P.1 

OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

135) IV-C-101 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:58 AM Sheet 135 of 232 
p ^ 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

APR I 8 1988 

OFFICE OF 

AIR AND RADIATION 

donor-Able Paul S# Saroane* 

United states Settats 

Wilmington, ">. :\ 

ti tetor Ur&anesi 

ir L-att leron u , i'H3, forwardinj 

i Lettur rrosi on - r con mte# lr« 3anuel iri^nt, 

«xi.' • ••»* [aire onooard 

refueling *raiissi ntrola. 

fo not-* >/ ir, -r i jn •.' i letter co you tnat ne lid a-stio 

(lis coiient? concern trig the prop-OS K>er4 fuel va-jor 

recovery ^yate«» to th* public <ioo.<et. 4» sopreciatc receiving 

coc-isents such ••»« tnots* :.'cw Mr. -Jrl ;it, and yoe cen be assure-1 

they will i^e carefully c-jislciered along with eaay othere we 

neve received on thi* important isius* 

*e are currently reviewing all the cccjnonts we reeeiveo 

ami revising our Analysis vh*re impropriate* In particular, 

we will soon send our revised onbo-ur-i safety analysis te the 

Secretary ot Tranaportation cor eowsent.* Subsequently* we 

will repropoes the rule for public comment en the safety 

issue as well es aay other significant changed circumstances. 

Sincerely /ours, 

L SIGNED BY 

RICHARD O.WILSON 

Richard o* rfilson 

oi rector, Office ot «toblle Sources 

bcc: Administrator 

Deputy Administrator 

Region 3 

Congressional Liaison/Quinn 

External Affairs/Mrs. Wilson 

Docket A-87-11 

Prepared by:MEPyles:AR-455:382-7645:AL-881503:4/13/88 
P.3 

.; 

ENVIRONMENTAL PROTECTION 

AGENCY 

MAY - 9 m 

CENTRAL DOCKET 

SECTION 
PAUL S. SARBANES . / 

MARYLAND '•--

United States Senate 

PA_ 

A 

WASHINGTON, DC 20510 

CZ 

r-i. i .• zc 

March 31, 1988 

Lee M. Thomas 

Administrator 

U.S. Environmental Protection Agency 

401 M Street, S.W. 

Washington, D.C. 20460 

Dear Mr. Thomas: 

Enclosed is a copy of correspondence I recently received 

from Mr. Samuel H. Wright, Vice President — Government Relations 

of PHH Group, a Maryland-based diversified business services 

firm. PHH Group has expressed serious concerns about safety and 

cost issues associated with the on-board system of vapor recovery 

for automobiles. The company requests that, on the basis of 

concerns raised by the National Highway Traffic Safety 

Administration and public and private organizations involved in 

motor vehicle safety, further studies be undertaken, including 

evaluation of all available alternatives. 

While I understand that the comment period on EPA's proposed 

regulations closed on February 11, I would appreciate your 

careful consideration of the concerns which Mr. Wright raises 

in his letter as well as any information you could provide regarding the alternatives to this system as well as the status of 

the rulemaking on this matter. 

Your attention to this matter is greatly appreciated. 

With best regards, 

Sincerely, 

Paul S. Sarbanes 

United States Senator 

PSS/csg 

Enclosure 

.w$$ 
P.5 

emu? 

11333 McCormick Road. Hunt Valley, Maryland 21031 (301) 771-1900 

SamuelH. Wright February 22, 1988 001)771.2471 

Vice President-Government Relations ** 

The Honorable Paul S. Sarbanes 

United States Senate 

332 Dirksen Senate Office Building 

Washington, DC 20510-2002 

Dear Senator Sarbanes: 

Re: Onboard Fuel Vapor Recovery System 

EPA Proposed Regulations 

On August 19, 1987, the Environmental Protection Agency issued a 

Notice of Proposed Rulemaking proposing that beginning in 1991 all 

gasoline powered motor vehicles be equipped with a fuel vapor 

recovery system. The purpose of the proposed system is to capture 

these vapors before they are released into the atmosphere. In many 

areas of the country, it is believed that these vapors have a 

deleterious affect on the ozone layer. 

While PHH recognizes that vehicle users share an obligation with 

all of our Nation's citizens to protect our environment, the current 

EPA regulations raise significant vehicle safety risks according to 

studies by the National Highway Traffic Safety Administration, the 

National Transportation Safety Board, the Insurance Institute for 

Highway Safety and the National Safety Council. PHH shares these 

safety concerns and, in its comments submitted to the EPA, requests 

that further study is needed to address these concerns, including 

evaluation of all available alternatives. 

I have enclosed a copy of our comments as well as a copy of a 

newsletter to our corporate clients describing the proposals. 

I urge you to support PHH's position before the EPA and to 

compel that agency to address all safety and cost issues before the 

proposed regulations are adopted. 

Thank you for your anticipated support. Please contact me if 

additional information is desired. 

Very truly yours. 

* /* 

r / / '• J V-k 

v- Samuel H. Wright 

cc: Mr. Marvin Moss 

SHW/sm 

Enclosures