
Summary of Responses to Comments Regarding Detailed Edits of the Proposed Fuel Regulations in the Tier 3 NPRM 
The following table contains our responses to detailed comments on the proposed amendments to the fuel regulations in 40 CFR Parts 79 and 80 that were contained in the Tier 3 NPRM.  

Comment
EPA Response/Action
§ 79.5: Improper use of the phrase "of this section"
Regulatory text amended to address comment 
40 CFR 80: Discontinue toxics calculation and reporting for blendstocks for butane and TGP.  Reduce sampling and testing for blendstocks (T50, T90, E200, and E300)
We are not making the requested changes as discussed in Section VI.A. of the preamble.  We may consider whether additional changes in the context of a broader regulatory streamlining rulemaking in the future. 
§ 80.2: Broaden definition of NGL used as an ethanol denaturant and as a blendstock for E51-83
Regulatory text amended to address comment with respect to NGL used as an ethanol denaturant.  
Deferring finalizing standards for E51-83 including the use of NGL as an E51-83 blendstock
§ 80.2(cccc): Amend E51-83 definition
Deferring finalizing standards for E51-83
§ 80.65(f)(3)(iii)(A): Amend text regarding reporting requirements
Regulatory text amended to address comment
§ 80.75: Amend text regarding reporting requirements
Regulatory text amended to address comments
§ 80.75: Extended deadline for attest engagements
We do not believe that it is necessary to extend the deadline as suggested in the comments, as discussed in Section VI.A.1.b. of the preamble to the final rule.  
§ 80.82: Amend requirements regarding butane quality records
Deferring making suggested change to allow additional consideration
§ 80.1347:  Change the words "at the refinery" to "by the refiner" regarding benzene sampling
Deferring making suggested change to allow additional consideration
§ 80.1601(a)(4):  Provide clarity regarding the applicability of requirements to E16-50
Deferring finalizing standards for E16-50
§ 80.1601(b)(2): Provide clarity regarding applicability of Subpart O requirements to E16-50 and E50-E83 sold in California
Deferring finalizing standards for E16-50 and E51-83
§ 80.1603(d)(3)(i): Clarify requirements regarding the reporting of conventional gasoline and CBOB volumes
We believe that regulations as amended are clear.
§ 80.1608: Provide clarity regarding the effective date for E51-83  requirements
Deferring finalizing standards for E51-83
§ 80.1608(b)(2): Amend benzene specifications for E51-83 
Deferring finalizing standards for E51-83
§ 80.1608(b)(4): Correct error regarding the RVP requirements for E51-83
Deferring finalizing standards for E51-83
§ 80.1608(c)(3): Amend benzene requirements for E51-83
Deferring finalizing standards for E51-83
§ 80.1610: Amend requirements regarding the demonstration of compliance with the requirements for denatured fuel ethanol
These comments are addressed in the context of responding to comments in chapter 5.3 of the Summary and Analysis of Comments document
§ 80.1611: Provide clarity regarding the effective date for E51-83 requirements 
Deferring finalizing standards for E51-83
§ 80.1611(a)(b): Amend requirements regarding the limitation on blendstocks  used in E51-83
Deferring finalizing standards for E51-83
§ 80.1612(b): Amend prohibition on use of E51-83 made with NGL for use on making E16-50
Deferring finalizing standards for E16-50 and E51-83
§ 80.1615(a): Allow butane blenders and transmix processors to generate credits 
We do not believe that is necessary or appropriate for butane blenders and transmix processors to generate credits
§ 80.1616(a): Change date until early credits are valid until March 31, 2020 
Regulatory text amended to address comment
§ 80.1622:  Extend application for small refiner/refinery status until June 31, 2014
The application was extended until January 1, 2015
§ 80.1632: Amend benzene requirements for E51-83
Deferring finalizing standards for E51-83
§ 80.1650(b)(1): Change registration date to June 30, 2014,
The registration date for refiners and importers has been set at December 1, 2016.
§ 80.1651: Amend Product transfer document requirements 
These comments are addressed in the context of responding to comments in chapter 5.3 of the Summary and Analysis of Comments document that accompanies the Tier 3 final rule
§ 80.1652: Amend Product transfer document requirements
These comments are addressed in the context of responding to comments in chapter 5.3 of the Summary and Analysis of Comments document
§ 80.1652(a)(7(iv): Clarify how identification of test method should be reported  
EPA will provide guidance on how reporting forms should be filled out
§ 80.1653" Amend Product transfer document requirements
These comments are addressed in the context of responding to comments in chapter 5.3 of the Summary and Analysis of Comments document
§ 80.1662(a)(5):  Amend branded refiner/importer liability regarding E16-50 and E51-83 violations
Deferring finalizing standards for E16-50 and E51-83
§ 80.1615(c): Amend Calculation of credits
Regulatory text amended to address comment
§ 80.1656: Provide exemption for aviation and racing gasoline
The exemption for aviation and racing gasoline is address in 80.1601
§ 80.1667:  Amend regulations re attest engagements
Regulatory text amended to address comment
Comments on regulatory sections regarding performance based testing
These comments are addressed in chapter 6.1.2. of the Summary and Analysis of Comments document that accompanies the Tier 3 final rule

