which greatly interested me. One was your statement that you felt there was a need for greater flexibility in handling the LA type of situations. You also stated that as research continues to find that smaller and smaller quantities of pollutants in the air will have adverse health effects. Does this suggest or would you suggest that among the options this committee needs to consider is that of moving away from a policy of zero health risk standards for the entire population? In other words, ought we to consider as an option the setting of standards which will eliminate the health risk to, say, 99 percent of the population while requiring that areas like Los Angeles be surrounded by signs saying, "Beyond this point breathing may be injurious to your health"? Mr. RUCKELSHAUS. I think, let me say as far as Los Angeles is concerned, Senator Buckley, that what we want to do in Los Angeles is run out the string on attempting to come up with a most reasonable plan that we can devise that will achieve the standard in Los Angeles by 1975 or 1977. What is it we can do? We are in the process of attempting to do that now. To assess the possibility of setting milestones, assuming that the plan itself appears to be unworkable, setting milestones along the way as to what they might do to achieve the standard ultimately. That is the kind of presentation we would like to make to the committee before we would make any recommendations as to what that flexibility ought to be if in fact we need additional flexibility. The other question that you raise which is certainly fundamental is supposing in a case like Los Angeles, if you couple the zero health risk standard with the very tight time frame in which the standards must be achieved, and the achievement of the standard itself within that time frame, while there is no question but what it benefits the air, might put such a disruptive force on the community that you have all kinds of effects that when weighed against the improvement in the air seem to be more important to the community. For instance, if it were necessary, as we now assess, to remove up to 80 percent of the vehicles or reduce by 80 percent the vehicle miles traveled at certain periods in the summer in Los Angeles, what would be the health effects of that? There clearly are some health effects. If it affected a person's ability to get to the job, make enough money to buy food, feed his family, it is going to have a health effect on that individual. We can't weigh that at the present, under the present law, against what we are attempting to do. So you can get at it in one of two ways. You can permit something to be weighed against a zero health risk standard or against the necessity of protecting the public health with one standard or you can give additional flexibility in moving the timeout in which a health related standard can be achieved. As Dr. Greenfield and Dr. Finklea will undoubtedly tell you, as we get more data on the various pollutants, it is clear that it tends to drive the standard down because we find health effects at ever lower level of these pollutants and it does appear that for some pollutants there simply is no threshold above which there is no health effect. So it gets to the point of eliminating all of that pollutant from the discharge in order to satisfy a zero health risk standard. How do you deal with this problem? It is an extremely difficult problem to deal with from the point of view of how you set a standard short of a zero health risk in what things are permitted to be weighed against it. I think historically, as I view the committee's decision to set a zero health risk standard, it was based on the fact that against health in the past was weighed the phrase economic feasibility. The concept of economic feasibility has been often greatly abused in the past in that it was an excuse for doing nothing. Having been in the State agency back in the early 1960's, I was faced constantly in attempting to get compliance with the pollution standard with that phrase in the statutes. "It is too expensive, can't do it, it is not worth it. Therefore, we are not going to." In general the courts would agree with that position. The question is because the concept of economic feasibility was abused, does that mean to discard it or is there some way to avoid the abuses that occurred in the past? I think that is something the committee ought to consider. It is a very difficult problem to wrestle with. If I had any suggestions as to how you might resolve it, I would be glad to give them to you. Senator BUCKLEY. I was going to suggest, as you are in the difficult position of having to try to plan strategies, we think about the alternatives perhaps it could be helpful if you would define for us, if you can, the areas of flexibility which you feel would enable us to achieve public policy. Mr. RUCKELSHAUS. Yes. I would be happy to do that, Senator. Senator BUCKLEY. Thank you. There is one other question I would like to ask. It refers to the question I asked yesterday and again this morning. There seems to be a conflict between conclusions drawn by the EPA study and by the National Academy of Sciences as to fuel economy. I refer to this because I happen to be very much engaged in doing something about the fuel crisis. But I believe you stated yesterday that it was the EPA conclusion that the 1975 model year requirements did not have significant adverse fuel impact. Mr. RUCKELSHAUS. Over 1973. Senator BUCKLEY. The National Academy of Sciences states on page 4 of its study, and referring to the 1973 model year light-duty motor vehicles, it concludes that model year 1975 vehicles using Wankel engines or catalyst equipped spark ignition piston engines will use significantly more fuel than their 1973 counterparts. Mr. RUCKELSHAUS. The Wankel may be based on the fuel penalty associated with the Mazda rotary engine. Where they arrived at the conclusion that the catalyst equipped 1975 automobile would have a significant fuel penalty. I don't know. The basis for my answering your question yesterday was testimony at the hearings by the major automotive companies, where in fact General Motors said they thought they would get about the same fuel economy from their 1975 system as they do from their 1973 vehicles. The catalyst itself does not cause any significant fuel penalty that we have been able to discern. There was testimony by Ford and Chrysler of some minimal fuel penalty problems. But again, in response to questioning, a lot of that was answerable on the basis of the advanced engine modification they might be using or in the case of Ford, I believe it was, the lower NO, standard which they were think ing about. So on balance, it was our best assessment that it would not be any significant fuel penalty associated with meeting the 1975 standards with the catalyst equipped automobile. Senator BUCKLEY. I am not questioning your conclusion. I am again disturbed that the public record would seem to have this conflict in the conclusion. I was wondering perhaps if somebody in your agency could consult with the appropriate person that participated in the study? Mr. RUCKELSHAUS. I certainly will. I don't understand how they conclude that. We will be glad to see any analysis they have and submit it for the record of this hearing. Senator BUCKLEY. Thank you very much. I have no further question, Mr. Chairman. Senator MUSKIE. I am sure all of us would like to pursue this health question and the NO, question further. But at this point this morning we had agreed informally to give you an opportunity to make another presentation that we think is important to an understanding of this whole subject; that is, the impact of the emission controls and the cost effectiveness of alternatives. I know you have developed such a presentation. I think it would be very useful to the committee and a very important part of the record. and I suspect of interest to the public. If you are ready to present that at this time. I think maybe we should receive it and maybe tomorrow we could get into any other questions on health and NO, matters as the committee may desire. Mr. RUCKELSHAUS. Mr. Chairman, that is fine. We did have available today both Dr. Finklea and Dr. Greenfield in the event the committee felt there was any necessity to go into the CO and HC health related standard. Senator MUSKIE. I would like to do that. Would they be available again tomorrow? Mr. RUCKELSHAUS. Yes. Senator MUSKIE. I would like to get this other basic presentation today so that tomorrow we can get into whatever questions remain in any area of this subject including this one. Mr. RUCKELSILAUS. Mr. Sansom? STATEMENTS OF ROBERT SANSOM, ASSISTANT ADMINISTRATOR FOR AIR AND WATER PROGRAMS, AND GEORGE V. ALLEN, JR., DEPUTY ASSISTANT ADMINISTRATOR FOR ENFORCEMENT, ENVIRONMENTAL PROTECTION AGENCY Mr. SANSOM. Mr. Chairman, I don't have formal charts. I think there are about 100 copies in the room. Assuming everyone has a copy of the handout, what I want to review here very briefly is an analysis of the relationship between the emissions standard for the automobile and the number of air quality control regions that would meet the primary standards for the automotive related pollutants without transportation controls. The first chart which you have is a chart that summarizes the present air quality in terms of the number of air quality control regions for carbon monoxide and oxidants that are in violation of the primary standard. You can see that 29 of those are in violation of the CO standard and our best estimate based upon the State implementation plans is 26 of those 29 will be requiring transportation controls in 1975. For oxidants, the total of 54 in violation of standard, 30 of which would require transportation controls in 1975. To give you some appreciation for the magnitude of the problem, the number of people in cars involved, we see that these totals, the 30 and the 26, because some of the same regions are in violation and require transportation controls for the achievement of both the oxidant standards and carbon monoxide, it comes down to a total of 38 air quality control regions out of the 247 in the country that require some degree of transportation and the land use controls in 1975. CHART NO. 1 PRIORITY I-AIR QUALITY CONTROL REGIONS Carbon Monoxide-Total Number: 29 Requiring Transportation Controls: 261 Requiring Transportation Controls: 301 Mr. SANSOM. These air quality control regions represent 91 million people or 43 percent of the total population and about 42 percent of the total automobile population. We have provided in the past a list of the air quality control regions involved. a listing is provided in that second page. CHART NO. 2 SCOPE OF TRANSPORTATION/LAND USE CONTROL PROGRAM 38 AQCRS require additional transportation/land use controls and/or two year extensions to meet standards. These AQCRS represent: A. Approximately 91 million people or 43% of the total population B. 41 million of the country's 98 million motor vehicles (42%) C. Majority of the major cities of the country, i.e., Los Angeles, New York, Chicago, Denver, Boston, San Francisco, Philadelphia, Dallas, etc. The third chart goes to the question of the type of control of the automobile, a series of alternatives here, ranging from alternative one, which is a continuation of the 1973-74 Federal emission standards, and those standards are listed. In other words, if we didn't do anything beyond what we are doing now, and the second option is the set of standards that the Administrator has imposed on all of the States except California for 1975. This is a set of standards achievable at advanced engine mods. Mr. SANSOM. The third option of the 1975 standards, the 90 percent reduction standards, which will be achieved nationwide in 1976, with the exception of the NOx standard which is the present NO, standard. The 1976 standard is now 0.4 which the Administrator could extend for 1 year. Lastly, is the 1976 standard for HC and CO, the same as 1975, but with the 90 percent reduction for NOx? had on Federal Register Notices dated May 31, 1972; July 27, 1972; Sept. 22, 1972: Designation of AQCR's requiring transportation/land use and/or 2 year extensions is and Oct. 28, 1972. CHART NO. 3 ALTERNATIVE CONTROL STRATEGIES I. Continuation of 1973/74 Federal Emission Standards: 30 gpm CO; 2.8 gpm HC; 3.1 gpm NO、 II. Controls achieveable by Advanced Engine Modifications 15 gpm CO; 1.5 gpm HC; 3.7 gpm NOx III. 1975 Standards as achieved by Oxidation Catalyst with replacement 3.4 gpm CO; .41 gpm HC; 3.1 gpm NOx IV. 1976 Standards achieved with Questor System in 1976 and later models 3.4 gpm CO; .41 gpm HC; .4 gpm NOx Mr. SANSOM. The next chart summarizes the fact that these varying degrees of control on the 26 air quality control regions that require transportation controls in 1975. From that chart you can see that if you stuck with the 1973-1974 standards that even in 1985, 21 of the 26 air quality control regions would still need transportation controls if they were to meet the primary standards. As an increased stringency of control, the engine mod strategy, which is, you can see the number of air quality control regions needing transportation controls in 1985 drops by six. If you go further, there is an additional 12 drop as a result of the achievement of the 1975 standards, the 90 percent reduction standards for carbon monoxide. You can see the effect of increasing stringency of controls is very small in the early years. That is because of the time it takes the automobile population to turn over at those higher degrees of control. CHART NO. 4 EFFECT OF VEHICLE CONTROL STRATEGIES ON 26 REGIONS REQUIRING TRANSPORTATION CONTROLS FOR CARBON MONOXIDE NUMBER OF PRIORITY I AQCR'S EXCEEDING STANDARDS1 1 Implementation of required transportation controls and/or stationary source controls is not assumed. 2 Implementation of 1976 standards yields similar results. The next chart is the oxidant chart. The same analysis and again you see, and in this case, there are 30 air quality control regions in 1975 that require transportation controls and you can see if you continue with the 1973-1974 standards, 17 of those will still require transportation controls in 1985 and you can see with increasing to the engine mod levels of control that 13 would still require transportation controls, while 17 would not, and then as you go further, into the 1975 HC standard, only 10 out of the 30 would require transportation controls in 1985. Twenty would not. Let me qualify this in a couple of ways. Even in the case of those air quality control regions requiring transportation controls with these varying degrees of control, the stringency of the control would be less as you have the increased degree of control, if you will follow me. |