As a state motor fuel quality regulator I would like to enter into the record the following comments on proposed changes to the FTC's Rule for Automotive Fuel Ratings, Certification, and Posting, commonly known as the Fuel Rating Rule. Massachusetts does not have a lab and use IR diagonstic technology for field tests and find that it is a great deterrent in eliminating the fraudulent business practice of mixing low octane with high octane fuel. It has a definite advantage over having to send samples to a lab for the simple reason that the results are readily available within a minute or so. When we do find a violation we offer the retailer the opportunity to have the fuel tested at his cost. We procure the sample, seal the container for chain of custody purposes and transport the sample to the lab of his choice, we have two labs in the Boston area. We have not had a dealer opt to have the sample tested at their expense. We also fine both the dealer and the trucker if the inventory records indicate that the low octane was dumped in the high octane tank. Massachusetts law states he who adulterates is guilty so the trucker even if ordered or directed by the retailer to dump excess fuel in the higher octane tanks is subject to a fine.