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Notice of Data Availability Concerning Supplemental Rulemaking on Ozone Transport Commission; Emission Vehicle Program for the Northeast Ozone Transport Region Publication: Federal Register Agency: Environmental Protection Agency Byline: Carol M. Browner Date: 24 October 1994 Subject: American Government  • The Environment
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[Federal Register Volume 59, Number 204 (Monday, October 24, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-26179]
[[Page Unknown]]
[Federal Register: October 24, 1994]
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ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 85
[FRL-5095-2]
Notice of Data Availability Concerning Supplemental Rulemaking on
Ozone Transport Commission; Emission Vehicle Program for the Northeast
Ozone Transport Region
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice of Data Availability.
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SUMMARY: On February 10, 1994, the Northeast Ozone Transport Commission
(OTC) submitted a recommendation to EPA under section 184 of the Clean
Air Act (the Act), for additional control measures to be applied
throughout the Northeast Ozone Transport Region (OTR). Specifically,
the OTC recommended that EPA require all state members of the OTC to
adopt an Ozone Transport Commission Low Emission Vehicle (OTC LEV or
LEV) program.
In today's notice of data availability, EPA is noticing additional
information regarding 49-state alternatives which have been suggested
during the course of the OTC/LEV petition process. This is the
additional information EPA referenced in its Supplemental Notice of
Proposed Rulemaking which was published in the Federal Register on
September 22, 1994.
DATES: Written comments on the specific issues discussed in this
document will be accepted until November 1, 1994. Please note, however,
that the public comment period for all other issues in this rulemaking
closes on October 24, 1994. Please direct all correspondence to the
address specified below.
ADDRESSES: Written comments should be submitted (in duplicate if
possible) to the Air Docket (see address below). Copies of information
relevant to this matter are available for inspection in public docket
A-94-11 at the Air Docket (LE-131) of the EPA, room M-1500, 401 M
Street SW, Washington, D.C. 20460, tel. (202) 260-7548, between the
hours of 8:00 am to 4:00 pm, on Monday through Friday.
FOR FURTHER INFORMATION CONTACT: Mike Shields, Office of Mobile
Sources, U.S. EPA, 401 M Street, S.W., Washington, D.C. 20460, tel.
(202) 260-3450.
SUPPLEMENTARY INFORMATION:
I. Background
Pursuant to section 184 of the Clean Air Act, the Northeast Ozone
Transport Commission (OTC) recommended that EPA require all state
members of the OTC to adopt an Ozone Transport Commission Low Emission
Vehicle (OTC LEV) program. On September 22, 1994, EPA published a
supplemental notice of proposed rulemaking (SNPRM) proposing to find
that reduction of new motor vehicle emissions through OTC LEV or a LEV-
equivalent program1 is necessary to mitigate the effects of
pollution transport and to bring nonattainment areas in the Northeast
Ozone Transport Region (``OTR'') into attainment and to avoid
interference with maintenance. 59 FR 48664. EPA had previously
published a notice announcing receipt of the OTC's recommendation, 59
FR 12914 (March 18, 1994), and a notice of proposed rulemaking (NPRM)
on the OTC recommendation, 59 FR 21720 (April 26, 1994).
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\1\A ``LEV-equivalent program'' was defined as an alternative
voluntary federal program that would achieve emission reductions
from new motor vehicles in the Northeast Ozone Transport Region
equivalent to or greater than would be achieved by the OTC LEV
program.
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Today's notice and its appendices provide information that has been
submitted to or developed by EPA after the SNPRM was signed. EPA
determined that additional public notice to make the public aware of
this additional information would be beneficial. EPA asks the public to
focus their comments on the key areas discussed below. Comments filed
after October 24, 1994, on topics addressed in previous notices (and
not discussed below) will be treated as late comments to which EPA is
not required to respond. The issues to be addressed are the following:
(1) The alternative voluntary federal program proposed by the American
Automobile Manufacturers Association; (2) the relevance of this
proposal and other 49-state motor vehicle programs to EPA's final
action on the OTC recommendation; (3) comparisons of the emission
reductions from new motor vehicles in the OTR achieved under OTC LEV
with those achieved under the automobile industry's proposal or under
other 49-state motor vehicle programs; (4) the effects on emission
reductions due to the migration of vehicles into the OTR from non-OTR
states; and (5) the effect on OTR boundary conditions of a 49-state
motor vehicle program. Commenters should be aware that before a 49-
state motor vehicle program could be adopted by EPA, EPA would be
required to provide the public with additional opportunities for
comment on the specifics of such a program.
II. Discussion
A. American Automobile Manufacturers Association's Proposal of a 49-
State Low Emission Vehicle Program
The American Automobile Manufacturers Association (AAMA) has
recently submitted a description of its proposed 49-state low emission
vehicle (``49SLEV'') program. AAMA believes that its proposed program
meets the test for a ``LEV-equivalent'' program that EPA proposed in
the SNPRM. AAMA's description of its program is republished as Appendix
A to this notice. To support its claim, AAMA relies on information
developed by its consultant, Thomas L. Darlington, Air Improvement
Resources, Inc. This information was presented at the September 30,
1994 meeting of the Subcommittee on Mobile Source Emissions and Air
Quality in the Northeast States of the Clean Air Act Advisory
Committee. The slides from that presentation are republished as
Appendix B. Further information from Mr. Darlington is available in the
docket for this rulemaking. EPA requests comments on AAMA's proposed
program and its supporting analysis.
B. Additional EPA Modeling Information Regarding Emission Reductions
From OTC LEV and Alternative Nationwide Program for New Motor Vehicles
EPA has prepared a simple analysis comparing emission reductions
from the OTC LEV program to those from a specified nationwide program.
The analysis was presented to the Mobile source Subcommittee at its
September 30, 1994 meeting. A draft staff report explaining EPA's
analysis is republished in Appendix C. A discussion of a nationwide
program's effect on the boundary conditions of the OTR states is in
Appendix D. EPA requests comments on these analysis.
C. OTC Critique of Modeling Information Comparing OTC LEV and
Alternative Nationwide Program for New Motor Vehicles
The OTC has also prepared modeling information comparing OTC LEV
and an alternative nationwide program for controlling new motor
vehicles and has critiqued the modeling done by AAMA and by EPA. In
Appendix E to this notice, EPA is republishing the slides from the
presentation of this information at the September 30, 1994, meeting of
the Subcommittee on Mobile Source Emissions and Air Quality in the
Northeast States of the Clean Air Act Advisory Committee.
Dated: October 17, 1994.
Carol M. Browner,
Administrator.
Appendix A
A description of the American Automobile Manufacturer
Association's (AAMA) 49-State Alternative Proposal with Related
Background Information sent in a letter of October 11, 1994 to Carol
M. Browner, Administrator, Environmental Protection Agency from
Jerry Esper, Director, Vehicle Environment Department, AAMA,
Washington D.C.
October 11, 1994.
Ms. Carol Browner,
Administrator, Environmental Protection Agency, Room W1200,
Waterside Mall, 401 M Street, S.W., Washington, DC 20005.
Dear Administrator Browner: Pursuant to the Environmental
Protection Agency Supplemental Notice of Proposed Rulemaking on
Ozone Transport Commission: Emission Vehicle Program for the
Northeast Ozone Transport Region (September 22, 1994 Federal
Register, page 48662), attached is a detailed description of the
American Automobile Manufacturers Association's 49-state alternative
proposal with related background information. We request that this
additional information be published in the Federal Register as part
of the AAMA proposal as soon as possible. We are submitting this as
a partial response to the SNPRM but are concerned that the October
24, 1994 filing deadline will not give adequate time for EPA and the
public to fully consider this information.
Sincerely,
Jerry Esper,
Director, Vehicle Environment Department.
Technical Program Description 49-State Alternative to OTC LEV
A supplemental notice of proposed rulemaking published on Sept. 22,
1994 indicated that EPA proposed to find that the low-emission vehicle
(``LEV'') program recommended by the Northeast Regional Ozone Transport
Commission (``OTC'') or an alternative ``LEV-equivalent program'' would
be necessary to achieve the national ambient air quality standards
(``NAAQSs'') for ozone, and for other purposes, in the Ozone Transport
Commission region (``OTR''). The SNPRM defines ``a LEV-equivalent
program'' as ``an alternative voluntary federal program that would
achieve emissions reductions from new motor vehicles in the OTR
equivalent to or greater than would be achieved by the OTC LEV
program.'' See 59 FR 48,664, 48,667 n.2.
This memorandum describes the 49-State low-emission vehicle
(``49SLEV'') alternative program, which meets the test for a ``LEV-
equivalent'' program established in EPA's recent SNPRM. The 49SLEV
program would provide reductions in ozone-forming emissions from the
federal Tier 1 level that are equivalent to, or greater than, a
combination of (1) the OTC-recommended program in the OTR jurisdictions
and (2) the sale and use of zero-emission vehicles (``ZEVs'') in the
OTR in the same volumes mandated in California.
Statutory and Regulatory Background
EPA promulgated its mandatory Tier 1 regulations for gasoline-
powered light-duty vehicles and light-duty trucks in 1991. See 56 FR
25,724 (June 5, 1991). Title II of the Clean Air Act Amendments of 1990
precluded EPA from adopting or enforcing mandatory new motor vehicle
exhaust emissions standards under section 202(a) of the Act that would
be more stringent than the Tier 1 standards for gasoline-powered
vehicles in those weight classes prior to MY 2004. See 42 U.S.C.
7521(b)(1)(C), (i). The limitations contained in the 1990 Amendments
therefore effectively require any eligible State that seeks light-duty
vehicle or light-duty truck emissions reductions more stringent than
those contained in Title II prior to MY 2004 to adopt the California
State standards under section 177 of the Clean Air Act. See 42 U.S.C.
7507.
Two States (New York and Massachusetts) have already begun to
enforce some of the California State standards under section 177. The
primary proposal under consideration in this docket is a more
comprehensive proposal to require all jurisdictions in the OTR to adopt
and enforce the California State standards under section 177. See 59 FR
21,720, 21,737-38 (Apr. 26, 1994). These efforts to adopt the
California program are based on a belief among some of the States in
the OTR that more stringent vehicle standards than the Tier 1 limits
are necessary in the OTR. See 59 FR at 48,671-90.
Data provided to EPA indicate that vehicles registered outside the
OTR generate a substantial percentage of vehicle miles travelled
(``VMT'') in the OTR during summer months. One portion of the VMT
generated by non-LEV vehicles is caused by the ``migration'' of non-OTR
vehicles into the OTR, as a result of permanent relocation of the
owners of those vehicles from non-OTR States into OTR States. The
balance of the non-OTC-controlled VMT within the OTR results from
temporary business or personal travel by non-OTR vehicles inside the
OTR. The analyses show that at least 6.5 percent of VMT in the OTR is
generated by vehicles originally registered outside the OTR that
permanently ``migrate'' into the OTR, and that an additional 4.1
percent of the VMT in the OTR results from temporary operation of non-
OTC vehicles inside the OTR.
Neither the individual States in the Northeast, nor EPA acting
under its authority in section 184 of the Clean Air Act, has much
practical ability to control the generation of VMT inside the OTR by
vehicles registered outside the OTR. Thus, even if the OTR States and
EPA take all the steps allowed under the Clean Air Act to introduce the
LEV program into the Northeast, that program will still not provide the
same level of emissions control benefits as the State of California can
claim for the LEV program in California. In the absence of some
regulatory breakthrough, the problem of non-OTR-controlled VMT will
continue until at least 2023, which is 20 years after a Tier 2
nationwide program might come into effect in MY 2004. (It is estimated
that the in-use vehicle population in the Northeast would take about 20
years to ``turn over,'' so that nearly all pre-MY 2004 vehicles would
be off the road.) Whether this factor would actually be addressed
beginning in MY 2004 depends upon whether EPA determines later in this
decade to revisit the Tier 1 standards, and if so what new standards
more stringent than the Tier 1 standards the Agency would adopt.
The 49-State LEV Alternative
The 49SLEV program would modify emissions control requirements for
vehicle manufacturers in two stages. Initially, the program would
require each manufacturer to sell a combination of LEVs and other
vehicles in the OTC jurisdictions that would achieve equivalent or
greater emissions reductions than the mix of vehicles it would have
sold under OTC LEV program (which would go into effect in MY 1999 in
the OTR). This aspect of the program will require the sale of
substantial numbers of vehicles certified to the LEV standards adopted
by California and using California test procedures and fuels, which are
summarized in Table 1 below, beginning in MY 1999.
Table 1.--Exhaust Emissions Standards for 49-State LEV Program
[Grams per mile]
------------------------------------------------------------------------
Durability basis
NMOG CO NOX
------------------------------------------------------------------------
LDV and LDT 1.............. 50,000 mi....... 0.075 3.4 0.2
100,000 mi...... 0.090 4.2 0.3
LDT 2...................... 50,000 mi....... 0.100 4.4 0.4
100,000 mi...... 0.130 5.5 0.5
------------------------------------------------------------------------
Under the 49SLEV proposal, each manufacturer would be required to
file annual reports with EPA demonstrating that the mix of vehicles it
produced for sale in the OTR region in MY 1999 and 2000 met the
equivalency test (which is described in the next section). Vehicles not
certified to the LEV levels shown in Table 1 above would be required to
meet the California ``Tier 1'', transitional low-emission vehicle
(``TLEV''), ultra low-emission vehicle (``ULEV'') or ZEV levels, which
are published in 13 CCR Sec. 1960.1(g)(1). Manufacturers that relied on
the early introduction of TLEVs or other non-Tier 1 vehicles into the
OTR before MY 1999 to meet the equivalency test would be required to
file reports beginning the first year that credits would be earned
towards the MY 1999 equivalence requirement.2 The vehicles sold in
the OTR under the 49SLEV program would be tested in accord with the
California vehicle test procedures (including test fuel
specifications). See 13 CCR 1960.1(g)(1). The California State enhanced
evaporative emissions standards and onboard diagnostics control
regulations (which are currently subject to review at EPA under section
209 of the Clean Air Act) would apply to these vehicles as well.
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\2\ The reporting requirements would be based on those contained
in the amendments to Part 86 in EPA's 1991 Tier 1 Final Rule. See,
e.g., 40 CFR 86.094-8 (1993).
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The second stage of the 49SLEV program would take effect in MY
2001, when all new passenger cars and light-duty trucks sold outside
California would be required to meet the LEV standards summarized in
Table 1. In that manner the 49SLEV program would provide for new motor
vehicle emissions reductions beyond the Tier 1 level on a nationwide
basis. It would do so before such a step would be possible under Title
II of the Clean Air Act, and without the need for any State action
under section 177. This would mean that all the MY 2001 and later
model-year VMT within the OTR--generated by vehicles registered both
inside and outside the OTR--would meet LEV levels. Such an approach
would be beneficial not only in the OTR jurisdictions, but also any
ozone nonattainment area outside California.3
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\3\ The 49SLEV proposal would affect the boundary conditions
required for standards attainment or maintenance modeling in some
OTR domains. If all MY 2001 and later VMT in the regions adjacent to
the OTR (such as the Virginia Tidewater and Piedmont and the Ohio
Valley) were controlled to LEV (rather than Tier 1) levels, urban
areas inside the OTR should consider whether their UAM modeling
should use lower VOC or NOX boundary conditions under a 49SLEV
scenario than under an OTC LEV scenario.
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Assuring Equivalent Emissions Control
EPA's supplemental notice published on September 22 contemplated
that any LEV-equivalent program would be accompanied by a simple means
by which the States and EPA could assure that regionwide emissions
reductions from the Tier 1 baseline would be at least as great, under
the alternative program, as under the OTC LEV program. See 59 FR at
48,667 n.2, quoted at p. 1 above. That general requirement in turn must
be translated into a specific compliance protocol that a given
manufacturer can implement in its own production plans.
To meet that requirement, the 49SLEV proposal includes a specific
new-vehicle phase-in schedule for light-duty vehicle and light-duty
truck (under 3,750 lbs. GVWR) LEVs and TLEVs in the OTR that would meet
or overachieve the requirement of equivalency. That phase-in schedule
begins the introduction of TLEVs in MY 1997 in order to generate
credits in time for the MY 1999 equivalence demonstration, and would
result in a sales-weighted OTR fleet NMOG averages for LDVs and LDTs
under 3,750 GVWR as follows: 0.20 g/mi. NMOG in MYs 1997-1998, 0.148 g/
mi. NMOG in MY 1999, and 0.095 g/mi. NMOG in MY 2000. The OTR fleet
NMOG level achieved in MY 2001, the first year of the 100 percent LEV
requirement, would be 0.075 g/mi. NMOG.4 Such a phase-in schedule
for TLEVs and LEVs in the OTR would be ``LEV-equivalent'' within the
meaning of the SNPRM published last month, when the migration benefits
of the non-OTC LEV vehicle for 2001 and later model years are
considered. This point is confirmed in EPA's emissions factor analysis
published on September 30, 1994.
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\4\ The 49SLEV program would also permit the carryforward,
carryback and trading of NMOG credits, but any NMOG deficit in the
OTR would have to be retired by the end of MY 2001.
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Fuels-Related Considerations
The 49SLEV program would not require the use of commercial
gasolines different from those anticipated in the Northeast and other
non-California jurisdictions under current law and regulations. Like
any other vehicle equipped with LEV hardware, vehicles certified under
the 49SLEV proposal would be expected to pass the standards applicable
to LEVs when operated on their certification fuel, which in most cases
is expected to be California ``Phase 2'' reformulated gasoline. That
gasoline will have strictly controlled sulfur levels, and will be
commercially available in California in 1996. Vehicle manufacturers are
expected to rely on the clean performance characteristics of that
gasoline, particularly as emissions standards become more stringent in
California.
The current California State regulations for onboard diagnostics
controls (the ``ODB II regulations'') applicable to MY 1999 and later
LEVs are currently under revision by the CARB staff, and those
revisions are not expected to receive final approval under California
law for several more months. Following final action in California, the
revised OBD II regulations would also require EPA review under section
209(b) of the Clean Air Act. See 42 U.S.C. 7543(b). California LEV
vehicles designed to meet the revised version of the CARB ODB II
regulations are at substantial risk of falsely illuminating their
malfunction indicator lights (``MILs'') when routinely operated on non-
California gasolines with unknown sulfur levels. (A MIL illumination
should be considered ``false'' when it results from gasoline
composition rather than the failure of an emissions component.)
In addition, data from recent test programs demonstrate that some
LEVs routinely operated on gasolines with sulfur levels higher than
those allowed in California will fail in-use compliance tests and, when
operated on high-sulfur fuels, will not be able to meet so-called
``maximum'' inspection/maintenance (``I/M'') cutpoints set at 1.5 times
the LEV certification standards. For those reasons, vehicles produced
for the 49SLEV program might require OBD II MIL illumination criteria
and I/M test procedures cutpoints that would take account of non-
California fuel quality. In addition, vehicles produced for the 49SLEV
program and registered outside California would receive additional in-
use test preconditioning and any special maintenance required to take
account of the differences between California commercial fuels and
those available elsewhere. The hardware used on the 49SLEV vehicles
sold outside California would be identical with the hardware on
California LEVs in the same model year.
Enforcement
Participants in the OTC LEV rulemaking have met regularly with the
States, the EPA staff and others to develop mechanisms to enforce the
obligations involved in the 49SLEV proposal described above. Some
proponents of the 49SLEV program have proposed to enforce its program
through a consent decree that would include all vehicle manufacturers
in the U.S. market. The EPA staff has also developed a plan to
promulgate voluntary regulations based on the 49SLEV proposal on an
expedited basis. There is general agreement that if the States and EPA
want the 49SLEV program to go forward, a satisfactory enforcement
mechanism can be developed, based on the work done to date.
Appendix B
Republished slides from the presentation of this information by
Thomas Darlington, Air Improvement Resources Inc., representing AAMA
at the September 30, 1994, meeting of the Subcommittee on Mobile
Source Emissions and Air Quality in the Northeast States of the
Clean Air Act Advisory Committee.
COMPARISON OF 49-STATE ALTERNATIVE
TO OTC LEV PROGRAM
PRESENTATION TO
SUBCOMMITTEE ON MOBILE
SOURCE EMISSIONS AND AIR
QUALITY IN THE
NORTHEAST STATES
September 30, 1994
Washington, D.C.
Tom Darlington
Air Improvement Resource
(810-380-3140)
OVERVIEW
INDUSTRY 49-STATE ALTERNATIVE
MIGRATION
PERMANENT
TOURISM
INVENTORY ANALYSIS
49-STATE
OTC LEV (+ZEV)
INDUSTRY 49-STATE ALTERNATIVE
INTENDED TO:
1. Match VOC and NOX benefits of OTC LEV (+ZEV) in OTR. (It does
this.)
2. Provide significant mobile source benefits to rest of nation.
3. Do so in a cost effective manner.
KEY ELEMENTS
CA LEV Vehicle
CA OBD2 hardware
Phased-in 30/60/100 starting in 1999 in OTR
Available 100% in rest of nation in 2001
TLEV's prior to 1999 to match OTC LEV + ZEV, corrected for migration
effects
MIGRATION
Two Types of Migration
Permanent
Temporary (Vacation + Business): Tourism
Both affect 49-state and OTC LEV, but to varying degrees. Affects OTC
LEV more than 49-State Alternative
PERMANENT MIGRATION
Bureau of Census Data 1985-90
People are a surrogate for vehicle migration
Estimate of Permanent Migration
Fleet Fraction: 6.5%
EPA: 7.25%
Independent Data Sources
Different Techniques
Same Answer
E.H. Pechan Review of 6.5%
Probably underestimates permanent migration due to moves less than 5
years
TEMPORARY MIGRATION
U.S. Travel Data Center
Summary of Trips from One Region to Another
Estimated VMT Fraction: 4.1%
E.H. Pechan Review:
Washington COG: 4% in 1990, 5% in 2010
Delaware Regional Planning Commission: 5%
MODELING RUNS
Assumes enforceability of 49-State Alternative
CA OBD2 on 49-state vehicles with I/M program that meets EPA
April 8 criteria
I/M 240
Audit program
Backstops
OTC LEV case includes benefits of ZEV's with and without power
plant effects
Other Assumptions
Fed Reform
Stage II
Onboard vapor recovery
POWER PLANT EFFECTS
Based on Sierra Research Report
Assumes Phase 2 controls
New England
Mid Atlantic (except Pennsylvania)
Vehicle power=0.37 Kwh/mi
Average emission rates
NOX=0.32 g/mi
VOC=0.015 g/mi
Comparison with NESCAUM 1992 analysis
NOX=0.12-0.15 g/mi
EMISSION INVENTORY COMPARISON
Difference in Emissions, OTC LEV minus 49 State
Permanent Migration 6.5%
Tourism 4.1%
Includes power plant emissions
------------------------------------------------------------------------
VOC NOX
CYR ------------------------------------
TPD % TPD %
------------------------------------------------------------------------
1996............................... -0.3 0 -0.08 0
1999............................... 4.1 <1 -3.0 <1
2002............................... 8.5 <1 -5.0 <1
2005............................... 7.0 <1 11.6 1.0
2007............................... 10.8 1.5 34.6 3.5
2010............................... 10.6 1.9 50.1 6.4
2015............................... 11.7 2.5 82.4 13.6
------------------------------------------------------------------------
Positive values indicate 49-State Alternative lower.
SENSITIVITY ANALYSIS WITHOUT POWER PLANT EFFECTS
Difference in Emissions, OTC LEV minus 49 State
------------------------------------------------------------------------
VOC NOX
CYR ----------------------------------
TPD % TPD %
------------------------------------------------------------------------
1996................................. -0.3 <1 0 0
1999................................. 4.0 <1 -3.9 <1
2002................................. 8.3 <1 -9.9 <1
2005................................. 6.2 <1 -3.9 <1
2007................................. 9.7 1.3 11.7 1.2
2010................................. 9.1 1.6 18.3 2.3
2015................................. 9.7 2.1 41.2 6.8
------------------------------------------------------------------------
BILLING CODE 6560-50-P
TP24OC94.000
BILLING CODE 6560-50-C
Comparision With EPA and State Analyses
------------------------------------------------------------------------
Item Air EPA State
------------------------------------------------------------------------
1. Enhanced I/M 100%........... 85%................. 100%
in OTR.
2. I/M of Blend of No I/M.............. Blend of
Tourism Enhanced, Enhanced,
Vehicles. Basic, None. Basic, None.
3. Power plant Both ways...... No.................. No.
effects.
4. OBD of 49- CA OBD2........ CA OBD2............. Fed OBD.
State.
5. Migration
Rates
Permanent... 6.5%........... 7.25%............... 7.25%*
Tourism..... 4.1%........... 4.1%................ 4.1%*
------------------------------------------------------------------------
*Still evaluating against vehicle registration data.
CONCLUSIONS
1. 49-State Alternative results in equivalent VOC and NOX emission
reductions to OTC LEV program with ZEV benefits in Northeast when
migration taken into account.
2. 49-State proposal results in significant nationwide benefits of VOC
and NOX.
Appendix C
Draft EPA staff report comparing the emissions benefits of the
OTC LEV program to those from a 49-State motor vehicle program.
Memorandum
Subject: Update of Emissions Estimates for OTC/LEV and National
LEV Programs in the Ozone Transport Region.
From: Office of Mobile Sources.
To: Subcommittee and Work Group Members on Mobile Source
Emissions and Air Quality in the Northeast States.
On July 12, 1994 the EPA Office of Mobile Sources (OMS) released
a memorandum providing emission estimates for the Ozone Transport
Commission OTC LEV Program and several scenarios related to an
alternative program of national standards. Since then, these
alternative standard proposals have changed and OMS has worked to
refine the original analysis to incorporate some of the issues
raised in response to its release.
The process of refining the analysis is not necessarily
complete, and further analysis will be needed if there are changes
in the proposed alternatives to the OTC LEV program. However, the
attached tables give EPA's current best estimates of the emissions
benefits of the various programs given the specific assumptions
detailed in the attachment. This analysis is an approximation of the
emissions under the various scenarios in order to illustrate their
relative impacts. It is not meant to replace the more complete
analyses needed for inventory creation, air quality modeling, or for
any SIP submission.
Two major issues concerning the national standards alternative
remain unresolved. These are: The mechanism for enforcing the
program prior to the 2004 model year, and the circumstances under
which these vehicles would have California OBD (or its equivalent).
If these issues are not resolved, the benefits of the national
alternative will be substantially smaller than what is shown in this
analysis. In presenting these emission estimates. EPA is
highlighting the importance of resolving these issues related to the
current proposals.
This memorandum will be followed by a more detailed memorandum
on the methodology used for the assessment of migration and tourism
impacts.
Attachments
Analysis of OTC LEV and National Alternative Scenario
EPA has prepared a simple analysis comparing the emission
benefits of the OTC LEV program to the National Alternative Scenario
(described below). This analysis is an approximation of the
emissions under the various scenarios for illustration of the
relative impacts of each scenario. It is not meant to replace any
more complete analyses needed for inventory creation for air quality
modeling or for any SIP submission. The mass emissions calculated in
this analysis do not necessarily agree with mass emissions given in
the previous Supplemental Notice due to differences in methodology
(as described below).
Basic Methods and Assumptions Common to All Scenarios
This analysis was done using MOBILE5a-AAMA PROPOSAL, the special
version of MOBILE5a created Nov. 15, 1993 to analyze the FedLEV
proposal. The only difference between MOBILE5a and MOBILE5a-AAMA
PROPOSAL is that the latter model includes some features which
simplify the modeling of variations of the California LEV program.
MOBILE runs using three different vehicle speeds were used to
model the OTR. Emission factors for light duty gas vehicles (LDGV--
passenger cars) and light duty gas truck 1's (LDGT1--light trucks
under 6,000 lbs.) for each speed were multiplied by the proportion
of VMT at that speed5 to get overall, speed-weighted emission
factors for LDGVs and LDGT1s. The LDGV and LDGT1 emission factors
were then multiplied by the proportion of VMT associated with each
vehicle class (taken from the default VMT mix output of MOBILE5) to
get composite LDGV/LDGT1 emission factors. These composite emission
factors were then multiplied by estimated VMT for these vehicle
classes in the entire OTR to get mass emissions results.
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\5\5 Speeds and VMT weights are from ``Adopting the California
Low Emissions Vehicle Program in the Northeast States--An
Evaluation'', September 1991, prepared for NESCAUM by E.H. Pechan &
Associates and Energy and Environmental Analysis.
---------------------------------------------------------------------------
All runs used a temperature range of 66-95 degrees, assumed
Stage II evaporative refueling controls were in place and 80%
efficient, and assumed Federal Reformulated Gasoline was in place
region-wide. VMT in 1990 for OTR states was taken from Federal
Highways Administration data. The passenger car and light truck
portion of the VMT was calculated using MOBILE5a default national
VMT fractions. A linear growth rate of 2% was used to project future
VMT.
Two I/M cases were run for each scenario: 85% of the OTR fleet
was assumed to be subject to an enhanced I/M program and 15% of the
OTR fleet was assumed to be subject to no I/M program. In all cases,
enhanced I/M programs were assumed to meet EPA's SIP requirements
for full credit for LEV type programs.6
---------------------------------------------------------------------------
\6\These requirements are specified in ``Emission Reduction
Credits for California Low Emission Vehicles (LEVs)'', memorandum
from Phil Lorang to Regional Air Division Directors, April 8, 1994.
This memo specified enhanced I/M performance standard cutpoints of
0.6 g/mi THC, 10 g/mi CO, and 1.2 g/mi NOX for vehicles with
emissions standards beyond Tier 1.
---------------------------------------------------------------------------
As a result of using a single set of MOBILE runs (and region-
wide rather than local VMT), this analysis does not take into
account differences in local temperatures, fleet mix, base year RVP,
growth in VMT, etc. These factors should have little effect on the
relative benefits of the various scenarios, but would have an effect
on the absolute emission factors or mass emissions in different
parts of the OTR.
Scenario-Specific Methods and Assumptions
New York and Massachusetts have both passed legislation
mandating the LEV program, which could remain in place regardless of
EPA action on the OTC LEV petition. The Tier 1, OTC LEV + ZEV, and
OTC LEV cases all assume that New York and Massachusetts will have
LEVs beginning with the 1996 model year. We ran MOBILE5 using an
identical input file to the OTC LEV + ZEV case except that the LEV
program start year was set to 1996. We weighted the output from
these runs with the output from the Tier 1, OTC LEV + ZEV, and OTC
LEV cases by the proportion of OTR VMT in New York and Massachusetts
to determine emission factors and mass emissions with the LEV
program in place in those states. The National Alternative Scenario
assumes no separate LEV program in New York or Massachusetts.
Two LEV scenarios were analyzed. The OTC LEV + ZEV scenario
assumes that the LEV program starts with the 1999 model year and
includes a ZEV sales mandate identical to the LEV program in
California. The OTC LEV case assumes that there is no ZEV sales
mandate in the OTR (other than in New York and Massachusetts as a
result of those states separate programs) but that each model year
beginning in 1999 meets the fleet average NMOG exhaust standards
required in California for that model year.
The National Alternative Scenario assumes 40% of the fleet in
the OTR will meet TLEV standards beginning with the 1997 model year.
Beginning with the 1999 model year, 30% of the fleet will meet LEV
standards, increasing to 60% in the 2000 model year, and 100% in the
2001 model year.
Two major issues concerning the National Alternative Scenario
remain unresolved. These are: the mechanism for enforcing the
program prior to the 2004 model year, and the circumstances under
which these vehicles would have California OBD (or its equivalent).
If these issues are not resolved, the benefits of the national
alternative will be substantially smaller than what is shown in this
analysis. In presenting these emission estimates, EPA is
highlighting the importance of resolving these issues related to the
current proposals.
The emission impacts of these scenarios (without the impacts of
migration or tourism) are shown in Table 1 below.
Table 1.--Emission Estimates for Passenger Cars and Light-Duty Trucks (< 6000 lbs.) in the OTR, Not Accounting
for Permanent Migration and Temporary Visitation by Vehicles From Outside the OTR.
----------------------------------------------------------------------------------------------------------------
VOC emissions (g/mi) NOX emissions (g/mi)
-------------------------------------------------------------------------------------------
Year National National
Tier 1 OTC LEV + OTC LEV alternative Tier 1 OTC LEV + OTC LEV alternative
ZEV scenario ZEV scenario
----------------------------------------------------------------------------------------------------------------
1990................ 4.33 4.33 4.33 4.33 1.88 1.88 1.88 1.88
1996................ 1.56 1.56 1.56 1.56 1.56 1.56 1.56 1.56
1999................ 1.26 1.26 1.26 1.25 1.34 1.33 1.33 1.33
2002................ 0.92 0.88 0.88 0.88 1.17 1.11 1.11 1.12
2005................ 0.78 0.69 0.69 0.69 1.05 0.89 0.89 0.91
2007................ 0.71 0.59 0.60 0.60 0.99 0.77 0.77 0.78
2010................ 0.64 0.47 0.48 0.49 0.91 0.60 0.61 0.63
2015................ 0.60 0.39 0.40 0.41 0.86 0.47 0.48 0.50
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
VOC emissions (tons/day) NOX emissions (tons/day)
-------------------------------------------------------------------------------------------
Year National National
Tier 1 OTC LEV + OTC LEV alternative Tier 1 OTC LEV + OTC LEV alternative
ZEV scenario ZEV scenario
----------------------------------------------------------------------------------------------------------------
1990................ 4,527 4,527 4,527 4,527 1,966 1,966 1,966 1,966
1996................ 1,809 1,809 1,809 1,810 1,809 1,809 1,809 1,809
1999................ 1,536 1,530 1,530 1,526 1,626 1,618 1,618 1,621
2002................ 1,165 1,117 1,119 1,115 1,490 1,407 1,409 1,424
2005................ 1,027 909 910 914 1,394 1,175 1,179 1,201
2007................ 971 807 812 817 1,346 1,041 1,052 1,062
2010................ 907 672 679 694 1,292 854 865 887
2015................ 897 585 596 623 1,297 706 724 747
----------------------------------------------------------------------------------------------------------------
Permanent Migration and Temporary Visitation Impacts on Emissions
Because the OTC LEV program will apply only to vehicles sold
within the OTR, and because the National Alternative Scenario has a
later start date outside the OTR, some increase in emissions will be
associated with the permanent migration and temporary visitation of
non-LEVs from other states into the OTR. The amount of excess
emissions associated with migrating and visiting vehicles is
dependent on two factor: the difference in emissions per vehicle
between the fleet entering the OTR and the ``native'' fleet within
the OTR, and the number of vehicles entering the OTR from outside.
The difference in emissions per vehicle between the fleet
entering the OTR and the native fleet within the OTR is dependent on
several factors, including the vehicle standard they are each
certified to and the I/M program each is subject to. The difference
in emissions due to differences in standards is larger in the OTC
LEV case, where immigrant vehicles are assumed to be Federal Tier 1
vehicles, than in the National Alternative Scenario, where the only
difference is that the start year of the program is delayed outside
the OTR.
Vehicles that permanently migrate into the OTR will be subject
to the same I/M program as vehicles originally sold in the OTR.
However, vehicles that are temporarily visiting the OTR are subject
to the I/M program in their home state. As a result, the emission
factors associated with the fleet of vehicles that permanently
migrates into the OTR will be different than the emission factors
associated with the fleet of vehicles temporarily visiting the OTR,
and the effects of permanent migration and temporary visitation must
be calculated separately.
Methodology for Estimating the Amount of Permanent Migration of
Motor Vehicles Into the OTR
There is no readily available source of information that allows
direct estimates to be made of the vehicle population in the OTR
that was originally sold outside the OTR. The ideal source of
information would be a state-by-state vehicle registration database
that includes the state of original sale for every motor vehicle.
Such a database would allow direct estimation of the number of non-
LEV vehicles in the OTR in future years. However, this kind of
database does not currently exist for the OTR.
The next alternative source of information would be a state-by-
state registration database that shows the percentage of newly
registered vehicles in the OTR that entered the OTR from states
outside the OTR in a one-year period. This kind of database would
allow estimation of the annual migration rate of vehicles into the
OTR. The individual states within the OTR may well have this
information, however, EPA was unable to obtain such information in
time for this analysis. We understand that the states are attempting
to develop such a database. However, as discussed below, an annual
migration rate is not enough by itself to estimate the number of
non-LEV vehicles in the OTR in future years; to calculate the
overall effect of migration on the fleet further analyses of the
type described below would be needed.
In the absence of a comprehensive source of data on vehicle
migration, we chose to use human population migration as a
surrogate. There are two sources for state-to-state population
migration data: the U.S. Bureau of the Census,7 which includes
questions about change in residency in the decennial census; and the
U.S. Internal Revenue Service8 (IRS), which maintains a
database of changes in filing addresses for personal income tax
returns.
---------------------------------------------------------------------------
\7\1990 Selected Place of Birth and Migration Statistics for
States, U.S. Bureau of Census.
\8\Statistics of Income Program, U.S. Internal Revenue Service.
---------------------------------------------------------------------------
The migration data collected by the Bureau of Census have one
major drawback. The data are based on a census form question which
asks respondents what state they lived in five years ago. Since
multiple moves are not recognized by this kind of question, the
census data tend to underestimate the actual rate of migration. For
this analysis, that kind of underestimation can be a problem. For
example, a resident of Ohio could move to New York for several
years, then return to Ohio, and not be recognized as ever having
lived in New York in the census database. However, if the Ohio
resident brought a non-LEV vehicle with her when she moved to New
York, that vehicle would contribute excess emissions to the New York
inventory while it was there.
The migration data collected by the IRS allow the estimation of
a true annual human migration rate from state-to-state. The IRS
records the current year address and previous year address for all
filers of individual income tax forms. Summaries of this database
showing annual state-to-state (and even county-to-county) migration
are available. The database shows both the number of individual tax
returns and the number of exemptions claimed on those returns.
Although this database does not include the portion of the
population that does not file tax returns, the data on exemptions do
give the best available estimates of annual state-to-state migration
of human population.
The IRS state-to-state migration data for 1991 to 1992 indicate
a human migration rate of 1.03% of the OTR population into the OTR
from non-OTR states other than California (i.e., in 1992, 1.03% of
the OTR population lived in a non-OTR state, other than California,
in the previous year). The same database also gives a 1.98% rate of
out-migration for the same period.
For this analysis, we have assumed that the vehicle migration
rate was equal to the human migration rate (i.e., that all people
who move take their vehicles with them). Thus, this approach is
likely to somewhat overestimate the vehicle migration rate since
some people will probably choose to sell their vehicles before
moving. On the other hand, if there is a significant difference in
the cost of vehicles within the OTR, people moving into the OTR may
be encouraged to keep their vehicles. Neither of these effects is
quantifiable with the available information.
The number of non-LEV vehicles in the OTR in future years will
depend not only on the annual rate of immigration of these vehicles
into the OTR, but also on the rate at which these vehicles are
scrapped and the rate at which they migrate back out of the OTR. To
account for these factors, we constructed a simple model which
estimates the percentage of immigrant vehicles for each model year
in the fleet in any calendar year. The model uses the motor vehicle
age distribution in MOBILE5a, which accounts for motor vehicle
scrappage, as the basis for this calculation. The MOBILE5a motor
vehicle age distribution is simply a table which indicates what
percentage of vehicles in the fleet in a given calendar year are the
current model year, one year old, two years old, etc. up to 25 years
old. Motor vehicle scrappage is reflected in the table by the fact
that the percentage of vehicles in the fleet decreases with age.
The model for determining the percentage of non-LEV vehicles in
the OTR fleet works as follows:
1. The MOBILE5a age distribution is used to determine the number
of vehicles of each of the past 25 model years in the fleet in any
calendar year.
2. The annual migration rate (1.03%) is used to determine how
many of those vehicles in each model year migrated in to the OTR in
the past year. This number is subtracted from the total number of
vehicles in each model year to determine how many vehicles in each
model year did not migrate in the past year.
3. The annual migration rate (1.03%) is then applied to the
number of vehicles that did not migrate in the past year to
determine how many of those vehicles migrated in between one and two
years ago. However, these vehicles have also had a year in which
they could have migrated back out of the OTR, so the number of
vehicles migrating in is adjusted by the out migration rate (i.e.,
1.98% of the vehicles that migrated in between one and two years ago
are assumed to have migrated back out of the OTR).
4. This process is repeated to estimate the vehicles that
migrated in between two and three years ago, between three and four
years ago, etc., all the way to the number of vehicles that migrated
in between 24 and 25 years ago for each applicable model year. Since
the out migration rate is an annual rate, the number of vehicles
that migrated in any one year period is adjusted to reflect the
number of years these vehicles could have migrated back out since
that year (i.e., of the vehicles that migrated in between two and
three years ago, 1.98% would have migrated back out between one and
two years ago and another 1.98% would have migrated back out in the
past year). Because this process incorporates the in migration rate,
the out migration rate, and scrappage (as reflected in the age
distribution of the fleet), the result is a table that estimates the
number of vehicles remaining in the OTR fleet (after out migration
and scrappage) that migrated in each year over a 25 year period.
5. The numbers of immigrant vehicles that migrated in each year
over a 25 year period and still remain in the fleet can then be
summed to estimate the total number of immigrant vehicles remaining
in the fleet. Using the MOBILE5a age distribution, and the in and
out migration rates calculated from the IRS data, we estimate that,
in one calendar year, the number of vehicles in the OTR that were
originally sold outside the OTR represents 7.25% of the OTR fleet.
This analysis does not reflect the likelihood that annual
migration rates into and out of the OTR will change over time, nor
does it reflect the potential for changes in the vehicle age
distribution over time. Increases in immigration rates (and/or
decreases in out migration rates) will tend to increase the number
of immigrant vehicles in the OTR. The effect of changes in vehicle
age distribution are less obvious. In the absence of more
information, we have chosen to assume that these factors stay
constant over time.
Calculation of the Emission Effects of Permanent Migration
The emission effects due to the permanent migration of vehicles
from outside the OTR were calculated by combining the emission
factors of the immigrant and native fleets assuming that the
immigrant vehicles make up 7.25% of the total fleet. For the OTC LEV
cases, the immigrant fleet emission factors were calculated assuming
Tier 1 standards (85% with enhanced I/M, 15% with no I/M) while the
native fleet emission factors were calculated assuming the OTC LEV
programs as described above, including the separate programs in New
York and Massachusetts (again assuming 85% with enhanced I/M, 15%
with no I/M). For the National Alternative Scenario case, the
immigrant fleet emission factors were calculated assuming full
implementation of the LEV standard beginning in 2001 (with no phase-
in or TLEV standards prior to that model year), while the native
fleet emission factors were calculated assuming the TLEV standards
starting in 1997, and LEV standards phasing in beginning in 1999, as
described above. Both the immigrant and native fleets were assumed
to be subjected to a mix of 85% enhanced I/M and 15% no I/M.
The results of the analysis of the permanent migration effects
are given in Table 2 below. Permanent migration has a smaller effect
on the National Alternative Scenario than it does on the OTC LEV
cases, which results in a closing of the gap between these two
programs. For VOC emissions, differences between the proposals with
migration factored in are probably not significant. For NOX
emissions, the OTC LEV cases have lower emissions in the early years
and higher emissions in later years, it is difficult to conclude
whether the differences are significant given the number and types
of assumptions made in this analysis.
Table 2.--Emission Estimates for Passenger Cars and Light-Duty Trucks (< 6000 lbs.) in the OTR, Accounting for
Permanent Migration by Vehicles From Outside the OTR
----------------------------------------------------------------------------------------------------------------
VOC emissions (g/mi) NOX emissions (g/mi)
-------------------------------------------------------------------------------------------
Year National National
Tier 1 OTC LEV + OTC LEV alternative Tier 1 OTC LEV + OTC LEV alternative
ZEV scenario ZEV scenario
----------------------------------------------------------------------------------------------------------------
1990................ 4.33 4.33 4.33 4.33 1.88 1.88 1.88 1.88
1996................ 1.56 1.56 1.56 1.56 1.56 1.56 1.56 1.56
1999................ 1.26 1.26 1.26 1.25 1.34 1.33 1.33 1.33
2002................ 0.92 0.88 0.88 0.88 1.17 1.11 1.12 1.12
2005................ 0.78 0.70 0.70 0.69 1.05 0.91 0.91 0.91
2007................ 0.72 0.61 0.61 0.60 0.99 0.79 0.80 0.79
2010................ 0.65 0.49 0.50 0.49 0.92 0.64 0.65 0.63
2015................ 0.60 0.41 0.42 0.41 0.87 0.51 0.52 0.50
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
VOC emissions (tons/day) NOX emissions (tons/day)
-------------------------------------------------------------------------------------------
Year National National
Tier 1 OTC LEV + OTC LEV alternative Tier 1 OTC LEV + OTC LEV alternative
ZEV scenario ZEV scenario
----------------------------------------------------------------------------------------------------------------
1990................ 4,527 4,527 4,527 4,527 1,966 1,966 1,966 1,966
1996................ 1,809 1,809 1,809 1,810 1,809 1,809 1,809 1,809
1999................ 1,536 1,531 1,531 1,527 1,627 1,619 1,619 1,623
2002................ 1,168 1,123 1,125 1,119 1,491 1,417 1,419 1,430
2005................ 1,033 923 925 920 1,396 1,200 1,203 1,210
2007................ 978 827 831 822 1,349 1,075 1,085 1,070
2010................ 918 699 706 699 1,296 904 914 896
2015................ 911 621 631 624 1,302 773 789 750
----------------------------------------------------------------------------------------------------------------
Methodology for Estimating the Amount of Temporary Travel by Motor
Vehicles From Outside the OTR
As in the case of permanent migration, there is no single
comprehensive database that allows the direct calculation of the
amount of VMT in the OTR associated with temporary visits (tourism
and business travel) by vehicles from outside the OTR. For this
analysis, we have adopted a method for estimating the amount of
temporary travel in the OTR developed by Thomas L. Darlington.\9\
This analysis relies on data from surveys conducted by the U.S.
Travel Data Center, a private organization in Washington, DC.
---------------------------------------------------------------------------
\9\Impact of Migration and Power Plant Emissions on the Benefits
of the OTC LEV Program Relative to the 49-State Alternative'', AAMA,
Thomas L. Darlington, Air Improvement Resource , Inc., October 1994.
---------------------------------------------------------------------------
In brief summary, Darlington's analysis takes the number of
person-trips to the three east coast census regions from other
census regions estimated from the travel surveys and apportions it
to the OTR based on population. The number of person-trips into the
OTR is then converted to vehicle trips, then to automobile and light
truck trips, and then to summer-time automobile and light truck
trips, all using information from the travel surveys. Trips are then
converted to miles using an estimate of average mileage per trip
from the survey data. Finally, Darlington assumes that half of that
mileage occurs within the OTR, and uses that estimate to calculate
the total numbers of miles per day in the OTR associated with
tourism and business travel from outside the OTR. As a result of
this analysis, Darlington estimates that 4.1% of VMT in the OTR is
due to vehicles traveling within the OTR from outside the OTR.
Some of the individual states within the OTR may have better
estimates of the amount of VMT associated with visitors, but the
U.S. Travel Data Center surveys seem to be the best available source
of this information for the whole region. The main weaknesses with
this approach are in the calculation of the number of person-trips
in the OTR and in the estimate of the mileage per trip in the OTR.
Because the survey data are broken down by census regions, which do
not correspond with OTR boundaries, some assumptions must be made to
calculate the number of person-trips in the OTR. Darlington's
approach was to apportion the number of person-trips in the South
Atlantic Census Region by the proportion of the Census Region's
population in the OTR. This approach is not unreasonable, but other
approaches may be possible. Similarly, for converting person trips
to miles, Darlington takes the average mileage per trip from the
survey data and assumes that half of that mileage occurs with the
OTR. Once again, this is not an unreasonable assumption, but other
assumptions may be equally valid. Until further information on this
kind of travel is obtained, we will rely on this approach to
estimate the temporary visitation rate.
Calculation of the Emission Effects of Temporary Visitation
The emission effects due to the temporary visitation of vehicles
from outside the OTR were calculated by combining the emission
factors of the tourist and native fleets assuming that the tourist
vehicles make up 4.1% of the total VMT. In all cases, the native
fleet emission factors include the effects of permanent migration,
as described above. For the OTC LEV cases, the tourist fleet
emission factors were calculated assuming Tier 1 standards, with no
I/M, while the native fleet emission factors were those calculated
assuming the OTC LEV programs as described above, including the
separate programs in New York and Massachusetts (again assuming 85%
with enhanced I/M, 15% with no I/M) and including the effects of
permanent migration. For the National Alternative Scenario case, the
tourist fleet emission factors were calculated assuming full
implementation of the LEV standard beginning in 2001 (with no phase-
in or TLEV standards prior to that model year), but with no I/M,
while the native fleet emission factors were calculated assuming the
TLEV standards starting in 1997, and LEV standards phasing in
beginning in 1999, as described above, but with a mix of 85%
enhanced I/M and 15% no I/M (and including the effects of permanent
migration).
The results of the analysis of the temporary visitation effects
(along with the permanent migration effects) are given in Table 3
below. Incorporating these effects results in substantial increases
in the emissions under all scenarios, but most of that increase is
due to the effect of differences in I/M programs between the native
and tourist fleets. In the absence of an enhanced I/M program (and
the emission credits associated with the combination of the enhanced
I/M program and California OBD), the differences between the tourist
fleet in the OTC LEV cases and the tourist fleet in the National
Alternative Scenario are much smaller, which results in a smaller
difference in the impact of tourism in these two cases. This
difference will be larger (i.e., the emissions increase due to
tourism in the OTC LEV cases will increase relative to the National
Alternative Scenario case) if some of the tourist vehicles are
assumed to be subject to an enhanced I/M program. However, the
percentage of vehicles subject to enhanced I/M outside the OTR is
small, and should have little impact on these results. Therefore,
conclusions about the relative benefits of these programs remain
unchanged from the discussion of the effects of permanent migration.
For VOC emissions, differences between the proposals with migration
factored in are probably not significant. For NOX emissions,
the OTC LEV cases have lower emissions in the early years and higher
emissions in later years, it is difficult to conclude whether the
differences are significant given the number and types of
assumptions made in this analysis.
Table 3.--Emission Estimates for Passenger Cars and Light-Duty Trucks (< 6000 lbs.) in the OTR, Accounting for
Permanent Migration and Temporary Visitation by Vehicles From Outside the OTR
----------------------------------------------------------------------------------------------------------------
VOC emissions (g/mi) NOX emissions (g/mi)
-------------------------------------------------------------------------------------------
Year National National
Tier 1 OTC LEV + OTC LEV alternative Tier 1 OTC LEV + OTC LEV alternative
ZEV scenario ZEV scenario
----------------------------------------------------------------------------------------------------------------
1990................ 4.34 4.34 4.34 4.34 1.88 1.88 1.88 1.88
1996................ 1.57 1.57 1.57 1.58 1.57 1.57 1.57 1.57
1999................ 1.28 1.28 1.28 1.27 1.35 1.34 1.34 1.34
2002................ 0.94 0.90 0.90 0.90 1.19 1.13 1.13 1.14
2005................ 0.80 0.72 0.72 0.72 1.07 0.93 0.93 0.93
2007................ 0.74 0.63 0.64 0.63 1.01 0.82 0.82 0.81
2010................ 0.67 0.52 0.53 0.52 0.94 0.67 0.68 0.66
2015................ 0.63 0.44 0.45 0.44 0.89 0.55 0.56 0.53
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
VOC emissions (tons/day) NOX emissions (tons/day)
-------------------------------------------------------------------------------------------
Year National National
Tier 1 OTC LEV + OTC LEV alternative Tier 1 OTC LEV + OTC LEV alternative
ZEV scenarios ZEV scenarios
----------------------------------------------------------------------------------------------------------------
1990................ 4,536 4,536 4,536 4,536 1,967 1,967 1,967 1,967
1996................ 1,826 1,826 1,826 1,827 1,816 1,816 1,816 1,816
1999................ 1,559 1,554 1,554 1,550 1,639 1,632 1,632 1,635
2002................ 1,151 1,148 1,150 1,143 1,508 1,436 1,438 1,448
2005................ 1,059 954 955 949 1,418 1,229 1,233 1,235
2007................ 1,007 861 866 854 1,373 1,110 1,120 1,101
2010................ 949 739 746 736 1,324 948 958 936
2015................ 945 667 677 666 1,335 827 842 798
----------------------------------------------------------------------------------------------------------------
Appendix D
Draft EPA staff report on a 49-State vehicle program's effect on
the Northeast Ozone Transport Region's boundary conditions.
Transport Benefits Associated With a 49-State Vehicle Program
EPA does not have a quantitative analysis that measures the
transport benefits to the Ozone Transport Region (OTR) from emission
reductions outside the OTR provided by a 49-State motor vehicle
program. At the request of the Ozone Transport Commission (OTC), EPA
has recently completed an analysis using the Regional Oxidant Model
(ROM) to determine the ozone effects associated with control
programs outside of the OTR. EPA modelled the impact by the year
2005 of including certain control strategies, including a .15 lbs/
mmBtu emission rate for large stationary sources of NOX
emissions and the adoption of the LEV program, throughout the
Eastern United States.
The results showed that the transport benefits to the OTR from
adopting these control strategies outside the OTR can be
significant. However, the analysis did not separate the LEV program
from the .15 lbs/mmBtu NOX stationary source program. From the
sheer magnitude of the tons of pollution taken out of the air by the
two programs, as well as the location of the large number of
NOX stationary sources in the Ohio River valley, it seems clear
that the vast majority of transport benefits seen in the ROM
analysis are the result of the .15 NOX stationary source
program. The transport benefits to the OTR associated with the LEV
program are likely to be comparatively small.
According to analyses conducted by EPA's Office of Mobile
Sources, the emission reductions associated with a LEV program are
relatively small outside of those areas where an enhanced vehicle
inspection and maintenance program is in place. Outside of the OTR,
enhanced vehicle I/M programs will be in place in Chicago/Milwaukee/
northern Indiana area, as well as areas like Houston, Texas, and
Atlanta, Georgia. These programs will likely not be in place in
Ohio, West Virginia, and other areas bordering the OTR. As a result,
the benefits of the LEV program tend to be more localized to those
areas with enhanced vehicle I/M, several hundred miles away from the
OTR.
Since the ROM analysis modelled the effects of the various
control strategies only through the year 2005, it seems likely that
whatever transport benefits there are to the OTR from a nationwide
LEV program will grow over time as the fleet turns over. However, in
the near term, the transport benefits to the OTR from a nationwide
LEV program will likely remain comparatively small.
Appendix E
Republished slides from the presentation of this information by
John Elston, Administrator, New Jersey Department of Environmental
Protection, representing the Ozone Transport Commission at the
September 30, 1994, meeting of the Subcommittee on Mobile Source
Emissions and Air Quality in the Northeast States of the Clean Air
Act Advisory Committee.
Review of Assumptions in OTC's Analysis of Latest Manufacturers'
Proposal
1. Enforcement of alternative voluntary national standards--
Enforcement remains a key issue in analysis of any proposal from the
auto manufacturers. A clear enforcement mechanism for the auto
manufacturers' proposal (which starts in 1997) has not been defined,
but the Clean Air Act does allow alternative standards to be
enforced in 2004. Two cases (1997 and 2004) have therefore been run
to show emissions under both enforcement scenarios.
2. On-Board Diagnostics--The OTC LEV program ensures that
vehicles will be equipped with the OBD-2 system available on
California LEV vehicles. The OBD-2 system is a critical and integral
component of the LEV program that provides early detection and
correction of excess and deteriorating emissions as well as
synergistic emissions reductions when coupled with other vehicle
emissions control programs such as inspection and maintenance
programs. The auto manufacturers' proposal as prepared in August
1994 included California OBD contingent on an adjustment in sulfur
levels in the nation's gasoline supply, an action that cannot be
assumed.
Very recently, representatives of the auto manufacturers have
suggested that perhaps there could be other approaches besides a
nationwide fuel supply modification. There have been suggestions
that OBD and I/M cutpoints could be raised, actions which can be
anticipated to raise emissions of motor vehicles. Thus, because the
auto manufacturers have not indicated how California OBD would
operate in their proposal to attain the full emission reductions
attainable, this analysis assumes Federal OBD.
3. Migration--The auto manufacturers have used a migration rate
into the OTR of roughly 12 percent (permanent--7%, temporary/
visitation--5%). These numbers have been generated primarily on the
basis of movement of people into the OTR, as opposed to vehicles.
Preliminary State data indicates that these numbers are probably
high, based on limited vehicle data collected by States. Ultimately
vehicle-based data is preferable to resident-based data, but it is
not readily available. Therefore, while the OTC States do not
necessarily accept the 7% and 5% estimates pending further
development of State vehicle-based data, these estimates were used
for the purpose of this analysis.
4. Power Plant Emissions--Because of the development of
stationary source NOX controls within the OTR, and the need to
come up with attainment demonstrations, the OTC acted on a plan on
September 27, 1994, which commits to a NOX budget for large
boilers, including those for utilities. Therefore, it is not
reasonable to assume that there will be increased NOX emissions
as a result of the additional electric generation resulting from
charging of electric vehicles. If there is increased electric
generation, emissions will still be controlled by virtue of the
overall budget.
5. Fuel distribution and refinery emissions--For each electric
vehicle on the road, it can be assumed that there is a gasoline-
fueled vehicle that is not, thereby eliminating the VOC emissions
related to gasoline handling at bulk terminals and gasoline
stations, and any VOC and NOX emissions related to refinery
operation within the OTR. These emissions are not included in this
analysis, thereby making the numbers reported here conservative with
respect to VOC and NOX.
6. Advanced technology--The OTC LEV program allows States to
eventually benefit from the advancement of technology for ULEVs and
ZEVs. While it is difficult to predict exactly what advances are
possible, it is clear that ULEV technology is now being developed to
respond to the LEV program. Under the OTC LEV program, the fleetwide
average is based on an assumption that in 2003, the fleet mix will
be primarily LEVs, with 10% ZEVs and the balance ULEVs. Given the
advances in ULEV technology, then an appropriate scenario to test
possible additional benefits in the future would be a switch from
LEV to ULEV technology (i.e. 90% ULEV and 10% ZEV). 2005 has been
chosen for the start of this scenario.
BILLING CODE 6560-50-P
TP24OC94.001
TP24OC94.002
BILLING CODE 6560-50-C
OTC Comparison of Emissions From OTC LEV and Automakers' Proposal (49 State)
[Tons per day in OTR]
----------------------------------------------------------------------------------------------------------------
VOC
-------------------------------------------------------------------------------
Year 49 State--2004 49 State--1997 Enhanced OTC
Tier 1 enforcement enforcement OTC LEV LEV
----------------------------------------------------------------------------------------------------------------
1999............................ 1450 1450 1439 1436 1436
2005............................ 1003 987 948 808 798
2007............................ 964 934 906 692 679
2010............................ 929 853 853 548 506
2015............................ 961 867 864 455 387
2020............................ 1005 905 901 440 349
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
NOX
-------------------------------------------------------------------------------
Year 49 State--2004 49 State--1997 Enhanced OTC
Tier 1 enforcement enforcement OTC LEV LEV
----------------------------------------------------------------------------------------------------------------
1999............................ 1568 1568 1566 1543 1543
2005............................ 1478 1448 1391 1116 1116
2007............................ 1479 1417 1366 980 970
2010............................ 1510 1393 1366 782 752
2015............................ 1599 1442 1427 632 577
2020............................ 1705 1519 1519 618 548
----------------------------------------------------------------------------------------------------------------
The automakers proposal indicates that fuel sulfur effects on California OBD operation are unresolved; Federal
OBD is therefore assumed.
All scenarios assume permanent migration of roughly 7% and visitation of roughly 5%; State vehicle data under
development indicates that these figures are probably overestimates.
Enhanced OTC LEV assumes 90% ULEVs and 10% ZEVs to reflect potential additional benefit in the future as a
result of advanced technology.
OTC LEV includes ZEV benefits.
1997 enforcement of 49 State proposal assumes that an enforcement mechanism is developed.
[FR Doc. 94-26179 Filed 10-19-94; 12:22 pm]
BILLING CODE 6560-50-P