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OAR Box 1846 

Prepped by Ollie Stewart 

Document Number: 

55) ll-H-3 

Docket Number: 

A-90-07 

Printed 11/18/2008 7:30:16 AM Sheet 55 of 93 
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Statement of the 

Motor Vehicle Manufacturers Association 

of the United States, Inc. 

on the 

U.S. Environmental Protection Agency 

Advance Notice of Proposed Rulemaking 

on 

Fuels and Fuel Additives Registration 

(Federal Register, Vol. 55, page 32218 

Tuesday, August 7, 1990) 

Ann Arbor, Michigan 

Wednesday, September 26, 1990 

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Statement of the 

Motor Vehicle Manufacturers Association 

of the United States, Inc. 

September 26, 1990 

Good afternoon Mr. Wilson and members of the Hearing Panel. 

My name is Marcel Halberstadt. I am Director of the 

Environmental Department in the Technical Affairs Division of the 

Motor Vehicle Manufacturers Association of the United States, 

Inc. (MVMA). The Association's members manufacture 94 percent of 

the cars, trucks and buses built in the United States. They are: 

Chrysler Corporation, Ford Motor Company, General Motors 

Corporation, Honda of America Mfg., Inc., Navistar International 

Transportation Corp., PACCAR Inc and Volvo North America 

Corporation. 

MVMA appreciates the opportunity to comment on the 

Environmental Protection Agency's Advance Notice of Proposed 

Rulemaking (ANPRM) dealing with "Fuels and Fuel Additive 

Registration" as published in the Tuesday, August 7, 1990, 

Federal Register. Volume 55, Number 152, page 32218. The ANPRM 

announced: 

"...EPA's intent to develop regulations and establish 

program protocols and test procedures related to the testing 

of motor vehicle fuels and fuel additives for purposes of 

registration as prescribed in section 211 (b) and (e) of the 

Clean Air Act. The regulations are to provide for tests to 

determine potential public health effects and such other 

information as is reasonable and necessary to determine 

emission control system effects and welfare impacts." 

It is clear from the reading of the ANPRM and Section 211 of 

the Clean Air Act that the requirement for determining the public 

health, welfare, and emission control system effects of fuels and 

fuel additives must be fulfilled by the fuel and fuel additive 

manufacturers. MVMA believes this responsibility should remain 

with the fuel and fuel additive makers under the new protocol. 

Requirements for testing of effects on emission control 

systems should be as rigorous as those required for vehicle 

certification. This is especially critical because, under the 

proposed Clean Air Act changes, vehicle manufacturers will be 

required to build vehicles that meet very stringent emissions 

standard requirements. Vehicle manufacturers must be assured 

that any fuel or fuel additive will not compromise their ability 

to meet these standards. 
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Testing requirements must also assess the impact of fuels 

and fuel additives on long-term durability of emission control 

systems. Vehicle manufacturers currently are responsible for the 

in-use durability of emission control systems for 50,000 miles 

for passenger cars and 120,000 miles for light-duty trucks. For 

cars, this is likely to be increased to 100,000 miles with the 

Clean Air Act amendments. Fuels or fuel additives which 

undermine the integrity of emission control systems designed to 

perform for the required period must not be approved. In 

addition, testing of control system effects must include a 

statistically significant sample of vehicle systems and be 

conducted under appropriate driving conditions to be considered 

valid. 

It is also important that the data and information generated 

from testing fuel and fuel additive effects on emission control 

systems be available for public review, as is presently done for 

fuel additive waiver applications. This is important, because as 

the designers and producers of the systems, vehicle manufacturers 

are in a unique position to understand best the implications and 

results of the testing protocol. 

In summary, MVMA believes that the testing of fuel effects 

on the emission control systems must be the responsibility of 

fuel and fuel additive manufacturers and conducted in a 

statistically valid and appropriate protocol, with opportunity 

for public review, evaluation and assessment of test results. 

MVMA favors the use of fuel additives that can provide consumer 

benefits such as: improved fuel quality; improved engine 

performance and durability; reduced deterioration of emission 

control systems (e.g., gasoline detergent-dispersant additives to 

maintain clean fuel and induction systems); and increased fuel 

supplies (e.g., appropriate nonpetroleum derived gasoline 

blending agents or gasoline feedstocks from biomass, oil shale, 

coal, etc.). However, fuel additives must not adversely affect 

the emission control performance and must not unreasonably 

increase the public's exposure to potentially harmful and 

currently unregulated emissions.