Jul 7, 2004· Comment supporting the proposed extension of time of one year to comply with the SPCC plan revision requirements, but request another ten months for compliance with the implementation requirements, submitted by Robert E. Fronczak, Association of American Railroads (AAR)· EPA-HQ-OPA-2004-0003-0044
Attached are AAR's comments to the Oil Pollution Prevention and Response; Non-Transportation Related Onshore and Offshore Facilities (Extension of the Compliance Dates of the Spill Prevention, Control and Countermeasure [SPCC] Rule). We also tried to attach the comments of the American Petroleum Institute (API) dated July 7, 2004, but were not able to do so using the electronic docket system. We support API's comments and incorporate them herein full by reference. Respectfully yours, Robert E. Fronczak, P.E.