In theory, those small retail stations are still regulated because they meet the definition of “importer”…which means they still need to register. I might have to do some more outreach to make sure we’ve captured them all. The proposed change is that they only have to keep records for transaction id, transaction type, name and fein of the transfer and recipient, volume, and whether the fuel is exempt or exported…these are the things that you have to keep track of now anyway, right? As importers of finished fuels, they won’t have to also track carbon intensity, physical pathway, biofuel producer, etc.
Does that make sense?
Cory-Ann Wind
Air Quality Planner
wind.cory@deq.state.or.us
503-229-5388
From: Terese Tyler [mailto:tctyler@spaceagefuel.com]
Sent: Monday, October 07, 2013 4:45 PM
To: OregonCleanFuels
Subject: RE: Proposed changes to the Oregon Clean Fuels Program
Cory-Ann – the only thing that I thought would be different …is that whoever was bringing the fuel across the state line would be responsible for reporting the fuel….regardless if they owned the tank that it was being put into. That way all fuel would be accounted for. The way it stands now is that the fuel imported to small retail stations will not be reported to your…because they are only importing finished fuels (because we are picking up in out of state terminals and dropping into their storage tanks).
Terese
Terese Tyler, Controller
PO Box 1429, Clackamas, OR 97015
v-503-212-3900 f-503-212-3910
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