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Prepped by Ollie Stewart 

Document Number: 

142)IV-C-108 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:58 AM Sheet 142 of 232 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

I ^^ffij | WASHINGTON, D.C. 20460 

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* MAR 3 0 1988 

OFFICE OF 

POLICY, PLANNING AND EVALUATION 

Honorable John Glenn 

Chairman, Committee on Governmental Affairs 

United States Senate 

Washington, D.C. 20510 

Dear Mr. Chairman: 

On September 15, 1987, the General Accounting Offica 

(CAO) sent tha Environmental Protection Agency (EPA) thair 

final report entitled "EPA's Efforts To Control Vehicle 

Refueling And Evaporative Emissions" (GAO/RCED-87-151). 

As required by Public Law 91-510, the Agency reviewed the 

report, considered the report's recommendation, and provides 

a response to the recommendation below. 

GAP Recommendation 

To provide more complete information and analyses to the 

public and to assist the Congress and other decisionmakers 

in evaluating the regulatory alternatives, GAO recommends that 

the Administrator, EPA, direct the Office of Air and Radiation 

to include the following in its refueling and evaporative 

control analyses: 

o better documentation of the cost-effectiveness of 

alternative ozone control strategies (including 

support for its $2,000 benchmark standard and 

necessary seasonal adjustments, and 

o a more explicit comparison of all the costs and 

benefits associated with the various refueling 

and evaporative emission control strategies, 

including a more thorough analysis of the effects 

of key uncertainties. 

EPA Response 

In principle, we agree with GAO that providing more 

complete information and analyses to the public assists 

in the evaluation of regulatory alternatives, and we always 

strive to provide as complete a public record as possible. 

It is important to note that GAO reviewed preliminary 

versions of the EPA refueling and volatility proposals. 
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The final versions of our proposals published in the Federal 

Register on August 19, 1987, and the accompanying analyses 

released at that time contain additional detailed information 

and discuss the sensitivity of a number of key variables. 

Also, public dockets for both proposed rules and the 

previous studies in these areas contain a large amount ot 

additional technical information and supporting analyses 

for the proposals. Information available in these dockets 

should provide adequate material for those evaluating the 

regulatory alternatives. Moreover, EPA will reopen the 

record of the proposed onboard rule when the Agency receives 

the cowman i-.s of the Secretary of Transport.:.'.tion with rasipac'.;' 

to motor vehicle safety and will repropose the rule for 

comment to assess changed circumstances. As stated in the 

report's "Results in Brief" section, GAO believes that most 

of the information EPA would need to address their recommendations is currently available and that we could deal 

with them in our final analyses without delaying the rulemaking process. It is our intention to consider GAO's 

specific recommendations during preparation of any' final 

rulemaking actions. 

I appreciate the opportunity to respond tc the report's 

recommendation. 

Sincerely, , 

•b^bb" Linda J. Fisher 

Assistant Administrator 
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'^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\ PBO*fc° 

WASHINGTON, D.C. 20460 

:•'.,-. 0 0 0 .iw_ 

OFFICE OF 

POLICY, PLANNING AND EVALUATION 

Honorable James C. Miller 

Director 

Office of Management and Budget 

Washington, D.C. 20503 

Dear Mr. Miller: 

On September 15, 19 87, the Administrator of the Environmental 

Protection Agency received a General Accounting Office report 

entitled "EPA's Efforts To Control Vehicle Refueling And 

Evaporative Emissions" (GAO/RCED-87-151). 

In accordance with P.L. 91-510, we have submitted written 

statements to the Chairmen of the House Committee on Government 

Operations and Senate Committee on Governmental Affairs. Copies 

of our statement are enclosed for your information. 

Sincerely yours, 

9/U^ 

jinda J. flPtsher 

Assistant Administrator 

Enclosures 
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j.xO> *rATi 

$ 4Gk \ UNITED STATES ENVIRONMENTAL ."PROTECTION AGENCY 

I ^fjj ^ ? WASHINGTON, D.C. 20460 

%p**C ^ 

OFFICE OF 

POLICY, PLANNING AMD EVALUATION 

Honorable Charles A. Bowsher 

Comptroller General of 

the United States 

Washington, D.C. 20548 

Dear Mr. Bowsher: 

On September 15, 1987, the Administrator of the Environmental 

Protection Agency received a General Accounting Office report 

entitled "EPA's Efforts To Control Vehicle Refueling And 

Evaporative Emissions" (GAO/RCED-87-151). 

In accordance with P.L. 91-510, we have submitted written 

statements to the Chairmen of the House Committee on Government 

Operations and Senate Committee on Governmental Affairs. Copies 

of our statement are enclosed for your information. 

Sincerely yours, 

Linda -JV Fisher 

Assistant Administrator 

Enclosures