P.1 

OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

176) IV-C-143 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:21:00 AM Sheet 176 of 232 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

P.2 

DEC 1 6 1988 

«& 

Mr* George C. Mield, President 

Automobile Inportera of Aaerica, Incorporated 

1725 Jefferson Davii Highway, Suite 1002 

Arlington, VA 22202 

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Dear Mr. Kieldi 

I am writing in response to your letter dated 

November 2, 1988 regarding various issues about EPA's 

Supplemental Notice of Proposed Rulemaking (SNPRM) for 

refueling and evaporative controls. The three main areas about 

which you expressed concern were the scope of the SNPRM, the 

amount of time provided for review and comment on the SNPRM and 

the issue of simultaneous final rules on gasoline volatility 

and refueling control. 

Regarding the scope of the SNPRM, you expressed concern 

that the reproposal i3 too limited and that it does not fulfill 

commitnents EPA made earlier. In the August 1987 proposal EPA 

agreed to issue a reproposal which would "asses? changed 

circumstances." The changed circumstances covered in the SJJPRM 

include the onboard safety issue, the simplified onboard system 

concept, revised onooard coats, the impact of state programs to 

install Stage II, Stage II costs, the most recent list of ozone 

nonattainment areas, revised test procedures and the inclusion 

of running loss controls. Therefore, we believe our 3NPRK 

fully responds to previous commitcents. Of course, you will be 

able to conunent on these and any other relevant issues ycu raav 

identify. 

You expressed reservations that EPA may not allow fl3>ple 

time for full anci complete public review and comment on the 

SNPRM, especially in light of the revised test procedures. 

Although a final decision on a tiwe schedule has not been made, 

we believe that a prompt schedule for the public hearing and 

comment period may be appropriate because we have already 

disseminated the key information upon which the SNPRM is 

based. Over the last several months we have released EPA's 

revised safety analysis along with the National Highway 

Transportation Safety Administration's comments, the draft 

revised test procedures/ the documentation and computer codes 

*U.S. GPO . 1985-46/-as-
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,. •-.S?\~ , . i" UNITED STATES ENVjROilMcMTAt. FSOTErT-n*- *' 

for the revised evaporative emissions model* and the ongoing 

running loss, test program results. As a result of these 

actions, commenters currently have the substance of the SNPRM 

available for review andthus are able1 to beginVtbeir^analyses.^ 

In closingt you stated your concern* aboutEPA's desire to 

simultaneously promulgate final rules for both gasolinev 

volatility controls and onboard refueling controls. You 

believe a gasoline volatility final rule should be promulgated 

prior to further action on refueling controls because the 

choice of RVP affects onboard cost, feasibility and leadtime 

requirements. You also believe that uncertainties about future 

RVP levels make it difficult for manufacturers to comment 

effectively on the proposed new emission test procedures. In 

response, we believe that the interactions which exist between 

refueling controls, excess evaporative emission controls and 

running loss controls, indicate that simultaneous gasoline 

volatility and onboard rules are advantageous and 

well-merited. This approach allows us to take a broader and 

more comprehensive view of both vehicle control and fuel 

control in the overall solution of the emissions problems to be 

dealt with. 

Thank you for relaying your concerns about the SNPRM to 

us. Please feel free to contact us again if further discussion 

is necessary. 

Sincerelv, 

Don R. Clay 

Acting Assistant Administrator 

for Air and Radiation 

cc: Docket A-87-11 

Docket A-85-21 

TV )-... 13 

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