The EPA has stated that PTD's include documents that reflect the transfer of ownership and physical custody of gas or blendstock, including invoices, receipts, bills of lading, manifests and pipeline tickets. Each of these documents contain different pieces of information required by the EPA. Some specify quality, quantity, parties of transfer, etc. Some are available prior to product shipment and some, such as pipeline meter tickets and final Bills of Lading, are provided after the product moves. Can we assume that the information identifying place of use restrictions, segregation requirements or standards of performance can be provided to the transferee prior to the product shipment? But that other transfer document requirements such as final quantity shipped, can be provided to the transferee after the product moves?

Yes. The regulations require PTD's be provided by the transferor to the transferee on each occasion when any person transfers custody or title of RFG, RBOB or conventional gasoline. The regulations do not specify at what point in the delivery PTD's are to be provided for each occasion. (7/1/94)

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