March 24, 2020
Chet M. Thompson President and CEO
American Fuel & Petrochemical Manufacturers
1800 M Street, NW Suite 900 North Washington, DC 20036 202.457.0480 office 202.457.0486 fax CThompson@afpm.org afpm.org
Andrew Wheeler Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460 Wheeler.andrew@epa.gov
Susan Bodine Assistant Administrator U.S. Environmental Protection Agency Office of Enforcement and Compliance Assurance Mail Code 2201A, Room 3204 WJC South 1200 Pennsylvania Avenue, NW Washington, DC 20460 bodine.susan@epa.gov
Re: Request for Conventional Gasoline RVP/RFG Volatility Waivers
Dear Administrator Wheeler and Assistant Administrator Bodine:
The American Fuel & Petrochemical Manufacturers (AFPM) writes to request a narrowly tailored waiver allowing retail operations and terminal operators additional time to transition from winter to summer gasoline. A waiver is necessary to address the "extreme and unusual fuel supply circumstance" that will prevent the distribution of an adequate supply of gasoline to consumers nationwide.
Specifically, we request EPA exercise its authority under Clean Air Act 211(c)(4)(C)(ii) and (iii) to temporarily waive the summertime conventional gasoline RVP and RFG volatility requirements and simultaneously prohibit entities from adding fuel or fuel additives in a manner that inhibits the prompt drawdown of existing inventories of wintertime gasoline.
Unlike events that have led to prior RVP waivers, such as hurricanes or pipeline disruptions, the ability to produce low RVP gasoline has not been compromised. Refiners have already converted their operations and begun producing low RVP BOBS required for summer gasoline. The problem facing the fuel distribution system is the inability to drawdown and convert fuel distribution tankage. This is because COVID-19 has drastically reduced the demand for gasoline and this demand destruction has resulted in the inability to deplete winter RVP gasoline volumes
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from terminal storage tanks. This demand destruction and its impact on tankage turnover times were unforeseeable and could not be prevented.
The inability to quickly turnaround gasoline storage tanks in this low demand environment requires EPA to issue the waiver described above. To balance the environmental benefits from the transition to summertime gasoline, additional measures should be considered to facilitate the prompt turnover of terminal and retail tankage.
We look forward to discussing these measures in greater detail. If you have any questions, please don't hesitate to contact me.
Respectfully,
Chet Thompson President and CEO
cc: Dan Brouillette, Secretary of Energy
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