $20 STAPPA $18 OTA $18 $14,500 (Thousanda) $14 $12 $10 $8 $7,000 $6,050 $8 $4,600 $4,800 $4 $2,127 $2 $0 TOP REASONABLY AREW TEX SPRAY COAT CONTROL 2 COMPUTION PART AUTO CAR & 10 BELACE 1 FOR AVALABLE ST THOMOU 1001 TAMPS 190 AUTO STANDARDS PROPOSALS - HC 0.5 0.4 BUSH X 0.3 X GRAMS PER MILE X S. 1630 0.2 CALIFORNIA 0.1 X X 0 1990 1994 1998 2002 MODEL YEAR 5 39 Bacbera Pennetor - alasha Enot Conver march pources want 2001 rosent anknorge r Failsoke pulpipe Co problem & melity stations onto of smke vehicles not puby to Hein I/M Serens receipe of have strchen Go there I/M hut 0) only every 3yrs. when stichers need h be parentd. will offer in amenhonent TN- same pitri pill Il M only n novethainment ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION BRIEFING SHEET SUBJECT: FEDERAL FACILITY COMPLIANCE PHOTOCOPY PRESERVATION Background: Currently, federal facilities in Alaska, including military facilities, comply with ADEC's stationary source requirements, as well as the local I/M programs operated in Fairbanks and Anchorage. However, military compliance with the I/M programs is a result of a substantial effort, including the involvement of Senator Stevens' office, to facilitate the cooperation of the military. An additional issue in military compliance are the vehicles which belong to military personnel stationed in an I/M program area but which are registered in other jurisdictions. With a registration- based compliance system, these vehicles do not become subject to the I/M program. After considerable effort in Alaska, we reached a 'gentlemen's agreement' with the base commanders that has resulted in emissions testing, either on-base or elsewhere, as a prerequisite for a base sticker. To our knowledge, this arrangement is unique to Alaska. There are a number of other nonattainment areas that have large numbers of either Federal or out-of-state vehicles that contribute to their air quality problems. Federal law does not require that the out-of-state vehicles operated by military personnel and their families conform to the same requirements as must other vehicles. Current compliance has been achieved because the present facility commanders have personally agreed to such. With the ongoing turnover in military personnel, there is no guarantee that future commanders will be so inclined. Added to this is the reluctance of the military authorities, in Alaska and elsewhere, to comply with other aspects of Clean Air Act activities (e.g., the furnishing of emissions data to local agencies) and with other federal laws. Therefore, it is our position that additional language is needed in section 118 of the Clean Air Act to specifically that such compliance is required. I A. 300r- D # : 322241887573 2023472416 55 -> 09 Te TO 1-30-90; 3:28 PM; XEROX TELECOPIER 295 ; The Mon. Max Baucus -2- other jurisdictions, they ware not subject to the State's I&M program. After considerable effort, we reached a resulted in on-base emissions testing as a prerequisite for 'gentlemen's agreement" with the base commanders that has 2 base sticker. While WE are pleased with the accommodation we have reached with our military neighbors, we wish to point out that to our knowledge, our arrangement is unique. A number of other nonattainment areas have large numbers of either federal or out-of-state vehicles that contribute to their air quality problems. In addition, we recognize that our arrangement is just that -- federal law does not require that the out-of-state vehioles operated by military personnel and their families conform to the same requirements am must other vehicles. Thus, we ask that you consider amending the Clean Air Act to provide for testing of these vehicles in nonattainment areas. Toward that end, the Alaska Department of Environmental Conservasion will be pleased to provide have ther informati developed on 1n concernine coopcration the with and ssions the 100A1 testing DAME program Enclosed with this letter 10 a summary of speoifio comments on provisions OI 8,1630 that directly affect carbon monoxide nona tainment areas. we ask that you take these comment into account -- you develop amendments to the Clean Air Act. Again thank you for spearheading this important bipartisan approach to reducing memor vehicie emi ions we look =0 antinuing you TOWNER with you and your committee meve markup of clean air TTPA COA I -0 Á HOVM ε # : TUMOR 0 4 [0 - : 31. 01. 2023472416 55 > 1-30-90; 3:27 PM; : XEROX TELECOPIER 295 TEVE COWPER GOVERNOR STATE ALASKA PHOTOCOPY PRESERVATION October 16, 1989 The Honorable Max Bauçus Chairman Senate subcommittee on Environmental Protection 458 Dirksen Senate Office Building Washington, D.C. 20510 Dear Mr. Chairman: We wish to express our appreciation for your introduction of the Clean Air Restoration and Standards Attainment Act of 1989 (S.1630). If enacted, this legislation will greatly aid the efforts of our communities to reach attainment of the National Ambient Air Quality Standards. We are very pleased to see the strong cold temperature carbon monoxide certification program that is contained in S.1630. As you know, the State of Alaska has consistently maintained that until cars and trucks can reduce emissions under normal operating conditions, many communities will be unable to meet standards for carbon monoxide. This is especially true for areas with colder climates. The program specified in S.1630 will provide substantial long-term CO reductions for communities across the nation. It is reassuring to hear that you and a number of your subcommittee colleagues voiced strong concerns about the motor vehicle averaging provisions contained in the President's clean air bill (S.1490) to Administrator Reilly during your September 26 hearing. We strongly endorse the approach you have taken in S.1630 by specifically forbidding averaging, as we believe that all new vehicles should be equipped with the best available pollution controls. We also wish to bring to your attention another problem we have faced in combatting our carbon monoxide problem. Several years ago, we recognized that the operation of some 6,000 vehicles in the State of Alaska -- vehicles that were not subject to our inspection and maintenance (I&M) program =- were contributing greatly to our carbon monoxide emissions, particularly during the months of November through March. Since these vehicles -- which belong to military personnel stationed in Alaska -- are registered in PHOTOCOPY PRESERVATION 1015 15th Street N.W. Suite 500 Washington, D.C 20005 JSCF JELLINEK, SCHWARTZ. Telephone (202) 789-8181 CONNOLLY & FRESHMAN, INC. Fox (202) 789-8243 / 789-8244 Telex S106001897 Cable JSCF USA TELECOPIER TRANSMITTAL TO: (Individual) Katy madinty (Company) Senator Gore's Office (Phone #) (Telefax #). 224-0580 FROM: Barbara Bennison DATE: January 31, 1990 NO. OF PAGES (including cover sheet): 4 IF COPY IS ILLEGIBLE OR INCOMPLETE, PLEASE CALL (202) 789-8181. OPERATOR: Barbara COMMENTS: PHOTOCOPY Per Katy our conversation, I am sending you Governor Cowper's clean air PRESERVATION letter of October 16, 1989, to Senator Baucus and a brief description of the I&M/military compliance issue. Thanks much for your help. Barbara Jim Danley, Representative geH. Smith, Director UAW CAP & Education Dept. on8 UAW Tennessee State UAW Community Action Program (CAP) Council JAW INTERNATIONAL UNION, UNITED AUTOMOBILE AEROSPACE & AGRICULTURAL IMPLEMENT WORKERS OF AMERICA-UAW CAP 5214 Maryland Way, Suite 305 Brentwood, Tennessee 37027 Phone (615) 371-9360 PRESTON W. LOVELESS ROBERT PRUITTE FINANCIAL SECRETARY CHAIRMAN HOMER DANIELS DEBRA LASSITER VICE CHAIRMAN RECORDING SECRETARY ESENTING ID AUTO WORKERS NOT 85 January 25, 1990 PHIS L 342 NON The Honorable IL 737 VILLE Albert Gore, Jr. United States Senate IL 903 IPHIS 393 Russell Senate Office Bldg. Washington, DC 20510 AL 1004 IPHIS Dear Senator Gore: AL 1086 1PHIS The UAW supported the Clean Air Act when it was originally AL 1303 IVAR passed in 1970, and again when it was re-authorized in 1977. AL 1407 KEVILLE However, in our judgment, tailpipe standards in S-1630 would be impossible to meet with current technology. We AL 1479 KEVILLE feel if these standards were enacted it would force the automobile companies to discontinue the production of AL 1617 RRISTOWN large and mid-sized vehicles, which would result in massive layoffs in the automobile and parts industries. CAL 1676 EVELAND IT IS WITH THIS IN MIND THAT I URGE YOU TO SUPPORT THE LEVIN- CAL 1832 NICKLES SUBSTITUTE PROPOSAL WHEN IT IS CONSIDERED ON THE DISON SENATE FLOOR. CAL 1853 RING HILL Sincerely yours, CAL 1856 LMER PHOTOCOPY ICAL 1988 Preston W Lovelem PRESERVATION FAYETTE Preston W. Loveless, Chairman ICAL 1989 Tennessee UAW CAP-PAC Council EMPHIS ICAL 2116 PWL/jb IDANON opeiu494 DOAL 2158 IMNOON CITY CAL 2181 ASHVILLE DOAL 2239 ASHVILLE DCAL 2240 MANKLIN QUENTIN N. BURDICK, NORTH DAKOTA, CHAIRMAN DANIEL PATRICK MOYNIHAN, NEW YORK JOHN H. CHAFEE, RHODE ISLAND GEORGE J MITCHELL MAINE ALAN K. SIMPSON, WYOMING Jerry MAX BAUCUS. MONTANA STEVE SYMMS. IDAHO FRANK R. LAUTENBERG, NEW JERSEY DAVE DURENBERGER, MINNESOTA JOHN B. BREAUX. LOUISIANA JOHN W. WARNER, VIRGINIA HARRY REID. NEVADA JAMES M JEFFORDS. VERMONT BOB GRAHAM. FLORIDA GORDON J. HUMPHREY, NEW HAMPSHIRE JOSEPH I. LIEBERMAN, CONNECTICUT United States Senate DAVID M. STRAUSS. STAFF DIRECTOR ROBERT F. HURLEY, MINORITY STAFF DIRECTOR COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS WASHINGTON, DC 20510-6175 June 15, 1989 Dear Colleague: This week's issue of Clearing The Air focuses on carbon monoxide (CO) pollution, its health impacts, and potential control options. Carbon monoxide pollution is largely a mobile source pollution problem. Cars and trucks account for between 70% and 90% of all CO emissions. As a result, most of the control options target tighter tailpipe standards and other automotive- related solution. This is in contrast to ozone pollution, where approximately 50% of the pollution is from mobile sources, the other 50% from stationary sources. Sincerely, John Chunge Committee John Ranking H. Member Chafee on Max Baunes Max Baucus Chairman Subcommittee on Environment and Public Works Environmental Protection CLEARING THE AIR Briefings on the Clean Air Act ISSUE NO. 5 June 15, 1989 CARBON MONOXIDE It is estimated that nearly 90 million Americans live in areas where carbon monoxide pollution exceeds federal standards. This fact sheet describes carbon monoxide pollution and its health effects. SOURCES OF CARBON MONOXIDE EMISSIONS Automobiles and other motor vehicles are the major source of carbon monoxide (CO). Carbon monoxide is a product of incomplete fuel combustion in the motor vehicle engine. Mobile sources account for between 70 and 90 percent of the carbon monoxide emissions in urban areas. Carbon monoxide is a colorless, odorless gas. Unlike some air pollutants which are emitted from tall stacks, carbon monoxide is emitted at ground level, or breathing level. Carbon monoxide emissions are not transported to other areas downwind as are certain ozone precursors. The 1970 Clean Air Act required that automobiles achieve 90 percent reduction in automobile emissions by 1975-1976. While the required reductions were not achieved during that timeframe, tailpipe standards and other automobile pollution control strategies have had a substantial impact on reducing carbon monoxide emissions. As the motor vehicle fleet turns over and a larger percent of new cars with pollution control devices are on the road, carbon monoxide emissions from mobile sources will continue to decrease. However, by the mid-1990s it is estimated that carbon monoxide emissions from automobiles and other mobile sources will increase due to the increase in vehicle miles traveled (VMT) each year. AREAS IN NONATTAINMENT During the early legislative efforts to control air pollution, carbon monoxide was recognized as one of the pervasive pollutants in urban air. Under the Clean Air Act of 1970, the Environmental Protection Agency was directed to set National Ambient Air Quality Standards (NAAQS) for six criteria pollutants, one of which was carbon monoxide. The Clean Air Act directed EPA to set standards to protect the public health with an adequate margin of safety. The current national standard for carbon monoxide is 9 ppm (parts per million) averaged over 8 hours, and 35 ppm maximum over a one-hour period. Each state was required to prepare, for EPA approval, a State Implementation Plan (SIP) which sets forth a strategy to enable the state to meet the NAAQS by 1977. The 1977 amendments to the Clean Air Act extended the deadlines for state attainment of NAAQS to 1982, and for states with severe air pollution problems, until 1987. These deadlines were further extended until August of 1988. The 1988 deadlines have passed, and EPA's figures indicate that at least 52 areas of the nation are not in attainment with the national health-based standard for carbon monoxide emissions. The estimated population living in these areas is over 89 million. HEALTH EFFECTS Inhalation of carbon monoxide poses a threat to human health because it reduces the body's ability to carry oxygen to body tissues. Carbon monoxide binds more easily than oxygen does with certain proteins, like hemoglobin, in blood. The more easily-bonded carbon monoxide thus prevents oxygen from bonding with blood proteins, and less oxygen is delivered through the blood stream. Oxygen is replaced by carbon monoxide, which does not perform the essential functions that oxygen does in the body. By depriving the body of needed oxygen, carbon monoxide is potentially lethal. At extremely high exposure levels, death by asphyxiation results. Carbon monoxide pollution is especially hazardous to fetuses. Because the fetus does not breathe on its own, it is totally dependent on the mother's blood stream for its oxygen supply. The blood stream passing through the placenta to the fetus is already low in oxygen because some of the oxygen has been used by the mother. Any further reduction of oxygen in the blood stream caused by carbon monoxide displacement of oxygen poses a threat to fetal development. The fetal brain has high oxygen requirements and is susceptible to damage from carbon monoxide. Health studies conducted on animals suggest that even modest levels of carbon monoxide pollution pose risks to fetal brain development and possible irreversible neural damages. The American Lung Association estimates that nearly 40 percent of the nation's pregnant women live in areas which have failed to attain the carbon monoxide standards. Another major segment of the American population which is especially vulnerable to carbon monoxide pollution are persons suffering from heart disease. Again, it is estimated that nearly 40 percent of these heart disease victims live in areas where carbon monoxide levels exceed national standards. The heart already weakened by disease is particularly sensitive to the displacement of oxygen from the bloodstream by carbon monoxide because the circulatory system has limited capacity to transport oxygen throughout the body. Even with mild exertion, angina patients will feel pain from carbon monoxide pollution. Some experts believe carbon monoxide pollution may trigger heart attacks. Healthy Americans may also experience adverse effects from modest carbon monoxide exposure. As oxygen levels in the bloodstream decline and carbon monoxide levels rise, persons may suffer reduced aerobic capacity. As the oxygen levels in the brain are reduced, individuals may experience loss of visual perception, manual dexterity, and learning abilities. CO "HOTSPOTS" The highest levels of carbon monoxide pollution are in areas where automobile and motor vehicle traffic is heaviest. Engines emit higher levels of carbon monoxide when traveling at low speeds and under stop and go conditions. Busy intersections, tunnels, and other areas which are congested with traffic become carbon monoxide "hotspots." In many urban areas, excessive carbon monoxide pollution is found across a broad portion of the urban area and not just in "hotspots." COLD WEATHER Carbon monoxide emissions are generally greatest in cold temperatures, unlike ozone emissions, which are largely a warm weather problem, High altitudes also exacerbate carbon monoxide pollution. Areas of the country like Denver, Colorado suffer especially aggravated carbon monoxide pollution in the winter months with the combination of high altitude and cold temperatures. Carbon monoxide emissions are high during "cold starts" because the motor vehicle engine is not burning the fuel as efficiently as does after the engine warms up. Therefore, carbon monoxide emissions in winter months in downtown areas, or other dense employment areas, in late afternoon when people are leaving work, can be of special concern. CARBON MONOXIDE CONTROLS Efforts to control carbon monoxide pollution focus on motor vehicles as they are overwhelmingly the primary source of carbon monoxide emissions. The current standard for carbon monoxide emissions from an automobile tailpipe is 3.4 grams per mile, Some legislative proposals would tighten tailpipe standards for automobiles as well as for other motor vehicles such as trucks and buses. The federal test procedure (FTP) which determines compliance with the tailpipe standard measures emissions under warm weather conditions. To more accurately reflect real-world emissions, some proposals would revise federal test procedures to include cold temperatures (20 degrees Fahrenheit) and varying driving conditions, such as low speeds and acceleration/deceleration. Tests have shown that properly maintained vehicles exceed the tailpipe standard for carbon monoxide after 30,000 miles. Proposals to control carbon monoxide include extension of the "useful-life" of the pollution control equipment on motor vehicles, as well as more effective inspection and maintenance programs to ensure properly functioning pollution control equipment. Alternative fuels such as methanol or ethanol blends, which have higher oxygen content than gasoline, combust more efficiently, producing lower carbon monoxide emissions. Tests in Denver have shown decreased carbon monoxide emissions from use of "oxygenated" fuels, and some proposals would set a minimum standard for the oxygen content of motor vehicle fuel. Other proposals for areas with severe carbon monoxide pollution problems include transportation control measures to reduce the number of vehicle miles traveled. National Audubon Society NATIONAL CAPITAL OFFICE 801 PENNSYLVANIA AVENUE. S.E. WASHINGTON, D.C. 20003 (202) 547-9009 January 30, 1990 Dear Senator Gore: As the Senate moves to consider the clean air act this week, you will undoubtedly be faced with more than one important vote on issues critical to the strength and effectiveness of America's clean air program. No single vote will be more important, however, than your decision whether to support the Environment Committee's forward-looking provisions on emissions and fuel economy standards for America's auto fleet, or to go along with the automobile industry's announced intent to gut those provisions. As you know, Majority Leader Mitchell has made passing S 1630, the Environment and Public Works clean air bill, a top priority and we strongly support that goal. We urge you to oppose any amendment to weaken or remove the second round of auto emissions reductions and the fuel economy standards from S 1630. These weakening amendments are expected to be offered by Senators Levin and Nickles. Without the second round of tailpipe reductions contained in S 1630, our efforts to clean our cities' skies will inevitably be offset by increased vehicle traffic. Without the fuel economy/CO2 standard contained in S 1630, we have no realistic way to get necessary reductions in America's automobile CO₂ emissions to the atmosphere. It is no secret that the auto manufacturers don't like these provisions. As reported in a recent Detroit News front page story (copy enclosed), the Big Three auto manufacturers have committed $1 to $3 million to a priority campaign to gut the key provisions of S 1630. Representatives of the auto industry continue to make the same arguments they promoted over a decade ago. Yankee ingenuity has been replaced with a "no can do" attitude. We believe the arguments are invalid and these tactics are socially irresponsible. Had Congress listened to these same arguments over a decade ago, US autos would still be getting 13/mpg and our urban smog crisis would be much worse than it is today. After years of delay, and enormous and expensive health-related air pollution problems, it is time to act on a clean air bill that meets the needs of American citizens and the environment. We urge you to reject the Levin-Nickles amendments and to oppose any other attempts to weaken S 1630. Sincerely, Brooks Yeaser Brooks Yeager Vice President, Government Relations 100% Recycled Paper Sunday, Doc. 24, 1989/THE DETROIT NEWS, FRONT PAGE A DETROIT NEWS EXCLUSIVE Levin goes to bat for Big 3 Plans to help automakers fight emission rules By Bryan Gruley passed by a Senate environmental Levin: Facing Detroit News Washington Bureau panel last month. They face a diffi- difficult battle. cult fight. WASHINGTON - Michigan The Levin-Nickles proposal is to Baucus bill, which the automakers Sen. Carl Levin and an unlikely ally be the conterpiece of an industry consider unnecessary, costly and not - a Republican senator from Okla- offensive taking shape as Congress feasible. homa - are preparing a legislative prepares for the final battle over the General Motors Corp., Ford Mo- one-two punch aimed at protecting Clean Air Act. After a decade of tor Co., Chrysler Corp. and import- the auto industry from the toughest stalemate, Congress is ready to com- ers from Japan and Europe plan to measures of a proposed Senate anti- plete revisions to the law, which spend more than $1 million on news- pollution bill. seeks to reduce acid rain, airborne paper ads listing cars they say will At the urging of the Big Three toxic chemicals and air pollution not be available if the more-demand- automakers, liberal Democrat Levin from automobiles. ing gas-milcage standards in the and conservative Don Nickles plan Baucus bill are passed, industry to offer legislation that would gut key THE AUTO industry has been sources said. provisions of a clean-air bill written quietly assembling a national grass- The automakers are also urging by Sen. Max Baucus, D-Mont., and roots lobbying effort to overhaul the Please see Levin/4A Levin closed factories and lost jobs, they say. "THIS THING is really scary," He leads fight said Timothy MacCarthy, a lobbyist for the Motor Vehicle Manufacturers against tougher Association. Environmentalists say the indus- car emission rules try made similar complaints in the 1970s but has since doubled gas mileage. They argue that automakers From Page 1A will not develop technology to im- prove fuel economy unless forced. the United Auto Workors union, "The auto industry's problem is auto dealers, suppliers. fleet opera- they've been discredited by always tors and plant managers to contact saying no," said Daniel Weise, a senators. lobbyist for the Sierra Club, an envi- "This is a call to arms," said ronmental group. "Because they were Elliott Hall. vice-president in charge so wrong, they have very little credi- of Ford's Washington office. bility with anyone outside there (De- troit)." LAST WEEK, GM Chairman At least six other bills that would Roger Smith, Ford Vice-Chairman increase CAFE levels are pending. Harold Poling and Bennett Bidwell, The automakers think they can chairman of Chrysier's automaking postpone a fuel-economy fight until unit, met with White House Chief of 1991 if they can kill Baucus' CAFE Staff John Sununu. provision. The executives contended that "We want to convince the admin- Congress threatens to overload the istration and Congress not to do a industry with clean-air and fuel- CAFE bill" until a new Congress economy rules just as slumping auto convenes in 1991, Ford's Hall said. sales are sapping the companies' resources to mcet new requirements. THE INDUSTRY is banking on the Levin-Nickles alliance, cemented The Senate clean air fight is in a face-to-face meeting of the sena- crucial because the bill's impact on tors Dec. 15. the auto industry has been largely Levin, who has led the auto indus- decided in the House. try's Senate battle since last spring, Congressional sources said Levin decided he should join with a Repub- and Nickles plan to introduce an lican who does not hail from a state amendment that would: with intense ties to the industry. Nickles' home state of Oklahoma Eliminate the certainty of a second includes a GM assembly plant in round of toughened tailpipe emission standards being imposed in 2003. Oklahoma City and a Ford glass plant in Tulsa. The Baucus bill would impose two "We need that kind of team," an rounds of toughened limits on smog- auto lobbyist said. "We wouldn't forming tailpipe emissions over the next 14 years. Levin and Nickles want to have two strong auto-state senators." either would eliminate the second Nickles, 41, is also chairman of round or make it contingent upon the National Republican Senatorial approval by the Environmental Pro- Committee, which raises money for tection Agency (EPA). GOP races. His pairing with Levin The provision would be similar to could put Nickles in an awkward one the House is likely to pass. position. Levin will likely be chal- Eliminate the Baucus bill's first- lenged for re-election next year by of-a-kind limit on emissions of car- Rep. Bill Schueite of Midland or bon dioxide. Detroit attorney W. Clark Durant, The provision amounts to a new Nickles' party colleagues. fuel economy rule, because carbon- Levin's mission in the clean air dioxide emissions can be cut signifi- battle is to undo the Baucus bill's cantly only by increasing gas mile- proposed second round of tailpipe age. The Senate panel that approved limits. the provision said automakers would need to boost their corporate average IN SEPTEMBER, the senator fuel economy (CAFE) to 33 miles per told a subcommittee chaired by Bau- gallon by 1996 and 40 mpg by 2000. cus that the so-called "tier II" limits The CAFE standard for 1990 is would cost $6.5 billion for only 2 27.5 mpg. percent in pollution reductions. The automakers are most con- "We ought to be spending that cerned about the CAFE provision. money on leap-ahead technologies They 3ay it would force them to for environmental cleanup," Levin discontinue all but their smallest said last month. models. while low gas prices have Nickles will focus on the proposed boosted demand for bigger, more carbon-dioxide standard - which powerful cars. industry people reier to as a "back- Production halts would mean door CAFE program." The Ponca City, Okla., business- the Wall Street Journal, the Wash- man has criticized CAFE in the past. ington Post and other national pa- "He's absolutely the best on fuel pers, as well as newspapers in the economy in the Senate," one auto home states of senators who are lobbyist said. "We're absolutely de- undecided on clean-air issues. lighted and grateful to have him." Ads in niche publications would The Senate historically has been seek to reach dealers, suppliers and hostile to the automakers on envi- others whose business or lifestyle ronmental issues. The Baucus pack- could be affected by the bill. age passed in committee by a lopsid- ed 15-1 vote. FOR EXAMPLE, an ad in Even Sununu was not entirely Trailer World would target people sympathetic to the auto executives who use midsize or large cars to pull who visited him last week, sources their trailers. familiar with the meeting said. "This battle could be won or lost at the grass roots," a lobbyist said. SUNUNU CHIDED Smith, "The key is to get people to Poling and Bidwell for not working understand how severely altered hard enough to support Bush's clean- their lifestyle is going to be (if the air proposals. Baucus bill passes). "The situation is not good," one "When they're going on vacation, congressional source said. "Together how are they going to fit all their kids (Levin and Nickles) may have a and two adults into a Ford Escort fairly good chance, although there's wagon?" going to be some pretty significant The canipaign budget is not final- opposition." ized, but sources said it will probably The automakers aim to use the total between $1 million and $3 Levin-Nickles proposal in their na- million. tional lobbying campaign, which will Industry lobbyists are seeking include newspaper advertising and personal visits with all 100 senators. mass mailings to groups such as Added lobbyist MacCarthy: retired auto workers. "We've got to hit the ground running As now planned, ads will run in in January." United States Senate WASHINGTON, DC 20510 January 24, 1990 Dear Colleague: The Senate is beginning consideration of S. 1630, the Clean Air Act Amendments. While the current Clean Air Act has improved air quality over the last twenty years, more needs to be done to protect public health and the environment. For tnis reason, we commend the President, the Environmental Protection Agency Administrator William Reilly, and the Members of the Senate Committee on Environment and Public Works for the serious attention that they have given to this important matter, and their efforts to put it on the Congressional agenda. In evaluating the various proposals that have been put forward, our goal must be to achieve both clean air and a healthy economy. The bill proposed by the President, the bill marked up by the House Environment and Health Subcommittee, and many of the elements of the bill passed by the Senate Committee, would make it possible for us to reach both of these goals. The historic Waxman- Dingell compromise on tailpipe emissions shows that it is possible to make real progress toward cleaner air without damaging the economy. Unfortunately, several provisions of the Senate bill relating to automobile emissions go far beyond the President's proposal, the Waxman-Dingell compromise, and even beyond current California standards. These provisions would impose extraordinary costs on automobile manufacturers, workers, and consumers, for marginal pollution reductions. o The Phase II emissions requirements (beginning in 2003) in the Committee proposal fail to recognize something which the Waxman-Dingell approach does, that these standards may not be technologically or economically feasible. o The Phase I emissions standards in the Committee proposal draw on the 1993 California standards, the most stringent in the nation, but go beyond those standards for the same time period. o The carbon dioxide emissions standards in the bill target only the automobile industry, and leave all other sources untouched. This section has no place in this bill. This provision, which was not included in either the President's bill or the House bill, would cost the American consumer an estimated $7 - 15 billion annually for a 1% reduction in man-made emissions of greenhouse gases. S. 1630, as adopted by the Committee, goes well beyond the more balanced approaches taken by the Administration, Waxman- Dingell and even California, as promulgated to date. We should avoid provisions that needlessly jeopardize our economic health and squander resources which could be used for significant long term environmental and economic gains. Sincerely, Dm Nill Carl Levin Don Nickles Carl Levin December, 1989 NISSAN R&D'S COMMENTS ON THE SENATE CLEAN AIR ACT AMENDMENTS TAILPIPE STANDARDS: The standards proposed in S. 1630 are beyond Nissan's current technological capability. We know of no proven and reliable current technology that would permit us to achieve the first-tier standards (0.25 NMHC, 3.4 CO and 0.4 NOx) in use. The tiere second-tier standards (0.125 THC, 1.7 CO and 0.2 NOx) are yet one more step beyond the feasibility of any technology we have projected. CPA cost estimates for Tier 6 B.V. for29.7 ONBOARD REFUELING CONTROL: To develop the technology necessary for safe and acceptable onboard refueling controls will require considerable effort. The National Highway Traffic Safety Administration recently released a study conducted for them by A.D. Little which concludes: "There is adequate evidence to conclude there are indeed potential safety risks associated with onboard systems." The effect of onboard on feasibility of DC tailpipe standards also needs to be considered. all fews dele Ca her C-PA $ 20 15,00 to egry were onlsd Nissan believes that a minium of four years lead time to begin the phase-in of onboard would be required. Nissan estimates that onboard controls will cost our customers about 100 dollars per vehicle, assuming adequate leadtime and a phase-in are permitted. service only mfor - of nor magnet recall USEFUL LIFE: A 10 year/100,000 mile useful life for light-duty vehicles would render even stas tech. less attainable the tailpipe standards contained in S. 1630, due to in-use deterioration. We you have no data on 100,000 mile deterioration that would allow us to predict at what levels vehicles would have to certify in order to meet more stringent standards. As a vehicle ages and changes ownership, there are factors over which the manufacturer has no control that affect emissions performance, such as poor maintenance, tampering, and the cumulative effects of poor fuel quality. LIGHT-DUTY TRUCK EMISSION STANDARDS: Current clean air law recognizes differences in the weight, operating conditions and performance requirements of passenger cars and light trucks. S. 1490 continues to recognize the inherent difference, whereas S. 1630 would establish identical emission standards for passenger cars and light trucks. The severe standards set in S. 1630 are thus even more infeasible for light trucks. CARBON DIOXIDE STANDARDS: we prefer the approach in S. 1630 for dealing with fuel economy to the approach in S. 1224 because S. 1630 establishes standards that are the same for all manufacturers. However, we know of no currently available or planned technology that would permit us to comply with the CO2 levels set forth in S. 1630, under any mix of vehicles that we envision selling. surip She. nother Men 90 CONCLUSION: We believe the requirements of S. 1490 pose more realistic goals than those in S. 1630, and achieve the best balance between environmental and economic considerations. S. 1490 permits less hurried development and recognizes the critical differences between certification and in-use emission levels. Even though the emissions reductions in S. 1490 will require considerable effort and will be costly, we support its reductions as stringent yet realistic goals. Nissan R&D is an independent, wholly owned subsidiary of Nissan Motor Co., Ltd. of Tokyo, Japan. FOR IMMEDIATE RELEASE October 17, 1989 RELEASE CONTACT Claudia Barker (916) 324-3298 PUBLIC INFORMATION OFFICE / 916-324-3298 NISSAN JOINS STATE'S PARTNERSHIP TO TEST CLEAN FUELS Nissan Research and Development, Inc. today joined California's public/private partnership program to test clean burning motor vehicles and fuels. Nissan now becomes the first foreign auto manufacturer to loan a flexible fuel vehicle (FFV) to the state's demonstration program. A 1989 flexible fuel Nissan Stanza was unveiled today at the California Museum of Science and Industry in Los Angeles, making it the first foreign FFV in the state's seven-year-old alternative fuels demonstration program. QQ M85 The Stanza and other FFVs could be the key to widespread commercialization of alternative transportation fuels, since they can run OF methanol gasoline, or any combination of the two in a single fuel tank. Methanol is a clean burning fuel that can be produced domestically from remote natural gas or biomass. Arecent study by the U.S. Environmental Protection Agency indicates that methanol can reduce smog-forming emissions on a per vehicle basis by up to 50 percent. butco₂ from com much Energy Commission Chairman Charles R. Imbrecht praised Nissan for being the first Japanese auto manufacturer to join in the state's efforts to clean up the air and strengthen domestic production of transportation fuels. "Alternative fuels will provide improvements in air quality beyond what is achievable from conventionally-fueled vehicles even those using the most advanced emission controls," Imbrecht said. "It is definitely in the state's best interest to pursue the use of clean fuels." The Nissan FFV is based upon a regular production 1989 Stanza with a standard CA20, 4-cylinder fuel injected engine. Modifications have been made to the fuel system and an electrostatic sensor detects the amount of methanol in the fuel mixture and adjusts the fuel injection system accordingly. "We at Nissan believe that it is important for California and the U.S. to identify ways to improve air quality and reduce this country's dependence on foreign sources of energy," said Thomas Mignanelli, Executive Vice-President of Nissan Motor Corporation in the U.S.A. "The California Energy Commission's alternative fuels demonstration program is a vital part of achieving that goal." "We are happy to join U.S. manufacturers in seeking solutions to these problems by donating the test vehicles that will provide key research in these areas," Mr. Mignanelli said. California, with help from its public/private partnerships, has a goal of putting 5,000 FFVs on the road by 1992. President Bush last June announced plans to have more than one million cars that use clean burning fuels on America's roads by 1996. FINTRGY COMMISSIONER ### CALIFORNIA ENERGY COMMISSION 1516 Ninth Street . Sacramento CA 95814 STATE OF CALIFORNIA NISSAN FLEXIBLE FUEL VEHICLE a 6 01/11 of CONTROL UNIT FUEL SENSOR Electrostatic type FUEL PUMP CANISTER FUEL TANK FUEL INJECTOR Side feed, ball valve ENGINE FUEL HOSE O₂ SENSOR FUEL TUBE CATALYST ENGINE OIL Low temperature reactivity NISSAN FFV STANZA NISSAN FLEXIBLE FUEL VEHICLE SPECIFICATIONS VEHICLE 1989 STANZA 4-DOOR SEDAN (CALIF. MODEL) TRANSMISSION 4-SPEED AUTOMATIC TRANSMISSION ENGINE 4-CYLINDER, IN-LINE (MODIFIED CA20E) BORE X STROKE 84.5 mm X 88.0 mm DISPLACEMENT 1974 cubic centimeters COMPRESSION RATIO 8.5 to 1 FUEL SUPPLY MULTI-POINT FUEL INJECTION IGNITION SYSTEM 2-PLUG-PER-CYLINDER, FULLY TRANSISTORIZED EXHAUST GAS RECIRCULATION OPERATES WITH 100% GASOLINE TO 30% METHANOL CATALYST UNDERFLOOR TYPE (1-LITER MONOLITH) FUEL SENSOR ELECTROSTATIC TYPE ENGINE OIL 10W-30 WITH SPECIAL ADDITIVES FUEL GASOLINE WITH UP TO 85% METHANOL (M85) ELECTROSTATIC FUEL SENSOR DIELECTRIC CONSTANT ε GASOLINE ε = 2.1 METHANOL ε = 34 3.0 CAPACITANCE METER OUTPUT V 2.0 - 1.0 0 25 50 85 FUEL ELECTRODE METHANOL CONCENTRATION vol % December, 1989 NISSAN R&D'S POSITION ON S. 1224, THE MOTOR VEHICLE FUEL EFFICIENCY ACT OF 1989 Nissan has been a leader in the implementation of advanced automotive technology to improve fuel efficiency (see Attachment). We plan to continue to aggressively pursue such efficiency improvements in the future, regardless of any action taken by Congress with regard to future standards. Nissan's concern with S. 1224 lies in the implementation technique of manufacturer- specific percentage improvement. Requring all manufacturers to improve their CAFE by a certain percentage above their 1988 baseline, as proposed in S. 1224, would discriminate against manufacturers with CAFE's above the existing standard, such as Nissan. If low-mileage manufacturers are allowed to meet lower targets, we face a competitive disadvantage which may in effect freeze us out of markets in which we currently compete. -- Nissan has already implemented available fuel-efficient technology to a greater- than-average degree than the industry overall. Nissan has less options to improve fuel economy than do low-mileage manufacturers. Further significant downsizing for our line of vehicles is not an available option without sacrificing the space and comfort needs of our customers. Nissan's primary option for substantial fuel economy improvement would thus be unproven and/or very costly new technology. Our cars could become unacceptably small or costly in comparison to vehicles offered by low-mileage manufacturers, since they can adopt the fuel- efficient technologies already used to a greater degree by Nissan, and use downsizing to a greater degree. -- The percentage-improvement approach could also fail to result in the intended fuel-savings if high-mileage competitors are shut out of the markets in which they currently compete at the expense of low mileage manufacturers who are required to make less fuel-efficient vehicles. The Office of Technology Assessment and others have proposed alternative approaches, based on size or weight classes of vehicles. A class-based approach would maintain competition, and require an even application of technology by all manufacturers. Congress should consider ways to encourage the purchase of fuel-efficient vehicles by consumers as an alternative to a regulatory program which would establish fuel economy standards which may discriminate against some manufacturers and could prove to be counterproductive in achieving fuel savings. Nissan R&D IS an independent, wholly owned subsidiary of Nissan Motor Co., Ltd. of Tokyo, Japan. Attachment I COMPARISON OF DIFFERENT CAFE STANDARDS REQUIRED UNDER S. 1224 '88 Model Year CAFE Standard under .1224 MANUFACTURER CAFE* (St'd = 26.0 mpg) 1995 -2000 MY 2001 MY - NISSAN 30.8** 37.0 43.1 MERCEDES 21.3 27.5 29.8 BMW 21.6 27.5 30.2 JAGUAR 22.0 27.5 30.8 PEUGEOT 23.4 28.1 32.8 PORSCHE 24.7 29.6 34.6 VOLVO 26.0 31.2 36.4 FORD (Domestic) 26.4 31.7 37.0 SAAB 26.5 31.8 37.1 GM (Domestic) 27.6 33.1 38.6 CHRYSLER 28.4 (Domestic) 34.1 39.8 MAZDA 28.7 34.4 40.2 MITSUBISHI 29.8 35.8 41.7 VW 30.3 36.4 42.4 SUBARU 31.8 38.2 44.5 HONDA 32.0 38.4 44.8 ISUZU 32.6 39.1 45.0 TOYOTA 32.6 39.1 45.0 HYUNDAI 35.0 40.0 45.0 *Source: NHTSA Automotive Fuel Economy Program 13th Annual Report to Congress (Federal Register, July 19, 1989, pp. 30310-20) **Source: NISSAN (1988 Final CAFE) Attachment II: FUEL ECONOMY IMPROVEMENT TECHNOLOGIES BY NISSAN % PENETRATION TECHNOLOGY TO IMPROVE FUEL ECONOMY '87MY '89 MY '87MY '88MY MARKET NISSAN NISSAN NISSAN (OTA) Front-wheel Drive 78.0 91.1 91.3 81.0 4-cylinder/4-valve 5.0 2.2 3.7 72.0*1 Four-speed Automatic*2 35.0 (40.1) 32.2 (59.1) 23.6 (46.3) 30 (57.3) [Automatic Transmission market share] [87.3*³] [54.5] [50.9] [52.4] Electronic Transmission Control 2.0 3.8 4.4 25.0 Aerodynamics (Cd from 0.37 to 0.32) N/A N/A N/A N/A --(Average Cd) (0.36) (0.36) (0.35) Tires N/A N/A N/A N/A Accessories N/A N/A N/A N/A Engine Improvements: -Overhead Cam Engines 40.0 100.0 100.0 100.0 -Roller Cams 40.0 0.0 0.0 0.0 -Low Friction Rings/Pistons N/A N/A N/A N/A Non-carbureted: 76.0 59.7 99.4 100 -Throttle Body Fuel Injection (TBI) 31.0 12.3 63.9 54.0 -Multipoint Fuel Injection (MPI) 45.0 45.0 35.5 46.0*4 NOTES: *1 Includes 3-valve engines 2 Figures in parentheses shows 4-speed penetration within A/T class 3 This figure is MVMA, not OTA, data 4 In '91MY, Multipoint Fuel Injection will reach 100% penetration 3 THE WASHINGTON POST EPA Sees Cheap Way to Clean Air Enlarging Autos' Charcoal Canisters Would Trap More Gas Fumes in Congress to cut tailpipe emis- tank when gasoline expands in hot By Michael Weisskopf sions would reduce hydrocarbons 1 weather. Once the car is started, Washington Post Staff Writer percent and long-debated measures the fumes are supposed to be The Environmental Protection to capture gasoline fumes released sucked into the engine and burned Agency yesterday proposed a $10 during refueling would cut hydro- off. remedy for the largest source of carbons only 2 percent. But gasoline has become more pollution from automobiles. EPA Administrator William K. evaporative in recent years because The proposal calls on automakers Reilly called the canister plan the of new refining techniques. The to increase the size of charcoal can- "most important modification to larger volume of fumes now over- isters that trap gasoline fumes from motor vehicles this agency can re- taxes the canister, which vents ex- the fuel tank during hot weather quire to achieve a genuine air cess hydrocarbons into the atmos- and route them to the engine to quality improvement." phere. The EPA discovered two burn. Environmentalists and industry years ago that vapors also are gen- Current canisters are not large spokesmen concurred in a rare spir- erated by a hot engine when the car enough to contain the fumes, which it of agreement. is running. WILLIAM KAREILLY evaporate in the atmosphere, caus- According to the EPA, the costs Proposals in Congress would re- plan is major "modification" ing smog. According to the EPA, of larger canisters and a stronger quire the EPA to regulate both gasoline vapors released during the vacuum capacity to suck trapped types of emissions. proposal is being promoted as ev- summer account for 5 percent of vapors into the engine would add The Bush administration had pro- idence total hydrocarbons-a key ingre- $10 to the price of a new car. With posed to give the EPA discretion to But David Hawkins, of the Na- dient of the smog contaminating 10 million new cars sold annually, require, such regulations, but Con- tional Clean Air Coalition, said the more than 100 metropolitan areas, consumers would spend $100 mil- gress has insisted. on specific re- including Washington. quirements because of the agency's proposal may have been motivated lion more a year. Environmentalists have pushed But officials project fuel savings record of inaction where discretion by the intense, attention Congress for larger canisters as the most ef- of $600 million a year in fuel be- is permitted. currently is focusing.on the issue. fective measure by automakers to cause engines can run on fumes. Reilly has promised to exercise It's like cadets who keep their reduce smog. Canisters were designed to ab- any discretion in favor of environ- shoes shined they know By comparison, costlier proposals sorb vapors released from the fuel mental protection, and yesterday's there's an inspection," he said. MAR 8 (LEG. DAY JAN 231. 1990 (Date) Roll Call Vote Legislative NO. 34 SUBJECT MOTION- To TABLE - LAUTENBERG AMOT. NO. 1335 YEAS NAYS Adams Armstrong / Baucus Bentsen Biden Bingaman Bond R Boren Boschwitz R Bradley 2 Breaux Bryan 2 Bumpers PHOTOCOPY 3 3 Burdick Burns R PRESERVATIO Byrd 4 Chafee 5. Coats R Cochran P. Cohen L. A Conrad Cranston R D'Amato Re Danforth K Daschle DeConcini 6 Dixon Dodd Dole Domenici R 7 Durenberger R Exon 8 Ford Fowler 9 Garn R are Glenn Gore 2 Gorton Pm Grabam, Florida Gramm, Texas Min Grassley Harkin Hajch Hatfield Heflin Heinz Heflin Heinz Helms Hollings Humphrey Inouye Jeffords 10 Johnston Kassebaum 11 Kasten Kennedy Kerrey, Nebraska Kerry, Massachusetts Kohl Lautenberg 3 Leahy 12 Levin Lieberman Lott Lugar Mack + Matsunaga McCain McClure McConnell Metzenbaum Mikulski 13 Mitchell Moynihan Murkowski Nickles Nunn Packwood + Pell Pressler Pryor Reid Riegle 14 Robb Rockefeller Roth Rudman Sanford Sarbanes Sasser Shelby Simon Simpson Specter Stevens Symms Thurmond Wallop Warner Wilson Wirth OTOCOPY OPO 1989 97-664 (m) SERVATION 65 33 900'0N 60.61 06:01 IPM 731