Page four 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 (2) If, using the best pollution control technology known today, compromise legislation, only a facility one-fourth smaller 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. Page five 4. such as windblown dust, and a minimum of emissions from 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. Page six 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 In October of 1975 the Engine Manufacturers Association provided In October, 1976, EMA and its member firms presented testimony in 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- NO (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 ̧ X Figure 2 summarizes the data given to the Board as a result of the 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 |