1
Jeff
Herzog
02/
18/
2004
04:
38
PM
To:
Charlie_
Drevna@
npradc.
org
cc:
Subject:
Latest
EPA
thinking
on
nonroad
rule
heating
oil
marker
exclusion
area
concept
Charlie,
I
thought
it
was
time
to
close
the
loop
with
you
re
our
exclusion
area
concept.

Our
current
thinking
is
that:

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,
and
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).
The
Northeast/
Mid­
Atlantic
exclusion
area
is
illustrated
in
the
following
figure:
(
The
shaded
area
represents
the
exclusion
area
(
ie.
the
area
in
which
a
marker
would
not
be
required
in
heating
oil,
and
in
which
small
refiner
and
credit
NRLM
could
not
be
sold.)

Regards
Jeffrey
A.
Herzog,
Mechanical
Engineer
United
States
Environmental
Protection
Agency
National
Vehicle
and
Fuel
Emissions
Laboratory
2
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
