Jeff
Herzog
11/
12/
2003
03:
32
PM
To:
Andrea.
Grant@
piperrudnick.
com,
ddoane@
ilta.
org,
dgilligan@
pmaa.
org,
LidiakP@
api.
org,
MELeister@
MAPLLC.
com,
Charlie_
Drevna@
npradc.
org,
BBrown@
ColPipe.
com,
MJoy@
AOPL.
com,
GScott@
colliershannon.
com
cc:
jhuber@
nora­
oilheat.
org,
JScandola@
buckeye.
com
Subject:
Suggested
revision
to
proposed
heating
oil
marker
requirement
Gentlefolk,
I
have
been
exploring
the
idea
raised
by
industry
of
excluding
parts
of
PADD
1
from
the
proposed
heating
oil
marker
requirements
(
for
2007­
2010)
a
bit
further.

Under
such
an
approach:
­
Terminals
in
the
exclusion
area
would
not
be
required
to
add
the
marker
to
heating
oil.
­
Terminals
outside
of
the
area
would
be
required
to
add
the
marker
to
heating
oil.
­
No
high
sulfur
(>
500
ppm)
small
refiner
or
credit
NRLM
could
be
used
in
the
exclusion
area.
All
high
sulfur
fuel
(>
500
ppm)
would
be
for
use
as
heating
oil
only.

John
Huber
of
NORA
also
suggested
such
an
approach
in
written
comments
that
he
filed
to
the
NR
rule
docket
this
week.
I
think
that
we
might
also
have
to
put
in
place
some
restrictions
on
bulk
shipments
(
by
pipeline
and
barge)
of
unmarked
heating
oil
out
of
the
exclusion
area.
Its
currently
unclear
to
me
whether
we
would
also
need
to
put
in
place
restrictions
on
the
shipment
by
truck
of
unmarked
heating
oil
out
of
the
exclusion
area.

If
we
were
to
take
such
an
approach,
my
initial
evaluation
suggests
that
the
following
area
might
be
the
best
fit
wrt
to
reducing
the
potential
costs
of
the
proposed
heating
oil
marker
requirement
while
maintaining
the
potential
benefits
of
the
proposed
small
refiner
and
credit
provisions:
>>>>
No
marker
would
required
in
heating
oil
(
and
no
high
sulfur
small
refiner
and
credit
NRLM
fuel)
in
PADDs
1A
and
1B
except
the
area
in
PADDs
1A
and
1B
which
also
belongs
to
"
Appalachian
No.
1"
(
i.
e.
Western
NY,
and
PA,
and
West
Virginia).

Any
thoughts?

I
also
asked
Jim
Scandola
(
of
Buckeye
pipeline)
and
John
Huber
for
their
input.
Feel
free
to
respond
by
e­
mail
or
to
give
me
a
call.
I
plan
to
docket
any
exchange
of
e­
mails
on
the
subject.
Please
don't
read
too
much
into
this.
We
just
want
to
flesh
the
idea
out
so
we
can
evaluate
it
fully.

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
