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March 23, 2020

Susan Bodine
Assistant Administrator
Office of Enforcement and Compliance, Air Enforcement Division
U.S. Environmental Protection Agency
William Jefferson Clinton Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

RE: Waiver Request Under Clean Air Act Section 211(c)(4)(C)

Dear Assistant Administrator Bodine:

On behalf of the American Trucking Associations (“ATA”), we respectfully request the U.S.
Environmental Protection Agency (“EPA”) grant a waiver of the federal Reid Vapor Pressure
(“RVP”) requirements that are set to change on May 1, 2020 at the terminal level and June 1,
2020 at the retail level. 1

The COVID-19 outbreak has resulted in severe travel limitations, emergency declarations, and
the closing of non-essential businesses which has created a dramatic decrease in gasoline
demand. With significant amounts of winter grade gasoline remaining in tanks, terminals, and
pipelines -- along with the inability to sell it after the May 1, 2020 transition date -- terminal
operators will have limited capacity to take loads of summer grade gasoline.

If terminal operators cannot take summer gasoline blends, transmission pipelines are expected
to become overloaded. Eventually, refineries may be forced to shut down production. These
problems will be especially exacerbated for pipelines that ship both gasoline and diesel as
backups in gasoline may block diesel fuel supplies (which are not experiencing the same
reductions in demand as gasoline) from reaching the market. While the drop in gasoline
demand is indeed changing the supply chain, the issue regarding the over-supply of winter
gasoline blends can be avoided with a RVP waiver for a fixed, clear period of time to allow
marketers to sell all of their winter grade fuel on hand today. Given the recent dramatic
1
ATA is a united federation of motor carriers, state trucking associations, and national trucking conferences
created to promote and protect the interests of the trucking industry. Directly and through its affiliated
organizations, ATA represents more than 34,000 companies encompassing every type and class of motor carrier in
the United States and Canada.
reductions in emissions resulting from unprecedented business closures, reduced travel, and
the downturn in electrical demand, we do not envision any negative air quality impacts on State
Implementation Plan attainment measures by granting a temporary waiver.

During these exceptionally trying times, it is critical for our country to remove all impediments
for trucking companies to keep delivering the nation’s supply of food, medicine, and other
essentialities. With more than 80% of U.S. communities relying exclusively on trucks for their
freight needs, we must ensure the trucking industry’s fuel supplies keep flowing to the more
than 600,000 interstate motor carriers nationwide. EPA, with the concurrence of the
Department of Energy, has the statutory authority to issue a temporary waiver under Clean Air
Act Section 211(c)(4)(C) to alleviate these concerns. The ATA urges EPA to grant this request
expeditiously to avoid disruptions in diesel fuel supplies.

On behalf of the 3.4 million hard-working truck drivers and the 7.7 million people employed in
our industry, we thank you for your timely consideration of our request. We look forward to
your leadership on this and other matters as you continue to help address the ongoing health
crisis at hand.
Sincerely,

Glen P. Kedzie
Vice President, Energy & Environmental Counsel

cc: Kurt Gustafson, PhD, OTAQ