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Why are credits and allotments expressed in ppm-gallons and not in ppm-barrels, since barrels or thousand barrels are the commercial units used by refiners?

See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help.

Consistent with the requirements under the RFG program, § 80.195(a)(2) provides that, for purposes of sulfur compliance and reporting, volumes are expressed in gallons. Accordingly, credits and allotments are required to be calculated and reported in units of ppm-gallons.

Although barrels may be the commercial units used by refiners, the conversion from barrels to gallons requires a simple calculation which should not impose an undue burden on regulated parties.