Letter to EPA on Winter-to-Summer Gasoline Transition Due to COVID-19
March 20, 2020
The Honorable Andrew Wheeler
Administrator U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Dear Administrator Wheeler:
The International Liquid Terminals Association represents more than 85 companies operating liquid terminals in all 50 states and in over 40 countries. Our members’ facilities provide critical links between all modes of transportation for liquid commodities, such as crude oil, petroleum products, chemicals, renewable fuels, fertilizer, vegetable oils and other food-grade materials that are central to the U.S. economy. Terminals provide essential logistics services that spur trade both within the United States and connect the U.S. economy with overseas markets. ILTA’s membership also includes about 400 companies that supply equipment and services to the terminal industry.
We are writing to bring to your attention an imminent effect of the Coronavirus pandemic. As you are no doubt aware, with so many people working from home to avoid interpersonal contact, there has been a significant reduction in demand for gasoline. This is having an unprecedented impact on outbound movements of gasoline from petroleum products terminals such that our members are becoming concerned they will be unable to accomplish the turnover of their gasoline tanks from winter to summer gasoline by the 40 CFR 80.27 May 1 deadline for doing so. As the situation appears to be worsening, we request that EPA consider the issuance of an enforcement waiver that would allow the release of winter gasoline and commingled winter and summer gasoline from terminals between May 1 and June 1. We have heard from our members that this should provide sufficient time at current product movement levels to affect the transition to summertime gasoline.
We understand that individual companies and other trade associations have already made similar requests for such a waiver and want to reinforce that while we are still more than a month from the May 1 deadline, a decision is needed from EPA now to allow the supply chain to work as it should. Our members will work diligently to make the turnover from winter to summer gasoline as quickly as possible under the current unprecedented conditions.
If you have any questions, please contact me at firstname.lastname@example.org or 301-325-2853.
Vice President for Government Affairs
cc: Kurt Gustafson, Office of Air and Radiation
Anthony Miller, Office of Enforcement and Compliance Assurance