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GOVERNMENT AFFAIRS INITIATIVES: Regulatory. October 9, 2006. Outline. IRS Tax Credits EPAct Implementation Private & Local Government Fleet Rulemaking OBD II Requirements Renewable Fuel Standard. IRS - Vehicle Tax Credits. Guidance issued in June - Notice 2006-54
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GOVERNMENT AFFAIRS INITIATIVES:Regulatory October 9, 2006
Outline • IRS Tax Credits • EPAct Implementation • Private & Local Government Fleet Rulemaking • OBD II Requirements • Renewable Fuel Standard
IRS - Vehicle Tax Credits • Guidance issued in June - Notice 2006-54 • Clarifies that aftermarket conversions qualify • Establishes voluntary certification process for manufacturers • Emission standards – does not provide additional guidance on “cleanest available technology” • Issues unresolved: • Application to leases • Recapture • AMT applicability (continued)
IRS – Fueling Station Credit • Guidance has not been issued - identified for possible release • Form 8911, “Alternative Fuel Vehicle Refueling Property Credit” – available • Instructions clarify that credit may be taken for more than one refueling property • Maximum of $30,000 (or $1,000) per property • Not clear if multiple dispensers at single location qualify • Not clear if upgrades to stations qualify (continued)
EPAct Implementation • Electric utility exclusion • Alternative Compliance Program • EPAct Implementation Report • Federal fleet fuel use requirements • GSA Cost Allocation requirements
Private & Local Government Fleet Rulemaking • Background – court case, ruling • Replacement fuel goal proposed • Hearing held October 2 • Comments due November 3 • Fleet determination next year
OBD II Requirements • EPA rules require full OBD compliance for aftermarket conversions • MY 2005 LDVs (effectively MY 2007 – now) • MY 2007 HDVs (effectively MY 2010) • Previously EPA provided some relaxation of requirements • Full compliance costly, burdensome • White Paper – looks at difficulties of requirements, opportunities for relaxation
Renewable Fuel Standard • EPAct 2005 provision for renewable fuel • Requires 7.5 billion gallons of renewable fuel by 2012 • Responsibility primarily for refineries • Credit trading program • Allows refineries to buy and sell credits • Credits based on gallon requirements • NG produced from renewable sources qualifies for credits if used as motor vehicle fuel • Comments due November 2006 – expect to support ability of NG fuel to earn credits