1
John
Huber
<
jhuber@
nora­
oilheat.
org>
11/
11/
2003
10:
27
AM
To:
Jeff
Herzog/
AA/
USEPA/
US@
EPA
cc:
Subject:
RE:
Low
Sulfur
and
Heating
Oil
Jeff
I
think
your
suggestion
would
have
minimal
impact.
In
Rochester,
Buffalo
and
Pittsburgh
(
extended
metropolitan
areas),
there
are
185,000
home
heating
oil
consumers.
At
an
average
consumption
of
700
gallons,
the
cost
of
the
marker
would
be
259,000.
I
do
not
have
county
data
on
off­
road
and
other
NRLM
uses.

I
guess
my
greatest
concern
would
be
clarity
of
enforcement.
I
guess
one
way
of
doing
it
is
for
terminals
in
PADD
1
in
this
Appalachain
area
to
agree
to
handle
a
marker
if
they
want
to
do
the
credit.

One
concern
I
have
is
how
the
credits
will
be
generated,
almost
everyone
overproduces
500
ppm
highway
diesel,
and
it
either
goes
off­
road
or
into
heating.
It
would
seem
that
as
a
result
everyone
will
have
credits,
and
have
the
right
to
internally
delay
the
program
start
with
the
credits
for
a
period
of
time,
the
credits
they
have
accumulated
by
the
ratio
of
NRLM
fuel
they
sell.
That
would
make
the
credit
program
very
extensive,
but
really
have
no
impact
on
behavior.
Am
I
missing
something?

John
­­­­­
Original
Message­­­­­
From:
Herzog.
Jeff@
epamail.
epa.
gov
[
mailto:
Herzog.
Jeff@
epamail.
epa.
gov]
Sent:
Monday,
November
10,
2003
4:
30
PM
To:
John
Huber
Subject:
RE:
Low
Sulfur
and
Heating
Oil
John,
To
explore
your
idea
a
bit
further
...
Envision
the
following
scenario
similar
to
that
discussed
in
your
comments:
No
marker
required
in
heating
oil
(
and
no
banking
an
trading
program)
in
PADDs
1A
and
1B
except
the
area
in
PADDs
!
A
and
!
B
which
also
belongs
to
"
Appalachian
No.
1"
(
i.
e.
Western
NY,
and
PA,
and
West
Virginia).
How
would
this
modification
to
your
proposal
affect
the
benefits
that
estimated
for
carving
out
all
of
PADD
1
as
a
no­
marker
area?
Do
you
see
any
other
problems
with
this
alternative?
Please
don't
read
too
much
into
this,
2
we
are
just
brainstorming.

Thanks
for
your
help
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
John
Huber
<
jhuber@
nora­
oilheat.
org>
To:
Jeff
Herzog/
AA/
USEPA/
US@
EPA
cc:

Subject:
RE:
Low
Sulfur
and
Heating
Oil
Received
Date:
11/
10/
2003
03:
34:
08
PM
Transmission
Date:
11/
10/
2003
03:
34:
08
PM
Jeff
My
limited
thinking
on
that
was
if
there
was
an
objection
to
my
proposal,
we
could
be
in
a
position
that
we
affirmatively
mark
product
in
PADD
I.

John
­­­­­
Original
Message­­­­­
From:
Herzog.
Jeff@
epamail.
epa.
gov
[
mailto:
Herzog.
Jeff@
epamail.
epa.
gov]
Sent:
Monday,
November
10,
2003
12:
46
PM
To:
John
Huber
Subject:
Re:
Low
Sulfur
and
Heating
Oil
John,
Thanks
for
your
thoughtful
comments.
I'll
make
sure
the
right
folks
are
aware
of
them
and
will
keep
you
in
the
loop
in
our
ongoing
3
discussions
on
the
marker
issue.
A
point
of
clarification:
re
the
marking
of
credit
gallons
being
a
reasonable
alternative
....
marking
credit
gallons
might
result
in
lower
costs
if
there
were
fewer
credit
gallons
than
heating
oil
volumes
(
hence
it
seems
attractive),
however,
we
would
have
to
ensure
that
such
a
system
satisfied
our
enforcement
goals
(
its
unclear
if
and
how
this
would
be
accomplished)
......

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
John
Huber
<
jhuber@
nora­
oilheat.
org>
To:
Jeff
Herzog/
AA/
USEPA/
US@
EPA
cc:

Subject:
Low
Sulfur
and
Heating
Oil
Received
Date:
11/
10/
2003
11:
31:
06
AM
Transmission
Date:
11/
10/
2003
11:
31:
06
AM
Jeff
Here
are
my
thoughts
on
this,
let
me
know
if
you
think
they
have
merit
or
I
should
try
a
different
approach.
John(
See
attached
file:
marking
comments.
doc)
