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To: Andrew Beck
Thank you for the opportunity to comment on the draft report of the
Governors' Task Force on Boutique Fuels. Having
reviewed the draft, ILTA has concluded that it fails to provide the information
that President Bush requested.
As the report states in the Executive Summary, the Task Force was charged
with identifying opportunities to increase cooperation among the federal
government and the states on gasoline supply decisions and to reduce the number
of boutique fuels.
The report contains no recommended opportunities for increasing
cooperation. Regional clean fuel
programs are mentioned as a "possible" means of cooperation.
The Executive Summary states in the fourth bullet that "careful
consideration should be given to the possibility of new legislative authority
which would allow for the adoption of regional clean fuel programs." This vague statement is not a recommendation.
The report fails to identify even a single opportunity to reduce the
number of boutique fuels. It is weighted heavily toward support of boutique
fuels in line with the views of the state regulators and the environmental
groups. In Section VIII, EPA
Recommendations and Observations, the report states that "EPA's review did
not reveal any studies or empirical data confirming that boutique fuels
presently contribute to higher fuel prices or present unusual distribution
problems." This amounts to a
casual dismissal of the industry's position on the economic realities inherent
in our nation's fuel market. All
EPA had to do was review the records of one of its own actions after Hurricane
Katrina. EPA was compelled by an impending gasoline shortage to grant
a waiver for use of winter blend RFG in place of the more scarce summer blend
that was otherwise required to be used through September 15.
The granting of this EPA waiver is a recent, compelling illustration of
the adverse impact of boutique fuels on gasoline supplies and price
volatility.
ILTA is disappointed in your conclusion that state renewable fuel
programs are outside the scope of the Task Force.
The long-term consequences of these programs, especially in terms of the
impact on the reliability of fuel supplies, should have been addressed in the
report.
Finally, we would note that EPA has vast analytical resources at its
disposal. By relying on the
manpower and expertise of contractors, EPA could have responded to President
Bush's request much earlier and much more aggressively with legitimate
recommendations. Unfortunately,
this did not occur.
David Doane
President, ILTA
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