-3 Volvos with three-way catalyst; Ethyl Corporation has a 30-car fleet operating using the certification cycle; a number of petroleum companies are checking consumer cars to determine if any MMT-related problems can be detected in normal use. A major problem in assessing the information provided by the automobile manufacturers that MMT could interfere with the operation of 3-way catalyst systems is an inability to obtain such advanced emission control systems to complete the test work we feel appropriate. Unless we are able to check the results in the same service with similar equipment, there is no way of verifying the data supplied. It should be pointed out that while the reluctance to distribute proprietary developments to others for test work is understandable, we have had good relations with the technical staffs of the manufacturers. Critical data has been shared with us in the past and we trust that effort will continue. 2/15/77 ATTACHMENT II CONSEQUENCES OF REMOVAL OF MMT FROM GASOLINE The use of MMT as an octane improver for unleaded gasoline is a vital part of Exxon U.S.A.'s plans to supply anticipated gasoline demand at an appropriate octane quality level. The recent re-imposition of the EPA lead phasedown has already made achievement of these plans difficult. Over the next three years, Exxon forecasts that gasoline supplies will be adequate, but that domestic refineries, including Exxon's five refineries, will have to operate at or close to maximum gasoline production levels. We also believe that major new investments in octane producing equipment (those in addition to the investments necessary to achieve the lead phasedown schedule) could not be built and brought onstream before 1980, even if started now. Therefore, if MMT were suddenly unavailable, steps would be required to compensate for the loss in octane producibility. The steps include reduced gasoline production, reduced gasoline octane quality, and increased lead levels in leaded grades. We estimate that the loss of MMT could reduce Exxon's gasoline producibility by up to 7% and we believe that the percent of lost gasoline producibility on a national basis would be comparable. If gasoline producibility is to be maintained, the loss of MMT would instead require reducing the octane quality of unleaded gasoline to a level likely to dissatisfy 25-30% of all the catalyst equipped cars built since 1975. The quality of our unleaded gasoline might be maintained by shifting high octane blend components out of leaded gasoline into unleaded. However, this would only shift the dissatisfaction from one group of customers to another. We estimate that this step would reduce the quality of the leaded grades to a level -2 that would dissatisfy almost seven (7) million of the pre-1975 cars already on the road. A third possibility is that the lead content of leaded gasoline could be increased in an effort to maintain leaded gasoline octane. This last step however is contrary to the EPA's lead phasedown objectives. Without MMT, it is unlikely that the October 1, 1979 lead limit of 0.5 g/gal can be met without a marked reduction in gasoline production and/or quality. If MMT is unavailable as an octane improvement additive beyond 1980, additional octane producing capacity would be required. By 1983 we estimate the loss of MMT would amount to 1.5 octane number on our total gasoline production. To recover this lost octane, Exxon would have to double the amount of investment currently planned to produce unleaded gasoline and to comply with EPA lead phasedown. We estimate that the cost to the refining industry could exceed $2 billion. This is in addition to the $2 to $4 billion which we forecast is already required by lead phasedown. This increased investment in octane capacity will also mean increased refinery energy consumption because of more intensive processing. We estimate that our energy requirements could increase by 1.3 barrels of crude per 100 barrels of gasoline produced for the octane required to offset the loss of MMT. Some refiners might have to install even more energy intensive steps, and increased energy requirements up to 5 barrels of crude per 100 barrels of gasoline produced are possible from some of the last increment octane investments. This increased energy consumption means increased imports of foreign crude. We estimate the loss of MMT could increase Exxon's foreign crude requirements by 3 million barrels per year. We estimate that total crude imports could increase by 30-40 -3 million barrels per year on a national basis. This increased crude requirement does not produce any additional product, rather it is consumed producing octane via refinery processing rather than with MMT. The costs of this increased octane investment and energy consumption would ultimately be borne by the gasoline consumer. Hawaiian Electric Company, Inc. STATEMENT BY HAWAIIAN ELECTRIC ON S.B.'s 95th Congress, 1st Session 252 & 253 96803 Unless S. B. 252 and S. B. 253 are modified as pro The posed below, passage of either of these bills will inevitably cause a precipitate increase of 10% to 20% per year in the cost of electricity on Oahu and provide no offsetting improvement in Air Quality. Since the cost of living in Hawaii is already among the highest in the Nation, such a cost increase may well deal a staggering blow to every facet of the economy. modifications we propose will not necessarily avoid the increase -- instead they will postpone it for a four year period during which measures can be taken to mitigate the eventual increase and during which at least $91 million dollars At of energy costs will be saved by the residents of Oahu. the end of this period, Hawaiian Electric would assure full compliance of its system with the applicable implementation plan. Our specific recommendations are given next, followed By a detailed discussion offered in support of our recommendations. Recommended changes: 1. Section 9 of S. 252 and Section 111 of S. 253 currently would allow delayed compliance for major emitters until 1 January 1979. similar manner so as to allow a compliance period |