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determine the kind of environmental control technology which must be used, they may seriously restrict the size of the facility which can be built, and they may greatly restrict number of locations in the country at which the facility may be built. Each of these restrictions can impose sizeable economic costs.

We

Example: We at Deere & Company estimate that we will have a
requirement to expand our grey iron foundry capacity by 160,000
tons of castings a year in the relatively near future.
already have a facility capable of producing this quantity of
castings, and a number of foundries the same size or larger
are currently in operation in the U.S.

(2)

If, using the best pollution control technology known today,
we were to build a facility capable of producing this amount
of castings, it would emit one-third more particulates than
would have been allowed under last year's compromise legislation
and over three times more than would have been allowed by last
(3)
year's Senate bill. Therefore, to comply with last year's

compromise legislation, only a facility one-fourth smaller
could be built. To comply with last year's Senate bill only a
facility three-tenths the size could be built.

Even such a smaller facility could be built in only a limited number of locations. To maximize whatever economies of scale the proposed legislation would still allow, terrain and atmospheric conditions would need to be optimum. To insure that present national health and welfare standards were not exceeded, the site must also have a minimum of background particulates,

(2) a bag house emission control system would be used for all process sources and would eliminate over 98% of process emissions.

(3)

This conclusion has been confirmed by technical and planning staff personnel at the U.S. EPA. The maximum 24 hour particulate concentration for such a facility would be approximately 100 ug/m3.

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4.

such as windblown dust, and a minimum of emissions from
adjoining or nearby manufacturing facilities, roads, etc.
Very few locations have all of these necessary characteristics.

The very stringent maximum emission limits imposed by the proposed non-significant deterioration amendments place an excessive and disproportionate economic burden on industry sources of particulate

emissions.

The imposition of very stringent controls on only 15% of the sources of particulates, while 85% of the particulate sources remain completely uncontrolled, imposes an unfair and disproportionate burden the controlled industry group.

Removal of the last percentages of emissions imposes a far greater burden, economically, than does removal of initial percentages. For example, building an 80,000 ton foundry with emission control equipment which removes 98.4%, rather than 96.8%, of particulates, increases the capital costs for such equipment by approximately 17% ($700,000).

Requirements that new facilities be significantly smaller than previous facilities will make it extremely difficult for new entrants in a business area to be competitive, since new facilities will not incorporate the economies of scale of existing facilities.

Requirements that new facilities be significantly smaller will result in greater energy usage, fewer production efficiencies, fewer economies of scale and more total pollution than would otherwise be the case. Three smaller facilities, equivalent in productive output to two larger ones, will emit more total pollutants than will the larger facilities because of needs for additional roads, materials handling, etc.

Requirements that new U.S. facilities be significantly smaller than facilities being built abroad will mean that these U.S. facilities will be less competitive, since they will not be able to achieve the economies of scale achievable by foreign competitors.

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Severe limits on the size of facilities which may be built in areas presently meeting national health and welfare standards will encourage industries located in high pollution areas to remodel existing facilities rather than move to cleaner areas of the country.

RECOMMENDATIONS

Considering that over 85% of particulate emissions remain uncontrolled, that national standards designed to protect public health and welfare already exist, that the limits being recommended by the Congress are two to five times more restrictive than those being recommended by the EPA itself, and that the cost of the proposed control technology, facility size constraints and location constraints imposed are extremely high, it appears that the emission limits--particularly the particulate limits-proposed in the non-significant deterioration provisions are far too restrictive.

We therefore recommend that the non-significant deterioration provisions be amended to provide that:

1.

2.

the maximum allowable emission increments established by the bill are those which have been proposed by the EPA and are contained in current EPA regulations.

a proposed facility will meet the maximum emission limits imposed by the legislation if it can be demonstrated that the facility will meet the limits under the normal atmospheric conditions which exist on 95 percent of the days of the year. Last year's compromise bill required the limits to be met under atmospheric conditions existing on all but the very worst day of the year.

Contact:

Wade Clarke

Law Department
Deere & Company
Moline, IL 61265
309/792-4954

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In October of 1975 the Engine Manufacturers Association provided
representatives of the House and Senate with a document entitled
"Heavy Duty Engine Control and Pollution Abatement." This docu-
ment summarized pertinent data regarding the differences between
light duty and heavy duty vehicles. It also summarzied historical
information regarding emission regulations for heavy duty engines.
A very important section, particularly in view of the current
energy problems, discussed the fuel penalties associated with
emission standards. Enclosed for your information are appropriate
paragraphs on this subject and Figure 2 as excerpted from our
October, 1975, report.

In October, 1976, EMA and its member firms presented testimony in
California on future emission regulations for heavy duty engines.
The data on fuel economy presented at those hearings further supports
the information shown on the attached Figure 2. The same fundamental
trends were reinforced by member firms testimony presented on
January 27, 1977, to EPA during California waiver hearings on heavy
duty engine standards and test procedures. Therefore, we offer
this information as currently representative of the trend of fuel
consumption penalties associated with low emissions standards.

We are pleased to have this opportunity to provide this information for the public record.

Cordially,

Thomasi

T. C. Young

Executive Director

TCY/jm

Encl.

EXCERPT

HEAVY DUTY ENGINE CONTROL

& POLLUTION ABATEMENT

OCTOBER, 1975

ENGINE MANUFACTURERS ASSOCIATION

Emission Control Fuel Considerations

The California Air Resources Board conducted a public hearing in April, 1975 to discuss the 1977 California gaseous emissions regulations affecting heavy duty gasoline and diesel engines. As this is the most recently compiled public information on the effect of emissions regulations on engines, pertinent aspects of this public hearing have been highlighted.

Testimony was received from the major engine manufacturers describ-
ing the trade-off to be expected in fuel economy and price to achieve
emissions levels of 25 gm/BHP-HR of CO and either 7.5 gm/BHP-HR of
HC+NO

NO

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(1.5 gm/BHP-HR of HC maximum) or 5 gm/BHP-HR sum of HC and Changes were described in terms of the 1975 California emissions levels of 30 gm/BHP-HR of CO and 10 gm/BHP-HR of NC+NO ̧

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Figure 2 summarizes the data given to the Board as a result of the
hearing. Percent increase in fuel economy and price to achieve
the hydrocarbon plus nitrogen oxide (HC+NO) emission standard,
starting from a level of 10 gm/BHP-HR.

From the data presented, it is apparent that both heavy duty diesel and heavy duty gasoline engines will suffer substantial fuel penalties if HC+NO2 emission standards are reduced below 1975 California requirement. The data shows that a standard of 7.5 gm/BHP-HR

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