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OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

136)IV-C-102 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:58 AM Sheet 136 of 232 
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y " > •' OyOOSZ-c-'10^ 

I \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

50 i Q 

OFFICE OF 

AU AMD RADIATION 

Honorable Pernand J. St Germain 

House of Representatives 

Washington, DC 20515 

Dear Mr. St Germain: 

Thank you for your letter of March 22, 1988 in which you 

passed along the comments of Mr. Raymond Duquette concerning 

EPA's proposal to require onboard refueling controls on new 

gasoline-powered vehicles and trucks. In your letter you 

requested EPA's comments on the possibility of allowing states 

to choose between onboard and Stage II controls. 

We do not believe this .approach is viable because new 

vehicles are manufactured and sold for a nationwide market. 

Thus, it would not be practical to implement onboard controls 

on a state-by-state basis. We believe that if onboard is to^be 

adopted, it must be a nationwide program, with the only 

possible exception being California which has the authority 

under the Clean Air Act to establish its own motor vehicle 

controls. 

It is our understanding from reading Mr. Duquette's letter 

that he supports EPA's onboard proposal and believes that, in 

light of EPA's action, states presently required to implement 

Stage II not be forced to do so. EPA's position is that Stage 

II may provide short term benefits while onboard controls are 

being phased in, and that states where Stage II is already 

installed or being installed should maintain their Stage II 

equipment until onboard is phased in. Other states would have 

the option of considering a short term Stage II program as part 

of the State Implementation Plan development process. Each 

case, though, would have to be reviewed separately in light of 

any final rule requiring the implementation of onboard controls. 
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MAY - 9 f988 

CENTRAL DOCKET 

SECT/ON 
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•>•:. 

• • . > , 

Kqaim_£_p*nk you for your letter and your concern in this 

matter. p••sured that we will consider Mr. Duquette's 

comments fl Bfc»; proceed with the rulemaking. We will also be 

placing ^flK letter along with his comments in the public 

docket for the onboard vapor recovery rulemaking. 

Sincerely yours, 

Richard D. Wilson 

Director, Office of Mobile Sources 

cc: Docket A-87-11 

ft 
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FERNAiM-D J. ST GERMAIN 

- 1ST DISTRICT, RHOOI ISLANO 

2108 RAVSURN HOUSI Offict BUILDING 

WASHINGTON, OC 20518 

TEL.: 202-225-4911 

2 0 4 JOHN E. FOOARTY BUILOINO 

PROVIDENCE, Rl 02903 

TEL: 401-528-6050 

TOLL Fun TEUFHOM 

1-300-662-6110 

«+ 

Congees* of ttie ®mteb Stated 

Jlouie of Ulepreaentattoe.* 

Washington, Mt 20515 

CHAIRMAN, 

BANKING, FINANCE AND 

URBAN AFFAIRS COMMITTEE 

CHAIRMAN, SUWOMMITTEE ON FINANCIAL 

INSTITUTIONS SUPIRVISION. 

REGULATION AND INSURANCE 

HI 

JJy/.sy 

March 22, 1988 

Mr. Lee M. Thomas ,,r 0 b\ 

Administrator -li1 -

Environmental Protection Agency 

401 M Street SW 

Washington, D.C. 20460 

Dear Mr. Thomas: 

I am writing on behalf of a constituent who is in favor of an 

EPA proposal to require auto manufacturers to add an on-board 

cannnister to capture emissions to all new cars, while opposing 

Stage II service station controls. 

Enclosed, please find a copy of Mr. Raymond Duquette's 

letter. Mr. Duquette suggests that states should be given the 

choice between on-board cannister and Stage II recovery controls. 

I would appreciate your comments on this suggestion. 

Thank you for your consideration of this matter. 

Sincerely, 

FJStG:jem 

enclosure 

J. St Germain 

mber of Congress 

'>£*/* 

rip) 

.JI 
m- pj5_ 

GA1TSETT SUNOCO STATION 

. 1101 Newport Avenue ^AR 3 1988 

i 

•*~ PAWTUCKET, H. I . <.)?861 

February 2b, 1988 

Hon. Fernand J. St.Germain 

2108 Rayburn Office Bldg. 

Washington, D. C. 20515 

Dear Representative St.Germain: 

The Federal EPA has proposed a regulation that will require auto manufacturers to add a larger canister on all new cars. EPA is bo be commended for making that difficult but prudent decision. OA-board canisters simply work better at capturing all auto emissions, including 

refueling losses, than the more controversial Stage II service station 

controls and is a nominal increase to the sticker price of a new car. 

As more and more new cars enter the fleet, Stage II will become redundant and increasingly less effective. 

Stage II requires a large capital investment, strict; enforcement program 

and .'considerable expense to maintain the equipment in proper working 

order. In my opinion, it is unreasonable for any state to require the 

industry to spend $20,000.00 per location for installation and hardware, 

$1500 to $3000 in annual maintenance 'costs .and to funnel tax dollars 

into an enforcement program for a suspect control measure. Stage II 

will certainly raise the price of gasoline to the consumer and, because 

of its avrkwardness, may reduce the efficiency with which customers are 

served and with which they've come to expect. That's a "double hit" on 

the consumer. 

I agree that cleaning up our environment is vitally important, and I 

fully support and endorse .EPA's on-board canister approach. It is a 

control measure that works better and costs less than the Stage II 

controls some states are being forced to implement. Those states should 

be permitted tbeoption of on-board as a substitute for Stage II. 

I urge you to quickly adopt the national on-board strategy under proposal 

and to consider some recourse for those states w?'.ich have been ordered by 

the courts to implement Stage II. 

Very truly yours, 

GANNETT SUNOCO SjCVriON 

RED:AED RaWmd. E. Duquety, Owner