Reporting for the Tier 2 Gasoline Sulfur Program

1. Reporting for the Tier 2 Gasoline Sulfur Program U.S. EPA Office of Transportation and Air Quality

2. Reporting - Topics Covered • Registration • Baseline Applications • First year deadlines • Annual Report Information Required • Annual Report Issues • Other Important Deadlines • Guidance on Annual Reports • Electronic Reporting Issues

3. Registration • RFG/Antidumping Registrations are sufficient (new registrations minimal) • May 10, 2000: all early credit generators must be registered • November 1, 2003: all refiner/importer registrations due • Future refineries: due 3 months before production

4. Baseline Submissions • Refiners seeking to establish sulfur baselines must apply by: • September 30 of 1st year of credit generation • December 31, 2000 for GPA gasoline baselines • September 30, 2000 for temporary hardship exemptions • December 31, 2000 for small refinery status

5. Important Deadlines at Beginning of Sulfur Program

6. Baseline Submissions • Guidance and spreadsheet format available at http://www.epa.gov/otaq/tr2home.htm#guidance

7. Baseline Submissions • RFG vendor software accommodates spreadsheet format. • Information must include all appropriate gasoline batches from ‘97 & ‘98 including volumes and sulfur content. • Only gasoline actually produced at a facility is counted in the baseline...therefore, some RFG reports are excluded (e.g., blendstocks).

8. Spreadsheet Format for Sulfur Baseline Submissions:

9. What do annual reports track? • Credit/allotment generation and use (accounting of credit/allotment balance) • Compliance with corporate pool average • Compliance with refinery standard • Transfer of credits/allotments • Conversion of allotments/credits

10. Annual Reports Registration number (facility, refiner, importer) Applicable baseline (for 2000 through 2003) Applicable average standards Applicable adjusted cap standards The total volume of gasoline produced or imported Annual average sulfur level of produced/imported gasoline Annual average sulfur after inclusion of credits/allotments The number of credits/allotments (C/A) at start of averaging period C/A generated C/A used C/A transferred with reporting id of other party C/A expired C/A to carry over to the next averaging period The number of each type of allotment converted to credits

11. Annual Reports (continued) Batch numbers Date batch produced Batch volume Sulfur content of the batch Additionally, for importers of sulfur FRGAS: Foreign refiner and refinery ids Volumes of certified sulfur FRGAS and non-certified sulfur FRGAS. Corporate Pool Average reports (for those not exempted) Corporate pool averages (for 2004 and 2005) Facility/batch info must be reported in aggregate for all gasoline imported or produced.

12. Annual Report Issues • Separate company/facility report • New report formats as program changes? • Credit Generation • Allotment generation/use • Corporate average standard • Small refinery timing allowances • Tracking of allotment/credit conversions • Discounting credits

14. EPA Guidance • EPA will issue guidance similar to baseline guidance well before annual reports are due • We hope to make submissions “electronic” with use of simple spreadsheet formats and/or text delimited files with web-based reporting or disk submission. • We seek refiner comment on the appropriateness of various electronic filing approaches. • Spreadsheet approach will facilitate updating of forms as program changes.

15. Electronic Reporting • We initiated RFG electronic reporting in the form of Electronic Data Interchange • Use of value-added networks (VANs) may not be needed with improvements in encryption techniques. • We would like to introduce spreadsheet/text file format (for sulfur AND RFG/antidumping) but EDI may be maintained. • We would like to eliminate most paper forms.

16. Sulfur Reporting • Questions? • Can email comments to: • Dave Kortum • kortum.dave@epa.gov