OAR Box 1846 

Prepped by Ollie Stewart 

Document Number: 

14) ll-C-2 

Docket Number: 

A-90-07 

Printed 11/18/2008 7:30:14 AM Sheet 14 of 93 

P.1 
P.2 

/4-90-O7 

TL-C-Z 

| r*mft 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

%.^---^-^J WASHINGTON, D.C. 20460 

OCT I 7 1989 

OFFICE OP 

PESTICIDES ANO TOXIC SUBSTANCES 

fe fi UL t Karen E. Rasmussen 

Director, Governmental & Industry Affairs i V 

Calif ornia Trucking Association JW 2 ^ ^ . 

1251 Beacon Boulevard J< 

West Sacramento, California 95691 •«>, 

Dear Ms. Rasmussen: 

On July 19, 1989, the Environmental Protection Agency (EPA) 

received a citizens petition under section 21 of the Toxic 

Substances Control Act (TSCA), which you submitted on behalf of 

your organization and five other petitioners. In the petition 

you requested that EPA promulgate a rule under section 4 of TSCA 

to require testing of methanol fuels by their manufacturers 

and/or processors. These fuels include methanol and blends of 

methanol and gasoline, in particular the blend composed, of 85% 

methanol and 15% gasoline referred to as "MSS." Your petition 

identified a number of areas where you believe further research 

is necessary. 

As you reflect in your petition, EPA has already been 

reviewing the need to conduct further research on the use of 

methanol fuels and has worked with a number of different 

organizations. EPA's review of methanol fuels has been part of a 

more extensive effort in which EPA has been examining the data 

needs for all alternative fuels as well as those for existing 

fuels. 

In response to your petition and in connection with EPA's 

ongoing review of testing needs for motor vehicle fuels, I am 

pleased to inform you that EPA will shortly commence a proceeding 

under the joint authority of section 211 of the Clean Air Act 

(CAA) and section 4 of TSCA to determine which testing is 

necessary concerning health and environmental effects of all 

motor vehicle fuels—including those currently in use, such as 

gasoline and diesel, and those undergoing development as 

alternative fuels, such as methanol; ethanol, compressed natural 

gas, and propane. EPA believes that such action is prudent at 

this time, although this should not be misunderstood to indicate 

that EPA has special concerns for any particular motor vehicle 

fuel in comparison to others. 
P.3 

EPA's proceeding will include consideration of ongoing and 

planned research by EPA's Office of Research and Development, as 

well as others such as the Health Effects Institute. EPA 

believes that its review of motor vehicle fuels testing needs 

must be comprehensive and must examine which mechanisms are most 

appropriate to obtain needed test data. Accordingly, during this 

proceeding, EPA will consider the use of section 211 of the CAA, 

which specifically addresses motor vehicle fuels and gives EPA 

authority to require registration of fuels and fuel additives and 

to require testing of the fuels by the registrants, the use of 

section 4 of TSCA, and the use of alternatives such as voluntary 

industry testing and government funded research. Any resulting 

testing program may include use of some or all of these 

mechanisms. 

I hope your organization and the other five petitioners will 

avail themselves of the opportunity to participate in this 

proceeding and help EPA determine what is the best testing 

program for all motor vehicle fuels. 

Sincerely, 

^pJaJ^Akrbr <jfou 

Linda J.^Fisher 

Assistant Administrator