P.1 

OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

194) IV-C-161 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:21:01 AM Sheet 194 of 232 
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UN.TED STATES ENV.RONMENTAL PROTECTION AGENCY 

WASHINGTON. D.C. 20450 

MAR 1 7 1989 

THE ADMINISTRATOR 

Honorable John D. Dingell 

Chairman, Subcommittee on 

Oversight and Investigations 

Committee on Energy and Commerce 

House of Representatives 

Washington, DC 20515 

Dear Mr. Chairman: 

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MAY " 5 1989 

EPA AIR DOCKET 

Thank you for your December 21 IQRR I .= •-•.,* 

comments of the Motor Vehicle Mannf^f ^ conveying the 

on our two October 27 1988 r*n?"ufaJ

turers Association (MVMA) 

running loss control and onboard ?aoo? lTM ^ ^

 con«rning 

comments were quite extensive »„S

 P 2 recover ^ issues. MVMA's 

comments in these areas fri^ m ? eXpec t t o receive more 

rulemaking activities on tS- ^ ^ °ther S a S w e continue our 

it would oe premat^e to provide ° d'at^d 1*1 ^ i n mind ' 

to each of MVMA's comments at thiJ ??! *t technica l response 

like to make a few events rega ding^RA's*Intenf6^ * W °

U l d 

to three specific issues raised by SVMA?

 W t h regar d 

Procedure^ ^rS^SIorSv? 6 "

3 " ^ r6fUeUn g t6S t 

set up to favor Integrated onbo^H °n *eptembe r 1' 1988) are 

force system design ?hf in?pn? nf Tf T

 an d thu s t o tr* t o 

is not to attempt to forL ItJi 5 h*

 t6S t Proced"re changes 

that both systems achieve a simlla^" '

 bUJ Cathe r t 0 ens ^e 

in-use. The fact thaJ lifUrlnl tea? VrTc.f emissio n cont TM l 

considered for diff*r«««- « I , procedures are beinq 

recognition of 2ta ISEL^Eft.XS!;" ' ^ ^ *TM*°^'-• i» a 

in the two approaches ?h2te is n^in^^T""" 9 dl «««nces 

design over another L/S . ° lnten t to encourage one 

approach. lITh^ a Tlso^n^'tlll^ f ^ .<* •

i U ", r 

other. W e hooe thlt roTM. * nq -

0 n e ap Proac h °"«*r the 

(or even *»??&' & ~! S ^^USe^e^" * " U 1 aU ° » 

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A second subject addressed by MVMA is the amount of 

leadtime which would be provided before onboard refueling 

control would be required. MVMA maintains that it is 

impossible to evaluate issues such as cost effectiveness and 

safety without a specific leadtime proposal. I want to 

reiterate EPA's commitment that any onboard rule will provide 

adequate leadtime to implement onboard controls both safely and 

effectively. As you know, EPA's draft SNPRM does not contain a 

new leadtime estimate. This is because we want to have a 

better idea of the leadtime implications of the test procedure 

changes and onboard technology improvements discussed in that 

document before revising our estimate. As we continue the 

rulemaking process, EPA hopes to receive additional comments on 

leadtime which factor in all of the new information since the 

original NPRM, and that specifically detail the relationship 

between, and sensitivity of, vehicle safety and total system 

implementation costs to initial leadtime and a phase-in 

approach. 

The third subject commented on by MVMA is the feasibility 

of running loss controls and the safety implications of a 

no-vent requirement. Contrary to MVMA's concerns, we did not 

intend that the potential running loss control requirement or 

the draft test procedure would prohibit manufacturers from 

using fuel tank pressure as part of their emission control 

strategy. Rather, our goal is to ensure that any vapor vented 

either prior to refueling or during in-use operation is routed 

to the carbon canister or engine, not directly to the 

atmosphere. We agree that emergencies and extremely atypical 

conditions in-use must be considered as part of any 

requirement. However, to be of greatest value, running loss 

emissions must be controlled under those conditions typical of 

high ozone days, when control is most critical. 

As mentioned above, as we proceed further in the 

rulemaking process we expect to receive additional comments on 

the areas addressed by MVMA. Let me assure you that we will 

very carefully consider the points raised by MVMA and others as 

we engage in additional analysis on these issues and that the 

comments received will be fully considered as we enter into 

decisions regarding rulemaking. 

Sincerely, 

William K. Reilly 

William K. Reilly 

cc: Docket A-87-11 

Docket A-85-21 

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