P.1 

OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

134) IV-C-100 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:58 AM Sheet 134 of 232 
P.2 

•* rSl* ^ UNITED STVTES ENVIRONMENTAL PROTECTION AGENCY 

i yST Z / WASHINGTON, D.C. 20460 

\ ^ APR 5 1988 

OFFICE OF 

AIR AND RADIATION 

Honorable Bill Bradley 

United States Senator 

Post Office Box 1720 

Union, New Jersey 07083 

Dear Senator Bradley: 

This is in response to your March 10, 1988 letter relaying 

the concerns of your constituent, Mr. Paul Erdbrink, regarding 

EPA's regulatory proposal to require onboard canisters on new 

vehicles to control refueling emissions. To assist you with 

your response, I have enclosed a copy of our proposal for your 

review. Section E (pages 31177-31182) explains EPA's overall 

rationale for proposing onboard controls. If you would like 

further details of our analysis, please contact Mr. Philip 

Carlson of the Standards Development and Support Branch of 

the Emission Control Technology Division, 2565 Plymouth Road, 

Ann Arbor, Michigan 48105 (FTS 374-8270 or Commercial (313) 

668-4270). 

Thank you for your letter. We will fully consider his 

comments in the next phase of our rulemaking process. 

Sincerely yours, 

CV- 'VT- £-Y 

Cv J . -1,-i.xR 

Richard D. Wilson 

Director, Office of Mobile Sources 

Enclosure 

Prepared by: Form Letter:sal:3/30/88:AL881280 - Ann Arbor, MI 

cc: Region 02 

Congressional Liaison/Quinn 

Docket No. A-87-11 c/o Jackie McManus''. 
P.3 

ENVIRONMENT-' PROTECTION 

AGENCY 

. m - 9 1988 

CENTRAL DOCKET 

SECTION 
P.4 

WV< ':IVI:l) |-!-H I 7 \ m 

Erdbrinks•Service Center 

825 Evesham Road 

Magnolia, NJ 08049 

February 9, 1988 

-: V i\V.V-i 

Mr. Lee Thonas, Adainiatrator 

Environmental Protection Agency 

401 M Street, S.H. 

Waterside Nail 

Washington, D-C.20460 

Dear Hr. Thomaaf 

Aa a dealer, I would like to express my concern about exiating 

federal proposals to install Stage II controls a* the pumps-. 

Like many other dealers I know, I strongly oppose such controls. 

The coat of installing Stage II controls — over $20,000 for 

the average station — and maintaining th08e controla — about 

$2,000 to $5-000 a year — could force me out of business, 

Theae controls are not worth the sosts. They arc hard to uae and 

they are difficult to maintain. Most importantly, there ia a 

better, more effective option -- the on board canisterThe on board caniater inatalled on new cara would be a more: 

effective way to prevent refueling emissions from escaping 

into the atmoaphere. Your own agency estimatea that caniaters 

would be 93 percent effective, while Stage II controls would be 

only 62 percent to 86 percent effective. Furthermore, the 

canister would have none of the disadvantages of the Stage II 

controla. 

I am also concerned that New Jersey gas stations are required to 

implement-the~_Stage II controls as an interim measure until the 

canister is in place (probably two or three years from the time 

it is required). Once the canister became effective, Stage II 

controla could be redundant -- making my investment in these 

controla inefficient and unnecessary; that is, if I an still in 

the businesso 

I urge you to reject all proposals to implement Stage II controls 

end to aupport the use of the on board refueling caniater. 

Sincerely, 

£jzd L * /K/IC $ Sc'/tu /cc Ce.^Jtci,