EPA’s On-Road Diesel Program: Issues of Importance to Diesel Fuel Marketers and Their Customers Gregory M. Scott, Esq. Collier Shannon Scott PLLC email@example.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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