Jeff
Herzog
03/
25/
2004
10:
26
AM
To:
"
Grant,
Andrea
­
DC"
<
Andrea.
Grant@
piperrudnick.
com>
cc:
Subject:
Current
Thinking
re
the
Northeast
Mid­
Atlantic
Exclusion
Area
under
the
NRLM
program
Andrea,
The
map
attached
below
illustrates
our
current
thinking
regarding
the
boundaries
of
the
exclusion
area
under
the
NRLM
rule.
High
sulfur
NRLM
under
the
program's
flexibility
provisions
could
not
be
sold
in
the
shaded
area.
This
would
allow
us
to
differentiate
heating
oil
from
NRLM
fuel
by
sulfur
content
in
the
shaded
exclusion
area.
Hence,
we
would
not
need
to
require
that
heating
oil
sold
in
the
exclusion
area
contain
the
marker.
Since
high
sulfur
NRLM/
LM
could
be
sold
outside
of
the
exclusion
area
under
the
rule's
flexibility
provisions,
heating
oil
sold
outside
of
the
exclusion
area
would
need
to
be
marked.
The
areas
excluded
from
the
marker
requirement
and
where
the
sale
of
fuel
manufactured
under
the
credit
and
hardship
provision
of
today's
rule
is
prohibited
are:
North
Carolina,
Virginia,
Maryland,
Delaware,
New
Jersey,
Connecticut,
Rhode
Island,
Massachusetts,
Vermont,
New
Hampshire,
Maine,
Washington
D.
C.,
New
York
(
except
for
the
counties
of
Chautauqua,
Cattaraugus,
and
Allegany),
Pennsylvania
(
except
for
the
counties
of
Erie,
Warren,
Mc
Kean,
Potter,
Cameron,
Elk,
Jefferson,
Clarion,
Forest,
Venango,
Mercer,
Crawford,
Lawrence,
Beaver,
Washington,
and
Greene),
and
the
eight
Eastern­
most
counties
in
West
Virginia
(
namely:
Jefferson,
Berkely,
Morgan,
Hampshire,
Mineral,
Hardy,
Grant,
and
Pendleton).

Best
Regards,

Jeffrey
A.
Herzog,
Mechanical
Engineer
United
States
Environmental
Protection
Agency
National
Vehicle
and
Fuel
Emissions
Laboratory
Assessment
and
Standards
Division
2000
Traverwood
Drive
Ann
Arbor,
Michigan,
48105
Phone:
(
734)
214­
4227
Fax:
(
734)
214­
4816
E­
Mail:
herzog.
jeff@
epa.
gov
