ILTA Asks Pennsylvania Regulator to Revisit State's Summer Gasoline RVP Waiver
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Letters, Comments & Testimony

Cathy Landry

ILTA Asks Pennsylvania Regulator to Revisit State's Summer Gasoline RVP Waiver

Suggests Pennsylvania Waiver Mirror EPA Policy

May 8, 2020


Walter T. Remmert
Director Bureau of Ride & Measurement Standards Pennsylvania Department of Agriculture 2301 North Cameron Street
Harrisburg PA 17110


Dear Mr. Remmert,

Thank you for your email response of Friday, May 8, 2020 to Jay Cruz of our staff regarding the Pennsylvania RVP waiver. In your email you clarified that after July 15, 2020 the Commonwealth will allow only summer-grade gasoline to be offered for retail sale.


We would like to make you aware that as of now, there has been very little turnover at the bulk storage terminal level of winter to summer-grade gasoline because of the extreme demand destruction resulting from the COVID-19 pandemic. If retail gasoline establishments must meet summer-grade requirements on July 16th, storage terminal operators will be unable to move winter gasoline for some time prior to that -- no retailer will want to take receipt of winter-grade fuel when they have to transition their tanks by July 16th. While there has been some recovery in gasoline demand, it remains significantly below what is normal and there is considerable concern among our members they would be forced to shut in (isolate) tanks with winter-grade gasoline as early as June 15th. This would make those tanks unavailable throughout the summer months and could negatively impact gasoline supply in Pennsylvania.


We request that Pennsylvania consider mirroring the US EPA RVP waiver which allows the sale of winter-grade gasoline until the supply is depleted. This “sell until depleted” provision has been adopted by every State adjacent to PA (NJ, DE, MD, WV, OH and NY).


Thank you for your consideration and please contact me at plidiak@ilta.org or 571-444-0282 if you have any questions.

Sincerely,
Peter Lidiak

Vice President, Regulatory Affairs

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