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Consultant CH2M Hill confirmed the validity of the model used in Publ 2514A by comparing emission test data with predictive emission models developed by API, ARCO , and Exxon. This study found that the API model used in Publication 2514A adequately predicts emissions for tanks ranging in size from 17,000 to 35,000 dead weight tons and for tanks being loaded within the lower 48 states. The model does not appear to apply to crude oil loading of tankers in Valdez, Alaska, because of unique local operating conditions. However, no known test data invalidates the model for predicting crude oil loading emissions from carriers smaller than very large carriers in the lower 48 states.