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Regulation of Fuels and Fuel Additives: Renewable Fuel Program

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American Petroleum Institute filings
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American Petroleum Institute filed 4 comments on this docket between Nov 13, 2006 and Mar 26, 2010. 182 other organizations filed here. The comment window closed 4019d ago.

What American Petroleum Institute filed (4)

Mar 26, 2010· Comment submitted by Jack N. Gerard, President and Chief Executive Officer, American Petroleum Institute (API)· EPA-HQ-OAR-2005-0161-2641

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Oct 7, 2009· Comment submitted by Robert L. Greco, III, API Group Director, Downstream & Industry Operations, American Petroleum Institute (API)· EPA-HQ-OAR-2005-0161-2523

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Oct 2, 2009· Comment submitted by Al Mannato, Fuels Issues Manager, American Petroleum Institute (API)· EPA-HQ-OAR-2005-0161-2393

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Nov 13, 2006· Comment submitted by Alfonse Mannato, American Petroleum Institute (API)· EPA-HQ-OAR-2005-0161-0185

November 12, 2006 U.S. Environmental Protection Agency Air Docket 1200 Pennsylvania Ave., NW Mail Code 6102T Washington, DC 20460 Attention: Docket ID Number: EPA-HQ-OAR-2005-0161 Re:The U.S. Environmental Protection Agency's Proposed Rule on Regulation of Fuels and Fuel Additives: Renewable Fuel Standard Program 71 Fed. Reg. 55551 The American Petroleum Institute (API) is pleased to provide the attached comments on the above referenced notice of proposed rulemaking. API is a national trade association representing more than 400 member companies involved in all aspects of the oil and natural gas industry. API members are dedicated to meeting environmental requirements, while economically developing and supplying energy resources for consumers. API members provide the fuels that keep America running. API believes that it is critical that fuel regulation retain sufficient flexibility to allow industry to meet America?s energy needs. In order to meet the growing needs of consumers, we understand that we must produce, refine and distribute more fuel than ever before under continually restricting controls. Flexibility in the national renewable fuel standard (RFS) plan is essential in order to integrate renewables into the nation?s gasoline pool in the quickest and most effective way possible. One of the greatest impediments to an efficient and workable national RFS is the rising tide of state biofuels mandates. These threaten to remove most of the flexibility that Congress and now EPA have carefully and intentionally put into the national RFS program. When API along with other stakeholders began talking to EPA about this regulation, we developed a set of principles whose overall goal was to maximize market efficiency. These principles can be described with just a few words: workability; transparency; enforceability; low cost, and certainty. There are some technical issues yet to be resolved, but overall the approach that EPA has chosen conforms to all of these principles. Moreover, EPA has worked cooperatively with all stakeholders ? demonstrating the benefits of dialogue and idea exchange between business and the regulatory community. U.S. EPA Air Docket November 12, 2006 Page 2 API recommends that EPA make several changes to the proposed rule to help ensure a smooth transition into the program during 2007. A smooth transition is made more difficult because the program provision have yet to be established and once set, will apply for a partial year API member companies are committed to meeting the requirements of the RFS in a timely and effective manner and oppose the suggestion made by several parties at the hearing that full implementation of the program should be delayed until 2008. There is no legal justification for the delayed implementation. EPA must finalize the regulation before the end of March and must start program implementation at least by July 1, 2007. If EPA is unable to meet this date, we will have to reevaluate this issue. The changes that should be made include: ? The final regulations should be prospective and become effective no sooner than 60-120 days after they are issued. Moreover, they should apply to RIN generators and obligated parties at the same time. That is, the date on which the RIN obligation commences must be identical with the date on which RIN creation begins. ? EPA needs to better coordinate the small refineries exemption. EPA has assumed in calculating the 2007 RFS required percentage of 3.71, that all small refineries (in addition to the small refiners) will be exempt. However, under the proposal these parties are obligated parties until their application for exemption is approved. These applications are not due to EPA until September 1, 2007. We suggest that EPA finalize (and announce in a supplemental notice) an earlier, accelerated schedule for small refinery exemption application so that small refineries can qualify for the exemption p…

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Abstract

Contact: David Korotney, Office of Air Radiation/Office of Transportation and Air Quality, (734)-214-4507

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Co-filers (182)

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