16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005 #00414

Submission Number:
00414
Commenter:
Jerry Parsley
State:
Texas
Initiative Name:
16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005
I sincerely request the Commission seriously consider performance-based test methods such as FTIR and Raman Spectrocopy coupled with chemometric models for the FTC's monitoring of motorfuels. Well developed examples of these methods often exceed the performance of the reference methods, specifically repeatability and reproducibility of ASTM D2699 and D2700 - Octanes of Motor Fuels, as well as ASTM D86 - Distillation of Petroleum Products. These Performance Based Test Methods are typically less capital intensive and significantly easier to support. Please give these technologies your serious examination and consideration.