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OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

81) IV-C-47 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:55 AM Sheet 81 of 232 
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| -JQL ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\ ^/AA WASHINGTON, D.C. 20460 

M 2 8 1988 

OFFICE OF 

AIR AND RADIATION 

Mr. J. N. Wootton 

Worsley Companies, Inc. 

10 Cardinal Drive 

P. 0. Box 3227 

Wilmington, North Carolina 28406 

Dear Mr. Wootton: 

Your letter of December 22, 1987 to Mr. Mitchell E. 

Daniels, Jr., at the White House has been referred to our 

office for response. 

We appreciate receiving your comments on EPA's proposed 

action to control vapors generated during the refueling of 

motor vehicles. A copy of your letter will be placed in the 

public docket for this rulemaking. As you know, EPA has 

proposed that these pollutants be controlled by the installation of "onboard" systems on new gasoline-powered vehicles. 

This proposal involves complex and controversial issues and we 

have spent a great deal of time analyzing the environmental and 

economic impacts. We held a public hearing on the proposal 

this past October and we expect to receive many additional 

comments by the time the comment period closes on February 11, 

1988. 

Once again, thank you for your views on this matter. 

They will be considered as we proceed with the next phase of 

the rulemaking. 

Please let me know if we can be of further assistance. 

Sincerely yours, 

ORIGINAL SIGNED BY 

RICHARD D. WILSON 

Richard D. Wilson 

Director, Office of Mobile Sources 

cc: Docket A-87-11 
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* 0> /># r c <• 

WORSLEY COMPANIES, INC. 

10 Cardinal Dr. • P. 0. Box 3227 • Wilmington, N.C. 28406 • (919) 395-5300 

COMPANIES^ , • ' 

December 22, 1987 

Mitchell E. Daniels, Jr., Assistant to the President 

Office of Political and Intergovernmental Affairs 

1600 Pennsylvania Ave. N.W. 

Washington, D.C. 20501 

Dear Mr. Daniels: 

Within a short period the EPA will be making a decision on 

the method to be used for controlling gasoline vapors. The two 

methods being considered are "Stage II" and "Onboard". 

Our position as a petroleum marketer, is that the EPA :| 

adopt the "Onboard method. The cost of eguipping and .; 

maintaining "Stage II" at locations dispensing gasoline would 

be in excess of $20,000.00. We are a five state petroleum 

marketer with 275 retail gasoline outlets. Of this 275, 135 of 

these outlets are classified as "mora and pop" locations owned 

and operated by individuals with limited capital. If "Stage II" 

is adopted 90% of these business will be forced to close, 

eliminating 484 jobs. The base of the economy for our great 

country is the small businessman, it appears that this fact is 

sometimes forgotten by various governmental agencies. Lets 

make the decision based on impact, not on big automotive 

lobbyists. 

The "Onboard" method can be designed and installed on new 

cars at very little cost. In addition to the cost, the EPA 

could have better input and control over design and 

installation with four or five automobile manufacturers than 

they would have over the thousands of service stations. 

We in the petroleum industry have almost been strangled 

with environmental controls. There is an option in this case, 

therefore, we would like to ask your help in supporting the 

"Onboard" method. 

Very truly yours, 

Worsley Companies 

Scotchman/Convenience Stores 

J.N. Wootton