June 22, 1973
Page 20870
THE ENVIRONMENTAL QUALITY LABORATORY
Mr. MUSKIE. Mr. President, the Environmental Quality Laboratory of the California Institute of Technology has issued a report which describes a "management standards" approach for achieving drastic reductions in the number of "smoggy" days in the South Coast Air Basin of California by the end of 1977. In order to illustrate the kinds of control measures that are required if the management air quality standards are to be satisfied, the laboratory chose one particular control strategy for detailed study. This strategy, called EQL strategy No. 1, is based on new "technical" control measures on stationary sources and used motor vehicles, combined with a set of social and economic incentives and disincentives designed to encourage the shift to low- pollution motor vehicles, to encourage the use of multiple-occupancy vehicles – buses, car pools, and so forth – and to halt or at least reduce the annual rate of increase in gasoline consumption in the basin. If EQL Strategy No. 1 is followed, they estimated that the average number of days per year on which the California ambient air quality standard on photochemical oxidants is violated would be reduced from 241 days in 1970 to 50 days by the end of 1975, and to 25 days by the end of 1977.
I call my colleagues' attention to this interesting and innovative approach to improving air quality. I ask unanimous consent that a summary of that study and a statement to the Environmental Protection Agency by Prof. Luster Lees of the Environmental Quality Laboratory be printed in the RECORD.
There being no objection, the material was ordered to be printed in the RECORD, as follows:
PART I: EQL STRATEGY NO. 1 – A SUMMARY
PART 1: SUMMARY
(Figures mentioned in text not printed in RECORD)
In 1970, 25 years after California enacted its first air pollution control law, Los Angeles County still had air that did not meet state air quality standards for photochemical oxidants (such as ozone) on 65% of the days; for carbon monoxide on 55% of the days, and for nitrogen dioxide on 31 % of the days. Clean air was three decades behind us, and state and local enforcement agencies estimated that it was two decades ahead – in 1990. The federal government said otherwise. With the enactment of the Clean Air Amendments of 1970 the timetable for clean air was moved ahead to 1975 – or 1977, at the latest.
The California strategy, on one hand, and federal requirements, on the other, seemed to represent two extremes. One was so slow that the time when economic and population growth would overtake control measures could be readily predicted. This would happen sometime in the middle of the 1980's. The other was so rapid that only a sudden and wrenching curtailment of transportation and economic activity could produce the required results. In the latter case, the cure might be worse than the disease.
An interdisciplinary team of researchers at the Environmental Quality Laboratory concluded that for air basins with critical air pollution problems – like that of Los Angeles and surrounding areas – compromise was needed. The team put together a strategy that seemed practical and – when added to pollution control measures presently in effect or planned – would reduce the number of substandard, smoggy days 80% by 1975 and 96% by 1977.
EQL Strategy #1 – so designated since it was only one of many possible combinations – would introduce several novel features to air pollution control. It would focus on the millions of motor vehicles presently on the road instead of relying, as has been the case heretofore, only on increasingly stringent control of new cars. Engine and evaporation emissions from the existing stock of cars would be reduced by a number of practical means: changing the fuel from gasoline to the cleaner-burning natural gas or propane; retrofit devices and engine modification; mandatory inspection and testing of vehicle emissions. Somewhat more radical were socio- economics policies that would reduce use of motor vehicles significantly and thus, for the first time, test the motorist's determination to reduce air pollution by asking of him a personal sacrifice of a measure of his freedom in deciding where, when, and how he would use his car.
Stationary sources would be recognized as significant causes of pollution in the Basin and efforts to make further emission reductions at power plants, industry, and even service stations, would be redoubled.
The cost of such a program is not small – about $1 billion for those technical measures to which a dollar value can be attached. That's about $100 a head for everyone in the South Coast Air Basin, or, looked at another way, it's less than 35 miles of a new freeway in Los Angeles.
I/1 NEED FOR A NEW AIR POLLUTION CONTROL STRATEGY IN THE SOUTH COAST AIR BASIN
Twenty five years ago the California State Legislature passed its first air pollution legislation. During the last quarter-century California has come to be recognized as a world leader in air pollution control. Yet in 1970 the California state ambient air quality standard on photochemical oxidants (including ozone), chosen so that it lies "below that (level) associated with aggravation of respiratory diseases," was violated on 241 days in the South Coast Air Basin. In that same year the standard on nitrogen dioxide was exceeded on 115 days and the standard on carbon monoxide (12 hour average) was violated on 203 days.
Without the air pollution control measures on stationary sources and new motor vehicles now in effect the situation would be even worse. But if the State and local control program in effect in 1971 were to be followed for the rest of this decade, it would lead at best to a relatively slow improvement in air quality in this Basin. For example, it is estimated that the California standard on oxidants would still be violated on 140 days in 1975 and on 85 days in 1980. The two principal reasons for this slow progress are: (1) the low "death rate" of dirty old cars and the low "birth rate" of new motor vehicles that meet stringent exhaust emission and evaporative control standards; (2) the increase in gasoline consumption at a rate of about 4% per year. The EQL is certainly not the only group to conclude that a new air pollution control strategy that would deal effectively with these two problems is urgently needed (Section II/1.1.).
While the EQL study of the "smog" problem was in progress, the federal government began to exert pressure for a much faster rate of improvement in air quality than the 1971 State and local strategy could possibly provide (Section II/1.2). On April 30, 1971, the Administrator of the Environmental Protection Agency, acting under the provisions of the Federal Clean Air Act of 1970 (as amended), published new federal air quality standards that are even more stringent than
the California standards. Except for the standard on nitrogen dioxide, the federal standards are not to be exceeded more than once a year. These standards must be attained within three years of the date of final approval of the state plan, except that an extension of up to two years may be granted by the Administrator.
Thus, the South Coast Air Basin is required to meet the new federal ambient air quality standards by 1975, except in the case of photochemical oxidants, for which the EPA granted a two-year extension.
If the state agencies do not prepare a satisfactory implementation plan, the Act empowers the Administrator of EPA to develop such a plan, and if the states do not have the authority to carry out the plan, the Act has given broad authority to the Administrator. Even if the Administrator does not act, private citizens and groups can sue under the Act to force compliance with federal ambient air quality standards.
In contrast to these new federal requirements the Los Angeles County Air Pollution Control District stated in its 1971 annual report that the present strategy would bring air quality up to the California state standards by 1990.
Thus, the present California control program places "clean air" so far in the future that any improvements in air quality might well be overtaken by population and economic growth long before the distant "target date" is reached. But to reduce violations of air quality standards from the present level of 241 days per year for photochemical oxidants (for example) to literally one day per year within the period allowed by the Clean Air Act would require drastic curtailments in the rates of consumption of gasoline, natural gas and residual oil in the Basin, and a sudden brake on economic activity. The most effective practical approach must lie somewhere in between these two extremes.
The approach adopted in this report occupies this "middle ground." We recognize that the South Coast Air Basin in California is faced with a uniquely difficult air pollution control problem.
Because of its special meteorology and topography, and the enormous rate of consumption of fossil fuels, even the best technology likely to be available in this decade would not reduce the average number of days per year on which State air quality standards on photochemical oxidants are violated below a lower bound of 10-15 days. We chose for detailed study a particular control strategy (called EQL Strategy # 1) designed to drive toward these lower limits as rapidly as feasible in the spirit (if not the letter) of the Clean Air Act of 1970 (as amended) . In summary, EQL Strategy # 1 is based partly on new "technical" control measures to reduce emissions from stationary sources and used motor vehicles. But even in the short run (1972–1977) we found it necessary to combine these technical measures with a set of social and economic incentives and disincentives designed to encourage the shift to low-pollution motor vehicles, to encourage the use of multiple-occupancy vehicles (buses, car pools, etc.), and to reduce the annual rate of increase in gasoline consumption in the Basin. These control measures are not supposed to be all-inclusive, and the "mix" is not optimized for minimum cost to achieve a given level of air quality. But they are representative of the kind of measures that are required.
I/2.1 GENERAL FEATURES
The EQL strategy depends on the concept of "management standards," based on technical, economic and social feasibility, that would serve as milestones enroute to the clean air required by both the California and federal ambient air quality standards. These management standards would set a first "target date," by which time significant percentage reductions are to be achieved in the number of days per year that ambient air quality standards are violated in the Basin. By the second "target date" substantial percentage reductions would have to be made in the remaining number of these "objectionable" days, etc. This approach provides the flexibility required, and allows for "feedback" from the public as it assesses the beneficial effects of specific control measures, measured against the economic and social costs of these measures.
The Clean Air Act of 1970 (as amended) appears to give the Administrator of the EPA discretionary authority to approve such an approach by a state during the period in which a time extension is in effect. Such extensions can be granted when (among other reasons) the necessary technology is unavailable; when the state has implemented reasonable alternatives (as would be the case if a strategy similar to EQL Strategy #1 were adopted); when reasonable interim measures are provided for (the basis of the EQL strategy). EPA regulations published in the Federal Register on August 14, 1971 encourage each state "to consider the socio-economic impact and the relative costs and benefits" of alternative strategies. Public welfare and productive capacity are to be weighed as well as public health.
Before discussing specific control measures contained in EQL Strategy #1, certain desirable main features of any such strategy are outlined as follows:
1. In order to be credible the "target dates" for the achievement of management standards ought to be set well within the present decade and not in the vague future one or two decades hence.
December 31, 1975 is a reasonable first target date (corresponding roughly to the end of the 3-year period allowed under the Clean Air Act), and December 31, 1977 is a reasonable second target date (corresponding to the end of the 2-year extension period).
2. These management standards should be expressed in terms of percentage reductions in the average number of days per year on which the California (or federal) standards on oxidants, nitrogen dioxide and carbon monoxide are exceeded. For example, a reasonable goal is to reduce these "objectionable" days in the South Coast Air Basin from the 1970 level of 241 per year to a level of 50 days per year by the end of 1975 (a reduction of 80%). By the second target date, at the end of 1977, the objectionable days should be reduced to 25 (an additional reduction of 50%).
3. Because of the relatively short time periods involved, the "technical" control measures required to reach these management standards will have to be based mainly on existing technology that can be developed and introduced within the next 2-4 years.
4. Any strategy must rely on a number of different control measures, each of which provides a modest improvement. It is the cumulative effect which is significant. There is no one "magic solution."
One such strategy (EQL Strategy #1) is described in the next sub-section. The control measures that are proposed are not supposed to be all-inclusive, nor are control costs supposed to be minimized. Our purpose is to illustrate the kinds of measures that must be taken if the requirements listed above are to be met. In most of the discussion to follow we are making the "conservative" assumption that new motor vehicles for model years beyond 1974 will meet the 1974 California exhaust emissions standards, but not the more stringent 1975-76 federal standards. Some of the figures to be presented in Part II will show the additional benefits to be gained (at additional cost!) if new motor vehicles do in fact meet the federal standards beginning in 1975.
I/2.2 SPECIFIC CONTROL MEASURES
The nature and extent of the specific control measures that are needed depend on the magnitude of the reductions in emissions of reactive hydrocarbons and nitrogen oxides that are required in order to meet the management air quality standards set forth in EQL Strategy #1. At present no general theory exists that would enable us to predict ambient air quality for photochemical oxidants, nitrogen dioxide and carbon monoxide in terms of the emissions level of the primary contaminants. In lieu of such a theory, the relationship between air quality and emissions levels is here established by means of a statistical analysis of air quality monitoring data obtained at the ground-level stations of the Los Angeles Air Pollution Control District over the last several years. An important simplifying physical assumption is made that for given meteorological conditions the atmospheric concentrations of carbon monoxide and the "early morning" concentrations of reactive hydrocarbons and nitrogen oxides are directly proportional to their respective emissions levels.
The application of this simple idea to the statistical data is best illustrated by dealing first with the contaminant nitrogen dioxide, which tends to be approximately proportional to the total input of nitrogen oxides. Statistical data is displayed in terms of the average number of days per year that the maximum atmospheric concentration exceeds a given level for at least one hour, plotted against the concentration (Figure 1). (The solid curve in Figure 1 corresponds to the 1969 average of about 1000 tons per day of nitrogen oxides emissions in the Basin.) As expected, "low" one-hour maximum concentrations of nitrogen dioxide around 10 pphm are exceeded quite frequently, but "high" concentrations around 50 pphm are rarely exceeded at this emissions level.
These observations correspond roughly to the relatively high frequency of occurrence of maximum mixing layer heights (or heights of the base of the infamous inversion layer) that are 3500 feet or less, compared to the infrequent appearance of maximum mixing layer heights that are 700 feet, or less. These relatively infrequent low inversion layers markedly concentrate the pollutants near the ground.
Suppose that by means of a set of control measures the level of emission of nitrogen oxides in the Basin is reduced by 50% to 500 tons per day. For the same meteorological conditions, atmospheric concentrations of nitrogen dioxide are also cut in half (dashed curve in Figure 1). In other words, if emissions are reduced by 50%, the simple rule to follow is that the number of days per year on which a particular maximum one-hour concentration of nitrogen dioxide is exceeded is the same as the number of days per year on which twice this concentration was exceeded at twice the emission level (horizontal dashed line in Figure 1). By following this rule, we see that at the new emissions level, a concentration of 25 pphm for one hour (California state standard) is exceeded on the same number of days per year as a concentration of 50 pphm was exceeded at the old emissions level. A 50% reduction in emissions level leads to a 90-95% reduction in days per year of violations of the state standard (vertical dashed line in Figure 1).
The situation for photochemical oxidants is more complicated than for nitrogen dioxide because the peak one-hour oxidant level depends on "early-morning" concentrations of reactive hydrocarbons and nitrogen oxides, on sunlight intensity, temperature and other variables in a complex manner. In spite of this difficulty, by using the Los Angeles APCD data Trijonis was able to work out "summer" and "winter" correlations between daily one-hour average oxidant level and "early morning" concentrations of reactive hydrocarbons and nitrogen oxides. The effect of reductions in emissions levels on the concentrations of these two substances is calculated just as nitrogen dioxide was analyzed in the simple illustrative example given earlier.
Our calculations show that in order to reduce from 241 to 50 the average number of days per year on which the maximum daily one-hour average oxidant concentration of 0.10 ppm is exceeded (fast "target" on EQL Strategy #1) the total emissions of reactive hydrocarbons from all sources in the Basin must be reduced to 28% of present levels, and emissions of nitrogen oxides must be reduced to about 45% of present levels. If these reductions were made, the California ambient air quality standards for nitrogen dioxide of 25 pphm for one hour would be exceeded on 10 days per year as compared with 130 days in 1970. The "health warning" 15 level of a one-hour average oxidant concentration of 0.20 ppm (twice the State standard) for persons with coronary artery diseases or chronic respiratory diseases would be exceeded on 15 days per year, as compared with 150 days per year in 1970.
Thus, Phase 1 of EQL Strategy #1 is designed to reduce total emissions of reactive hydrocarbons to 28% of present levels and nitrogen oxide emissions to 45%, of present levels by December 31, 1975.
These objectives would be accomplished by means of the following Phase I control measures, combined with the effects of the new cars introduced into the Basin.
A. MOTOR VEHICLES
1. Mandatory conversion of all gasoline-burning commercial motor vehicles of model years 1970 and later in both small and large fleets (trucks, taxis, buses, cars) to burn a gaseous fuel, such as compressed natural gas or liquid propane gas, by December 31, 1973, in the South Coast Air Basin. This measure means that about 33% of the gasoline now burned in the Basin would be replaced by gaseous fuels.
2. (a) Mandatory installation on 1960-1965 gasoline-powered cars of a currently available control device that reduces hydrocarbon emissions by about 60% and NOx emissions by about 35% on pre-1966 cars.
(b) Mandatory installation on 1966-1970 gasoline-powered cars of a control device that reduces nitrogen oxides emissions by a substantial amount.
3. Mandatory installation of an evaporative control device on gasoline-powered 1966-1969 vehicles that reduces fuel tank evaporative emissions by 90%. (Starting with the 1970 models new cars have such controls.) Since this device is estimated to cost approximately $150 to purchase and install, some subsidy or cost-sharing would be required. (Less expensive retrofit devices are currently under study at the EQL.) If such a subsidy were to be paid to vehicle owners for installation of this device, an equal subsidy ought to be made available to vehicle owners who elect any other step that would reduce reactive hydrocarbon emission in the Basin by a comparable amount. Example: purchase of a post-1969 vehicle to replace an older vehicle that is sold to a new owner who lives and works outside the Basin.
4. A mandatory vehicle emissions inspection system that would: (1) insure that new and used gasoline-powered vehicles meet the emissions standards set for them by present and proposed control measures; (2) insure that vehicles operating on gaseous fuels are properly tuned to achieve the low exhaust emissions levels qualifying them for the 7 cents/gallon (equivalent) State fuel tax remission; (3) form the basis for a system of emission taxes.
5. Social and economic incentives and disincentives designed to encourage the shift to low-pollution motor vehicles by motorists and vehicle manufacturers, to encourage the use of multiple-occupancy vehicles, and to halt or at least reduce the annual rate of increase in gasoline consumption. Such measures include: (1) emissions taxes assessed on car owners in proportion to the amount of emissions their cars discharge into the air; (2) reserved "fast lanes" on freeways for buses and carpools; (3) controlled access to freeways so that buses and carpools are given priority during rush hours; (4) free or subsidized parking for carpoolers; (5) buses and demand- jitneys partially subsidized by revenues collected from emissions taxes; (6) as a last resort, additional gasoline taxes and/or a limit on the total consumption of gasoline in the Basin at 2.7 billion gallons per year by a system of freely auctioned coupons, giving motorists in the Basin gasoline purchase rights up to this total amount, but no more.
In our calculations we assumed that by December 31, 1975, the combined effect of all the measures under #5 amounts to a 20% reduction in the motor vehicle pollution remaining after measures #1-4 are put into practice.
B. STATIONARY SOURCES
1. Nitrogen Oxides. Mandatory installation of two-stage combustion and/or gas recirculation (or other control devices) designed to cut NOx emissions by 50% by the end of 1973 in all fossil-fuel power plants. Mandatory use of low "excess" air in industrial boilers and heaters using natural gas with a rating in excess of 30 million BTU/hour (about 8.5 megawatts).
2. Hydrocarbons. (a) Substitution of nonreactive materials by users of organic solvents emitting "high reactivity" HC (as defined by the Los Angeles APCD) in order to cut these emissions by 50% by 1973. (b) Mandatory recirculation of vapors from gasoline storage tanks in filling stations back to tanker trucks during filling operations.
C. PHASE TWO
Phase 2 of EQL Strategy #1 consists of a limited number of "smog alerts" to be called in the Basin during the period July through September when the oxidant exceeds 0.20 ppm at any station in the Basin, or when early morning inversion layer height and temperature indicate a high probability that this level will be exceeded . Beginning in 1973 two or three such alerts would be called, and by 1975 the number of such alerts would be increased to 6-8.
Although we do not attribute any specific reduction in the number of "objectionable" days to Phase 2, it seems clear that the two phases of EQL Strategy #1 are mutually reenforcing.
Incentives for reducing emissions are created by calling smog alerts that shut down or curtail emission sources while reductions in emissions require fewer smog alerts. If our target of about 15 days per year for an oxidant level of 0.20 ppm is reached by the end of 1975, these smog alerts could be discontinued.
1. During these smog alerts only "low emission" vehicles, vehicles with two or more passengers, and buses and jitneys would be permitted on the freeways.
2. During an alert all stationary sources of "high reactivity" HC emissions would be shut down.
Rough estimates indicate that the cost of Phase 1 of EQL Strategy #1 for the South, Coast Air Basin is about one billion dollars through December 31, 1975, which amounts to about $100 per head, or $300 per household ($25 per head per year or $75 per household per year). The cost breakdown is as follows: (1) loss of federal and State tax revenues by conversion to gaseous fuels – $400 million; (2) Vacuum Spark Advance Disconnect – $70 0 million; (3) evaporative control retrofit – $225 million; (4) mandatory motor vehicle inspection program – $200 million; (5) controls for stationary sources – $100 million.
By the second target date of December 31, 1977, EQL Strategy #1 calls for no more than 25 days per year on which the California ambient air quality standards for oxidants is violated in the Basin. Our calculations show that in order to achieve this objective the total emissions of reactive hydrocarbons in the Basin must be reduced by about 22% of present levels and nitrogen oxides emissions must be reduced to about 38% of present levels. If the Phase I control measures are successful in reaching their targets by the end of 1975, it turns out that the additional reductions in total emissions that are required by the end of 1977 could be achieved by means of two specific control measures: (1) continued conversion of gasoline-burning commercial vehicles to burn a gaseous fuel, as long as emissions from new vehicles are significantly higher than emissions from gaseous-fueled vehicles (maintaining the level of one-third of the gasoline replaced by gaseous fuels at all times); (2) continuation of mandatory vehicle emissions inspection program (A.4 of Phase 1). The social and economic incentives and disincentives listed under A.5 of Phase I would almost certainly be necessary in the long run (Section I/3I), but no additional reductions in emissions after 1975 are attributed to these measures in the present "conservative" calculations. The additional cost of this program from the end of 1975 to the end of 1977 is estimated at about $300 million. (The total cost of the emission controls for new cars for 1976 and 1977 is estimated at about $300 million in this Basin.)
In Section II/2 of this report the reductions in emissions from motor vehicles and stationary sources that can be achieved by each of the control measures in EQL Strategy # 1 are discussed in detail. In Figure 3 and 4 we show the breakdown in reductions in reactive automotive hydrocarbons and nitrogen oxide emissions for L.A. County. Figures 5 and 6 show the contribution from stationary sources and the reductions in total reactive automotive hydrocarbons and nitrogen oxide emissions. Based on these reductions the projected improvement in ambient air quality for photochemical oxidant and nitrogen dioxide are calculated by methods already outlined and described in detail in Section II/2.2. In Figures 7 and 8 the results of these calculations are illustrated for the "present strategy" (1971) and for EQL Strategy #1. Figure 9 shows the projected reductions in the number of "health warning" days (proposed by the Los Angeles County Medical Association for persons suffering from coronary artery diseases or chronic respiratory diseases).
Control measures A.1 and A.5 on motor vehicles will also greatly reduce carbon monoxide emissions into the atmosphere of the Basin, as shown in Figure 10. In Figure 11 we show the corresponding projected improvements in ambient air quality for carbon monoxide according to the "present strategy" and EQL Strategy #1. By 1977 EQL Strategy # 1 would virtually eliminate the carbon monoxide problem in L.A. County.
In Sections II/3 and II/4 the feasibility of the "technical" control measures A.1-A.4 and B.1 and 2 for motor vehicles and stationary sources is examined. By feasibility we mean supply, distribution and marketing of gaseous fuels; economics of conversion to gaseous fuels; safety, insurance and reliability of gaseous-fueled motor vehicles; economics and performance of "retrofit" devices on used cars; availability and performance of control devices for stationary sources. No important technical or economic difficulties were uncovered in this study. However, a considerable amount of "risk capital" and organizational effort is required to put these
control measures into effect on the time schedule adopted in EQL Strategy #1. On the other hand, the program provides some attractive opportunities for profitable business ventures and for employment of presently under-employed or unemployed skilled people in the Los Angeles area.
In Section II/3 the controversial question of the conversion of commercial motor vehicles to burn a gaseous fuel is discussed in some detail. The supply problems for compressed natural gas (CNG) and propane (LPG) in this Basin were studied carefully, not only by the EQL staff but also independently by a well-known oil and gas consulting firm retained by the EQL – The Pace Company of Houston, Texas. The Pace Company report concluded that supplies of CNG and LPG are adequate to replace up to 33% of the gasoline burned in the Basin. The report recommended a "mix" of 25% CNG and 8 % LPG to make up the figure of 33 %. This amount of CNG is equivalent to 250 million cubic feet per day. In the "smoggy" summer months "firm" customer demand for natural gas is about 500 million cubic feet per day, leaving about 2.5 billion cubic feet per day for "interruptible" users (Figure 12). About 10% of the "interruptible" supply would have to be diverted from electric power plants and industrial users to motor vehicles. Such a diversion could be accomplished by means of a small price differential. In the relatively "smog-free" winter months natural gas is in short supply because of large "firm" customer demand. Thus motor vehicles converted to CNG are almost always equipped with dual-fuel systems that allow them to switch to gasoline in the winter months, or when they are outside the Basin.
If 8% of the projected gasoline consumption in the Basin is replaced by propane by 1975, the requirement for propane amounts to about 10 million barrels per year, a quantity equal to the total consumption of propane in California in 1970 (Fgure 13). However, propane supply is increasing rapidly in the 1970's. Canadian propane supplies are available, and the figure of 8% is regarded by the Pace Company as a reasonable initial target that would not place too great a strain on refineries and other sources (mainly natural gas fields).
So far as distribution of CNG is concerned commercial fleets generally would have their own fueling facility, including compressor and storage tank. Recently the Union Oil Co. and Pacific Lighting Corp. announced a cooperative pilot program whereby two service stations in Riverside, California, will sell CNG to motor vehicles. This system could be expanded rapidly to include a certain fraction of the service stations in the Basin. Propane, on the other hand, is already available at about 64 stations in the Los Angeles area, and a number of other stations now selling propane to campers could easily obtain the necessary permit to sell this fuel to motor vehicles.
This distribution system could also be expanded once the demand was established.
Similar conclusions about feasibility were reached regarding the possible rate of conversion of motor vehicles to burn a gaseous fuel. After several days of training, a good mechanic can convert one vehicle in about one working day. Thus 1000 mechanics working 250 days per year could convert the estimated 500,000 commercial fleet vehicles in the Basin in about two years.
In contrast to these technical-economic measures, the detailed effects of the social and economic measures listed under A.5 (and discussed in detail in Section II/5) are very difficult to forecast.
The whole purpose of this set of incentives and disincentives is to provide alternate modes of transportation and to influence human behavior. Lacking a predictive theory of human behavior we need to introduce demonstration or "pilot" programs in order to obtain "feedback" from the public in a reasonably short time period. In the case of the emissions tax, for example, an iterative procedure could be utilized, in which a certain reasonable tax schedule is set and the effects observed for one year, after which the schedule is revised as needed. These pilot and iterative programs are necessary first steps toward a long-range strategy for the post-1982 period.
I/3 A GLIMPSE AT THE POST 1982 PERIOD AND LONG-RANGE NEEDS
Sometimes in the early 1980's emissions of reactive hydrocarbons, nitrogen oxides and carbon monoxide into the atmosphere and the number of smoggy days in the Basin will begin to increase again, even if EQL Strategy No. 1 is fully implemented (Figure 14). The projected growth in population and in the rate of consumption of gasoline, natural gas and oil in the Basin makes this outcome inevitable if no new steps are taken. Section II/6 of this report contains a brief discussion of some possible approaches to the long term air pollution problem in the Basin, including (1) introduction of new technology, e.g., electric commuter cars, replacement of natural gas and oil-fueled industrial burners by electric-powered devices, replacement of electric power plants inside the Basin by new power plants located outside the Basin; (2) limitations on population, industry and commerce in the Basin, provision for a balanced transportation system, and important changes in life-style.
NOTE: Figures are not reprinted in RECORD.
STATEMENT TO THE ENVIRONMENTAL PROTECTION AGENCY
(By Lester Lees)
A significant milestone in the long struggle to abate smog in the Los Angeles Basin was reached with the publication of the transportation control plan by the EPA on January 15, 1973. In preparing the plan the EPA firmly established the fact that not only would no single abatement measure eliminate smog, but that even the vigorous implementation of all available measures for emission reduction would fall far short of achieving the federal ambient air quality standards. To achieve these standards would require the imposition on a vast scale of other kinds of measures which are largely untried and mostly unpredictable. In commenting on the plan today, I will concentrate on three main points. First is the need for management standards to serve as interim goals in a time-phase program to achieve the ambient air quality standards. Second is the desirability of a flexible strategy which employs several measures in addition to the technical emission reduction measures. The third is concerned with providing the time required to bring measures of the second kind into effective operation; that is, the need for a buildup period.
Finally I will comment on the cost of an effective smog abatement program. A technical commentary on the analytical technique used in preparing the plan is in an appendix submitted for the record. Also submitted for the record are four additional documents which contain the detailed reasoning on which this statement is based.
In order that we can discuss the question of air quality on a common basis, I would like to point out that the air quality standards consist of two parts. One part is a specified concentration level and averaging time; for example, the oxidant standard 0.08 ppm (federal) or 0.1 ppm (State of California) for one hour. The second part is the number of days per year that this specified level may be exceeded. In the Clean Air Act this number is more than one day per year. Air quality is best measured in terms of the average number of days per year that the specified level is exceeded (currently over 200 days per year for oxidant in this air basin).
For this discussion I will use the level of 0.1 ppm of oxidant averaged for one hour as the specified level. In order to illustrate the effect of the choice of level on the average number of days per year that a particular level is exceeded, I will also show some results for a level of 0.2 ppm of oxidant averaged over one hour.
My three main points can all be made by referring to Figue 1. The segmented bar in the center with the hatching represents the daily hydrocarbon emissions in the Basin in 1977. The various levels are those remaining after the several reduction measures shown have been applied.
The levels are quantified in two ways. The first is in terms of percentages of the total level that would exist if no reduction measures were to be imposed. The second way is in terms of the number of days the oxidant standard would be exceeded. The calculations on which this chart is based are similar to those we have discussed in detail in the SMOG book. The results shown in the upper part of the bar differ somewhat from the calculations made by the EPA because they are based on a somewhat different set of technical control measures. In addition the 0.1 ppm for one hour level was used, which is slightly higher than the federal level, and a more complex model was used to relate the level of emissions to the number of days the 0.1 ppm for one hour would be exceeded. These are important technical differences between this analysis and the one made by the EPA. The differences are discussed in detail in the appendix, and it is hoped that the discussion will be carefully considered by those charged with further analysis within the EPA.
Even more important than the differences, though, are the similarities. Both analyses show that any reasonable set of technical emission control measures will fail to achieve the ambient air quality levels (either state or federal) on something like 60 to 80 days per year. It should be emphasized that fixing on the federal rather than the state level and agreeing on a specific set of measures would still leave a great deal of uncertainty about the number of days the level would be exceeded. This uncertainty is due to two factors. The one is an inherent inability to calculate accurately the effectiveness of the measures imposed and the resulting level of emissions. The other is the variability of the weather from year to year, which greatly affects the number of days the level is exceeded for a given level of emissions.
Both of these factors act to increase the uncertainty as the number of days on which the level would be exceeded becomes smaller. This is why the scale of the number of days is not continued below 20 days. These two sources of uncertainty, plus the very high cost of the technical measures and the untried nature of the other measures, led to the idea of management standards.
Management standards are interim goals selected on the basis of reasonable predictability of effectiveness, acceptable cost, and a specific time scale. They are based on the accepted ambient air quality levels and recognize that these levels will necessarily be achieved over a period of time rather than all at once. They are not equivalent to merely extending the time allowed to achieve the final goals. They do allow for implementing other measures after the uncertainties associated with the technical measures have been dispelled and after some experience on a small scale with other measures. The best available data now suggests that a realistic goal is 60 days per year that could be achieved in 1977 by the vigorous implementation of the technical measures together with a small scale application of other measures. At that time there would be little uncertainty about the technical measures and less about the other kinds. It would then be possible to devise the next phase of the program with much more confidence and to decide whether there should be another set of interim goals.
My second major point has to do with the measures that will be required beyond the technical measures to finally achieve the ambient air quality standards. Make no mistake, I do not have a "magic" solution to this difficult problem, and I do not believe the problem can be attacked really well until after more of the effects of the technical measures are known and some experience with the other measures obtained.
For purposes of this discussion the measures other than the technical measures can be classified into three categories. First are those measures intended to reduce vehicle miles traveled. Second are those measures intended to reduce the number of vehicles in use. Third are special measures intended to reduce vehicle use on days forecast to be especially susceptible to smog. Each category has a counterpart that pertains to stationary sources. The classification scheme is admittedly crude, but it will serve to make the point. The point is that measures of all three kinds should be considered. The use of a number of measures of different kinds in a strategy has a number of desirable features.
When the Administrator considered measures to be used beyond the technical measures, he rejected all those except gasoline rationing. In his explanatory comments he elaborated on the many difficulties expected in instituting rationing to the extent envisioned, and the probable disruption to the economy of the Basin. Indeed, one is led to believe that rationing to this extent may prove to be not possible. This illustrates one of the reasons for a multiple strategy. If one of the measures proves to be infeasible or not feasible to the extent planned, there are no other measures which can be used to compensate. Specifically, if gasoline rationing does not work, then we shall need an alternative.
Another aspect of the desirability of a multiple strategy is that no one measure need be as intense as it would be if it were used alone. This is illustrated in the lower part of the chart. The numbers chosen are intended to be illustrative and are, of course, subject to the uncertainties discussed above. But, for example, if the number of vehicles in the Basin and the consumption of gasoline were limited to present levels instead of being allowed to grow at present rates, the emissions remaining after the technical measures were applied would be reduced by perhaps 16%. Then if, in addition, gasoline were rationed by 33 % (instead of 82 %) there would remain about 20 or 25 days per year on which special additional restrictions would have to be imposed. Such a mixed strategy, because the measures are less intense, would have much different effects than a single measure strategy.
It is hoped that a mixed strategy would contain more than just three measures as shown in the example. Other measures such as emissions taxes and incentives and disincentives aimed at encouraging people to use public transportation instead of automobiles should be considered.
Airport operations and goods movement need to be examined for possible reductions in emissions through reduced activity. Some of the measures considered will turn out to be infeasible to implement, others not to work in practice. Unless enough are considered right from the beginning, there may not be enough left to do the job.
A final aspect of the desirability of a multiple measure strategy has to do with adverse impacts.
Whereas the problem in setting up the mixture of technical measures has mostly to do with getting a maximum effectiveness (and acceptable cost), the problem in getting the right mix of the other measures seems to be more concerned with minimizing adverse impacts. There seems to be little doubt that sufficient gasoline rationing would reduce emissions enough. The question about rationing is whether the adverse impacts are acceptable. The sample strategy was chosen to be different to illustrate this. While a limitation on the number of vehicles would have a major impact, it would probably be different, and perhaps less, than an 82 % reduction in the gasoline available.
In the same vein, proscribing driving for 20 days would have a different impact than reducing driving by 82% for up to 180 days.
To summarize this point, the strategy to be used after the technical measures are fully exploited should be a mixed strategy with a number of measures of different kinds. In beginning to devise such a strategy no measure should be eliminated from consideration without good reasons, even though means for implementation or possible impacts may not be fully understood.
This brings me to my third major point. A great deal of work needs to be done to examine nontechnical measures. We have made a modest beginning in examining emissions taxes and measures to be used on days forecast to be especially susceptible to smog. That work is reported in the SMOG book and other documents submitted. We intend to continue. Nevertheless, we conclude that much of what needs to be learned about these measures can only be learned by experience. In some cases that may be possible by pilot programs, and, if so they should be used.
In other cases the measures will just have to be tried. Certainly a measure should not be tried unless careful study indicates that it will probably work and have an acceptable impact. Even so, it will often be prudent to start a measure at low intensity and allow a period of planned build-up.
This is also the approach that is used in technical measures to allow time for people and organizations to accommodate themselves to a new set of constraints. A good example is in a system of periodic motor vehicle inspection and mandatory maintenance where it may be necessary to initially set the standards quite loose and tighten them over a period of time to give the automotive service industry time to respend to the increase in maintenance work. That system of a gradual build-up seems equally applicable to such diverse measures as expansion of public transit and special restrictions on days forecast to be bad. It is for that reason that we suggested (in the SMOG book) the inclusion of such measures at a modest level of intensity even in the first and second phases of a phased program. A similar suggestion is included in the sample plan in the chart.
It is important to include this idea of a build-up in any kind of a plan, even one which is aimed at fully achieving the standards by 1977 and even one which relies on a single measure such as gasoline rationing. If only gasoline rationing were to be used, and I certainly would not recommend such an approach, it should be started well before 1977 to allow time to get the machinery worked out and for people to reorder their lives. A modest level of rationing as early as 1974 would be none too soon. The same comment applies to all other measures of this sort whether used alone or in a mixture. The comment also applies to bad day measures.
The question of when to apply measures to limit growth is particularly difficult. Indeed the whole question of whether or not any growth limiting measures are acceptable is one that may not be settled for a long time. I would merely note here that the most difficult year in which to control smog will be 1977. As the Administrator has pointed out, the increasing percentage of post-1974 vehicles will ease the problem considerably by the early 1980s. This indicates that an immediate, and perhaps even temporary, restriction on growth would be more helpful than a later one that came too late to prevent a large influx of pre-1975 vehicles.
Throughout this discussion so far we have accepted the California standard of 0.1 ppm of oxidant for one hour. Considerable discussion and debate has centered around the choice of a particular pollutant concentration level as a "safe" standard. However, even if the allowable level were to be doubled, Figure 24 from the SMOG book shows that all of our conclusions about the need for management standards and a time-phased approach are still valid. At present even this higher level is exceeded well over 50 days per year (in 1971, 67 days at Pasadena and 95 days at Riverside). There is very little disagreement that exposure of the population to a level as high as 02 ppm of oxidant for one hour on that many days per year is not consistent with the requirement that the "health and welfare" of our citizens must be protected. The final point to be made and which supports the three major points and the idea of a phased approach to smog abatement has to do with cost. It is completely natural that the first measures used against smog in Los Angeles were those that were simplest, most effective, and least expensive. Positive crankcase ventilation is an outstanding example of this. As the inexpensive measures are exhausted, though, each new measure adopted is more expensive than the previous one simply because the less expensive ones are adopted first. The result of this process, which is the best process that could be used, is shown in the second figure. This curve was taken from a study by Dr. Trijonis about a year ago of the costs of reducing the level of emissions below the level then projected for 1975. The curve illustrates clearly the rising costs of decreasing emissions. The total five year strategy examined in the SMOG book is estimated to cost well over one billion dollars or $100 for each person living in the South Coast Air Basin. This amount may prove to be acceptable to the people here.
Nevertheless, it must be realized that each additional step will cost much more to achieve the same amount of improvement in air quality than the previous one.