United States        Air and Radiation      EPA420-R-01-023
            Environmental Protection               April 2001
            Agency                     M6.EVP008



vvEPA     Estimating Running Loss


            Evaporative Emissions in


            MOBILES
                                 > Printed on Recycled Paper

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                                                                          EPA420-R-01-023
                                                                                 April 2001
                                        in

                               M6.EVP.008
                                Larry C. Landman

                         Assessment and Standards Division
                       Office of Transportation and Air Quality
                       U.S. Environmental Protection Agency
                                    NOTICE

    This technical report does not necessarily represent final EPA decisions or positions.
It is intended, to present technical analysis of issues using data which are currently available.
         The purpose in the release of such reports is to facilitate the exchange of
      technical information and to inform the public of technical developments which
        may form the basis for a final EPA decision, position, or regulatory action.

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                             ABSTRACT
     This report documents the method used in MOBILE6 for
estimating the running loss emissions from vehicles.

     In earlier versions of EPA's MOBILE model, running loss
emissions (defined as evaporative hydrocarbons that are emitted
when the vehicle is in operation) were calculated as functions of
ambient temperature, fuel volatility, driving cycle, and vehicle
parameters (i.e., fuel delivery system,  model year ranges, and
functionality of the evaporative control system).   This report is
not a complete re-analysis of the older data used in those
previous versions of MOBILE.  Rather, this report incorporates
the effects of "gross liquid leakers" (see report M6.EVP.009)
with the MOBILES running loss estimates, and then verifies that
this approach is consistent with the results of recent running
loss testing  (while the MOBILES estimates alone are not).

     This report was originally released (as a draft) in June
1999.  This current version is the final revision of that draft.
This final revision incorporates suggestions and comments
received from stakeholders during the 60-day review period and
from peer reviewers.

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               Estimating Running Loss Evaporative
                      Emissions in MOBILES
                    Report Number M6.EVP.008

                         Larry C.  Landman
            U.S.  EPA Assessment and Standards Division


1.0   INTRODUCTION

     Running loss emissions are defined  as  evaporative
hydrocarbons that are emitted when  the vehicle  is  in  operation.
Since the MOBILE4 computer model, the US Environmental  Protection
Agency  (EPA) has estimated running  loss  emissions  based on
analyses of testing performed by one of  its contractors
(Automotive Testing Laboratories, Inc.).  In MOBILE6, the  running
loss emissions are calculated separately for each  hour  of  the
day, based on the vehicle activity  for that hour.   The  hourly
emissions are then weighted together  (to form a daily composite
value) proportional to the number of miles  driven  each  hour.

     The test programs were designed to  test in-use vehicles  with
three different driving cycles:

     •  The  New York City Cycle (NYCC)  features low speed stop-
        and-go  traffic conditions with an average speed of 7.1
        mph.  Details on this  cycle can be found on EPA's website
        (at  http://www.epa.gov/oms/emisslab/methods/nycccol.txt) .

     •  The  EPA Urban Dynamometer Driving Schedule  (UDDS) is
        commonly called the "LA-4"  or "the city test"  and
        represents  city driving conditions.   It is used for
        light-duty  vehicle testing and has an average speed of
        19.6  mph.   Details on  this cycle can be found on EPA's
        website (at http://www.epa.gov/oms/emisslab/methods/uddscol.txt) .

     •  The  Highway Fuel Economy Driving Schedule  (HWFET or HFET)
        represents  highway driving conditions under 60 mph with
        an average  speed of 47.9 mph.   Details on this cycle can
        be found on EPA's website (at
        http://www.epa.gov/oms/emisslab/methods/hwycol.txt) .

The duration of the running loss test is approximately  one hour
for each of those three driving cycles.   Therefore, the NYC
driving cycle is repeated six times  (6 bags), the  two portions of
the LA-4 cycle are repeated three times  (6  bags),  and the  HFET
driving cycle is repeated five times  (5  bags).

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     The running loss emissions test programs were designed to
collect data at four levels of fuel volatility  (7.0, 9.0, 10.4,
11.7 psi in Reid Vapor Pressure [RVP])  and at three levels of
ambient temperature  (80, 95, and 105° F).  Not all vehicles were
tested for all combinations of fuel RVPs and ambient
temperatures, however.  There was usually no testing at extreme
conditions, such as the combinations of high RVP fuel and high
ambient temperature  (e.g., 11.7 psi/105° F), and low RVP fuel and
low ambient temperature (e.g., 7.0 psi/80° F), because of their
less likely occurrences in the real world.  Also, if the running
loss emission results from a test vehicle were low  (less than 0.5
grams)  at certain fuel and temperature combination  (for example,
9.0 psi/95° F),  it was assumed that at the combinations of lower
fuel volatility and/or lower ambient temperatures (i.e., 7.0
psi/95° F,  9.0 psi/80° F,  and, 7.0 psi/80° F), this vehicle would
have emissions at a similarly low level.  Therefore, to save
resources,  the vehicle was not tested for the combinations of
lower fuel volatility and lower ambient temperatures.  Further,
there have been no tests on 11.7 psi RVP fuel shortly after the
issuance of MOBILE4 in 1989.

     In MOBILE4 model, when the test data were not available at
certain combinations of fuel volatility and ambient temperature,
the gram per mile (g/mi) running loss emissions were estimated
from a variable called "True Vapor Pressure  (TVP)."  In the
MOBILE4.1 model, this TVP was used to correlate with the running
loss emissions from failed vehicles.  These TVPs by bag are
expressed as functions of fuel volatility and fuel tank
temperature.  The TVP values were calculated for all combinations
of fuel volatility (7.0, 9.0, 10.4, and 11.7 psi RVP) and tank
temperature profiles  (with the initial tank temperatures at 80,
87, 95, and 105° F).

     In recent years, industry sources have performed running
loss testing programs in which random samples of in-use vehicles
were tested  (see Section 2).  In this analysis, we compared these
new data to the MOBILES predictions to determine whether changes
need to be made for MOBILE6.


2.0   NEW RUNNING LOSS TEST DATA

     During the summer of 1997, running loss tests were performed
on 150 vehicles as part of a testing program  (project number
E-35)  conducted for the Coordinating Research Council  (CRC) . [1]*
The running loss emissions for these vehicles were measured over
a single LA-4 driving cycle, using tank fuel  (RVP about 6.8 psi),
and ambient temperature about 95 degrees Fahrenheit.  The
following summer  (1998), CRC conducted a testing program in which
   The numbers in brackets refer to the references in Section 6 (page 8).

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                                -3-
running loss tests were  performed on 50 late-model year vehicles
(1992 through 1997, with a mean age of 4.5 years)  (project number
E-41) .  [2]  These 50 newer vehicles  were again tested using tank
fuel (RVP about 6.8 psi)  and with an ambient temperature of about
95 degrees Fahrenheit; however,  a longer driving cycle was used
consisting of an  LA-4  followed by two NYCC cycles followed by a
second LA-4.  A summary  of the results from those two programs
are given below in Table 1.   Within each age range, the mean
running loss test emissions were calculated as well as the 90
percent confidence intervals.   The value "Mean Age"  was calculated
by subtracting the model year from the test year (either 1997 or
1998) .
                               Table 1
                    Summary of CRC Running Loss Testing
CRC
Project
E-35

E-41**
MdYr
Range
Pre-80
80-85
86-91
92-97
Mean
Age
(years)
21.984
13.744
8.340
4.320
Sample
Size
61
39
50
50
Runing
Loss
(gram/mile)
2.3044
1.3800
0.4678
0.3351
90 Percent
Confidence Interval
0.9730
0.5745
0.1497
0.0901
3.6358
2.1855
0.7859
0.5801
       **  The running loss results of the vehicles tested in Project E-41 are based on a longer
          driving cycle but at a slower average speed than the cycle used in E-35.
3.0   MOBILES PREDICTIONS OF RUNNING LOSS  EMISSIONS

     The MOBILES model  was  run to generate predictions of the
running loss emissions  in the CRC project E-35, that is:
    •  the ambient temperature was set equal to 95° F,

    •  the driving cycle was  set  to a single LA-4,  and

    •  the fuel RVP was set  to 6.8 psi.

MOBILES estimates were  calculated for each model year within each
of the three purge/pressure  strata from reference [4].  Then,
using the weighting factors  from Appendix A of that reference,
revised (i.e., re-weighted)  MOBILES predictions were produced  for
the running loss emissions.   Since the CRC testing measured all
evaporative emissions that  occurred during the test, those
results (in Table 1) include both running loss and resting loss
emissions.  Therefore,  resting loss emissions  (from reference [3])
were calculated and added to the re-weighted MOBILES estimates.

     Since most of the  CRC  testing was performed during the
summer of 1997, two separate MOBILES runs were necessary  (one  on
January 1, 1997 and the second on January 1, 1998).  The two

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MOBILE5 runs were  averaged together to estimate the running  loss
emissions of the in-use  fleet (by vehicle age) measured during
summer 1997.  Those predictions  are given below in Table 2.

                               Table 2

             Re-Weighted MOBILES Predictions of Fleet Running Loss
                         (At CRC Test Conditions)

Age
(years)
0
1
2
3
4
5
6
7

Predicted
Run Loss
(g/mi)
0.1028
0.1220
0.1421
0.1456
0.1507
0.1576
0.1672
0.1800


Age
(years)
8
9
10
11
12
13
14
15

Predicted
Run Loss
(g/mi)
0.1975
0.2199
0.2498
0.2863
0.3334
0.3850
0.4403
0.4945


Age
(years)
16
17
18
19
20
21
22
23
24
Predicted
Run Loss
(g/mi)
0.5434
0.5836
0.6193
0.6409
0.6554
0.6648
0.6706
0.6742
0.6759
The comparison  (between  the data in Tables 1 and 2]
illustrated by  the  following graph (Figure 1).
is
     Even the most  cursory comparison between the average  running
loss emissions  in Table  1  and the re-weighted MOBILES predicted
running loss emissions in  Table 2 (or simply between the data  in
Figure 1) suggests  that  not only do the predicted values
underestimate the observed mean values, but they also do not even
fall within those rather large 90 percent confidence intervals.
This underestimation  is  most significant for vehicles over the
age of 10 years.  There  are a number of possible explanations  for
those differences;  however,  EPA believes that the most likely
explanation is  the  presence of vehicles identified as "gross
liquid leakers"  (GLLs)  (see reference [5])  in the CRC sample.

     In reference [5], EPA  used the  term "gross liquid leaker"  to
identify vehicles having substantial leaks of liquid gasoline, as
opposed to simply vapor  leaks.  In that report, EPA stated that
the running loss emissions from such a vehicle tested over a
single LA-4 driving cycle  would be at least 7.0 grams per  mile.
When we examine the running loss test data used in the analysis
for MOBILES, it is  questionable whether any of the test vehicles
would meet EPA's definition of a GLL.*  In the upcoming section
(Section 4.0),  we will consider the effect of adding the
emissions from  the  GLLs  to the (preceding) MOBILES estimate.
   The possible  absence of  "gross liquid leakers" in  the data set  used for
   MOBILES  is not unreasonable  considering the relatively  small number  of
   such vehicles in the in-use fleet.

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                               Figure 1

                Comparing Re-Weighted MOBILES Predictions with
                       CRC Running Loss Emissions
      E  3
      5
      2  2
CRC Means

90%Conf. Interval

MS Estimate
                                   12

                            Vehicle Age (years)
                            18
24
4.0   EFFECT OF "GROSS LIQUID LEAKERS" ON RUNNING LOSS
     EMISSIONS

     In reference  [5], EPA  defined for running loss testing,
"gross liquid  leakers"  to  be vehicles with both  liquid leaks of
gasoline and running loss  test emissions of at least  7.0  grams
per mile.  Using that definition, we note that six  (6)  of  the
vehicles in the CRC  testing programs met those criteria.   We can
then revise Table  2  by  including the estimated running loss
emissions of the "gross liquid leakers"  (from reference [5]) .   The
revised values are in Table 3 (on the following  page).

     When we compared the  CRC running loss test  results (from
Table 1) with  these  MOBILES predictions that were modified to
include the effects  of  GLLs (from Table 3), we obtained the graph
in Figure 2  (on the  following page).

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                                   -6-
                                 Table 3

         Re-Weighted MOBILES Predictions of Fleet Running Loss Including GLLs
                           (At CRC Test Conditions)

Age
(years)
0
1
2
3
4
5
6
7

Predicted
Run Loss
(g/mi)
0.1170
0.1411
0.1697
0.1821
0.2014
0.2279
0.2642
0.3163


Age
(years)
8
9
10
11
12
13
14
15

Predicted
Run Loss
(g/mi)
0.3877
0.4778
0.5940
0.7292
0.8843
1 .0426
1.1978
1.3365


Age
(years)
16
17
18
19
20
21
22
23
24
Predicted
Run Loss
(g/mi)
1 .4559
1.5509
1 .6335
1 .6846
1.7210
1 .7447
1 .7609
1 .7727
1.7788
                                  Figure 2

                   Comparing CRC Running Loss Emissions with
                  Re-Weighted MOBILES Predictions Including GLLs
at
E  3
E
5
2  2

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                                -7-
though the difference grows to almost  0.58  grams  per mile for the
oldest vehicles:

     •  From a statistical standpoint,  those larger differences
        are  actually relatively small,  less than 10 percent of a
        standard deviation.

     And,

     •  The  differences  between the CRC averages and the
        predicted results are  the largest in the portion of the
        in-use fleet that contributes the least to the total
        emissions due to the small number of in-use vehicles
        involved.  For example,  fewer that one-tenth of the fleet
        is composed of vehicles older than 15 years of age,
        thereby reducing the effect of any potential offset.
5.0   CONCLUSIONS

     EPA proposes, for MOBILE6, to use  the MOBILES  model  to
estimate the running loss emissions  from  that  portion of  the
fleet that does not contain vehicles  that are  "gross  liquid
leakers."  For the portion of the fleet composed  (entirely)  of
vehicles that are "gross liquid leakers," EPA  proposes to use
report M6.EVP.009 (i.e., reference [5]) to both estimate and
weight the emissions.  The mean running loss emissions of "gross
liquid leakers" was estimated to be  336.78 grams  per  hour
(divided by the average speed to obtain units  of  "grams per
mile") .

     In that same report, the estimated frequency of  "gross
liquid leakers" in the in-use fleet  (as a function  of the
vehicle's age) is given by the equation:

  Rate of Gross Liquid Leakers
      „_,„..    T ^           	0.06	
      Based on Running Loss Testing       = 1 + -i20*exp[-0.4*AGE]

     Although this analysis concentrates  on light-duty vehicles,
this approach shall be used in MOBILE6  for all vehicle types.

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6.0   REFERENCES

1)  D. McClement, "Measurement of Running Loss Emissions from In-
   Use Vehicles (CRC Project E-35)", CRC Report No. 611,
   Prepared for the Coordinating Research Council, Inc. by
   Automotive Testing Laboratories, Inc., February 1998.

2)  D. McClement, "Real World Evaporative Testing of Late Model
   In-Use Vehicles, CRC Project E-41", Prepared for the
   Coordinating Research Council, Inc. by Automotive Testing
   Laboratories, Inc., December 17, 1998.

3)  Larry Landman,   "Evaluating Resting Loss and Diurnal
   Evaporative Emissions Using RTD Tests," Report numbered
   M6.EVP.001, April 2001.

4)  Larry Landman,   "Estimating Weighting Factors for Evaporative
   Emissions in MOBILE6," Report numbered M6.EVP.006, April
   2001.

5)  Larry Landman,   "Evaporative Emissions of Gross Liquid Leakers
   in MOBILE6," Report numbered M6.EVP.009, April 2001.

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                               -9-
                           Appendix A


         Response to Peer Review Comments from Sandeep Kishan


     This report was formally peer reviewed by one peer reviewer
(Sandeep Kishan).   In this appendix, comments from Sandeep Kishan
are reproduced in plain text, and EPA's responses to those
comments are interspersed in indented italics.  Each of these
comments refer to page numbers in the earlier draft version
(dated July 1,  1999) that do not necessarily match the page
numbers in this final version.

               ************************************

This memorandum provides peer review comments on two EPA
documents:  "Estimating Running Loss Evaporative Emissions in
MOBILE6," Document No. M6.EVP.008, June 28,  1999, and
"Evaporative Emissions of Gross Liquid Leakers in MOBILE6,"
Report Number M6.EVP.009, June 30, 1999.  Both of these are draft
reports.

Overall,  we think that the reports are good, and they present
some new data analysis techniques that are attractive.  Since, in
the past, we have had to do similar data analyses and modeling
for evaporative emissions from vehicle test data, we can
appreciate many of the difficulties and data limitations you are
subject to.  We hope the comments below help you with this
effort.

Document No. M6.EVP.008  (June 28, 1999)

We have the following questions, comments, and recommendations on
this draft report.   For each item we give the page number and
paragraph that the comment refers to, if it is a specific
comment.

Overall this report was clearly written and the general
methodology seems alright.  We do not have any recommendations of
any alternate datasets.  It seems to us that the more serious
problem with the report is that we are not convinced that the
MOBILES predictions adequately describe the new CRC E-35 and E-41
data.  In the comments below, we make suggestions which would
help clarify this comparison to the reader.

1.   Page 1, Section 1.0 - We agree with the general methodology
     used for data collection in past studies.  That is, we agree
     that the running loss emissions do not need to be tested at
     combinations of temperatures and volatilities that are
     either both low or both high.

     EPA, of course, agrees with its own methodology.

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2.   Page 4,  Paragraph 1 - The report suggests a number of
     possible explanations for the differences between
     corresponding values in Table 1 and Table 2.   A short
     paragraph listing and very briefly discussing alternative
     explanations would give credence to the conclusion that
     gross liquid leakers is the most likely explanation.

     It was not EPA's intention to develop several possible
     explanations as to why the CRC running loss results were
     substantially higher than the predictions from MOBILES.
     Rather,  EPA's goal was to find  (and test) a reasonable
     hypothesis.  This report concludes that the sum of the
     running loss emissions attributable to "gross liquid
     leakers"  (GLLs) and the MOBILES estimates of running loss
     emissions from the non-GLLs is a close approximation of the
     actual results found in the CRC sample.


3.   Page 4,  Paragraph 1 - A comparison of the Table 2 averaged
     results from the CRC projects with the Table 2 MOBILES
     predictions by age is a weak comparison.   In general,
     whenever averages are used in data analysis,  information is
     lost.  We suggest that instead, a tougher, and therefore
     more revealing, comparison should be made by comparing the
     individual running loss minus resting loss values from the
     CRC studies with the MOBILES predictions by vehicle age.
     This could be conveniently done in a plot of running loss
     versus vehicle age with the CRC data points on the plot and
     the MOBILES curve on the plot.  If it is possible to make
     such a plot with the CRC data, the result avoids the loss of
     information produced by taking averages.   Also, if the plot
     were made in this way,  it would not be necessary to delete
     suspected gross liquid leaker running loss values from the
     plot.  These points would merely be points with high running
     loss values and could be highlighted as those which are
     suspected of being gross liquid leakers.

     The CRC data will be provided  (in a spreadsheet) with this
     report.   So, the users may create their own scatter plots if
     they desire.  The plots in this report have been revised to
     include the  (90 percent) confidence intervals at each point
     rather than the full scatter plot of all the data.


4.   Page 5,  Table 3 - The values for mean age in Table 3 are
     exactly the same as the values in Table 1.  Presumably, if
     six vehicles have been removed to produce Table 3 the mean
     ages will be different.

     The reviewer is correct about that error.  However, based on
     some of the comments from this reviewer,  EPA decided to
     change the approach / emphasis  (not the actual analysis or

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                               -11-
     conclusions)  to improve clarity.   One of the results of that
     change was the dropping of that table from this revision.


5.    Page 5,  bottom half -

     [This material is now on the bottom half of page 6.]

     At this point in the report,  the discussion centers around
     the significance of the differences between the MOBILES
     prediction curve and the CRC data values.   There are two
     problems with this analysis.

     First, statistical tests of significance are usually made in
     a space where the variance is relatively homogeneous and
     normally distributed.  The fact that the standard deviations
     of the measured values in Tables 1 and 3 are one and a half
     to three times the means indicates to us that the running
     loss values have skewed distributions.  Since automotive
     emissions values typically are skewed approximately in a
     log-normal fashion, we suggest that instead the test of
     significance be based in log space.  For us,  this would most
     convincingly be put forward by plotting the running loss
     emissions on a log scale in the plot suggested by Comment 3.
     The MOBILES curve should pass somewhere through the center
     of the 200 CRC measurements.

     As noted in our response to the third comment, the users may
     create their own scatter plots (using a logarithm scale in
     this case) to compare the results from the CRC sample with
     the estimates from MOBILES and MOBILES.

     Second,  to verify that no significant difference exists
     between the measured CRC values and the MOBILES predicted
     value, some sort of formal statistical test should be
     performed.  We suggest that a paired t-test be used to
     compare the average of the residuals  (measured CRC value -
     predicted MOBILES value) for each car with the standard
     deviation of the mean of the residuals.  These calculations
     should be done in log space,  where we presume the variance
     is homogeneous and normal.  If the mean residual is found to
     be not significantly different from zero,  then it can be
     concluded that the measurements and the predictions are the
     same.  If the mean residual is significantly different from
     zero, then either the MOBILES model needs to be changed or
     an explanation needs to be provided that the significant
     difference is small and is of small practical importance.

     The approach suggested by the reviewer is valid; however,  it
     is more extensive than what EPA is attempting.  In fact, a
     statistical analysis of the results at the age of 20 years
     may find the difference to be statistically significant, but
     the relatively small number of in-use vehicles at that age
     reduces the effect of that difference on the overall in-use

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                               -12-
     fleet (composite)  running loss value to be insignificant for
     practical purposes.


6.    Page 6,  Figure 1 - It appears to us that this figure
     indicates that MOBILES under predicts the CRC values by
     about 40%.  Since the standard deviations in linear space of
     the running loss values from the CRC studies are greater
     than the means of those running loss emissions,  any model
     which has a curve between 0 and the means will be within one
     standard deviation of the means.

     The reviewer is correct.   We have, therefore, dropped this
     figure  (graph) from this revision  (as noted in the response
     to the fourth comment) to improve clarity.  The new Figure 2
     (in this revision) avoids these problems and still conveys
     the desired information.


7.    Page 5,  Paragraph 2  -

     [This material is now on page 6.]

     The word "excellent" is glaring in light of the
     relationships shown in Figure 1.  Regardless of the outcome
     of any further analysis on this data in this report, we
     suggest selecting a less enthusiastic word.

     As noted in the response to the preceding comment, that
     figure has been dropped  (replaced) to improve clarity.
     However, the word "excellent" has been retained, but it now
     applies to the fit in the  (new) Figure 2  (for vehicles under
     the age of 11).  We believe that its use is appropriate.


8.    Page 6,  Section 5.0  -

     [This section  ("Conclusions") is now on page 7.]

     Based on our comments above, the report does not convince us
     that there is no significant or important difference between
     the CRC running loss values and the MOBILES running loss
     predictions.  Nevertheless, it could very well be that the
     conclusions stated in Section 5.0 are correct.

     The differences between the MOBILES estimates of running
     loss  (plus resting loss)  emissions and the results obtained
     by CRC in its recent testing programs are significant.  We
     believe that  (for practical purposes) those differences are
     explained  (and eliminated) by including the emissions from
     the "gross liquid leakers" as illustrated in Figure 2 on
     page 6  (of this revision) which was added to improve
     clarity.

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                               -13-
                           Appendix B

               Response to Comments from  Stakeholders
     No comments were submitted in response to EPA's posting a
draft of this report on the MOBILE6 website.

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