p.1 

OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

158)IV-E-31 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:56 PM Sheet 158 of 242 
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

MAR 3 | '°RR 

MEMORANDUM 

SUBJECT: 

FROM: 

EPA Meeting with 

Recovery NPRM 

NTEA Regarding Onboard Vapor 

TO: 

THRU: 

Glenn W. Passavant, Senior Project Manager 

Standards Development and Support Branch 

Public Docket A-87-11 

Chester J. France, Chie 

Standards Development rt Branch 

On January 13, 1983 a meeting was held between EPA staff 

and representatives of the National Truck Equipment Association 

(NTEA) in Room 937W of the EPA headquarters building in 

Washington, DC. An attendees list is attached. The purpose of 

the meeting was to discuss NTEA's concern about EPA's NPRM for 

onboard vapor recovery for heavy-duty gasoline-fueled vehicles 

(HDGVs). 

First, NTEA explained the role of their organization and 

the nature of the size and product of their member companies. 

NTEA represents about 1300 companies whose business is to 

modify chassis cabs and complete vehicles procured from the 

primary manufacturer for use in commercial applications. 

Companies in this business are often referred to as secondary 

manufacturers. Most of these companies are small businesses, 

but according to NTEA their member companies are responsible 

for about 75 percent of the commercial vehicle modifications 

each year. A brochure provided by one of the NTEA member 

companies is attached. 

NTEA began the discussion by explaining how EPA's 1983 

rule on HDGV evaporative emission controls had made it much 

more difficult for them to add extra fuel tanks and that much 

of this business was lost to the primary manufacturers who 

began offering more optional dual tank packages. NTEA 
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explained - that even though EPA had included provisions in the 

regulations to cover evaporative control systems for extra 

tanks added by secondary stage manufacturers, the canisters 

needed were OEM products and as such were not available to them 

soon enough into the initial model year of evaporative control 

for these vehicles. Furthermore, NTEA member companies felt 

constrained by manufacturer warnings that modifying 

fuel/evaporative systems could void the emissions warranty on 

the system. During the course of the discussion it was also 

noted that NTEA member companies may presently incur a safety 

liability as a result of modifying fillneck and tank locations, 

etc. 

With regard to EPA's onboard NPRM, NTEA expressed concern 

that the proposed rule could reduce the vehicle/chassis 

configurations available for them to modify, and that onboard 

hardware could affect their ability to do the customizing 

necessary in their business. The primary manufacturers make 

only a limited number of models/configurations now, and 

customizing and modifying by the secondary manufacturers 

becomes more difficult as more standards are imposed. In 

NTEA's view, any new standard adversely impacts the flexibility 

of their member companies. Finally, NTEA suggested that EPA's 

regulatory flexibility analysis should consider this effect. 

In response to these concerns, EPA asked NTEA to provide 

in their written comments suggestions on how their concerns 

could be addressed effectively in the regulations. Options 

discussed included developing a method for secondary 

manufacturers to recertify, clarifying the emission warranty 

liability regulations with regard to secondary manufacturers, 

and working with the manufacturers to assure they provide 

workable, well designed onboard systems for these vehicles. 

With regard to further analysis, EPA also asked that NTEA 

provide a distribution of the Gross Vehicle Weight Ratings of 

the vehicles affected and an explanation of how they now handle 

^certification with regard to FMVSS 301. 

Finally, NTEA w?.3 invited to visit EPA's Ann Arbor 

laboratory to view onboard system hardware and further discuss 

any technical issues with EPA staff. 

Attachments 
P.4 

SUBJECT: Onboard/Volatility 

National Truck Equipment Co. 

Date/Time: Jan 13, 1988 Room No. 937 

ATTENDEES 

NAME 

Glenn Passavant 

Ralph Colleli 

Don Zinger 

James Carney 

OFFICE 

EPA - Ann Arbor 

EPA - OGC 

EPA - OMS, Washington 

National Truck Equipment Assoc 

Mark Sidman Weiner, McCaffrey, Brodsay & Kaplan, 

Gus Avrakotos 

Craig Potter 

Lee Crenshaw 

Bill Chappell 

Dick Wilson 

NTEA 

EPA 

(NTEA) Crenshaw Corp 

Baker Equip Engr Co 

EPA 

] 

(313) 

Wash, DC 

(202) 

(804) 

(804) 

PHONE NO. 

668-4408 

382-7625 

382-7647 

968-2000 

628-2000 

628-2010 

382-7100 

231-6241 

342-6766 

382-7645 
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We were suiting our customers' 

needs to a T way back in 1919. 

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When Model T trucks were 

puttering down Main Street, 

USA, Joseph B. Baker was 

puttering around in his small 

shop customizing them for 

specific jobs. You see, our 

founder was a visionary. He 

saw that the assembly lines of 

Detroit were cranking out trucks 

for the masses, but only a job 

j shop could properly 

j outfit them for specific 

| applications. 

Over the past 

I seven decades. Baker 

| Equipment Engineering Company has grown into a multi -faceted 

equipment distributot Today, we can not only 

provide you with top-quality equipment and 

engineering services, we can also supply you 

with parts and service, as well 

as such specialized services 

as rental and leasing. The same 

sound business principle of 

meeting our customers' needs 

is still the cornerstone of our 

company, and always will be. 

In fact, serving our customers so well over the 

years has served us well, as we've been able to 

grow and diversify. Presently, we're expanding 

into new markets, aside from 

the utility industry we already 

serve, where there's a need for 

truck-mounted equipment. 

As always, we'll continue to 

provide pur customers with 

that personal attention to detail that has accounted for our success ever 

since the days of the Tin Lizzy 

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Our customers know a good product line when they see it. 

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You're looking at the best equipment from the 

best manufacturers, bar none. Aerial Lifts by HiRanger, Versalift and Telelect. Digger Derricks 

and Cranes by Telelect.Trailers by Hogg & Davis 

as well as Butlet Braden Winches. Baker Bodies, 

and IMTCO Cranes. And. while we're dropping 

names, we should also mention we're the number 

one distributor for Stanley Hydraulic Tools. 

As new products become available from 

these manufacturers, they are reviewed by our 

management team, and those that pass muster 

are placed in our unequalled product line. And 

as customers give us suggestions, we pass along 

their comments to manufacturers in order to 

help them develop and design better, more 

efficient equipment. 

Offering the finest line-up of equipment and 

tools in the industry is the least wecandoforour 

customers. We're also here to train your people 

on a one-to-one basis, to provide.you with 

demonstration vehicles to test, and to help keep 

you Informed of new government regulations. 

When it comes to following up and following 

through after the sale, we offer you the largest 

network of sales and service representatives to 

be found anywhere. 

So, as you can see, there's more to our topquality product line than meets the eye. 

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with special applications, 

odern computer sysiem. 

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If you t\CNe a need for a special piece of 

equipment, your specifications can only be 

drawn from data. At Baker, we draw that data from 

a sophisticated computer system which enables 

us to draft your mechanical drawings on a monitor, as well as feed in weight and dimensional 

information. Utilizing the computer, our engineers 

can provide drawing and engineering data to 

assist you in developing proper specifications. 

Being able to store and retrieve drafting, 

weights, and other engineering information, as 

well as material costs, we don't have to re-invent 

the wheel with each new project or bidding 

situation. This means our engineers spend more 

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time on engineering and less time on paperwork. 

And you get a more cost-effective piece of 

quality equipment in the bargain. 

Not only does the computer allow our 

engineers to make better use of the time they 

spend on your job. it also helps them to better 

understand your equipment, how it works and 

performs, and how it should be mounted, based 

on computer-stored pasl histories. 

With access to data banks of design information, our CAD-CAM programs can assist you 

in devising the specifications that will meet your 

expectations, both on and off the road. 

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Above all. service is 

what distinguishes a distributor from a manufoc -

turec And you'll find that 

top-notch service is what 

distinguishes Baker from 

other distributors 

If you need help in 

the field, our trained technicians can service you on 

the iobsite. or in any of our 

strategically located eastern 

Service Centers 

If you need parts, call 

on our rnulti - million - dollar, 

computer-monitored parts 

inventory And if for some reason we don't have something in stock, our parts expedifors can access mvenK L tories at any Baker location 

P y and usually find It in a matter 

B__* ^ ST-% of hours. 

|^«f i If you're concerned about 

^^^ J I fleet maintenance or training. 

I we have the people who can 

^•Bil^HBi H help you set up PM programs 

or employee training sessions. 

If you can't afford new equipment, we can either 

rent you late-model quality equipment or rehabilitate 

your older equipment for you. 

We do it oil. We build, outfit, repair, and service 

all of the equipment we sell, rent or lease. Whal 's more, 

we believe the quality of our service is unexcelled In 

the industry 

Offering complete service is a tall ordet Bui at 

Baket we believe it's what keeps satisfied customers 

coming back. 

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They rent or lease it instead, from the most 

rtensive fleet of vehicles in the industry. Baker 

luipment Leasing Company offers you a 380-

Mcle fleet of late-model trucks to choose from, 

s also offer more rental and leasing options 

an anyone for either your short or long-term 

seds. And to be even more accommodating; 

we can steer you in the right direction for the 

financing that fits your budget. 

Ourtrained technicians service and maintain 

our fleet so well, all vehicles look and, more 

importantly, operate in top form. We can even 

provide pick-up and delivery when necessary. 

So if you have a specific need for a certain 

project, are experiencing equipment delays, or 

have equipment in the shop, we can see you 

through. If you have a peak load situation due. 

to weather or season, or you'd like to test some 

equipment before purchasing it, we're here to 

help. Or if you simply don't want to expend the 

capital for new Aerial Towers. Digger Derricks, 

Construction Cranes,Cable Reel or Pole Trailers, 

or any other specialized units, call on us, toll free 

at (800) 466-2610. In Virginia, (804) 358-0481. 

Whetheryou need top-quality equipment for 

a week, month,year or more. Baker Equipment 

Leasing Company is the only reason not to buy 

our equipment. 
Some of our customers aren't even in the utility industry. 

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Serving the special needs of the utility 

ustry has taught us a thing or two. For 

ance. sometimes utilities approach the 

ne job in different ways. Each has particular 

uirements for equipment and mountings, 

sending on the work application. So it didn't 

z. us long to learn to addpt ourselves to our 

customers' individudl requirements. 

Likewise, we learned we could adapt ourselves to other markets as well, with the common 

denominator being the need for specialized 

truck-mounted hydraulic equipment and tools. 

By packaging bucket trucks with chip boxes, 

brush chippers and pruning tools, we entered 

n-.' •" , 

the tree-trimming industry. By providing rail gear, 

special tool boxes and heavy-duty bodies with 

crew cabs and cranes, we started supplying the 

railroad industry. And now. through contact from 

domestic ond foreign distributors, we've entered 

the export market, as well. 

We continue to manufacture fire-fighting 

aerial devices, and our research and development in this area is extending the reach and 

flexibility of this specialized equipment. 

So by meeting the diverse demands of one 

industry, we acquired the skills and expertise to 

meet the demands of diverse industries. 

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f you like receiving personal attention and 

ing every derail looked after for you. then you 

uld get to know our employees. They make it 

' business to satisfy the customer And you'll 

plenty of satisfaction out of that. 

Employees sporting 10,15.20 and even 30-

r pins are commonplace throughout the 

company, from the shop floor fo the board room. 

That's because we're a family-owned business that treats its customers and employees as 

one big family. We encourage our people to get 

involved in industry dssociations.to attend various 

conferences and seminars, and to conduct workshops and presentations f a our customers. 

Through regular contact, you'll get to know 

your Baker sales, service and parts personnel as 

well as they know you. 

When working with our engineers in devising 

your equipment specifications, you'll build quality 

equipment as well as a bond of trust. 

By visiting our plants and service centers or by 

having our technicians visit you. your equipment— 

as well as your confidence in Baker—will be 

maintained to the utmost. 

That's why when it comes to customer service, 

customers come to Baker Over and over again 

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ker is following the signposts of the future 

many roads as we diversify into new marxpand into new territories, and introduce 

quipment into our product line. All to better 

our present and prospective customers, 

jse. just as you've depended on us in the 

,e want to be here to handle all of your' 

equipment needs in the future. 

Diversif ication gives us strength to weather the 

whims of any given industry's economic condition, while expansion affords us the latitude to 

assimilate regional economic slowdowns. 

A continually updated product line allows us 

the ability to meet the ever-changing needs of 

customers and industries alike as technologies, 

methodologies and economies dictate. A 

customer service network second to none puts 

us in closer contact with our customers, and the 

marketplace. This enables us to anticipate trends, 

predict peak equipment demands, and be 

more attuned to financial forecasts/ 

For the future, we still plan to offer the newest 

products, as well as more engineering expertise, 

more rental and leasing options, more parts and 

. more customer services than any other company. 

That you can depend on. Which is why you 

can depend on Baker for the road ahead. 

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