If a refiner produces only conventional gasoline, what is the purpose of the added burden of testing, auditing, documentation, and general compliance requirements? Since there is only conventional gasoline produced, there can be no dumping. Also, if the EPA is concerned with other companies dumping into our conventional gasoline pool by selling us blendstocks, the blendstock accounting section would prohibit this. Thus, we come back to the question, "What is EPA's intent with the baseline and compliance requirements for conventional gasoline refiners?" Can the EPA exempt refiners from the accounting requirements for conventional gasoline? The EPA could exempt conventional gasoline reporting for a baseline volume; however, this implies that the EPA has a hidden agenda to control the future quality, if not the current quality, of conventional gasoline. Is it possible to petition the EPA for an exemption to the accounting and compliance requirements for conventional gasoline?

The Clean Air Act requires that all conventional gasoline on average be at least as clean as it was in 1990 regardless of who produces the conventional gasoline. Therefore, all refiners and importers are subject to requirements that ensure the quality of their conventional gasoline beginning in 1995. Refiners and importers of conventional gasoline could provide "dirtier" gasoline if not specifically prohibited, regardless of whether they produce or import RFG. Therefore, neither the statute nor the regulations provide for exceptions to these requirements. (7/1/94)

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