-57~
TABLE LV-B

Manufacturers' Estimates of Costs
(Per Vehicle)
for Control Equipment

Truck Category (GVWR)

Manufacturer 0-6,000 1b 6,001--8 500 1b
on 2/ minimal $165 - $210

rora »/ - $402

Chrysler (Dodge) of $12 $260

tae Sf nea. $400

AuC/Jeep 2! $7.60 ~ $122 $140 - $175
Toyota 2/ $106 - $150 Rede
Volkswagon 3% of sales price n.a.

SALES WEIGHTED AVERAGE g/ $8.64 - $16.67 $243.70 -— $264.63

a. Minimum system would be catalyst, EGR, and evaporative controls (EVAP).

Costs are for a catalyst system. A few 0 ~ 6,000 pound trucks may
tequire the installation of this system. Costs also include $37 for
engineering, test facility construction, and changes in operating
costs.

Some current LDTs may require EGR timer, air pump, catalyst, and heat
shields. 6,000 to 8,500 pound trucks will need equipment such as
catalyst heated air, exhaust system improvements, air pump, proportional
EGR. Cost includes amortized development, certification, retooling and
expansion expenses.

Cost includes cost for catalyst, air injection, EVAP, and carburetor and
EGR revisions. Cost also includes $127 for exhaust system changes.

C3 5/7 will require catalysts, transmission controlled spark (TCS), and
improved exhaust systems. The high cost estimate is for a system that
includes catalyst, TCS, and air injection for Cherokee Wagoneers and
truck models,

Costs for either a thermal reactor or catalyst which may be required
on some models to meet standards.

Assumes that costs for all importers will be the same as those for Toyota.


-121-



-23-

To further eliminate cross-over of body styles and vehicle usage
(and to eliminate the current situation. in which one type of truck may
be required to be certified under both the light and heavy duty truck
regulations) EPA has included an optional light duty truck category
for trucks. up to 10,000 pounds GVWR. Trucks in this class may, at
the manufacturer's option, be certified as light or heavy duty trucks.
This arrangement will allow vehicles in the 8500 to 10,000 pound
GYWR range to be certified under regulations which best reflect their

design and usage characteristics and will ninimize the number of

re currencly) certified under two

procedures.


S-1
SUMMARY SHEETS
FOR
FINAL ENVIRONMENTAL IMPACT STATEMENT
PREPARED BY
OFFICE OF MOBILE SOURCE AIR POLLUTION CONTROL

ENVIRONMENTAL PROTECTION AGENCY

1. Title of Action: Emission Standards for New Light Duty
Trucks. This is an administrative action.

2. Description of Action: The EPA has. set more stringent
emission standards for new light duty trucks, and has enlarged
the current light duty truck class to include trucks up to 8500
pounds gross vehicle weight rating (GVWR). The emission standards
which apply to trucks up to 8500 pounds GVWR are 1.7 grams/mile (g/m)
hydrocarbons (HC), 18 g/m carbon monoxide (CO) and 2.3 g/m oxides of
nitrogen (NOx). The EPA has set these standards for 1979 and
later model year light duty trucks.

3. Environmental Impact: This action will affect the air
quality of the nation as a whole, and in particular will improve air
quality in those areas of the country projected to have problens
in meeting air quality standards. About one-third of the U.S.
population now lives in those areas. In those areas the
action will, in 1990, result in a six percent oxidant air quality
improvement, a five percent carbon monoxide air quality improvement
and a three to four percent reduction in the expected air quality

degradation for nitrogen dioxide.


-117-



-66-

manufacturers who cannot. Spread out costs and recoup losses by increa—
sing prices in other markets may get caught in a cost-price squeeze.
The most susceptable to this type of predicament would be IHC since it
concentrates in the utility truck market and has estimated its costs
to comply at $400 per vehicle, well above the industry average of
about $250. Dodge, though it does compete in several LDT markets

may also have difficulty in recouping all its estimated $260 in costs.

AMC/Jeep, though a small producer, has estimated a cost increase of

$i75 and thus should be able to remain competi

terms of price.

Whether or not 4 particular manufacturer will be priced out of a
particular market is impossible to tell since it will depend upon how
the low cost manufacturers decide to price their products. This is a
corporate decision which must take into consideration many factors of
which one is the possibility of legal action being taken against cer-
tain firms if there is evidence of predatory pricing. To date there
is little evidence to support the conclusion that the price leaders of
the light truck industry have priced, or will price, their products so

as to intentionally drive competion out of business.


-77-

the majority of the nation by implementing a few of the available
strategies. For example, if a goal is to move people from one city to
another, i.e., commuters from Washington to Baltimore, and there exist
three possible means of meeting that goal, then the three means are
reasonable alternatives. If however, the three means fails to meet the
goal, either individually or in combination, the three cannot be consi-
dered as alternatives. Consider the following:

Alternative A can move 22% of the required people.

Alternative B can move 36% of the required people.

Alternative C can move 18% of the required people.

"

Implementing all three "alternatives" results in moving only 76%

of the required amount of people between Washington and Baltimore. Thus

the three "alternatives"

are not in actuality alternatives since even
if all three were implemented the goal would not be attained.

Much the same situation exists for the case of reducing nationwide
emissions of HC, CO and NOx in order to meet the NAAQS. Calculations
performed for a long-range Federal government planning effort 3/ indicate
the need for substantial emissions reductions. in large areas of the
nation. The following chart, based on measured air quality data for
1971 through 1973, represents the emission reductions needed to meet
NAAQS from sources which existed during the 1971-1973 time period. When
growth is considered, the needed degree of control is increased (i.e.,

more control than is indicated by the chart is needed today simply due

to growth in the number of both mobile and stationary sources).

37 Panel Report on Air Quality, Noise and Health, Interagency Task
Force. on Mobile Vehicle Goals Beyond 1980, March 1976.


-13-
B. Design Characteristics
The industry has traditionally grouped trucks into eight classes

based on gross vehicie weight rating (GVWR}. These classes are:

Class. Weight (lbs GVWR) Class Weight (Ibs GVWR)
Class I o - 6000 Class V 16,001 ~ 19,500
Class II 6001 - 10,000 Class VI 19,501 ~ 26,000
Class IIL 10,001 - 14,006 Class VII 26,001 ~ 33,000
Class IV 14,001 - 16,000 Class VIIL ever 33,000

Table II-l shows data collected by the MVMA which details the
levels of factory sales of trucks im these eight classes over the
past several years. These data indicate clearly that of ali trucks
sold in the U.S. in recent years, the majority (over eighty percent)
are less. than 10,000 pounds GVWR. Few Class III vehicles are
made though the volume did grow significantly between 1969 and
1973. Most trucks over 10,000 pounds GVWR are in Classes V
through VIII, i.e. over 16,000 pounds GVWR.

Table II~2 offers a more detailed look at the composition of
truck Classes I, TI, and III. These data show that almost all trucks
in these classes are less than 10,000 pounds GVWR with only two
percent of factory sales falling im Class III. Ninety percent of
the trucks in Class III are multistop trucks, primarily
incomplete vehicles used for mabile homes. Multistop trucks less
than 10,000 pounds GYWR are also produced but account for only
two percent of factory sales in Classes I and II. Other types
of incomplete vehicles [cab chassis, etc] make up four percent

of sales in Classes I and II and ten percent in Class III.


-126-

‘
: : t H
o TM
3 i *s >
S 4 o ~
Ss . Ss
tt GS
z .
“So



“7TT=


Table I¥-G

Cost Effectiveness of Selected Proposed Federai Emissions Contol Programs

Base Line Emissions Emissions After Control Cost ef Cantrol ($/ton)
Control Program Program Emission Level 1/ Program Initiated ric co NOx
Option 1
LD? Interim 1974 LT
Standard Standard 2.0/20/3.1
HOY 27/18/253
Current Ls
Levels 4.3/44/5.2 206 a1 aa
LDY 1975 1675 Ted.
California LDV
Standards Stendards 1.5/15/3.1 -9/9.0/2.0 303 30 165
LDV Fed. 1975 Fed.
Statutory Stds. LDV
Standards 1,5/15/3.1 241/38. 6/0.4 420 al 2300
HDV Fed.
Interim
Etandcard ~2 29 3 ad
LDV/LDT IM 3/ ~ - 61-414 4-29 -
T/ All emissicns Factors in grams per male HC/CO/NOx except Eor UDY
2/ Heavy Duty Vehicle (ED¥) ewissions levels based on 1974 vs. proposed 1978 HD¥
emissions standards.
1974 Standards: 16 grams/thp-hr (HC#NOx), 40 grans/bhp-hr (CO).
3978 Preposec Standards: 1.5 gracs/bhp-ne (IC), 25,0 grems/bip-hr (Co), 16.9 grams/bho/hr NOx).
3/ IM Cost Effectiveness calculaticns assume 3 30% failure race.
ii Gatained by weighting GéGo0g GVWR end €000-B5004 cium cost-eftectiversss values.

-ZL-


-30-

TABLE II-5
PROJECTED SALES AND REGISTRATIONS OF TRUCKS

IN THE NEW LIGHT DUTY TRUCK CLASS TRROUGH 1990

Sales Total Registrations 2/
Year (millions of units) (mtilions of units)
1974 1.97 4 17.4
1975 2.05 18.3
1976 2.13 19.2
1977 2.22 20.2
1978 2.31 21.3
1979 2.40 22.3
1980 2.50 23.4
1981 2.61 24.8
1982 2.71 26.0
1983 2.82 27.0
1984 2.94 27.7
1985 3.06 28.8
1986 3.18 29.9
1987 3.2 31.1
1988 3.45 32.3
1989 3.59 33.6
1990 3.74 35.0

if Figure (1.97 million) represents actual factory sales of light duty
trucks in the weight range 0-10,000 pounds GVWR, adjusted by 5
percent to account for vehicles estimated to be between 8,500-10,000
pound GVWR.

2/ Based on data from U.S. Census of Transportation, and assuming constant
growth of the light duty truck class over the period of interest (1960
to 1990).


for personal transportation, while multistop vehicles are used to a much
lesser extent for personal transportation. Therefore, the cutpoint

desired is the one which maximizes the number of pickup trucks, minimizes
the number of multistop trucks and cab chassis, does not exceed 9500

pounds GVWR, and if possible, is greater. than 8000 pounds GVWR. Considering
sales distribution to achieve this objective, 8500 pounds appears. as the
optimum minimum cutpoint. Selection of an 850C pound GVWR cutpoint

would expand the present LDT class from approximately 1.8 million

vehicles per model year to approximately 2.5 million vehicles per model
year. (based on 1973 MVMA sales figures).

There is no one breakpoint that can be established to separate
LDTs from HDVs which will completely eliminate cross-over or potential
cross-over of vehicle body styles and vehicle usage. Cases where some
models straddle the 8500 pound cutpoint will still exist. Therefore, it
is proposed that the cutpoint ‘be defined as shown in Figure 6. All
vehicles with GVWR at or below 8500 pounds must be certified with the
LDT test procedure. All vehicles at or above 10,000 pounds GVWR aust
be certified with the HDV test procedure. Manufacturers of vehicles
between 85C0 and 10, 6CO pounds GVWR can submit a request with their Pa:
reification applicaticens steting wh 2
wish to apply. This arrangement will allow vehicles in this ' "usage
overlap" GVWR range to be certified with the reguiations which best
reflect their usage characteristics and will minimize the number of
vehicles which would be certified under two test procedures.

Figure 6
LDT Cutpoints

LDT or HDV

LDT HDV
Certification Certification

7500 8000 8500 9000 $500 10000 10500 11000
Gross Vehicle Weight Rating, pounds

Two incentives would exist for manufacturers to certify these
vehicles in the optional range by the HDV test procedure rather than
the LDV test procedure. The current HDV test procedure is an engine test
procedure and involves a smaller sample of engines than is the case
under LDT certification, since the range of chassis options does not
increase the sample size. In addition, the current HDV standards are not
of equivalent stringency: to the LDT standards for an equivalent vehicle.


~37-

ASSUMPTIONS FOR TABLES III-A, III-B, and ITI-C

- Light duty vehicles will be controlled to
statutory emission levels (.41 HC, 3.4 CO,
-4 NOx) beginning in 1978 as required by

the current language of the Clean Air Act.

- Light duty trucks will be controlled to levels
comparable in stringency to the 1977 interim
light duty vehicle standards (1.7 HC, 18 CO,

2.3 NOx) beginning in 1979.

- Both light duty vehicle and light duty truck
evaporative emissions will be controlled to
more stringent levels using a new test procedure

beginning in 1978 as has been promulgated by

EPA, 41 FR 35626, 8/23/76.

- Heavy duty vehicle exhaust emissions will be
controlled to interim levels of 10 g/bhp-h
HC + NOx and 25 g/bhp-h CO beginning in 1978
as has been proposed by EPA, 41 FR 21292,
5/24/76. More stringent standards are planned
for 1983 but are as yet undefined and have

not been considered in the above tables.


C. Economic Impact

If manufacturers elect to pass the entire $219 cost of this regu-
lation on to the consumer this would increase typical 1975 list prices
of light duty trucks with GVWRs between 6000 and 8500 pounds by approxi-
mately 3.8 to 6.0 percent. Assuming that the relationship between
changes in price and the resultant changes in demand for the light duty
truck market is the same as that in the light duty vehicle market, the
implemeritation of the propdésed regulations could cause as much as a 3.8
to 6.0 percent decrease in unit sales for these heavier trucks. A six
percent decrease in sales, of 4,000 to 8,590 pounds is eq
3.0% decrease demand for all trucks in the new light duty truck class.
Manufacturers would be expected to experience similar losses in sales
revenue and profits.

This impact should be considered a worst case situation. In
performing this analysis EPA has attempted to provide a very conservative
estimate of the impact of these regulations on light truck demand by
assuming that the price elasticity of LDIs was -1.0. If this is true,
then a one percent increase in sales price would yield a one percent
decrease in sales. However, there is no economic data to support a
conclusion that a -1.0 price elasticity is realistic for LDTs. Industry
and academic studies done on passenger car price elasticities have
yielded values between -0.3 and -1.0. Thus on the low side a $219
price increase in 6000 to 8500 pound GVWR LDTs may result in only a 1%

to 1.8% decrease in sales of those trucks.


-33-

The projections of total mobile source emissions by class of vehicle
given in Tables III-A, III-B and III-C allow for a general overview of
the contribution to air pollution that each class of vehicles makes
through 1990, and of the distribution of the burden of control of
emissions from all mobile sources. From these tables it can be seen
that emissions from the class "other mobile sources," and to a lesser
extent those from heavy duty vehicles, grow in proportion to emissions
from light duty vehicles and light duty trucks. This apparent inequitable
distribution of the burden for reducing mcbile source emissions can

be in part accounted for by the lack of authorizing legislation

My

the control of emissions from the bulk of the category "other mobile
sources" (excluding motorcycles and aircraft), and due to the fact that
for heavy duty vehicles, no emission reduction credit is given for

the planned long term heavy duty vehicle emission regulation. 2/

This chapter examines the impact of one of the actions in EPA's
overall strategy to reduce mobile source related emissions. The contribu-
tion of light duty trucks to total mobile source emissions is examined, -
and projections are given for the improvements in air quality which can
be attributed to the light duty truck regulation in those areas which are

not expected to meet ambient air quality standards.

2/ The planned long term heavy duty vehicle emission regulations
include the development of an urban-based test procedure, and the
imposition of stringent emission standards for heavy duty vehicles.


~65-

Table IV-D

Market Sales: Trucks in the New Light Duty Truck Class LV

Light Truck Sales
% of Light as a.% of total % of Motor % of Passenger
Truck Market 2/ Truck Sales by Co. Truck Market Car Market

Chevrolet 36.7 90 34 21.2 3/
GMC 6.7 84 7.1 -
Ford 31.5 84 31.2 23.0
Chrysler (Dodge) 12.1 84 11.9 11.7
AMC/Jeep 4.0 i9n,9 3.5 3.7
THC 2.1 37 4.6 -

Other Truck Manufac—
tures 0.0 0.0 1.9 -

Other Manufac~
turers of Passenger

Cars - - - 22.2
Imports 6.9 - 5.8 18.2
100.0 - 100.0 100.0

‘l/” Light Truck defined as 0-8,500 GvWR.

2/ Based on U.S. Truck Sales (1975) as contained in Automotive News
1976 Market Data Book.

3/ GM's total market share for passenger cars was 43.4%.


~102-

The relative thoroughness of the two test procedures and the-relative
stringency of the two standards will be subject to modification: (1)

if imterim HDV regulations are promulgated and/or (2) when the "final"
HDV test procedures and standards are promulgated. Therefore, since
these incentives are more than likely short term, it would probably not
be cost effective for a manufacturer to redesign large groups of vehicles.

In addition, 95% of the under 10,000: pound GVWR trucks are currently
at or below 8500 pounds GVWR. Therefore, a relatively small percentage
of trucks fall into the optional category. There is little indication
that the percentage of trucks in this optional GVWR range will increase
in order to avoid LDT certification. Unless an entire model-line can be
pushed over the 8500 pound cutpoint, the result would be a two procedure
certification situation wich is not cost effective for a manufacturer,
especially considering the low model-line sales volumes in this GVWR
range. Major design changes would be required to move entire model
lines over the 8500 pound cutpoint. It is doubtful whether consumers
who are using LDTs primarily for personal transportation would be
willing to pay the additional costs which would occur as the result of
added weight. The e, it is more likely that when a model extends
from the Lpt range to the optional range, the manufacturer will choose
to certify the entire model with the LDT procedure to avoid the costs
of dual certification. This viewpoint nas been supported in informal
discussions with several manufacturers. On the other hand, efforts
to move the commercially used multistop or cab chassis vehicles over
the 8500 pound cutpoint (where the majority of them are currently
located) would essentially support the contention that those vehicles
should in fact be regulated as HDVs. This is also likely to happen
based on informal discussions with manufacturers.

E. Alternative Cutpoints:

Previous attempts to define a cutpoint between LDTs and
HDVs have considered the following options:

1. The cutpoint defined at 14,000 pounds GVWR. The 14,000
pound limit represents the point of minimum cross-over for currently
produced vehicles and also represents the point of minimum cross-over
in the future if manufacturers choose to "beef-up" some vehicles to
get them out of a LDT class. However, a 14,000 pound cutpoint includes
a large porportion of all multistop vehicles and incomplete motor
home chassis as well as a large number of incomplete cab chassis.

These vehicles tend to be used strictly for commerical or recreational
purposes and are not expected to drive like the current LDTs within
the urban environment.



eee

bot.


-43-

2. Air Quality Impact of the Action

The reductions in urban emissions in 1990 discussed above, 0.51
million tons per year of hydrocarbons, 3.0 million tons per year of
carbon monoxide and 0.25 million tons of oxides of nitrogen, will
result in measurable air quality improvements, Table IlI-F presents
those air quality improvements, and allows for a comparison with the
alternative of taking no action. Table III-F is a summary of the
results of an EPA analysis 4/ which examined the impact of this
regulation on the expected air quality of thirty-six Air Quality
Control Regions. The analysis was performed using emission factors

oresented in Appondix 2B to this repert for Light duty vehicles

and light duty trucks, and in Supplement No. 5 for the compilation
of Air Pollutant Emission Factors (AP-42), U.S, EPA, April 1975,
and using a computer. simulation model 5/ to predict the future air
quality impact of various growth and control situations.

Oxidants, the most pervasive air quality problem, will be
reduced six percent in 1990 as a direct result of this regulation.
This reduction in ambient oxidant levels will occur in those 29 Air
Quality Control Regions failing to meet the ambient air cuality
standard for oxidants which have been included in the analysis.
Similar improvements in oxidant levels, although not quantified

here, can be expected to occur in other areas of the country.

4/ Amalysis of Alternative Standards for Light Duty Trucks, EPA,
November. 1976.

S/ N. deNevers and R. Morris, "Rollback Modeling - Basic and Modified,"
presented at the annual meeting of the Air Pollution Control Association,
June 24-28, 1973. Chicago, Illinois, paper no. 73-139.


=85-

will be examined. Those alternatives, suggested by Chrysler Corporation,
Ford Motor Company and the Council on Wage and Price Stability are
described in Table VI-C and are examined below.

a. Alternative I - Impose More Stringent Standards, But Do
Not Change the Light Duty Truck Class Definition

b. Alternative II ~ Impose More Stringent Standards, and Change
the Definition ta Inciude Trucks up to 7000 Pounds CVWR

EPA has proposed to implement in model year 1979 more stringent
emission standards for heavy duty engines 6/, which are currently used
in trucks greater than 6000 pounds GVWR. It has been argued that

including the 6000 to 8500 pound GVWR trucks in the light duty truck

unnecessary, since in

subjected to EPA's more stringent heavy duty engine emission standards.
Commenters further claimed that since the cost-effectiveness of the
proposed heavy duty engine emission control strategy is greater than
for this regulation (i.e., fewer dollars per ton of pollution controlled),
it would appear to be a more cost-effective strategy overall to leave
the 6000 to 8500 pound GVWR trucks in the heavy duty engine class
and to impose more stringent heavy duty engine emission standards
on those trucks 7/.

Alternative II has been suggested by Ford and Chrysler as a
means of minimizing the adverse impacts perceived by those compaines
due to enlarging the light duty truck class to 8500 pounds GVWR. Ford
and Chrysler contend that the number of individual truck configurations 8/,

67 41 PR 21292, May 24, 1976.

a See, e.g., Council on Wage and Price Stability, April 12, 1976,
page 20.

8/ A vehicle configuration is.a specific combination of vehicle
weight, engine transmission, axle ratio and tire. size.


-6-

Estimates of the cost of achieving the 1979 standards have been
developed. Analysis done by EPA has led to the conclusion that a
sticker price increase of $219 would be necessary to install a catalyst
emission control system capable of meeting the final standards on those
trucks being added to the class.

4s most manufacturers have already elected to equip current Light
duty trucks with catalyst systems and the existing emission control
systems will meet the new emission standards with slight modification,
the real cost of this regulation is the cost of installing $219 worth of
control equipment on those vehicles which were formerly classed as heavy
duty vehicles (6CCO to 8500 pounds GVWR) and which have become light
duty trucks under the new class definition. These costs are estimated
to represent between 3.8 and 6.0 percent of the sales price of typical
6000 to 8500 pound GVWR light duty trucks. The aggregate cost to
install control equipment on all 1979 model year light duty trucks
is estimated to be about $309.2 million, of which about $8.7 million is
the expense of certifying the vehicles with EPA.

Consumer demand, employment and competition in the light duty truck
industry are not expected to be permanently impacted, as the long run
growth in production is expected to increase significantly and will help
to ‘decrease any short term market instability caused by this regulation.

F. Alternative Actions Considered

The principle alternative actions considered were (a) Take no
action, (b) Set alternative light duty truck standards and (c) Control
other sources of HC, CO and NOx. The alternative of taking no action

was rejected because major population centers are projected not to meet


I.

Il.

TIt.

TABLE OF CONTENTS

Introduction

A. Background

B. Deseription of this Action

C. Light Duty Truck Class Structure
D. Environmental Impact

E. Economic Impact

F. Alternative Actions Considered
G. Organization of the Report

Light Duty Truck Characterization

A. Introduction
B. Design Characteristics
C. Usage Characteristics
D. Selection of Light Duty Truck Class Definition
E. Emission Characteristics of Trucks in the
New Light Duty Truck Class
F. Growth of the New Light Duty Truck Class

Environmental Impact

A. Background

B.. Primary Impact
1. Emission Reductions for Light Duty Trucks
2. Air Quality Impact of this Action

C. Potential Secondary Environmental Impacts of
the Final. Regulations
1. Sulfuric Acid Emissions
2. Water Pollution, Noise Control and Energy

Consumption

Economic Impact

A. Economic Backgrouuus
1. Description of Light Duty Trucks
2. Descriptions of the Manufacturers
B. Cost of Implementing the Final Regulations
C. Economic Impact
D. Cost Effectiveness

E
»
to

NOUR wWwWe

bil

18
22

24
28

31
39
39
43

47
47

53
53
54
55
62
67


-40-

factor data on light duty trucks contained in Appendix B to this report,
urban emissions of HC, CO and NOx from the total in-use population

of light duty trucks have been projected through 1990 with and with-
out the regulations in effect (Table III-E). One can see that the
control standards will be effective in reducing the absolute urban

light duty truck emissions of HC, CO and NOx.


-71-
proposed 1979 heavy duty vehicle interim standards, the 1979 light duty
truck regulations are the most cost effective in controlling HC, CO
and NOx emissions. Further control of light duty vehicles becomes
increasingly costly as standards get more stringent than. existing
standards. However, additional control of light duty truck emissions
is possible without having to spend as much per ton of pollutant

controlled.


emission reduction strategies. Finally, there has been no further
consideration of alternative NOx emission reduction strategies, since
this regulation is as cost-effective as a wide range of mobile and
stationary source NOx emission reduction strategies.

In addition to considering control of other mobile and stationary
sources of HC, CO and NOx emissions, two alternative strategies in
addition to the one selected were considered. These alternatives are:

-Take no action to reduce light duty truck emissions.
~-Implement alternative emission standards for light

duty trucks,


ENVIRONMENTAL IMPACT STATEMENT
EMISSION STANDARDS FOR NEW
LIGHT DUTY TRUCKS
PREPARED BY

OFFICE OF MOBILE SOURCE AIR POLLUTION CONTROL

APPROVED BY

Eric 0. Stork, Deputy Assistant Administrator
for Mobile Source Air Pollution Control

Date: hobo
io¢


(x 1045

Number of Units Sold

eae

Ford £973 Truck Sales

Vehicle Sales by GVER

19 “T

t
: ' Multistop
i

wt Lo.

Cab Chassis

GVWR x 103


oo -129- .

'
BM -
_ ve v .
L . a
a . 4
a a ne

a
id



s-3

6. Availability: Copies of the final EIS were made available
to the Council on Envircnmeatal Quality and the public .
Single copies of the final EIS are available upon requese from the
Public information Center (PM-215), U.S. Environmental Protection

Agency, 401 M Street, 5.W., Washington, D.C. 20460;


Percent

of seles

Figure 4

Chevrolet 1973 Truck Sales
(19, 20, 39 series)

Percent of Sales by GVWR

Pickup & Chassis Cab (C&K-10)] SL.9
Station Wasoas (C&K-10) 3.2
FED Ueility vemtele (ce%-Iny | 5.3
Pickup & Chassia Cah (Co 6-20) Lo
eration Vannns (7ts79) Ls
Pickup & Chagats nb (C-39) 4h
Yan Statton ¥asnn (6210) O58
Han (6-10) 2.9
van seacton lagen (6020) Le
han (5220) 2.8
Van Seaton Hazen £6039) a

od.

0.7
si 3
Saletsrop ¢P-29) 0.6
Multistas (?-30) 1.3
Yotor Hose Lt

cvua x 107

4 5 6 7 8 9 19 Wl 12 13 14

~LOT-


-28-

F. Growth of the New Light Duty Truck Class

At the current time no known econometric models for estimating
light duty truck sales are available for EPA use. Since limitations
in time and availability of personnel do not permit internal development
of such model, simple least square regression analysis 7/ was used
to determine the pattern of light duty truck sales over a 15 year
period (1960-1974). From this data an average yearly growth rate
in sales was calculated. Estimated factory sales for light duty
trucks for 1975 to 1990 were then made by applying the growth
rate to producticn Figures, using 1974 production as a base year.

Figure 2-1 shows the recent growth in tke sales of light duty
trucks. Between 1960 and 1974 light duty truck sales grew at an
average rate of 4.1 percent per year. Over the same time period,
automobile sales grew at the rate of only 3.8 percent per year.

The current (1974) population of registered light duty trucks is
approximately 17.4 million. 8/ Table II-5 projects amnual new sales
and total population of light duty trucks through 1990 assuming an

annual growth rate of 4.1 percent.

7/ The “least squares method" is a statistical technique for fitting
a straight line through several data points.

8/ Commercial Car Journal estimate based on data from U.S. Census of
Transportation, Bureau of Census.


-87-
to be different than those which would be predicted for a 6000 to 8500
pound GVWR truck subjected to the same control strategy. This is the most
important distinction to be made when examining the merits of continuing
to classify 6000 to 8500 pound GVWR trucks as heavy duty vehicles.

The heavy duty engine emission test cycle is a steady-state cycle
which exercises an engine over a range of speeds and engine loads.
These different speed and load conditions (e.g., 2000 rpm and 75 percent
of rated power) were selected to be representative of the type of
operation that. heavy duty vehicles encounter in-use. Emission results
ootained from each of the steady-state acdos of operation on the test
cycle (13 for gasoline-fueled engines and 9 for Diesel engines) are
weighted proportionately to approximate the amount of time each of the
engine types experience in that steady-state condition in-use. The
results of these heavy duty engine testing cycles and the subsequent
weighting of the test values to obtain one emission level allow EPA to
predict the actual in-use emission rates for heavy duty vehicles. This
technique of predicting in-use vehicle emission rates based on the
results of an engine test cycle is a valid technique for heavy duty
vehicles since the engine test-cycle has been designed to model the
types of operation that the vehicle typically experiences in actual
use on the road. Further changes to the heavy duty vehicle emission
measurement precedures are being investigated by EPA in connection
with its long term heavy duty vehicle program.

Because the usage pattern that a vehicle experiences influences

its actual on-the-road emissions, the vehicle must be tested on a


Table VI~B
AVAILABLE NOx EMISSION CONTROL STRATEGIES

Control Strategy

(% control before strategy-% control NOx Removed Percentage of Cumulative. % Cost-Effectiveness Annual Cost Cumulative
control after strategy) (million of tons) Baseline of Baseline ($/ton) (billion $) (billion $)
*ktK Proposed Action 0.58 2 ielaial 73 0.042 kk
From 0% to 41%
Control
New Utility Boilers 352 il 1. 100 0.35 0.35
From 25% to 50%
Control
Industrial Boilers 2.46 7 18 150 0,37 0.72
From 25% to 65%
Control
Exist. Util. Boilers 0.62 2 20 225 0.14 0.86
From 25% to 50%
Control
Sta, IC Englnea 2.87 9 29 340 0,98 1.84
Frow 25% to 75%
Control
Other Mobile 2.9 9 38 450 1.3 3.14

From 19 yo/wile
to 80% Control

LDV From 2,0 to 192 6 4h 450 0.86 4.0
1.0 ym/mile

Util, Boilers From 6.62 20 64 1200 7.94 11.94
50% to 90% Control

Sta, IC Engines 0. 86 3 67 1700 1.46 3.43
From 75% to 90%

Control*

LDV to 0.4 gm/mile 1.15 3 70 2300 2.65 16.08

* STA IC ENG Control Does Not Include Small Engines

SOURCE: Air Quality, Nose and Health, Interagency Task Force on Motor Vehicle
Goals Beyond 1980, March 1976.

kee’ Not 4a original, added for tllustrative purposes,


-10-

as light duty vehicles, and have been tested on a test procedure
which accounts for a wide variety of commercial use applications.

In order for a regulation for the reduction of truck emissions
to be effective, two ccncerns must be satisfied by that regulation.
First, the test procedure on which the emission standard is based
should, to a reasonable degree, predict. the actual emissions of
the truck when the truck is operated in the environment where air
quality problems are acute, in this instance in urban environments.
Second, the emission standard imposed. by the regulation should
achieve reductions in emissions which are technically feasible for
all trucks subject to the regulation, with due consideration of
the cost-effectiveness of the control and the lead time necessary to
develop and implement the control.

The first concern arises due to the fact that emission
characteristics of vehicles differ depending on the operating
patterns of the vehicles. For instance, a vehicle operated at
a constant speed of 50 miles per hour would be expected to have
different emission characteristics than a vehicle operated in
stop and go traffic. The test procedure on which the emission
standard is based would be meaningless if it did not accurately
model the operating pattern of vehicles in the area of interest,
in this case urban operation.

The second concern arises from the widely varying design of
trucks. Trucks are produced with different design capacities,
and even are produced in markedly different manners. Because
of these vast differences in truck design all trucks cannot

successfully achieve the same absolute levels of emission control.


~52-

duty vehicle emission standards were 1.5 g/m HC, 15 g/m CO and 3.1 NOx.
In 1977, the light duty vehicle emission standards remained the same
for HC and CO, and changed to 2.0 g/m for NOx. Because EPA projects
that light duty vehicle emission control technology will be employed
on light duty trucks subject to this regulation, and because the final
light duty truck emission standards have been adjusted to account for
differences in weight between cars and trucks, it is concluded that
light duty trucks which employ emission control technology similar to
that employed on 1977 light duty vehicles will not experience a fuel
penalty due to more stringent emission control. As indicated by the
improvement accomplished by the light duty vehicle industry in model
year 1977, there eppears to exist the potential for improvements in
light duty truck fuel economy in the 1979 model year. It should be
noted that the fuel economy improvements for light duty vehicles in
the 1977 model year are a result of engineering improvements in
emission control systems, and are not due to reduced vehicle weight.
The referenced analysis estimates that an overall improvement in fuel
economy (which includes the benefits due to reduced vehicle weight)

of 6 percent occurred in the 1977 model year.


~94-

deleted (see issue #7). In addition, the analysis of the latest. road
load horsepower data has lead to a reduced road load horsepower. require-
ment (see issue #9). The net effect of these revisions has been to
assure that’ the proposed standards are not more stringent than the

1977 LDV standards. No change in the proposed standards has been

recommended.

5. Class Definition - Comments were divided over the issue of an
appropriate class definition with some support for the EPA proposal and
some alternative suggestions ranging from no change to the current LDT

(6000 pounds GVWR) class definition to enlarging the LDV class to include

vehicles up to 10,000 pounds GVWR.. Some manufacturers argued that
vehicle design parameters should be the basis for distinguishing. light
duty trucks from heavy duty vehicles. The EPA position has been that the
primary use of vehicles should govern their classification for emission
testing purposes, and the majority of trucks under 8500 pounds GVWR are
used primarily for personal transportation. Only those design features
which would largely preclude personal transportation have been selected
as criteria for allowing heavy duty certification. To this end FPA has
accepted the contention that delivery vans which can carry only property,

and are.characterized by much larger frontal areas than pickup trucks and

conventional vans, are properly regulated as heavy duty.

The recommendation is to exclude vehicles with frontal areas of
greater than 46 square feet. The other aspects of the class definition,
i.e., 6000 pound curb weight.and 8500 pound GVWR (optional to 10,000

pound GVWR) should remain unchanged from the NPRM. The 10,000 pound GVWR


-73-

CHAPTER V
Other General Considerations

A. Irreversible and Irretrievable Commitment of Resources

The major commitment of natural resources associated with this
regulation relates to the approach taken by the manufacturer to achieve
the standards. Although this cannot be accurately determined at this
time, analogies to automotive control and current light duty truck con-
trol will provide some evidence of potential commitment of resources.
In general, any resource commitment is expected to be negligible.

If catalytic converters’ are used exclusively to meet the 1979
standards, an additional commitment of platinum, palladium and steel
would be required over and above that needed for light duty vehicles
and current light duty trucks which already employ catalysts. The total
light duty truck demand for platinum and palladium might be as high as
18 percent of the automotive demand in 1990, or somewhat less than
180,000 troy ounces per year if all light duty trucks were to employ
catalysts. Should trends established for catalyst usage in 1975 on
light duty trucks 1/ continue through 1990, and should all heavier
trucks added to the light duty truck class employ catalyst, the
Incremental demand in 1990 (the amount which can be attributed to
this regulation) would be approximately 60,000 troy ounces per year.

4n increase of this size would not strain world production capabilities.

1/ 62 percent of the 0 to 6000 pound gross vehicle weight light duty
trucks used catalysts in 1975 and no 6000-8500 pound gross vehicle
weight trucks used catalysts.


-34-

Table ITI - A

Nationwide HC Emissions

10® tons per year (percent of total regulated mobile source emissions)

‘Source 1972 1975 1980 1985 1990
LDV. Exhaust 4.8 (41%) 4.9 (45%) 3.4 (412) 1.7 (38%) 1.0 (31%)
Evap + Crank-

case 3.1 (27%) 2.6 (242) 1.8 (222) 0.7. (16%) 0.3 (92)
LDV Total 7.9 (68%) 7.5 (69%) 5.3 (65%) 2.4 (53%) 1.3 (44%)
LDT Exhaust 0.8 G2) 0.8 (73) Q.9 (11%) 0.3 (18%) 8.8 (25%)
Evap + Crank-

case 0.6 (52%) 0.5 (5%) 0.4 (5% 0.2 (42) Q.1 (3%)
LDT Total 1.4 (122%) 1.4 (13%) 1.3 (162) 1.0 (22%) 1.0 (31%)
EDV Exhaust 1.7. (152) 1.4 (13%) 1.1 (132) Q.7 (16%) 0.6 (19%)
Evap 0.6 (52) 0.6 (6%) 0.4 (52) 0.4 (9%) 0.3 (9%)
HDV Total 2.3 (202) 2.0 (18%) 1.6 (202) 1.1 (242%) 0.9 (28%)
Total Regulated
Mobile Sources 11.6 10.9 8.2 4.5 3.2
Other Mobile
Sources 1.3 1.4 1.7 2.0 2.3
Total Mobile
Sources 12.9 12.3 9.9 6.5 5.5

Source: Revised Esmitates of Total Nationwide Fmissions for Various
Regulatory Alternatives, internal EPA memorandum, January, 1976,

as amended October, 1976.

4NOTE: Totals may not add due to rounding errors.


~46-

Table IIL - F
Urban Air Quality Impact of the Proposed Action

Average Percent Improvement in CO Air Quality
Concentration From Base Year (1970) (CBD Growth)

1380 1985 i990
No Action 25 50 58
Proposal 25 54 63

Average Precent Improvement in Oxidant Air Quality
Concentration From Base Year (1970)

1980 1985 1990
cBD* 15 27 26
MET#* 2 24
Proposal
CBD 16 31 32
MET 12 28 30.
Average Percent Degredation in NOx Air Quality
Concentration From Base Year (1972)
1980 1985 1990
No Action
CBD 7 7 12
MET 9 9 14
Proposal
cEBD 4 5 9
MET 9 6 10

*CBD = Central business district growth assumed for mobile sources.

*MET = Metropolitation area growth assumed for mobile sources.


TLL



-51-

2. Water Pollution, Noise Control and Energy Consumption

Control of light duty truck erissions is expected to have negligible
impact either on water pollution, or on the ability of manufacturers to
meet present and future noise emission standards for light duty trucks.

Fuel economy of light duty trucks is not expected to be adversely
impacted by this regulation. At the emission levels promulgated, most
light duty truck manufacturers are expected to equip light duty trucks
with catalyst emission control systems, resulting in no fuel economy
change for those vehicles currently regulated as light duty trucks (0 to
6C0O pounds GVWR). For those vehicles added to the light duty truck
class (6000 to 8500 pounds GVWR) which are currently experiencing a zero
to five percent fuel economy penalty compared to uncontrolled vehicles 11/,
application of catalyst technology is expected to result in fuel economy
comparable to that of uncontrolled vehicles.

Even though the emission standards promulgated for light duty trucks,
1.7 g/m HC, 18 g/m CO and 2.3 g/m NOx, require a reduction in NOx emissious
from the current 3.1 g/m NOx emission standard for light duty trucks, fuel
economy of trucks in the new light duty truck class is not expected to be
adversely affected. Analysis of the 1977 model year light duty vehicle
fuel economy results obtained in EPA's certification program 22 has
shown that 1977 model year light duty vehicles are 2.8 percent better in

fuel economy than comparable 1976 model year vehicles. In 1976, the light

1i/ An Examination of Interim Emission Control Strategies for Heavy
Duty Vehicles, OMSAPC, EPA October 3, 1975.

12/ Fuel economy of the 1974-1977 Models, Draft SAE paper September 1976.


-136-

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-47-

C. Potential Secondary Environmental Impacts of This. Regulation

1. Sulfuric Acid Emissions

Historically, stationary sources have been the major contributors
to sulfate concentrations in urban environments, contributing 99 percent
of the total sulfate air burden. 7/ With the introduction of the current
catalyst/air pump technology applied to mobile sources, there exists
the potential for a significant source of mobile related sulfate
emissions in the form of sulfuric acid aerosol. While of negligible
magnitude on a regional basis, mobile source sulfuric acid emissions
could produce a significant localized urban sulfate concentration ia
urban street canyons or congested urban freeway situations. Moreover,
mobile source sulfates differ from stationary source sulfates in that
they are emitted near the ground and in the form of a fine sulfuric
acid mist.

The increase sulfate emissions due to the use of oxidation
catalyst/air pump combination has been of considerable concern to EPA.
In pre-model year 1975 non-catalyst systems, most of the fuel sulfur
leaves the vehicle after combustion as $02. In cxidation catalyst/air
pump systems used on 1975 model year automobiles and light duty trucks,
more of the sulfur leaves the combustion chamber as S03. The S03

combines with water in the exhaust to torm sulfuric acid aerosol.

7/ Communication with M. Williams, OMSAPC, EPA, June 1975.


The two categories of man-made sources of HC, CO and NOx pollution
are stationary sources and mobile sources. In 1972, the stationary
source contribution to nationwide emissions of HC and NOx was roughly
equal to the mobile source contribution (see Chapter III, Tables III-A,
III-B and III-C), but mobile sources accounted for almost all the CO
emissions in areas encountering violations of the National Ambient Air
Quality Standards (NAAQS). Thus it could be concluded that HC and NOx
emission control strategies, on balance, should be apportioned. equally

among stationary and mobile sources, and that CO emission control should

be borne al

In preetice however, and
due to the statutory framework of the Clean Air Act, emission reductions
for significant mobile sources have been accomplished much more quickly
than those for stationary sources.

In comparing any mobile or stationary source. emission control
strategy as a reasonable alternative to this regulation, consideration
must be given to the purpose for the control of emissions. from both
mobile and stationary sources. The Clean Air Act as amended June 1974
requires that NAAQS be met in all regions of the nation by 1977. This
goal, while unlikely to be achieved by a number of urban areas of the
country in 1977 2/, requires large reductions in the emissions of HC, CO
and NOx. To be able to substitute one emission control strategy tor

another implies that the goal of meeting the NAAQS canbe achieved by

2/ Announcement of the Administrator of the ZPA, May 30, 1975.


-86-

each requiring a different emission control system calibration, increase
dramatically for trucks above 7000 pounds GVWR. This proliferation of
truck configurations in the weight range 7000 to $500 pounds GVWR occurs
because more trucks in this remge are special order trucks, built at
the request of the truck buyer to satisfy his individual needs.

Ford and Chrysler also contend that above 7000 pounds GVWR,
trucks begin to take on truly heavy duty characteristics, such as
components of greater weight and durability than passenger car components,
rougher ride. and slower acceleration capabilities.

Cost-effectiveness data for the proposed heavy duty engine
emission control regulation were developed by considering the amount
of emission control achieved by, and the cost for such control, for a
“typical” heavy duty truck. "Typical" in this instance is a heavy

duty vehicle with the following characteristics 9/:

Gasoline-Fueled Diesel

24,000 pounds GVWR 55,000 pounds GVWR
16,000 miles per year 43,600 miles per year
10 year Life 10 year life

4.6 mpg 4.6 mpg

It is not appropriate to conclude that costs for control of 6000
to $500 pound GVWR trucks under the 1979 heavy duty engine emission
standards would be the same as the costs to control a "typical" heavy
duty truck as described above. Further, the predicted emission
reductions for a "typical" heavy duty truck when subjected to the

1979 heavy duty engine emission control regulations can be expected

9/ Draft Environmental and Inilationary Impact Statement, Interim
Heavy Duty Engine Regulations for 1979 and Later Model Years,
EPA, April 21, 1976.


TABLE ILI-D

Estimated Incremental Degree of Control for

Final Emission Standards

Less Than 6000 6000 to 8500 Overall?
Vehicle Weight Category Pounds GVWR Pounds GVWR Incremental
Exhaust HC 15% 53% 38%
Exhaust CO 10% 44% 29%
Evhaust Noh 25% 55% 42%
Evaporative HC yab 28% 10%
Crankcase HC ~_ NAc

Weighted by vehicle miles traveled, and based on change in lifetime

emissions of a typical truck resulting from the proposed standards.

Evaporative emission standards currently apply to light duty trucks

in the weight range © to 6000 pounds GVWR therefore no further control

is assumed.

Gasoline engines, under the current light and heavy duty vehicle regu-

lations, have no crankcase emissions.


-127-

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-120- +

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There is the potential for an increase in sulfuric acid
emissions from trucks in the new light duty truck.class, although
such increase at most would be slight. Sulfuric acid emissions
from mobile sources have been extensively examined by EPA, and
there is no indication at this time that current levels of mobile
source sulfate emissions represent an immediate hazard to the public
health or welfare. EPA's examination of the sulfuric acid emissions
from mobile sources is continuing.

4, Economic Impact: The sticker price of new light duty
trucks is expected to increase slightly for trucks currently
regulated as light duty trucks (0 to 6000 pounds GVWR), and could
increase as much as $219 for those heavier trucks being added to
the new light duty truck class. Fuel economy of. all light duty
trucks should not be adversely affected.

5. Alternatives Considered:

A. Take no action.
B. Further control of emissions from stationary sources.
C. Further control of emissions from mobile sources other
than light duty trucks.
D. Alternative means for control of light truck emissions:
I. Impose emission standards of 1.7 g/m HC, 18 g/m
CO and 2.3 g/m NOx, but do not change the light
duty truck class definition.
IL. Impose emission standards of 1.7 g/m HC, 18 g/m

CO and 2.3 g/m NOx, but limit the enlarging of
the light duty truck class to 7000 pounds GVWR.


FIGURE 1
PERCENT OF TRUCKS USED FOR PERSONAL TRANSPORTATION AS A FUNCYION OF CROSS VEHICLE WEICHT RATING

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uotieqiodsusiy, [RUCSiad 1oJ asf] quaciag

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1972 Censns

Source:


-64-
the product mix of light duty trucks sold may cause deereases in
demand, and therefore employment, at some plants which may be made
up by increased output at other plants.

Competition in the light duty truck industry is unlikely to

‘be significantly affected by this regulation. Table IV-D shows
the percentage of the light duty truck market, total truck market,
and passenger car market held by each firm. The numbers have

historically been quite consistent with GM and Ford being the dominant
market forces.

The low volume producers may be Mora hard pressed, however, to
bear the costs of certification and any costs to develop a control
system for use on light duty trucks. Dodge, AMC/Jeep and International
Harvester may be placed at a disadvantage because they have smaller
production runs over which to spread costs of developing. and testing
control systems they. will eventually use in production trucks.

Further, at least IHC will experience some disadvantage because it has
certified only heavy duty engines since 1975 and therefore has very
limited facilities and experience for developing LDV type control
systems for their products that will be LDTs after 1979.

The smaller volume manufacturers may be subject to intensified
price competition in some markets after the 1979 regulations are
promulgated. Larger manufacturers who can spread cost increases

out over several markets, may increase prices in selected markets

or of selected trucks by léss than the actual costs. Smaller


-50-

By 1978 this figure is expected to increase significantly. Of those
trucks manufactured in 1975, about twenty percent were equipped with a
catalyst in combination with an air pump (approximately 280,000 vehicles).
This compares with 1975 light duty vehicle sales figures for catalyst/air
pump vehicles of 2.5 to 3.0 million units.

The final light duty truck emission standards were set. at levels
which do not require the application of catalyst technology, and in no
case should the standards require the application of catalyst/air pump
technology. Even though these standards do nor require the use of
catalyst/air pump technology, some manufacturers may choose to employ
such technology on some trucks to increase fuel economy and driveability.
In worst case 10/, the incremental increase in catalyst/air pump vehicles
in 1979 as a result of the proposed regulation would be 760,000 vehicles
per year. This worst case situation would represent a annual increase

in all catalyst/air pump vehicles of less than seven percent.

i0/ internal EPA projections based on trends in 1975-1977 catalyst
usage.


-99-

Appendix A

Selection of a Breakpoint Between LDTs and HDVs

A. Design Characteristics:

Examination of the physical characteristics of all trucks
in the HDV class leads to the observation that the vehicles between
6000 and 10,090 pounds GVWR more closely resemble LDTs than HDVs.
MVMA sales data (See Chapter II) show that about 60% of all HDVs lie
within the 6000 to 10,000 pound GVWR range. Based on 1973 sales, this
represents 761,000 vehicles. (For purposes of comparison, roughly
1.7 million LDTs were sold in 1973.) Nearly 85% of the 6000 to 10,000
pound GVWR vehicles are pickup trucks, vans, and station wagons built
on a truck chassis. These vehicles differ from their LDT counterparts
only in having slightly higher capacity chassis components, including
tires, suspension systems, frames and brakes. All of the vehicles in
the 6000 to 10,000 pound GVWR range use the s same engines as LDTs, differing

res such as c

ator and dist

calibrations, and in some cases, lack of ' "add-on'' emission conttois
(EGR, air pumps, evaporative emission controls). 1/

The 10,000 to 16,000 pound GVWR range represents a transition
range where significant changes in vehicle design occur. Less than 2%
of all vehicles in thecurrent HDV class fall within this range. Approxi-
mately 90 to 95% of the vehicles in the 10,000 to 14,000 pound GVWR
range are motor homes built by over 100 manufacturers on.bare chassis.
sold by the four major light truck manufacturers. The vast majority of
these are built on Dodge chassis. According to 1973 MVMA sales data,
over 39,999 of the 44,000 vehicles sold within the 10,000 to 14,000
pound GVWR range were motor homes on Dodge chassis. Some of the vehicles
in the 14,000 to 16,000 pound GVWR range are also motor homes, but in general,
the vehicles in this range (6300 in 1973 according to MVMA) appear to
be working type vehicles with engines and chassis more like heavier
vehicles than LDTs.

B. Usage Characteristics:

Since the physical characteristics of trucks are basically
similar up to about 10,000 pounds GVWR, a decision on a breakpoint is
largely dependent upon usage data. The most appropriate GVWR cutpoint
would be one which maximally separates those truck types which are
basically used for personal transportation from those truck types which
basically have commercial applications. The 1972 Department of Commerce
Truck and Bus Survey data 2/ and the 1973 Department of Transportation
Weigh Station Survey data 3/ were used to investigate the usage character-
istics of vehicle models by GVWR.. The histogram in Figure 1 summarizes
the responses of truck owners who were asked to specify the primary
usage application for their vehicle. The histogram shows the percent of


=24-

E. Emission Characteristics of Trucks in the New Light Duty Truck
Class

Trucks in the new light duty truck class, having been tisterically
subjected to two separate regulatory requirements, currently have widely
differing emission characteristics. Those trucks which have previously
been regulated as light duty trucks (0 to 6000 pounds GVWR) have been
subjected since 1975 to standards of 2.0 grams per mile (g/m)
hydrocarbons, 20 g/m carbon monoxide and 3.1 g/m oxides of nitrogen
(2.0 g/m in California). Actual emission levels of trucks subjected
to those standards vary with vehicle age and the deterioretion
associated with the particular emission control system used on the
individual truck. For a typical light duty truck which has been
subjected to a 2.0 g/m hydrocarbon standard, actual performance
emission levels would be expected to vary from 1.6 g/m during the
truck's first year of operation to 7.6 g/m at the end of the truck's
in-use life. Similar ranges would be expected for carbon monoxide
and oxides of nitrogen under a 20 g/m and 3.1 g/m standard
(respectively), with carbon monoxide performance levels ranging
from 20 g/m to 99 g/m, and oxides of nitrogen performance levels
ranging from 2.5 g/m to 3.9 g/m.

The remainder of the trucks in the new light duty truck class,
those in the GVWR range 6000 to 8500 pounds, have been subjected
since 1974 to heavy duty engine standards and have been tested
using heavy duty engine test procedures. Initial (first year)
emission performance levels for a typical 60CO to 8500 pound

GVWR truck were established in an EPA testing program 5/ at 4.3

5/7 EPA in-house testing, and "Technical Evaluation of Emission Centroi
Approaches and Economics of Emission Reduction Requirements for Vehicles
Between, 6,000 and 14,000 Pounds Gross Weight", Calspen Corp. November
1973, EPA-460/3-73-005.


-20-

trucks are primarily commercial use vehicles. This would
indicate that an appropriate divisor between light duty trucks
and heavy duty vehicles would be one which maximizes inclusion
of pickup trucks in the light duty truck class, and which

minimizes inclusion of panels, cab chassis and multistop trucks.


~1U 3.

2. The cutpoint defined at 10,000 pounds GVWR. The 10,000
pound limit is used by the Department of Transportation to define light
trucks, and it currently includes all standard pickups, vans, and station
wagons.’ However, this cutpoint splits the muitistop vehicles and motor
homes and cab chassis production which increases markedly arcuna 10,000
pounds GVWR. Thus, these non-personal usage vehicles would have to
be certified under both the light duty and heavy duty certification
programs. This results in increased cost to the manufacturer and the
EPA, The.10,000 pound cutpoint would result in a class which is mostly
composed of personal usage trucks with similar payload characteristics;
however, a small fraction of the class would have substantially different
usage and payload characteristics.

3. The cutpoint defined in terms of body styles. A body
style definition would define a LDT class to include all pickups, vans
and station wagons. Other vehicles such as motor homes, aultistop
vehicles, stake trucks, box vans, and tow trucks would be excluded.

This approach is, however, virtually unworkable since. it is not possible
to clearly define some.of the applicable body styles.
@ motor home is often difficult to
body styles could de adequately defined based on current venicie design,

ic is not possible to predict future design developments. As a result

of this problem, a body style definition has not been determined reasonable
in this analysis nor has it been received well by the manufacturers.

Footnotes

1/ Technical Evaluation of Emission Control Approaches and
Economics of Emission Reduction Requirements for Vehicles
Between 6,000 and 14,000 pounds GVW, by Bogdan, Burke and Reif,
Calspan Corp., Nov. 1973, EPA-460/3-73-005.

2/ "Truck Inventory and Use Survey," 1972 Census of Transportation,
U.S. Department of Commerce, October, 1973.

3/ 1973 Truck Weigh Station Survey Data, U.S. Department of
Transportation, Federal Highway Administration.


-32-

All of these actions, including the reduction of emissions from
light duty trucks, are a part of EPA's overall strategy for achiev-
ing ambient air quality standards. When examined individually,
emission reductions from any one of the several actions may appear
to be marginal. However, when examined in the aggregate, they provide
for substantial reductions in mobile source emissions.

Hydrocarbon emissions from all mobile sources in 1972’ totalled
approximately 13 x 106 tons. As a result of the varicus ccentrol actions

expected to be implemented by EPA in the near future and described in

projected to be

to below 6 x 106 tons. Similar reductions are expected to occur for
carbon monoxide, with emissions of carbon monoxide falling from 87 x
106 tons per year in 1972 to under 50 x 108 tons per year in 1990.
Emissions of oxides of nitrogen from mobile sources are expected to
remain through 1990 at about 9 to 10 x 105 tons per year. 1/

The aggregate mobile source emissions are examined individually
by class in Tables III-A, III-B and III-C. The major classes of mobile
sources, light duty vehicles, light duty trucks and heavy duty vehicles
are presented and emission projections are given for each class frem
1972 to 1990, The class "other mobile sources" includes motorcycles,
aircraft, and uncontrolled mobile sources such as tractors, vessels,
lecomotives, wiscellanecus off-highway vehicles and lawnmowers and

other utility engines.

1/ EPA staff analysis, September 1976.


-113- .



Lees rou
Fon pb ellie: ee 6 -

oat



-56-

Table IV-A

Cost of Catalyst Control System

A. System Required to Meet 1974 LDV Cost
Federal Standards (3.1, 39, 3.1) 1/

Evap. Control

Transmission Control Spark
Anti-Dieseling Solenoid

Intake Air Heater

Port Exhaust Gas Recirculation (EGR)
Modulation Valves

Miscellaneous Modifications

Air Pump

Total Cost: 1974 Fed. System

B. System Required to Meet 1977 LDV
Federal Standards (1.5, 15, 2.0)

1974 Federal System
Oxidation Catalyst
Improved Exhaust System

1) Standard using 1972 FIP.

Total Cost:

(3.0, 28, 3.1)

Source:

Using 1975 FIP Standards will be

1975. dollars

86
100
25

$ 241

Automobile Emission Control - The Technical Status and

Development Trends as of March 1976. A Report to the

Administrator prepared by the Emission Control Technology

Division, Mobile Source Pollution Control Program.
April 1976.




-74-

Commitments of other resources such as steel, aluminum, etc.,
are so small as to be over-shadowed by normal market fluctuations.

There is the potential that the 1979 standards could result
in an increase in gasoline consumption in comparison to uncontrolled
light duty trucks, However, fuel economy relative to an uncontrolled
light duty truck is not expected to decrease if manufacturers exploy
catalyst technology as is expected. As such, no increase in gasoline
consumption is forecast.

B. Relationship of Short-Term Uses of the Environment and
Maintenance and mcement, of Long-tera ductivity

Regulation of light duty truck emissions results in 2 substantial
decrease in hydrocarbon, carbon monoxide and oxides of nitrogen emissions
from this source. This reduction will be beneficial and aid in the long~

term attainment and maintenance of acceptable air quality levels.


Table II-3
EMISSION RATES FOR AN. AVERAGE TRUCK IN THE

NEW LIGHT DUTY TRUCK CLASS - NC FURTHER CONTROL

Base Case 0~6000 GVWR 2.0/20/3.1
6000-8500 GVWR 4.3/44/5.2

Vehicle Age Emission Rates* {(0-8500 GVWR)

(years) EC £o BOx
L 3.4 41.7 3.8

2 4.1 49.6 3.9

3 5.2 57.4 4.0

4 5.4 65.3 4.0

5 6.1 73.2 4.1

6 6.7 81.0 4.2

7 7.4 88.9 4.3

8 8.0 96.7 4.4

9 8.7 104.6 4.5
10 9.3 112.5 4.6
11 9.3 112.5 4.6
12 9.3 112.5 4.6
13+ 9.3 112.5 4.6

*grans per vehicle mile

NOTE: Excessive emission levels during 2 vehicle's later years of operation
indicate a lack of proper maintenance, This trend towards excessive
emission levels can be slowed if proper maintenance practices are
followed throughout the vehicle's life. Imposition of requirements
concerning proper maintenance practices by vehicle users is the subject
of another program under development within EPA, the Inspection and
Maintenance program.


“9 2-
Chapter VIL

PROBLEMS AND OBJECTIONS RAISED BY FEDERAL, STATE AND
LOCAL AGENCIES, AND BY THE PUBLIC

A. Introduction

This chapter summarizes the comments received in response to the
Notice of Proposed Rulemaking and the Draft Environmental Impact
Statement. The summarized comments, and EPA's disposition of those
comments are grouped according to the basic issues raised by the
commenters ..

A complete summary and analysis of comments is not included with
this finai EIS due to the volume of ccmments received. Single copies
ci that document, “Summary and Anelysis of Corments to the NPRM,”
are available in the Public Information Center, PM-215, U.S. Environmental
Protection Agency, 401 M Street, S.W., Washington, D.C. 20460.

B. List of Commenters

1. American Farm Bureau Federation

2. American Motors Corporation

3. Kenneth A. Burkholder

4. Chrysler Corporation
5. The Council on Wage and Price Stability
6. Department of Defense
7. Department of Transportation
8. Energy Research and Development Administration
9. Ford Motor Company
10. General Motors Corporation

11. International Harvester Company


-7-

air quality standards through the 1980's and control of trucks in the
new light duty truck class provides measurable improvements in air
quality at reasonable cost. The second alternative was rejected because
it did not. provide as much emission control for light duty trucks as did
the final approach selected.

The third alternative considered, control other sources of HC, CO
and NOx, was rejected primarily due to the fact that even with imple-
mentation of all identified control strategies, many of the Nation's
areas will be unable to meet the National Ambient Air Quality Standards.

G. Organization of the Report

This report presents an assessment of the environmental and. a
summary assessment. of the economic impact of the light duty truck regu-
lations EPA is promulgating. It provides a description of the information
and analyses used to review all reasonable alternative actions and to make
the final selection.

The report has been divided. into six major sections plus this
introduction. Chapter II presents a general description of the present
in-use population of trucks, a description of the rationale for the
selection of the new light duty truck class definition, a projection
of growth in the sales of new light duty trucks, and a characterization
of emissions from trucks in the new light duty truck class.

As assessment of the primary and secondary environmental impacts
attributed to these regulations is given in Chapter III.. The degree

of control reflected by the standards is described and a projection of


~75-

Chapter VI

ALTERNATIVE ACTIONS

A. Identification of the Alternative Actions

EPA's procedures for the voluntary preparation of Environmental
Impact Statements state that EPA will "...[d]escribe and objectively
weigh reasonable alternatives to the proposed action, to the extent such
alternatives are permitted by law." 1/ In determining which alternatives
are reasonable, EPA has traditionally examined such factors as magnitude
of emission reductions, econcmic considerations, expected adverse impacts
and irreversible commitment of resources. Only when all these factors
have been balanced can an effective, non-disruptive strategy for the
control of emissions be selected.

The final regulations for the control of emissions from light duty
trucks achieves this balance, in that it will result in a nationwide
reduction in HC, CO and NOx emissions at reasonable cost and with
negligible adverse impacts. A wide range of possible alternative
actions exist to. achieve similar reductions in emissions, with varying
costs and varying adverse impacts. This wide range of possible alter-—
natives includes emission control strategies for the many different
types of stationary sources (i.e., power plants and industrial sources),
emission control strategies for other mobile sources, limitations on
growth or use of emission sources, and of course different strategies

for the control of light duty trucks.

1/ 39 FR 37419, October 21, 1974, section 3(c)(2).


Table VI-A
AVAILABLE HC EMISSION CONTROL STRATECIES

Control Strategy

(Zcontrol before strategy-% control UC Removed Cunulative % Cost-Effectiveness Annual Cost Cumulative
after strategy) (millions of tons) Percentage of Baseline of Naseline ($/ton) (million of $) (millions of $)
Degreasing 0-40 0.30 lal La -210 -61 ~61
Gravure 0-98 0.22 0.8 1.9 -50 -1l -72
Cas Terminal 0-67 0.91 3.4 5.2 0 9 “72
Acrylonitrile 0-35 0.10 ) 5.5 i) ° 772
Polyethylene 0-95 0.19 7 6.2 0 0 +72
Charocoal 0-99 0.34 1.2 74 ° ° ~72
Miscellaneous Chemicals 0-35 0.60 2.2 9.6 9 ie} “72
Dry Cleaning 0-80 0.48 1.7 1.3 10 5 -67
Industrial Finishing 0-75 1.u2 6.3 7.8 10 18 ~49
Carbon Black 0-95 0.14 5 8.3 10 1 48
Forwaldehyde 0-95 0.06 2 b.5 10 1 “47
Refining 0-67 1,53 5.7 4.0 13 20 27
Arch. Coatings 0-100 1.00 3.7 7.6 is 45 ~12
GHDV Evap. 5.8 - 0.5 gu/mi 0.58 2.1 9.7 18 10 -2
Open Burning 0-25 0.30 lal 0.8 20 6 4
Ethylene Oxide 0-95 0.44 1.6 2.4 20 9 i3
Acrylonttrile 36-99 0.17 0.6 3.0 37 6 19
Ethylene Dichloride 0-95 0.36 0.6 3.6 40 6 25
Paint & Varnish 0-70 0.09 0.3 3.9 50 5 30
Degreasing 41-90 0.36 1.3 5.2 85 31 61
Industrial Finishing 76-97 0.55 2.0 7.2 100 55 116
Gasoline Handling 16-50 0.57 2.0 9.2 100 57 173
Cyclohexanone 0-95 0.19 0.7 9.9 120 23 196
Metal Decorating 0-90 0.14 0.5 0.4 150 20 216
##** Proposed Action 0-38 0.94 3.5 ake 200 188 tek
Miscellaneous Chemicals 35-53 0.30 1. 1.5 200 60 276
Gasoline Distribution 67-99 0.43 1.5 3.0 270 11s 391
Coke Ovens 0-80 , 0.24 9 3.9 435 105 496
LDV Exhaust 0.9 = 0.4} go/ni 0.93 3.5 7.2 470 440 936
LOT & GHDV Exhaust 2.9 - 0.8 gm/mi 0.84 3.1 0.2 470 395 1330
Foundries 0-60 0.15 0.5 0.7 500 75 1410
Letterpress & Lithography 0-90 0.27 1.0 1.7 700 190 1600
Gae landling 51-91 0.68 2.5 aol 700 475 2080

SOURCE: Air Quality, Noise and Health, Interagency Task Force on Motor Vehicle
Goals Beyond 1980, March 1976.

week Not in original, added for illustrative purposes.

~18-


~3-

B. Description of this Action

EPA has beth enlarged the current light ducy truck class,
and has imposed more stringent emission standards for all trucks in
the resulting new light duty truck class.

The upper weight limit for the light duty truck class definition.
has been. raised from 6000 to 8500 pounds GVWR. Addition of these
higher capacity trucks to the light duty truck class will enlarge the
class by approximately 80 percent.

Standards which have been promulgated for the new light duty truck
class, 1.7 g/m EC, 18 g/m CO and 2.3 g/m NOx, will resuit in moderate
emission reductions for those trucks currently regulated as light duty
trucks (0 to 6000 pounds GVWR), and will achieve significant emission
reductions. for those trucks formerly tested under the heavy duty engine
regulations (6000 to 8500 pounds GVWR).

Both these actions have been made effective beginning in the 1979
model year.

Cc. Light Duty Truck Class Structure

Truck design and usage characteristics have been examined to
provide a basis for selecting a new light duty truck class definition
which would result in similar trucks being regulated under standards
and test procedures moat appropriate for those trucks. Trucks with
like design characteristics have been grouped together, so that emission

Standards can be imposed in a cost-effective manner. Trucks with like


-109-

Section I - Light Duty Vehicle Emission Factors


-79-

A different situation exists for controlling NOx. The first four
and perhaps the fifth emission control strategy presented in Table VI-B
could be implemented to assure that all areas of the nation met the
NAAQS for NO2. Unlike the case for HC, there appear to be adequate
means for meeting the NOg standard and thus what becomes important is
to examine the merits of individual NOx emission control strategies to
assure that the NAAQS for NO2 is met in the most efficient manner.
Table VI-B also presents cost~effectiveness data for the various mobile
and stationary source emission control strategies. Recalling from
Chapter IV that the cost-effectiveness for NOx emission control for this
regulation is $73 per ton of NOx, it can be seen that this regulation
ranks with the most cost-effective emission ccntrol strategies (both
mobile and stationary source) identified as available by the Agency.

Thus the Agency finds no reason to further examine alternative
mobile or stationary source emission control strategies in its examina-
tion of reasonable alternatives to this regulation. For HC emission
control strategies, there do not appear to be an adequate number of
individual alternative control strategies sufficient to achieve the
NAAQS for oxidants in substantial. portions of the country. For this
reason all reasonable HC emission control strategies are planned to be
implemented. For CO, which is almost entirely a mobile source-related
pollutant, comparison of the relative merits of several mobile source
emission control strategies made in Chapter IV shows that this regula-—

tion is cost-effective in relation to other available mobile source CO


Figure 2

Percent of all Pickup, Panel Van, Multistop Trucks Used for Personal Transportation

as a Function of Registered Gross Vehicle Weight

Pickup

Panel Van

Multistop

EE EIA ETS,
S See

BXESOST

i
Sey

SERRE ETE]

RASSEN.

AIS NEY FEU AION BE

POE MITT ALAN OL

EEDA SRE INS, TORR
v i
TAR SARA

sy
AGS CY

aed

a

axe
TINE SENTRA

SSS
an
CORIO ER AERATOR TIN LETTS

OPERA TEN TREE I HK

votqzeqodsuesy

° o oS coy
“ nx od

yeuosiag oj pasy quaoiag

14

12

lL

10

5 4

3

CWWR x 198

1972 Census of Transportation

Source:


-90-

Table VI-C
ALTERNATIVE LIGHT DUTY TRUCK

Esstion REGULATIONS

Base Case - No further control is imposed; the light
duty truck class continues to be subject
to the current standards of 2.0 g/m EC,
20 g/m CO and 3.1 g/m NOx. The light
duty truck class definition is uncharged
at 0 to 6000 pounds GVWR, and the 60C0
to 8500 pound GVWR vehicles continue

to be regulated as heavy duty vehicles.

Final Regulations - Laight duty trucks are controlled beginning
in model year 1979 to emission levels of
1.7. g/m HC, 18 g/m CO and 2.3 g/m. NOx.
The light duty truck class is enlarged
to include all trucks up to 8500 pounds

GVWR and 6000 pounds curb weight..

Alternative L - Light duty trucks are controlled
beginning in model year 1979 to em{ssion
levels of 1.7 g/m HC, 18 g/m CO and
2.3 g/m NOx. The light duty truck
class definition {s unchanged at 0 to

6000 pounds GVWR. Trucks 6000 to $500


-58~
to vehicles which could impact emissions. EPA estimates that the
total certification costs in 1979 will be $8.7 million. In subsequent
years this total will decline substantially es carry over applies.
EPA estimates per vehicle certification costs over the period 1979 to
1983 to be about $2.

An advantage of using a catalyst system is that it does not
impose a fuel economy penalty on the vehicle. This occurs because
the operation of the catalyst is basically independent of the operation
of the engine. Use of catalyst technology permits manufacturers sore

freedom to adjust the engine for fuel eccnory while maintainiag a con-

cinued high level of emission control. A aon-cataiyst cont

though its initial. cost may be $30 less than a catalyst system, is often
accompanied by a 10 to 15 percent fuel econcny penaity. 4l

Maintenance costs are not expected to change as a result of
these regulations although if any maintenance costs change, those require-
ments should decrease. Unleaded fuels which must be used on catalyst
equipped vehicles cause less damage to exhaust systems and spark plugs,
increasing the amount of time between replacement of these parts. Sinca
emissions can be controlled by and large in the catalyst, frequent
tuneups may be less crucial to emissions control. Decreases in main-
tenance requirements should offset the slightly higher cost of unleaded
fuel.

The incremental cost of implementing these regulations may be calcu-

lated by estimating the number of trucks which must meet the stancard and

4/ Trade-Offs Associated with Possible Auto Emissions Standards,
Emission Control Technology Division, OMSAPC, February 1975.


“54+

classified as light duty trucks under these regulations. Factory sales
over the past ten years grew at a 4.1 percent annual rate, though in
1974 and 1975 sales fell nearly 12 and 20 percent respectively frem 1973
levels. 1976 sales have again picked up and, if sales for the first
six months are repeated, will exceed 1973 sales by 230,000 units.

2. Description of the Manufacturers

Under the redefinition of the light duty truck class there will
be five primary domestic manufacturers of light duty trucks. Ford and
General Motors (Chevrolet and GMC) currently dominate the market, producing
over 70 percent of all trucks in the new light duty truck class which

eaily. They are followed by Cirysiee edge} with 12

are sold dom
percent, American Mctors/Jeep with 4 percent, and. International Earvester
with 2 percent. Part of the U.S. production is exported for sale in
foreign markets. Imports only account for about 7 percent of total U.S.
domestic sales. 2/

The wholesale value of all trucks and buses produced in the U.S.
in 1974 was approximately $10.1 billion. Total domestic factory sales
of trucks and buses in that year was 2.46 million vehicles of which
approximately 1.9 million would have been classified as light duty trucks
under the 1979 light duty truck regulations. 3/

None of the five domestic producers derives much of its total
revenue from the sale of trucks in the new light duty truck class.
Except for International Harvester, all produce passenger vehicles.

International Harvester produces heavy duty trucks as do Ford and Gif.

Most have wholly owned subsidiaries, or divisions which manufacture

27 Motor Vehicle Manufacturers Association.

3/ Automotive News Almanac, April 1975.


-Lo-

Table II-1

FACTORY SALES OF TRUCKS

FACTORY SALES OF TRUCKS AND BUSES BY GROSS VEHICLE WEIGHT, POUNDS

6,000 6,001- 10,001- 14,001- 16,001- 19,501- 26,001- Over
Bless 10,000 14,000 16,000: 19,500 26,000 33,000 33,000 TOTAL

982.511 962,987 14,342 1,129 10,582 174,218 27,310 99,081 2.272.160
1,536,778 731,529 9,094 4,318 13,071 224,499 34,432 173,592 2,727,313

- 1,735,645. 761,481 44,724 7.477 18,941 203,300 42,200 165,920 2,979,638
1,414,551 584,612 44,221 9.945 28,080 42,213 143,127 2,446,807

. 1,196,544 486,388 17,928 14,871 58,042 36,441 110,735 2.053.146
950,252 401,592 353 9.379 59,205 38.451 101,054 1,892,440
1,121,222 405,108 7,161 13,491 78,105 33,304 117,383 1,923,179:

. 1,136,059 385,803 4,646 17,495 79,436 41,814 89,561 1.896.078
899,986 289,835 5,207 16,499 88,213 37,960 77,828 1,539,462
1,020,158 296,957 7,485 21.286 125,473 44,337 91,027 1,731,084
1,058,211 294,178 5,020 25,751 144,449 39,968 74,603 1.751.805
919,663. 250,204 5,804. 24,234. 142,277 29,613 64,159 1,540,453
836,129 246,650° 5,679- 28,4505 145,298 32,186 58,746 1,462,708
677,804 243,050 8:503: 27,495 142,163- 35,153- 42,862 1,240, 168
897,292 853,310 13,914 O17 5,718 139,769 21,555 70,283 2,002,758

. 1,409,586 660,312 8,911 3,220: 10,271 197,450 29,091 150,785 2,469,626
. 1,639,663: 713,210. 44,272 6.4435 15,543: 180,345 37,834 149,503 2,786,813
1,339,226) 549,523, 43,898 8.661 24,826 163,266 37,727 127,284 2,294,371.

. 1,133,911, 453:98r 177796 12,602 52,038 110,587 32,795. 100,598 1,914,308"
895,238: 373,595: 65103 8,357 S246: 103,318 34,75 91,434& 1,565,669
1,052,057" 379,492 6,525 11,272 68,617" 125,910 30,858: 106,446- 1,781,177
1,069,422 365,785 4,338 14,690 67,381 123,059 37,882 82.534 1,765,091
836,512 269,273 4,850 14,236 76,874 107,972 33.911 70,810 1,414,638

- 957,227 278,099 5,805 18.714 109,696 110,528 41,158 85,302 1,606,526

Source: MVMA. Motor Vehicle Facts and Figures "76°


~45-

the bulk of the control of oxides of nitrogen necessary to maintain
current ambient levels. EPA's action in promulgating revised light
duty truck regulations contributes to this effort to maiatain current
ambient levels, in that it slows the increase in nitrogen dioxide

ambient concentrations.


-49-

reasonable certainty whether, and if so at what level, establishment

of a sulfuric acid emission standard for automobiles may be required

or prudent to protect the public health. We are continuing vigorously

to investigate the current areas of uncertainty, including health effects
and exposure estimates, and will continue to monitor vehicle sulfuric

acid emission rates and the development of sulfuric acid control techniques
by industry. Moreover, we will monitor ambient sulfuric acid levels

in the vicinity of roadways. These programs will provide us the

capability to identify the potential hazard of sulfuric acid emissions

to public health and allor

real danger could develop."

These light duty truck emission standards are not expected to
increase present mobile source sulfate emissions significantly or to
present a future problem. Current data indicate that there is no
substantial difference in the sulfuric acid emission levels of catalyst/
non-air pump and non-catalyst vehicles. 9/ In contrast, sulfuric acid
emissions of catalyst/air pump vehicles do appear to be at levels
generally higher than those for either catalyst/non-air pump or non-
catalyst vehicles. Estimates of 1975 light duty truck sales show that
the light duty truck manufacturers may be expected to equip about 60

percent of their production units with catalysts (approximately 830,000

vehicles).

9/ Test Report, Automotive Sulfuric Acid Baseline Program, Environmental
Protection Agency, Emission Control Technology Division, January 1976.


-78-

Number of AQCRS Maximum

Where Required Control Control

Pollutant Exceeds 50 Percent . Required
co 20 822%
Ox 22 882%
Nog 90 32%

The same long-range planning study examined all available mobile
and stationary source emission control strategies, both as to their
cost and emission reduction potential. Tebles VI-A and VI-B (from that
study) are presented and allow an examination of all currently available
emission reduction strategies with a view towards selecting the most
cost-effective approach to achieve any total amount of emission reduc-
tion. Because CO is almost entirely a mobile source-related pollutant,
stationary source controls were considered as alternatives only for the
control of NOx and HC (which is a precursor to oxidant formation).

It can be seen from Table VI-A that there is an extensive range
of sources and control strategies for HC emissions. Recalling, however,
that reductions totaling. more than 88% are needed if all areas in the
mation are to achfieve the NAAQS, and that there are 22 ACCRs where the
degree of hydrocarbon control required exceeds 50%, it can be seen from
Table VI-A that. emissions reductions totaling only 54% are currently
identified as being available.. Thus there will continue to be areas of
the nation which are unable to meet the NAAQS for oxidants in the
future, even with all stationary and mobile source controls imple-
mented. To forego one emission control strategy in favor of imple-
menting another would therefore be a dereliction of EPA's statutory

mandate to assure that NAAQS are met.


ye
MET PUDE, |
7
He Bae | eT

(oa

-€CI-



-li-

To impose emission standards effectively, trucks must be grouped
so that similar trucks may be subjected to similar standards.
The imposition of emission standards can then be done in a
cost-effective manner.

The current grouping of trucks (light duty trucks below
6000 pounds GYWR and heavy duty trucks above 6000 pounds GVWR)
fails to adequately satisfy the two concerns discussed above.
The 6000 pound GVWR division does not result in trucks being
tested using the most appropriate test procedure, and does
not allow the imposition of emission standards on similar
trucks. For example, under the current division of trucks,
two pickup trucks within the same model line, designed and
produced’ in a similar manner and operated in urban areas in
a similar manner, may be subjected to different emission.
control regulation (light. and heavy duty truck) simply because
one is less than 6000 pounds GVWR and one is more than 6000
pounds GVWR.

To make the light duty truck regulations more effective,
EPA has grouped trucks with like operating characteristics
in one class. This grouping will allow the emissions of
trucks in urban areas to be accurately assessed, and will
result in urban emission reductions being achieved by trucks in
the new light duty truck class. For the purpose of choosing
a group of trucks which are amenable to the same level of

emission control, EPA has also grouped trucks with like design


cot ab -
/3 we
ae ae ee -
Le ede, a ‘

~SEI~

Me»:

he



-53-

Chapter IV
ECONOMLC IMPACT 1/

A. Economic Background

1. Description of Trucks in the New Light Duty Truck Class

The new light duty truck class consists of many different styles
of trucks intended for. various types of operation. Included in the
class are pickup trucks, van trucks, panel trucks, station wagons
built on pickup truck chassis, multistop trucks (e.g., bakery and
milk trucks), and off-road and utility vehicles (e.g., four wheel
drive vehicles). Some trucks in the new light duty truck class are
sold as cab chassis combinations te special body builders who
complete the construction of the vehicle (e.g., some mobile homes).

Most of these trucks are equipped with V-8 engines essentially
the same as those used in light duty vehicles. The major differences
are in the carburetor and distributor settings with minor differences
in basic engine specifications like valve diameters and bearing load
ratings. The similarities between light duty vehicle and light duty
trick engines should allow adaptation of light duty vehicle emission
control systems for use on trucks in the new light duty truck class.

Factory sales of light duty trucks less than 6000 pounds GVWR
was about 977,000 vehicles in 1975. Approximately 874,000 trucks
between 6000 and 8500 pounds GVWR were produced in 1975. These 874,000

vehicles, which were certified ag heavy duty vehicles. in 1975, will be

i/ This chapter consists of data and conclusions extracted from a more
detailed analysis entitled "Economic Assessment of the Revised Light
Duty Truck Regulations for 1979 and Later Model Year Light Duty Trucks,"
prepared by the Office of Mobile Source Air Pollution Control.
Information in this chapter not specifically referenced may be found
in that document.


V. Other General Considerations

A. Irreversible and Irretrievable Commitment of
Resources

B. Relationship of Short-term Uses of the Environment
and Maintenance and Enhancement of Long-term
Productivity

VI. Alternative Actions

A. Identification of Alternative Actions
B. Analysis of Impacts of the Alternatives to the Proposed

Action
1. Take No Further Action to Reduce Light Duty Truck
Emissions

2. Implement Alternative Emissions Standards for
Light Duty Trucks

VII. Problems and Objections Raised by Federal, State and Local
Agencies, and the Public

Appendix A - Selection of a Breakpoint Between LDTs and HDVs

Appendix B - Light Duty Vehicle and Light Duty Truck Emission
Factors

73

74

75
83

83
84

92

99

108


Cost Effect
GVWR Truc!

Air Pump

Miscellaneous Modifications
Modulation Valves

Heated. Air

EGR

Certification

Baseline Emissions (g/mi)

Proposed 1979 HDE Regulations

Reduction (g/mi)
Lifetime Reduction. (tons
100,000 miles)

-Cost Effectiveness

-70-

Table IV-F

iveness of 6000 - 8560 Pound
ks to Meet HDE Regulations

$68

4.3
1.6
2.7

/
3

$227/ton


-25-
g/m hydrocarbons, 44 g/m carbon monoxide and 5.2 g/m oxides of nitrogen.
Based on the similarity of these vehicles in terms of vehicle and engine
design to light duty vehicles for which emission control deterioration
rates have been determined 6/, the initial performance levels for a
typical 6000 to 8500 pound GVWR light duty truck, regulated under
current heavy duty standards, would be expected to deteriorate from
5.7 to 11.4 g/m hydrocarbons, 67.8 to 128.9 g/m carbon monoxide and remain
at 5.4 g/m oxides of nitrogen at the end of the truck's in-use life.
Composite emission rates for trucks in the new light duty truck
class have been developed by weighting the emission characteristics
discussed above for both the 0 to 6000 and 6060 to 8500 pound GVWR
light duty truck groupings. This weighting assumes that 55 percent
of the new light duty truck class will be comprised of 0 to 6000
pound GVWR trucks, and that the remaining 45 percent will be 6000
to 8500 pound gross vehicle weight trucks. (The bases for this
assumption are further discussed in Chapter IV of this statement.)
Table II-3 examines the emission rates (obtained through this weighting
process) for an average truck in the new light duty truck class.
Table II-3 is provided as a base case, as it assumes that no further
control is imposed on trucks in the new light duty truck class. Table
II-4 presents similar emission rates for a typical truck in the new
light duty class when controlled under this regulation. These emission
rates form a basis for the examination in Chapter III of this state-

ment of the air quality impacts of EPA's proposed action.

6/ See Appendix B.


Cost Effectiveness ~ 1979

~68=—

TABLE IV-E

LDIT Exhaust Emissions Regulations
6000 to 8500 Pound GVWR Trucks

Transmission Controlled Spark
Anti Diesel Solenoid

‘Intake Air Heater
Proportional EGR

Modulation Vaives
Miscellaneous Mods

Air Pump

Oxidation Catalyst

Improved Exhaust Material

Development and Certification

Base line Emissions (g/mi)

LDT 1979 Standard (g/mi)
Reduction (g/mi)

Cost Allocation ($)

Lifetime Reductions (tons/100,000 miles) .29

Cost Effectiveness

HC so x
- - 3
3 - -
2- 3 -
- - 20
2 - 3
? ? 6
8 7 -
50 50 -
12 13 -
2 3 3.
86. 33 35 = 204 af
4.3 bo 5.2
~ 417 23
2.6 26 2.8
2.86 32
$297 $29 $109

af Cost of evaporative controls, $15, is not included in chese. calcu~
lations since these controls are not used for the control of exhaust

emissions.


-61-

vehicle separate from passenger cars with separate standards, the
ratio between these two categories of trucks approached 1 to Ll.

Just one year before, in 1974, trucks with GV¥WR's less than 6,000
pounds out numbered trucks with GVWRs between 6001 and 8500 pounds
two to one. This two to one ratio is one that had been relatively
stable for many years. Since 1975 sales of the heavier trucks have
increased (doubled between 1974 and 1976) while sales of the lighter
trucks have decreased. 1975 saw a dramatic increase in the sales of

van trucks which mostly have GVWRs of greater than 6,000 pounds. 1975

facturers introduced to replace models which previously had GVWRs of
less than 6,000 pounds. What ever tha reason for this-shift, the result
is to significantly increase the costs of this action over what it would
have been had the historical 2 to 1 split persisted. For example the
first year (1979) costs would have been $211.2 million and total five
year costs $1.15 billion had this historical split continued.

As a result of implementing new light duty truck regulations govern-
ment expenditures will increase. Two additional man years for labora-
tory and data technicians will be reauired at a cost of $45,000. Costs
for testing vehicles at EPA is expected to increase since the number of
durability and emission data vehicles will go up by 11 and 55 vehicles
respectively. Total costs to the govermment for increased testing and

two additional positions will be $160,000 for the 1979 model year.


-18-
C. Usage Characteristics

Since the physical characteristics of trucks up to 10,000
pounds GVWR are basically similar, with truck design in transition
from 10,000 to 16,000 pounds GVWR, an optimum division between
light duty trucks and heavy duty trucks would be one which
separates those trucks on the basis of usage characteristics.
This would allow trucks to be tested using the most appropriate
test procedure, or one which most accurately characterizes the
expected usage patterns of trucks in actual urban operation.

Examination of Census data for the eight MVMA truck classes
indicates that truck use varies according to weight. Trucks
in classes I and II are primarily used for personal transportation
and agriculture, those in classes IV, V and VI are used primarily
in support of agriculture, manufacturing and construction, and
class VII and VIII trucks are used in construction, wholesale and
trade for hire. 2/

About 53 percent of trucks under 10,000 pounds are used
for personal transportation and 21 percent for agricultural
purposes. Use of trucks for personal transportation declines
‘significantly for Classes III, IV and V for which only 11
percent of trucks in these categories are used in that manner.
Agricultural uses increase to 32 percent, however, while
commercial uses follow a similar pattern. Only 14.9 percent
of trucks under 10,000 pounds GVWR are used in support of
manufacturing, construction, the wholesale and retail trades,

and "for hire.“ In classes ILI, IV and V 38.4 percent of trucks

2/ 1972 Census of Transportation - "Truck Inventory and Use
Survey"


10® tons per year

Source

LDV

LDT

EDV

Total Regulated
Mobile Sources

Other Mobile
Sources

Total Mobile
Sources

(percent of total regulated mobile source emissions)

Table III-B

-35-

Nationwide CO Emissions

1972 1975 1980 1985 1990
57.2 (73%) 58.5 (73%) 40.8 (65%) 19.5 (47%) 11.3 (32%)
9.4 (122) 10.0 (12%) 10.0 (16%) 9.8 (24%) 10.6 (30%)
12.0 (15%) 12.0 (15%) 12.1 (19%) 12.3 (30%) 13.2 (38%)
78.6 80.5 62.9 41.6 35.1
8.3 9.1 10.6 12.3 14.4
86.9 89.6 73.5 53.9 49.5

Source: Revised Estimates of Total Nationwide Emissavus .v. various

Regulatory Alternatives, internal EPA memorandum, January, 1976,

as amended October, 1976.


-55-

many of the parts needed to construct the vehicle and to supply the
replacement parts market. All have diversified into some non-trans—
portation related enterprises such as electronics, appliances or

plastics, though non derive more than around five percent of total

revenue from these lines of businesses.

B. Cost of Implementing the LDT Regulations

Analysis done by EPA has indicated that it would cost about $211
to install in LDTs a catalyst emission control system capable of meeting
the emission standards. This is based on the assumption that the same
equipment which can be used on light duty vehicles tc meet the current
1977 light duty vehicle Federal emission standards also couid te used
to meet the 1979 light duty truck standards. The cost of the equipment
is given in Table IV-A. During the public comment manufacturers
provided their estimates of the costs of the control equipment necessary
to meet the new standards, This data is summarized in Table IV-B.

In addition to equipping trucks with pollution control equipnent
manufacturers will have to expend financial resources to develop control

systems and calibrations and to certify with EPA that their trucks are

capable of meeting the standards. EPA estimates that the industry w
spend about $17 million for development during model years 1979 to
1983. This is about $6 per truck sold during that period. Certification
costs will be higher during the 1979 and 1980 models than during the
period 1981 to 1983 assuming that the standards do not change. That is
because manufacturers will be able to "carry over" results of

certification tests from one year to the next if no changes are made


-21-
DB. Selection of a Light Duty Truck Class Definition

There is no one criterion that can be established to completely
separate light duty trucks from heavy duty vehicles which will
completely eliminate cross-over of vehicle body styles and vehicle
usage. From the discussion of truck design and usage characteristics
presented above, it is apparent that a optimum divisor between
light and heavy duty trucks is one which satisfies the following
concerns:

1) Design characteristics
So that trucks included in the new light truck class are

amenable to the. same absolute degree of emission control, and

cost-effective urban emission reductions, trucks of similar
design should be grouped in one class. Examination of truck
design characteristics has led to the following conclusions:

a) The largest sales volume of trucks is found under 10,000
pounds GVWR, with the remaining majority of truck sales
being concentrated above 16,000 pounds GVWR.

b) Most of the trucks sold less than 6000 pounds GVWR have
counterparts which are also sold between 6000 and 10,000
pounds GVWR, although none of these truck types are sold
above 10,000 pounds GVWR,

c) Engines are similar in all trucks up to 14,0C0 pounds

GVUR and in most cases those engines are. sinilar to
passenger car engines.

2) Usage characteristics
To be able to adequately characterize actual emissions from

trucks operated in urban areas, where urban vehicle operation is

simulated by the procedure currently used on light duty

vehicles and light duty trucks less than 6000 pounds GVWR, trucks

of similar use should be grouped in one class, Truck use

characteristics discussed earlier lead to the following conclusions:


cycle that adequately represents those usage patterms. EPA has
determined (see Chapter II of this statement) that the actual usage
patterns of light duty trucks up to 8500 pounds GVWR, when operated

in urban environments, closely approximate those of passenger cars.
This characteristic of light duty truck operation, personal transpor-
tation, is highly transient in nature. Personal usage in urban areas
is characterized by stop and go operation, or by the type of operation
experienced by the typical commuter. Steady state testing, as is per-
formed in EPA's heavy duty engine test procedure, is incapable of
accurately modeling this transient operation. Analysis performed 10/
of data obtained for EPA indicates that transient operation cannot be
adequately simulated by the heavy duty engine steady-state test procedure,
or by any modification of that steady-state procedure for the purpose
of assessing the emissions from vehicles. Thus, to accurately assess
the in-use emission performance of vehicles that are typically operated
on transient cycles, the heavy duty engine test procedure cannot be
used.

The light duty vehicle and truck test cycle, however, does
adequately assess the in-usé-vehicle emission performance of cars and
light duty trucks, since that test cycle is a simulation of an urban
communter-type trip. The light duty cycle contains transiént operation,
which exercises the vehicle over a range of accelerations and decelera~
tions. Since light duty trucks up to 8500 pounds GVWR are operated a
substantial portion of the time as personal use transportation vehicles,

use of the light duty test cycle is appropriate for these vehicles.

10/ Transient vs. Steady-State Test Procedures for Measuring Emissions
of Heavy Duty Diesel Trucks, Internal EPA Memorandum, September 28,
1976, and Prediction of Heavy Duty Gasoline Trucks' Transient Emissions
from Steady-State or Sinusoidal Test Procedures, Internal EPA Memoran-
dum, October 13, 1976.


Strategy

No Action
Provosal

No Action
Proposal

No Action
Proposal

-42-

Table III-E
Comparison of Light Duty Truck Urban
Emissions With and Without the

Proposed Action

1972 1975 1980 1985 1990
Hydrocarbons (0% tons per year)
79 79 85 +95 1.08
79 79 +76 +60 57
Carbon Monoxide (10° tons per year)
6.05 6.58 7.40 8.84 10.30
6.05 6.58 6.83 6.73 7.32
Oxides of Nitrogen qo tons per year)
35 38 44 52 61
35 38 239 234 -37


-83-

B. Analysis of Impacts of the Alternatives to this Regulation

Economic impacts of the alternatives to this. regulation are
summarized in this chapter, and are more fully described in "Economic
Assessment of the 1979 Light Duty Truck Emission Standards," Office
of Mobile Source Air Pollution Control, EPA.

1. Take No Further Action to Reduce Light Duty Truck Emissions

Total light duty truck emissions, if no further control is
imposed, are expected to increase between now and 1990 to the extent
that they comprise over 14 percent of the total mobile source emissions.
Between now and 1990 emissions of other sources will be significantly
curtailed as attainment of acceptable air quality is pursued, and the
importance of light duty truck emissions in finally achieving the air
quality standards will be increasingly evident. A large number of
the regions presently exceeding the air quality standards for oxidants,
carbon monoxide and nitrogen dioxide will continue to have difficulties
in achieving or maintaining these standards in the 1980's. Emissions
from light duty trucks will add to this burden.

Under the alternative of taking no action, costs to the
industry and the consumer would appear to be less than those incurred
under this regulation. As indicated in Chapter IV, the aggregate
costs to the consumer and to the industry are expected to reach 830
million dollars for the five year period 1979 to 1983. These costs.
would not be incurred by the public directly should no further action
be taken to reduce light duty truck emissions. Since additional
reductions in emissions from mobile sources are necessary to meet

and maintain ambient air quality standards. in many regions Al, costs

4/7 See Chapter III, Section A.


~“0U-

Table IV-C

Incremental Cost of Implementing
the 1979 Light Truck Regulations

U.S. Truck Sales

Incremental Cost

0 - 6000 6000 - 8500 of Control
1974 1,616,319 639,689 )
1975 1,204,259 895,758 0
1976 © 1,255,000 8/ 1,287,000 3/ 0
1977 & 1,306,000 1,340,000 0)
1978 @ 1,360,000 1,394,000 0

o = $500
1979 & 2,724,000 309,174,000 2/
1980 & 2,336,000 321,886,000
1981 © 2,952,000 335,052,000
1982 © 3,073,000 348,785,000
1983-° 3,199,999 363,086,000

a/ Estimate made on the basis of actual six month production being
repeated in last six months of 1976.

b/ Cost estimates are based on 1 to 1 split between 0 - 6,000 and
6,001 to 8,500 pound trucks with $8 and $219 costs for each
category respectively.

e = estimated


-84-

would be incurred by the public for those additional reductions in
emissions when obtained from emission sources other than light duty
trucks. As shown in Table IV-4, the costs per pound of pollutant

removed from the ambient air. for several selected mobile sources are

all higher than those costs for light duty trucks (with the exceptior

of the planned 1979 Federal interim heavy duty vehicle emission standards).
This indicates that obtaining equal reductions in emissions from other
sources would be more costly to the consumer than obtaining those
reductions from light duty trucks.

2. Implement Alternative Emission Standards for Light Duty Trucks

Several alternative emission levels were considered by EPA ia
the context of selecting the emission levels that were proposed 5/.
These alternative emission levels included emission standards of equi-
valent stringency to the 1975 California interim light duty vehicle
standards (0.9 g/m HC, 9.0 g/m CO, 2.0 g/m NOx), and emission levels
based on a sliding scale according to vehicle weight. Alternatives
for the light duty class boundary (e.g., up to 8500 pounds GVWR) were
not examined as to their environmental, economic and social impacts,
but were rejected on technical bases. Discussion of these alternatives
considered by EPA in its selection of the propesed action can be
obtained by consulting the Draft Environmental Impact Statement for
this regulation,.dated February 12, 1976.

Although the analysis of the alternative emission levels
for light duty trucks presented in the Draft EIS will not be reprinted
here, two different alternative regulatory approaches that have been

suggested during the public comment period on the proposed regulation

5/ 41 FR 6279, February 12, 1976.


-119-



Section II ~ Light Duty Truck Emissicn Factors


Sales (000,000)

Figure 2-]

ANNUAL TRUCK SALES FOR

THE NEW LIGHT DUTY TRUCK CLASS

4.1% growth

(annual) /
/
L /
/
1.
0.5
0 + + +
"60 "62 64 "66 "68 "70 "72 "74
Model Year
Source:

Motor Vehicle Manufacturers Association, 1974 Motor
Truck Facts


~5=

The urban emission reductions obtained from imposition of this
regulation will result, in 1990, in a six percent improvement in
oxidant (hydrocarbons) levels, a five percent improvement in carbon
monoxide levels, and a three to four percent reduction in expected
nitrogen dioxide air quality degredation. Similar improvements can
be expected as a result of this regulation in regions other than those
analyzed in this report.

There are no anticipated secondary environmental impacts in the
areas of truck fuel consumption, noise pollution control, water or solid
waste pollution. Fuel economy of trucks currently regulated as light
duty trucks (0 to 6000 pounds GVWR) should not be affected by this
regulation, as no design changes should be necessary to meet the stan-
dards. For the heavier trucks to be added to the new light duty truck
class, imposition of these standards may result in slight fuel economy
improvements. There is the potential that sulfuric acid emissions from
the new light duty truck class could increase as a result of this regu-
lation, but the increase is not considered major. This potential
problem has been examined in connection with the ongoing work within EPA
directed towards development of a sulfuric acid emission standard for
application on light duty vehicles and light duty trucks. Such a stan-
dard is not at this time deemed necessary to protect the public health.
E. Economic Impact

Five domestic manufacturers dominate the light duty truck industry.
Ford and General Motors account for 75 percent of all trucks in the
enlarged light duty truck class which are sold domestically, with Chrysler,
American Motors and International Harvester’selling about 18 percent.
Imports account for only about 7 percent of the total U.S. domestic

sales of trucks in the enlarged light duty truck class.




-44—

Data available to EPA 6/ show that about 60 urban areas currently
fail to meet the ambient oxidant air quality standard. In addition,
some rural regions in the midwest and throughout the East coast are
experiencing widespread violations of the oxidant standard. It
seems likely then, that additional violations of the oxidant standard
will be discovered as the air quality monitoring network throughout
the country is enlarged, and that this regulation will have a more
broadly basea impact on.the oxidant problem than indicated by
examining the 29 regions included in the anaiysis.

Twenty-six urban areas were analyzed for carbon monoxide.

Carbon monoxide, unlike hydrocarbons (oxidant precursors) and oxides of
nitrogen,.is almost uniquely a motor vehicle problem. This is due to

the fact that locations which experience violations of the carbon monoxide
standard are most always those locations with high traffic densities.
This regulation will, in 1990, reduce the carbon monoxide concentrations
an average of five percent in those twenty-six urban areas.

For oxides of nitrogen, this regulation will slow the increase in
ambient concentrations by three to four percent in 1990. Since the
ambient nitrogen dioxide air quality proble= eppears to be one of
containing growth in emissions of oxides of nitrogen rather than
rolling back current levels, and since future growth of stationary
source oxides of nitrogen emissions will be the major air quality
problem, emission limitations for new stationary sources will form
@/ Air Quality Impact of Alternative Emission Standards for Light

Duty Vehicles, Environmental Protection Agency, Office of Air and
Waste Management, Revised March 12, 1975.


usage patterns have also been included in the new light duty truck
class, so that a test procedure which simulates urban light duty truck
(and passenger car) usage can be applied to predict actual urban
emissions from trucks in the new light duty truck class.

While the new light duty truck class is structured to minimize
truck overlap (or one model line with trucks both. above and below
8500 pounds GVWR), complete elimination of this overlap is not possible.
To account for such overlap, EPA has included an optional. category (up
to 10,000 pounds GVWR) in which manufacturers may choose to certify trucks
under the light duty truck procedure.

As a further limitation of the cross-over of body styles, and to
exclude where possible trucks which are clearly used for commercial
purposes from the light duty truck class, trucks with frontal areas
greater than 46 square feet have been excluded from the new light duty
truck class. This inclusion of high frontal area trucks in the heavy
duty class will eliminate certain delivery vans and other large
vehicles from the light duty truck class, on the basis that usage
characteristics of these trucks do not warrant their inclusion in
the light duty truck class.

D. Environmental Impact

This regulation will reduce urban emissions from trucks in the
new light duty truck class in 1990 by 0.51 million tons per year of
hydrocarbons, 3.0 million tons per year of carbon monoxide and 0.25
million tons per year of oxides of nitrogen. The projected reductions
are those which can be expected to occur in areas having the most

serious air quality problems in the near term and through the 1980's.


-38-

Also, a stringent evaporative emission standard
for HDVs is planned for the 1983-1985 time frame
but has not yet been defined and is not considered

in the above tables.

The category “other mobile sources" is defined
to include motorcycles, aircraft, tractors,

vessels, locomotives, miscellaneous off-

highway vehicles and

utility engines.


-118-



vabie Tl-2

Domestic Factory Sates - 1973 Calender Year

Under Total Under Total Under
6000# GVWR 6-10000# 10-14000# |} 10,000 CVwR 14, 000f GVWR

° Pickup 4,067, 908 467,307 weee- 1,535,215 1,535,215
(68%) (622%) (66%) (65%)
Multistop 2,603 34, 282 39,659 37,685 77,344
(9%) (5%) (90%) Qn feb)

Other: Bare Chassis
Chags{s w/cab 6,253 88,068 4,613 94,32} 98,934
Chaasis w/cowl (1%) 112) (10%) (4%) (Cy al
= Van 204,348 101,553 sere 305,901 305,901
“OO 0) (bah) 3%) (13%)
f Hat Pagsenger Van 49,501 93,981 93,981
OU Gn (6%) (42) (42)
eae Stetion Wagon 80,842 20,713 4 w+--- 101,555 101,555
O OC (5%) (3%) (4%) (4h)
Panel 3,213 ooen- weeee 3,213 3,213
4 (0%) (0%) (0%)
Se General Utility 261,602 | meen fw nee 161,602 161,602
(102) (7%) an
1973 Sales Tatal 4,576,470 757,003 44,272 2,333,473 2,377,745

Source: MVNA Date Sheets FS 74 and TS 3

~LI-


-12-

characteristics in one class. This chapter examines truck design
and usage characteristics, with a view toward outlining the consi-
derations EPA has in grouping trucks into classes and imposing
emission standards based on those considerations.

Following this examination of truck design and usage
characteristics and the rationale for EPA's selection of light
duty truck class definition, emission characteristics of trucks
in the new light duty truck class are discussed, and growth of
the new light duty truck class is projected. These further
discussions concerning light duty truck erission characteristics
and growth are presented to form the bases for the examination
in the remainder of this. statement of the environmental, economic

and social impacts of EPA's final regulation.


-1-

Chapter I
INTRODUCTION
A. Background

Light. duty trucks have been Federally regulated since 1968. From
that time until model year 1975, light duty trucks were tested on the
same test procedure and subjected to the same emission standards as
light duty vehicles. Over those years, both the standards and test pro-
cedures for light duty vehicles and light duty trucks underwent several
modifications. Current test procedures for light duty vehicles and
light duty trucks involve operation of tast vehicles on 2 simulated
urban driving cycle, and measurement of exhaust emissions during that
driving cycle. The current. emission standards for both types of vehicles
are based on testing of those vehicles on the urban driving cycle, and
hence characterize the vehicles' expected urban emissions.

Since model year 1975 light duty trucks have been subjected to
standards differing in stringency from light duty vehicles. As the
result of a court decisicn 1 EPA was required to base emissicn
standards for light duty trucks on section 202(a) of the Clean Air
Act which specifies that EPA should set emission standards for any
class of vehicles (in this. instance, light duty trucks) which causes
or contributes to air pollution, or is likely to cause or contribute

to air pollution which endangers the public health or welfare.

1/ International Harvester vs. Ruckelshaus, 478 F. 2d 615 (D.C.
Cir. 1973).



~130-

. : é :
~ bs :



-108-

Appendix B ~ Light Duty Vehicle and Light Duty
Truck Emission Factors

Section I of this appendix presents light duty vehicle
emission factors in a format similar to that used in the
“Compilation of Air Pollutant Emission Factors," (AP-42). The
emission factors are preliminary factors derived from EPA's
annual program to examine the acutal in-use emission rates of
light duty vehicles and light duty trucks. These factors
have been compiled based on the latest test results from
that program and are currently. being. further screened within
the Agency for inclusion in a future edition of AP-42. The
factors assume that the emission standards for light duty
vehicles which are currently mandated by the Clean Air Act
will be in effect (i.e., 1978 model year standards of .41
grams per mile (g/m) HC, 3.4 g/m CO and .4 g/m NOx).

Section II of this appendix contains light duty truck
emission factors, both for the case of taking no further action,
and for the case of imposing emission standards associated
with this regulation (i.e., 1979 model year standards of
1.7 g/m HC, 18 g/m CO and 2.3 g/m NOx), These emission
factors are also preliminary factors based on data from EPA's
latest emission factors testing program, and are currently
undergoing additional review within the Agency for inciusion

in AP-42,


-67-
BD. Cost Effectiveness

Cost effectiveness is a statistic which measures the economic
efficiency of undertaking some action to achieve a certain goal. In
the context of controlling the emissions from mobile sources cost
effectiveness is measured in terms of cost per ton of pollutant
controlled. To calculate this number the costs of controlling each
pollutant must be determined. The allocation of control costs to
each pollutant is somewhat arbitrary. EPA has attempted to allocate
control costs in Table IV-E, based on the effect each component may
have on emissions. The cost effectiveness of the 1979 light duty truck
regulations for 6000 to 8500 pound GVWR vehicles is also shown in Table
IV-E.

Une alternative to the new 1979 light duty truck regulations was to
reduce the standards but leave the definition of a light truck unchanged.
For those vehicles in the class (0 - 6,000 pounds. GVWR) the cost would
be $8 for development and certification while the incremental amount of
control would be 0.3g/mi - HC, 2.0g/mi. - €O, and 0.8g/mi ~ NOx. ‘The
resulting cost effectiveness numbers are, for the respective pollutants,
$8l/ton - HC, $12/ton - CO, and $30/ton - NOx.

In combination with this a cost effectiveness for leaving 6,000-
8,500 pound GVWR trucks in the heavy duty vehicle class should be
determined. The cost effectiveness numbers calculated for the heavy
duty engine Notice of Proposed Rule Making (See Draft Environmental
and Inflationary Impact Statement - Interim Heavy Duty Engine Regulations

for 1979 and Later Model Years, dated 4/21/76) are not appropriate


-22-

1) The light duty truck class should be structured to
maximize inclusion of pickup trucks, since in the
weight ranges under consideration 2lmost all pickup
trucks are used primarily for personal transportation.

2) The light duty truck class should sinimize. inclusion
of multistop trucks, panels, vans aad cab chassis,
since those types of trucks are used primarily for
commercial purposes.

3) The weight limit division between light and heavy
duty trucks should not be less thaa 8000 pounds GVWR,

since the percentage of trucks used for personal

transportation up to 8000 pounds is consistently above
50 percent.

Considering all these concerns, and examining truck sales
distribution (see Appendix A, Figures 3 and 4), 8500 pounds GVWR appears
the optimum minimum cutpoint between light and heavy duty trucks. In
addition, trucks above 6000 pounds curb weight which are often built to
carry permanently installed equipment used for commercial and recrea-
tional purposes have been excluded from the new class. As a further
limitation. of the cross-over of body styles, and to exclude where
possibile trucks which are clearly used for commercial purposes from the

light duty truck class, trucks with frontal areas greater than 46 square

feet have beead exciuced

on the new light duty truck class, This
inclusion of high frontal area trucks ian the heavy duty class will
eliminate certain delivery vans and other large vehicles from the light
duty truck class, on the basis that usage characteristics of these

trucks do not warrant their inclusion in the light duty truck class.


-8-

air pollutant emissions for the national light duty truck population
with and without the regulation through 1990 is presented. The
impacts of these regulations on urban emissions and the expected air
quality benefits are described. Secondary effects on other air
pollutant emissions, water pollution, noise, and energy consumption
are also discussed in this section.

Chapter IV presents an assessment of the economic impact of the
regulations. Included is an assessment of the impact of these regulations
on producer and consumer costs (operating and first cost), and the
growth and structure of the Light duty truck industry.

Chapter V discusses irreversible commitments of resources, and
reviews the relationship of short term uses of the environment to long
term preductivity.

Chapter VI presents an evaluation of the environmental, social,
and economic impacts of alternative actions including no further
regulation of light duty truck emissions, alternative emission standards
for light duty trucks and the additional reduction of emissions from
other mobile sources and from stationary sources.

Chapter VII summarizes the comments EPA has received om the proposed
regulation and on the Draft EIS. Also included in this chapter is EPA's

disposition of the major comments.


-27-

Table II-4
EMISSION RATES FOR AN AVERAGE TRUCK IN THE

NEW LIGHT DUTY TRUCK CLASS — FINAL STANDARDS

0-8500 GVWR 1.7/18/2.3

Vehicle Age Emission Rates*

(year aC ey Nox
1 1.4 18.3 1.9

2 1.9 26.1 2.0

3 2.5 33.9 2.1

4 3.5 43.7 2.2

5 3.6 49.5 2.3

6 4.2 57.4 2.4

7 4.7 65.2 2.5

8 5.3 73.0 2.7

9 5.9 80.8 2.8
10 6.4 88.6 2.9
11 6.4 88.6 2.9
12 6.4 88.6 2.9
13+ 6.4 88.6 2.9

*grams per vehicle mile

NOTE: Excessive emission levels during a vehicle's later years of operation
indicate a lack of proper maintenance. This trend towards excessive
emission levels can be slowed if proper maintenance practices are
followed throughout the vehicle's life. Imposition of requirements
concerning proper maintenance practices by vehicle users is the subject
of another program under development within EPA, the Inspection and
Maintenance program.


-96-

8. Baseline Emissions of Trucks in the 6000 to 8500 Pound
GVWR Range - American Motors and General Motors have claimed

lower current baseline emissions than reported by EPA, and thus, argue
that EPA has overstated the benefits of the proposed action. Cn the
other hand, Chrysler has reported a baseline higher. than EPA's. Further
analysis of the original baseline data by EPA has lead to a reduction in
the calculated baseline emissions, but not to the extent suggested by
AMC and GM. The baseline has been decreased from 5.5 grams per mile

for HC, 58 grams per mile for CO, and 6.3 grams per mile for NOx to 4.3
grams per mile, 44 grams per mile, and 5.2 grams per mile EC, CO and

NOx, respectively. This revised baseline has been used in computing

9. Road Load Horsepower - The NPRM proposed values of road load
horsepower substantially higher than the existing requirements. Manu-
facturers submitted data indicating these values were too high and EPA
collected additional data confirming that contention. A new table of
road load power requirements has been developed. These power settings,
although lower than those proposed, are higher than the current regulation
requires and will result in a more accurate measurementof emissions and

fuel economy from LDTs.

10. Cost Effectiveness - The Council on Wage and Price Stability
(CWPS) has requested expansion of the cost effectiveness analysis in the
regulatory support documentation so as to evaluate separately the actions
of expanding the LDT class and then reducing the standards. Both CWPS

and General Motors have argued that an evaluation of the alternative of leaving


aie

-8E1-.



~89-

A further consideration in examining whether 6000 to 8500
pound GVWR trucks should be regulated by EPA as light duty trucks
or as heavy duty trucks involves the cost of each regulatory approach.
Regulating those trucks as heavy duty vehicles involves. less
cost, since the heavy duty procedure is an engine test procedure.
This means that one engine can be designed and tested to demonstrate
conformity with Federal emission standards, and then be used by the
truck industry in a wide variety of trucks. To require that these
6000 to 8500 pound GVWR trucks be regulated as light duty trucks would
mean that each truck coniiguration (as opposed to each engine) would
Have to be designed to meet emission standards. There are substan-
tially more truck configurations than engines.

Although a more costly approach, EPA has rejected the alternative
of leaving the 6000 to 8500 pound GVWR trucks in the heavy duty class.
The approach taken by EPA, that of requiring that 6000 to 8500 pound
GVWR trucks be included in the light duty truck class, was selected
because of thé increased emission reductions available from this class
of vehicles when tested under the light duty test cycle. Even
though this approach is more costly than either of the alternatives
discussed above, the Agency has determined that the emission reduc-
tions to be realized by this regulation are both necessary and
cost-effective in comparison with a wide range of other mobile -and

stationary source emission control strategies.


-9-
Chapter IL
LIGHT DUTY TRUCK CHARACTERIZATION

A. /Introduction

In the area of mobile source air pollution control, EPA's
primary concern in the near term is the reduction of urban
emissions, since air quality problems are most acute in urban
areas, Trucks of all types operate in urban areas, and hence
contribute to urban air pollution. To effectively reduce the
truck contribution to urban air pollution, these trucks must
be subjected to regulations controlling emissions from each
individual truck. However, unlike passenger cars, trucks
differ widely in their design and use characteristics. This
wide difference in truck design and use characteristics makes
it impractical to subject all trucks to the same emission
standards, and to require that 211 trucks be tested (for
compliance with emission standards) using the same test procedure.

Because trucks do differ go widely, EPA has in the past
divided trucks into light and heavy duty truck classes vy, The
first class, light duty trucks, has been defined as all trucks
less than 6000 pounds GVWR. These trucks have been subjected
to emission standards similar to light. duty vehicles (although
slightly less stringent) and have been tested on the same
test procedure as light duty vehicles. The second class,
heavy duty trucks, has been defined as all trucks above 6000
pounds GVWR. Engines employed in these heavier trucks have

been subjected to emission standards not nearly as stringent

i/ Current light duty truck and heavy duty engine emission control
regulations are contained at 40 FR 27593, June 30, 1975.


-95-

option remains to allow for common certification of a manufacturers

product line which may extend beyond the 8500 pound GVWR limit.

6. Incomplete Vehicles - Several manufacturers have argued that
incomplete vehicles are generally finished as commercial or recreational
use vehicles whose final configurations would meet the criteria for
inclusion in the heavy duty vehicle class. They have further argued that
the proposed procedure for certifying incomplete vehicles is overly

restrictive. EPA has partially concurred with these arguments.

The recommendation is to allow the primary manufacturer to classify
incomplete trucks either as LDTs cr as HDVs based on their intended
completed vehicle configuration. The maximum curb weight and frontal
area which the manufacturer intends to allow as a certified configuration
would be attached to the vehicle in the form of a label for all LDTs.
Incomplete HDVs under 8500 pounds GVWR would be labeled with a minimum
curb weight of 6000 lbs. or a minimum frontal area of 46 square feet..
Subsequent manufacturers completing these vehicles would be responsible

for purchasing and completing vehicles in a certified configuration.

7. Payload - The NPRM proposed that a 500 pound simulated payload
be substituted for the 300 pound payload in the existing regulation.
Comments received were largely negative and indicated that the use of
the higher payload was inconsistent with the personal use concept which
is the basis for the revised class definition. FPA concurs, and

therefore it is recommended that the 300 pound payload be retained.


~100-

vehicles used primarily for personal usage as a function of GVW. In
determining trends of personal usage with GVWR, special attention should
be given to the 5000, 6000, 8000, 10,000 and 16,000-26,000 pound GVWR
points since most of the truck sample is concentzated at these points.
(The sample was selected to represent the distribution of trucks in the
field.) With this in mind, the percent of personal usage vehicles tends
to remain stable at about 50% through 8000 pounds GVWR, remain stable at
about 2% for 16,000-26,000 pound vehicles, and be in transition between
8000 and 16,000 pounds GVWR. These data support a lower GVWR limit of
8000 pounds.

Figure 2 expands the lower GVW range of Figure 1 examining the
percent of vehicles used primarily for personal transportation by
vehicle type: pickups, panels and vans, multistops. Within each of
these body styles, the percentage of personal usage is fairly constant
with GVWR aithough it should be noted that the percent of 10,000 pound
GVWR pickups used primarily for personal usage is significantly less
than the percent of under 10,000 pound GVWR pickups used primarily for
personal usage. Averaged over all GVWR ranges, these data indicate that
53.5 percent cf pickup trucks are used primarily for personal usage,
23.6 percent of panels and vans are used for personal usage, and only
6.3 percent of multistop vehicles are used for. personal usage. Usage
data on cab chassis are not available, but it can be reasonably
assumed that these vehicles are basically non-personal usage vehicles,
since incomplete vehicles are typically finished with cargo carrying
bodies or permanent motor home equipment. Therefore an analysis of
Figure 2 indicates that not only do pickups account for the largest
percentage of trucks under 14,000 pounds GVWR, but they are the vehicles
which are used, to .a very large extent, for personal transportation.

Cc. Sales Distribution:

A selection of the specific cutpoint requires an examination
of the sales distribution of vehicles by body type and GVWR. Figures
3 and 4 present 1973 sales data from Ford and Chevrolet respectively.
(Chrysler has informally indicated that their vehicles are distributed
similary to their competitors.) Examination of the Ford data indicates
that a cutpoint. at 8500 pounds GVWR maximizes the overall percentage of
pickups included in the LDT class. A cutpoint below 8500 pounds GVWR
would omit a significant number of pickups. The range between 8500
and 9500 pounds GVWR is not heavily populated. Within this range, the
Chevrolet and Ford data indicate that the number of cab chassis and
multistop vehicles are about equal to the number of pickups.

D. Cutpoint Selection

All trucks up to about 10,000 pounds GVWR have similar design
characteristics. Functional usage data indicate that the majority of
trucks below a lower limit of 8000 pounds GVWR are used primarily for
personal transportation. In terms of body styles, pickups dominate the
GVWR range up to 10,000 pounds GVWR and are consistently used primarily


-116- .



-63-

Since no econometric studies to determine LDT price elasticities
have been conducted EPA must be satisfied by concluding that sales
decreases resulting from the light duty truck regulations may lie
anywhere within a 0.5 to 3 percent range. Exactly where within that range
the potential decrease in sales will fall is impossible to say with any
certainty. Some consumers may react to the $219 price increase for the
heavier trucks by electing to purchase a lighter truck. This would
increase the demand for these vehicles and mitigate the effects of the
lower demand for heavier trucks. In addition, any significant improve-
ments in general economic conditions resulting in increases in dis~
posable income or improvement in credit availability would increase the
demand for light trucks and probably overshadow the small negative
effects of the price increase.

It is not anticipated that this regulation will so adversely
affect consumer demand that any of the approximately 22 LDT
production facilities will be closed down. There may be
temporary production slow downs at some plants as consumers
re-evaluate their needs for specific light duty trucks and demand
patterns shift between the competing types, sizes, and styles of
trucks. But long run consumer demand for light duty trucks is
expected to continue to grow and so no permanent unemployment

of the industry's 36,036 5/ employees is anticipated. ‘Changes in

5/ Data obtained from U.S. Department of Commerce, County Business
"Patterns 1973.


-69—
as a comparison because they were based on equations developed for en

“average” heavy duty vehicle which was considered to have a GVsR of

26,000 pounds. Emissions factors for such a vehicle are much different

than a typical 6,000 to 8,500 pound GVWR truck. EPA does not neve data
which indicate in grams per mile how a lighter truck would. perform under
the 1979 heavy duty truck regulations (the results of which are expressed
in grams per brake-horsepower hour) and it is impossible to accurately
extrapolate the relationship from the data based on an average truck of

26,000 pounds GVWR..

6,000 to 8,500 pound trucks in the HDV class it is necessary to assume that,
emissions of these trucks will be equal to the gram-per-mile equivalent to
the proposed 1979 heavy duty engine standards. (1.6g/mi - HC, 69g/mi ~ CO,
and 6.3 g/mi - NOx). The resulting analysis shown in Table IV-F shows

that only control of HC would be gained. Emissions of CO and NCx might
well get worse. The costs associated with this increase in pollution

have not been factored into the $227/ton cost effectiveness number for

HC which is obtained. It should be remembered, however, that this

analysis is based on the assumption that gram-per-mile equivaients of a

26,000 pound GVWR truck can be extrapolated to obtain a value for
6,000 to 8,500 pound GVWR trucks, an assumption which is highly tenuous
and may potentially lead to a highly inaccurate number.

The cost effectiveness of the 1979 light duty truck regulations can
be seen in comparison with other mobile source cost effectiveness numbers

in Table IV-G. A review of this data indicates that except for the


-14-

Another observation is that almost all of the types of
vehicles which make up the current light duty truck class
[less than 6,000 pounds GVWR] are also manufacturered in larger
versions up to 10,000 pounds GVWR. Approximately one half
of all passenger vans, about one third of regular vans and
pick up trucks, and one fifth of station-wagons built on
truck chassis are between 6,000 and 10,000 pounds GVWR. Also
noteable is the fact that all of these truck types are less
than 10,000 pounds GVWR. Thus only multistop vehicles and
other incomplete trucks are produced in truck Class III as
well as Classes I and II.

The main item that all trucks up to 14,000 pounds GVWR
have in common is the engines. All domestic trucks in this
GVWR range use essentially the same engines as current 0 to
6000 pound GVWR light duty trucks. In most cases, these engines
are identical to those used in passenger cars or are close
derivatives of passenger car engines. The engines differ in
emission controls since some have been tested as light duty
trucks and others as heavy duty vehicles. These differences
amount to different carburetor and distributor settings and
differences in the "add-on" emission control devices. For
example most of the engines certified for heavy duty use do not
have exhaust gas recirculation, air injection, evaporative

emission controls, transmission controlled spark settings, or

catalysts.


the 6000 to 8500 pound GVWR vehicles in the HDV class under the proposed
interim 1979 HDV standards is necessary. The cost effectiveness analysis

has been revised to respond to these comments.

11, Optional Equipment Listing - This list of equipment would

have provided data om options aifecting frontal area of the vehicle

which in turn can influence the road load and subsequently emissiors and

fuel economy. However, the requirement as stated in the NPRM was too general
and would have required manufacturers to report a myriad of options that would
not affect the road load power. Therefore the reccmmencation has been

made to delete the proposed optional equipment listing requirement, end

ro replace it with a requirement to cal

including the frontal area cf optional ecu

33% of a given model line.

12. Ddsadvantages of Catalysts - Three basic disadvantages of

catalysts were claimed by several commenters, These were: (1) fire
danger; (2) unavailability of unleaded fuel in rural areas; and (3)
sulfate emissions. EPA has concluded on the basis of recent studies
that the fire danger from catalyst-equipped vehicles is no greacer
than that from existing non-catalyst vehicles already in widespreac
use in rural areas. EPA has also concluded that adequate amounts of
‘unleaded fuel will be available in all areas of the country by 1979
as a result of increasing numbers of light duty vehicles requiring its
use. Finally, the Administrator has decided not te presose standards
for sulfate emissions control at this time. If in the future it is
determinedthat sulfate emissions from catalyst vehicles represent a

significant hazard then an independent action will te taken.


-19-

are used to support these enterprises, 48.6 in class VI. and 76.5
in classes VII and VIII.

The data considered nus rar 1ena aagitionas support to tne
conclusion that: a breakpoint between light duty trucks and heavy
duty vehicles should be no higher than 10,000 pounds GVWR. =PA
conducted additional analysis 3/, however, to examine the
physical and usage characteristics of trucks below 10,000 pounds
GVWR so as to identify a cut-off point for the new light duty
truck definition that would minimize the inclusion of trucks
used for commercial purposes in the new light duty truck class.
One result of that analysis indicates that persenal transportation
is the dominant use for trucks up to 8000 pounds GVWR, percentage
of personal transportation is in transition in the gross vehicle
weight range 8000 to 16,000 pounds, and personal transportation
accounts for only two percent of the usage in trucks 16,000 to
26,000 pounds GVWR. When considering this data alone, indepen-
dent of other usage data, 8000 pounds GVWR appears to separate
light duty trucks from heavy duty vehicles on the basis of
personal use versus commercial use.

Cn further examination of usage characteristics of trucks
less than 10,000 pounds GVWR by truck type (see Appendix A), it
can be seen that pickups in that weight range are primarily

personal usage trucks and that panels, cab chassis and multistop

3/° The EPA analysis, "Selection of a Breakpoint Between Light
Duty Trucks and Heavy Duty Vehicles" is included as Appendix A
to this report.


~43~

Extensive efforts have been made within government and industry to
improve the information about mobile source sulfate emission factors,
sulfate air quality modeling techniques and sulfate health effects as a
function of exposure level. In addition technology assessment work is
proceeding to identify how sulfates are formed in catalyst/air pump
systems, and to develop other low sulfate producing catalytic control
systems such as the 3-way catalyst. The work in these areas is directed
toward development of a sulfuric acid emission standard for light

duty vehicles and light duty trucks should such a standard become

fate levels in real-life localized problem areas will not result in

situations hazardous to human health.

Although work is progressing within EPA directed towards develop-
ment of a sulfuric acid emission standard, current data indicate
that such a standard will not be needed in the near term. EPA's
decision not to propose a sulfuric acid emission standard was announced
April 12, 1976, by Dr. Thomas Murphy 8/, at which time Dr. Murphy
presented EPA's rationale and future plans in. this area:

"...{O]ur decision not to propose a standard at this time does not
mean that a standard may not be needed and promulgated in the future,

Rather, it means that EPA is not today in a position to determine with

8/ Opening Remarks by Thomas A. Murphy, Deputy Assistant Administrator,
Air, Land and Water Use, U.S. Environmental Protection Agency at the
Symposium "The General Motors/Environmental Protection Agency Sulfate
Dispersion Experiment," Research Triangle Park, North Carolina,

April 12, 1976.


-93-

12. Motor Vehicle Manufacturers Association
13. Perkins Engines
14. State of New York, Department of Environmental Conservation

15. Volkswagen of America, Inc.

Cc, Summary
1. Lead Time - The vehicle manufacturers have indicated that they
cannot achieve compliance with the proposed regulations in 1978. EPA's

analysis supports this argument and results in a’ recommendation to delay

implementation until the 1979 model year.

2. Fuel Economy ~- Most manufacturers have claimed that a fuel

economy penalty will be incurred as a result of the proposed action.
EPA's subsequent analysis of the additional data presented by the

commenters reaffirms that there need not be a fuel penalty as a result

of the proposed regulations.

3. Cost - A wide range of cost data inputs were received from the
manufacturers. Analysis of these data has lead to minor revisions in
EPA's original estimate. The estimated cost for 0 to 6000 pound GVWR
vehicles is now $8 per vehicle and the estimated cost for 6000 to 8500
pound GVWR vehicles has been increased slightly to $219 per vehicle

(including $15 for evaporative emission control equipment).

4, Stingency of Standards - Some manufacturers claimed that the
standards were more stringent than the 1977 LDV standards because of the
added payload and higher road load proposals. The higher payload re-

‘quirements were reassessed and it has been recommended that they be


-31-

Chapter III
ENVIRONMENTAL IMPACT
A. Background
On March 5, 1975, EPA Administrator Russell Train announced the
interim automotive emission. standards fot the 1977 model year and
recommended the delay of statutory HC, CO and NOx automotive emission
standards until 1980 in light of uncertanties regarding automotive sulfuric
acid emission levels. Because of continuing difficulties in achieving
the oxidant, carbon monoxide and nitrogen dioxide air quality standards
in major urban areas and the fact that the more stringent automotive

rds may

a delayed, EPA 4s taking 2 new lock at the
potential for further reduction of other sources of emissions of
hydrocarbons, carbon monoxide and oxides of nitrogen.

During the same March 5th press conference, Administrator Train
announced several actions designed to provide additional reductions
in emissions of hydrocarbons, carbon monoxide and oxides of nitrogen

from other sources. The actions included:

1. More stringent emission standards will be proposed for
heavy duty vehicles.

2. A new evaporative emission standard for autcmobiles will
be proposed for the 1978 model year.

3. Motorcycle emission standards will be set for the 1978
model year.

4, Existing standards requiring a 90 percent reduction in
hydrocarbon emissions during vehicle refueling must
result in use of the most effective control devices
which are available or can be developed.

5. EPA will re-examine current regulations providing
for hydrocarbon control from paints, solvents, dry-
cleaning liquids, and refineries with a view to
tightening them.


‘
ty | rt pe an

We ra

COO Be | Lag
Awe _
f { af aoe

-TEI-


-15-

In summary the major conclusions that can be drawn

concerning the present truck fleet are:

1)

2)

3)

4)

In terms of sales, the largest group of trucks is found
in the range of 0 to 10,000 pounds GVWR, with the re—

maining majority of trucks concentrated above 16,000
pounds GVWR.

Most. of the trucks sold in the current light duty truck
class [pickup, vans, station wagons on truck chassis] are
also produced between 6,000 and 10,000 pounds GVWR though
mone are greater than 10,000 pounds GVWR.

Few trucks are produced in Class III. Class III consists

exclusively cf multistop trucks and other incomplete

vehicles that are used primarily for mobile homes.

Engines found in all domestic trucks up to 14,000 pounds
GVWR are similar to the engines used in 0 to 6000 pound

GVWR trucks, and in most cases are also similar to those.
used in passenger cars.

These conclusions imply that the breakpoint between heavy

duty vehicles and light duty trucks, if based solely on truck

design characteristics, should be no higher than 10,000 pounds

GVWR.


es

applying a cost of control factor to that estimate. Combining sticker
frice increases and changes in operating costs (if any) the fallcwing

incremental costs (per vehicle) of meeting the emission standards were

derived:
Trucks Previously Certified Trucks in
as Heavy Duty Vehicles Curtent Light
Duty Truck Class

Sticker Price: Equipment $211 $0
Development 6 6
Certification 2 2
Cperating Costs: Maintenance 0 Q
Fuel o is)
Total $219 $8

Hany manufacturers ere
systems on light duty trucks less thaa 6000 pounds GVWR prior to the
1979 model year. For the purposes of calculating the aggregate incre-
mental cost of this regulation EPA assumed that ail trucks currently
defined as light duty trucks were so equipped. Trucks between 6000
and 8500.pounds CVWR are considered to have essentially no emission
control devices and so the full $219 expense would be required. The
aggregate incremental costs are given in Table IW-C.

For the years 1979-1983 the total cost of implementing this regulation
will be $1.67 billion. The calculations made in preparing Table IV-C
assume that light duty truck sales will continue to expand at 4.1
percent per year. It was also assumed that the sales split between
0-6000 pound trucks and 6,000-8,500 pound trucks will be the same
during the 1979-1983 period as it was in 1975 and 1976. In these

years, the first where light trucks were considered a class cf


~8cI-



-Lig-



~114-.



~2-

Section 202(a) further specifies that EPA must consider both the cost of
cocpliance with the regulation, and previde adequate time to comply with
the regulation.

As a further result of that court decision, EPA established a class
of vehicles differing from light duty vehicles for the purpose of setting
emission standards. That class, the light duty truck class, was defined
to include all trucks less than 6000 pounds gross vehicle weight rating.
(GVWR). In the same regulatory action which defined the light duty truck
class 2f, EPA sat emission standards for light duty trucks of 2.0 grams
per mile (g/m) HC, 20 g/m CO and 3.1 g/m NOx. Since model year 1975, the
light duty truck class definition and emission standards have not been
changed.

In contrast, light duty vehicles are being subjected to increasingly
more stringent emission standards. Beginning in model year 1975, light
duty vehicles are required to meet emission standards of 1.5 g/m HC,

15 g/m CO and 3.1 g/m NOx. In model year 1977, as currently required
by the Clean Air Act, the light duty vehicle NOx emission standard will
be lowered to 2.0 g/m. Further development of vehicles to meet auch
lower emission standards scheduled to be imposed in the future is

progressing in the light duty vehicle area.

2/ 38 FR 21362, August 7, 1973. Current emission regulations for light

duty vehicles, light duty trucks and heavy duty engines are set forth
at 40 FR 27593, June 30, 1975.


-91-
Table VI~c (cont'd) ....2.

pounds GVWR are regulated as heavy duty
vehicles, and are subjected in model year
1979 to emission standards of 1.5 g/BHP-hr

HC, 25 g/BHP-hr CO and 10 g/BEP-hr HC + NOx.*

Alternative IT ~ Light Duty trucks are controlled beginning
in model year 1979 to emission levels of
1.7 g/a BC, 18 g/m CO and 2.3 g/m NCx.
The light duty truck class is enlarged
to include all trucks up to 70600 pounds

GVER and 6000 pounds curk weight.

* As has been proposed for trucks greater than 8500 pounds GVWR, 41 FR 21292,
May 24, 1976.


-36-

Table III - Cc

6 Nationwide NOx Emissions
10° tons per year (percent of total reguleced mobile source emissions)

Source 1972 1975 1980

LDV 5.0 (64%) 5.1 (612) 3.5 (49%)
LDT 0.8 (10%) 0.9 (11%). 0.9 (13%)
HOV 2.0 (26%) 2.4 (29%) 2.8 (29%)
Total Regulated

Mebile Sources 7.8 8.4 7.2
Other Mobile

Sources 2.3 2.5 2.9
Total Mobile

Sources 10.1 10.9 10.3
Source:

1985

1.5 (26%)

0.8 (14%)

3.4 (602)

5.7

3.3

9.0

Revised Estimates of Total Nationwide Emissions for Various

Regulatory Alternatives, internal EPA memorandum, January, 1976,
as amended Octover, 1976.

1990

0.9 (162)
0.9 (16%
3.9 (70%)
5.6

3.9

9.5


“CO 7T-



-98-

13. Engine Calibrations - It has been argued that the expanded

class definition will greatly expand the number of engine calibrations
required for those vehicles previously certified as HBV. EPA has
agreed that numbers of calibrations will increase and has recognized

this as an additional cost of the action.

14. Four Wheel Drive - In response to comments from American
Motors, the recommendation is made to include specific procedures for

the certification testing of four wheel drive vehicles.

we

teguiations - Differences now ex

between California and EPA proposed regulaticns in regard to aspects
of class definition and test procedure. It is recommended that such

differences be resolved as part of the California waiver proceedings.


39-

Bi Primary Impact

1. Emissions Reductions for Light Duty Trucks

As shown in Table III-D the exhaust emissions standards will decrease
hydrocarbon, carbon monoxide and oxides of nitrogen emissions from light
duty trucks sold in model year 1979 and subsequent model years by 38
percent, 29 percent and 42 percent respectively on a per truck tasis.
Evaporative emission standards for light duty trucks, part of the final

regulations, currently acply ¢

°

The primary impact of the final evaporative. emission standards occurs
for those light duty trucks which have been added to the light duty truck
class (6000 to 8500 pounds GVWR). These heavier rated trucks. are currently
controlled under the heavy duty engine regulations, and are not subject
to am evaporative emission standard except in the state of California.
For these. trucks, imposition of the final evaporative emission standard
results in a 28 percent decrease in evaporative emissions from each
truck sold in model year 1979 and subsequent model years.

As new light duty trucks are put into use and older ones are scrapped,
emissions of the "average" light duty truck on the road will decrease.

Using sales projections, usage data, data on annual mileage 3/ and emission

3/ Annual mileage data on light duty trucks is contained in the preliminary
edition of Supplement No. 5 for compilation of Air Pollutant Emission
Factors (AP-42), U.S. Environmental Protection Agency, April 1975.