ILLINOIS POLLUTION CONTROL BOARD

November 8,

1990

IN THE MATTER OF:

)

R88—30(B)

LIMITS TO THE VOLATILITY

)

(Rulemaking)

OF GASOLINE

)

PROPOSED RULE.

SECOND NOTICE.

CONCURRING OPINION

(by J.

C. Marlin):

I concur with today’s order given the necessity of having an

ozone control program stronger than that mandated by USEPA in

force in 1991.

However,

I believe that the proposal as passed will add

unnecessary complexity to the overall petroleum distribution

system.

Current regulations require the use of 9.5 RVP gasoline

in Southern Illinois, Missouri, and most southern states during

July and August of 1991.

As a practical matter gasoline is

formulated near the 9.0 RVP level to meet this standard.

The adopted rule sets a standard of 9.0 but allows a 0.3

tolerance,

which as a practical matter means that gasoline must

be formulated at 8.8 to 9.0 to meet the tolerance.

This

is the

standard the federal rules will use in

1992.

Using the current 9.5 standard for June-August would keep

Illinois gasoline

in line with that used in the Southern states

for the summer of 1991.

This would eliminate the additional

confusion and distribution problems associated with marketing

gasoline formulated for an “Illinois only” rule.

It would also

make enforcement easier since the 1991 federal procedures would

be directly applicable.

Both proposals will do essentially the same job,

but the 9.5

would keep things simple, and that is no small consideration

given the overall magnitude of efforts needed to address today’s

air pollution problem.

I, Dorothy M. Gunn, Clerkbf the Illinois Pollution Control

Board hereby certify

~j~at

the above

o curring Statement was

submitted on the /~‘~day of

__________________,

1990.

~2M~Z4

,~.

,~L

Dorothy M. 9~nn,

efk

Illinois PoWlution Control Board

C. Marlin

116—143