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The original documents are located in Box 6, folder "Auto Emissions (3)" of the James M.
Cannon Files at the Gerald R. Ford Presidential Library.
Copyright Notice
The copyright law of the United States (Title 17, United States Code) governs the making of
photocopies or other reproductions of copyrighted material. Gerald Ford donated to the United
States of America his copyrights in all of his unpublished writings in National Archives collections.
Works prepared by U.S. Government employees as part of their official duties are in the public
domain. The copyrights to materials written by other individuals or organizations are presumed to
remain with them. If you think any of the information displayed in the PDF is subject to a valid
copyright claim, please contact the Gerald R. Ford Presidential Library.
{ca. May 16, 1975]
Dat bow vyn
DECISION
THE WHITE HOUSE
Dut testruring what
WASHINGTON
what is
Date for
MEMORANDUM FOR:
THE PRESIDENT
Tentruey
FROM:
JIM CANNON
wednr by
SUBJECT:
AUTO EMISSION STANDARDS
The Congress now has before it from the Administration
two different sets of recommended auto emission standards
for 1977-1981, model year cars:
Your January 30 proposals which were a part of your
energy package. rut dut -
Russ Train's March 5 decisions and recommendations
which were driven by concern over sulfuric acid from
catalytic converters.
verrum
Since Mrin March 5:
wot S State will Been
OMB has led an extensive interagency review of the
implications of various alternative emission standards
for public health, air quality, fuel economy and con-
sumer costs.
Russ Train's decisions have been challenged by elements
within EPA, by environmentalists, and by elements of
s
industry most interested in continued use of converters.
It has become very clear that information is not available
to permit firm conclusions as to the importance of the
sulfuric acid problem and this information will not be
available for at least several months. Experts disagree
as to the potential danger.
Other groups are doing sulfuric acid studies, including
the National Academy of Sciences.
The Rogers Subcommittee in the House is marking up a
Clean Air Act bill and the Muskie Subcommittee is holding
hearings with Russ Train scheduled to testify on Wednesday
May 21. Senate hearings are now scheduled to end with
Train's appearance.
FORD & LIBRARY GERALD
Digitized from Box 4 of the James M. Cannon Files at the Gerald R. Ford Presidential Library
- 2 -
Auto companies need to know by early August what the emission
standards will be for 1977 model cars. If the Congress does
not act, Russ Train's March 5 decisions with respect to 1977
standards will go into effect -- resulting in continuing
1975-76 standards for hydrocarbons (HC) and carbonmonoxide
(CO); and tightening the nitrogen oxides (NOx) standard below
1975-76 levels and your January 30 proposal.
This memorandum and its enclosures (a) summarize the findings
from the OMB-led review, and (b) seek your decision on two
issues:
1. Do you wish to submit a new legislative proposal
and, if so, when and how should it be done?
2. If you wish to propose specific standards, what
should they be and what model years should they cover?
For all practicable purposes, the voluntary 40% fuel economy
agreement with automobile companies is suspended or nullified
by the Train recommendations. Depending upon your decisions
on the above issues, it may be feasible and desirable to work
out a new agreement.
ISSUES FOR DECISION
The two issues listed above will be presented in the order
listed, but we recommend that you not decide either of them
until you have considered both.
Issue #1
All of your advisers, except Russ Train, Russ Peterson and
Cap Weinberger believe that some new statement is needed
since events have left unclear the Administration's position.
The lack of clarity could be used by the Congress to criticize
the Administration or perhaps as an excuse for not moving on
legislation in time to meet the deadline facing automobile
companies for 1977 models. It will be clear in the discussion
of alternative standards that retention of your January 30
proposal with respect to HC and CO --- i.e., adopting California
standards -- is no longer practicable since it would increase
sulfuric acid emissions.
Normally, a new legislative proposal would be developed,
following your decision on specific standards, and submitted
to the Congress with a letter or statement. This normal
sequence is complicated by two factors:
FORD LIBRARY & GERALD
- 3 -
to
The great complexity of the problem and the difficulty
of conveying a clear understanding to the Congress and
the public.
The absence of hard information on the potential serious-
ness of the sulfuric acid problem and the sharp disagree-
ment among experts and parties at interest over the
sulfuric acid question.
In addition, Senator Randolph apparently wants public encour-
agement to broaden the scope of the Muskie Subcommittee
hearings so that fuel economy and consumer cost issues are
considered as well as air quality. Through the Public Works
Committee Chief Council, the Senator has proposed that you
(a) issue a statement on the importance and complexity of
the issue, (b) emphasize the importance of a cooperative
effort with the Congress to resolve it, (c) request hearings
be opened so that Administration witnesses other than EPA
can present information on all realistic alternative emission
levels, and (d) not make specific recommendations until after
Senate hearings are completed.
Alternatives - Issue #1
Alt A. Develop new legislative proposal; submit the proposal;
backed up with a statement or fact sheet which dis-
cusses the implications of alternative emission
standards; and defend.
The principal arguments for this approach are that
(a) it is normal procedure, (b) it places you in a
strong leadership position -- and leadership is par-
ticularly important on this complex issue, and (c) it
probably would involve less time in getting to a final
Congressional decision -- and the auto industry must
have a decision soon.
The arguments against it are that (a) the proposal
will become a target and the complexity and the lack
of definitive information makes any position somewhat
difficult to defend; (b) conceivably some new infor-
mation or positions will come out which will undercut
the proposal, and (c) discussion of other alternatives
may be limited.
Alt B. Follow Randolph proposal; help assure that information
is presented on all alternatives, take no position until
after hearings.
The principal arguments for this approach are that
(a) it would improve the quality of information
available to the Congress and the public
- 4 -
on all alternatives, thus increasing understanding of
a complex issue; (b) reduce the likelihood of Con-
gressional attacks on the Administration's proposal
and the substitution of a politically more attractive
but less meritorious alternative, and (c) you could
make your decisions on the basis of evidence developed
by Congress as well as the Executive branch.
The principal arguments against it are that (a) the
hearings will be closed with Train's appearance and
no really significant new information has emerged,
and (b) it may take longer to get final Congressional
action.
Recommendations and Decision - Issue #1
Alternative A.
Develop new legislation,
)
Lynn, Seidman,
submit facts and take a
Friedersdorf
position.
Alternative B.
q
Submit facts only. Decide
Randelph, Train,
on a legislative position
Buchen, Peterson
after hearings.
Issue #2. If you wish to propose specific standards, what
should they be and what model years should they cover?
Auto emission standards have an impact on air quality, health
effects, aesthetics, fuel economy, fuel ingredients, initial
car costs, car maintenance costs and, indirectly, on auto-
mobile sales and employment in auto and related industries.
Jim Lynn's memorandum at Tab A identifies and discusses the
alternative emission levels and their implications in detail.
That memo also presents the alternatives and recommendations
for your decision (Pages 9-12 of Tab A).
If you decide to propose standards other than those recommended
by Russ Train, your advisers believe it is essential that you
issue a statement which (a) explains the importance and com-
plexity of the issue to the public, and (b) outlines the
rationale for your position.
A decision on the alternatives in Tab A in fact involves a
number of implicit decisions:
In view of the uncertainty over the sulfuric acid problem,
should it be taken seriously?
- 5 -
What consideration warrants higher weights in selecting
among alternatives -- public health, meeting air quality
standards, fuel economy, consumer costs, etc.?
For what period of time should auto emission standards be
set and stabilized -- three years, five years?
Will (or should) use of the catalytic converter be suspended?
Enclosed at Tab B is a rough draft of a public statement,
message or letter that could be used if you decide to take a
new position. Minor changes would be needed, depending on
the option you select. This draft is included in the package
as an attempt to give you a basis for judging the possible
extent of public understanding of the issue and your decision.
Even though energy and economic issues have taken on added
significance since the Clean Air Act's rigid requirements
were enacted, I believe that health continues to be the most
important consideration to the public and that health should
recieve highest priority consideration in making your decision.
By way of guidance in reviewing the detailed paper at Tab A,
several generalizations can be made:
Air Quality
- The auto-related pollution problem is large limited to
metropolitan areas; HC, CO or NOx now or in the future
exceed national ambient air quality standards only in
these areas.
- Regardless of the auto emission standard selected, there
will be little impact on the expected ambient air quality
in 1985 for HC, CO and NOx because:
CO has already been reduced substantially.
HC has been reduced substantially from car exhausts;
most HC comes from other sources.
NOx is now a problem in only three cities (Chicago,
Los Angeles, and New York City) and will be in nine or
ten by 1985, but most NOx comes from stationary sources.
Estimates are in dispute over sulfuric acid emissions
from catalyst equipped cars, and likely build-up of
sulfuric acid concentrations. But there is general
agreement that catalyst equipped cars emit fifty times
as much sulfuric acid as non-catalyst cars, and catalyst
equipped cars equipped with an air pump to meet Cali-
fornia HC-CO standards emit at least twice as much
sulfuric acid as catalytic mufflers in use in the rest
of the country.
- 6 -
Health Effects
- Since the marginal differences in HC, CO & NOx are
very small, regardless of the auto emission standard
selected, the potential health effect is also very
small.
- The health impact of sulfuric acid is expected to
be serious at levels expected in 2-3 years under
EPA's original projections and 4-6 years in selected
areas under more optimistic projections.
- Russ Train's decision on HC-CO standards (which he
has not changed, despite attacks on it) reflects the
conclusion that a very small but generally known health
impact from the marginally less restrictive HC-CO
standards is preferable to an unknown but potentially
serious health impact from sulfuric acid -- which would
be increased by tightening the HC-CO standard.
Fuel Economy
- Tighter emission standards generally result in less
fuel economy.
Consumer Costs
- The tighter the emission standards, the higher the
initial car cost.
FORD
Technological and Fuel Options
- The tighter the emission standards, the fewer the
technological options for meeting standards (e.g.,
statutory NOx levels --- 0.4 grams per mile -- rule
out diesel and stratified charge engine options.)
Recommendations and Decision (Issue #2). Data on alternatives
in Tab A, with arguments for and against at Pages 8-11.
Option 1: Energy Independence Act
- 1977-81
0.9 9.0 3.1
Option 2: Train - March 5
Train, Peterson
- 1977-79
1.5 15.0 2.0
- 1980-81
.9 9.0 2.0
(sulfate standard for 1979)
Option 3: Extend current stds.
Zarb, Coleman,
- 1977-81
1.5 15.0 3.1
Frizzell, Morton,
Seamans, Buchen
Weinberger
(Options 4 and 5 on next page)
#1
- 7 -
Option 4: Canadian stds.
Lynn, Simon,
- 1977-81
2.0 25.0 3.1
Greenspan
Seidman
Option 5: 1973-74 stds.
- 1977-81
3.0 28.0 3.1
DECISION
EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C. 20503
MAY 16 1975
MEMORANDUM FOR: THE PRESIDENT
FROM:
JAMES T. LYNN
SUBJECT:
Automobile Emission Standards
Background
Pursuant to the Clean Air Act, the Administrator of EPA
has established national ambient air quality standards
which each region must achieve and maintain to protect
health and welfare. Both stationary pollution sources
and automobile emissions must be controlled to meet
ambient standards.
Though ambient standards for pollutants are set by the
Administrator of EPA as a regulatory action, automobile
emission limitations are fixed in the Clean Air Act.
Therefore, changes in automobile emission limitations
require legislation.
The three automobile pollutants with statutory limitations
are hydrocarbons (HC), carbon monoxide (CO), and nitrogen
oxide (NOX).
The levels established for ambient standards are themselves
controversial. However, the National Academy of Science
has recommended their retention pending further analysis.
Such analysis may lead to change (more or less strict than
present). However, we are advised that it will take
at least three years to improve the existing data base
sufficiently to establish new ambient standards. Therefore,
for purposes of present decision making we have no choice
but to use the present ambient standards as criteria to
determine the effectiveness of automobile emission
limitations in protecting public health.
FORD LIBRARY & GERALD
2
The Clean Air Act imposes increasingly more stringent
automobile emission limitations. (Tab 1 shows chronology
of statutory standards.) 1973-74 vehicles produce about
65 percent less HC and CO than uncontrolled vehicles. 1975
vehicles, meeting the current standards, produce 83 percent
less HC and CO and 11 percent less NOX than uncontrolled
(pre-1968) vehicles. The existing law, however, requires
that these automobile emissions be reduced even further
beginning with model year 1977 for NOX and model year 1978
for HC and CO.
In return for a voluntary agreement by automobile manu-
facturers to increase fuel economy 40 percent by 1980,
the Administration's Energy Independence Act proposed
amending the Clean Air Act to allow limitations for HC
and CO which are less stringent than the law would require
through 1981, but more stringent than limits currently
in force. It also proposed that the NOX limit be frozen
at its current level until 1981 rather than become more
stringent (in 1977) as present law requires. (Tab 1 also
shows Administration positions on automobile standards
since 1973.)
Subsequent to submitting the Energy Independence Act to
Congress, the Environmental Protection Agency held public
hearings related to five-year emission levels. The
hearings publicized that the catalytic converter, used to
meet the HC and CO standards for 1975 and 1976 models,
produces potentially harmful quantities of sulfuric acid.
(See Tab 3.)
Present data are not sufficient to make specific calcu-
lations or final judgments on what sulfuric acid emission
levels would be safe from a public health standpoint.
However, it is known that sulfuric acid emissions can pose
a significant public health risk and that automobile
emission of sulfuric acid may double if the more stringent
HC and CO standards proposed in the Energy Independence
Act were imposed for 1977 and subsequent model years
The Administrator has, therefore, concluded and publicly
announced, that the HC and CO standards should be kept
at their current 1975 levels through model year 1979.
Since even current emission levels present some potential
health risk from converter-produced sulfuric acid, the
Administrator stated that a sulfuric acid standard would
be established for model year 1979 vehicles. At the same
time, the Administrator called for making the NOX standard
more stringent in model year 1977 than the Energy Inde-
pendence Act proposed. (See Tab 1.)
3
Thus, the Executive Branch has two different auto emission
recommendations before Congress. The Administration could
avoid further conflict on this matter by not making another
recommendation for automobile emission levels, and let the
Congress grapple with the problem. In fact, senior staff
of the Senate Public Works Committee, which has jurisdiction
over the Clean Air Act, have proposed that the Administration
take no position, but instead work with the Committee to
delineate the feasible options. The options would be the
subject of public review and Congressional hearings, after
which the Administration and the Committee would formulate
their respective positions on the issue.
However, both public credibility and the need of the
automobile industry for resolution by August of this year
to design, certify and place orders for 1977 model vehicles
argue for strong leadership by the Administration. Further-
more, there is a real risk that the voluntary fuel economy
approach (40 percent improvement by 1980) may be jeopardized
by decisions or delays in decisions on this issue.
While the choice of emission standards must represent a
balance among public health, air quality, esthetic, energy
and cost considerations, the problems currently confronting
the nation are different than those prevailing in 1970
when the Clean Air Act was passed. Inflation, unemployment,
and the added cost and reduced availability of energy
suggest the possibility of Congressional reassessment of
the relative weights accorded to various factors other than
measures necessary to health.
The agreement by all health scientists that sulfuric acid
from the catalytic converter is either a present or potential
threat to public health requires that we reconsider our
previous position on automobile emission levels, which to
a large extent are premised on the use of the converter at
least until model year 1981. The two important questions
to be addressed are:
a. Does the reduction in automobile emission standards
to the levels on 1975 and subsequent model
years have a significant impact on the ability of
air quality regions to achieve ambient air standards?
(Data presented in this memorandum indicate that
the present range of options does not have a
significant impact on air quality.)
4
b. Are automobile standards becoming stricter so quickly
that technology presently identified to meet them
creates other pollutants or hazards which are more
dangerous, or potentially more dangerous, than the
pollutants the technology is designed to reduce?
(This memorandum indicates that the answer may be
yes in the short term -- at least until catalytic
converters can be significantly modified or
abandoned in favor of new engine technology.)
Issue
What should be the Administration recommendation to Congress
on automobile emission levels for 1977-1981?
Options
LIBRARY
The feasible range of options is:
HC
CO
NOX
(grams/mile)
1.
Energy Independence Act
.9
9.0
3.1
(January 1975 Recommendation)
2. EPA Proposal (March 1975)
1977-1979
1.5
15.0
2.0
1980-1981
.9
9.0
2.0
1979 Sulfuric Acid Standard
(to be set later)
3.
1975 Standards
1.5
15.0
3.1
4.
Canadian Standards
2.0
25.0
3.1
5.
1974 Standards
3.0
28.0
3.1
6.
Standard through 1981 if
present law is not amended:
1977
1.5
15.0
2.0
1978-1981
.41
3.4
.4
5
Analysis
Over the next ten years, the quality of the nation's air
with respect to regulated pollutants is, with few exceptions,
virtually independent of the particular auto emission
option chosen. However, the health risk from sulfuric
acid is affected by the choice of option, as are auto
cost and fuel economy.
The principal reason for regulating HC is to reduce the
rate at which photochemical oxidants are formed, thereby
aiding in the attainment of the national ambient oxidant
standard. Data assembled by EPA shows that oxidant levels
in 1985 for most major metropolitan areas will exceed the
air quality standard even though they will decrease from
present levels in all problem regions. This reduction
occurs because of increased control on stationary sources
which account for 75 percent of the HC emissions and the
replacement of older uncontrolled cars with newer controlled
vehicles. The same data shows that the magnitude of this
reduction is virtually the same for all auto emission
options under consideration. The range of difference in
the 1975 oxidant level projected to occur because of auto
emission choice varies from 0 to 2/100 of a part per million
and in no air quality control region is this critical to
meeting the ambient standard.
With respect to CO, 7 regions out of 26 problem regions
will exceed the air quality standard in 1985. However,
the data illustrate that carbon monoxide levels will
decrease over 1971-1973 levels regardless of the
auto emission option chosen. This decrease occurs because
uncontrolled automobiles are being replaced by new, controlled
vehicles. Of all the regions projected to meet the ambient
CO standards in 1985, only 3 would fail to meet standards
as a result of choosing the most lenient auto emission option -
Denver, Puget Sound, and Portland, Oregon.
Based upon existing air quality data, there are no measurable
health risks associated with the application of hydrocarbon
and carbon monoxide emission standards (within the range
of options presented) which are less stringent than those
the President has proposed.
6
With respect to NOX, ambient concentration levels will
increase in all 10 problem regions by 1985. This increase
will, on the average, amount to 32 percent at the 3.1 auto
emission level and 22 percent at the 2.0 auto emission level.
However, this 10 percent difference has a very limited
effect on the ability of problem areas to achieve or main-
tain the ambient air quality level. This is because control
technology for stationary sources is not developed, and,
therefore, marginal reductions in automobile emissions
will be greatly exceeded by increased emissions from
stationary sources.
The application of the 3.1 NOX level will not greatly
increase health risks nationwide. With an ambient air
quality standard of 100 ug/m³ health data suggests that
the level at which people having acute respiratory problems
would show acute illness is 200 ug/m³. (Healthy indi-
viduals would show signs of respiratory diseases at
concentration levels of 400 to 450 ug/m³. ) Los Angeles
is the only area which is expected to approach the
200 ug/m³ level by 1985, and California has the lower
2.0 grams/mile level in effect as a State regulation.
Tab 2 presents more detailed analysis on the contribution
of automobile emissions to total ambient conditions and
identifies those regions which will exceed ambient
limitations for each pollutant as a direct result of
adopting less stringent standards than proposed in the
Energy Independence Act. All other regions in the country
will be below or above the ambient standards regardless
of the option chosen. It should be noted that actual
ambient air concentrations may be less than the levels
indicated. For example, the air quality projections used
do not reflect the reductions in vehicle miles traveled
that are already occurring as a result of higher gasoline
prices, retrofit programs or air quality maintenance plans.
The sulfuric acid emission problem is set forth in Tab 3.
It arises because of the chemical reactions within the
catalytic converter used to control auto HC and CO emissions.
Use of the catalyst is the most likely technical approach
to lower HC, CO and NOX emissions until new engines can be
brought on market probably around 1981. With present engine
technology, Option 1 requires use of a special air-injection
catalyst on standard and larger cars that generates twice
the amount of sulfuric acid as current catalysts.
7
Because reducing NOX generates additional HC and CO, the
air injection catalyst is very likely to be used to meet
Option 2 as well, thus defeating the purpose of EPA's
recommended increase in HC and CO limitations. Use of
the catalyst is optional with Options 3 through 5, but
it would probably not be used extensively for Options
4 or 5.
Other possible means of controlling sulfuric acid emissions
are reducing or eliminating sulfur in gasoline, but these
have been rejected by EPA as impracticable for cost or
other reasons. Therefore, the Administrator proposes to
set a sulfate emission limit for 1979 cars and leave the
means of achieving it up to industry. The problem with
this approach is that we don't know yet what additional
hazards may be created by the industry in solving the
sulfuric acid problem. In short, history may repeat
itself.
It should be emphasized that the timing and extent of
the public health risk caused by auto-emitted sulfuric
acid are not known. Current data indicate that it could
be a problem in some areas of California as early as 1977
under worst weather conditions or in 1979 in localized
areas of other States under less unfavorable circumstances -
though the extent of the risk and its timing are unproven
and controversial.
Secretary Weinberger has concluded that regardless of the
option selected for hydrocarbon and carbon monoxide emission
standards, a gradual reduction in the ambient levels of
these substances will be achieved. Therefore he supports
the 1975 interim standards of 1.5 and 15 for hydrocarbons
and carbon monoxide respectively. In respect to nitrogen
oxide, Secretary Weinberger believes that while it is
prudent to minimize exposure to this substance, he believes
it appropriate to select the 3.1 grams per mile option
in order to minimize the emission of new compounds whose
health significance has yet to be established.
The National Academy of Sciences is preparing a report which
reportedly will urge the nationwide implementation of the
statutory standards (Option 6) with the possible exception
of a 2.0 NOx level in all States (except California)
through 1981. The report concludes that instead of relaxing
or holding emission standards constant to avoid a sulfuric
acid risk, a program of desulfurization and reblending
should be introduced to whatever extent necessary.
8
The Manufacturers of Emission Controls Association has
released a report charging that EPA has significantly
overestimated the sulfuric acid problem. The report
concludes that a sulfuric acid standard is not warranted.
The report also concludes that if sulfuric acid becomes
a problem at a later date, then advanced catalyst
technology and the desulfurization of gasoline are the
best alternatives.
Several of the Federal agencies have reacted to the
aforementioned arguments. EPA, FEA, DOT and DOC do not
consider desulfurization or extensive reblending to be
viable alternatives because of the costs, the necessary
lead time, and the crude oil loss associated with their
widescale implementation. EPA has also shown skepticism
about the short run (1981) viability of advanced catalyst
technology.
There are other anecdotal problems with the converters
such as potential fire hazards, hydrogen sulfide emissions
and other potentially hazardous compounds created, but none
of these has been proven a significant risk.
Conclusion: The decision seems to turn on the question
of relative public health risk -- yet the facts bearing
on public health are not clear, and the data are incon-
clusive. It appears to be a trade-off between the known
small hazard of increased HC, CO and NOX emissions and
the unknown, but potentially large hazard of sulfuric acid
emissions.
A specific comparison of options follows. The summary on
cost and fuel economy impact of each is supported by
information in Tabs 4 and 5. Conclusions of recent major
studies of this problem are summarized in Tab 6.
The analysis of each option includes the pros and cons
of the technical issues involved -- health, fuel economy,
economics, and the environment. However, non-technical
considerations are also important in arriving at a final
decision. The major non-technical implications of each
option is discussed in the subsequent section.
9
Option 1 (Energy Independence Act)
(.9 - HC; 9.0 - CO; 3.1 - NOX
through 1981)
Arguments for:
Of the options presented, probably most acceptable
to environmentalists.
Would allow continued reductions in automobile
emission standards while studies of sulfuric
acid continue.
Option could be combined with other measures
to minimize sulfuric acid emissions where
localized problem might occur (e.g., reblending,
desulfurization, and re-allocation of low sulfur
gasoline) (See Tab 3.)
Will not effect 40 percent voluntary goal since
this option was the basis for voluntary program.
Arguments against:
Will require general adoption of air-injected
catalyst, which emits twice as much sulfuric
acid as catalyst currently in use. (See Tab 3.)
Will increase public health risk associated with
sulfuric acid emissions.
Will increase sticker price by $50 per vehicle.
(See Tab 4.)
May impose a 3 to 5 percent fuel economy
penalty over 1975 production automobiles -
85,000 barrels of oil per day in 1980.
(See Tab 5.)
Option 2 (EPA)
(1.5 - HC; 15 - CO; 2.0 - NOX
...
1977-1979)
(.9 - HC; 9.0 - CO; 2.0 - NOX
1980-1981)
(Sulfate standard to be set soon for 1979 model years)
Arguments for:
Sulfate standard would press oil and auto
industries to reduce emissions of sulfuric
acid that would otherwise result from choosing
the HC and CO limits of this option.
Will eliminate public health risk of sulfuric
acid after 1979.
10
Arguments against:
Tighter NOX level for 1977 and subsequent
model years may negate reductions in sulfuric
acid emissions resulting from relaxing the HC
and CO standards for two years. With given
technology manufacturers are likely to choose
the air-injected catalyst to meet this combin-
ation of limitations, particularly since more
stringent HC and CO standards are proposed
for 1980 and 1981 under this option. (See Tab 3.)
Continues public health risk associated with
sulfuric acid emissions until 1979.
Increases cost by $15 to $25 per vehicle
over current sticker prices. (See Tab 4.)
Imposes a 3 to 5 percent fuel economy penalty
over 1975 automobiles - 85,000 barrels of oil
per day by 1980. (See Tab 5.)
Option 3 (Current standards extended through 1981)
(1.5 - HC; 15 -- CO; 3.1 - NOX)
Arguments for:
Some auto companies would reduce the use of
catalysts and thus reduce emissions of sulfuric
acid.
Even with catalysts this option avoids significantly
increasing the public health risks caused by sulfuric
acid. (See Tab 3.)
By definition, no cost increases occur.
(See Tab 4.)
Continued fuel economy improvements will
not be interrupted. (See Tab 5.)
Arguments against:
Notwithstanding evidence to the contrary, the
popular perception will be that air quality will
get worse.
Lose much of momentum for reducing automobile
emissions, and, therefore, might undermine other
environmental initiatives.
11
While avoiding the increase in health risk
that is associated with Option 1, some risk
would remain as long as converters are used.
Options 4 and 5 (Canadian Standards or 1974 standards
through 1981)
(2.0 -- HC; 25 - CO; 3.1 -- NOX / 3.0 - HC; 28 - CO;
3.1 - NOX
respectively)
Arguments for:
Allows elimination of catalytic converter which
some companies will drop.
Permits decrease in emissions of sulfuric acid
without forcing another short-term technological
change.
Sharply reduces public health risk caused by
sulfuric acid emissions. (See Tab 3.)
Does not significantly impact ability to achieve
ambient air quality standards.
Energy savings would occur relative to
1975 production automobiles by 1980.
40 percent fuel economy goal could be exceeded
by 1980.
Would result in savings in the initial cost
of automobiles.
Arguments against:
Congress, at least key committees, will strongly
oppose a reversal of the long-run trend in the
reduction of automobile emissions standards.
Notwithstanding evidence to the contrary, will
be attacked as crippling nation's ability to
achieve ambient air standards.
Will be violently opposed by environmentalists.
Health scientists may oppose not lowering
NOX level.
Presents the greatest reversal from the
existing standards in the Clean Air Act.
Loss of fuel economy in the short term.
12
Options 4 and 5 (Sub-option)
A sub-option associated with the adoption of either the
Canadian or 1974 standards would be to ban the use of the
catalysts beginning with the 1977 model year.
Arguments for:
The mandatory removal of catalysts would eliminate
all health risks associated with sulfuric acid.
Cars without catalysts emit only one-fiftieth
(1/50th) of the amount of sulfuric acid emitted
by catalyst equipped vehicles.
It can be argued that merely easing limitations
(without banning the catalysts) will not insure
protection of public health since manufacturers
may continue to use the catalyst anyway.
Arguments against:
Mandatory removal at this time is premature since
the extent or timing of the sulfuric acid risk
is not precisely known.
Allowing the market to operate will result in
the optimal mix of converter and non-converter
use on vehicles. On the one hand, the potential
price effect would probably cause manufacturers
to drop the catalyst if they are not necessary
to meet the standards. But on larger cars, where
severe fuel penalties could occur if the converter
is banned, manufacturers would prefer modifying
the converter over the next five years to reduce
the sulfuric acid risk. In this sense, a
sulfuric acid standard would allow the manufacturer
much more production flexibility than a ban.
13
Non-Technical Considerations
Many environmental groups continue to oppose any relax-
ation of automobile emission standards. They argue that
sulfuric acid emissions can be controlled by desulfurization,
re-blending and the allocation of low-sulfur gasoline to
problem regions.
A significant segment of health scientists believe that
the side-effects of catalysts, such as sulfuric acid,
are more injurious to public health than are the pollutants
they abate (HC and CO). A large number of health scientists
will support a 2.0 NOX level, although a minority might support
a 3.1 level.
We have not discussed these particular options with either the
auto industry or labor. It appears, however, that all of the
major auto manufacturers would support any action which
would reverse the downward trend in emission standards.
We expect that labor will resist any actions which will
result in a significant increase in the price of automobiles.
Although several bills have been introduced in the Congress
to freeze the standards at the 1975 levels which involve
substantial use of catalytic converters, some members of
the substantive committees in both Houses have indicated
that at this time, they are not convinced that the sulfuric
acid problem is severe enough to justify delaying the
continued reduction of automobile emissions.
There is substantial evidence that by model year 1981
new "lean-burn" or "stratified charge" engines would
permit meeting the lower (2.0) NOX standard. Thus, another
variant of Options 4 and 5 would be to propose lowering
the NOX standard for 1981 models. However, under no
circumstances should it be made more stringent than 2.0.
In fact, unless application of the current statutory
NOX standard (.4 grams/mile) is delayed through at least
1990, the industry will not (and cannot) shift to a lean-
burn or stratified charge engine.
Even with such a variant, however, the environmentalists
would be very much opposed if either Option 4 or 5 were
adopted, and chances of Congressional acceptance is
quite slim.
FORD LIBRANY
14
The reason is that these options rean stors backward
from the current standards for HC and CO. I'ven
though there is now substantial evidence that the
Canadian or 1974 standards do not adversely change
the possibilities of attaining our clean air ambient
air quality standards for IIC and CO, and there is also
now at least a serious question of sulfuric acid
health risks from converters, claims will be made
that we "sold out" to Detroit. the problem is
compounded by comparison to your proposed Energy
Independence Act, which vas 180 degrees in the opposite
direction, with respect to NC and CO, less than three
months ago. Although you were apparontly not apprised
of the potential sulfuric acid problem in connection with
those decisions --- apparently because the experts vere not
then as concerned as now as to possible risk -- critics
will point to a reversal as showing we are in "disarray."
If either Option 4 or S is chosen, your commitment to
reviewing the situation annually to weigh the sulfuric
acid risks, technology advances, and new ways to attack
the stationary source problem should be stressed.
Prior to making a final decision on this issue, I recommend
that you meet with Russ Train, Rog Morton, Frank Zarb,
Cap Weinberger, Bill Seieman, Jim Cannon, Russ Peterson,
and myself.
Agency Positions
Mr. Coleman
Option 3
Mr. Frizzell (Interior)
Option 3
Mr. Morton
Option 3
Mr. Peterson
Option 2
Dr. Seamans
Option 3
Mr. Simon
Option 4
Mr. Train
Option 2
Mr. Weinberger
Option 3
(with retrofit of existing
stationary sources for
NOX)
Mr. Zarb
Option 3
(amend voluntary fuel
economy goal to
44 percent)
Mr. Lynn
Option 4
CC: Official File
Director
Mr. Gibbons
Director's Chron
Mr. Crabill
/NRD/EnBr/DGibbons/co
Deputy Director
Mr. Tozzi
5/16/75
TAB 1
CHRONOLOGY OF AUTOMOBILE EMISSION LEVELS
The statutory standards for automobiles have become
progressively more stringent since 1968. Whereas ambient
standards are established by the Administrator of EPA
as a regulatory action, automobile emission standards are
set statutorily in the Clean Air Act. The following table
shows the emission standards by model year. The
Administration has made two legislative recommendations
to relax the statutory standards. These are footnoted
below:
Model Year
Automobile Emission Standard
United States (Clean Air
(grams/mile)
Act)
HC
CO
NOX
Uncontrolled
8.7
87
3.5
1970
4.1
34
No standard
1972
3.0
28
No standard
1973-1974
3.0
28
3.1
1975-1976 2/
1.5
15
3.1
1977
1.5
15
2.0
1978
.4
3.4
.4
State of California (State law)
1975
.9
9.0
2.0
1/
In December 1973, the Administration proposed a three
year freeze of the standards at the 1975 interim levels.
The Congress adopted this proposal for two years
(1975 and 1976.)
2/
The Administration, in the Energy Independence Act of
1975, proposed adopting the standards for HC and CO
currently in force in the State of California, but
proposed keeping the NOX standard frozen at their
present levels through 1981.
3/ After public hearings, Administrator Train, as a
regulatory action, has retained the current HC and
CO standard through model year 1977. He had no
regulatory responsibility over NOX, however, and
therefore, the lower NOX level reflects current law.
At the same time, EPA made its recommendation for the
next five years. This recommendation is Option 2.
TAB 2
AIR QUALITY IMPACTS DUE TO LESS STRINGENT
AUTOMOBILE STANDARDS
The following tables show the direction and magnitude of
change in ambient concentration levels for HC, CO, and NOX
which would result from adopting standards which are less
stringent than those proposed in the Energy Independence
Act. Three points should be noted. First, though the
tables assume that the statutory standards will be in force
after the 1981 model year, if any of the options were kept
through model year 1990, the concentration levels for each
region would change very little and the conclusions reached
remain basically the same. Secondly, because the concen-
tration levels are projected through modeling techniques
marginal changes in the concentration levels, whether increases
or decreases, are often within the range of statistical error.
Third, the estimates of total auto pollution emitted are based
on historical growth rates for vehicle miles traveled and auto
fuel economy. No compensation has been assumed for the higher
cost of gasoline and the higher price of standard automobiles -
both of which have already affected total pollutants through
reduction in vehicle miles traveled and through change in the
mix of new cars on the road in favor of smaller cars which emit
less pollutants per mile. The auto-caused ambient pollution
levels are therefore likely to be overstated in 1981 - 1985.
Hydrocarbons
Only 25 percent of total hydrocarbon emissions are generated
by automobiles. Therefore, hydrocarbon ambient air concen-
trations tend to be much less sensitive than carbon monoxide
to the level of vehicle emission control.
The following chart displays the limited differential impact
that more stringent vehicle hydrocarbon standards would have
on ambient air quality by 1985 in those areas considered
to have a hydrocarbon problem.
(Table appears on following page.)
All of the twenty regions that are projected to exceed the
ambient standard in 1985 will be above the standard regardless
of the automobile emission level chosen. Conversely, all of
the regions projected to have concentration levels below the
ambient standard in 1985 at the stricter vehicle limitation
are also projected to be below the ambient standard if any
of the other automobile emission standards shown is chosen
instead.
Predicted Ambient Oxidant Concentration Levels
1985
(Ambient Standard = .08 ppm) *
HC Automobile Emission Standard
(in grams/mile)
Current Stds
EPA
Canadian Stds
Extended thru
Recommended
President's
Base
Region
through 1981
1981
Standards
Proposal
1971-73
Birmingham
.12
.12
.11
.11
.22
Mobile-Pensacola
.04
.04
.04
.04
.11
Clark-Mohave
.13
.12
.12
.12
.22
Phoenix-Tucson
.16
.16
.16
.16
.19
Los Angeles
.43
.42
.42
.41
.62
Sacramento Valley
.21
.20
.20
.20
.24
San Diego
.20
.20
.20
.19
.30
San Francisco
.23
.23
.23
.23
.30
San Joaquin
.22
.21
.21
.21
.26
S.E. Desert
.32
.32
.32
.32
.28
Denver
.17
.16
.16
.16
.28
NY-NJ-Conn.
.14
.13
.13
.13
.26
Philadelphia
.10
.10
.10
.10
.20
National Capitol
.26
.26
.25
.25
.38
Cincinnati
.12
.11
.12
.11
.17
Indianapolis
.08
.08
.08
.08
.14
S. Lou.-S.E. Texas
.20
.20
.19
.19
.32
Boston
.11
.10
.10
.10
.21
Toledo
.07
.07
.07
.07
.14
E1 Paso-Las Cruces
.06
.06
.05
.05
.13
Genessee-Finger
Lakes
.08
.08
.08
.08
.15
Dayton
.13
.12
.12
.12
.18
Portland, Oregon
.08
.08
.08
.08
.14
S.W. Penn.
.12
.12
.11
.11
.21
Austin-Waco
.07
.07
.07
.07
.16
Corpus-Christi
.14
.14
.14
.14
.19
Dallas-Ft. Worth
.05
.05
.05
.05
.13
Houston-Galveston
.27
.27
.27
.27
.32
San Antonio
.07
.07
.07
.07
.15
Puget Sound
.08
.08
.08
.08
.16
* The projected concentration levels assume the continuance of historic growth rates
for the central business districts in each region.
FORD DARAGE
3
Carbon Monoxide
Carbon monoxide levels in the atmosphere are much more
sensitive to changes in automobile emission controls that
either HC or NOX. Unlike those pollutants, the growth of
stationary sources over the next ten years all have little
effect on CO air quality. The following table shows 1985
projected concentration levels for twenty-six regions for
each of the options presented. The most important con-
clusion is that air quality is improving rapidly and will
continue to improve until 1985 under all of the emission
control options presented. This is because older uncontrolled
cars are being replaced by newer controlled cars. The under-
lined regions are those which would exceed the ambient
standard if a CO standard less stringent than proposed
in the Energy Independence Act were adopted.
(Table appears on following page.)
The chart reveals several observations. First, there is
only a limited difference in ambient concentration levels
at any of the standards represented, but the difference is
particularly small when comparing either the President's
proposed vehicle standard (9.0 grams/mile), EPA's recommended
standard (15 grams/mile until 1979 and 9.0 grams/mile from
1979 to 1981), or the current standard (1.5 grams/mile)
extended until 1981. In fact by 1985, the average ambient
levels for this pollutant will have been reduced about
70 percent over 1970 levels with all five options.
Secondly, the choice of option will not significantly
affect any single area's ability to achieve or maintain
the standard by 1985. When comparing the President's
proposed standard for carbon monoxide with EPA's recommended
standard or with the current standard extended through 1981,
with the sole exception of Denver, those areas below the
ambient standard in 1985 will be below it regardless of
the automobile emission standard chosen. The adoption of
the Canadian standard would mean that two additional areas
(Portland, Oregon and Puget Sound) would violate the ambient
standard by 1985, but only by a marginal amount.
Predicted Ambient CO Concentration Levels
1985
(9 ppm = ambient standard)
CO Automobile Emission Standard
(in PPM)
1974 and
Canadian Stds
Current Stds
Recommended
President's
Base
Region
through 1981
through 1981
Standards
Proposal
1971-73
Birmingham
6
5
5
5
18
North Alaska
11
11
11
11
35
Clark-Mohave
6
6
5
5
15
Phoenix-Tucson
16
14
14
13
42
Los Angeles
13
12
11
11
41
Sacramento Valley
7
6
6
6
22
San Diego
5
5
5
5
15
San Francisco
6
6
6
6
18
San Joaquin
4
3
3
3
13
Denver
11
11
9
9
33
Hartford-New
Haven
9
9
7
7
27
NY-NJ-Connecticut
15
13
13
13
51
Philadelphia
9
8
8
8
32
National Capitol
7
6
6
6
20
E. Washington
7
7
6
6
18
N. Idaho
Chicago
7
6
6
5
23
Indianapolis
5
4
4
4
15
Kansas City
6
5
5
5
15
Baltimore
7
7
7
7
18
Boston
6
5
5
5
18
Minneapolis-
St. Paul
9
8
8
7
22
Central New York
5
4
4
4
15
Portland, Oregon
10
8
8
8
26
S.W. Penn.
7
6
6
6
22
Wasatch Front
15
13
13
13
41
Puget Sound
10
8
8
8
24
5
Nitrogen Oxides
Federal Government and independent scientists have all
predicted that a steady increase in ambient nitrogen dioxide
concentrations will occur in metropolitan areas over the next
ten years. Because the technology for controlling stationary
sources is very limited, the EPA feels that a more stringent
automible standard will reduce that rate of increase. At the
3.1 grams/mile automobile emission limitation, a 32 percent
average increase in air quality concentration is anticipated
by 1985, compared to a 22 percent increase if the 2.0 grams/
mile limitation were adopted.
Though the more stringent standard would have a significant
effect on the overall predicted increase, the differential
effect of the more stringent automobile standard on the
ambient concentration levels in those areas with nitrogen
dioxide problems, is much less pronounced. This is shown
in the following table which displays ambient projected
concentration levels in the ten problem areas for 1980
and 1985 and for both automobile emission standards.
Projected NOX Air Quality Concentrations
(Ambient standard is 100 ug/m )
NOX Automobile Standard
(in grams/mile)
1980
1985
Base
Region*
3.1 g/m
2.0 g/m
3.1 g/m
2.0 g/m
1972-73
Phoenix
97
92
111
100
78
Los Angeles
173
163
194
173
148
San Francisco
93
88
102
92
82
Denver
119
115
135
125
100
NY/NJ/Conn
124
125
144
136
113
Philadelphia
107
104
121
117
89
National Capital
104
100
116
107
88
Chicago
133
129
152
145
117
Baltimore
99
96
116
109
96
Wasatch Front
121
116
137
124
100
*
Projected concent
ion levels assume the continuance of historic
growth rates for
ral business districts in each region.
6
By 1980, seven of the ten potential problem regions will
exceed the ambient air quality standard if the 3.1 grams/
mile automobile emission standard is maintained. All of
those seven regions, however, would exceed the ambient
standard even if the 2.0 grams/mile automobile emission
level were adopted. In addition, the three potential
problem regions which have projected concentration levels
below the ambient standard at the 2.0 grams/mile vehicle
limitation also will not exceed the ambient standard at
3.1 grams/mile.
With the exception of San Francisco, by 1985 all ten regions
are predicted to have concentration levels above the ambient
standard if either the 3.1 or 2.0 grams/mile limitation is
placed on automobiles. San Francisco would remain below the
standard if the more stringent emission limitation is
adopted and, in fact, California currently has the more
stringent limitation in force as a State regulation.
Two additional aspects of the above analysis should be noted.
First, the projected air quality data for the ten regions
assumes that the historic growth rates of industrial develop-
ment and vehicle miles traveled in each metropolitan area
will continue through 1985. No consideration, for example,
was given for possible reductions in future vehicle miles
traveled (and, therefore, reductions in pollutant emissions)
which result from higher gasoline prices.
Secondly, the projected increases in nitrogen dioxide cannot
be stopped without major technological innovations in
stationary source control. Therefore, regardless of how
stringent an automobile standard is applied, the future
concentration levels in major metropolitan areas will
primarily be a function of stationary source emissions. As
a result, EPA's desire for a more stringent vehicle standard
essentially reflects concern with total ambient concentration
levels and does not address the relative degree of control
exercised over stationary and mobile sources.
FORD
LISRARY
TAB 3
HEALTH IMPACTS OF SULFURIC ACID EMISSIONS
FROM AUTOMOBILES
Though ambient carbon monoxide and hydrocarbon concentration
levels are not significantly affected by the range of auto-
mobile emission standards presented, the concentrations of
sulfuric acid are affected.
Gasoline contains sulfur which, after combustion, is released
as sulfur dioxide. In the process of removing other pollutants
the catalytic converter changes some of the sulfur dioxide
into sulfuric acid mist.
The catalyst emission system generally used to meet the
1975 interim standards produces less sulfuric acid than the
system needed to meet more stringent emission standards.
Current estimates indicate that with existing automobile
emission technology, the President's proposed emission
standard for hydrocarbons and carbon monoxide (.9 and 9.0),
will require the use of an air-injected oxidation catalyst.
This catalyst results in a doubling of sulfuric acid emissions.
Though there are several non-catalytic technologies which
can meet the stricter emission limitations and which do not
produce sulfuric acid there is little production potential
for using these non-catalytic systems before the 1981 model
year.
While all scientists agree that sulfuric acid is a toxic
and potentially dangerous pollutant, there is still dis-
agreement on the quantities of emissions needed to pose
a health risk and on how long it would take for the
build-up in concentration levels to occur. Because new
data is currently under review and the state of knowledge
is in flux, specific calculations or final judgments on
sulfuric acid emission levels or the air quality or health
impacts of the options presented cannot be made.
The following table therefore represents our best estimates
of the years in which the sulfuric acid emission levels from
automobiles could pose a serious threat to public health.
FORD
LIBRARY
2
Model Year 1/ in which
Sulfuric Acid could pose
a serious health problem
Average
Adverse
Meteorological
Meteorological
Standard
Conditions
Conditions 2/
1975 Interim Standards
1981
1979
1975 California Standards
In 49 States
1979
1977
In California 3/
1978
1977
1/
The data assumes that there are no emissions of sulfates
from stationary sources, and that 70 percent and
90 percent of the fleet in 1975 and 1976 respectively
will utilize catalysts.
2/
Adverse meteorological conditions would occur in large
metropolitan areas on an average of 6-7 days a year.
3/
The dates for reaching a critical problem are earlier
in California than the remaining 49 States because
California utilizes higher sulfur gasoline.
3
The potential health effect of sulfuric acid emissions from
automobiles is complicated by two additional factors.
First, data available to date do not take into account
"background" emissions of sulfates from stationary sources,
e.g., coal-fired generating plants. These data represent
only the potential health effects of emissions from mobile
sources. The extent to which sulfate emissions from station-
ary sources add to the potential health risk associated
with sulfuric acid emissions from automobiles is not known
at this time. However, most analyses are tending toward a
separation of the two pollutants from a health perspective.
This is primarily because the particle size of sulfates is
much larger than sulfuric acid mist and is not absorbed
as deeply into the respiratory system. Also the toxicity
of sulfate emissions from stationary sources is generally
much less than sulfuric acid and finally, emissions from
stationary sources do not occur in the breathing zone as
do automobile emissions.
It is generally agreed that reducing nitrogen oxide
emissions will result in an increase in emission of hydro-
carbons from engines. To reduce that increment, manu-
facturers may increase the use of the air-injected oxidation
catalyst -- even to meet the less stringent HC and CO
standards. If this were the case, then nearly twice as
much sulfuric acid would be generated as projected for
the table above. However, at this time it is not known
definitely whether manufacturers could achieve reductions
of the HC increment through the use of engine modifications
instead of the air-injected catalysts.
Short Term Actions Available for Localized Sulfuric
Acid Problems
As noted in the section on health effects, under certain
adverse meteorological conditions localized sulfuric acid
problems could occur. There are two short-term actions
available to offset this possibility. While feasible,
both have some drawbacks as well.
FORD LIERARY
4
1.
Gasoline Blending - catalyst equipped vehicles could
be provided with lead-free and low-sulfur fuel which,
if allocated to certain problem areas, would reduce
emissions of sulfuric acid. This would, however,
impose an allocation problem on the industry.
Refiners have also indicated sufficient quantities
would not be available to meet widespread problems
beyond 1977 or 1978.
2. Desulfurization of oil - though technically possible
at this time, the desulfurization of oil would require
capital investment at a time when refiners are
attempting to expand domestic capacity. It would
also require an increase in crude oil consumption
due to additional refining and therefore, some increase
in the price of gasoline. If desulfurization were
instituted nationwide, capital cost would range between
$2 and $4 billion, crude oil consumption would increase
.5 percent and the price of gasoline would increase by
1 to 2 cents per gallon.
TAB 4
ECONOMIC IMPACT OF AUTOMOBILE OPTIONS
The options presented will impose varying cost burdens
on the consumer. Also, separate costs are associated with
actions on NOX and actions on HC and CO.
NOX
Consumers will face sticker price and operating cost increases
over the 1975 model vehicles if EPA's recommended 2.0 grams/mile
limitation is imposed. Estimates range from $10-25 for
front-end costs per vehicle and from $0-15 in operating
costs over 50,000 miles. However, not included are the
additional costs of increased fuel consumption associated
with this lower standard, which rough estimates place at
$1.7 million per day.
HC and CO
The costs of maintaining the more stringent hydrocarbon and
carbon monoxide standards (.9 and 9.0) as proposed by the
President in the Energy Independence Act is estimated to be
$50 per vehicle over 1975 automobiles. This would
represent the additional costs of using the air-injected
oxidation catalyst. However, not included are estimates
of operating costs which would result from the increased
consumption of gasoline that maintaining this option
implies. Rough estimates place this cost at $1.7 million
per day.
TAB 5
ENERGY IMPACTS OF OPTIONS
The options presented will have differential fuel economy
impacts and therefore different impacts on manufacturers'
ability to meet the 40 percent fuel economy goal. EPA dis-
agrees with the fuel economy penalties here. The agency
firmly believes that there are no technological barriers
to reducing emission standards without a fuel penalty.
However, a recent Columbia University study supports an
even larger NOX penalty than the one used in this analysis.
A.
Impact on 40 Percent Fuel Economy Goal
% Over
Shortfall (-)
1974
or excess (+)
Over President's
Options
Goal
Energy Independence Act
40%
EPA Proposal
36%
- 4%
1975 Stds. thru 1981
46%
+ 6%
Canadian and 1974 Stds. thru 1981
50%
+10%
B. Energy Impacts*
Options
Barrels per day (in 1980)
Energy Independence Act
85,000 (loss)
EPA Proposal
137,000 (loss)
1975 Stds. thru 1981
0
Canadian and 1974 Stds. thru 1981
27,000 (gain)
*
Base is 1975 model year automobiles meeting 1975 interim
emission standards.
TAB 6
SUMMARY OF REPORTS ON AUTOMOBILE
EMISSION STANDARDS
Two noteworthy reports have been published which address
an entire range of automobile options and their impacts
on air quality, health, energy and costs.
National Academy of Sciences
At the request of the Committee on Public Works, the
National Academy of Sciences submitted a report entitled
Air Quality and Automobile Emission Control (August, 1973).
Air Quality
The NAS concluded that:
a. Federal ambient air quality standards for carbon
monoxide (CO) could be met by 1990 even with some
relaxation of the present automobile emission standards -
but only if heavy vehicle and stationary sources were
reduced to the same degree as emissions from
automobiles.
b. The statutory emission standard of .4 grams for NOX
may be more stringent than needed but only if
stationary emissions are reduced to the same extent
as automobile emissions.
C. The impact of HC emissions from automobiles varies
greatly among geographical regions. In general, however,
the statutory standard of .41 grams/mile is not
sufficiently stringent to assure compliance with the
ambient air quality standard for oxidant. Present
analyses, therefore, are inadequate to justify changes
in the Federal motor vehicle emission standard for
hydrocarbons at this time.
Role of Auto Emissions in Total Health Problem
The NAS concluded that between one-tenth and one-fourth of
the air pollution hazard is a result of automobile
emissions. For the whole U.S. population, effects of this
magnitude might represent as many as 4,000 deaths and
4 million illness restricted days per year.
2
Columbia University
In a more recent study funded by the NSF, Columbia
University has publicized The Automobile and the Regulation
of Its Impact on the Environment. This report has
concluded that:
a. The ultimate success of a strategy placing major
reliance on emission controls in new vehicles depends
on the availability of a durable and maintainable
control technology. The development of such a
technology would be best promoted by delaying the
1975/1976 standards for HC and CO until the 1980
model year.
b. The availability of control technology limits the
degree of NOX emission reduction which can be achieved.
Because of errors in ambient NOX concentration
measurements, the eventual reductions in automobile
NOX emissions required to meet ambient air quality
standards are still in question.
C. While recognizing a fuel economy penalty of 5 percent,
it is recommended that an emission level of 2.0 grams/
mile for NOX be adopted for at least five years.
d. To induce advanced technologies, it is recommended
that a schedule for NOX emission standards for the next
ten years be developed and promulgated.
DRAFT
5/16/75
The Congress is now engaged in a review of automobile
pollution control requirements of the Clean Air Act. The
decisions that must be made on these requirements will
affect in a major way the interest of most all Americans --
those who own and drive cars and those who do not. The
decision is important to all Americans because it will
have an impact on our Nation's ability to achieve objec-
tives involving public health, energy, consumer prices,
unemployment, and the strength of our economy, as well as
the objective of improved air quality. The decision must
reflect the best possible choice as to priorities and
balance among the competing national objectives that are
involved.
On January 30, 1975, I recommended that Congress establish
auto emission standards that would remain stable for 1977
through 1981 model year cars. At the same time, my Adminis-
tration obtained the commitment of the nation's major auto
manufacturers to make a major effort to increase fuel
economy for the new car fleet in 1980 by 40% over 1974
levels.
Subsequent to those developments, the EPA conducted
extensive hearings relating to auto emission requirements.
On March 5, 1975, following those hearings, EPA Administrator
Train announced conclusions and recommendations with respect
to 1977-1981 standards which were different from the standards
I had proposed. The Administrator indicated that his deci-
sions and recommendations were heavily affected by his
- 2 -
conclusion -- which had the full support of the Secretary
of Health, Education and Welfare -- that sulfuric acid
mist emitted from cars equipped with catalytic converters
may, within a few years, cause a potentially serious health
problem. This new conclusion called sharply into question
the wisdom of tightening auto emission standards as I had
proposed on January 30. These tighter standards would
have required that many automobiles be equipped with
catalytic converters with air injection pumps. Automobile
catalysts equipped with air pumps emit more than twice as
much sulfuric acid as those without air pumps.
Following the EPA action, I directed that a thorough
interagency review be conducted of the auto emissions control
problem and of alternative emission control requirements, so
as to identify for each set of requirements the implications
for air quality, health effects, fuel economy and consumer
costs. Despite some uncertainties, principally with respect
to health effects that will result from sulfuric acid
emitted by catalytic converters, I believe the information
now available provides the basis for prompt decision on auto
emission standards.
Before presenting my specific recommendations, I believe
it is important to provide a brief summary of (a) the back-
ground and status of. current statutory requirements, (b) the
alternatives that have been evaluated within the Executive
Branch, and (c) the principle factors that should be taken
- 3 -
into account in deciding the auto emission standards issue.
This brief review of the matter should make it clear that
this is a most complex public policy decision that requires
weighing and balancing a broad array of potential benefits,
risks and costs for the Nation.
Background
The Clean Air Act amendments of 1970 set very rigid
standards and deadlines for the reduction of hydrocar-
bons (HC) , carbonmonoxide (CO) and oxides of nitrogen (NOX)
from automobiles. It proved impossible to meet the orig-
inal requirements and changes have been made. The current
statutory requirements are:
HC
CO
NOX
1977
1.5
15.0
2.0
1978 and future years
.41
3.4
.4
There is broad agreement that the current statutory
standards applicable to 1978 would be extremely difficult
and perhaps impossible to meet, would involve increased
costs and decreased mileage, and will have to be changed.
These requirements as well as the 1977 requirements are now
being subjected to Cogressional review.
Alternatives
The review by Executive Branch agencies considered the
implications of a range of alternative automobile emission
requirements which might be applied to 1977 through 1981
model automobiles. Specifically, the following standards
*
- 4 -
applicable to hydrocarbons (HC) / carbonmonoxide (CO) and
oxides of nitrogen (NOX) emissions have been considered:
Emissions in grams per mile
HC
CO
NOX
My January 30
recommendations covering
1977-81 model years
0.9
9.0
3.1
Mr. Train's March 5
conclusions
- for 1977-79 models
1.5
15.0
2.0
- for 1980-81 models
.9
9.0
2.0
Continue standards
applicable to 1975-75
models for 1977-81
1.5
15.0
3.1
Adopt Canadian 1975-76
standards for 1977-81
models
2.0
25.0
3.1
Reimpose standards
applicable to 1973-74
models for 1977-81
3.0
28.0
3.1
Important Factors
There are a number of significant factors that need to
be considered in evaluating the automobile emission problem:
1. Controls on auto emissions have produced significant
benefits and will continue to do so in those areas that
have an auto-related pollution problem. Lower pollutant
levels in these areas can reduce adverse health effects and
reduce photochemical oxidants (smog) which is aesthetically
unpleasant and a serious respiratory irritant.
2. Automobile related pollutants are a problem in a number
of metropolitan areas but are not a problem in many
parts of the country. Auto emission standards, however,
- 5 -
have been applied nationwide (except in California which
may have more stringent standards) and the added costs
for pollution control equipment, maintenance, and lower
gasoline mileage are paid by drivers in all areas of the
country -- including those areas that do not have a problem.
3. Controlling automobile pollutants is a technologi-
cally complex problem as illustrated by the fact that steps
taken to control some pollutants from internal combustion
engines have had the effect of increasing other pollutants
or creating new ones. For example, controls to reduce
hydrocarbons (HC) tend to increase emissions of oxides of
nitrogen (NOX) - and the reverse is also true. The most
recent example is the potentially serious problem of sulfuric
acid mist from cars equipped with catalytic converters
installed to meet 1975-76 hydrocarbon (HC) and carbonmon-
oxide (CO) standards. Also, experts now indicate that
reduction of NOX standards below the current standards (3.1
grams per mile) could require the use of larger catalysts
or catalysts with air pumps which increase sulfuric acid
emissions.
4. Considerable progress has been made on automobile
emissions since the 1970 Clean Air Act Amendments were
passed. In the case of HC and CO, the standards applied to
1973-74 model cars reflect a 65% reduction in emission from
- 6 -
pre-control levels (and 1975-76 standards reflect an 83 per-
cent reduction) * In the case of NOX, EPA determined subsequent
to the 1970 amendments that earlier assessments of NOX con-
centrations in air were in error and that a 90 percent re-
duction in NOX emissions was not necessary to meet ambient
air quality standards. However, NOX emissions have been
reduced by 12 percent from uncontrolled levels and work is
underway to find more effective ways of controlling NOX
emissions from stationary sources. Stationary sources con-
tribute more NOX than automobiles in most of the 10 metro-
politan areas that could have concentrations exceeding the
national standard over the next 10 years.
5. Tighter or looser auto emission standards for HC,
CO or NOX within the range of alternatives available make
little difference in the air quality in the areas that have
an auto-related pollution problem. This little known fact
is true because: (a) of progress already made in controlling
emissions or (b) automobiles are not the principal source of
the pollutant involved. The contribution of HC, CO and NOX
from automobiles will continue to decline as more and more cars
meeting existing or past standards replace older models in the
Nation's fleet of automobiles. In the case of carbonmonoxide,
concentrations in metropolitan areas around the country have
* Substitute parenthetic phrase if decision is to
maintain current (1975-76) standards.
- 7 -
-
been declining steadily. Hydrocarbon emissions (which are an
ingredient of photochemical oxidants or smog) have been de-
clining but less rapidly than carbonmonoxide because auto-
mobile exhaust emissions account for only about 25 percent
of the hydrocarbons that comes from other than natural sources.
In the case of NOX, three metropolitan areas in the country
experience concentrations at this time which exceed national
air quality standards and this number may increase to 9 or 10
areas in the next 10 years. The growth would be due primarily
to stationary sources. Tightening standards for automobiles
below the current levels could produce slightly lower con-
centrations in the future, but such tightening would not
assure meeting national ambient air quality standards in the 9
or 10 metropolitan areas expected to have a problem. As
indicated above, tightening of HC, CO or NOX standards is
expected to increase the emission of sufuric acid.
In addition, a reduction in vehicle miles traveled due
to energy conservation actions or growth in vehicle miles
traveled that is less than EPA has projected will further
minimize projected auto-related pollutant problems.
6. Experts believe there is little or no health impact
that can be attributed with the small margin of change in
ambient air quality that would result from tighter or looser
- 8 -
HC, CO or NOX auto emission standards within the range being
discussed. This is the case principally because tightening
standards beyond 1973-74 levels (1975-76 levels*) will have
very little impact on concentrations of these pollutants in
the areas that have an auto-related pollution problem.
7. There is uncertainty concerning the health impact
of sufuric acid mist emissions from catalyst equipped cars
because of insufficient data and divergent estimates of the
importance of the problem among the various interests concerned.
The seriousness of the sulfuric acid emissions problem will
depend upon (a) the amount of emissions from catalyst
equipped cars, (b) the extent to which concentrations of
surfuric acid buildup in areas that impact the public, and (c)
whether there is a threshold below which sulfuric acid is not
injurious to health. While there is uncertainty, the Admin-
istrator of EPA and the Secretary of HEW have made it clear to
me that they believe there is the potential for a significant
health risk that cannot be dismissed with information now
available. This assessment led the Administrator of EPA
to conclude on March 5 that HC and CO standards should not be
tightened at this time because tighter standards would, with
technology now available, force use of catalysts and air pumps
on many cars nationwide in 1977. Because of the potential risk,
the Administrator also announced that he is proceeding to set
an emission standard covering sufuric acid applicable to 1979
model cars.
*
Substitute parenthetic phrase if decision is to
maintain current (1975-76) standards.
- 9 -
8. Auto emission standards have had a significant
impact on miles per gallon of gasoline and on our Nation's
total petroleum demands and reliance on foreign sources.
a. Emission controls applied to automobiles between
the years 1968 and 1974 caused a very significant reduction
in miles per gallon of gasoline. It is true, however, that
the use of catalytic converters on 1975 cars manufactured
to meet 49-State emission standards permitted engine adjust-
ments which helped regain some lost gasoline mileage. The
higher levels of pollution created in the retuned engines
were captured and changed chemically in the catalytic con-
verters. Cars which must meet the tighter emission standards
applied in California generally get poorer gasoline mileage
than similar model cars produced for other states.
b. An additional impact on petroleum demands comes
from the need for unleaded gasoline for catalyst-equipped
cars. The production of unleaded gasoline required changes
in refinery processes which increased the qunantity of
crude oil required to produce each gallon of gasoline at the
required octane level.
C. While there is some disagreement among Executive
Branch agencies, the best information now available indicates
that for the next few years emission standards tighter than
current levels will involve significant gasoline mileage
- 10 -
penalties. Specifically, with technology now available,
there would be a fuel economy penalty associated with tightening
the NOX standard from 3.1 to 2.0 grams per mile and there
would be an additional penalty associated with tighter HC
and CO standards.
d. There is also general agreement that technology
is available to permit increases in fuel economy over the next
few years compared to 1974 levels if 1975-76 standards are
maintained through 1971. Even greater fuel economy im-
provements could be achieved within a few years if either the
1973-74 standards were reestablished or Canadian standards
were adopted.
9. In addition to poorer fuel economy, increased
consumer costs resulted from higher initial car costs for
emission control equipment and associated maintenance costs.
Tightening of HC, CO or NOX standards from 1975-76 levels would
involve additional consumer costs. Actions to reduce sulfuric
acid emissions from catalyst equipped cars would involve
large additional costs.
10. Less stringent auto emission within the range now
available would open up technological options for meeting
standards that would not be available with tighter standards
(e.g., the so-called stratified charge and diesel engines,
"lean-burn" technologies and other internal combustion engine
modifications). These technological options will permit
fuel economy improvements that are not possible with
tighter standards.
- 11 -
11. The basic philosophy and approach that has been
used to bring about auto emission controls needs to be
reconsidered in light of current conditions.
a. We should be clear about the philosophy that has
been applied in the Clean Air Act auto emissions standards
and the rationale behind that philosophy. Briefly, the
philosophy has been that automobile companies do not have
market incentives to develop technology to reduce auto
emissions and would not develop such technology unless
forced to do so by progressively rigid standards backed
up by law and regulation. It would be difficult to contend
that progress achieved so far in controlling auto emissions
would have been achieved if this approach had not been used.
On the other hand, hindsight suggests we may now be faced
with a potentially serious sulfuric acid problem which
might not have occurred had more time been allowed to
develop and assess technology before it was put into use.
The wisdom of continuing a rapid "technology forcing"
approach is open to question.
b. Auto emission standards have been changed frequently
in recent years, allowing little time for developing and
assessing alternative technologies. As standards have
become more stringent, the technological changes required
- 12 -
have become more extensive and more sophisticated. More
time is required to develop and assess improved technology
and bring it to a stage where it can be used on production
line cars. These factors, the current economic status of
the automobile industry, and the demands being placed on
the industry simultaneously to meet safety standards and
to improve fuel economy need to be kept in mind when the
Congress considers the question of whether standards should
be held stable for more years than has been the case in the
recent past.
12. Prompt Congressional action is needed on auto
emission standards. This matter warrants thorough dis-
cussion by the Congress and the public because of the far
reaching implications. The matter also requires an early
decision by the Congress. Specifically, the Administrator
of EPA adivses me that in order to meet deadlines for
emission testing and certification of 1977 model cars, the
automobile industry will need to know 1977 emission standards
by early August 1975 so that there will be time to complete
design and engineering, build prototypes, complete emissions
testing such as 50,000 mile endurance tests, and finally
to produce new cars in adequate quantity to meet demand
from the American public.
- 13 -
13. The broader economic implications of the auto
emission decision must also be kept in mind. There
undoubtedly has been some contribution to inflationary
and recessionary pressures in the economy from the
increased consumer costs, and poorer gasoline mileage
(and greater reliance on foreign oil) resulting from
emission control requirements. Inflationary and recession-
ary conditions have both contributed to and resulted
from sharply lower sales and employment in the auto
industry. Of course, any costs associated with auto
emission controls must be balanced against the health,
aesthetic and economic benefits that are gained from
improved air quality.
14. Actions to reduce auto emissions must take into
account other sources of the same pollutants. In cases
where stationary sources of the same pollutants are
significant contributors to a problem in the metropolitan
areas of concern, it may be far more cost effective to place
greater reliance on reducing pollution from stationary
sources. The problem of other sources is complicated
by a growing body of opinion that natural sources of
pollutants -- which cannot be controlled -- may be
sufficiently important in some areas to prevent attaining
- 14 -
national air quality standards regardless of what is done
to control man-made sources.
Legislative Recommendations
Based upon the information and data that have been
developed during the Executive Branch review of the auto
emissions issue, I have today recommended to the Congress
that the Clean Air Act be amended to set standards of
grams per mile for HC,
for CO, and
for NOX.
I have further recommended that these standards be kept in
force for
years. These standards would be equivalent
to those in effect for
model year cars. My conclusions
are based on an evaluation of air quality, health, consumer
cost, fuel economy, and other energy and economic considera-
tions.
First, the principal reason for my recommendation of
less stringent HC and CO requirements than I recommended
earlier is the unknown but potentially serious health
effects associated with sulfuric acid emitted from catalyst
equipped vehicles, and the fact that this problem is
exacerbated by the use of air pumps which would be needed
on most cars to meet those standards. In the absence of
better data and greater agreement among experts, the
potentially serious health effects must take precedence
over the known but very small potential health effect
- 15 -
associated with the slight changes in HC and CO concentra-
tions if HC and CO standards tighter than I have proposed
were established.
Second, I have concluded that tightening of the NOX
standard from 3.1 to 2.0 grams per mile would be undesirable
because the probable fuel economy loss and the probable
need to use air injected catalyst systems to meet the
2.0 standard, which would increase sulfuric acid emissions.
These potential costs are not balanced by the benefits of
the very small change in ambient air quality and the im-
perceptible impact on health that could result from the
tighter standards.
Third, the marginal benefits in a few metropolitan
areas which might result from tighter nationwide standards
are very small. Based upon the information now available,
those benefits do not appear to justify the additional
consumer and energy requirements costs, that would be
imposed nationwide. Furthermore, the standards I have
proposed preserve technological approaches to pollution
control that are cheaper in terms of fuel requirements and
consumer costs which would not be available under tighter
standards.
FORD LIBRARY & 834870
- 16 -
Fourth, I have proposed that the standards remain
constant for
years so that the industry is not
distracted unnecessarily from efforts to improve safety
and fuel economy. A pause for this period will not have
significant adverse effects on our progress in improving
air quality. It will also provide time for industry
and the Government to help avoid costly errors and
increase the chances of meeting fuel economy, safety
and consumer cost objectives.
Administrative Actions
Because of the far reaching impact that automobile
emission standards can have on all of the factors I have
discussed, I feel very strongly that we should have known
a great deal more about their impact before standards were
set.
I believe the Nation should not be subjected to far
reaching Federal actions such as establishment of auto
emission standards which required the catalyst without
far better information than was available before this
action was taken.
Current law requires that an Environmental Impact
Statement be prepared showing the expected environmental
impact of major Federal actions significantly affecting
the quality of the human environment. Somewhat ironically,
- 17 -
that requirement has not applied to Federal pollution
control actions, such as the setting of auto emission
standards which led to the catalyst technology. If such
a requirement had been followed we might have known in
advance of the health, environmental and economic impli-
cations of auto emission standards which led to the
installation of catalytic converters.
Because of my concern over the potentially unforeseen
results of Federal actions, I have directed previously
that inflationary impact statements be prepared on
significant Federal actions affecting the economy. I
intend to continue pursuing that basic approach to Federal
decision making.
THE WHITE HOUSE
WASHINGTON
Fill
May 16, 1975
TO:
JIM CANNON
THRU:
JIM CAVANAUGH
FROM:
GLENN SCHLEEDE
SUBJECT: BETTER INFO ON AUTO
EMISSION DECISION
Here is a quick a dirty response
to your question of this morning.
If you think this is worth pursuing
--e.g., for another paragraph in
the President's statement on auto
emissions, if he makes one -- I'll
be pleased to work on it.
cc: Mike Duval
FORD LIBRASK
THE WHITE HOUSE
WASHINGTON
May 16, 1975
MEMORANDUM FOR:
JIM CANNON
GERALD FORD
FROM:
GLENN SCHLEEDE
SUBJECT:
BETTER INFORMATION FOR DECISIONS
ON AUTO EMISSION STANDARDS
This morning, we discussed briefly the problem of missing
or biased data and information bearing upon the auto
emissions issue. This memorandum outlines briefly (a) the
general kinds of information needed, (b) the deficiencies
in our institutional arrangements for getting it, and (c)
a step that you might want to consider to improve the
situation.
Information and Data Needs
1. Research and development leading to new or improved
technology -- conventional internal combustion engine
and advanced concepts. Most of this is left up to
industry. Exceptions are:
a. A $10+ million "advanced auto power sources"
program now in ERDA which is doing some work on
concepts that might be useful in the mid-1980's
b. Small amounts of work in scatted labs of ERDA,
DOT
2. Health and Environmental Effects of pollutants. Large
programs in or sponsored by EPA, HEW (National Institutes
of Environmental Health Sciences and Occupational
Safety and Health), ERDA and NSF.
3. Transport of pollutants from source to receptor. This
involves monitoring, instrumentation, micro and macro
atmospheric work, modeling, etc. Large amounts of
work done by EPA, ERDA and some by NOAA. Additional
work sponsored by NSF.
4. Studies on tradeoffs and balance among air quality,
health, fuel economy, consumer cost, safety and other
objectives. Some work done in EPA, FEA, DOT, HEW,
ERDA, Commerce, Treasury, CEQ, and by OMB and Domestic
Council staff. Also some from NSF and the Science
Adviser's office.
GERALD FORD LIBRARY
The Deficiencies
1. We do a poor job in anticipating information require-
ments and -- as with the case of the sulfuric acid
situation -- run up against problems that require
time for R&D, development of instrumentation, modeling.
2. Much of the information that is developed is under the
control of agencies that have a particular point of
view to defend; e.g., EPA. Because of this, the
information that emerges is either biased or suspected
of being SO.
3. Virtually no one is charged with doing analyses on
a continuting basis that make the balances and lay out
the tradeoffs among objectives. The analyses that
do emerge reflect the agency's point of view. The
exceptions are those we get from OMB (2 people part time
on the auto emission issue), Domestic Council staff
(2 part time), and some staff and consultant help that
we've squeezed out of the science adviser's office.
4. The feedback loops from policy issues (i.e., what
information are we likely to need before we face this
issue again?) and regulatory decisions don't work well.
(Of course, this problem isn't limited to auto emissions.)
5. Despite the dollars we are pouring into R&D, monitoring
and studies, we don't have any organization charged with
and held accountable for reviewing and analyzing and
improving the data needed to make auto emission decisions.
This is also true despite the fact that (a) the decisions
are costly, and (b) we've know the issue would face us
periodically since 1970 and we know now it will keep
coming back in the years ahead.
Possible Steps Foreward
1. A directive to several agencies from the President to
step up their work -- primarily in number 4 of the
information and data needs, above. FEA and DOT are
good candidates to serve as "counterweights" to EPA.
ERDA might be a good candidate to lean on for (hopefully)
more objective overview analyses because: (a) ERDA has
broad capabilities in its various labs which could be
drawn upon if ERDA put together the right kind of
overview structure to do the integrating job, and (b)
ERDA has funds that could be diverted.
2. If we are to have a science adviser, a directive to him
to look at the whole area and report back on how existing
work needs to be reoriented to fill gaps. I frankly
doubt that much new money is needed. Until we have a
[ull time science adviser, Guy Stever might be given the
job.
ACTION
THE WHITE HOUSE
WASHINGTON
May 19, 1975
MEMORANDUM FOR:
THE PRESIDENT
FROM:
JIM CANNON June
FORD & LIBRARY 078839
SUBJECT:
AUTO EMISSION STANDARDS
Summary
The Congress now has before it from the Administration two
different sets of recommended auto emission standards for
1977-1981 model year cars: (a) your January 30 proposals
which were a part of your energy package, and (b) Russ Train's
March 5 decisions and recommendations which were driven by
concern over sulfuric acid from catalytic converters.
Briefly, the situation now is that:
Your January 30 proposal for auto emission standards is
no longer viable in the face of Russ Train's March 5 actions.
If Train's position stands, automobile companies cannot
commit to a 40% fuel economy goal by 1980.
All your advisers except Russ Train and Russ Peterson
believe Train's March 5 announcements should not be
adopted as Administration position.
You now have two issues to decide:
1. Do you wish to submit a new legislative proposal and,
if so, when and how should it be done?
All your advisers except Train, Peterson and Weinberger
believe you have no real choice but to submit a new legis-
lative proposal because there is confusion on the Hill as
to your position and there is no basis for attempting to
get a new fuel economy agreement with the automakers. If
you propose new legislation, there are two alternatives:
The normal procedure of developing the proposal, sub-
mitting and defending it.
A proposal by Senator Randolph that you issue a statement
and have Administration witnesses present facts, but not
take a position until Senate hearings are complete.
2. If you wish to propose specific standards, what should
they be and what model years should they cover?
- 2 -
Only Train and Peterson favor adoption of Train's March 5
position as Administration position. Your other advisers
are split between two options:
Continuing 1975-76 standards through 1981.
Adopting Canadian standards (which are slightly less
rigorous than 1975-76 standards) for 1977-1981.
The balance of this memorandum and Tab A presents details.
Other background factors that you should be aware of are:
OMB has led an extensive interagency review of the whole
auto emissions matter -- which provides the basis for Tab A.
Russ Train's decisions have been challenged by elements
within EPA, by environmentalists, and by elements in indus-
try most interested in continued use of converters. A
National Academy of Sciences group may also question the
decisions.
Hard information on the sulfuric acid matter is not available.
The Rogers Subcommittee of House Commerce is marking up an
auto emissions bill.
The Muskie Subcommittee of Senate Public Works is winding
up hearings this Wednesday with an appearance by Russ Train.
No other Administration witnesses are scheduled.
Auto companies must have a final decision on 1977 model
year requirements by early August. If Congress does not
act, Train's decisions for 1977 will stand. These involve
tightening the NOx requirement.
ISSUES FOR DECISION
The two issues listed above will be presented in the order
listed, but we recommend that you not decide either of them
until you have considered both.
Issue #1
All of your advisers, except Train, Peterson and Weinberger
believe that a new Administration position is needed. The
lack of clarity could be used by the Congress to criticize
the Administration or as an excuse for not moving on legis-
lation in time to meet the deadline facing automobile compa-
nies for 1977 models.
Normally, a new legislative proposal would be developed,
following your decision on specific standards, and submitted
to the Congress with a letter or statement. This normal
sequence is complicated by two factors:
FORD
LISRARY
- 3 -
The great complexity of the problem and the difficulty
of conveying a clear understanding to the Congress and
the public.
The absence of hard information on the potential serious-
ness of the sulfuric acid problem and the sharp disagree-
ment among experts and parties at interest over the
sulfuric acid question.
In addition, Senator Randolph apparently wants public encour-
agement to broaden the scope of the Muskie Subcommittee
hearings so that fuel economy and consumer cost issues are
considered as well as air quality. Through the Public Works
Committee Chief Council, the Senator has proposed that you
(a) issue a statement on the importance and complexity of
the issue, (b) emphasize the importance of a cooperative
effort with the Congress to resolve it, (c) request hearings
be opened so that Administration witnesses other than EPA
can present information on all realistic alternative emission
levels, and (d) not make specific recommendations until after
Senate hearings are completed.
Alternatives - Issue #1
Alt A. Develop new legislative proposal; submit the proposal;
backed up with a statement or fact sheet which dis-
cusses the implications of alternative emission
standards; and defend.
The principal arguments for this approach are that
(a) it is normal procedure, (b) it places you in a
strong leadership position -- and leadership is par-
ticularly important on this complex issue, and (c) it
probably would involve less time in getting to a final
Congressional decision ---- and the auto industry must
have a decision soon.
The arguments against it are that (a) the proposal
will become a target and the complexity and the lack
of definitive information makes any position somewhat
difficult to defend; (b) conceivably some new infor-
mation or positions will come out which will undercut
the proposal, and (c) discussion of other alternatives
may be limited.
Alt B. Follow Randolph proposal; help assure that information
is presented on all alternatives, take no position until
after hearings.
The principal arguments for this approach are that
(a) it would improve the quality of information
available to the Congress and the public
- 4 -
on all alternatives, thus increasing understanding of
a complex issue; (b) reduce the likelihood of Con-
gressional attacks on the Administration's proposal
and the substitution of a politically more attractive
but less meritorious alternative, and (c) you could
make your decisions on the basis of evidence developed
by Congress as well as the Executive branch.
The principal arguments against it are that (a) the
hearings will be closed with Train's appearance and
no really significant new information has emerged,
and (b) it may take longer to get final Congressional
action.
Recommendations and Decision - Issue #1
Alternative A. Develop new legislation,
Lynn, Seidman,
submit facts and take a
Friedersdorf, Cannon
position.
Alternative B. Submit facts only. Decide
Randolph, Train,
on a legislative position
Buchen, Peterson
after hearings.
Marsh
Issue #2. If you wish to propose specific standards, what
should they be and what model years should they cover?
Auto emission standards have an impact on air quality, health
effects, aesthetics, fuel economy, fuel ingredients, initial
car costs, car maintenance costs and, indirectly, on auto-
mobile sales and employment in auto and related industries.
Jim Lynn's memorandum at Tab A identifies and discusses the
alternative emission levels and their implications in detail.
That memo also presents the alternatives and recommendations
for your decision (Pages 9-12 of Tab A).
If you decide to propose standards other than those recommended
by Russ Train, your advisers believe it is essential that you
issue a statement which (a) explains the importance and com-
plexity of the issue to the public, and (b) outlines the
rationale for your position.
A decision on the alternatives in Tab A in fact involves a
number of implicit decisions:
In view of the uncertainty over the sulfuric acid problem,
should it be taken seriously?
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- 5 -
What consideration warrants higher weights in selecting
among alternatives -- public health, meeting air quality
standards, fuel economy, consumer costs, etc.?
For what period of time should auto emission standards be
set and stabilized -- three years, five years?
Will (or should) use of the catalytic converter be suspended?
Enclosed at Tab B is a rough draft of a public statement,
message or letter that could be used if you decide to take a
new position. Minor changes would be needed, depending on
the option you select. This draft is included in the package
as an attempt to give you a basis for judging the possible
extent of public understanding of the issue and your decision.
Even though energy and economic issues have taken on added
significance since the Clean Air Act's rigid requirements
were enacted, I believe that health continues to be the most
important consideration to the public and that health should
recieve highest priority consideration in making your decision.
By way of guidance in reviewing the detailed paper at Tab A,
several generalizations can be made:
Air Quality
- The auto-related pollution problem is large limited to
metropolitan areas; HC, CO or NOx now or in the future
exceed national ambient air quality standards only in
these areas.
- Regardless of the auto emission standard selected, there
will be little impact on the expected ambient air quality
in 1985 for HC, CO and NOx because:
CO has already been reduced substantially.
HC has been reduced substantially from car exhausts;
most HC comes from other sources.
NOx is now a problem in only three cities (Chicago,
Los Angeles, and New York City) and will be in nine or
ten by 1985, but most NOx comes from stationary sources.
Estimates are in dispute over sulfuric acid emissions
from catalyst equipped cars, and likely build-up of
sulfuric acid concentrations. But there is general
agreement that catalyst equipped cars emit fifty times
as much sulfuric acid as non-catalyst cars, and catalyst
equipped cars equipped with an air pump to meet Cali-
fornia HC-CO standards emit at least twice as much
sulfuric acid as catalytic mufflers in use in the rest
of the country.
- 6 -
Health Effects
- Since the marginal differences in HC, CO & NOx are
very small, regardless of the auto emission standard
selected, the potential health effect is also very
small.
- The health impact of sulfuric acid is expected to
be serious at levels expected in 2-3 years under
EPA's original projections and 4-6 years in selected
areas under more optimistic projections.
- Russ Train's decision on HC-CO standards (which he
has not changed, despite attacks on it) reflects the
conclusion that a very small but generally known health
impact from the marginally less restrictive HC-CO
standards is preferable to an unknown but potentially
serious health impact from sulfuric acid -- which would
be increased by tightening the HC-CO standard.
Fuel Economy
- Tighter emission standards generally result in less
fuel economy.
Consumer Costs
- The tighter the emission standards, the higher the
initial car cost.
Technological and Fuel Options
- The tighter the emission standards, the fewer the
technological options for meeting standards (e.g.,
statutory NOx levels -- 0.4 grams per mile -- rule
out diesel and stratified charge engine options.)
Recommendations and Decision (Issue #2) Data on alternatives
in Tab A, with arguments for and against at Pages 8-11.
Option 1: Energy Independence Act
- 1977-81
0.9 9.0 3.1
Option 2: Train - March 5
Train, Peterson
- 1977-79
1.5 15.0 2.0
- 1980-81
.9 9.0 2.0
(sulfate standard for 1979)
Option 3: Extend current stds.
Zarb, Coleman,
- 1977-81
1.5 15.0 3.1
Frizzell, Morton,
Seamans, Buchen
Weinberger
(Options 4 and 5 on next page)
Cannon
Marsh
Option 4: Canadian stds.
Lynn, Simon,
- 1977-81
2.0 25.0 3.1
Greenspan
Seidman
Option 5: 1973-74 stds.
- 1977-81
3.0 28.0 3.1
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LIBRARY
Dunhan
THE WHITE HOUSE
Caranamsh
WASHINGTON
May 23, 1975
ADMINISTRATIVELY CONFIDENTIAL
MEMORANDUM FOR:
JIM CANNON
FROM:
JERRY H.
SUBJECT:
Auto Emission Standards
Your memorandum to the President of May 19 on the above subject
has been reviewed and the following notation was made:
-- Issue #1 - I prefer Alt. B with an
accompanying message pointing out
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hard choices.
Issue #2 - If we go with this I go for
Option #3.
We should be prepared when Congress
reconvenes.
Please follow-up with the appropriate action.
Thank you.
cc: Don Rumsfeld
Jim Lynn
:
1 I ID 15