Notice of Data Availability Concerning Supplemental Rulemaking on Ozone Transport Commission; Emission Vehicle Program for the Northeast Ozone Transport Region

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 X

CYR ----------------------------------

TPD % TPD %

------------------------------------------------------------------------

1996................................. -0.3 TP24OC94.000

BILLING CODE 6560-50-C

Comparision With EPA and State Analyses

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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%*

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*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.

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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

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\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.

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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 (X 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 (X 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 (X 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]

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VOC

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Year 49 State--2004 49 State--1997 Enhanced OTC

Tier 1 enforcement enforcement OTC LEV LEV

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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

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NOX

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Year 49 State--2004 49 State--1997 Enhanced OTC

Tier 1 enforcement enforcement OTC LEV LEV

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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

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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