Hi Cory-Ann
Am I interpreting the proposed change correctly? We will not have to transfer obligation to downstream parties? For example, if our ethanol plant in Boardman produces 40 million gallons of ethanol during a calendar year, we would only report their production and not pass it through from the plant to Kinergy to Chevron, for example. If Kinergy has rail cars of Midwest ethanol delivered to Eugene that are transloaded into trucks for delivery to Vitol, for example, we would only report the initial receipt of the rail cars of ethanol and not transfer the obligation to Vitol?
Please clarify my understanding of what the intent of the below proposed change means:
Remove requirement to transfer obligations downstream from the initial importer
(OAR 340-253-0310)
Thank you,
Maria
Maria Tharpe
Operations Compliance Manager
Pacific Ethanol, Inc. & Subsidiaries
Kinergy Marketing LLC
400 Capitol Mall, Suite 2060
Sacramento, CA 95814
www.pacificethanol.net / NASDAQ: PEIX
Ph: 916.403.2763 Cell: 559.360.8597 Fax: 916.403.2773
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From: OregonCleanFuels [mailto:OregonCleanFuels@deq.state.or.us]
Sent: Monday, October 07, 2013 10:52 AM
To: WIND Cory Ann
Subject: FW: Proposed changes to the Oregon Clean Fuels Program
Dear Registered Party,
This is just a reminder that you have until 5:00 pm on Friday, October 11th to send me your feedback on the proposed rules.
Note: The initial e-mail below went to just the primary contacts listed when you submitted your registration applications. This e-mail includes the secondary and other contacts in addition to the primary contacts.
As always, please let me know if you have any questions.
Cory-Ann Wind
Air Quality Planner
503-229-5388
From: OregonCleanFuels
Sent: Monday, September 30, 2013 3:01 PM
To: WIND Cory Ann
Cc: COLLIER David
Subject: Proposed changes to the Oregon Clean Fuels Program
Dear Registered Party,
Thank you all for your participation as DEQ completes the registration process and continues to develop the recordkeeping and reporting tools for the Oregon Clean Fuels program. Working with you has helped me identify what works and what doesn’t and what needs improvement. Based on information gathered so far, DEQ is proposing some modifications that include:
· Clarify definitions
· Make the rules consistent with the recordkeeping and reporting tools
· Update the look-up tables
· Focus the administrative requirements to the most critical parts of the program
The current plan is for the modifications to be proposed at the Environmental Quality Commission’s meeting in December 2013 through a temporary rulemaking, so that they can be in place prior to the first annual report due date of April 30, 2014. A permanent rulemaking would follow at the June 2014 meeting. The objective of the rulemaking is to eliminate unnecessary requirements and reduce the burden on smaller businesses participating in the program.
Attached to this e-mail are a factsheet that provides the context and process for the proposed changes and the redline-strikethrough version of the draft rules. Please contact me at OregonCleanFuels@deq.state.or.us or 503-229-5388 if you have any questions. If you have any feedback, please do so by 5:00 pm Friday, October 11, 2013.
Cory-Ann Wind
Air Quality Planner
503-229-5388