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									EPA’s On-Road Diesel Program:


            Issues of Importance to
  Diesel Fuel Marketers and Their Customers

           Gregory M. Scott, Esq.
         Collier Shannon Scott PLLC
         gscott@colliershannon.com

               June 10, 2003
         Overview of Presentation

   My Background
   NACS and SIGMA
   History of NACS/SIGMA Involvement in
    Program
   Diesel Fuel Marketer Plans for 2006
   Questions to be Addressed by EPA and the
    Marketplace
                Background
   CSS Is Washington, D.C. Based Law Firm
   With Large Legislative and Regulatory Practice
   Firm Has Represented:
     – National Association of Convenience Stores for
       30 Years
     – Society of Independent Gasoline Marketers of
       America for 25 years
   My Background: Capitol Hill; Political Consulting;
    Legal and Lobbying Work at CSS
             NACS and SIGMA
   NACS
     – 1,700 retail member companies;
     – 100,000 stores;
     – 130 billion gallons of motor fuel in 2002
   SIGMA
     – 270 independent motor fuel marketers
     – Supply over 28,000 outlets
     – 48 billion gallons of motor fuel in 2002
   Together, NACS/SIGMA Members Sell Over 85% of
    Motor Fuel in Nation Each Year
          NACS/SIGMA Involvement in
              On-Road Program
   Opposed 15 ppm Diesel Sulfur Standard in 2007
     – Supply Concerns
     – Cost/Price Concerns
   Opposed 80/20 Phase-In
     – Supply Concerns
     – Customer Concerns
     – Possibility of Contamination
     – Possibility of Misfueling -- Intentional or Not
   Sued EPA -- Lost Lawsuit
NACS/SIGMA Involvement in On-Road
         Program (Cont.)

 Represented on CDIRP
   – Supply Issues Not Addressed
   – Marketer/Customer Issues Not Addressed
   – Report Was A Whitewash of Problems We Face
  Co-Sponsored Houston Diesel Sulfur Workshop
   – Best Discussion of Challenges to Date
   – Not Many Answers, Many Questions
   – Still Waiting for EPA Follow-Up
Diesel Fuel Marketer Plans for 2006
   Start of Program is Three Years Away
     – Diesel Fuel Marketer Plans Still Being Formed
     – Market one diesel or two?
     – Choose market segment to service?
     – Install additional tanks?
   Marketer Plans Will Depend on the Following Factors:
     – Mix of 15/500
     – Overall Supply
     – Price Delta Between 15 and 500
     – Customer Demand
Questions to Be Addressed by EPA and the
               Marketplace
   Many Questions Must Be Answered:
      – Will NOx adsorbers be viable in 2007?;
      – Are manufacturers looking at other devices?;
      – Mix of 15/500 at the rack;
      – Field test methods -- none exist;
      – Prevention of misfueling, intentional or not;
      – Marketer/customer liability issues;
      – Impact of off-road proposal on supply
   To date, EPA has been silent on all these issues
   The marketplace may not begin to speak on these issues
     until 2006
                 Conclusion


   Thank You
   Questions?

								
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