## Chevron

September 1 0, 20 15

Mr. Christopher Grundler Director, Office of Transportation and Air Quality U.S. Environmental Protection Agency Mail Code 640 1 A 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 Maria Pica Karp Vice President and General Manager Chevron Government Affairs 60 0 13 th Street, NW Suite 600 Washington, DC 20 00 5 Tel 202 408 5800 Fax 202 408 5845 mpica@chevron.com

Re: Docket ID No. EPA-HQ-OAR- 2015-0111 "Standards for the Renewable Fuel Standard (RFS) Program for 2014,2015, and 2016; Proposed Rule"

Dear Mr

. Grundler;

In reviewing the docket for 2014, 2015 and 2016 RFS NPRM we noted that Protec Fuel misrepre s ented Chevron's policies in its comments on the proposed rulemaking. We are writing to correct the record.

In its comments, Protec Fuel mischaracteri z es a 20 11 communication from Chevron to its branded reseller customers, including it as an example of "actions taken by obligated parties to discourage growth of E 15 and E85 adoption " 1 and concluding that it "contradict[ s] what is being stated by obligated partie s , namely major oil companies." 2 We disagree with Protec Fuel's characterization as it is ultimately the decision of the independent retail outlet owner on what products to offer.

A copy of this 2011 communication from Chevron is attached as Exhibit A. In addition, Protec Fuel inaccurately claims in its comments that "Chevron Corp. prevents the selling of E 15 / E85 at all stations. " 3 This statement is incorrect, and we explain below why Protec Fuel's claim is wrong.

Under our long-standing policy and practice, the operators of Chevron® and Texaco® branded motor fuel retail outlets may sell, in addition to our branded products, motor fuels from a source other than Chevron
, including alternative or renewable fuels like E 15 and E85

. We only require that retailers do so in a way that ( 1) avoids consumer confusion over the source of the products sold and infringement of Chevron's trademark s , and (2) complies with Chevron's retail outlet image standards and applicable laws. Chevron provides written guidelines to help retailers implement non-Chevron product offerings at stations in our branded network. A copy of those guidelines is attached as Exhibit B. They state that "non-Chevron branded motor fuel s can al s o be sold in conjunction with Chevron branded fuels under the branded

1 Steve Walk
, Protec Fuel
, C omments to Docket ID No

. EPA-HQ-OAR-2015-0111, July 16
, 2015, page 6

. 2 Ibid
, page page 9

. 3 Ibid
, page 7

.Page 2

canopy when proper care is taken to clearly identify them as 'Not a Chevron Product' ." 4 The letter in Exhibit A simply serves as a reminder of this Chevron policy.

Chevron supports the responsible development of biofuels. The United States need s all sources of commercially viable energy and biofuels are an important resource

. Almost all of C hevron's gasoline now contains up to 10 percent ethanol and we have spent millions of dollars to enable ethanol blending at our motor fuel terminals. We have also been actively engaged in efforts to develop technologies for converting biomass into transportation fuels at commercial scale.

Thank you for allowing us to correct the record in this regard. Please add our response to the EPA docket referenced above. If you have any questions about these comments, please contact Bill Hornbach ( billhornbach @ chevron.com ; 925-842-3484) or Dave Sander ( davesander @ chevron.com ; 202-408-5853).

cc: Paul Machiele
, EPA Director of Fuels Programs, Assessment and Standards Division

4 Chevron Retail Image Guidelines, Section 12.2

### Exhibit A

To 

### Retailers and Marketers

From 

### Americas Products

Date 

### January 21
, 2011

Re 

### EPA Amends Partial Waiver for E15

Dear Retailers and Marketers:

T he EPA has amended the previously issued partial waiver for gasoline blended with up to 15 volume % ethanol (“E15”) to include its use in 2001 model year vehicles and newer

.
Chevron remains concerned that EPA’s decision to approve E15 was made prematurely based on limited or inadequate tes t data. Complete testing is the right thing to do for consumers, as use of E15 may jeopardize engine warranties and is necessary to determine what, if any, impact it will have on engines, retail infrastructure and the environment. Chevron supports the use of ethanol blended fuels
, like E10, that have been thoroughly tested , are approved for use by engine manufacturers and meet all laws and industry standards

.
EPA’s decision does not mandate E15’s use in the marketplace, and Chevron has no plans to offe r a Chevron or Texaco branded E15 product at this time. We will continue to monitor the ongoing research and government requirements and may offer this product at a later time.
As a reminder, marketers and retailers may not in any way adulterate motor fuel sold under Chevron’s trademarks . This includes blending ethanol of any concentration into Chevron or Texaco branded gasoline unless expressly authorized by Chevron (or unless an applicable state law requires Chevron to allow ethanol blending). Unsanctioned ethanol blending would constitute a breach of your supply contract with Chevron and violate trademark laws . In addition , any Retailer or Marketer that engages in unauthorized ethanol blending will bear all liability associated with the blend ed products.
Please contact you Business Consultant or the Retail Marketing Center at 1

- 877

- 243

- 8457 should you have any questions.

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