OAR Box 1132 

Prepped by Candice Davis 

Document Number: 

13) ll-C-9 

Docket Number: 

A-86-03 

Printed 4/18/2008 2:24:46 PM Sheet 13 of 122 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

JUN -4I9&7 

OFFICE OF 

AIR AND RADIATION 

Thomas J. Donohue 

President and Chief Executive Officer 

American Trucking Association, Inc . 

2200 Mill Road 

Alexandria, VA 22314 

Dear Mr, Donohue: 

ThanX you for expressing your views on diese l fuel sulfur 

control. Briefl y recapping the events leading up to our 

current study on sulfur control, EPA established the NOx and 

particulat e standards in March of 1985 for trucks and buses 

starting with the 3 988 model year. The sulfur issue was raised 

by several manufacturers at that time, 

controlling fuel sulfur was not a 

feasibility * however, EPA did agree to 

detai l at a late r date (for further 

10 606, March 15, 1985, and the Regulatory 

Oxides of Nitrogen Pollutant Specifi c Study 

Analysis of Comments, March, 1985). 

but EPA concluded that 

prerequisit e to trap 

stu^y the issue in more 

background, se e 50 PR 

Impact Analysis, 

and Summary and 

On June 17, 1986, a Federal Register notic e announced the 

availabilit y of a preliminary report on diese l fuel qualit y and 

i ts effects on emissions, performance, durabilit y and costs. A 

docket was opened (A-86-03) to receive comments on the report. 

We have been analyzing these comments, and in addition have 

been preparing aore detailed analyses of some of the issue s 

such as the effec t of sulfur on engine 

sulfur controls and the effec t of sulfur 

engine technology and cost. These wil l be 

to be completed near the end of this year. 

proceed with a formal rulemaking wil l be made 

of this study. 

wear, the costs of 

content on required 

compiled in a study 

A decision to 

upon completion 
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One of the more difficult aspects of this study is our 

evaluation of the types of technologies that would be used to 

meet the 1991 and 1994 heavy-duty diese l particulat e standards 

on current fuel versus a low-sulfur fuel and any resultant cost 

differential. We have requested detailed projections on this 

issue from al l of the heavy-duty engine manufacturers in our 

meetings on trap development efforts. To date , a number of 

manufacturers have submitted general statements concerning the 

effect of low sulfur fuel on potentia l compliance. However, 

littl e detailed information supported by complete test data has 

been received. Such information is critica l if EPA is to 

accurately quantify the effect of diesel fuel sulfur control on 

the heavy-duty die3el industry, and determine the industry's 

abilit y to meet the 1991 and 1994 standards with and without 

sulfur control. We are continuing to work with the 

manufacturers on this. Some recent information received from 

manufacturers indicates that substantia l numbers of engines may 

meet the 0.25 g/BHP-hr particulat e standard without traps and 

without sulfur control. 

In summary, we are pushing ahead with bur study on the 

basis of our own analyses and the information we have received 

to date . Thank you again for providing your perspective on the 

importance of reducing sulfur levels in diese l fuel. I assure 

you your comments will receive careful consideration in our 

deliberation on this issue. 

Sincerely, 

DON H. CLAY FOR 

J. Craig Potter 

Assistant Administrator 

for Air and Radiation