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OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

82) IV-C-48 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:55 AM Sheet 82 of 232 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

J/41 ? t; p^f) 

OFFICE OF 

AIR AND RADIATION 

Mr. James B. MacRae, Jr. 

Deputy Administrator 

Office of Information and Regulatory Affairs 

Office of Management and Budget 

Washington, D.C. 20503 

Dear Mr. MacRae: 

Thank you for your December 8, 1987 letter commenting on 

our proposals to limit gasoline volatility and refueling? 

emissions. We appreciate your taking the time to communicate? 

your views to us on these important matters. 

Your comments touched on a number of important issues. You 

are already aware of our current position on most of these 

matters, since they were enunciated in our proposals. However, 

I would like to briefly comment on the issues raised in your 

letter relating to recent developments since the publication of 

our proposal. You highlight an apparent decline in the number 

of ozone nonattainment areas; the Court-ordered Stage II 

installation program for New York; the Northeast states' 

agreement to proceed with regional volatility controls; and 

then indicate your opinion that ozone control should best be 

viewed as a regional rather than a nationwide problem. 

It is correct that the number of ozone nonattainment areas 

declined based upon the use of 1984-1986 design values compared 

to 1982-1984 data used in our proposals. On the other hand, 

you are probably aware of the indication^ that the number of 

nonattainment areas may increase substantially when 1987 data 

are included. We plan to complete our review of the 1987 data 

in time to include design values based upon 1985-1987 in our 

revised analyses. Thus, our decision will be based upon the 

most currently available data. 

You next pointed out that the Federal District Court has 

imposed a stringent Stage II installation timetable upon the 

state of New York. We agree that the impact of this action 
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must be considered in our deliberations. We will be assessing 

the impact of the New York program, as well as the New Jersey 

program, on our analyses, including recognition of the fact 

that such programs could be phased out if actually installed in 

advance of an onboard program, or that other actions could be 

taken by these states as part of the SIP process. As you know, 

many of these states strongly support a nationwide onboard 

control program in addition to their regional Stage II programs. 

The Northeast states have indicated broad support for 

gasoline volatility control but, as of yet, none have adopted 

specific regulations to that effect. We will continue to 

analyze the implications of regional versus national volatility 

control, but our current analysis and that of the petroleum 

refining industry seems to indicate that, in this case, 

nationwide control makes more sense than regional control. 

Once again, please be assured that we will be considering 

carefully the points which you have raised as we proceed with 

the rulemaking process following the public comment period.. 

Your comments will also be placed in the public dockets for the 

two proposals. We look forward to further contact on these 

matters in the future. 

Sincerely, 

$§&§ J. Cttig potter 

J. Craig Potter 

Assistant Administrator 

for Air and Radiation 

cc: Docket A-87-11 

Docket A-85-21