P.1 

OAR Box 1818 

Prepped by Ollie Stewart 

Document Number: 

53) ll-D-25 

Docket Number: 

A-87-11 

Primed 11/6/2008 3:12:45 PM Sheet 53 of 79 
P.2 

ONE Hui.DPEcrx CONGSISS 

•%J / 

JOHN 0. DINGEIL MiCKlCA-N. CKI.SUJ.;. 

R31- A-vrj'l Q1EGCN 

DE-VMS E iClfll. CM 0 

Jt " SUIll' l MNSAS 

GSWY 5.IC»SlCI VNNESOTA 

RICK BOUCHER VIRGINIA 

JIU COCFIR. TENNESSEE 

THOMAS A. LUI £N. OWO 

0OUS WALGRE.N. PENNSYLVANIA 

KC-RWAN I LENT. SEW

 VCR.< 

D A N COATS INO-ANA 

TMOMJkS J SLUE/. JR.. VIRGINIA 

MICHAEL G. OXLEr. OHIO 

D A N SCHAECES. COLORADO 

MICHAEL SILlRAilS. FLORlOA 

MICHAEL F. eJOWtTT. J*l 

CHIEF COUNSEL/STA/* OWtCTOd 

,<£-r . 7-J&-F -7 / /y-o-5 

°H.g. t^onse of 'RcprescntatiDcs 

^DfecommitttE on ©ton-sight and Jnotsrigarions 

of rfje 

Committee on €ncrg? an& Commerce 

©afifjington. B<£ 20515 

ROOM :*2 i 

RAVOUBN HOUSE OF'ICI 8UIOISS 

fHONEtJO") JJJ-AI4I 

ff 

July 17, 1987 

The Honorable Lee M. Thomas 

Administrator 

Environmental Protection Agency 

Waterside Mall — West Tower 

401 M Street, S. W. 

Washington, D. C. 20460 

Dear Mr. Thomas: 

Enclosed for your information are letters I have sent to the 

Vice President, the White House Chief of Staff, the Office of 

Management and Budget (OMB), and the National Transportation 

Safety Board (NTSB) concerning the safety issues relative to 

onboard/volatility rules now pending at OMB. 

As you can see, I am quite disturbed about this safety issue 

and about your agency's consideration of the issue. Regrettably, 

I view that consideration to be inadequate in light of comments 

by the National Highway Traffic Safety Administration and the 

insurance Institute for Highway Safety. The issue will be 

.included in our next hearing now rescheduled from July 27 to 

September 21, 1987. 

I have asked the NTSB to conduct an examination of .this 

matter and expect your agency's full cooperation. 

cc: 

/John D. Dingell 

f

 Chairman 

Subcommittee on 

Oversight and Investigations 

The Honorable Thomas J. Bliley, Jr., Ranking Minority Mer.ber 

Subcommittee on Oversight and Investigations 

The Honorable George Bush 

Vice President of the United States 

The Honorable Howard Baker, Chief of Staff 

The White House Office 
-&*• _ 

The Honorable Lee M. Thomas 

Pdge 2 

The Honorable Diane K. Steed, Administrator 

National Highway Traffic Safety Administration 

The Honorable James E. Burnett, Chairman 

National Transportation Safety Board 
P.4 

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-H.£. House of Utprcsentattoes 

gotaranrirtn on ©wrjigtit nut Jittutigations 

of the 

Committee on Cnergp and Commerce 

fltafftingtott, B C 20515 

•OOM 1)11 

AATIUM -OUJI :>XCI KOiHC 

.10*1 IU-4I4I 

July 14, 1987 

Mr. Kerley LeBoeuf 

President 

National Association 

Convenience Stores 

1605 King Street 

Alexandria, Virginia 

Dear Mr. LeBoeuf: 

of 

22314-2792 

Thank you for your July 10, 1987 reply to my letter of June 

19 concerning your Association's efforts to foster onboard 

controls in California and nationally as a means to halt imposition by the States of Stage II vapor recovery controls in ozone 

nonattainment areas. Your reply was quite helpful and, as you 

noted, candid regarding your motivation. 

I also appreciate your providing some indication of the 

scope of your membership. I observe that 12 of your members "own 

more than 500 stores" which amounts to more than 6,000 stores by 

those 12 firms, assuming you mean that each firm owns more than 

500. I assume these firms include the Southland Corporation 

which owns the 7-Eleven stores and others. I would be interested 

in knowing what portion of the total membership, including the 12 

members with more than 500 stores, own gasoline outlets as part 

of those stores. 

I stress that I am not an advocate of nationwide Stage II 

controls, nor, as my good friend Vic Rasheed knows, a fan of such 

controls on a State-by-State basis. But several States committed 

to the Environmental Protection Agency (EPA) to those controls in 

1979 and 1982, apparently without any opposition from your 

Association or others. They must now comply with the law. 

Further, as Mr. DiBona knows, I do not find it useful for one 

industry or business group to argue "not me" when it comes to 

pollution controls and seek to foist the problem onto their 

sister industries or business groups. As you know, in the case 

of ozone nonattainment, there are fewer and fewer major sources 

of ozone precursors to control. The Environmental Protection 

Agency and the States must turn to many small sources like 

bakeries, wineries, aerospace, dry cleaners, plastic parts 

coating, metal rolling, wood furniture coating, auto-body 

finishing, and many others to'obtain the needed reductions. I 
P.5 

Mr. Kerley LeBoeuf 

Page 2 

feel certain 

they must be 

controls. 

these entities would not be pleased to learn that 

controlled and that your members could escape those 

I point out that when I made similar points to the American 

Petroleum Institute, its President, Mr. DiBona, initiated 

with the auto industry aimed at resolving this 

discussions are continuing and I understand they 

for the environment, safety, and those other 

want to discuss them with Mr. DiBona. 

discussions 

problem. Those 

are bearing fruit 

industries. You may 

Whether onboard controls are beneficial environmentally and 

an adequate substitute for Stage II controls is a matter that is 

not free from doubt. The enclosed July 2 letter from the 

California Air Board certainly does not resolve that doubt in the 

case of vapors from underground storage tanks. However, I have 

not, as yet, expressed opposition to onboard controls, except for 

the safety concerns of such controls which you, like the EPA, 

appear to dismiss rather cavalierly. 

I note your reference to the April 27 testimony of the 

National Highway Traffic Safety Administration (NHTSA) and EPA's 

draft document. As you note, NHTSA believes that if the safety 

issue is to be resolved, adequate leadtime must be provided. 

However, NHTSA has not agreed that the leadtime proposed by EPA 

is adequate. Moreover, in a June 11, 1987 letter to EPA (copy 

enclosed) NHTSA said: 

As we have expressed to the Environmental Protection Agency (EPA) staff previously, and as we 

testified last month before the House Subcommittee on 

Oversight and Investigations of the Committee on Energy 

and Commerce, we believe that there will be some 

unquantifiable, increased risks of crash and non-crash 

fire associated with onboard controls. However, the 

provision of adequate leadtime could help to reduce 

these risks. 

We do not believe that technological breakthroughs 

are necessary to minimize the risks of increased fires, 

but* in the absence of sufficient leadtime for manufacturers to thoroughly design and test their systems, 

we believe that automobile safety could be degraded. 

Vehicle fires are serious events. Each year, 

about 1,500 vehicle occupants are killed in firerelated 

events. Another 10,000 are injured. Approximately 85 

percent of these are passenger car and light truck 

occupants. The presence of post-crash fires is 

estimated to markedly increase the chances of occupant 

fatality or serious injury. 

= . 
P.6 

Mr. Kerley LeBoeuf 

page 3 

• "••••eSSffiH 'increased ^^of'"^ ^ ^iicS.S'K.V 

:S5ei"Jd*Sit4 ISHHFloSnSIs" end that -th. provision of 

associow.v. . t re du c e these risks," but not 

adeauate leaatime couia »<**F - —_—,— .,«—-., 

nl»r2ssarilv eliraina"te~Them (underlining supplied). NHTSA's 

llltlt asks many questions about the EPA safety analysis which 

have not been answered. 

vehicle fires are not necessarily everyday occurrences. But 

when they happen, they kill and badly injure. You do not have to 

see many to realize that they are horrendous. To me, this is not 

a situation where government (State or Federal) can afford to be 

wrong. Your Association may be satisfied with the idea of trying 

to "balance or compromise between risk and design criteria," but 

I am not and I gather that NHTSA, at least, shares my concern. 

As to the Insurance Institute, your reliance on 

Mr. Potter's November 26, 1986 memorandum and the API correspondence is misplaced. I enclose that safety organization's 

most recent letter to me which I believe supports that organization's concerns. Also enclosed is my recent letter to EPA 

which also includes more detailed comments by the auto and truck 

industry on the safety issue. 

I appreciate your calling to my attention comments by a Ford 

Motor Company representative. I note that the Los Angeles Times' 

article is not a direct quote and you did not provide the 

representative's testimony. I would like to see his total 

comments. As to Ford working on a larger canister, our 

investigation shows that such a canister is not an "onboard" 

system. The canister is only a part of the system and I understand that the talks between API and the auto industry indeed 

contemplate possible use of a larger canister, but not the 

complex onboard system. 

As to the spit-back issue, I agree it is of concern. But 

the concern, as EPA has told our Subcommittee, is not limited to 

Stage II nozzles. 

In closing, I once again emphasize that the safety issue is 

real for ay constituents. EPA has not adequately addressed it. 

It should be "real" for the California legislature and your 

Association as well. Also, I do not believe Stage II controls 

are required nationwide or in many states. However, my views on 

that might shift, in furtherance of the public interest and 

despite my affection for Vic Rasheed, if organizations like yours 

continue to push (for largely parochial reasons) an onboard 

system on a State-by-state basis that raises serious, unresolved 

safety issues. 

Your suggestion about discussions is a good one. You should 

contact my counsel, Mr. David B. Finnegan (225-2927) to arrange a 
P.7 

Mr. Kerley LeBoeuf 

Page 4 

•reasonable time to meet with my staff. I will try to attend as 

well. 

With best wishes 

JOHN D. DINGELL 

Chairman 

Subcommittee on 

Oversight and Investigations 

Enclosures 

cc: The Honorable Thomas J. Bliley, Jr., Ranking Minority Member 

Subcommittee on Oversight and Investigations 

The Honorable Elizabeth Hanford Dole, Secretary 

Department of Transportation 

The Honorable Diane K. Steed, Administrator 

National Highway Traffic Safety Administration 

Department of Transportation 

The Honorable Lee M. Thomas, Administrator 

Environmental Protection Agency 

The Honorable Judith E. Ayers, Regional Administrator 

Environmental Protection Agency, Region IX 

Mr. Brian O'Neill, President 

Insurance Institute for Highway Safety 

Mr. Vic Rasheed, Executive Director 

Service Station Dealers of America 

Mr. George C. Nield, President 

Automobile Importers of America 

Mr. Thomas Hanna, President 

Motor Vehicle Manufacturers Association 

Mr. Charles J. DiBona, President 

American Petroleum Institute 

Mr. Kenneth A. Doyle, Executive Director 

Society of Independent Gasoline Marketers of America 

Mr. Phillip Chisolra, Executive Director 

Petroleum Marketers Association of America 
P.8 

Mr. Kerley LeBoeuf 

Page 5 

Mr. Owen Bieber, President 

United Auto Workers of America 

Ms. Jananne Sharpless, Chairwoman 

Air Resources Board 

The Honorable Newton R. Russell 

Member of the Senate, State of California 
P.9 

AM ItlOUftClft MAID 

.v»to»jn 

M IP 0*1 

iit.iiiaiwt.ti tan 

(lift) UMNO % , , iM f 

duly ti 1M7 

Tht MtAOFlblt Mtwton I . tuiitl l 

Mttber tf tht Sonata 

Stttt Ctpttol, loo* 1011 

Sacrtttnta. CA 11114 

Ottr Senator ftvtit.lf 

Ti.1i IttttP 1a 1n rttponae to /our tutatlant rtgtrdlna 

anootro vapor recover/ control!. Zn eddi t1on, tM i Itttor 

prevldta en update to tht A1r fteaourcea leard'a (Aft!) April 1 | 

.117, tntlyil l ptruinlnf. t t tiliHt n btnttUi rttyltlnt fret 

Itplatentation of onboard vapor recover/ contrail, 

Tha falltwlni aueationi art addrtntd I t tM i Ittttrt 

1. ean tht All achitvt addltltntl ovaparatlve 

tmislen i centre) untor current lot, ant without 

the wit of onboard control t/ltetl f 

2. It 1t ptntll t that inboard Ptfytllnf atliHoni 

control t/attta will bt .ti t tff.dtn t 1n 

cuitoter atrvict than Stigt !! vapor rtcovtr/ 

i/ittna? 

3. would tht uit of onboard rtfutl.nf ttiulo-ni 

control a/iteti increua twmioni Trot 

underground atorago tanki at faiollno itattomt 

4. Cowld thtrt t t t not et1u1tnt Incrttat 

taaoettttd with onboard control i/itctit 

In retard t t citation 1 , AM anticipate! ech1tv1nf 

additional control tf ntn-rtfutllna, tvaptratlvt tiUtltni . u 

•r* dtvelopine, within prtiont atttutor* authority, control 

•ttfttrtt tt lleilt Me m tvaptratlvt ttiaaltni which occur on 

hlfh totptrature tajri. Thtat control ttaiurti would 

ntcttuMI / rtiult I t on merttat In tht lil t tf tht 

evaporative control etnuttr relative t t canlittn etrrtntl/ 

•tint, ttHftt d to control tvaptratlvt ttUHom . The/ would 

not ilUt t 1n tne control tf refutllng atliiloni.* 

•In thlo latter, »ovaptrttlva ttlaHtna - rtftri tt ioaellnt 

which ovtporatta frooi tht vehicle faa tank and ********S*! 

hood luring nanal vthlclt operitiao and iteraee. •••J"! 1" * , 

•••}#•<•«•.• ret-aft te tee |IIAH M vttert 1a ti t Vthltlt • fOOl 

tank which .re ftrctd out at tht tank 1a filltd wit* fuel. 
P.10 

e j f MO N le9:02« M »WW*B'**aaeroim«*»*n* 0 *•• * 

Stnttir lyutl l -I - *' / t» 1117 

Itplottntatltn tf tht tflltsrd rtfuellng caiman 

control ttuipttnt iptclfttd 1R Al 7lf wttld It tut team tf 

achieving tht belle abjective if larptr tveperatfve control 

canlittrt. properly dedfned onboard rtfttllng einlittra would 

it affective 1n capturing refutllng tttstt. Tht/ would Hat be 

tfftctlve it controlling eieeu ovaporatlvt Missions which 

eceur tt high tttperiture day I, Itch a/ittn wtuld alia lin t 

tipeiurt tf tht population tt hii-ifu. btnitnt tHultn i ttltttd 

during refuellne tt ttatltna not otulpped with vapor rtcevery 

(ttaft II) nestles. 

It ftapenae to jutatUn I , wt do »et Itlltvt onboard 

eontPt] systots v/HI It le u effective than atrvict station 

Staff 21 vaptp recover/ eentreli, unon conalttrlng tni/ 

rtfutHnt et1ia1oni, onboard vaptr rtcoter/ s/ittti art 

tftHattd tt It sllfhtl/ tore efficient 1o capturing refueling 

tuitions than staff 22 vaptr rtttvtr/ syattie. This, 

projection 1i baaed on mftraatltt frot prttftypt enlttrd vapor 

recover/ s/itewi and current tvaptratlvt t»1talon contra! 

i/itati , which Indlcatei that onboard vapor recover/ tystttt 

would fenerall/ have a iHthtly hlfhtr tffltltney 1n tuctater 

strvlet (III) conpartd tt Stage It vapor Ptetvtr/ system (lot 

to 92%)* Tht eititited efficiency for onboard vapor recover/ 

etnlittrs. however, doet net takt into account tht potential 

increaie 1n undtrfptund lervHe i tat ten iterate tank ttlmoni , 

which 1s dlscusattf ntit. 

In rtsptnit tt tueitlen I , itpletentatUn tf tnloard 

vaptr recover/ cenlatera would reiult in tt Increaie 1n 

eiriealona frot) underground atorago tanki at lervlce itatloni 

which currently utlUtt Ittft 22 vaptr recovery controla. 

Theae 'breathing loaata* occur btctust tht vtptra In the 

vehicle fuel tank are captured ot tht vehicle and thus are net 

returned tt tht strvlet atatlon underground atorago tank. The 

mcrteao would I t ele-ut I torn ptr day tf h/drecirbeni m the 

Sttth Coaat A1r Itiln , Thtst etiisloni vtry only sllfhtl/ with 

Stift U systtt efficiency. 

Plttit nttt that API4i analyaU dtttd April 11, 1117, 

did ntt comltor tht increaie 1n underground storage tank 

et1ii1en». 

« 

Tht rtsptnst tt tutttlon 4 dtptndi tn which 

vt end refueling controls are edopted and 11 

tne ?nw wf fttt l Vtntll tf tllltlftf ItrvlCt Itttlt i Stl f - . . 

vopor recovery controla. Aa indicated aleve, the effectiveneu 

Tht rttptnst tt tutttlon 4 dtptndi tn which 

tveporatlvt end refueling control I are edopted and lapletentcd, 

and tht effectiveneu tf eilitlna itrvlct atatlon Stipe 22 

vopor recovery controla. Aa indicated Aleve, the effectiveneu 

tf Stage It contrail can vary fret) II I tt lit , dtptnilftf 

largely tt lev wt11 tht prtfrea) l i enforced ly local sir 

pollution control tffldtle . it Mot aaauted %n tvereft itift 

11 offtctlvtneaa tf III , tut alio preottt ttr •{•Iffls ftr an 

eitraatli well enforced Itott 2! tretrae. which la li t tfftetlvt. 
P.11 

i 

Itnstor lautll •!• •' -Jvly t, lit? 

I MP analysis 1s tuatiMitd It tht ftlltwlnf Table. 

(Ottalli art prtsinttd 1ft tht attachtent.) If, se planned. Alt 

adapts within tht nu t few ytara, POfulrotenti ftp tore 

tfftctlve avaperatlvt control (non-rtfut11ft|) tysttit, vt 

tstUatt hydrocarbon tttssltnt will it reduced by I tt 40* tut 

ptr day (tpd) m tht stuth Ctsst Air latin. If tht Lttuiiturt 

oatabHahts a rttulrtttnt for onboard rtfvf.1n| ctntrtis, 1n 

which cast nan.refueling tvspppstlvi Missions would alio bt 

ttntPtlltd, ttiaaitna would Hi t It reduced 1/ 1*40 tpd, if M 

auute the South eoait A1 P Quality JUAiiMtnt UstPtct has m 

place en average level of tnforctttnt of current service 

itatltn Stage II vapor control etulpacnt. Our rtetnt 

•valuation sf tht tnftrctttnt proprat tf tht Stuth Ctsst Air 

Qualtly Management Olatrlct 1hd1catea 1t Its ouch better than 

average enforcetant tf atrvict atatltt vaptr aentrol atuipaent, 

thus the eaimon i reduced ly an tnbotrd rtqulrttant would bt 

about I tpd 1 tat. (Thli oecura bocauit thtrt are fewer vapori 

eaeapma the aervlco ititlon Stage 22 netxlea which can be 

captured by onboard control si however, tht InePUie 1n 

undtpfround itorife tank breathing taissfths retalnt 

eaatntlally the iate.) 

mu 

Sal talon Reductions Achievable with Onboard Rofuelinf 

Centre! Coopered tt laprovod evaporative Control 

(South Coast A1r laals - yeor 1000) 

Scenirlo HC CtHelon Seduced, tpd 

1. Itproved Cvoporttlvt Control m sm 

hot days (All reflation) 1*40 

!• Onboard lefuelinf Ctntrtli 

(Al 7ft), euutlng averafe 

tnforcetent tf strvlet 

ttttltn vapor control! I-4Q 

I. Sate eo II above, tictpt 

taautlnp eicellent 

tnforcetent of ttrvlct 

etetlon vopor control I. I-'7 
P.12 

«•-» • " • ' 

Ithtttr futial! •4* * V ». US7 

I Mat that thli Ififiraitttn *111 la helpful in nur 

aaatsiatnit af I I 711. Mtist feel free tt rtqutat any t 

addltltnal mforaattan ytv at/ reguire. 

j/ninne Ihtrpltts •' V 

Ci/1rwo»an 

f^^-P»^ 

Attachaont 

cci Tht honorable bilH e Irown, *)r, 

Sptaktr of tne Asatably 
e)T-e*-e) T MO M i e it4e n MWK«R^ S I «. *- a 1*1 X 

CilcuHtlen wm M llntfltl 

I. uutei 

ktP|tP canliten will control 1-40 tpd tf NC taitaiona 

which occur aa hot asys ttt are ttt Itinf captured by 

tha tvaptratlvt control systta Itstallad tn til pocent 

cere, deference 1) 

Stige 22 tervlee ititlon noiiloi capture frot 10 to 

fit of refuel 1n| aalulom . deference t) 

Onloard controls trill capture vapori which oaeape 

control ly current ltt|t 21 tyatett. deference 1) 

Underground storage tanks «111 M1t NC t when tht 

diapltctd faaoHnt 1 I ttt ropleced with uturatod 

gaaonne vapor (at would occur 1f tit veptra i t tht 

nearly oapty venule fttl took are dlaplaced during 

refueling to en onloord ccnlsttr Itttttd tf rtturntd 

by tna Stipe II systea to tht itrvlct itttlon 

underground itorego tank). 

I I . Uleilon Reduction! free. Onloord Control Syattat 

Mjflll Hilt H pjfUlo 

1. Onloard eentrola capture 

etiiHoni which ticapt stage 

2 2 cantrtlefe gnttrground tank breethlng 

louei (• attns Increaie) 

I, Tttal refueling et1ai1ona control 

(• aeons mcreeio) 

4, OnloePd control tf htt dey 

tvtptritlvt taliHom 

I. aat Ptductlon in ttusltns 

I 

I 

40 

40 

I 

I 

40 

37 

Referencei 

1. K.O. Orachahd. A1 A1Pr ftttturees RtSturees Itara leerd., t tat Ta T Mt cattaiia Ctckottt., ;' A1r j 

Itstupcts Iterd. *levlitd Incrtaattil Itntflt A»s1ysls for Onboi 

Refuel1nf Ia1ii1en Ctntrti 1n Ctl1fara1t\ April 13, 1107. 

f. A1P 

S/iteti 

ro l-TTT" 

ItiturctS Itert, teetrt t i taiellee faoor 

ii7ran*nxiiL»inirn«ttfTTii a 
P.14 

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T - • • • 

- 0 T WO, 

cr a m • n i 0 

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P.15 

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"We.** I Jtr Hfw TQM 

OM C3«M eouwu 

•MjMii j IUI.IT 0 yerunu 

«<n*.||, 5 3H.1T >«Q 

OMiKJutf-m. CXOMOQ 

H:3 . House of "Rrpruaitattocs 

gtbrwfflftta on @^eriigjtt and lircutigattonj 

o( rfje 

Cesimittte on Cnerg? and Commerce 

«ait)ington. B C 20515 

June 24, 1987 

The Honorable Elizabeth Hanford Dole 

Secretary 

Department of Transportation 

400 Seventh Street, S. W. 

Washington, D. C. 20590 

Dear Madam Secretary: 

Enclosed is a copy of my letter 

Protection Agency (EPA) concerning, 

consultations over regulations and r 

vehicle industry. I am deeply conce 

the EPA have not established a reaso 

ensure that actions and rules affect 

industry are totally consistent with 

environmental and fuel economy laws 

industry. There is nothing in any o 

such a process and I believe that th 

it. I strongly urge that you, Mr. L 

and Mr. Ray Barnhart initiate an eff 

process immediately. Please keep me 

beginning 30 days fr^m the receipt o 

With best wishes. 

to the Environmental 

among other matters,. 

ules affecting the motor 

rned that your Department and 

nable non-dilatory process to 

ing the motor vehicle 

ail the safety, 

applicable to this regulated 

f those laws that precludes 

e public interest requires 

ee Thomas, Ms. Diane Steed, 

ort to establish such a 

informed of your progress 

f this letter. 

cc: The Honorable 

Subcommittee 

'John D. Dingell 

Chairman 

Subcommittee on 

Oversight and Investigations 

Ncrman F. Lent, Ranking Minority Member 

:-. Oversight and Investigations ] 

The Honorable T: 

Subcommittee ~.~. 

and Hazardous 

cr-tas A. Luken, 

Transportation 

Mater ials 

Chairman 

, Tourism, 
P.16 

V " ^ ^The Honorable Elizabeth Hanford Dole 

Page 2 

T M Honorable Bob Whittaker, Ranking Minority Member:. 

iubcc«ittee on Transportation, Tourism, 

and Hazardous Materials 

The Honorable Henry A. Waxman, Chairman 

Subcommittee on Health and the Environment 

The Honorable Edward R. Madigan, Ranking Minority Member 

Subcommittee on Health and the Environment 

The Honorable James C. Miller III, Director 

Office of Management and Budget 

The Honorable Lee M. Thomas, Administrator 

Environmental Protection Agency 

The Honorable Charles A. Bowsher, Comptroller General 

General Accounting Office 

The Honorable Ray A. 9arnhart, Administrator 

Federal Highway Administration 

Department of Transportation 
P.17 

*-» . 

<**. erreeei OMfll!* 

suae* C KIA*T OMO 

.IM u>rri**» UMJUl 

•JCIMUO-I* »**»*•» 

..<* zooms rvemttn 

" netil *. lui M »• * 

OCM WHOM . I Ummv'*»»» 

HOUim . LOT <e|W TOM 

CkMtCOaTt MOUM 

-»OeULe J WKf A. •*•**•»» 

«MA l 3UJT OHO 

H.J5. ftowt of Krpracntatitjci 

^tbiiiuoiiiuu M 9vtrRjjttt aid Imurigatiimi 

o( tfte 

Committee on Cnergp anb Commerce 

•Jiljincjtan, S C 2051 5 

June 23, 1987 

The Honorable Lee M. Thomas 

Administrator 

Environmental Protection Agency 

waterside Mall — West Tower 

401 M Street, S. . W. 

Washington, D. C. 20460 

Dear Mr. Thomas: 

This supplements my letter of May 8, 1987 concerning ozone 

nonattainment and related matters discussed at our hearing of 

April 27, 1987. 

Enclosed is a copy of a June 11 letter 

Highway Traffic Safety Administration (NHTSA 

the Environmental Protection Agency's (EPA) 

Redborder rulemaking now pending at the Offi 

Budget (OMB). Further comments are to be ma 

expected by this Subcommittee) after the rul 

is initiated. The letter certainly shows a 

concern by NHTSA about onboard controls and 

of the controls than has been evidenced by t 

to date. The letter also provides a discuss 

burdens that the foreign and domestic motor 

deal with in the remainder of this decade. 

demands placed on the resources of the indus 

wide variety of entities. In my view, that 

the iceberg considering all of the final and 

by NHTSA and EPA that must be implemented by 

earlier. Not all of them are mandated by Co 

cases, lead time, at the very least, can be 

NHTSA states: 

from the National 

) to you concerning 

"draft" proposed 

ce of Management and 

de by NHTSA (and are 

emaking, assuming it 

greater safety 

about the complexity 

he Federal government 

ion of the regulatory 

vehicle industry must 

It discusses the 

try, which includes a 

is only the tip of 

pending rules issued 

model year 1992 or 

ngress. In all 

crucial. 

... we believe that there will be some unquantifiable, increased risks of crash and non-crash fire 

associated with onboard controls. However, the 

provision of adequate leadtime could help to reduce 

these risks. 

We do not think that technological breakthroughs 

are necessary to minimize the cisks of increased fires, 

but, in the absence of sufficient leadtime for manufacturers to thoroughly design and test their systems, 
P.18 

The Honorable 

Page 2 

Lee M. Thomas 

we believe that automobile safety could be degraded* 

Vehicle fires are serious events. Each year, 

about 1,500 vehicle occupants are killed in firerelated 

events. Another 10,000 are injured. Approximately 85 

percent of these are passenger car and light truck 

occupants. The pcesence of post-crash fires is 

estimated to markedly increase the chances of occupant 

fatality or serious injury. 

The idea that the Federal Government is planning to propose 

regulations that will result in "some unquantifiable, increased 

risks of crash and non-crash fire associated with onboard 

controls" boggles.the mind. It is not, in my view, consistent 

with the safety laws administered by the Secretary of 

Transportation through NHTSA. Indeed, the onooard issue, the 

volatility issue, the Ford ambulance issue, the Colorado 

oxygenated fuel issue, and the heavy duty diesel engine issue all 

raise questions about the extent to which your agency and NHTSA 

coordinate to ensure that regulations issued and actions taken by 

EPA and NHTSA do not create safety, emission, or fuel economy 

problems. 

The Clean Air Act, of course, spec 

NHTSA's safety laws) that EPA standards 

design, standards and that, in the case 

must consult Secretary Dole on safety i 

understand, however, that the failure o 

expressly require consultations in othe 

importance or need for them, particular 

regulating the same industry and are pa 

branch. Clearly, these laws do not pre 

The fact that the regulated industry or 

issues directly with EPA or NHTSA is no 

from the public's standpoint, particula 

recall after the fact and after possibl 

injuries. I request an explanation abo 

coordination between your agencies rela 

actions affecting this industry and the 

environmental impact. How, and to what 

consultation regularly provided? 

ifically provides (as does 

are performance, not 

of onboard controls, EPA 

s sue s. I do not 

ri E?A or NHTSA statutes tt 

r areas obviates the 

ly where both agencies are 

rt of one Executive 

elude such consultation. 

others do not raise these 

t necessarily comforting 

rly if the sole remedy is 

e fatal or non-fatal 

ut the extent of 

tive to proposed rules and 

ir safety and 

extent, is such 

The attachment to the enclosed NHTSA letter raises a number 

of significant safety questions. I request your reply to each of 

them. 

Your May 20 letter to me responds to my April 6 letter 

regarding the legality of Colorado's mandate of oxygenates in 

gasoline for carbon monoxide control. Cn June 12 the Center for 

Auto Safety wrote to you about the safety implications of the 

Colorado action (copy enclosed). Please provide a copy of your 

reply to the Center, as well as a copy of your study of the 
P.19 

- * 

The Honorable Lee M. Thomas 

Page 3 

* 

relevant loqol Issues, will NHTSA be consulted about this 

matter? 

r request EPA's response to these matters as part of your 

reply to my May 8 letter. Please provide a copy thereof to the 

General Accounting Office. 

With best wishes. 

Chairman 

Subcommittee on 

Oversight and Investigations 

Enclosures (2)j 

cc: The Honorable Norman P. Lent, Ranking Minority Member 

Subcommittee on Oversight and Investigations 

The Honorable Thomas A. Luken, Chairman 

Subcommittee on Transportation, Tourism, 

and Hazardous Materials 

The Honorable Bob Whittaker, Ranking Minority Member 

Subcommittee on Transportation, Tourism, 

and Hazardous Materials 

The Honorable Henry A. Waxman, Chairman 

Subcommittee on Health and the Environment 

The Honorable Edward R. Madigan, Ranking Minority Member 

Subcommittee on Health and the Environment 

The Honorable Elizabeth Hanford Dole, Secretary 

Department of Transportation 

Tht Honorable James C. Miller III, Director 

Office of Management and Budget 

The Honorable Charles A. Bowsher, Comptroller General 

General Accounting Office 

The Honorable Diane K. Steed, Administrator 

National Highway Traffic Safety Administration 

Department of Transportation 

The Honorable Ray A. Barnhart, Administrator 

Federal Highway Administration 

Department of Transportation 
M I |C." 

The Honorable •>•

 M« Thomas 

Administcatoc 

Environmental Protection Agency 

401 M Street, 9N 

Washington, DC 20460 

Dear Mr. Thomas: 

Thank you for providing the opportunity to review your "draft" proposed 

rulemaking on onboard controls of refueling vapors. We commend your staff 

foe their efforts to provide helpful review and analysis in the rulemaking 

documents of the various complex safety eeeues surrounding these control 

systems. 

These comments represent the Department of Transportation's views on the 

safety of onboard hydrocarbon control technologies and on the safety aspects 

of the rulemaking envisioned by EPA. We ace writing in response to your 

request to consult with us as required by Section 202(a)(6) of the Clean Air 

Act, as amended. Of course, since these DOT conments are submitted at an 

early stage in your rulemaking process (prior to publishing a formal proposal), 

we do not yet have the benefit of views from the regulated industry or other 

interested parties on the specific details of an EPA requirement in this acee. 

We believe the views of those parties ace essential foe DOT to evaluate the 

safety of actual, intended production systems, and foe us to offer sore 

definitive opinions on matters such as leadtime. Thus, out comments should 

be regarded mm tentative, and we request the opportunity to consult with you 

again after the close of youc public comment period. 

As we have expressed to the Environmental Protection Agency (EPA) staff 

previously, and as we testified last month before the House Subcoamittee 

on Oversight and Investigations of the Committee on Energy and Commerce, 

we believe that there will be some unquantifiable, increased risks of crash 

and non-crash fire associated with onboard controls. However, the provision of adequate leadtime could help to reduce these risks. 

We do not believe that technological breakthroughs are necessary to 

minimize the risks of increased fires, but, in the absence of sufficient 

leadtime for manufacturers to thoroughly design and test their systems, 

we believe that automobile safety could be degraded. 

Vehicle fires are serious events. Each year, about 1,500 vehicle occupants 

are killed in fire-related events. Another 10,000 are injured. Approximately 

85 peceent of these ace passengec cac and light truck occupants. The presence 

of post-crash fires is estimated to markedly increase the chanoes of occupant 

fatality or serious injury. 
P.21 

Addition*l1 sssmats ot ** •« « - ^ ^ eeeewit. o» 

, op. our ee—nt. .« «-«*•-' 

*•

 W| W • Sincerely* 

Original Signed ty 

Diane K. Steed 

Enclosure 
Qaneral QQT Staff Comments cn Iaa\iaa i n Safntv Aan-ffnTffl-ant 

In discussing the issue of possible overpressurization of the fuel system 

during refueling. EPA believes that the simple Liquid Seal solves all of 

the potential problems of the Mechanical Seal. What is the vapor control 

efficiency of tht Liquid Seal? It is probably lower than the mechanical 

seal. How does that [lower] efficiency affect the benefit comparison with 

Stage II controls? Does filler neck length have to be increased 

substantially for a Liquid Seal? That could have safety implications. 

It would appear that manufacturers have hardware alternatives, sur-h as 

simple add-ons to current evaporative emission control systems that could 

lower current crash safety levels; such as system redesigns and/or 

reconfigurations that could maintain, decrease, or improve current crash 

safety levels; and such as internal fuel tank bladders thtft could improve 

current crash safety levels. All three options could affect non-crash 

fires, but EPA is in the best position to determine that through their 

testing and evaluation programs for onboard vapor controls. Non-crash 

fires could arise, for example, in a high ambient temperature if the 

carbon cannister is "loaded" too fast, or if Internal system overpressure 

results in an unintended fuel and/or vapor leak. 

The alternatives which offer a better prospect of safety improvement, such 

as system redesign, reconfiguration, or bladders, would require more lead 

time than simple add-ons. 

Deterioration of vapor recovery systems would cause an increase in 

emissions, but would it cause any decrease in safety? Safety must be 

considered for the entire vehicle life, approximately 15 years. The 

50,000 miles typically used for emission systems is not long enough. Does 

system deterioration create any operator incentive for maintenance? If 

not, they will not be maintained ajf, all and safety could be adversely 

affected. 

« 

What about fuel systems that are replaced or repaired after failure or 

malfunction or after a collision? Is there any incentive to leave out or 

improperly install some of the components as a less costly repair or as a 

repair timesaver? Are there any critical components, such as valves or 

seals, where damage is not easily detected or where damage can be ignored 

by the repairer? Are there any critical clearances where an improperly 

rerouted hose or line could reduce safety? 

Is there any data on the efficiency of emission and/or evaporative systems 

in much older cars [e.g., 10-15 years]? Is there any data in areas 

without any swrintenance or periodic inspection requirements? 

In discussing the design of a rollover valve to fail in the closed mode, 

it was stated.that this was a "safe" mode because it would block the vent 

and make refueling difficult, thus providing an incentive for the operator 

to repair it. What pressure build up hazards might arise if the valve 

failed during operation of the vehicle? 
To help protect occupants against the incidence of post-crash fires,.this 

agency has issued Federal Motor Vehicle Safety Standard No. 301, fuel System 

Integrity. This standard limits the amount of fuel leakage allowed after 

the regulated vehicles are subjected to front, rear and side crashes and a 

rollover test. Regulated vehicles are all vehicles (except motorcycles) 

with a Gross Vehicle Weight Rating (GVWR) of 10,000 lbs. or less, and all 

school buses (of any weight). Heavy trucks and heavy buses other than 

school buses are not subject to this regulation. 

While FMVSS No. 301 has been effective in significantly reducing post-crash 

fires, by itself it can not protect against all situations in which a fire 

could occur. First, our standards are minim'jn performance standards and 

offer protection only in the crash configurations specified. Second, the 

standard regulates only leakage of liquid fuel — it does not address the 

possibility of fire as a result of ignition of fuel vapors. Third, 

the National Traffic and Motor Vehicle Safety Act requires manufacturers to 

be responsible for the recall and remedy of any of their vehicles found to 

contain any safety-related defect, including any defect not related to aspects 

of performance covered by our safety standards. Manufacturers seek, through 

extensive testing during the design phase (beyond that required by FMVSS 301), 

to try to avoid designs that will develop defects. Thus, manufacturers 

require adequate time to design (or redesign) fuel systems which minimize the 

extent of crash, and non-crash, related fires. 

we believe that the addition of onboard controls will increase the complexity 

of the fuel system. In turn, this complexity, absent countervailing efforts 

by the manufacturers, could increase the risk of fire. We say this because 

the most cotnnon forms of possible compliance appear to include more complex 

valves, wider diameter vapor lines, and larger vapor canisters. As 

complexity increases, so does the possibility of something going wrong. 

Similarly, the larger surface areas of the vapor lines and canister, by 

themselves, increase the possibility of puncture and hence fire. Also, to the 

extent that fuel tanks and/or fuel lines are recontoured or rerouted, 

additional work is required to assure adequate safety. 

EPA's assessment of this issue in the document entitled Safety Implication 

of Onboard Refueling Vapor Recovery Systems, recognizes and addresses these 

risks. Your analysis contains, for example, estimates of the costs and time 

required to maintain the current safety level. Our staffs agree that any 

increased risk can be minimised with the provision of sufficient leadtime. 

However. \m have serious concerns over the amount of leadtime your staff 

believes is sufficient. 

L 
EPA estimates that two years of leadtime with a possible effective date of 

September 1. 1989, is appropriate. We have two concerns with these estimates. 

First, we do not believe two years is adequate leadtime. When Standard No. 301 

was list amended, the agency generally provided 2 1/2 to 3 1/2 years leadtime. 

Most of our regulations, including far simpler ones, provide at least 2 years 

leadtime and, recognizing the complexity of automobiles, often provide 3-5 

years leadtime. For example, our passive restraint regulation provided 5 years 

leadtime, with a phase-in period beginning 2 years after the rule was issued. 

A pending proposal to amend our hydraulic brake standard would allow 5 years 

leadtime and a recent regulation requiring the use of a new test dummy also 

provided S years. 

Our second concern, which relates to both the time required for implementation 

and a September 1, 1989, effective date, is that manufacturers' test 

facilities, as well as their safety engineering resources, are currently 

being strained. Manufacturers are currently conducting extensive crash 

testing to implement the requirement that passive restraints be included 

in all passenger cars by September 1, 1989 (that standard requires a barrier 

crash of a vehicle). The plans of the auto companies to install driver side 

air bags, a device with which many cotrpanies do not have extensive experience, 

will result in even more of a design/testing burden than probably would be the 

case with the provision of automatic safety belts. 

Similarly, the requirement to use the new Hybrid III test dunny by September 1, 

1991, is resulting in still more crash testing. NHTSA also has 

pending a requirement that light trucks and vans (under 10,000 lbs. GVWR) be 

crash-tested to provide occupant protection starting September 1, 1989. 

(Testing would precede that substantially.) Although that effective date may 

be extended, it will still result in yet an additional workload during the 

next few years. Manufacturers have provided conments to our dockets stating 

that their facilities and resources are being taxed. Ford, for example stated 

that the requirement for light truck dynamic testing alone will result in 775 

barrier tests, or 3 1/2 times the current test workload. Also, NHTSA has 

announced that it plans to issue an NPRM this summer which would require crash 

testing to improve side impact protection. 

We point out the above to advise you of our assessment of the industry's 

testing burden. While a phase-in of onboard controls would somewhat alleviate 

the problem, a "front-loaded" requirement as is being suggested (e.g., 70 

percent cce-pliance beginning two years after a final rule) would appear to do 

little to ease manufacturers' problems. We urge EPA to specifically consider 

these burdens in assessing appropriate leadtime. without having knowledge of 

the specific technologies manufacturers would employ, we are unable to advise 

you, considering current manufacturer safety workload, what, precisely, 

adequate leadtime would be. Should EPA issue an NPRM, we would, of course, 

assist you in further addressing these issues after conments are received. 
FtiVSS '301 for all other venicies. . 

at anv point and angle. Depending on the design and location of tne tan-* 

and its protective structure, a number of tests could be required to 

ascertain the "worst case" for a new or significantly redesigned model. 

Only after such a "worst case" was determined, may it be possible to do a 

"single" test. : 

In discussing tha Motor Carrier Safety Regulation that fuel tanks over 25 

gallons must accept fuel at a rate of 20 gallons per minute, a rate not 

uncommon for diesel fuel dispensers, EPA notes that the "DOT/BMCS" have 

expressed a willingness to consider changing this requirement to apply 

only to diesel fuel tanks. What are the vapor recovery plans, if any, for 

diesel fuels/vehicles? What will EPA do until OMCS acts to change their 

regulations for gasoline fueled truck tanks? How long will OMCS 

rulemaking take? What if they don't act? How does this situation affect 

overall vapor recovery lead time [and benefits]? 

Many large fuel tanks on trucks and tractors incorporate a whistle to 

indicate when the tank is full. Does fuel vapor escaping from the whistle 

preclude such designs? 

Motor Carrier Safety Regulation Part 393.67 requires a safety venting 

system and an air vent. The procedure for the safety venting system test 

specified in the regulation is to apply an enveloping flame to the tank. 

Since many different fuel tank configurations are used for HDGV's, 

recertification may be more difficult than anticipated by.EPA. Other 

means to demonstrate compliance may have been employed by the vehicle and 

by fuel tank and component suppliers, but the prescribed flame tests are 

time consuming and require special considerations for the safety of 

testing personnel. 

In discussing lead time, EPA believes that vehicle and component tooling 

actions can occur simultaneously with development or certification. Crash 

testing involves a complex interaction of many different parts of the 

vehicle, and certification testing is usually done on v^ry accurate, 

near-production prototypes. In addition, sin'ce a number of FMVSS's 

require crash tests, manufacturers must coordinate development and 

certification crash tests on their scarce and expensive prototypes. While 

some risks are unavoidable, manufacturers may be unwilling to include 

systems which are not fully developed in their prototype crash tests. 

Thus, much of the FMVSS 301 testing may have to be done sequentially, as 

opposed to concurrently. 

On page 26 EPA tries to put the fire problem in perspective by arguing 

that only 0.1 percent of vehicle crashes result in a fire. EPA concludes 

that "vehicle crash fires are uncommon events." Although the numbers are 

correct, thtlr conclusion is subjective. The 0.14 percent of crashes they 

cite resultt in more than 20,000 crash fires annually (for passenger cars 

alone) involving 1000 fatalities and 6000 moderate to serious injuries. 

When viewed in an absolute sense, it is doubtful whether the problem can 

be characterized as "uncommon," or not serious. 

EPA's example on p.50 of how manufacturers manage safety concerns uses 

IIHS' bumper tests as an example of different performance levels. 

(However, the bumper tests, and the bumper standard, are little related to 
In discussing moving the vapor cannister away from potential sources oi 

ignition and/or tampering, EPA suggests an underbody location. Can the 

cannisters purge properly at the temperatures of the underbody, as opposed 

to the elevated temperatures under the hood? How does that affect system 

size/design/cost? »* 

In discussing tha possibility of pre-refueling overpressure effects. EPA 

suggests that a small hole could be made in the J-tube of the Liquid Seal 

to allow fuel to drain from the tube and still provide a refueling seal. 

This could only work if the entire tube were above the level of the fuel 

in the tank. With this design, and the liquid "head" needed to mai.-.tain a 

vapor seal, doesn't that make packaging [size/height] extremely 

difficult? How would •'overfill" be prevented in such a design, such that 

the level of fluid in the tank were always below the level of the drain 

hole? If the fluid level is above the drain hole, what would happen? If 

the drain hole were plugged by a piece of dirt or other foreign matter, 

what would happen? How large is the drain hole [i.e.. Could it be easily 

plugged? Is more than one hole needed? Can a sufficient seal be 

accomplished with adequate drain holeCs]?]? Has a Liquid Seal with 

adequate drain hole[s] been tested for.vapor recovery efficiency [i.e., 

Could that change the benefit calculations?]? 

In the EPA analysis, it was noted that GM is currently using external 

vapor vent lines on some fillpipes, a design that GM had characterized as 

an unacceptable safety risk in 1978. However, EPA does not address the 

possibility that this design change was made only after several years of 

actual, empirical field experience with the older design[s]. This could 

affect the design/leadtime issue. 

In a section on Opportunities for Improvement EPA has a list of fuel 

system/vapor recovery design features which they believe could actually 

improve safety. Many of these are rather major changes to the vehicle 

fuel system, which could mean longer lead times. 

EPA notes that BMCS requirements apply to all "HDGV's over 10,000 lbs. 

GVWR. It should be noted that Motor Carrier Safety Regulations only apply 

to those HDGV's used in Interstate Commerce, although other HDGV's may 

[voluntarily] comply with those regulations. 

In discussing the Motor Carrier Safety Regulations, EPA notes that 

virtually all HDGV fuel tanks are "frame mounted" [and thereby not 

subjected to any impact (i.e., "drop") tests - only a safety venting test 

and a system leakage test]. While this makes lead time less critical, it 

does little to assure the crash safety of onboard vapor controls for 

HDGVs. At ltaat a "side mounted" fuel tank, although apparently rarely 

installed, does have to meet a drop test on one corner of the tank, from 

30 feet, onto an unyielding surface. An additional drop from 10 feet, 

directly on the fillpipe, is also required. No such tests are required 

for the "frame mounted" tanks. 

In characterizing FMVSS 301 for school buses over 10,000 lbs. GVWR, EPA 

states that it is a single barrier test which-does not include a 

rollover. While it is true that no rollover is required, FMVSS 301 for 

large school buses requires impacts with a qontoured moving barrier [a 

rigid fixed or a flat moving barrier, as in FMVSS 208, is required in 
P.27 

It 

me or 

and 

,-«. -. • hat. safety concerns can be eliminated, 

siUt*.> Wf-16 EP A V^\\ l relate this "desire- to either Led tt 

desired!- the paper f.il 5° £* £ . „Utlon, then, both leadtt.. 

U U - ."'pr& K

 S siinl"-" y more then EPA estimate,. 

cost ere pr ^ b < J 3 pe r 

On p.65, EPA •«*-«!**" ^.fjhl i estimate ia baaed on 4 testa. This 

Sod? line/strl*- *•*•*.?-?£

 th & . typical frontal teat .1 

eatimat. .«»?_««!"-Li 0 " a «

T S r the vehicle. Given tha 

Lone costs 

estimate seems extremely i«- •••- -:- vehicle . Given that FMVSS 301 

STltSSS? not including the cost o«!ion» . « d that expensive prototypes 

requires protection in all

 f

c ^/b ~Subat antially more than EPA estimates. 

might be tested, the costs couia „.,-„„ , 

a c «««••>,« >r* necessary to deve-op and 

On leadtime, EPA argues that only

 4"* ^^Hturer s have already begun 

oStimtse working Prototypes since many ^nufactur ^ t penalizes 

wirk on the }««•• /lels-ir ^sources who have been awaiting «ormal 

those companies "" * i*";r f^'m s unfair to subtract from the required 

government action. Second, it »«•»» t voluntarily on the 

leadtime the time that companies may have *£«) rul e is l99U6d. It is 

on5yealthLatatire%hrmlnbufarturers know exactly what is required of 

them. 

E P A also atatea th"-""^L^onduct.d'si^UneoulS^s'tr . v.,, 

optimisation, and tooling can oe «w« " t eonduetinf 

rf»ky »""»^ionf .J°tes ttn« .PPeaMto entafl'great financial risk to a 

dUr*fii!S.r* "ctuding or "a^le . running nultlpl./«»curr.nt 

:£.rn.t".%ro.ra£s for th. sa*. vehicles. 
CENTER FOR AUTO SAFETY 

MOiSsmeT.NW SUITHIO WASHINGTON, oc 20009 203.331.7700 

N E W S 

P.28 

Release: FRIDAY AM's 

June 12, 1987 

tor ra«ir<* infnrnution*. 

STAT E QiYGENATED FJ1£LS tfAUAAILS £flS£ 2AEU I 4 HEALTH HAZAAD 

The Center for Auto Safety (CAS) today urged EPA and the Colorado 

Air Quality Control Commission not to adopt proposals in Colorado and 

other states requiring all motorists to use oxygenated fuels, such as 

ethanol and methanol blend gasoline. CAS said such plans would: (1) 

lesd to more vehicle fires from overpressurized fuel, (2) csuse 

widespresd driveability problems including stalling, (3) dsmsge vehicle 

components and (•*) degrade air quality. According to CAS:'"From a 

consumer viewpoint, mandating complete use of oxygensted fuels in 

Colorado's Front Range region would be a disaster." 

CAS said the plan would "cause economic chaos for consumers'1 forced 

to pay repair costs for vehicle damage occuring after the warranty 

expires and for owners of older cars not designed to withstand alcohol. 

CAS said the plan: 

misses the fundamental distinction between voluntary 

use of oxygenated fuels and mandated use of such fuels. 

Where use of alcohol and other oxygenated gasoline 

blends is voluntary, consumers can select a fuel which 

is compatible with their vehicle. 

CAS noted the U.S. Environmental Protection Agency and automakers, 

including Ford, GM and Chrysler, have all identified vehicle damage 

resulting from use of fuels containing alcohol. Until recently, many 

manufacturers cautioned owners against using ethanol or methanol -- a 

practice which voided some manfacturers'warranties. 

-MORETV* Ceeaar (ear Ant* Safety ia • tammeur group 'Minded be Ralph Nader end 

CnHM-Mri Uneea m WTO but letuch a nam independent af its founder*. 
P.29 

*' Since alcohol bends have a higher vapor pressure (volatility ) 

than gasoline, CAS warned that without stringent volatilit y limits , ' 

greater use of these fuels , especiall y at higher altitudes , wil l cause 

widespresd stallin g and fuel-spurting problems. Higher volatilit y fuels 

are cited as a factor causing fuel-spurting and fire s in 3 pending 

Department of Transportation safety Investigations into over half a 

millio n vehicles. 

On 1983-86 Ford vans, motor homes and ambulances, there are nearly 

MOO reports of overpressurized fue l including UO fire s and 10 burn injur! 

Three recent Ford van fire s in Colorado have prompted a Denver law fir-*!. 

Burns & Flga , to fil e a nationa l clas s action agains t Ford, which 

maintains the defect is due to higher volatilit y gasoline. Colorado's 

own Department of Highway's warned van owners to stop using gasohoi. 

Although alcohol mandates are for the winter, CAS noted gasoline 

distributors would market alcohol blends in non-winter months as well 

to avoid the cost of shifting back and forth from alcohol blends. Since 

alcohol blends have evaporative hydrocarbon emissions up to 300% higher 

than alcohol-fre e gasolines, CAS said this would cause additional smog an 

ozone violations in the summer. Outside the safety hazard, states would 

at best be trading a winter CO pollution for a summer ozone problem. 

While the proposal permits use of alcohol-fre e MTBE blends, CAS 

said NTBE-S short supply and higher cost, along with unwillingness of 

gasoline rtttiler s and distributor s to carry multipl e grades of gasoline 

wil l mean that consumers wil l be forced to use either ethanol or methane: 

unless Colorado mandates an alcohol-fre e gasoline. 

CAS comments came in a lette r to EPA Administrator Thomas and 

written testimony on a Colorado proposal to require winter use of 

oxygenated fuels as a means of reducing carbon monoxide pollution. A 

public hearing on the Colorado mandate is scheduled for June 18 in Denvt 
P.30 

' Center for Auto Safety. 

3001 S Stfvct N.W. Suite UO 

Wwhinfton. DC. 20009 

June 11, 1987 

Lee M. Thomas, Administrator 

U.S. Environmental Protection Agency 

401 H Street, S.W. 

Washington, D.C. 20460 

Desr Administrator Thomas: 

The Center for Auto Safety is deeply concerned about the growing 

movement to mandate alcohol fuels as a panacea to air pollution problems 

as the December 31, 1987, deadline for attainment with ambient air 

quality standards approaches. Instead of eliminating air pollution 

problems, use of gasoline containing alcohol will Increase evaporative 

hydrocarbon (HC) emissions by up to 3001. Even worse, ethanol blends 

pose a significant safety hazard because they are not even subject to 

ASTM volatility standards under Clean Air Act waivers. 

When the Environmental Protection Agency (EPA) approved 1C1 ethanol 

blends [then called Casohol] in December 1978, former Administrator 

Costle said: 

CUlse of Gasohoi is very small . . . amounting to less than 

0.0051 of the nation's gasoline sales. Therefore, there is 

no significant environmental risk associated with its continued use. [But] authority to regulate or ban Gasohoi in 

the future is retained . . . should it ultimately be determined that it poses unresolvable problems. 

Citing studies that showed significant increases in volatility and 

evaporative emissions thst result from adding ethanol to finished 

gasoline, Administrator Costle promised: 

to review the environment;! effect of fuel volatility 

variation to determine whether volatility controls should 

be pursued. To deal with the volatility variability of 

gasoline will . . . desl with Gasohoi evaporative losses 

as well. 

Under your leadership, EPA is engaged in the initial steps of 

regulating til gasoline volatility including alcohol blends. Recognizing thst ethsnol and methanol blends increase evaporative emissions 

by up to 220 snd 3251 respectively, EPA has proposed as an option that 

all alcohol blends meet the sate volatility standards as gasoline which 

will be lower than present ASTM volatility standards. The Center for 

Auto Safety and the Natural Resources Defense Council testified at E?Ar 

Ann Arbor hearings on this proposal in favor of stringent volatility 

standards for alcohol blends. 

Despite the pending EPA volatility rulemaking, ethanol proponents 

are moving ahead with efforts to mandate oxygenated fuel use as a means 

of reducing carbon monoxide (CO) levels without any volatility restrictions as part of the mandate. While the programs are labeled oxygenate 
P.31 

Lee M. Thomas 

June 11, 1987 

Page Three 

blends wil l not only increase evaporative HCeralssions and ozone levels 

but also cause grester safety risks in vehicles which need lower volatilit y fuels in the summer than the winter to avoid firas and poor 

driveability. 

We raise these issues now because EPA must grant final approval for 

any plan to mandate use of oxygenated fuels submitted under the State 

Implementation Plan (SIP) requirement of the Clean Air Act. At minimum. 

EPA must tske the serious safety concerns we have raised into consideration as part of its SIP review. Additionally, EPA should not approval 

any SIP containing an oxygenated fuels mandate unless the following 

restrictions apply: 

1. Every servic e station in the mandate area must offer at al l 

times an alcohol-free gasoline. 

2. At least 401 of the gasoline sold must be alcohol-free. 

3. All finished alcohol-gasoline blends must meet ASTM D 439 

specifications and have a Raid vapor pressure which is 1 psi 

less than that set forth by D 439 at all times of the yesr. 

4. An Inspection and enforcement program must be sdopted to 

ensure full compliance with availability of alcohol-free 

fuels as well as pump labeling requirements. 

5. A public education program oust be adopted to ensure 

that the pubic knows which vehicles are not compatible 

with alcohol-blends. 

6. If alcohol-blends sre sold without volatilit y controls, 

the sale of alcohol-blends which do not meet the requirements of 3 above is prohibited in non-winter months. 

Beyond imposing these restrictions in programs to mandate use of 

alcohol fuels, EPA should establish volatilit y standards for alcohol 

blends thst require s 1 psi lower Reid vapor pressure thsn that required 

for alcohol-fre e gasolines ss psrt of its rulemaking on gasoline volatility . Finally, the Center requests EPA to use 101 ethanol blends as a 

certification fuel in its evaporative emissions compliance tasting to 

ensure ttr t effective controls sre installed in motor vehicles. 

Sincertfljf, ec\cw. Clarence M. Ditlow III 

Executive Director 

Attachments 
GASOHOL MARKET SHARE BY STATE 

P.32 

Alabama 

Alaska 

Arisoaa 

Arkansas 

California 

Colorado 

Connecticut 

Delaware 

District of Columbia 

Florida 

Georgia 

Hawaii 

Idaho 

Illinois 

Iowa 

Kansas 

Kentucky 

Louisiana 

Maine 

Maryland 

Massachusetts 

Michigan 

Mississippi 

Missouri 

Montana 

Nebraska 

Nevada 

New Hampshire 

New Jersey 

New Mexico 

New York 

North Carolina 

North Dakota 

Ohio 

Oklahoma 

Oregon 

Pennsylvania 

Rhode Island 

South Carolina 

South Dakato 

Tennetttt 

Tesat 

Utah 

Vermont 

Virgiaia 

Washington 

West Virginia 

Wisconsin 

Wyoming 

CjajulUl 

1,881 

267 

1,395 

1,166 

11,636 

1,338 

1,393 

326 

163 

3,462 

3,148 

349 

463 

4,836 

1,369 

1,234 

1,736 

2,132 

348 

1,976 

2,388 

4,086 

1,231 

2,614 

441 

777 

309 

446 

3,311 

783 

3,941 

3,092 

383 

4,739 

1,890 

1,23V 

4,429 

379 

1,630 

387 

2,334 

8,899 

733 

232 

2,719 

1,912 

aoi 

2,022 

332 

,466,00 0 

,709,00 0 

,903,000 

,202,000 

,231,000 

,918,000 

,470,000 

,204,000 

,074,000 

,027,000 

,673,00 0 

,709,000 

,302,000 

,634,000 

,838,000 

,260,000 

,311,00 0 

,374,00 0 

,083,000 

,290,000 

,603,000 

,109,00 0 

,066,00 0 

,239,000 

,744,000 

,136,00 0 

,110,00 0 

,902,000 

,078,000 

,404,000 

,933,000 

,963,00 0 

,713,00 0 

,030,00 0 

,867,00 0 

,669,00 0 

,736,00 0 

,026,00 0 

,720,00 0 

,433,00 0 

,948,000 

,228,000 

,798,000 

,812,00 0 

,433,00 0 

,436,00 0 

,431,00 0 

,990,00 0 

,979,000 

United State s Tota l 109,375,313,00 0 

Cjuohol 

196,111,00 0 

- 0 -

- 0 -

9,913,00 0 

228,017,00 0 

237,333,00 0 

16,409,00 0 

- 0 -

22,00 0 

381,364,00 0 

- 0 -

- 0 -

21,167,00 0 

,035,454,00 0 

696,i37,00 0 

21,167,00 0 

336,478,00 0 

123,397,00 0 

- 0 -

720,00 0 

- 0 -

343,883,00 0 

-0-

19,736,000 

9,079,000 

242,367,000 

1,142,000 

-0-

-0-

73,302,000 

-0-

121,220,000 

36,680,000 

531,639,000 

23,374,000 

168,000 

-0-

-0-

700,000 

32,402,000 

363,020,000 

429,493,000 

6,223,000 

-0-

349,930,000 

7,374,000 

-0-

13,069,000 

291,000 

7,317,413,000 

10.4 

-0-

-0-

.9 

2.0 

13.2 

1.2 

.1 

.1 

10.6 

-0-

-0-

4.6 

22.4 

i.3 

22.8 

32.0 

3.8 

-0-

.1 

-0-

16.4 

-0-

.7 

1.8 

31.2 

.3 

-0-

-0-

9.6 

-0-

3.9 

9.3 

14.6 

1.3 

.1 

-0-

-0-

.1 

13.3 

14.4 

4.8 

.8 

-0-

12.9 

.4 

-0-

.7 

.1 

7.2 
P.33 

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Cammittie an Ciur-fp ano Commtrtt 

•ifUintfon, SC 20513 

-June 29, 1987 

The Honorable Lee M. "nomas 

Administrator 

Environmental Protection Agency 

Waterside Mall — West Tower 

401 M Street, S. W. 

Washington, 0. C. 20460 

The Honorable Diane K. steed 

Administrator 

National Highway Traffic Safety Administration 

Department of Transportation 

400 Seventh Street, S. w. 

Washington, D. C. 20590 

The Honorable James C. Miller III 

Di rector 

Office of Management and Budget 

Old Executive Office Building 

Washington, D. C. 20500 

Dear Administrators Thomas, Steed and Mr. Miller: 

This letter supplements my May 8, 1987 letters to the 

Environmental Protection Agency (EPA) and the Department of 

Transportation (DOT) with copies to the National Highway Traffic 

Safety Administration (NHTSA) and the Office of Management and 

Budget (OMB) concerning the Redbocder package of proposed onboard 

control and volatility rules now pending at OMB and before the 

EPA Administrator. Enclosed are letters from the Motor Vehicle 

Manufacturers Association, the Automobile Importers of America, 

and the Insurance Institute for Highway Safety. Each of these 

documents is highly critical of EPA's consideration of safety 

relative to the development of onboard control rules. 

These documents, coupled with NHTSA's recent criticisms of 

the rules, raise serious questions about the adequacy of EPA's 

consideration of this life and death issue -- public safety. In 

the past (and probably in the future), I have been a strong 

critic of OMB's regulatory review v~,~n:.-., %,,*_ ip this case, I 

think that OMB and NHTSA hav« n-x ?! •:-> .\ K. i ; r. i:ut to tell EPA that 

its rulemaking is deficient from a public safety standpoint and 

should be withdrawn now. Publishing the proposed rule would not 
-'The Honorable Lee M. Thomas 

The Honorable Diane K. Steed 

Page 2 

be in the public interest until these safety issues are resolved. 

That should not be attempted through quiet, behind-closed-doors, 

non-public discussions at OMB. It should be done at EPA with 

participation of these private organizations, NHTSA, and possibly 

others. At the very least, the EPA proposal should be in the 

form of an Advanced Notice of Proposed Rulemaking. Incidentally, 

I again stress that I do not consider a national Stage II program 

as an alternative to onboard controls. 

I request a reply by July 17, 1987. Please include a table 

showing in chronological order all meetings and telephone 

conversations between OMB, NHTSA, and HPA from the time rules 

were provided to OMB to the present, the participants, and their 

purpose. 

With best wishes 

/ JOHN D. DINGELL 

Chairman 

Subcommittee on 

Oversight and Investigations 

Enclosures (3) 

cc: Subcommittee on Oversight and Investigations Members 

Mr. Brian O'Neill, President 

Insurance Institute for Highway Safety 

Mr. George C. Nield, President 

Automobile Importers of America 

Mr. Thomas Hanna, President 

Motor Vehicle Manufacturers Association 

Mr. Charles J. DiBona, President 

Aaerican Petroleum Institute 

The Monorable Charles A. Bowsher, Comptroller General 

General Accounting Office 

Mr. Nick Nikkila, Vice President 

State and Territorial Air Pollution Program Administrators 

Mr. Robert P. Miller, President . 

State and Territorial Air Pollution Program Administrators 

Mr. Donald Moline, President 

Association of Local Air Pollution Control Officials 
P.35 

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Ctsioitttre on Cwrgp. jnd Commerc* 

•Jftjinfftfln. » C 20515 

Nay 12, 1987 

Mr. Brian O'Neill 

President 

Insurance Institute for Highway Safety 

600 New Hampshire Avenue, N. w. 

Suite 300 

Washington, D. C. 20037 

Oear Mr. O'Neill: 

Thank you for your very helpful letter in reply to my 

request concerning the safety of onboard controls for new motor 

vehicles. 

Enclosed is a copy of my opening statement and ay memorandum 

to the Members, together with a lengthier staff memorandum. X 

call your attention to pages 19 to the end of the staff memorandum. 

Also enclosed are ay letters to Secretary Dole, Administrator Thomas, and the two motor vehicle associations. Also 

enclosed is EPA's draft safety analysis. As you can see, the 

Subcommittee shares your concern about the safety issue and 

requests any further comments you may deem appropriate after 

reviewing these materials. It is my understanding that the 

Environmental Protection Agency (EPA) tends to discount the 

Institute's comments apparently because you have not provided any 

data to support your contentions. 

I request your response by June 22 or earlier. 

with best wishes 

JOHN D. DINGELL 

Chairman 

Subcommittee on 

Oversight and Investigations 

Enclosures 

cc: The Honorable Noraan F. Lent, Ranking Minority Member 

Subcommittee on c-.-ersight and Investigations 
P.36 

IN.SUR -v\CE 4 -

INSTITUTE-'-

FOR 

HIGHWAY 4 

\AFFH 

June 16, 1987 

John D. Dingell. Chairman 

U.S. House of Representatives 

Subcommittee on Oversight & Investigations 

of the Committee on Energy & Commerce 

Washington. 0. C. 20515 

Dear Chairman Dingell: 

This is in response to your May 12 letter concerning the safety of on-board 

vapor recovery systems. 

Safety Issues 

The issue of the safety of emission controls cannot be dismissed as cavalier; 

as has been done by the Environmental Protection Agency (EPA). As early as 

1971. the National Highway Traffic Safety Administration (NHTSA) sponsored a 

study that investigated the crashworthiness of automotive fuel systems.1 

That study concluded: 

The use of evaporative emission control systems. 

however, could lead to increased spillage problems as the 

vehicles age due to the complexity of many of the systems 

and associated maintainability problems.... 

Many of the system failures and malfunctions which could 

occur during operating conditions would affect engine and 

vehicle performance but would not necessarily constitute a 

fire hasard. Other evaporative emission control system 

failures, however, could be quite hazardous. A hazardous 

situation would arise if fuel or vapor escaped from the 

system.... (T]he fuel vapors could form a flammable 

fuel-air mixture for eventual ignition by shorted wires 

within the vehicle or by outside ignition sources, 

especially during an accident. 

Another very hazardous condition could arise should any 

of the vapor Ur.es between the tank and liquid-vapor 

separator develop leaks. Fuel could be spilled from the 

tank through the damaged line during severe maneuvering 

forces or during crash conditions.... 
The Honora-.-s -c.-\ - • — ? - • - • 

June 16. 1987 

Page Two 

Another study investigated 73 collision fire case studies during the early 

1970s and noted. "The evaporative emission control system in its s'implest form 

represents a substantial amount of 'outside plumbing fixtures.' each of which 

increases the problem of monitoring fuel system integrity during and following 

collision."* This study also commented on vapor emission controls and their 

integrity in the 30 mph frontal crash tests conducted in the previously 

mentioned crashworthiness study.l Twelve 1970-1971 passenger vehicles were 

tested; half were foreign and half were domestic. Six of the 12 sustained 

fuel system damage, with domestic vehicles incurring more than twice as many 

disruptions as the foreign vehicles. The report concluded: "Under collision 

conditions, therefore, it is apparent that fuel system integrity has been 

compromised by efforts to obtain better fuel evaporative control." 

This evidence conflicts directly with the EPA premise that these systems 

present no increased safety hazards.' EPA claims that the addition of check 

valves and even solenoid valves would not decrease system reliability. This 

is fundamentally wrong. Any competent analysis would conclude that the 

reliability of these items must be leas than 100 percent. An EPA survey of 

some 795 vehicles in 1984 and 1985 revealed related maintenance problems for 

on-board control systems in 11.3 percent of the vehicles.- These problems 

ranged from broken canisters, leaking rollover valves, to inoperative purge or 

vacuum control valves.4 Obviously. EPA has neglected their own data in 

assessing the safety and reliability of these on-board systems. 

EPA attempts to discount the safety threat of fuel leakage and possible 

associated fire danger by stating that it is possible to meet Federal Motor 

Vehicle Safety Standard (FMVSS) 301 with new vehicles. EPA apparently fails 

to recognize that FMVSS 301 allows 30 ounces of liquid Leakage after a barrier 

test and an additional equal amount after a rollover. This standard prohibit 

the massive fuel spillage associated with a fuel tank rupture, but it still 

allows significant liquid leakage and unlimited vapor leakage. EPA evidently 

believes that several cups of gasoline or several liters of vapor are not 

unsafe in the presence of possible crash ignition sources. EPA projects vapor 

canisters of approximately 3 liters for automobiles, whereas the manufacturers 

estimate canisters at least twice that size (e.g.. 6.4 liters for a full size 

Chevrolet and possibly 12 liters for light trucxs with dual tanks). Moreover. 

IIHS barrier crash tests have produced canister damage :n frontal barrier 

crashes as low as IS mph.' 

Public Health Issues 

A review of the available and ongoing research on the adverse health effects 

from expoeure to gasoline vapor concluded "that current scientific information 

is sufficient to classify wholly vaporized gasoline vapors as animal 

carcinogens, according to accepted scientific standards. In the absence of 

evidence to the contrary, it might also be prudent to assume that vapors from 

wholly vaporized gasoline are human carcinogens."* The report further 

states: 

However, these vapors may be quite different from those to 

which consumers or workers are usually exposed. Accordingly, 

the unaaious scientific view is that the biological and 
P.38 

The Honorable John 0. Dingell 

June 16, 1987 

Page Three 

,«osur. elements of the gasoline vapor problem are ""•"• * 

complicated and. as yet. unresolved. Consequently, the 

usefulness of available animal and human data '« ^J'J * *° 

ott.rmine health risks is quit, limited. U-*^ n t J "0 * " 1 1 

vapors may. upon further investigation, prove to ??•»•«* 

s ^ f leant cHcinogenic risk, for humans. Th. evidence i, 

not available to make that statement today. 

5 2 2 «,5:«.th^:«r!^ .1.. i»U«. on l<TM*« ^.'l?^ ^ 

evidence that on-board r.cov.ry syst.ms can increase the risk of post crash 

Tic. injury, and death. Apparently, EPA believes that spetulaJJ^health 

hazards analyses can be turned into precise estimates but that evidence 

concerning increased risk of fires in crashes can be ignored. 

I trust these coeiDents will be of value to your committee. 

Sinqerely, 

Brian O'Neill 

President 
Mazda (North America), Inc. 

Research & Development Conter 

A nn Arbor 

' 2C2 .vccs* *"*;e - er .s 

i — i.-rc' V'C" .a,- -3'CS 

:3-3: -.: ?5S- " • 

u 

June 24. 1987 

The Honorable John 0. Dingell. Chairman 

Cofistittee on Energy and Coronerce 

U.S. House of Representatives 

2125 Rayburn House Office Building 

Washington, D.C. 20515 

Dear Mr. Chairman: 

This responds to your letter of May 11, 1987, in which you solicited 

comments from the automobile industry regarding several issues raised by the 

Environmental Protection Agency [EPA] proposal calling for onboard refueling 

vapor emission controls. Specifically, you raised questions about the safety 

implications that the current proposal will have, especially in consideration of 

its Limited leadtime provisions. You also asked of the proposal's applicability 

to light duty and heavy duty trucks, the status of the vehicle technology 

necessary to comply and estimated compliance costs. 

Mazda (North Aaerica), Inc., on behalf of Mazda Motor Corporation of 

Hiroshima, Japan, welcomes the opportunity to provide its views on these issues. 

Our comments address: 

1. Disadvantages to small car manufacturers. 

2. Lower vehicle utility. 

3. Insufficient leadtime. 

If required, Mazda believes that the onbosrd refueling vapor eaission 

control systea requirement of a 24 month leadtime period is inadequate to permit 

us to provide aa optimised onboard refueling vapor emission control systea. 

Instead, ve ask for a minimum four year postponement of the effective date, after 

which only nearly introduced carlines need meet onboard refueling vapor emission 

control system requirements for aoae limited period. 

Thank yon for the opportunity to comment on this extremely importsnt 

rulemaking activity. Attached are Mazda's specific comments. 

Sincerely. 

c. ^-^C ------

KanjI Shiaaaura 

Executive Vice-President 

and General Manager 
P.40 

References 

1. Johnson. Neva B. An Assessment of Automotive Fuel System Fire 

'* Hazards. Springfield. VA: National Technical Information 

Service. U.S. Oept. of Transportation. National Highway 

Traffic Safety Administration. DOT HS 80062*.. 1971. 

2. Blaisd.ll. David M.. Kerkhoff. John F.. and Sev.ry. D.rvyn M. 

Automotiv. collision fires. Proceedings of Eighteenth Stapp 

Car Crash Conference. Warrendale. PA: Society of Automotive 

Engineers. 1974. pp. 113-200. 

3. U.S. Environmental Protection Agency. Safety I-nplications of 

Onboard Refueling Vapor Recovery Systems. Technical Report 

Draft. Standards Development and Support Branch. Emission 

Control Technology Division. March 1987. 

4. Multinational Business Services. Inc. Costs and Cost 

Effectiveness of Stage II and Onboard Refueling Vapor Controls. 

Washington, X : Motor Vehicle Manufacturers Association. 

April 1987. 

5. General Environments Corporation. Report of 1975 Vehicle Low 

Speed Impact Testing. Washington. DC: Insurance Institute for 

Highway Safety. January 1976. 

6. Health Effects Institute. Gasoline Vapor Exposure and Human 

Cancer: Evaluation of Existing Scientific Information and 

Recommendations for Future Research. Report of Institute's 

Review Committee. Cambridge, MA. September 1985. 
P.41 

The Honorable John D. Dingell 

June 24, 1987 

Page 2 of 4 

Comments of Masda Motor Corporation 

Onboard Refueling Vapor Eaission Control Systems 

Masda supports tha positions regarding onboard refueling vapor emission 

control systeas tsken by the Automobile Importers of America, Inc. and the 

Insurance Institute for Highway Safety. The following comments represent Mazda's 

concerns and views. 

I. Saall Vehiele Design Disadvantages 

Masda's current plan for compliance with an onboard refueling vapor 

eaission control systea requirement includes s canister voluae of 3.0 to S.O 

liters at a 10 gpm dispensing rate [the maximum rate considered allowable to 

avoid premature fuel pump shut-off]. This assumes that certification fuel 

is aaintained at RT? limits of 9.0 psi, with similar controls on commercial 

fuel. The canister will be located ia the rear just ia freat of the fuel 

tank, which will reduce fuel tank and luggsge storage volumes by a still 

undetermined amount. 

EPA. however, has ststed that only a 2 liter canister would be necessary for smaller vehicles, which implies thst onboard refueling vapor 

emission control systea packaging for small csrs would be no different than 

for large cars. Aa Mazda understands this ressoning, only tha scale of the 

systea would vary, not the packaging complexities. EPA's aaalysis is 

apparently based on the conclusion that canister sise is proportional to 

vehicle sise. Maxda doea not disagree with EPA'e assertioa that fuel tank 

voluae is generally proportional to canister size. However, Masda does 

disagree with EPA that vehiele size ia proportional to fuel tank voluae. 

which apparently has led the EPA to conclude that vehicle size oust be 

proportional to canister else. 

An aaalysis of fuel tanks of vehicles sold in the United States shows 

that fuel tank voluae is not proportional to vehicle wheelbase or weight. 

Fuel task voloaes of vehicles of similar weight vary SO percent, while fuel 

tank welumes of vehicles of a similar wheelbase vary in some cases 100 

perceat* The above data are froa the 1987 Market Data Book, published 

annaaUy by Crain Communications. Inc. These data suggests that onboard 

refueliag vapor eaission control canister size will not be the aaae in 

vehicles of comparable overall sise, creating unique packaging problems. 

Ia those smaller vehicles for which canisters will require proportionally more voluae than those for larger cars, mora extensive developnent 

efforts will be required. This additional effort will lead to higher prices 

for aaall vehicles compared to large vehicles. Hardware eosta alone are 

estimated by Masda to be $40 per vehicle for both passenger csrs and light 

duty trucks. For maximum efficiency, engineering, testing snd certificstion 

costs must be incorporated into the regular development cycle of new passen-
The Honorable Jobs D. Dingell 

June 24, 1987 

Page 3 of 4 

ger car models, which takes about four years from concept co production. To 

minimize additional eosts for an onboard refueling vapor eaission control 

systea. a leadtime of four years is required. In relative terms, light duty 

trucks developaent costs will be greater than passenger cars due to the 

infrequent aodel changes that occur. With cycle plans of eight to ten 

years, redesign, retesting, recertificstion snd retooling of light duty 

truck vehicles during the aodel run will result in higher production costs 

as amortization over the originally planned production volumes will be 

frustrated. Masda does not market a heavy duty truck in North America and 

is accordingly unable to comment on this market segment. 

The difficulties of continued compliance with CAfl requirements will 

also correspondingly incresse. An onboard system will provide aa incentive 

to consumer to choose large vehicles, instead of smaller,' more fuel efficient ones, through a lower price differential between the two classes of 

vehicles. This will tend to increased corporate average fuel economy 

levels. Fuel economy will be further reduced because of the extra weight of 

aa onboard refueling vapor emission control systea. 

II. Vehicle Utility Losses 

Vehicle value will decline as onboard refueling vapor eaission control 

systeas compromise function aad consumer satisfsction. Consuaers will be 

disadvantaged by the proportionally higher loss of fuel tank voluae and 

luggage voluae lost to canisters in smaller cars. Reduced fuel tank volumes 

will reduce driving range, thereby forcing consumers to make more frequent 

refueling stops. EPA officials have acknowledged that smaller vehicles will 

sustain such concessions. Although we have not precisely calculated this 

loss in value, it must be factored into the overall coat/benefit analysis so 

that real-world overall costs will be reflected. Also, structural changes 

will be necessary to allow space for the csnister and associated equipment, 

which will interfere with access to spare tirea and jacks. 

III. Laadtiae leaaireaents 

One of the aest disturbing aspects of the proposed rule ia the limited 

leadtime provided to design a syatea that will have a major iapact on 

aaaufacturers' ability to coaply with safety and other emission control 

requiraeents. In addition to the canister, additional components [vapor 

lines froa the fuel tank to the engine via the canister, new cut valve 

systeas aad protective shielding for each subsssembly] oust be provided. 

Vehicle structural reinforcements snd rear passenger compartment/luggage 

araa body pans must be reconfigured, sa testing is conducted snd tooling ia 

arranged. Finally, new procedures aust be created so that the new systems 

can be properly evaluated. 
P.43 

The Honorable John D. Dingell 

June 24, 1967 

Page 4 of 4 

The vehicle design cycle is complex and lengthy. Design and engineering sctivitics address safety and eaission issues while the vehicle is 

still literslly on the drawing board. Requiring manufacturers to engsge in 

the very difficult and complex task of reconfiguring systems due to sn 

onboard refueling vapor emission control system ia not reasonable in the 

middle of a model life. For example, development of 1993 models is already 

underway. Most of these vehicles' systems will be complete by the beginning 

of 1990. Emission certification will occur in mid-1991. Production and 

actual vehicle sales would then begin in aid to late 1992. Any changes in 

vehicle design specificstions after the initial planning stages will disrupt 

the oversll schedule and increase vehicle cost. 

The two year leadtime provision of the EPA proposal does not recognize 

these concerns, especislly regarding fuel systea asfety. A comprehensive 

task force devoted exclusively to onboard refueling vapor eaission control 

systeas is essential, but will detract froa other safety efforts and prevent 

safety improvements. For example, ve are now developing systems to comply 

with the requireaents of FMVSS 208, Occupant Protection. A craahworthy 

onboard refueling vapor eaission control systea will require the aaae 

design, engineering, tearing and aanagerial facilities and personnel aa 

needed now to develop restraint systeas as required by the NHTSA. 

A similar dilemma exists in emission certificstion engineering activities. Onboard refueling vapor emission control systems will hsve e deleterious influence on vehiele emission control systeas. The introduction of 

purged gasoline vapor into the intake manifold will alter stoichioaetry, 

which ia turn has aa influence on amissions and performance ss the air/fuel 

ratio will vary outside of the range tolerated by Mazda's current systeas. 

The developaent of the vapor recovery systea vill require re-evaluation of 

the engine eaission control systea and development of suitable counteraeasures. The resources to coaplete this task must coae froa other eaission 

control engineering groups, postponing improvements mandated by regulation 

and the market. Resources will also be taken away froa basic engine 

developaent, which continually iarproves the efficiency, performance and 

durability of modem motor vehicle engines. The loss of these activities is 

a cost of the 0 A propossl. 

Masda therefore believes that a 24 month leadtime period is not practicable. 

A miniaum foar year leadtime ia necessary to avoid a massive redesign effort for 

existing models. For s limited period of time after the initial compliance 

requirements become effective, only newly introduced models should be required to 

comply with onboard refueling vapor recovery requirements. If onboard refueling 

vspor emission control systems are mandated, only this implementation schedule 

will allow tha industry to efficiently comply with its requirements. 
V 

AUTOMOBILE IMPORTERS OF AMERICA, INC. 

1723 JCFFCNSON 0AV1S HIGHWAY. SUITE 1002 • ARLINGTON. VA 22202 • ,7«j , 97 * 3330 • «A«HFA^i703. 979-1333 

CHAIRMAN 

m. MIIXST 

SAAB-SCANIA 

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TOYOTA 

TRtASURIR 

J. MIU. Y 

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NISSAN 

ALFA HOMCO 

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HYUNOAI 

ISUZU 

JAOUAH 

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SAAB-SCANIA 

SUBARU 

SUZUKI 

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KOITO 

LUCAS 

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TOVO Tine 

YOKOHAMA 

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June 22, 1987 

Honorable John 0. Dingell 

Chairman, Committee on Energy 

and Commerce 

House of Representatives 

Washington, D. C. 20515 

Dear Mr. Chairman: 

AIA welcomes the opportunity to respond to your 

letter of May 11, 1987 and comment on the safety 

aspects of onboard refueling control systems. 

As you have noted, comments on the safety of onboard 

systems have ranged from the view that they present a 

serious 3afety problem to providing a safety benefit 

in the Environmental Protection Agency's (EPA's) 

view. Our view most closely matches that presented 

by the National Highway Traffic Safety Administration 

(NHTSA) -- that adequate leadtime is needed to 

prevent safety problems with such systems. Clearly, 

the automobile industry has developed technologies in 

the past to deal with many different challenges and 

this problem is no different. While we think onboard 

systems can be designed to be safely incorporated 

into a motor vehicle, adequate leadtime must be 

allowed to properly design and test such systems to 

ensure that no safety problems exist. Product 

liability is a constant concern and automobile 

manufacturers cannot afford to rush to the market 

with quickly designed control systems that will not 

pass the rigorous test of life with the customer. 

We cannot agree with EPA's assertion that two years 

of leadtime is adequate for the proper design and 
AUTOMOBILE IMPORTERS OF AMERICA. INC. 

> * 

production of onboard control systems. in our view, a m.lniaun of 

four years leadtime is needed to design, test and produce these 

systems. EPA presumes that onboard control is simply an extension 

of existing evaporative control systems. This is not the case. 

' The problem) is not incremental; onboard canisters would be large 

enough (4 to 5 times as large) so as to require substantial new 

design and testing. Certain models may require even more 

development time. The complexities introduced by small specialty 

cars with packaging concerns and light-duty trucks with dual fuel 

tanks make the job even tougher. For the more difficult cases, a 

phase-in of controls may make sense, but such a phase-in would 

have to truly phase-in controls along the lines of 10% the first 

year, pousibly 25% the second year, etc. EPA's rumored phase-in 

of 70% in the first year simply does not provide any relief and 

for many of our members is the same as a 100% requirement, due to 

the limited model lines they produce. 

If timeliness of hydrocarbon control is of importance to EPA, we 

continue to be baffled by its reluctance to impose Stage II 

requirements on nonattainment areaa. While onboard controls will 

still require some years to develop and many more years to 

infiltrate the fleet, Stage II is production ready and currently 

being installed in St. Louis. Stage II installations will affect 

all vehicle refuelings as soon as installed and operating. 

We strongly support EPA's planned control of fuel volatility as 

this reduces the size and design complexity of onboard control 

systems. It will aiso have the benefit of reducing excess 

evaporative emissions on cars currently in use. We also recommend 

that EPA pursue rulemaking to limit the in-uae dispenaing rate for 

fuel to 10 gallons per minute. 

Our comments do not cover the specific issues of canister size and 

costs of onboard coaponents as these vary from manufacturer to 

manufacturer. Our member companies, however, will be commenting 

individually in some detail on the issues raised in your letter. 

Again, we thank you for this opportunity to make our views known. 

Sincerely, 

THE AUTOMOBILE IMPORTERS OF AMERICA 

>AC— ?>—^^<-^^ * "*-c 

George C. Nield, President 

cc: The Honorable Lee M. Thomas, Administrator 

Environmental Protection Agency 
P.46 

AUTOMOBILE IMPORTERS OF AMERICA. INO- ;1 

CC The Honorable Elizabeth Hanford Dole, Secretary 

Department of Transportation 

The Honorable Diane K. Steed, Administrator 

National Highway Traffic Safety Administration 

Department of Transportation 

The Honorable Charles A. Bowsher, Comptroller General 

General Accounting Office 
P.47 

MOTOR VEHICLE''MANUFACTURERS ASSOCIATION 

of the United States. Inc. 

300 NEW CENTER BUILDING • DETROIT. MICHIGAN 48202 • JJ5.EA 313-872-4311 

DONALD 0 LENNOX. CAeirsufl 

THOMAS H. HANNA, PreMtltnt sod Chief Kxtcuuva Otflcar 

June 24, 1987 

The Honorable John D. Dingell 

Subcommittee on Oversight and Investigations 

Committee on inergy and Commerce 

House of Representatives 

2323 Rayburn House Office Building 

Washington, D. C 20615 

Dear Mr. Dingell: 

•-. , .•._• . ;_..i . i> •- • 

! jl JUN2 6'*9S7 JU 

ihu sLJ 

SuoccmrT-ir.ee on Cversignt 

and investigations 

Your letter of May 11, 1987 to the Automobile Importers of 

America, Ine. (AIA) and the Motor Vehicles Manufacturers 

Association of the united States, Inc. (MVMA)* raises several 

Issues on the subject of onboard vapor recovery which ace of 

vital Importance to our member companies. We appreciate this 

opportunity to answer and comment on your questions, primarily 

safety and lead-time as they affect all vehicles, including 

heavy-duty trucks. Also, you have solicited our comments on the 

alleged convenience of onboard control systems and the control of 

fuel dispensing rate. 

on 

The attached 

sequence of your 

response addresses your questions in the 

May 11 letter to the two associations. 

\ 

We regret that we cannot furnish you with specific cost 

estimates relating to the Environmental Protection Agency 

-suggested alternative technology "fixes" about which you asked, 

Individual member companies are in the process of investigating 

the feasibility and cost aspects. This information can be 

provided in the future. 

•MVMA represents U.S. automobile, truck and bus manufacturers 

producing some 98 percent of all domestic motor vehicles. MVMA 

members are: American Motors Corporation; Chrysler Corporation; 

Ford Hetor Coapany; General Motors Corporation; Honda of America, 

Mfg., Inc.; LTV Missiles and Electronics Group, AM General 

Division; M.A.N. Truck t Bus Corporation; Navistar international 

Transportation Corp.; PACCAR Ine; Volkswagen of America, Inc., 

and Volvo North America Corporation. 

z

7

/^. uttf k JSJ5/ O£S. 

T U NO. 1009770 AUTOMAKERS 0ET 
The Honorable John D. Dingell •» 2 -

P.48 

.1 

*-.<« vmi mav deoend on MVMA's continued willingness to A9ii2'Jfth III and Sour staff on any of these refueling 

cooperate with you and your • imme Jiat e an d ongoing 

matters, all of wnicn

 main ^" ni .s t , VQ U o c vou c staff have 

attention of our member companies, ir you « j;"."' " " " 

qSes?ions on these responses and comments, please let me know 

Very truly yours, 

- • * ' 

Thomas H. Hanna 

Attachments 

cc: The Honorable Elizabeth Hanford Dole, Secretary 

Department of Transportation 

The Honorable Lee M. Thomas, Administrator 

Environmental Protection Agency 

The Honorable Charles A. Bowsher, Comptroller General 

General Accounting Office 
P.49 

MVMA RESPONSE TO MAY U ^ 1987 LETTER TO -

: 

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MVMA AHO AIA fRQH CONGRESSMAN JOHN D^ DINGELL 

REGARDING ONBOARD VAPOR RECOVERY 

Safety 

NVHA disagrees that the EPA Adainlstrator (and his stsff) were 

not advised of critical safety Issues either overlooked or 

Ignored by EPA In Its extensive analysis of the onbosrd Issue. 

At the April 17, 1987 hesrlng before the House Subcoaalttee on 

Oversight and Investigation, Mr. Thoaas indicsted thst 

aanufscturers had not told hia of a "aajor problem" with onboard 

refueling vapor recovery froa a safety standpoint. 

A group of NVHA, AIA, and auto coapany executives aet with the 

Adainlstrator on June 26, 1985 to discuss various aspects of the 

refueling issue. During a suaaary presentstion, seversl safety 

concerns were expressed, including the difficulty of assuring 

that the large vent valvi required to route refueling vapors to 

the canister would always be seslsd off in the event of a vehicle 

crash, aad the potential fuel spillage in the event of a 

dispensing nossle falling to shut off at the end of a refueling 

event. 

-1-
P.50 

On June 11, 1986, GM representatives met with EPA Assistant 

Administrator Craig Potter and a part of that discussion included 

the presentation of a chart describing safety challenges. The 

chart comprehensively listsd all known safety design criteria 

recognized at that tiae that aust be used to ensure a safe 

onboard refueling eontrol systea under all foreseeable operating 

conditions. 

On Deceaber 23, 1986, NVHA and AIA sent a joint letter to the 

Administrator expressing the industry's concerns that EPA was 

apparently not giving appropriate considerstion to the stated 

safsty issues. Specifically eaphaslsed In that' letter were the 

unresolved "signiflcsnt safety issues:" 

1. Fuel systea integrity. 

2. Fuel spitback. 

3. Fuel dispensing nossle failure. 

Ultlaately, onboard refueling would result in soae interaction 

between the automotive and petroleua equipaent Industries. If 

nossle compatibility with mechanically seeled fill pipes becomes 

important to EPA ia its rulemaking, equipaent aanufscturers, 

speeifleaXly nossle manufacturers, aay need to participate In the 

discussion of refueling safsty. EPA has rscognised this link and 

in August of 1986 invited equipaent 

-2-

J 
P.51 

manufacturers to a airu-worfcshop in Ann Arbor, Michigan to 

discusa potential interactions with fuel dispensing e-juipaent. 

However, it does not appear that EPA has followed up 'on this 

critical aspect perhaps preferring to resolve the matter at a 

later time. 

MVMA has repeatedly articulated Its safety concerns as they 

relets to potentlsl ruleasklng actions. Based on the 

Adainistrstor's testimony before the House Subcoaalttee on 

Oversight and Investigations, however, there appears to be a gap 

in understsnding. In order to preclude further aiscommunlcation, 

we would state that serious and aajor safety concerns reaain 

unsolved for aany of our aeaber coapanies. These concerns aust 

be addressed before rulemaking can proceed. While EPA has 

rsceived aany different coaments on the "feasibility" of dealing 

with these probleas the Agency In large part has brushed them 

aside by asking a ssrles of siaplifylng assuaptlons. These 

safety Issues aust be addressed. 

-3-
P.52 

Ltad-Tiae 

NVHA hat reviewed the draft copy of an EPA March 1987 document 

"Technical Report - Safety implications of onboard Refueling 

Vapor Recovery Systems EPA-AA-SDS8-8705" furnished to us as an 

enclosure with your May 11, 1987 letter to MVMA and AIA. 

Although a final agency decision or position is not presented in 

the Technical Report, it appears EPA believes a 24-aonth 

lead-tlae Is appropriate to implement onboard systeas on most 

vehicles exeept "unique" cases which would require phsse-in and 

an additional 12 months. Supporting this position, the EPA 

report states that aany of the original developaent and safety 

issues are the saae as they were for the original evaporative 

system iapleaentation effort, years ago. Also, EPA states that 

the current availability of "working prototypes that already 

exist" (p.66) on modified vehicles will serve to expedite 

manufacturers' developaent programs. 

Industry rsviswers of such systems all share one common 

observation; there is a significantly large disparity between 

these concept demonstration systeas and production prototypes 

that are built to perform reliably under all actual custoaer 

conditions. Such s disparity only allows the conclusion that 

recovery of refueling vapors could be achieved on the vehicle, 

but fails to resolve many of the uncertainties and unknowns about 

-4-
in-use safety, operation, reliability, and effectiveness. Tor 

example, vapor adsorption onto canister charcoal during refueling 

must occur at a rsts over 100 times faster than any current 

experience with vapor loading. 

The investaent of extensive lead-time and capital Is the only 

aesns to resolve these concerns and this proesss can only begin 

efter e final ruleaaking action. 

Also, in support of a 24-aonth lead-tiae cequireaent, EPA cites 

previous eveporative caissions ruleasklngs snd subsequent 

Industry coapllance tlaes. A 12-aonth lead-tiae for s 6 grsas 

per test stsndard In 1978 Is an Irrelevant coaparison (p.69), 

sines only ainor hardware changes were required for the 

transition froa a 2.0 graa trap test to a 6.0 graa SHED test. At 

that tiae, hardware packaging and safety issues had been 

addressed seven years esrlier. 

Siailarly, the reduction (froa 6 graa per test) to a 2 graa SHED 

standard in 1981 resulted In various degrees of modifications to 

sealing aeehanisas and control hardware that had been packaged on 

vehicles as a result of the earlier standard. The absence today 

of a rule forcing a coaplex vehicle control systea with 

quaatloaable safsty and unestabllshed test requireaents does not 

perait aanufscturers' early Investaent in necessary equipaent to 

gain "early experience." 

-5-
P.54 

Contrary to the EPA belief* no earlier experience is Matched by 

the paekaglng snd engineering tssks of the higher flow capacity 

coaponents associated with an onboard ruling. The addition of 

the second canlstsr, or sn Integrsl dual-purpose one has no 

precedent on light-duty vehicle coapacts and subeoapacts. 

Manufacturers are experiencing constsnt Internal negotiation 

aaong engineering groups for valuable under-chessl* sites because 

space on future platforas will continue to be at a preaiua. roc 

exaaple, leed-tlaes for body panel revisions range froa 20 months 

to 36 aonthe, depending on the Iapact of the design on structural 

aeabers. 

rurtheraore, In support of rational lead-tiae, insufficient fleet 

testing prior to production release could result In accelerated 

judgaents which could, In turn, leed to high refueling eaissioni 

and ineffective eaission eontrol techniquee. 

The irony of lead-tiaes lsss than 48 aonths is that the Agency 

has, at various tiaes for the last 9 years, proposed to Initiate 

refueling vapor recovery ruleaaking and Is now suggesting that 

the solution which would have the aost extended lapleaentatlon 

requirement be promulgsted with only half the appropriate 

1 sad-time). Alternatively, a solution with an environmentally 

attraetlve lead-tiae (24-36 aonths) Is Stage II vapor recovery, 

fully iapleaented within five years, as opposed to onboard 

recovery requiring 12 years. 

-6-
P.55 

HVKA continue to believe that 48 aonths of lead-tiae vjbuld be 

needed for light-duty vehicles/trucks before production start-up. 

Sy contrast, heavy-duty gasoline vehicles may require additional 

tlae as discussed a separate section on heavy-duty vehicles. 

Light-duty vehicle/truck lead-time Is detailed in Plgures 1 & 2 

(following pages) and Is coaposed of typlcsl aajor allestones, as 

explained In earlier correspondence, including: 

Receipt of prototype parts 

Begin proving ground vehicle 

endursnce with prototypes 

14 oos. after proaulgation 

20 BOB. after proaulgation 

Begin revisions and changes 

Begin phase III prototypes 

and 100,000 alls endurance 

Coapletion of refueling test 

faeility 

Order production tools 

Chsrcoal capacity rsady 

22 aos. after proaulgation 

25 oos. after proaulgation 

28 aos. after proaulgation 

35 aos. after proaulgation 

40 aos. after proaulgation 

Receive eaisslons certificates 43 mos. after promulgation 

Start of volume production 48 aos. after promulgation 

Aa IMv acknowledges, this schedule aay not be synchronised with 

the actual calendar, since a rule announcement any aonth later 

than July would add froa one to 11 aonths and one full aodel year 

to the iapleaentation target year as a result of a post-July 

announceaent. 

-7-
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- 9 -
P.58 

3 

Finally* at this time, the timetable for dispenser no»zle 

modifications is unknown, or has not been made publicly 

available. 

Because of its relevance here, we are repeating a portion of an 

earlier MVMA document that comments on EPA's replies of March 25, 

1987 to your Questions 1 and 2 about the alleged convenience of 

onboard systeas and the control of fuel dispensing rate, 

respectively. 

-10-
P.59 

/ Section^ 

MVMA Commentary on EPA Administrator Lee Thomas' 

March 25. 1987 Letter to Congressman Dingell 

MVMA COMMENT ON EPA RESPONSE TO QUESTION 1: Regarding the Aii.-1ed 

Convenience of onboard Control Systems 

MVMA disagrees with the EPA conclusion that any potential 

inconvenience of onboard refueling control systeas can be 

overeoae with proper engineering. Our discussion in Section C3 

addresses an iaportant facet of this question related to fuel 

efficient cars and is repeated hers. 

Autoaotive aanufacturers have long made the point that the 

necessity of adding a seeond very large charcoal canister — 

or drastically increasing the sire of the existing charcoal 

esnistsr — for onboard control of refueling eaissions would 

adversely affect efforts to Improve vehicle space efficiency 

for fuel economy improvement. Today's saaller front-wheel 

drive cars hsve high space efficiency, but by the same token. 

have extreaely crowded engine coapartaents. More severely 

sloping hood lines for Improved aerodynaaics will further 

reduce engine compartment space. In fact, one MVMA member 

company has reported that the design of one high production 

volume car will require that an evaporative emission ccnr—_ 

canister be placed at the rear of the vehicle because of 

inadequate engine compartment space. Even that rear mour, .mg 

location cannot accommodate a significantly larger cams'-r 

without application of major new and untried packaging 

concepts. 

As overall vehicle sise decreases, the size of aany 

components decreases as well. However, in general, component 

sizes do not decrease in direct proportion to vehicle size. 

Furthermore, it is self-evident that passenger compartment 

size cannot be reduced in proportion to overall vehicle size 

if reasonable utility and marketability are to be maintained. 

As vehiele sise is reduced, therefore, available "real 

estate" for additional or larger functional components will 

decrease. 

A specific sxaaple of a group of components whose size cannot 

be reduced in proportion to overall vehicle size, is the tic 

conditioning systea. The capacity of that systea and, 

therefore, the size of the components (e.g., compressor, 

condenser and evaporator) Is a function of passenger 

coapartaent size rather than overall vehicle size. As an 

appropriate numerical comparison, the Chevrolet Nova 

passenger coapartaent is 80% as large as that of the 

- 11 -
P.60 

" ^ 

Chevrolet Capci.ce (EPA volume index of 86.5 versus 108.3, 

respectively) even though the curb weight of the Xova (as an 

overall vehicle size indicator) is only 60* of th'e Caprice. 

Even if they could be perfectly optimized, the Nova air 

conditioning components would be expected to be 80% the size 

of the Caprice components rather than 60%. 

Suspension cbmponents are another obvious area where "real 

estate" requirements do not decrease in proportion to overall 

car size. The entire range of wheel sizes for all cars sold 

In the U.S. (except a few sports cars) is only 13 to 15 

inches. Furthermore, suspension control arm "real estate'' 

requirements are dictated primarily by pivot point location 

and resulting link lengths which change little with car size. 

There are also technical constraints on the hardware for 

onboard refueling control systems which aggravate the small 

car problem, while canister size might be reduced cougnly -.-

proportion to fuel tank capacity, plumbing size (piping and 

valves) cannot. Plumbing size is dictsted by the raaximurr 

tank fill rate likely to be encountered (10-12 gal./min.) 

which Is, of course, s service station dispenser 

characteristic and therefore independent of vehicle size. 

Canister geoaetry constraints will also act to prevent use of 

the last available liter of irregular vehicle "real estate" 

since canister efficiency requires a reasonable length to 

diaaeter ratio. 

All things considered, it is clear that a new requirement f:: 

an additional or larger charcoal canister would be more 

likely to seriously encroach upon usable luggage compartment 

space, fuel tank size or even passenger compartment space of 

saall cars than on larger cars. 

while EPA may be correct that onboard systea packaging problems 

are not insurmountable, the likely encroachment (at least for 

many cars) into luggage or fuel tank space must be considered 

more than an inconvenience. As suggested above that 

inconvenience will not be "designed out" in future new models, 

since space effieiency will inerease leaving less available space 

for additional or enlarged components. 

The EPA discussion of the "weight penalty" in this response l-as 

been addressed in Seetion 03 as follows: 

In its response to this question, EPA discusses their "...35 

par vehicle fuel recovery credit for onboard controls..." 

That diseussion goes on to specifically state that the weight 

penalty for onboard control hardware "...reduces the recovery 

credit by an average of about 26% for passenger cars, light 

trucks, and heavy trucks. "We find it curious that there is 

no recognition in this discussion that EPA's July 1984 

"...Strategies for Gasoline Marketing Industry" document 

indicated (page C-23) that the added hardware weight would be 

- 12 -
P.61 

exoected to completely offset the energy value of the 

recovered fail vapors. The appropriate paragraph states m 

its entirety: 

Aa was stated in the previous EPA report (Appendix AJ, 

the implementation of an onboafd vapor recovery 

reSuiriment would not be expected to iapact LDV or LOT 

fuel consumption. Hydrocarbons retained by the onboard 

canister represent about 0.1 to 0.2% of vehicular fuel 

consumption; The use of this fuel by the engine could 

thus be expected to decrease fuel consumption by this 

amount. However, the additional fuel needed to 

transport the added weight of the onboard system is als 

in this range. Thus, no net change in fuel consumption 

is expected. 

also 

MVMA believes the 1984 EPA statement of the technical facts 

is correct, while the subject discussion refers to an 

attached "enclosure," that document does not provide 

sufficient detail to understand the reasons for the major 

change In EPA's thinking in this matter. However, 

Attaehaent 3 to this commentary, subaitted to EPA In May J! 

1986 by an MVMA member company, discusses the Importance of 

considering the necessity for an equivalent (acceleration) 

performance basis and the reality of weight compounding in 

such analyses. That document concludes there indeed would be 

no net energy benefit of onboard control systeas even if -.he 

recovered gasoline vapor could be utilized by the engine «t 

normal metering effectiveness — a highly unlikely 

ci rcumstance. 

It should also be noted that the foregoing presumes complete 

effectiveness in capturing, as well as utilizing, tha refueling 

vspors. As discussed elsewhere in this doeuaent, the EPA 

prediction of 93% efficiency for onboard systeas represents a 

substantial overstatement. Consideration of a realistic capture 

efficiency In the added weight versus recovered energy trade-off 

would likely result In a significant negative energy benefit for 

onboard control. 

13 -
p.e 

MVMA COMMENT ON EPA RESPONSE TO QUESTION^: Regarding Control 

Fuel Oispensrng'Rate 4 

MVMA agrees that an onboard refueling control system would 

require thst fuel dispensing rate be controlled, but also 

believes that enforcement would be necessitated. 

Limiting fuel dispensing flow is a commendable objective for E?A 

to pursue toward reducing volatile organic compounds (VOC) from 

retail fueling operations because it would set a fixed design 

target for vehicle manufacturers. Note, however,that 

manufacturers could not be responsible for the failure of station 

operators to observe a flow rate limit. If onboard control is 

required, a fixed dispensing rate must not only be considered, 

but must also be promulgated and enforced in order to realize 

maximum benefit. Liquid seal systems would be most vulnerable to 

spillage and spitback when design dispensing rates are exceeded. 

Alternatively, mechanically sealed systems, when subjected to the 

common "topping-off" operation at the end of self-serve fills, 

may experience tank pressurization as a result, exhibiting 

spillage on extraction of the nozzle spout froa the fill pipe. 

MVMA believes it is realistic to anticipate nozzle design rate 

violations that would defeat the intent of the rule unless an 

enforcement provision is mandated. This maxiaua delivery rate 

enforcement issue has not been addressed by EPA. The cost of 

that enforcement effort accrues as a cost against "onboard" and 

further reduces the cost-effectiveness of onboard vapor recovery. 

The unwillingness of station operators to accept any new exposure 

to the liabilities of potential refueling recovery system nozzle 

shut-off failure would likely force them to demand replacement or 

retrofitting of their equipment with pressure switches. The 

nationwide Introduction of pressure switch-equipped dispenser 

nozzles is an important hidden cost which EPA has chosen to 

ignore in every analysis. This significant non-vehicle factor 

would increase the total cost of onboard refueling and critically 

reduce its cost effectiveness, requiring both new initial capital 

as well as a maintenance Increment for the pressure switch 

Itself. This need for such a protection in the nozzle has be-in 

recognized by the Petroleum Equipment institute in July, 1981, 

(Ref. "Tulsa Letter - PEI" 26 July 1984, Attachment 1) and 

appears in the Gasoline Marketing docket. 

- 14 -
July 21. 19« 

Tulsa Letter 

Ba am. '•**•> 9eeM»e) r»ltn i teaaamwm ifie 'eMKli 

P.63 

Dear PEI Member: 

Air sollutloa ia aeet U.S. cities exceeds stsadards set by Co«-

grase «aer the Claaa Air Aat. oae way ee reduce this pellutlea is eo 

capture the displaced gaeellae vapors thst fleet eut through tha fillpipe, past the aessla sad late the atmosphere, each tlaa ea automobile is 

refueled. Eetlaaeas are that fee every 1.000 galleae ef easellae pumped 

at eerrlaa • tat lea a, 10 pe«Ads ef displaced hydrocarbea vapors escape lace 

eha air. These vapers rise aad form a eaeg-produciaf canopy ever every 

aajor city. Saleetlsts caa measure the ceaceatratloa of the vapors vMch 

cellect ia aatropelleaa skies. Xa populous areas • the level ef uaburned 

bydreearbeaa, produced by vapers that escape from uncoetrelled bulk planes, 

teralaaloi dry cleaning pleats, automobile rafuellag feallltlae. aad chealcal pleats, asovmco ee hundreds of teas each year. 

what this weans, apparenely, is ehst even if the regulatory soluelea co ehe refuel las vapor problem euros out eo be a require-none for -inboard eaalseerat le will etlll be noceseary eo replace ehe aosslee en ehe 

aatloa's fueling facility pumps with new aotzles of s teaevhae dlfferene 

design. A tight seal will be required at ehe flllplpe. If there is noe a 

tight seal* displaced vapers will eeatiaue eo eeeape into the air around 

the aessle spout. The seal could be produced by s device oa the nossle 

spout itself, or by use of s sealing rlag inside the flllplpe. Ia all 

probability, the requirement will be for s aeel iaslde the flllplpe. If 

tha aessla wars designed ts crsata a seal, it would also create pressure 

problems ia the tsaka ef vehicles not flttsd with the overslse caalatsrs. 

Use of a aaallag device iaslde the flllplpe, then, presumably will be 

dictated. Eves so, soma arrsageaeae aust ba made for relieving excess 

prsseure that aay occur ia tha fuel eaak—ia elreiautancae, for exaaple, 

where a vapor blockage develops between ehe fuel eaak aad ehe carbon 

caaletes- system* Use ef seme sort of presoure-rallsf device oa ehe nossle 

Itself weald appear te be the oaly way of handling preesure build-up 

problems ia the vehicle's fuel system. 

fulsalateer/MT ii. [Ml/Fate 1 

- 15 -
TulsaLsttsr/July, 26, 1984/Pags 3 

P.64 

.^. oil company peep la are also prlvaeely expressing concert 

about tha lele vapor pressure levels of aodern gasoline blends if onbeerd 

rystsas ars dlceated. tsfiaers ars producing aa exeeaa of butane and 

prepaae ehese days, aad te dispose of ehsas light eads ehsy are blending 

ehea late their gasoline stocks. If s closed fueling systaa la used in 

auteeebllao sad trucks, with s eight seel at the oossls/flllplpe Interface , pressure probloas could, conceivably, occur ia ths ayacea. 

If the ul><«-»*• »-alutlon ee ehe gasoline rsfuelias vapor problem 

doee turn out to be the onboard systea, aad if aosslis of a new design «->• 

required, they will have te be installed nationwide. Plsaalng for Seage 2 

systems largely has boea confined to aaeropolleaa areas. Somewhere 

between 30 aad 30 large cielaa have been eargeced, at various timet, for 

Stsge 2. If all now cars coming out of Detroit are equipped wlch onboard 

canisters sad with s sealing device ia tha flllplpe, however, aosslee 

capable of providing pressure relief auat be iascslled at every recall and 

private gasoline fueling facility. 

- 16 -
rh^rcoal Capacity 

MVMA'S discussion on EPA's April 24, 1987 reply to your Question 

14 about carbon capacity to supply the total domestic industry 

follows. 

It is the understanding of MVMA that suppliers of activated 

charcoal to the automotive market could require 24-30 months 

leed-tims aftsr contract commitments aade by canister 

manufacturers. Contract commitments would, by their nature, 

include annual voluae projections. However, these usage 

projections would be available only after the following aequence 

of events: 

1. EPA promulgates onboard rule including test procedure 

and regulated standard. 

2. Autoaotive aanufacturers perform ressarch and 

developaent. 

3. Manufacturers coaplete prototype cycles including 

perforaance testing. 

4. Manufactursrs accuaulate in-use vehicle test fleet 

data snd analysis. 

5. Manufacturers make canister sizing and tooling 

decisions. 

6. Manufacturers enter into contract commitments to 

charcoal suppliers. 

•17-
It is anticipated that this final step, i.e., contract 

coaaitaents, would occur in the range of 28-35 aonthi/'after 

proaulgation of a final rule. Low-risk capital investment 

decisions by the carbon Industry may anticipate buyer production 

volumes by 4-8 months in advance of actual commitments. 

This analysis considers the interaction of the timetables of two 

of the three domestic Industries faced with an onboard rule, and 

It reinforces the need for the stated (and restated) 48-month 

lead-timo. The third affected industry, petroleum equipment 

suppliers, to our knowledge has not revealed any timetable. 

In the Adainlstrstor's reply to your question on eoaaerclal 

charcoal capacity, EPA projects total motor vehicle esrbon 

requirements will increase three to three and a half times the 

current annual usage. 

Factors which Influence MVMA's projections of 4 to S times 

current use are: 

1. Inclusion of all heavy-duty gasoline vehicles (with 

larger tanks). 

2. Dual canistsr designs (non-integrated). 

3. Packaging-driven canister geometry and the adverse 

effect cn adsorption of the heat of condensation. 

-18-
P.67 

4. Uncertainties of effects, of oxygenated fuels on long 

tera carbon performance. 

5. Reduced purge vacuum at altitude considering the 

requirement to certify each family at both high 

altitude and at sea level with no hardware distinctions. 

6. Unknown effects of future octane boosters on carbon 

performance (fuel additives are beyond auto 

manufacturers' control). 

7. Improved passenger car aerodynamics causing Increased 

operating temperatures and coincident Increase In tank 

vapor management burdens In-use. 

Notwithstanding this list of factors, canister sizing would also 

depend on the variables originally outlined by EPA, including 

test fuel temperature, tank fuel temperature, fuel volatility and 

delivery rate, exhaust emissions and driveability purge 

scheduling, the test cycle, and auxiliary cell cooling allowances 

on the dynamometers. 

On the question of ths letter from North American carbon, 

regardless of agreement or disagreement on its accuracy, if a 

rule is promulgated, a significant tonnage would likely be 

sourced with specialized companies. The environmental impact on 

•19-
locale or region as a result of a 4 to 5-fold production increase 

must be considered before a rulemaking on refueling vapors. An 

example of such a locale would be Charleston, South Carolina. 

Onboard recovery technology centers on the reliable regenerative 

capability of activated carbon in canisters. However, EPA's own 

in-use testing demonstrates that commercial gasolines are 

contributing to a deficit in that capability to regenerate 

freshly available adsorptive capacity after tens of thousands of 

miles in some cases. 

Thus, s rational approach to any new rulemaking- which would 

intiaately rely upon a technology exhibiting evidence of 

degenerated performance using uncontrolled non-test fuel must be 

to, first, determine the nature and cure for that degenerated 

performance. In that regard, MVMA disagrees with the EPA 

conclueione linking certsin degraded evaporative control 

performance with any parameter of "poor vehicle design." 

-20-
Design Alternatives 

P.69 

1 

HVHA has several thoughts on EPA's discussion of onboard, system 

design alternatives, rsfusling valve designs, and design 

criteria. 

The Technical Report suggests a "design alternative" for onboard 

recovery, but after a review of the practical aspects of its 

implementation, MVMA questions the value of such an alternative. 

The virtues of the alternative system are discussed in the EPA 

report as having improved crashworthiness and as "to perhaps 

improve crashworthiness over current vehicles.1' 

A schematic of this systsm is shown on p. 53 (Pigure 18) of the 

Technical Report, AS described, It affords a good example of the 

48-month lead-time required to integrate new systems into models 

based on a coaaon platfora. By dsslgn, this systea requires a 

liquid-sealed fill pipe or "J-neck" to eliminate the existing 

external fill pipe vent tube. Generally the elimination of 

potential sourcss of liquid fuel loss is a desirable objective. 

In that context, presuaably the absence of the external vent is 

how EPA would justify an iaproveaent in crashworthiness over 

current vehicles. However, this technique is not applicable to 

all vehiele designs. We provide a separate discussion on 

external vent tubes latsr In this attachment. 

-21-
P.70 

As a recent MVMA contracted study points out, and corroborating 

the findings of an EPA investigation, a minimum liquid* head in 

the fill pipe of 14 to 16" at 8-10 gallon's per minute (GPM) 

filling rate is necessary to maintain the liquid seal in this 

design. For many existing models, ths creation of such a liquid 

head would require major changes in the design of the fuel tank 

and fill pipe, while some other models would not allow such a 

revision due to body shape constraints. 

If features of this EPA alternative could be incorporated into 

the fuel tank fill pipe zone, two additional packaging tasks 

would remain: 

1. installation of the "Mechanical or Solenoid Actuated 

vent/Rollover valve, Limiting Orifice, and Vapor Liquid 

Separator" between the body floorpan and the top of the 

tank. 

2. integral vapor canister enlarged initially to 

accoaaodats the refueling vapor load (and enlarged again 

to aeeoaaodate the extra refueling vapor generated as a 

consequence of the "J-neck" design) to be located with 

alniaua length refueling vapor transfsr tubing. 

The first of these two reaalnlng packaging requireaents implies 

alterations in the floorpan and/or the top of the fuel tank, 

requiring advance tooling time and structural validation through 

-22-
P.71 

actual impact tests to accommodate the EPA alternative refueling 

valve location. Implicit also is the potential consequence of 

lost tank liquid voluae in order for the-designer to incorporate 

this valve feature above the liquid level while protecting 

traditional design objectives for minimum allowable expansion 

voluae and for minimizing the effects of "slosh" dynamics 

encountered during vehicle cornering. Lowered tank liquid 

capacity must be recognized as a customer inconvenience. 

The second packaging requirement, placemeat of a single refueling 

vapor eanister, further enlarged to accept the added burden of 

excess vspors csused by the open "J-neck" design, aay also 

require long-lead underhood or underbody changes to nest the 

overall esnister voluae, its large pluabing, and its brackstry. 

In consideration of this, although the piece costs would bo 

higher, a manufacturer may be forced to package two canisters, 

the second dedicated to managing refueling vapor alone. The 

added weight and the pluabing coaplexity of a two-canister system 

could be the direct consequence of a regulatory schedule 

constructed by EPA so ss to place onboard recovery on parity with 

the inherently aore readily iaplemented Stage II control systea. 

Por tha reasons and uncertainties outlined above, MVMA questions 

tha value of this alternative, and we have a continuing concern 

about the efficacy of any liquid-sealed onboard systea at nozzle 

delivery rates below 8 GPM. 

-23-
Valvi DiSlgn 

The Technical Report offers a commendable but simplistic 

assessment -of some suggested refueling vent valve designs. 

Ssvsral design suggestions are evaluated against only three 

criteria which raises the concern that EPA may not fully 

appreciate the comprehensive requirements for multiple features 

of a refueling vapor recovery system. 

MVMA recognizes that the purpose of the Technical Report Is to 

address safsty Issues. Nevertheless, aside froa rollover 

performance, refueling valve actuation, and crashworthiness 

objectives, the designer's attention aust also focus on the 

interaction of the operator with the dispensing nossle snd the 

vehicle. Notwithstanding gross component failures, other 

variables affecting the safety of the refueling event, assuming 

no taaperlng, Include nozzle shut-off threshold, fueling rste, 

rate of flllplpe column build, conditions affecting tank pressure 

during fueling, control of nozzle engagement depth, nozzle spout 

geoaetry and condition, and overfill relief function. Since the 

aajority of these variablss are outside manufacturers' control, 

NVHA strongly urges EPA to review the available evidence 

supporting the assumption that conventional nozzles, under all 

condltleaa, would be fully compatible with, and would be expected 

to safely refuel onboard recovery-equipped vehicles. 

-24-
P.73 

Bladder Tanks 

The concept of a flexible bladder or diaphragm in the tank is 

suggested in the Technical Report as the ultimate system for 

prevention of .refueling vapor losses. 

An Investigation of this concept by General Motors in the late 

1960's revealed that if a flexible, fuels-compatible material 

could be found for the bladder, it may become possible to develop 

an evaporative control system supplemented by a charcoal 

canlstsr. Thst Investigation further revealed that a means for 

pressure relief would be necessary because of the high vapor 

pressures expected inside the bladder under warm conditions. 

Also, the study predicted that refueling losses, although 

theoretically substantially rsduced, would not be zero beesuse of 

natural vapor growth under the surface of the bladder. 

Several unresolved engineering questions about ths concspt are 

overfill protection, fuel level gauging, bladder material 

selection for high strength and maximum flexibility at all 

teaperatures, and total tank performance and reliability. Thus, 

this systea presently does not represent a viable production 

alternative. 

-25-
P.74 

System Complexity 

* 

The Technical Report suggests system safety need not be 

compromised by added complexity. EPA has suggested that the 

suscsptibility to damage of, for example, a nozzle-actuated 

rollover valve should be relatively the same as that of current 

gas caps, fill pipes, and vent lines. MVMA contends that no 

valid conclusion msy be drawn about systea safety when only 

single components of that systsm are evaluated for their 

Integrity relative to existing componentry. Even if each 

discrste eoaponent of two csndidate systsas were judged to have 

equivelent susceptibility to dsasge, the system with one fewer 

component thsn the other is intuitively safer than the larger 

one. Susceptibility is cuaulative and aay be proportional to the 

number of discrete components. 

Therefore, the notion of single-component "relative 

susceptibility" is irrelevant and ignores the actual 

responsibility of aanufscturers who must build hundrsds of 

thousands of such coaplete systeas to perform reliably under all 

foreseeable conditions thus accepting the total, or cuaulative 

susceptibility of a final production design. 

Elsewhere in the report, EPA rationalizes added coaplexity as a 

potsntial for incresssd vehicle safety, citing exaaples of 

elsctronic engine controls and computer-controlled suspension 

systeas. MVMA fails to understand the association between the 

-26-
P.75 

safsty of electronic controls and the new risk of firs hazards 

rssulting froa the addition to the vehicle of more and larger 

fuel vapor and liquid handling components. 

The Technical Report suggests crashworthiness of onboard systems 

should be the saae as that of existing evaporative eaisslons 

systsas. in fact, MVMA asmber companies are aware of no 

production onboard refueling vapor recovery systems which can be, 

or have been evaluated to support the statement that "...there 

should be no new or unique problems in this area." 

-27-
P.76 

Rollover Protection 

»* 

MVMA agrees with the expressed opinion of Mr. Miller of the 

National Highway Traffic Safety Administration (NHTSA) in his 

testimony before the Subcommittee on April 27, 1987, that 

additions to fual systems do not need to compromise safety and 

that onboard refueling vapor recovery would require that 

manufacturers must be given sufficient lead-time to ensure no 

compromise. 

A recurrent theme in the Technical Report is that onboard systems 

could register an improvement in safety over that of current 

evaporative control systems. The origin of this "improvement" 

seeas to be the potential for adding a rollover protection velve 

at the terminus of the fill pipe's vent tube and integrated into 

the nozzle-actuated refueling valve compared to no rollover 

protection at that location on current vehicles. 

For the purpose of clarification it is well to make the 

distinction between current fill pipe vent tubes and a fill 

pipe-aounted refueling/rollover vapor transfer tubs. A typical 

current fill pipe vent line (e.g., 1/2 inch diameter) is parallel 

to the fill pipe and, at the conclusion of a refueling event, 

forma a closed liquid loop between the tank and its fill pipe 

mouth to assure nozzle shut off. Its proximity to ths fill pipe 

is such that crashworthiness requirements for the two are nearly 

Identical. At least one manufacturer, on some models, includes 

that venting function inside the fill pipe itself. A fill pipe 

-28-
P.77 

separation, for example, and any subsequent gross liquid loss 

would render the smaller vent tube path less significant for its 

potential contribution to total liquid loss. 

By contrast, each rollover valve design example presented by EPA 

in Figures 9-15 of the Technical Report creates a unique path 

leading to the vapor canister. This new direct path could 

transfer tsnk liquid to the remote canister, and equally 

important, to any intermediate vent line points leading away from 

the valve assembly toward the canister. Thus, a protection 

feature is justified to prevent liquid escape froa or through 

that path. However, for damage or openings between the tank and 

the top of the fill pipe along the vent tube, the added rollover 

valve would afford no added protection compared with current 

practice. 

As EPA recognizes, impacts could expose any new fuel system 

coaponentry to damage and, as NHTSA emphasizes, Fsdsral Motor 

Vehicle Safety Standard 301 does not quarantee crashworthiness 

protection for every potential condition. Therefore, it is 

viewed as mandatory that, unlike unprotected parallel and 

proxiaate fill vent tubes, new tubes which exit the fill pipe 

zone to other locations and which have the potential for liquid 

transport be protected with rollover protection, without such 

protection, tank pressure could force fuel to flow froa any new 

openings Incurred by an Iapact, or into the canister itself. 

-29-
P.78 

Thus, the response of manufacturers to a rule which first adds a 

new increment of susceptibility to damage would then /nclude any 

precautionary changes or additions necessary to cancel that 

increment.. Therefore, manufacturers' attempts to preserve 

susceptibility at a pro-rule level cannot be construed as safety 

"improvements" over the existing fuel system. 

-30-
P.79 

Heavy-Duty Vihiclis 

Heavy-duty vehicles by thsir very nature present more difficult 

onboard refueling design problems than light-duty vehicles. 

Heavy-duty vehicles are built for a wide variety of applications, 

aany of which are very low voluae. From a design standpoint, 

eech unique configuration would require its own development, and 

therefore generste additional engineering costs, as is necessary 

for current evaporative eaission requireaents. Also, It Is not 

uncoaaon for the prlaary aanufacturer to ship an incoaplete 

vehicle to a body builder for final asseably. In fact, of the 

two domestic heavy-duty gasoline vehicle manufacturers, 100% of 

one aanufaeturer's Class III production is shipped as incomplete 

vehicles. The added fuel systea coaplexity of en onboard systea 

can be expected to aggravate the safsty concerns associated with 

certain sscondary vehicle aanufacturer modifications. The 

economies of seals available with passenger car production are 

not aa applicable to heavy-duty vehicles. 

An laportant factor affecting the design of refueling vapor 

recovery systeas for heavy-duty vehicles, which Is significantly 

different than for light-duty vehicles, is fuel consuaption. A 

heavy-duty vehicle carries auch heavier loads and aecoapllshes 

considerably aore work and, thus, consuaes mors fuel per mile 

thaa a light-duty vehicle. As S rssult, a heavy-duty vehiele 

would be required to purge aore refueling vapor per aile than a 

light-duty vehicle. For exaaple, a heavy-duty gasoline-powered 

-31-
P.80 

truck, with a fuel economy of six miles per gallon, will consume. 

almost 17 gallons of fuel pi* 1°° «i.lia traveled, whereas a 

light-duty vehicle, with a fuel economy of 25 miles per gallon 

will consume only four gsllons per 100 miles. Since the 

refueling vapors generated are directly proportional to the fuel 

dispensed and consumed, a heavy-duty vehicle produces, and would 

be required to purge, more than four times the saount of 

refueling vapors than a light-duty vehicle. This difference 

alone greatly Increases the difficulty of designing a control 

systsa that would provide adequate canister purge for a 

heavy-duty vehicle coapared to a light-duty vehiele. 

Coapounding the difficulty of designing s refueling vspor storage 

systea for heavy-duty applications is the problea of purging the 

canisters. Engine vacuum Is used to purge the canisters of their 

hydrocarbon vapors. However, the duty cycle of many heavy-duty 

vehicles requires auch operation at or near wide open throttle, 

where engine vacuua is near zero. This serves to reduce the 

hydrocarbon purge flow to the engine. 

It is laportant to note that although the fuel consuaed on a per 

vehicle basis is auch greater for a heavy-duty vehicle than for a 

light-duty vehiele, the total aaount of gasoline consuaed by all 

heavy—duty vehicles is only 6% of the total aaount of gasoline 

eonsuaed by sll vehicles. Because the heavy-duty vehicle portion 

of total refueling vapors Is so saall, It Is difficult to justify 

the aueh greater design coaplexity and extra cost per vehiele 

-32-
P.81 

that would be required to install refueling vapor recovery 

systeas on heavy-duty vehiclii. J 

Safety is also an issue which aust be considered in the design of 

onboerd refueling systsas for heavy-duty vehicles. Regulatory 

requireaents aust be aet. Federal Motor vehicle Safety Standard 

301, fuel systea integrity, Is clear In Its applicability to some 

heevy-duty vehicles. 

Federal Motor Carrier Safety Regulations rsquire additional 

design considerations relative to fuel tank design. These 

include e fuel tsnk drop tsst, safety venting systsa, and for 

fuel tenks greeter than 25 gallons cspscity, a alniaua sceeptsble 

gasoline fill rate of 20 gallons per ainute for vehicles engaged 

In Interstate commerce. Sines no heavy-duty vehiele onboerd 

refueling systeas have yet been aade public the additional costs 

and tiae to achieve eoaplianee to all federal requireaents have 

not been deterained. The 20 gallon per ainute flow rate 

discussed above also conflicts with ths draft EPA refueling test 

procedure, which specifies a tsn gallon per ainute flow rate. 

Onboard systea design requirements sre also aors stringsnt for 

heavy-duty vehicles than light-duty vehicles. Fuel tsnk sizes 

vary la heavy-duty vehicles, from around 20 gallons to over 100 

gallons. Larger fuel tanks will rsquire proportionally larger 

refueling vapor canisters than light-duty vehicles. Although 

some trucks may havs specs available for larger refueling 

-33-
canisters, the optimal canister design parameters, such as 

length-to-diameter ratio, aay not be met due to space' 

considerations. Smaller canisters could be connected in parallel 

or in series, but with a concoaitant Increase In systsa 

complexity and cost. Furthermore, canister locations under the 

hood, near clean, dry air for the canister purge air inlet, may 

be sacrificed due to the size of the canister(s). Less desirable 

locations, under the truck bed for exaaple, may be required, 

forcing the addition of more components, such as splash shields 

snd sir inlst tubing, to assure a source of elean air for the 

purge. On aany applications, such as rscreational vehicles, 

large fuel tanks are combined with a lack of available space for 

large canistsrs. Soae of the interior voluae of the recreationsl 

vehicle would naed to be given up to aake rooa for the 

canistsr(s). 

Congress recognised the needs of heevy-duty vehiele aanufscturers 

when the Clean Air Act was aaended in 1977 and a four-year 

miniaua lead-tiae was given to these manufacturers for 

developaent of eaission cor-erol systeas. An onbosrd requirement 

is st least as stringent ss other regulations which have been 

promulgated, and a four-year lead-tiae may not even be sufficient 

for all heavy-duty vehicle configurations. The issuee discussed 

above, including onboard systea design, vehicle peekaglng, 

control of purgs flow, and safsty will require tiae to resolve. 

Siailarly, heavy-duty vehicle onboard control systsas costs can 

not be easily ascertained. At this point, it csn only be ssid 

-34-
P.83 

that a typical onboard system for heavy-duty vehicles will 

probably coat auch aore than a system designed for Ught-duty 

vehicles. 

8:28 

-35-
P.84 

NISSAN RESEARCH & DEVELOPMENT, INC. 

3995 Research Park Drive 

P.O. Box 8650 

Ann Arbor, Michigan 48104 

Telephone 

(313) 665-2044 tf 

June 17 , 1987 

Ref: W-152-S 

The Honorable John D. Dingell 

Chairman, Committee on Energy and Commerce 

U.S. House of Representatives 

Room 2125, Rayburn House Office Building 

Washington, D.C. 20515 

Dear Mr. Chairman: 

Our trade Association, the Automobile Importers of America 

(AIA), forwarded to us your May 11, 1987 letter requesting 

auto manufacturers' comments on onboard technology issues, 

from a safety standpoint in particular. Nissan appreciates 

the opportunity you have provided for expressing our views 

and concerns. 

As we informed you by letter dated May 1, 1987, Nissan did 

conduct an extensive feasibility study on onboard refueling 

controls. A copy of our Statement on Gasoline Refueling 

Vapor Recovery Controls and that feasibility study, 

Technical Information on Recovery Regulation, were attached 

to our May 1 letter. Those materials constitute our fullest 

statement on onboard controls as they affect Nissan's 

products. 

We believe that the answers to your specific requests are, 

for the most part, contained in the Technical Information 

document. The chart attached references the sections and 

page numbers where we address the issues that you raised. 

We regret that in some instances we may have not fully 

answered your questions, but we prefer to adhere to our 

comprehensive statement. 
P.85 

John D. Dingell 

June 17, 1987 

Page Two 

Incidentally, the materials enclosed in our May 1 letter 

were presented to EPA Administrator Lee Thomas and his staff 

at a meeting on May 15, 1987. I have enclosed a copy of 

Nissan's abbreviated presentation to Mr. Thomas, for your 

reference. 

Please contact me or Mr. Hiroyuki Shinbara of my Washington 

staff if Nissan can provide you with further information. 

Mr. Shinbara can be reached at (202) 466-5284. Again, we 

thank you for the opportunity to share our views on this 

important issue. 

Sincerely, 

Toshic/Maeda / *^«>u« _ 

Executive Vice President 

& Chief Operating Officer 

Enclosures: 

1. Response chart 

2. Presentation to EPA Administrator, May 15, 1987 

cc: The Honorable Charles A. Bowsher, Comptroller General 

General Accounting Office 

The Honorable Lee M. Thomas, Administrator 

Environmental Protection Agency 

The Honorable Elizabeth Hanford Dole, Secretary 

Department of Transportation 
P.86 

A REFERENCE OF NISSAN'S RESPONSES 

TO CONGRESSMAN JOHN DINGELL'S MAY 11. 1987 LETTER 

ON ONBOARD CONTROL FEASIBILITY 

(SOURCE: TECHNICAL INFORMATION ON RECOVERY REGULATION. 

NISSAN MOTOR CO., LTD., APRIL, 1987) 

QUESTION/ITEM IN OUR TECHNICAL INFORMATION. 

SEE THIS SECTION: (PAGE) 

* CANISTER LOCATION & 

SAFETY 

* SAFETY & LEADTIME 

* LEADTIME & COST 

* EPA'S 3/25/87 

RESPONSE TO DINGELL: 

1. 

2. 

3. 

4. 

CANISTER SIZE 

CANISTER INSTALLATION 

PURGE TECHNOLOGY 

SPITBACK & FUEL 

DISPENSE RATE 

EPA'S 4/24/87 

RESPONSE TO DINGELL: 

1. CANISTER SIZE 

II-l-B CANISTER LOCATION 9-17 

II-2 VENT CUT VALVE 17-19 

III COST & INCONVENIENCE 26-35 

II-l-A CANISTER CAPACITY 

II-l-B CANISTER LOCATION 

I1-4 PURGE SYSTEM 

II-3 SEAL 

9-10 

11-17 

24-25 

19-23 

II-l-A CANISTER CAPACITY 9-10 
P.87 

NISSAN RESEARCH & DEVELOPMENT, INC. 

3995 Research Park Drive 

P.O. Box 8650 

Ann Arbor. Michigan 48104 

T.kphoe. 

(313) 665-2044 

NISSAN MOTOR COMPANY. LTD. 

PRESENTATION BEFORE 

THE HONORABLE LEE M. THOMAS 

ADMINISTRATOR, ENVIRONMENTAL PROTECTION AGENCY 

REGARDING 

ONBOARD GASOLINE REFUELING VAPOR CONTROL 

MAY 15, 1987 

PRESENTED BY: 

NISSAN RESEARCH & DEVELOPMENT, 

INC. 

Toshio Maeda 

Executive Vice President 

& Chief Operating Officer 

L 
P.88 

NISSAN MOTOR COMPANY. LTD. 

PRESENTATION BEFORE EPA ADMINISTRATOR ON 5/15/87 

(GIVEN BY TOSHIO MAEDA, NISSAN R&D . INC.) 

FIGURE 1 

Figure 1 shows the basic onboard vapor control system. The 

basic system needs are the refueling canister, vent cut 

valve, seal, and purge control. 

— The CANISTER adsorbs gasoline vapor; 

the VENT CUT VALVE connects and disconnects fuel tank 

and canister; 

the SEAL prevents gasoline vapor from escaping; 

— and the PURGE CONTROL transfers gasoline vapor to the 

engine where it is burned. 

FIGURE 2 

Figure 2 shows the significant onboard system development 

factors related to lead time. These development factors are 

for development of new technology for each system component. 

They also include' confirming the safety, exhaust emissions, 

driveability and durability performance of the "whole" 

vehicle with the onboard system. 

First, the refueling canister design must be optimized to 

relate to new factors such as shape and higher temperature 

swings. Also, installation of this canister will lead to 

sheet metal changes, which in turn requires die changes. 

As a result, in order to ensure compliance with safety 

requirements, we must conduct vehicle safety tests with the 

onboard system installed. Moreover, we will also need to 

conduct tests to ensure canister durability. 

Next, new technology for a variable orifice purge control 

must be developed, to overcome both worsened exhaust emission 

performance and poor driveability. 

This variable orifice purge system consists of a control 

circuit and a proportional solenoid valve. Compared to the 

one commonly used in our vehicles, this new valve requires 

radical change of the valve seat structure, which 
P.89 

significantly affects the seal performance and durability 

performance. This change would actually amount to the same 

development effort as for a whole new valve. 

Then, calibration and emission control, driveability and 

durability testing will be required. 

For the next major part, Nissan has studied two types of vent 

cut valves, a mechanical and an electric type. 

The mechanical vent cut valve must be installed on the inlet 

portion of the filler pipe, thus in the vehicle side impact 

deformation zone. At this time, we cannot be sure that the 

valve and associated vapor line will maintain fuel system 

integrity if damaged in a crash. 

To eliminate these concerns, the electric vent cut valve is 

being studied as a possible alternative. This electric valve 

consists of a small, lightweight refueling sensor on the 

filler pipe inlet portion, and a solenoid valve controlled by 

an electric circuit from a sensor. Since the solenoid valve 

can be installed any place outside of the deformation zone, 

the solenoid valve and the vapor line can more readily escape 

damage in a crash. 

This sensor requires further development. Also, we must be 

confident that it can withstand a vehicle side impact. 

The last item, the seal, is also a new technology with which 

Nissan has no experience. 

Nissan is convinced that to comply with EPA's draft refueling 

test procedures, neither the mechanical seal or the liquid 

seal are feasible for our models unless filler pipe 

configurations are redesigned. Sheet metal (or body design) 

changes are therefore necessary. Nissan also needs to 

develop a seal for each of eight different U.S. models. 

TABLE 1 

Table 1 shows the candidate locations for installing the 

canister. I'd like to point out that Nissan has considered 

every possible canister location for our vehicles. 

We have concluded it is infeasible to install the 

canister in the engine compartment due to severe space 

constraints. 
P.90 

(We have prepared these slides on the current engine 

rooms in three of our U.S. models — the Sentra (PHOTO 

1); the Maxima (PHOTO 2); and the 300ZX (PHOTO 3).) 

The passenger compartment is also infeasible without 

reducing occupant comfort, due to reduced compartment 

volume. 

Locating it next to the fuel tank is undesireable, since 

this would lessen the vehicle cruising range. 

And inside the trunk compartment and below the floor are 

also undesireable because of consumer inconveniences such 

as reduced trunk space and seating comfort, and the-loss 

of a flat floor. Also, sheet metal changes will be 

necessary. 

(PHOTO 4) Here is a slide of the trunk space in our 

current Maxima. 

(PHOTO 5) This slide shows the diminished space once a 

canister has been installed in the trunk. By the way, 

the canister was intentionally put in the forward area of 

the trunk, to.keep it safer in a crash. 

(PHOTO 6)-_ As you can see in this slide, a trunk that 

once could hold four suitcases can now only hold three. 

Installing the canister in any crush zone such as below 

the trunk will require reinforcement of the vehicle body 

structure, to prevent the canister from damaging the 

fueling system in the event of an impact. 

In any damage zone like the bumper or fender, canister 

damage by even a minor impact can lead to consumer 

tampering if refueling performance is impaired, and can 

cause undetected vapor leakage. 

Therefore, Nissan concludes that only the trunk compartment 

and below the floor are feasible as canister locations. In 

either case, sheet metal changes will be necessary. 

FIGURE 3 

Figure 3 shows that Nissan's filler pipes have a more complex 

configuration than the design used for EPA's seal 

development. This is because the compact design features on 

Nissan's current models compel us to use curved filler pipes. 
P.91 

The filler pipe configuration affects emission control 

feasibility relating to refueling emissions and refueling 

performance. 

The curved filler pipe can cause the liquid seal to release 

more gasoline vapor and will result in non-compliance with 

the refueling emissions standard. 

Moreover, such a filler pipe can cause premature shut-off and 

non-compliance with the EPA draft refueling test procedures, 

regardless of whether we use a mechanical or liquid seal. 

Thus, in order to achieve compliance, it will be necessary to 

change the filler pipe configuration and the body structure. 

FIGURE 4 

Figure 4 shows our time table for development of the onboard 

system. Our time table assumes that we will continue to 

devote resources to experimentation with onboard design 

concepts until a definitive requirement is established by the 

final rule. 

In the first year after the promulgation of the rule, 

Nissan will construct onboard refueling test facilities which 

correlate to the final test procedure requirements, and will 

start development to establish preliminary system choices. 

We anticipate that test facility construction alone requires 

10 (ten) months. 

Nissan recently did construct a new onboard test facility. 

Planning and construction took 14 (fourteen) months, because 

Nissan had no prior experience with the control of fuel 

temperature as required by EPA, or with the fire prevention 

facilities requirement of the Tokyo-Yokohama city government. 

Based on our experience, Nissan believes that remodeling of 

the existing shed test facility to accommodate onboard 

testing will require roughly the same efforts as would 

construction of a new test facility, due to our need to 

comply with the fire prevention regulations. 

In addition to upgrading the existing test facility to the 

additional specifications of the final rule, Nissan would 

require two additional test facilities to accomodate a 

requirement that 70% of production comply with the onboard 

standard in the first year. 
P.92 

After constructing the test facility, we can start to conduct 

the onboard test according to EPA final test procedures, and 

we can.start development aimed at establishing preliminary 

system choices. Those choices include selecting an 

integrated or non-integrated system, mechanical or liquid 

seal, mechanical or electric vent cut valve, and canister 

installation location . 

After establishing a preliminary system choice at 13 

(thirteen) months, Nissan will improve and calibrate the 

system in order to ensure compliance with safety and emission 

standards and to prevent poor driveability, especially under 

hot weather conditions. Then Nissan will set the significant 

system specifications which affect emissions performance-. 

The time needed from completion of the test facility to the 

decision on the significant specifications of the system is 

approximately 15 (fifteen) months. 

— After the decision on the significant system 

specifications at 25 (twenty-five) months, Nissan will start 

to evaluate the vehicle with the first choice onboard system, 

in order to show compliance with safety standards and to 

confirm acceptable driveability and durability under all 

weather conditions. 

The time needed from that decision to completion of 

confirmation testing on the safety compliance, driveability 

and emissions of the "whole" vehicle is 4 (four) months 

minimum. 

— 29 (twenty-nine) months after the promulgation of the 

final rule, Nissan will begin constructing the emission 

certification vehicles and then will begin exhaust emission 

durability testing to obtaii the data required to be 

submitted to EPA. 

The time needed for making the certification vehicle is 4 

(four) months. 

For light-duty trucks, the interval for required emissions 

durability testing is 13 (thirteen) months. 

— After durability testing, Nissan will apply for 

certification. The time between shipping of the 

certification vehicle and EPA's review of Nissan's 

application for certification is 3 (three) months. 

The time needed between obtaining certification and the start 

of mass production is 1 (one) month. 
P.93 

Therefore, for light-duty trucks, almost 50 (fifty) months 

are necessary from the promulgation of the final rule to 

start of mass production. 

For light-duty vehicles, the final-rule-to-production 

interval is 44 (forty-four) months, since the durability test 

period for those vehicles is approximately 6 (six) months 

shorter than for light-duty trucks. 

FIGURE 5 

For onboard system development, figure 5 shows that it is 

impracticable to follow essential development procedures if 

allowed only two years lead time. 

We cannot proceed with final test facility construction plans 

until we have final specifications. Construction will take 

ten months from the time we know the final test 

specifications. 

As you can see, for light-duty trucks we would have to make a 

system decision at the same time the regulation is 

promulgated — without benefit of development. Also, we 

would have to-begin certification of LDT's before we have 

completed the test facilities. Under EPA regulations, we 

cannot begin certification without testing the vehicle. 

Simply put, we do not have enough time to develop, evaluate 

and produce a system that we are confident will meet safety, 

emissions, durability and driveability requirements. And 

therefore we run the risk of failing federal requirements, in 

which case we would be forced to temporarily stop production 

and sales. We also risk choosing a design that proves 

infeasible in the market. 

FIGURE 6 

Figure 6 shows Nissan's full model change cycle. Currently, 

Nissan markets eight U.S. models, and the cycle of each 

individual full model change is between four to six years. 

In other words, one or two models are changed per year. 

In our lead time analysis, we have assumed, for 

simplification, that Nissan changes two models every year. 
P.94 

Each model group, such as A, B, C, or D mentioned in figure 

6, includes two Nissan models. And the sales volume share 

for each model group is between 15 to 30%. 

If the phase-in requires 70% of a maker's sales volume to be 

converted in the first year, then at least three of Nissan's 

model groups must be changed to accommodate onboard controls 

simultaneously, resulting in increased development costs and 

a loss of five production years of existing model life. That 

is, there is a loss of two years for model group "A" and 

three years for model group "B". 

TABLE 2 

Table 2 shows the cost increases estimated in the cases of 

two years and four years lead.time. 

Despite our conviction that it is infeasible to comply with 

an onboard regulation in a two-year lead time case, we 

prepared this analysis with the assumption that we could 

squeeze all necessary tasks into two years, to demonstrate 

the added cost of .increasing our R& D activity and 

interrupting model cycles. 

Nissan concluded that the lead time cases other than our own 

proposal will result in cost increases, due to increased R & 

D costs and the shorter sales interval for R& D and tooling 

expense recovery. 

For example, the expense for crash testing and other 

evaluation will be incurred only for the change of adding an 

onboard system, and the system cost increase will reflect all 

of this expense. 

The loss of model life occurs when we must introduce a model 

with different sheet metal and tooling before the completion 

of the existing model cycle. 

FIGURE 7 

Next, we would like to explain the cost of the onboard 

system. Figure 7 and Figure 8 show two kinds of onboard 

systems, both under consideration by Nissan. Because our 

development has not progressed sufficiently to allow us to 

choose specific onboard systems, our estimates are cost 

ranges. 
P.95 

Figure 7 shows a system which I will call "system A". System 

A is an integrated canister with a mechanical seal and a 

mechanical vent cut valve. 

FIGURE 8 

For comparison, figure 8 shows a system which I will call 

"system B". System B is a non-integrated canister with a 

liquid seal and an electric vent cut valve. 

TABLE 3 

Table 3 shows the onboard system cost estimated by Nissan. 

We estimated the cost for Nissan's Sentra and 300ZX models, 

assuming four years lead time plus phase-in of one model 

group per year. 

The estimated production cost ranges are from $46 to $61 

(forty-six to sixty-one dollars), and the retail equivalent 

cost ranges are from $84 to $110 (eighty-four to one hundred 

ten dollars) per vehicle. 

Major components of the cost estimate are the refueling 

canister, the variable orifice control system, and hoses and 

tubes. 

TABLE 4 

Table 4 shows the detailed estimate of canister production 

costs.' The cost of the charcoal carbon is about $5 (five 

dollars). The canister casing is about $3 (three dollars). 

And the cost of other canister parts is about $6 (six 

dollars). Totally, the production cost of the refueling 

canister is about $14 (fourteen dollars). 

TABLE 5 

Table 5 shows the detailed estimate of piping production 

costs. The cost of tubes is about $7 (seven dollars). The 

cost of hoses is about $5 (five dollars). And the cost of 
P.96 

other related parts is about $6 (six dollars). Totally, the 

production cost of the piping is about $17 (seventeen 

dollars). 

TABLE 6 

Table 6 shows the detailed estimate of variable orifice 

control production costs. The cost of a purge control valve, 

such as the proportional solenoid valve, is about $13 

(thirteen dollars). And the cost of revising the existing 

engine control unit is about $4 (four dollars) . Totally, the 

production cost of a variable orifice control system is_about 

$17 (seventeen dollars). 

CONCLUSION 

In conclusion, based on Nissan's engineering analysis and 

experimentation with onboard vapor controls, we believe the 

following: 

First, a four year lead time is essential for development and 

application of onboard controls. Phase-in of one model group 

per year will avoid increased costs due to mid-cycle model 

changes and increased development activity. 

Second, for Nissan's products, onboard controls will cost 

between $84 to $110 (eighty-four to one hundred ten dollars) 

per vehicle, with four years lead time plus phase-in of one -

model group per year. 
Intake Manifold Purge Control System 

Vent Cut Valve 

Seal 

Refueling Canister 

Fuel Tank 

F 1 G. 1 B A S I C ONBOAR D VAPO R CO NTRO L SYSTE M 
• FIG . 2 DEVELOPMEN T FACTOR S 

ONBOAR D SYSTE M 

DEVELOPNENT FACTORS OF ONBOARD SVSTEM 

O F 

J-J ' 1 

Canister - OptiBiia Design 

(New Factors! 

Shape,Temperature) 

--*-Installation 

-•-Die Change 

*-»*• far©IMIUftS$3 

Purge New Technology 

(Variable Orifice) 

Exhaust Emissions — 

Vent Cut —i-*- Installation 

Valve 

•—-New Technology 

-**- Driveabi 1 ity 

Seal New Technology^ gaifeftyS 

—-— Die Change 

-Refuelin g Emissions 

Feasibilit y 

[REMARKS] 

©SEAL NEU TECHNOLOGY: Mechanical Seal 

•Durabilit y of seal 

•Eaissio n Control Feasibility 

Concur I?n>j>(i E®i^fiePi7Qfta@iiSo $®@$ Elbaas®^ 

• Fault Design 

(in event of malfunction of automatic shut-off) 

Liquid Seal 

• Canister Size 

•Eaissio n Control Feasibility 

CPU Hap Pflwa EaraffafauiimftjisiiQiao Qafr (Qtaafso} 

Si/MOT: It is necessary to conduct the safety compliance tests in order to 

ensure compliance with @ai?QftJ7 I?(^l!]alP@flS@raft@o 

flfll I t i s necessary to conduct the exhaust caissions durabilit y tes t 

in order to ensure ftfixi ©anss&onis aftaradlaipdla eaaslliaraeti aad ftftxi 

JI„,,.w.>P.,:»!Am aUi AlV^. ennsv a ucnraA/sm ta-aGifil fifty @5 ftlba EUFSS asaftao-
P.99 

TABL E 1 CANISTE R INSTALLATIO N 

CANDIDATE LOCATION 

ENGINE COMPARTMENT 

PASSENGER COMPARTMENT 

FUEL TANK 

TRUNK COMPARTMENT 

BELOW THE FLOOR 

CRUSH ZONE 

(BiLOf THE TRUNK) 

DAMAGE ZONE 

(BUMPER/FENDER) 

FEASIBILITY 

NO 

NO 

UNDESIRABLE 

UNDESIRABLE 

UNDESIRABLE 

NO 

NO 

COMMENTS 

NO SPACE AVAILABLE 

LOSS OF VOLUME & INTRUSION OF 

GASOLINE FUMES: LESS COMFORTABLE 

(INCONVENIENCE) 

DECREASING FUEL TANK CAPACITY: 

LESS CRUISING RANGE 

(INCONVENIENCE) 

LOSS OF VOLUME & OF FLAT FLOOR 

(INCONVENIENCE) 

§ H f GOTH EfflfflgH 

LESS SEAT-COMFORT (INCONVENIENCE) 

mm nom EIB«H 

It is necessary to F@flaj?®p@@ ftfiys 

kselty SftFciSJUFQ, in order to prevent 

the canister from damaging the 

fueling system in case of impact. 

Since the canister could be 

damaged \$$ [ME®!? fiG3©Q@ftS, the back 

pressure due to broken casing,bent 

tubing,or broken carbon can cause 

spitback and render refueling 

difficult or even impossible, 

HdQtas ft® ftaOJiEiQPiilGo Even if 

refueling were not hampered by the 

damaged canister, a cracked casing 

will Hoali \ya0@i?a ofiftlbamft ftCi® 

@@ra@maD@ir09 GWSQllQCslGQo 
P.1 

F i I 1 e r P i 

Rear View 

FWD PASSENGE R CAR 

Fille r Pip e 

Side View 

RWD PASSENGE R CAR 

Fille r P 

E P A TEST I NG TAN, 

FIG . 3 TH E FILLE R P I P E CONFIGURATIO N 
FIG . 4 TIM E TABL E FO R DEVELOPMEN T OF 

T H E ONBOAR D SYTE M 

(Y « a r ) 

Firs t Xo.. l 

£ipo r I •»c o 

I t i-l c 

S . h • - , I o 

0 t b o i f i 

S r i i • • 

D.velopiat i 

V • h I c 1 • 

E » i I u i i I o i 

Con 111 t n Ion 

Productio n 

DAS E | T/CA R EVA L 

L D V 

I 

L O T 

I 

ft 

flnil Suit Prct lalnarjr 

Srttca 

Decision 

Sri 

Dec 

| f undncntil Ten ) [ 

/• of 

Com true 11 on 

FKIIIUCJ 

(10) 1(3)1 

T^-iT 

Test vehicle order 

(l.M 

251 

0 

Ccrtlflcillon Vchlclo Order 

Trill Production Order 

PLANT | [ 

ce 

lion 

' fUi l 

SpecifICIIIOA 

•0« I s Ion 

Stirt of 

Cir 

Aur 

liproveicnl of Srstc. 

Cillbrillo n of Srsu . 

Crash Tes t 

(4)

.,.

(4)

. l (13) 

29 

.vtluillo n of Ychlclo 

1 

d 

3 3 ; 4 6 

( 1 ) 

4 ^ 49: t-i-50 

, , Crash Test • • ^ 

_) ( -.nbllltr Test 

Drlveibllltr Test etc./ 

i"i",fi!.lllir IT 

10000 Ml let | | 

Shlppln. 

r§l ' 

EPA Tc-l 

D-ubllllr 

120000 HIICJ 

O Production 

/ Su n of 

Trlil ) / LOY 

/ kttr 

[_J | Product log'Trlil') 

Stirt of 

LDT1 

Jit 5 r 

BASE (Fundmntil lo t . 

consiructloa of fact title 

T/CAR fXiMn. tail car.tat. 

. Iiprovntnt'of -tnlc-i 

EVAL ; Euluillon of eiri 

PUNT iPrcductloa trial 

L D V 

LOT 

This ichcduli l l ipplleibla. 

for I or ! todeli 

Ooelopicot of 

other KodeI 

PHASE-IN 13 prefered 

(after experience with 1 or 2 models) a 
P.3 

FIG. 5 IN THE CAS E OF 2 YEARSr LEA D T I ME 

2 (Year ) 

_l 

Final Rule 

Systea 

Decision 

Construction of 

facilities 

Cannot Develop Systea -

Cannot Construct Facilities Before" 

Durability Test 

Certification/—\ 

Truck Order I—/ 

Durability 

120000 Miles 11 

Start of 

LDT 

Assy 

Systea 

Decision 

Construction of 

facilities 

Systea 

Development ) 

-ertification j—\ 

/chicle Order I—/ 

Ce 

V 

Durability 

50000 Miles DI 

Start of 

LDV 

Assy 
P.4 

FIG . 6 FUL L MODE L CHANG E CYCL E 

Model 

Change 

Croup 

A 

B 

C 

D 

Sales 

voluae 

(%) 

3 0 

1 5 

2 6 

2 9 

YEARS AFTER THE PROMULGATION OF THE RULE 

0 1 2 3 4 5 6 7 

• i • • i i i • 

I

E

 I b><T><iN I I I 

i 

i

E

 i N rx3xi><d N N i 

l 

t 

|

E

 1 J N 1 1 1 | N N ! 

1 

• 

1 

i

E

 i i j N i i i i 

> 

(YEARS) 

1 

- -

: 

N N : 

E : EXISTING MODEL-, N : NE* MODEL , NN : NEXT NEf MODEL 

If the phase-in requirement is that 70 X of sales voluae aust be converted in 

the first year, then at least three of Nissan's aodel groups aust be changed to 

accoaaodate onboard controls siaultaneously, resulting in increased developaent 

costs and a loss of 5 years of existing aodel life (i.e. 2 years for aodel group 

"A" and 3 years for aodel group "B"). 
P.5 

TABL E 2 ESTIMATIO N OF COS T INCREAS E 

I N TH E CAS E OF INSUFFICIEN T LEA D T I M E 

LEAD TIME 

4 YEARS • 

PHASE-IN ADOPTION 

(SYNCHRONIZING 

FULL MODEL CHANGE) 

ai[§iM30§ 1?B![M» 

2 YEARS • 

SIMULTANIOUS 

ADOPTION 

2 YEARS • 

PHASE-IN ADOPTION 

(lst:70X,2ND:90X) 

-

2 YEARS • 

PHASE-IN ADOPTION 

(SYNCHRONIZING 

FULL MODEL CHANGE) 

2 YEARS • 

PHASE-IN ADOPTION 

(THE ORDER OF HIGHER 

SALES VOLUME) 

4 YEARS • 

SIMULTANEOUS 

ADOPTION 

-

MODEL 

CHANGE 

GROUP 

A 

B 

C 

D 

AVE. 

A 

B 

C 

D 

AVE. 

A 

B 

,C 

I) 

AVE. 

A 

B 

C 

D 

AVE. 

A 

B 

C 

D 

AVE. 

A 

B 

C 

D 

AVE. 

YEARS 

2 

125 

115 

110 

155 

126 

125 

115 

110 

117 

110 

110 

125 

125 

AFTER THE 

3 

125 

115 

110 

110 

113 

125 

115 

110 

110 

113 

110 

110 

110 

125 

110 

118 

4 

100 

100 

100 

115 

110 

110 

109 

100 

115 

110 

110 

109 

100 

110 

110 

107 

100 

115 

110 

; 108 

100 

j 135 

115 

108 

115 

_ 

PROMULGATION 

5 

too 

100 

100 

100 

100 

110 

110 

105 

100 

100 

no 

1 10 

105 

100 

100 

110 

110 

105 

100 

100 

115 

110 

106 

100 

100 

115 

108 

106 

6 

100 \ 

100 j 

100 • 

100 j 

100 i 

100 : 

100 . 

110 ! 

103 : 

100 

100 

100 

110 

103 

100 

100 

100 

110 

103 

100 

100 

100 

110 

103 

100 

100 

100 

108 

102 

OF THE 

7 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

—' 

RULE 

8 

100 

100 

100 

100 

100 

1.00 

100 

100 

100 

100 

100 

100 

100 

100 

100 

.100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 

100 
7f 

v_= 

Water Separator 

a i r 

Refueling Canister 

Control Unit 

Variable Orifice Control 

Rollover Valve (with Fuel Check Valve) 

Vent Cut Valve 

chanical 

Seal 

Over Fill Limiter 

FIG . 7 SYSTE M A (SKNTRA ) 
Rollover Valve (with Fuel Check Valve) 

Refueling Sensor 

Vapor/Liquid Separator | 

Evapo Canister V ^ 

Refueling Canister 

FIG . 8 SYSTE M 13 ,> ( 3 0 0 Z X ) 

Over Fil l Limiter 

J-Dend Liquid Seal 
P.8 

1 ' 

TABL E 3 ESTIMATIO N O F 

ONBOAR D SYSTE M COS T 

o 

a-

< _ 

o 

SYSTEM COMPONENT PARTS 

PAR T NAME 

|Refuelin g Caniste r 

Rollover Valve(vith Fuel Check Valve) 

Vent Cut Valv e 

|variabl e Orific e Control 

Ove r Fi1 1 Limite r 

Mechanica l Nozzl e Sea l 

J-Ben d Liquid-Typ e Sea l 

Vapor/Liqui d Separato r 

Vate r Separato r 

Contro l Uni t 

Hos e k Tub e 

Switc h 

Harnes s 

Caniste r Attachin g Bracket" ' 

Caniste r Cove r Pane l 

Evap o Caniste r 

Credi t 

Tota l Variabl e Cos t 

Estimate d Cost t o th e Consumer 

COST ($) 

SYSTEM A 

(SENTRA) 

1 4. 3 

2. 4 

. 1 . 6 

1 3. 1 

0. 6 

1. 2 

0 

0. 4 

0. 4 

3. 8 

15. 7 

0 

0. 3 

U / K 

U / K 

-.5 . 0 

- 2 . 4 

4 6. 4 

8 3. 5 

COST ($) 

SYSTEM B 

(SENTRA) 

1 3 . 6 

2. 4 

5. 0 

1 3 . 1 

0. 6 

0 

0. 5 

0. 4 

0. 4 

3. 3 

1 8. 3 

2. 5 

0. 3 

U / K 

U / K 

1. 5 

- 2 . 4 

6 0. 0 

1 0 8. 0 

COST ($) 

SYSTEM B 

(300ZX) 

15. 6 1 

2. 4 

5. 0 

1-3. 1 j 

0. 6 

0 

• 0. 5 

0. 4 

0. 4 

3. 8 j 

17. 3 | 

2. 5 

0. 3 

U / K 

U / K 

1. 4 

- 2 . 4 

6 0. 9 

1 0 9. 6 

[Remark s ] 

£< ; Ve can not estimate this cost at this time because ve have 

not found the proper space to locate refueling canister yet. 
P.9 

COWF/OfWrMJ. 

TABL E 6 ESTIMATIO N O F DETAILE D 

VARIABL E ORIFICECONTRO L COS T 
P.10 

TABL E 5 ESTIMATIO N OF DETAILE D 

PIPIN G COS T (300ZX.SYS T E M B) •9% * 

CONFIDENTIAL 
P.11 

TABL E 4 ESTIMATIO N OF DETAILE D 

CANISTE R COS T 

CONFIDENTIAL 
P.12 

TOYOTA MOTOR CORPORATION 

U. S. OFFICE 

WASHINGTON BRANCH 

185 0 M STREET. N. W. 

WASHINGTON. D. C. 2003 6 TELEPHONE (202) 773-1707 

June 26, 1987 

The Honorable John D. Dingell 

Chairman, Committee on Energy and Commerce 

United States House of Representatives 

2125 Rayburn House Office Building 

Washington, D. C. 20515 

Dear Mr. Chairman: 

Enclosed is Toyota Motor Corporation's (TOYOTA) response to your 

May 11, 1987 letter to Mr. Hanna of MVMA and Mr. Nield of AIA 

regarding the safety aspects of on-board refueling control 

systems. TOYOTA thanks you for giving us the opportunity to 

present our views on this important subject. 

TOYOTA, will be happy to answer any questions you or your staff may 

have regarding these comments. 

Sincerely, 

TOYOTA MOTOR CORPORATION 

v-Z-2- H>t O^'V^V 

Tei ji^Iid a 

Manager 

Washington Branch Office 

TI :cc 

Enclosure 

cc: The Honorable Lee M. Thomas, Administrator, EPA 

The Honorable Diane K. Steed, Administrator, NHTSA 

The Honorable Charles A. Bowsher, Comptroller General, GAO 
P.13 

1. GENERAL COMMENTS 

We appreciate that EPA has expressed its position on the issue of 

safety regarding on-board vapor recovery systems in the document 

entitled "Safety Implications of On-Board Refueling Vapor Recovery 

Systems" (EPA-AA-SDSB-87-05). However, our opinion is that there 

is a great difference in the understanding of safety problems 

between EPA and TOYOTA as a vehicle manufacturer. Therefore, we 

are making our comments on EPA's study as follows. 

We agree with EPA's general position that before introducing 

on-board refueling emission control systems into the market, these 

systems should be safe. However, we can't agree with EPA's 

opinion that the technology to insure the safety of on-board 

systems can be developed based on that of the evaporative emission 

control system. Since the on-board system is much larger, far 

more complex, and will be located in a different part of the 

vehicle which is susceptible to more adverse conditions, simple 

application of technology from the evaporative system to on-board 

systems is not possible, and in some cases, inappropriate. 

Although EPA determines that the incidence of defect and of 

vehicle fire during impacts is low based on the data for the 

evaporative emission control system, this is not representative 

information. It appears that EPA discusses these safety issues as 

the same problems as emission-related issues, including the 

incidence of defect or trouble with the emission control system. 
P.14 

We believe the risk of vehicle fire must be much lower than EPA is 

suggesting. Because of the difference in the hardware, the amount 

of vapor generated, and the various conditions under which the 

vapor is generated and stored, the development of new technology 

beyond that used for the existing evaporative systems will be 

required to assure the safety of this system. Such a development 

will require enormous funds and substantial lead time. 

It should be noted that TOYOTA'S position on refueling emission 

control has never changed. We believe the on-board controls are 

unwise, when aiming for the reduction of volatile organic 

compounds by implementing the vapor recovery requirement. On the 

other hand, the Stage II controls are wise because of lower cost, 

immediate effect and established control technology. 

We will make comments on the difference in the understanding of 

safety problems between EPA and TOYOTA, discussing the abovementioned EPA report. We hope these comments will be helpful for 

your efforts regarding the refuiling emission control issue. 

2. SPECIFIC COMMENTS 

A) Rollover Protection (EPA Report IV.A.2~3) 

-2-
P.15 

EPA's view is not appropriate that implementing on-board 

controls could actually result in a net improvement in overall 

fuel system safety. 

Our current vehicles have incorporated various rollover 

protection devices so that they may comply with FMVSS 301. In 

this report, the EPA staff says that vehicle manufacturers 

should develop the on-board system with full consideration of 

the safety risks. Saying this, in other words, the EPA staff 

itself recognizes the existence of a safety problem. It is 

obvious that the adoption of on-board control systems results 

in an inherent increase of safety risks. At best, after 

extensive research, development, testing, and the application 

of various modifications, we believe the safety risk can be no 

better than equal to that of existing vehicles. 

Although EPA is referring to an external vent line that 

connects the fuel tank to the top of the fillpipe as one of 

the parts used in the conventional control technology, this is 

not appropriate to be compared with parts of refueling 

emission control systems because of the differences in the 

characteristics of on-board control systems. In the case of 

the above-mentioned pipe, even if it is transformed during a 

vehicle crash, there are no serious problems when the vapor 

line is closed. On the other hand, malfunction of the 

-3-
P.16 

refueling emission control-related' parts (e.g., vapor vent 

valve) which is caused by the impact will'have a serious 

adverse effect on safety. 

EPA's opinion that implementing on-board controls could 

actually result in a net improvement in vehicle safety during 

crash accidents is not correct. EPA appears to be confusing 

the application of technology from the relatively simple 

evaporative system to the far more complex on-board system. 

B) Location of Charcoal Canister (EPA Report IV.A.3.c) 

EPA's view on the charcoal canister location is too optimistic, 

From our experience, it is impossible to install a canister in 

the engine compartment, especially that of a small vehicle. 

It is also impossible to place it outside of the engine 

compartment without major modifications in the body 

structure. The comments TOYOTA has submitted previously point 

out that vehicle utility will be lowered by the installation 

of a canister, even if it could be installed by modifying the 

vehicles currently in mass production. It is unfair that EPA 

says our discussion of this problem is merely a possibility. 

To TOYOTA, it is a certainty that major modifications to the 

body must be perf-.-~ed due to the lack of space in the engine 

compartment. 

-4-
P.17 

C) Recognition of Defects " 

We must not consider defects of the emission control system 

and those of vehicle safety devices as the same things. 

EPA determines that the incidence of defect and of vehicle 

crash fires associated with such defects is low, based on the 

data for the evaporative emission control system. Once again, 

EPA appears to be equating emission-related defects to 

safety-related defects. This simply is not an accurate way of 

analyzing this issue. 

We believe the vehicle fire hazard must be reduced to a much 

lower level than EPA is allowing. If any manufacturers 

encountered vehicle fires at the same rate as evaporative 

defects or tampering, that level would be highly 

unacceptable. NHTSA has required safety recalls in situations 

with very low percentages of vehicles being susceptible to 

fires due to its great concorn for occupant and property 

damage in fires. Because of the difference in the hardware 

between on-board and evaporative systems and the quantity of 

vapors generated and collected between on-board refueling and 

evaporative emission control systems, the development of new 

technology beyond that used for the evaporative system will be 

needed for the security of the required system. 

-5-
P.18 

We agree with EPA regarding the vehicle manufacturer's* 

responsibility to make the risk in the whole vehicle as small 

as possible. However, it is not possible to establish a safe 

on-board system without a major development effort. In order 

to make such a safe on-board system available, enormous funds 

and enough lead time are required. 

D) Tampering 

Regarding the tampering problem, the comments in the previous 

section apply. 

We suppose EPA judges that the 3.5% tampering rate for the 

evaporative emission control system is low as compared with 

20% for other emission control components as determined in 

EPA's tampering surveys. However, from the viewpoint of 

safety, this figure indicates very significant problems and 

can't be overlooked. As noted above, if safety-related 

problems arise in 3.5% of vehicles, there is cause for concern, 

We can't agree with EPA in the expectation that the difficulty 

of reaching this system will discourage tampering. If 

excessive dust, moisture, or some other operational problem 

should arise that may adversely affect the ability to refuel 

the vehicle, there will be a great incentive to tamper with 

the system. Such tampering would affect emissions, and may 

also have an adverse impact on safety. 

-6-
P.19 

E) Recognition of Safety Risk (EPA Report V) 

TOYOTA believes that the overall safety risk should not be 

increased with the installation of on-board control systems. 

Managing risk involves a series of trade-offs, balances, and 

compromises with other key design criteria. 

However, when considering the "balances", we must make a full 

modification of an overall vehicle design in order to employ 

the on-board control system. This is a key factor in 

minimizing risk. For this reason, it is not correct to 

estimate the necessary cost of the system o_£ the safety 

components of the system design simply by summing the costs of 

only the component parts. 

For example, in some of our models, changes in dimensions of. 

suspension and- changes in the shape of side members and seats, 

etc., will be required. Although we recognize the necessity 

of certain design compromises, EPA must be fully aware of the 

great burden and responsibility imposed on vehicle 

manufacturers and should also be aware of the difficulty 

manufacturers face in managing the risk associated with 

on-board systems. 

-7-
P.20 

F) Assurance of On-board System Integrity 

In the case of the electronic engine control system, EPA said 

that complication of systems doesn't cause deterioration of 

safety. But it is necessary to recognize the long period and 

the large cost for insurance of the system integrity. It is 

not always true that complication of vehicle systems does not 

cause deterioration of safety. The issue is which system is 

being made more complex. Generally, in any system 

complication that increases safety risks, the manufacturer 

must bear the burden of additional testing, development and 

cost in order to cope with it. Without such burdens, system 

safety would not be assured. 

A collapsible bladder tank design, indicated in the report, is 

not an available technology, but only an idea. It is 

inappropriate to describe such technology as if it were 

available. If EPA expects availability of such technology, 

EPA should consider the necessary lead time and cost. 

G) Cost (EPA Report VI.A) 

EPA insists that on-board controls will cause only a slight 

parts cost increase at the time of implementation, using 

FMVSS 301 as an example. But this is.not correct. 

•8-
P.21 

At the time of initial implementation of FMVSS 301, fuel 

systems were only modified to satisfy the test requirements of 

this standard because we were concerned with fuel system 

safety even before FMVSS 301 became mandatory. But the 

increase of parts cost was much greater than that indicated by 

EPA. 

In the case of on-board controls, it is impossible to satisfy 

the various requirements without a much larger parts cost 

increase because the on-board controls require new components 

which have sufficient safety, as well as structural and fuel 

system, modifications. 

EPA's estimate of developmental costs is also too small. EPA 

apparently views on-board system development as only an 

improvement on the current evaporative system. But, the 

on-board system requires the development and modification of 

many components which require enormous cost and manpower. 

In addition, we must make various evaluation tests of the 

safety, reliability, and durability of the system and 

vehicles. Even in the case of FMVSS 301, it took enormous 

cost and manpower for the modification and evaluation phase 

which led to compliance. For these reasons, our estimated 

cost is far greater than EPA's. 

-9-
P.22 

3. LEAD TIME AND PHASE-IN 

We have had doubts about the justification of on-board refueling 

vapor recovery controls. Even if on-board controls became 

mandatory, the 24 month lead time insisted upon by EPA is too 

short to get every model to comply with the requirements under the 

current development system. NHTSA's testimony to the Oversight 

and Investigations Subcommittee on April 27, 1987 reinforces this 

position. 

A) Lead Time 

TOYOTA has stated that we need three years for lead time, on 

condition that the research for the on-board svstem has been 

finished before the promulgation of the rule. However, since 

our research' of the on-board system has not been finished yet, 

we will require greater lead time depending on the date of the 

rule promulgation and the requirements contained in any final 

rule. 

In order for each vehicle model certification of the on-board 

controls, we must assume the burdens of the R & D of the 

on-board systems and, at the same time, the various full 

evaluations, including crash testing. 

-10-
P.23 

Therefore, the necessary developments include not only-the 

modifications of body structures involved with the on-board 

systems, but also the optimum composition and setting of the 

systems in consideration of safety during various accidents. 

We must take the following steps for every model: 

(1) modification and changes of designs, 

(a) modification of body structure design 

(b) development of the on-board system for the body 

and engines contemplated for use 

(c) modification and changes of equipment designs 

associated with the on-board system 

(2) prototype production 

(3) evaluation (emission performance, reliability, 

durability, safety, etc.) 

(4) certification tests (emission and safety) 

(5) preparation for manufacturing (directions, tooling, etc.) 

Such steps have never been taken, except at model 

changeovers. To make these changes in the middle of a model 

production will significantly increase costs since the 

-11-
P.24 

development, testing, etc., can be amortized over a much 

smaller number of vehicles. In addition, insufficient lead 

time may cause manufacturers to delay other improvements in 

safety and emission systems, since extraordinary efforts must 

be made to assure the effectiveness and safety of on-board 

systems. Therefore, we think a three year lead time from the 

date of completion of system development is a minimum 

requirement. 

B) Phase-in 

Even if on-board vapor recovery regulations are put into 

effect, they are not practicable without a gradual phase-in 

approach as discussed in NHTSA's April 27th testimony. Though 

we agree with EPA about the utility of a phase-in for on-board 

controls, a front loaded phase-in over a two year period is 

not suitable or adequate. The phase-in discussed by EPA is 

insufficient to reduce the certification burden on vehicle 

manufacturers, and will cause manufacturers to re-allocate 

safety resources to this effort instead of other pressing 

needs. 

In view of typical model life, we recommend a moderate 

phase-in approach, such as the one used by NHTSA for 

FMVSS 208: Passive Restraint System (e.g., 10 percent of 

-12-
P.25 

production certified in the first year, 25 percent in the 

second, 40 percent in the third and the remainder certified in 

the fourth year). In addition, extensions for particular 

cases, such as long-life models and small sales volume models, 

would be needed due to the longer periods between model year 

changes. 

-13-
P.26 

JAGUAl? 

IACUAR CARS INC. 

600 WILLOW TREE ROAD • 

LEONIA, NEW IERSEY 0:605 

TELEPHONE: (2011 59.-5200 

TELEX:135491 

2 July 1987 

The Honorable John D. Dingell 

Chairman, Committee on Energy and Commerce ( s 

House of Representatives 

Washington, DC 20515 

Dear Mr. Chairman: 

Jaguar Cars Limited welcomes the opportunity to respond to your 

letter of 11 May 1987, requesting comment on the implications of 

the proposed on-board refuelling vapour recovery regulations. 

As you may know, Jaguar Cars is a manufacturer of compact luxury 

cars in the United Kingdom. Since seventy percent of Jaguar 

production is imported into the United States, any change in 

current regulations has serious implications for Jaguar Cars' 

business plan for the early 1990's. 

The impact of this proposed regulation on vehicle safety has 

attracted a number of divergent views ranging from the 

Environmental Protection Agency's (EPA) opinion, that fuel 

handling systems designed to achieve compliance would provide a 

safety benefit, to the opposite view that such designs which 

make fuel systems more complicated could create serious safety 

problems. Jaguar Cars' share the view expressed by the National 

Highway Traffic Safety Administration (NHTSA), that adequate 

lead-time is required to ensure safety problems do not occur 

with such systems. We think that on-board refuelling vapour 

recovery systems can be designed to be safely incorporated into 

passenger cars, granted sufficient lead-time to permit the proper 

design, development and proving to take place. As a responsible 

manufacturer we cannot afford to rush into the market place with 

a hastily designed system which may not satisfy the rigorous test 

of life in the customers' hands. 

The two years of lead-time proposed by the EPA is, in our 

opinion, totally inadequate for the proper design, test and 

development of an on-board system. We estimate that at least 

four years lead-time is required to satisfactorily accomommodate 

all the activities necessary to bring such a system to the point 

where it could be sold to the customer. A bar chart representing 
P.27 

JAGUAR 

the required design, development and proving programme is 

illustrated in attachment 1. The EPA has presumed that an 

on-board system would simply be an extension to the current 

evaporative emission control system. As far as Jaguar Cars' are 

concerned, this is not the case; on current and future Jaguar 

models, all of which are of compact size and equipped with fuel 

tanks of 20 to 30 gallons capacity, it has been estimated that 

vapour collection canisters containing 4 to 6 litres of 

activated charcoal would have to be accommodated. Since it is 

likely that the canister and its associated pipework would be 

located at the rear of the vehicle, the impact on fuel tank 

and/or trunk capacities could be considerable, for existing 

models, without careful attention to packaging. It has been 

suggested that relief from the lead-time constraints could be 

obtained by adopting a 'phase in' period. However, this 

principle would not provide any relief for manufacturers, such 

as ourselves, with limited model lines. 

With regard to the cost of on-board systems, Jaguar are unable 

to make an accurate estimate, but suggest that hardware on-costs 

would be unlikely to exceed $50 per car, plus engineering costs 

of between $30 and $50 per car. 

We also note the response of the NHTSA contained in Mrs. Steed's 

letter of 11 June 1987, to the draft proposed rule-making and 

fully endorse the comments submitted, particularly in respect to 

lead-time and safety considerations. 

Finally, we strongly support the EPA's proposal to control fuel 

volatility as this results in a reduction, all be it small, in 

the size of the vapour collection canister required in on-board 

refuelling vapour control systems. Such a control would 

immediately benefit air quality by reducing excess evaporative 

emissions from vehicles currently in use. In conjunction with 

any on-board vapour control regulation, we also support the EPA 

in its recommendation to pursue rule-making to limit the maximum 

in use dispensing rate for gasoline delivery pumps to 10 gallons 

per minute. 

We thank you for this opportunity to make our views known.. 

Yours sincerely, 

l7-&y /fT.N. Crisp 

Group Chief Engineer 

PU & Transmission Engineering 

TMC/LTJ 
P.28 

JAGUAR 

cc: The Honorable Elizabeth Hanford Dole 

Department of Transportation 

The Honorable Lee M. Thomas, Administrator 

Environmental Protection Agency 

The Honorable Charles A. Bowsher, Comptroller General 

General Accounting Office 
P.29 

JUL.06 '87 11:01 JAGUAR TECH LIBRARY 0203 404035 P.004 

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P.31 

NEWS FROM THE WORLD OF FORD 

IMMEDIATE RRT.g_.gp 

WASHINGTON, July 17 — In order to put to rest concerns 

about the safety of ambulances built on 1983-87 Ford E-350 chassis 

and vans and to expedite their inspection and modification, Ford 

Motor Company will conduct a voluntary safety-related defect 

recall of these vehicles, a company vice president announced here 

today. 

Helen 0. Petrauskas, Ford vice president - Environmental 

and Safety Engineering, said, "Our customers, the ambulance 

operators, told us they wanted this recall carried out under the 

Federal.Safety Act and that EMS companies would bring in their 

vehicles more promptly under a formal safety recall. Our decision 

was transmitted yesterday by letter to the National Highway 

Traffic Safety Administration." She spoke at a news conference 

that was beamed by satellite to seven other cities. 

Mrs. Petrauskas said that the information gained from a 

pilot owner notification program conducted jointly by Ford and 

leading ambulance manufacturers last month will be applied to the 

safety recall. 

"A cracked component was discovered during the inspection 

of a modified ambulance that caught fire in Maryland," she said. 

"The component, a valve seal grommet, has been redesigned, 

manufactured from a different material, rigorously tested, and all 

250 ambulances involved in the pilot program were recalled. In 

- MORE -

WASHINGTON PUBLIC AFFAIRS OFFICE, 815 CONNECTICUT AVENUE N.W., 9TH FLOOR, WASHINGTON, D.C. 20006 TELEPHONE: (202) 785-6014 
P.32 

- 2 -

addition, we are now pressure-checking all fuel systems, have 

•increased the number of components in the modification kits and 

have instructed our dealers that no ambulance should leave the 

service bay until all conditions which we have identified as 

clearly unacceptable are repaired. 

"We will fix all those conditions, even including 

ambulance manufacturing and operator maintenance errors that are 

totally unrelated to the original design and construction of the 

E-350 chassis or van. 

"Finally, Ford dealership technicians will give each 

ambulance a validation drive to verify that the modifications have 

been made correctly, but also to evaluate the performance and 

driveability of the ambulance before and after the modification." 

The voluntary recall affects approximately 15,000 to 

16,000 ambulances in the United States and less than 200 in 

Canada, Mrs. Petrauskas said. The exact number is not known 

because Ford dealers sell chassis and vans to some 30 or more 

ambulance and specialty truck manufacturers who convert them into 

ambulances and resell them to ambulance operators. The company has 

no way of knowing who the ultimate purchaser is for any but a few 

of the ambulances. 

There are 52 5 Ford dealers nationwide who have been 

trained to conduct the recall. The company hopes to have the 

majority of the ambulances inspected and modified in about eight 

weeks, but this is controlled to a large degree by the promptness 

with which ambulance operators bring in their vehicles. The cost 

of this voluntary action could be as high as $30 million. 

- MORE -
P.33 

- 3 - . 

The company's notification letter to NHTSA also"contained 

these points: 

Ford has not found any safety-related defect 

in the E-350 chassis or van as it is built by 

Ford and sold to independent ambulance 

manufacturers for their conversion and resale 

to ambulance operators. 

Ford investigations have convinced the company 

that several adverse factors must act in 

. combination to create the potential risk of a 

fire. Among the causes that Ford engineers 

have found are: discrepancies such as crimped 

vapor lines which prevent the fuel vapor 

venting system from operating properly (thus 

causing pressure to build up in the fuel 

tank), blockage of underbody air flow or use 

of improper mufflers, poor maintenance 

practices, improper electrical equipment and 

wiring and use of highly volatile "winter 

grade" fuel during hot weather. 

Ford believes the voluntary recall will 

effectively deal with all major adverse 

factors known to contribute to excessive 

underbody heat levels and fuel system 

overpressurization. The program, together 

with prudent operating and maintenance 

practices, should eliminate the risk of fuel 

systems-related fires. 

Ford Motor Company will send notices of the safetyrelated defect recall to about 17,000 ambulance operators next 

week. The voluntary recall supercedes the joint program announced 

last month by Ford and leading ambulance manufacturers, but Ford 

believes that leading ambulance manufacturers will support the new 

safety recall, Mrs. Petrauskas said. 

Mrs. Petrauskas also announced that stringent tailpipe 

emissions standards will require that all heavy duty trucks up to 

14,000 lbs. GVW powered by gasoline engines be equipped with 

catalytic converters beginning with the 1988 model year. For this 

- MORE -
P.34 

i 

- 4 -

reason, Ford will be taking all feasible steps to preclude future 

ambulance conversion of incomplete vehicles and E-350 vans 

equipped with catalysts. 

"Given what we have learned about the severity of 

ambulance operation and the environment in which ambulances must 

operate, we do not believe it is prudent for these vehicles to be 

equipped with catalytic converter systems which are inherently 

more complex and which need to operate at higher temperatures than 

do non-catalyst exhaust systems," she said. "We decided that 

ambulance operators would be better served by the well-proven 7.3 

liter diesel engine that does not require a catalytic converter." 

# ## 

7/17/87