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OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

137) IV-C-103 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:58 AM Sheet 13 7 of 232 
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T7 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

APR I 9 1988 

OFFICE o r 

AIR AND RADIATION 

ionorable Christopher Sheye 

rfouee of Representatives 

waehlngtoa, D. C. 20513 

Dear Hr, Shayat 

Thank you for ^easing along tue comments of Josepa R« 

Driscoll and Arthur loldetein concerning SPA* a propoaal to 

require onboard refueling *iUu;>n controls, Jle assured that 

those coanent* will be con*id*r»ci in cn* next phaa« of our 

rulemaking pvejOOOO* -i•» wil l als o oa placlay tnaai in the 

fciublic docket for cne rulemaking. 

Thank you again tow your ooaoern in thi a aattor , 

sinoerely youra, 

ORIGINAL SiGNE.0 BY 

RICHARD O.WILSON 

I ftieoard 0, tfllaea 

director , Ottloe ol Mobile Source* 

cot Docket n-*7-il 

Prepared bytPCarle©ntBCTDiS-374~8270iAL-1330i4/13/8f 

boot Administrator 

Deputy jAdaiinietrator 

Region 1 

Congreseional Llaieon/Quinn 
P.3 

•4nP4^OTECT'ON 

w - 9 m 
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CONGRESS OF THE UNITED STATES 

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April 6, 1988 

Mr. Lee M. Thomas 

Environmental Protection Agency 

West Tower, Room 835, A-103 

Washington, D.C. 20460 

Dear Mr. Thomas: 

Enclosed are letters I received from Joseph 

Driscoll, President of Buckley Gasoline Marketers, 

Inc. and Arthur Goldstein, President' of Petrol Plus 

Company, about the proposed Environmental Protection 

Agency regulation to require auto manufacturers to 

add a larger emissions canister to all new cars. I 

respectfully request that you consider their 

comments. 

Thank you for your assistance. 

Christopher Shays 

Fourth District Connecticut 

Offices 

0/ Sincerely, 

or / , 

/7^c/>/>^ O0?*<f3 

Christopher Shays 

Member of Congress 

CS:drb 

(

.M 5 l.alaveiie Boulevard 

Bridgeport. CTOtit.04 

r>7.)-:W70 

SUM Washington Boulevard 

Stamford. CTOIi'.IOI 

:«")7-H277 

50 Washington Street 

Norwalk. CT IMiSfH 

,HI,()-l.4t>9 

I HUH l.ongworth Building 

Washington. D.C. 'JO'il'i 

2()2/22r>-:")r>41 Mu 
P.5 

Fuels 

For 

Modern 

Living 

BUCKLEY GASOLINE MARKETERS, INC. 

146 ADMIRAL STREET P.O. BOX 3301 

BRIDGEPORT, CT 06605-0301 

(203) 366-2644 

rtflft 

February 17, 1988 

Representative Barbara B. Kennelly 

1230 Longworth House Office Bldg. 

Washington, D.C. 20515-0701 

Dear Congresswoman Kennelly: 

MAR 161988 

We are an independent Gasoline Distributor marketing gasoline throughout 

the State of Connecticut. Our customers run the gamut from large service stations 

to small commercial customers. As such, we applaud the Federal EPA proposal that 

will require auto manufacturers to add a larger cannister on all cars. EPA is to 

be commended for making that difficult but prudent decision. On-board cannisters 

simply work better at capturing all auto emissions, including refueling losses, 

than the more controversial Stage II service station controls, and only adds 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 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 awkwardness, 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. 

The economic impact as mentioned above is horrendous but in addition, studies 

have shown: 

A. That on-board canisters are 98% efficient, whereas Stage II is 

only 62% efficient. 

B. API figures indicate that Stage II is not cost effective in that 

it will cost $2,400 to capture one ton of hydrocarbons with that 

system versus only $750 using on-board canisters. 

C. The proliferation of self-service stations will present a problem 

to our elderly and handicapped customers, as the weight and 

awkwardness of the Stage II two-hose system will preclude their 

using same, and this will force them to spend more money for 

full-service. 

Continued... 
P.6 

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

support and endprse 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 the option 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 which have been ordered by the 

courts to implement Stage II. 

Sincerely, 

BUCKLEY GASOLINE MARKETERS, INC. 

Joseph R. Driscoll, 

President 

JRD:deb 
P.7 

PETROL 

PLUS PETROL PLUS 2^ CC.ViME:7CE PC scx-i: 4J13 

Telephone 725-4C2

 s;ew.-ieven ""vr'!"'- ;..= 

GASOLINES » 3.E3EL »:.;:< : CH » ::SR:G-r iTS • 

x-::-: 

Representative Christopher Shays 

1630 Longworth House Office Building 

Washington, D.C. 20515-0704 

Dear Representative Shays; 

February 12, 1988 

The Federal EPA has proposed a regulation that will require auto 

manufacturers to add a larger canister on all new cars. EPA is to be 

commended for making that difficult but prudent decision. On-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 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 awkwardness, 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 the option of on-board as 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 which have 

been ordered by the courts to implement Stage II. 

Sincerely, 

Arthur Goldstein 

President