Honorable Lee M. Thomas (b) Please explain to what extent gasoline volatility affects evaporative, exhaust HC, refueling, stage I, and bulk storage and distribution emissions. (c) Are evaporative control systems designed by auto manufacturers to meet hydrocarbon (HC) standards based on a vehicle fueled with a certification test gasoline which has a Reid Vapor Pressure (RVP) of 9.0 psi? Is it true that this level of volatility was developed by EPA in the early 1970's, but the RVP has increased due to the adding by the oil industry of butane to meet rising energy costs? When did EPA first discover this change in RVP? What is the effect of this higher volatility on approved control systems and emissions? (d) According to a portion of a September 1985 document of the Office of Mobile Sources (OMS) entitled "Gasoline Volatility and Evaporative Hydrocarbon Control," a "Presentation to the Administrator" OMS said: Control Approaches The long-term solution to the excess evaporative emission problem is to equate in-use and certification fuel RVPs. This can be done at any RVP between 9 psi, that of the current test fuel, and 11.5 psi, that of future commercial fuel. Equating the RVPS of the two fuels at 11.5 Equating the RVPS of the two fuels between Equating the RVPS of the two fuels between 9.0 and 11.5 psi focuses part of control on the vehicle and part of control on the fuel. In-use volatility controls can be implemented term. Honorable Lee M. Thomas Please provide the full text of this document, explain its purpose, and state when this presentation was made, the result thereof, and the participants. Please provide a copy of all letters, memoranda, notes, and other documents in EPA files, including OSM and Ann Arbor, from January 1, 1984 to the present. What is the legal basis for such controls? What are the pros and cons of these control approaches? That document also states that the "basic problem is that butane costing 50 cents per gallon can essentially be sold for 90 cents per gallon by adding it to gasoline." Is that true? What does butane do for octane and fuel economy? What are the volatility impacts and concerns where there are alcohol or other blends? (e) What is the Evaporative Index and what does it have to do with emissions? Please explain its relationship to a so-called "DuPont Waiver" and explain that waiver and its status? What did EPA require in that waiver and why? What is the relationship of these matters to Oxygenated Fuels Association? What is that Association seeking? (f) The November 8, 1985 edition of Inside E.P.A. states that EPA "has resolved internal staff differences over a draft technical report of its Ann Arbor" office "that supports the regulation of gasoline volatility levels to reduce ozone emissions". What were those differences and how were they resolved? The article states that the revisions "have not changed EPA staff opinion that volatility controls are a more cost effective way to control ozone than a Stage 11, at the pump system.' Is that true? Please explain the basis for these views. The article then states: EPA sources say a conference is planned on the volatility issue to give EPA Administrator Lee Thomas a "handle" on public opinion about the viability of volatility controls as part of the agency's decision on how to regulate gasoline marketing. EPA reportedly is leaning toward a move to control potentially toxic gas vapors through nationwide use of on-board automobile canisters, and is contemplating volatility controls to reduce ozone formation from auto emissions. Stage II devices could control both gas vapors and ozone, EPA sources explain, but reportedly not as cost-effectively. Nor could Stage II be implemented as quickly as volatility controls, sources say; therefore, volatility controls would be better able to ease state's troubles in meeting the 1987 air act ozone attainment standard. Honorable Lee M. Thomas Sources say EPA's office of air quality planning and standards intends to push Thomas to make a decision on the gasoline marketing question shortly after the volatility conference. OAQPS is reportedly loathe to postpone a decision on the larger issue of gasoline marketing controls until after a decision can be made on volatility, despite the need to be certain of a volatility level for test fuel used in certifying the adequacy of automobile pollution controls. Please explain the purpose of the conference and the relationship of the volatility question and its resolution to Stage II and on-board controls. Please explain the basis, if any, for EPA resolving the on-board control versus stage II control before the volatility issue is resolved. What is the proper volatility level and why for test fuel? (g) We are concerned about the fuel for engines problem in general from the standpoint of the interrelated concerns of fuel economy, emissions, vehicle performance, emission control device performance, including existing canisters, and other matters, including lead phasedown, and about the ability and vigilance of EPA in dealing with this important fuel issue, particularly under section 211 of the Clean Air Act. We are concerned about the extent to which the refiners and others in the oil industry may be taking actions, possibly inconsistent with section 211, that could adversely affect efforts of automakers and EPA to improve fuel economy and control emissions (while ensuring vehicle performance) and guaranteeing the effectiveness of control devices. An article in the January 27, 1986 edition of Automotive News (p. 19) calls attention to auto firms' "effort to get oil companies to provide satisfactory fuel for engines with port fuel injection." We are also concerned about the need for any auto firm to issue the enclosed "Customer Information" and the effectiveness of such a notice because of fuel-related problems that these firms cannot control. Please identify (with the cooperation of the Administrator of the National Highway Traffic Safety Administration) all these fuel problems, explain their impacts on fuel economy, emissions, etc., and indicate what EPA is doing about them. 13. The GAO report states that: EPA "has not presented most of its costeffectiveness estimates for vehicle-refueling control options with ranges to reflect the underlying uncertainty"; Honorable Lee M. Thomas - There are several "uncertainties" affecting Unless EPA presents these uncertainties, "the "EPA's selective presentation of uncertainty EPA presented its "Options Paper" in draft GAO questions EPA's cost-effectiveness EPA "did not estimate the impact of a stage GAO recommends: To improve EPA's cost-effectiveness analysis What will EPA do to implement this recommendation and when will this be done? We also request the EPA respond to the GAO conclusions and comments at the end of this chapter. We request your comments and responses on the above matters (and the GAO report) before EPA makes any decisions on the matters discussed in the report but no later than the end of next month. Please provide a copy of your reply to the GAO for its review and comment to the Subcommittee. Honorable Lee M. Thomas Page 13 With best wishes. Sincerely, Enclosures (2) CC: JOHN D. DINGELL Chairman Subcommittee on Oversight and Investigations Honorable James T. Broyhill, Ranking Minority Member Honorable Charles A. Bowsher, Comptroller General Honorable Harry R. Van Cleve, General Counsel Honorable Diane K. Steed, Administrator National Highway Traffic Safety Administration Honorable James C. Miller III, Director |