Happy New Year to each of you. I know many throughout the country looked forward to closing the book on 2020, but for those of us in the fuels regulatory arena this was a bitter-sweet ending. Watching the ball drop at the stroke of midnight signaled the close of a regulation (40CFR80) many of us have grown up with. And as the celebration began for 2021 with the hope of better days ahead, we open the cover to a new version of the fuel’s regulation (40CFR1090). Yes, the structure has shifted, the length significantly condensed, and the approaches have been streamlined; but overall, the requirements remain. Still, we find ourselves torn between the comfort of the old and the ambiguity of the new. Soon, like the old book, this new version will become worn and tattered, and the content well understood. Until then, may you find blessings in this new year. Cheers to 2021.    Throughout the next few months, we will be highlighting some of the key changes under §1090 in our Focus on Fuels newsletter. If you have a particular topic upon which you would like to gain our perspective, please inquire with our fuels regulatory team.

In-Line blend waivers

Gasoline manufacturers currently operating under an in-line blending waiver approved under 40 CFR Part 80 have an opportunity to modify their approach when submitting a revised in-line blending waiver under 40 CFR Part 1090. As with many areas of one’s compliance program, taking a fresh look at the existing practices versus the requirements has proven beneficial time after time. Operational facilities continue to be challenged to transform and to reduce workload where possible but hesitate to consider opportunities in areas of safety or compliance. By levering our industry experience, we have been able to assist clients in assessing their approach to compliance while ensuring their compliance programs are not sacrificed. Our regulatory group is actively working with existing clients in revising their in-line blend waivers using this type of approach. Clients are finding the detail of information written into their existing waiver not only exceeds the regulatory requirements but adds an unnecessary cost burden to their operating cost. Are you ready to take a fresh look at your practices versus the requirements? TM&C Fuels Regulatory Practice has a wealth of experience spanning several decades in virtually all of the clean fuel programs affecting refiners and marketers. Throughout its history, TM&C has provided consultation on EPA and state fuel programs in essentially all aspects of compliance. TM&C publishes a monthly newsletter focused on a deeper dive into the current regulatory issues facing the industry. If you would like to be included on the distribution list, please visit our website: www.turnermason.com and send us a note under ‘Contact’ or feel welcome to give our regulatory compliance team a call at 214-754-0898.

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