### Assessment of Reasonable Progress for Regi onal Haze in MANE-VU Class I Areas:

Methodology for Source Selection, Evaluati on of Control Options and Four Factor

Analysis

ADDENDUM FOR RESIDUAL OIL

April, 2011

INTRODUCTION

In July of 2007, the Mid-Atlantic/Northeast Vi sibility Union (MANE-VU) released a report

entitled “Assessment of Reasonable Progress fo r Regional Haze in MANE-VU Class I Areas:

Methodology for Source Selection, Evaluation of C ontrol Options and Four Factor Analysis.”

The purpose of this report was to analyze the economic and environmental impacts of potential

control measures that could be implemented by MANE-VU States to reduce emissions from

specific source categories in order to make r easonable progress toward meeting visibility

improvement goals.

One such control measure is to reduce the sulfur content of home heating and residual oils. The

MANE-VU states have signed a Statement of the Mid-Atlantic /Northeast Visibility Union

(MANE-VU) Concerning a Course of Action Within MANE-VU Toward Assuring Reasonable

Progress that outlines a strategy to re duce the sulfur content of home heating and residual oils.

The 2007 “Assessment of Reasonable Progress” repor t evaluated home heating oil as one of its

sectors. Although the use of low sulfur residual oil was identified as an option for reducing SO2

emissions at electricity generating units (EGUs) and industrial, commercial and institutional

(ICI) boilers, it was not analyzed as a stand-alone strategy. This addendum is intended to provide

that information by analyzing the economic and environmental impacts of reducing sulfur in

residual oil, with respect to the four factors listed in the Clea n Air Act (Section 169A). The four

factors are: cost of compliance, time necessa ry for compliance, energy and non-air impacts, and

remaining useful life of the sources. This document primarily focuse s on reducing the sulfur

content of No. 6 residual oil. Information on redu cing the sulfur content of No. 4 residual oil is

presented wherever data were available.

BACKGROUND

Residual oil is also known as No. 6 fuel oil. No. 4 oil, sometimes also called a residual oil, is a

blend of No. 6 and No. 2 (distillate or diesel) fuel oils. No. 6 fuel oil is commonly used in

electric generating units, industr ial, commercial and institutio nal boilers. No. 4 fuel oil is

commonly used in large residential facilities.

The Department of Energy - Energy Informati on Administration (EIA) provides information on

the oil consumption by district (Petroleum Administration for De fense Districts or PADD) and

sector. MANE-VU states are located in P ADD1A (CT, ME, MA, NH, RI, VT) and PADD 1B

(DE, DC, MD, NJ, NY, PA). Figures 1 presents total residual oil cons umption by year for the

years 2000-2009. Figure 2 presents average resi dual oil consumption by sector for 2006-2009

PADD1B consumes more residual oil than PADD1A; this is especially true for residual oil used

for vessel bunkering. Residual oil used for vesse l bunkering is combusted by the vessel in which

1

### it is bunkered. For both districts, there is significant residual oil consumption by the electric

power sector (43% of total for PADD1A, 21% of total for PADD1B).

Figure 1: Total Residual Oil Consumption by Year

Figure 2: Average Annual Residual Oil Consumption by S ector (2006-2009)*

*The most recent four years available.

Sulfur in Residual Oil

SO 2 

### emissions are proportional to fuel oil su lfur content. It is uncommon, although not

infeasible, to control SO 2 

### emissions from oil-fired boilers us ing control devices. Therefore, the

2

### most common and cost-effective method for controlling SO 2 

### emissions from residual oil in the

U.S. is by lowering the amount of sulfur in the fuel.

Currently, the sulfur limits in residual oil in the MANE-VU stat es vary between 0.3 – 2.8 percent

(in this document, all sulfur conten t percentages refer to percent sulfur by weight). Many states

have different fuel sulfur limits for different areas, depending upon popula tion or region; Table 1

presents the range of fuel sulf ur limits allowed by each state.

Table 1: MANE-VU State Sulfu r Limits for Residual Oil (P ercent Sulfur by Weight)*

State Maximum Sulfur Limit

No. 4 Maximum Sulfur Limit

No. 6 Data Source

Connecticut 0.48% 0.74% Wendy Jacobs

Delaware 0.5 – 2.0% 0.5 – 2.0% Jack Sipple

Maine 0.7% 1.0 - 2.0% MV 2018 Inventory

Maryland 1.0 – 2.0% 1.0 – 2.0% Ralph Hall

Massachusetts 0.5 - 2.2% 0.5 - 2.2% 310 CMR 7.05

New Hampshire 1.00% 2.00 – 2.20% Env-A 1604

New Jersey 0.3 – 2.0% 0.3 – 2.0% N.J.A.C. 7:27-9

New York 0.30 – 1.50% 0.30 – 1.50% Mike Jennings

Pennsylvania

(Philadelphia) 0.3 – 2.8%

(0.3%) 0.5 – 2.8%

(0.5%) 25 PA Code 123.22

(3-207(1)(a))

Rhode Island 0.7% 1.0% MV 2018 Inventory

Vermont 2.0% 2.0% VT APCR 5-221

Washington, D.C. 0.7% 1.0% MV 2018 Inventory

* Sulfur limits based on rules in effect as of May 2010.



### The MANE-VU states signed a Statement of the Mid-Atlantic /Northeast Visibility Union

(MANE-VU) Concerning a Course of Action Within MANE-VU Toward Assuring Reasonable

Progress which outlines a strategy to re duce the sulfur content of ho me heating and residual oils.

For No. 4 residual oil, sulfur is to be reduced to 0.25 – 0.5% sulfur by weight. For No. 6 residual

oil, sulfur is to be reduced to 0.3 – 0.5% sulfur by weight. These limits will apply no later than

2018. It is estimated that this st rategy will reduce sulfur dioxide emissions from residual oils by

up to 50%.

Several MANE-VU states are in the process of passing or amending regulations to implement the

limits in the MANE-VU Statement, including New Jersey and Maine. New Jersey’s amendment

to N.J.A.C. 7:27-9 was adopted and effectiv e on September 20, 2010, which lowers the sulfur

content in 2014 for No. 6 residua l oil to 0.3% – 0.5% and for No. 4 residual oil to 0.25%.

Maine’s legislature passed a bill mandating lower sulfur fuel st andards in April, 2010. This bill

requires 0.5% sulfur by weight in residual fuel oils by Janu ary 1, 2018. The Maine Department

of Environmental Protection has been directed to adopt rules allowing equivalent alternative

3

### sulfur reduction strategies for licensed sources. Additional requirements include establishing an

advisory committee and conducting a fuel oil supply study in 2014.

Residual Oil Supply

The following table illustra tes the average total annual stocks fo r residual oils of varying sulfur

content for the United States and for PADD1 for the years 2006 – 2009 (in thousand barrels ±

standard deviation). Also shown is the percentage of U.S. st ocks represented by the PADD1.

All data were gathered from the EIA web site on February 28, 2011.

Table 1: Average Annual Residual Oil Stocks:

Average ± Standard Deviation for the Years 2006 - 2009

Residual

< 0.31% S Residual

0.31-1.00% S Residual

> 1.00% S All Residual

(Total)



### U.S. (Total) 5,190 ± 1333 12,214 ± 1,635 21,292 ± 928 38,696 ± 2,777

East Coast

(PADD1) 3,571 ± 763 6,516 ± 1,594 4,917 ± 454 15,004 ± 2,523

PADD1 Portion

of U.S. 70% ± 10% 53% ± 6% 23% ± 1% 39% ± 4%

The information presented in Table 2 indicates that a large amount of lower sulfur residual oil is

available on the East Coast and thus , presumably, in the Northeast.

FOUR FACTOR ANALYSIS OF POTENTIAL CONTROL SCENARIOS FOR

EMISSIONS FROM HEATING OIL COMBUSTION

Cost of Compliance

Residual oils with varying sulfur contents, including low sulfur cont ent, are currently available in

the Northeast fuel oil markets. Many Mid-Atlan tic and Northeast states require low sulfur

residual oil (e.g., 0.3% - 0.5%) in certain areas, a nd thus there is an existing market for low

sulfur residual oil. In add ition, the MARPOL Annex VI fuel sulfur limits specify 1.0% for

marine vessels in Emission Control Areas (which includes the U.S. coast) in 2010 and 0.1% in

2015, adding to the market for low sulfur residual oil. EIA provides information on the cost of

residual fuel oil by district and by sulfur content. The EIA sulfur categories are ≤ 1.00% and >

1.00% sulfur by weight.

The following table illustrates the recent price differences between ≤ 1.00% and > 1.00% sulfur

residual oils for the U.S., PADD 1A (CT, ME , MA, NH, RI, VT) and PADD 1B (DE, DC, MD,

NJ, NY, PA). Monthly price averages were av eraged to compute annual prices and price

differentials in cents per gallon for the years 2006 – 2009. This data was then averaged and is

presented in Table 3 below, along with the standard deviations. All data were gathered from the

EIA web site on February 28, 2011 and all price comparisons are before taxes.

4

### Table 3: Price Ranges and Price Different ials (Minimum, Average, and Maximum) by

Sulfur Content of No. 6 Residua l Oil for the Years 2006 - 2009

No. 6 Residual Price

> 1.00% No. 6 Residual Price

≤ 1.00% Price Differential

Cents per Gallon, excluding taxes

Min. Avg. Max. Min. Avg. Max. Min. Avg. Max.

U.S. 117.4 143.8 189.9 132.2 161.2 215.7 13.2 18.8 31.1

PADD1A 118.2 147.1 193.9 127.1 160.7 206.7 8.9 9.9 12.9

PADD1B 117.7 142.9 186.9 136.5 168.7 222.9 19.5 26.2 39.2

NYC

Metro 117.9 141.5 186.0 141.4 164.7 202.9 23.5 23.2 16.9

As can be seen in Table 3, the price differential between No. 6 residual oil ≤ 1.00% and > 1.00%

sulfur is less than the U.S. average for PADD1 A but more than the U.S. average for PADD1B.

Lower sulfur No. 6 residual oil ranges from 8.9 to 39.2 cents per gallon more than higher sulfur

No. 6 residual oil.

This additional expense, however, is expected to be offset by re duced maintenance costs with the

use of lower sulfur No. 6 oil sim ilar to the reductions in maintena nce costs that occurs when the

sulfur content of No. 2 oil is re duced. Low sulfur oil is cleaner burning and em its less particulate

matter than higher sulfur oil; this reduces the rate of fouling of heating units substantially and

permits longer time intervals between cleanings. For example, when the existing oil sulfur

content for No. 2 distillate oil is 2,000 ppm and 500 ppm sulfur is substitute d, the service interval

can be extended by a factor of three or more (e .g., cleaning at three year intervals rather than

annually) (NESCAUM 2005). The decreased deposits w ould also enable a more efficient transfer

of heat, thereby reducing the fuel usage. Similarly, there are substa ntial potential cost savings for

switching to lower su lfur residual oil.

Under the MANE-VU low sulfur residual oil strategy, refineries would need to bring additional

lower sulfur residual oil to ma rket by 2014. However, due to th is long lead time and the new

MARPOL Annex VI marine vessel regulations that require sulfur conten t reductions in 2010 and

2015, the cost to produce residual oil that co mplies should not be too onerous on refineries.

Time Necessary for Compliance

Refiners in the United States are already produc ing low sulfur residual oil. Existing boilers do

not need to be retrofitted or modified to com bust lower sulfur residual oil. Consequently, the

time necessary for compliance does not hinge on replacing any equipment. Many residual-oil

burning facilities, however, have large oil stocks on-site. These stocks may take several years to

5

### be completely depleted and mixing between the old, higher sulfur residu al oil stock and new,

lower sulfur residual oil is likely to occur. Therefore, compliance may best be monitored by

ensuring the purchase and/or sale, rather than the combustion, of lower sulfur residual oil.

Energy and Non-Air Impacts

Reducing the sulfur contents of residual oil has a variety of beneficial consequences for residual

oil-fired boilers. Low sulfur residual oil is cl eaner burning and emits less particulate matter than

higher sulfur oil; this reduces th e rate of fouling of heating units substantially and permits longer

time intervals between cleanings. The decreased deposits would also enable a more efficient

transfer of heat, there by reducing the fuel usage. Both of these factors result in cost-savings,

partially offsetting the higher costs of lo wer sulfur residual oil described above.

Remaining Useful Life of the Source

Residual oil-fired boilers have finite life times, but they do not need to be replaced to burn lower

sulfur fuel. In fact, burning a lower sulfur resi dual oil may increase thei r lifespan. Lower sulfur

oils cause less corrosion in the heating system because internal condensation produces less

sulfuric acid than higher sulfur oil.

6

### 7 REFERENCES

NESCAUM, 2005. Low Sulfur Heating Oil in the Northeast States: An Overview of Benefits,

Costs and Implementation Issues

.

US Energy Information Administration, 2010. In formation downloaded from the World Wide

Web on February 28, 2011.at: http://tonto.eia.doe.gov/dnav/pe t/pet_pri_dist_dcu_R1X_m.htm

### APPENDIX

1TextSales of Residual Fuel Oil by End Use by AreaData from U.S. Department of Energy,Energy Information Administration websitehttp://tonto.eia.gov/dnav/pet/Annual Residual Fuel Oil Stocks by Sales Type, by SulfurPetroleum Marketing Monthly, February 2011TotalConsumption06-09 Avg06-09 StdDev2000200120022003200420052006200720082009U.S.9,751,0211,298,21213,210,93513,609,37910,361,61511,412,83311,794,36213,442,16510,273,63110,706,4798,272,9526,705,631PADD15,007,307925,4867,526,9958,075,1166,185,9827,489,1877,757,7709,016,8435,555,9115,527,2353,938,7762,920,034PADD1A570,678133,312986,3731,000,134738,6491,390,2391,238,0441,361,581676,210614,965420,858274,660PADD1B2,258,283303,8402,928,1533,165,2152,357,6332,915,4772,826,6043,876,9202,316,3262,528,9151,929,6081,607,207OTR Total2,828,961421,2413,914,5264,165,3493,096,2824,305,7164,064,6485,238,5012,992,5363,143,8802,350,4661,881,867Consumption bySector - PADD1A06-09 Avg06-09 StdDev2000200120022003200420052006200720082009Commercial124,2348,664114,15686,14988,501150,209192,682208,830102,50588,16186,91564,826Industrial266,80365,901355,553474,236319,056224,662233,570251,167239,005194,642109,340106,980Electric Power510,66352,483458,707390,256277,9571,013,906808,988837,753286,245311,508210,64551,213Vessel Bunkering32,42617,82955,43646,83051,4455212,07858,37346,10018,02913,02250,075Other2,2139072,5212,6631,6909417265,4582,3552,6259361,566Total936,339133,312986,3731,000,134738,6491,390,2391,238,0441,361,581676,210614,965420,858274,660Consumption bySector - PADD1B06-09 Avg06-09 StdDev2000200120022003200420052006200720082009Commercial435,11740,556495,051485,510433,113527,840508,662439,849346,426380,176299,425338,089Industrial179,12726,690226,604240,402145,183181,283189,255176,101173,749157,892121,67871,617Electric Power979,374291,668880,3521,304,358683,0711,261,7431,121,1642,069,711612,111715,339166,514238,261Vessel Bunkering1,118,16685,4731,243,3751,038,4441,036,387892,057968,4601,152,5561,156,9891,247,3891,327,839938,273Other48,7557,77482,77196,50159,87952,55439,06338,70327,05128,11914,15220,967Total2,760,539303,8402,928,1533,165,2152,357,6332,915,4772,826,6043,876,9202,316,3262,528,9151,929,6081,607,2071

### Text

06-09 Avg. Consumption by Sector and Area PADD1A PADD1B

Commercial 85,602 341,029

Industrial 162,492 131,234

Electric Power 214,903 433,056

Vessel Bunkering 31,807 1,167,623

Other 1,871 22,572

06-09 Avg. Consumption by S ector as % PADD1A PADD1B

Commercial 17% 16%

Industrial 33% 6%

Electric Power 43% 21%

Vessel Bunkering 6% 56%

Other 0% 1%



### 1Fuel Oil Price Comparison Charts DRAFT (02/28/11)

Data from U.S. Department of Energy, E nergy Information Administration website

http://tonto.eia.gov/dnav/pet/

Residual Fuel Oil Price by Sales Type, by Sulfur, Sales to End

Users

Petroleum Marketing Monthly, February 2011

PADD 1A (New England) = CT, ME, MA, NH, RI & VT

New England PADD 1A Residual Fuel Oil Retail Prices by All Sellers (Cents per Gallon Excluding

Taxes)

Residual >1%S Residual ≤ 1%S Differential % Difference

(¢/gal) (¢/gal) (¢/gal)

Jan-02 45.6 58.9 13.3 29.2%

Feb-02 47.0 55.3 8.3 17.7%

Mar-02 47.4 57.6 10.2 21.5%

Apr-02 54.5 61.9 7.4 13.6%

May-02 57.1 61.6 4.5 7.9%

Jun-02 57.1 61.2 4.1 7.2%

Jul-02 56.7 63.8 7.1 12.5%

Aug-02 59.5 61.7 2.2 3.7%

Sep-02 63.1 67.7 4.6 7.3%

Oct-02 68.1 70.7 2.6 3.8%

Nov-02 58.6 66.4 7.8 13.3%

Dec-02 63.2 74.0 10.8 17.1%

12 month Average 56.5 63.4 6.9 12.9%

Jan-06 117.1 126.5 9.4 8.0%

Feb-06 118.1 131.4 13.3 11.3%

Mar-06 120.7 129.8 9.1 7.5%

Apr-06 124.2 129.6 5.4 4.3%

May-06 125.1 131.1 6 4.8%

Jun-06 121.8 129 7.2 5.9%

Jul-06 120.0 128.2 8.2 6.8%

Aug-06 124.9 138 13.1 10.5%

Sep-06 109.0 120.5 11.5 10.6%

Oct-06 110.4 115.3 4.9 4.4%

Nov-06 112.8 122.3 9.5 8.4%

Dec-06 113.8 123.3 9.5 8.3%

12 month Average 118.2 127.1 8.9 7.6%

Jan-07 102.9 120.2 17.3 16.8%

Feb-07 109.8 128 18.2 16.6%

Mar-07 112.5 125.8 13.3 11.8%

Apr-07 118.0 126.6 8.6 7.3%

May-07 127.3 134.7 7.4 5.8%

Jun-07 128.3 140.1 11.8 9.2%

Jul-07 140.9 141.2 0.3 0.2%

Aug-07 140.5 146.4 5.9 4.2%

Sep-07 144.8 149.4 4.6 3.2%

Oct-07 156.9 167.2 10.3 6.6%

Nov-07 177.8 180.0 2.2 1.2%

Dec-07 176.8 185.1 8.34 4.7%

12 month Average 136.4 145.4 9.0 7.3%



### 1

### 2 Jan-08 182.2 197 14.8 8.1%

Feb-08 175.6 185.1 9.5 5.4%

Mar-08 181.5 187.9 6.4 3.5%

Apr-08 193.9 204.2 10.3 5.3%

May-08 213.4 222.8 9.4 4.4%

Jun-08 234.8 257.7 22.9 9.8%

Jul-08 267.7 278.1 10.4 3.9%

Aug-08 244.3 256.0 11.7 4.8%

Sep-08 215.0 232.6 17.6 8.2%

Oct-08 173.5 183.2 9.7 5.6%

Nov-08 131.5 157.5 26 19.8%

Dec-08 112.9 118.6 5.7 5.0%

12 month Average 193.9 206.7 12.9 7.0%

Jan-09 116.0 135.4 19.4 16.7%

Feb-09 122.7 128.2 5.5 4.5%

Mar-09 118.1 131.3 13.2 11.2%

Apr-09 119.3 NA 0.0%

May-09 126.0 156.6

Jun-09 167.7 172.0 4.3 2.6%

Jul-09 NA 167.4

Aug-09 177.6 177.6 0.0 0.0%

Sep-09 NA 175.1

Oct-09 173.6 185.0 11.4 6.6%

Nov-09 W 185.4

Dec-09 W 187.6

12 month Average 140.1 163.8 9.0 5.9%

Conclusion: Assume 7.5 cents per gall on increase in cost for switching from greater than 1% Sulfur Residual Oil

to less than 1% Sulfur Residual Oil.

### Text

Fuel Oil Price Comparison Charts DRAFT (02/28/11)

Data from U.S. Department of Energy, Energy Informat ion Administration website h ttp://tonto.eia.gov/dnav/pet/

Residual Fuel Oil Price by Sales Type, by Sulfur, Sales to End

Users

Petroleum Marketing Monthly, February 2011

PADD 1B (Central Atlantic) = DE, DC, MD, NJ, NY & PA

Central Atlantic PADD 1B Residual Fuel Oil Retail Prices by All Sellers (Cents per Gallon Excluding

Taxes)

Residual >1%S Residual ≤ 1%S Differential % Difference

(¢/gal) (¢/gal) (¢/gal)

Jan-02 40 53.7 13.7 34.3%

Feb-02 40.0 51.7 11.7 29.3%

Mar-02 48.6 55.5 6.9 14.2%

Apr-02 55.3 61.6 6.3 11.4%

May-02 55.7 66.2 10.5 18.9%

Jun-02 55 59.4 4.4 8.0%

Jul-02 54.9 61.3 6.4 11.7%

Aug-02 58.9 66 7.1 12.1%

Sep-02 61.3 66 4.7 7.7%

Oct-02 63.6 70.4 6.8 10.7%

Nov-02 53.3 70.6 17.3 32.5%

Dec-02 57.9 75.7 17.8 30.7%

12 month Average 53.7 63.2 9.5 18.4%

Jan-06 117.6 139.8 22.2 18.9%

Feb-06 118.9 140.4 21.5 18.1%

Mar-06 120.2 136.9 16.7 13.9%

Apr-06 122.8 142 19.2 15.6%

May-06 126.1 NA

Jun-06 124.6 141.9 17.3 13.9%

Jul-06 123.3 144.6 21.3 17.3%

Aug-06 127.1 137.5 10.4 8.2%

Sep-06 113.0 127.5 14.5 12.8%

Oct-06 105.0 129.9 24.9 23.7%

Nov-06 107.1 132.6 25.5 23.8%

Dec-06 106.7 128.3 21.6 20.2%

12 month Average 117.7 136.5 19.6 16.9%

Jan-07 98.0 126.6 28.6 29.2%

Feb-07 102.7 129.8 27.1 26.4%

Mar-07 108.1 132.8 24.7 22.8%

Apr-07 116.0 134.6 18.6 16.0%

May-07 130.1 139.6 9.5 7.3%

Jun-07 132.1 143.9 11.8 8.9%

Jul-07 138.0 151.3 13.3 9.6%

Aug-07 141.7 153.3 11.6 8.2%

Sep-07 141.3 157.8 16.5 11.7%

Oct-07 155.9 174.5 18.6 11.9%

Nov-07 182.9 206.4 23.5 12.8%

Dec-07 179.7 210.1 30.4 16.9%

12 month Average 135.5 155.1 19.5 15.2%



### 1

### 2 Jan-08 178.6 215.8 37.2 20.8%

Feb-08 172.3 208.8 36.5 21.2%

Mar-08 183.1 223 39.9 21.8%

Apr-08 186.9 230.4 43.5 23.3%

May-08 203.5 247.1 43.6 21.4%

Jun-08 227.6 286.8 59.2 26.0%

Jul-08 264.2 303.1 38.9 14.7%

Aug-08 247.2 282.5 35.3 14.3%

Sep-08 221.5 NA

Oct-08 171.7 185.9 14.2 8.3%

Nov-08 100.8 146.5 45.7 45.3%

Dec-08 84.9 122.0 37.1 43.7%

12 month Average 186.9 222.9 39.2 23.7%

Jan-09 88.7 122.6 33.9 38.2%

Feb-09 96.5 132.3 35.8 37.1%

Mar-09 94.6 144.2 49.6 52.4%

Apr-09 102.1 NA

May-09 118.5 142.0 23.5 19.8%

Jun-09 140.3 158.9 18.6 13.3%

Jul-09 140.0 153.1 13.1 9.4%

Aug-09 152.1 172.0 19.9 13.1%

Sep-09 152.1 168.3 16.2 10.7%

Oct-09 156.2 184.9 28.7 18.4%

Nov-09 168.6 194.2 25.6 15.2%

Dec-09 166.8 192.4 25.6 15.3%

12 month Average 131.4 160.4 26.4 22.1%

Conclusion: Assume 7.5 cents per gall on increase in cost for switching from greater than 1% Sulfur Residual Oil

to less than 1% Sulfur Residual Oil.

### Text

Fuel Oil Price Comparison Charts DRAFT (2/28/11)

Data from U.S. Department of Energy, E nergy Information Administration website

http://tonto.eia.gov/dnav/pet/

U.S. Residual Fuel Oil Retail Prices by All Sellers (Cents per Gallon Excluding Taxes)

Residual >1%S Residual ≤ 1%S Differential %

Difference

Jan-09 95.1 119.2 24.1 25.3%

Feb-09 97.8 124.3 26.5 27.1%

Mar-09 95.2 121.8 26.6 27.9%

Apr-09 100.7 119.3 18.6 18.5%

May-09 121.0 123.9 2.9 2.4%

Jun-09 143.4 145.7 2.3 1.6%

Jul-09 138.4 149.5 11.1 8.0%

Aug-09 152.2 164.2 12.0 7.9%

Sep-09 151.6 168.4 16.8 11.1%

Oct-09 153.1 173.4 20.3 13.3%

Nov-09 166.0 175.9 9.9 6.0%

Dec-09 165.7 183.5 17.8 10.7%

12 month Average 131.7 147.4 15.7 13.3%

Conclusion: Assume 16 cents per gallon increase in cost for switching from greater than 1% Sulfur Residual Oil

to less than 1% Sulfur Residual Oil.

PADD1A Residual Fuel Oil Retail Prices by All Sellers (Cents per Gallon Excluding Taxes)

Residual >1%S Residual ≤ 1%S Differential %

Difference

Jan-09 116.0 135.4 19.4 16.7%

Feb-09 122.7 128.2 5.5 4.5%

Mar-09 118.1 131.3 13.2 11.2%

Apr-09 119.3 NA

May-09 126.0 156.6 30.6 24.3%

Jun-09 167.7 172.0 4.3 2.6%

Jul-09 NA 167.4

Aug-09 177.6 177.6 0.0 0.0%

Sep-09 NA 175.1

Oct-09 173.6 185.0 11.4 6.6%

Nov-09 W 185.4

Dec-09 W 187.6

12 month Average 140.1 163.8 12.1 8.2%



### 1

### Text

Fuel Oil Price Comparison Charts DRAFT (6/11/08)

Data from U.S. Department of Energy, E nergy Information Administration website

http://tonto.eia.gov/dnav/pet/

PADD1B Residual Fuel Oil Retail Prices by All Sellers (Cents per Gallon Excluding Taxes)

Residual >1%S Residual ≤ 1%S Differential % Difference

Jan-09 88.7 122.6 33.9 38.2%

Feb-09 96.5 132.3 35.8 37.1%

Mar-09 94.6 144.2 49.6 52.4%

Apr-09 102.1 NA

May-09 118.5 142.0 23.5 19.8%

Jun-09 140.3 158.9 18.6 13.3%

Jul-09 140.0 153.1 13.1 9.4%

Aug-09 152.1 172.0 19.9 13.1%

Sep-09 152.1 168.3 16.2 10.7%

Oct-09 156.2 184.9 28.7 18.4%

Nov-09 168.6 194.2 25.6 15.2%

Dec-09 166.8 192.4 25.6 15.3%

12 month Average 131.4 160.4 26.4 22.1%



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Fuel Oil Price Comparison Charts DRAFT (02/28/11)

Data from U.S. Department of Energy, E nergy Information Administration website

http://tonto.eia.gov/dnav/pet/

Residual Fuel Oil Price by Sales Type, by Sulfur, Sales to End Users

Petroleum Marketing Monthly, February 2011

Residual Fuel Oil Retail Prices by All Sellers: Yearly Averages

(Cents per Gallon Excluding Taxes)

U.S.

Year U.S. Residual >1%S U.S. Residual ≤ 1%S Differential % Difference

2006 117.4 132.2 14.7 12.7%

2007 136.1 149.3 13.2 10.2%

2008 189.9 215.7 31.3 19.7%

2009 131.7 147.4 15.7 13.3%

06-09 Avg 143.8 161.2 18.8 14.0%

StdDev 31.8 37.2 8.4 4.0%

PADD1A

Year PADD1A Residual >1%S PADD1A Residual ≤ 1%S Differential % Difference

2006 118.2 127.1 8.9 7.6%

2007 136.4 145.4 9.0 7.3%

2008 193.9 206.7 12.9 7.0%

2009 140.1 163.8 9.0 5.9%

06-09 Avg 147.1 160.7 9.9 6.9%

StdDev 32.6 34.1 1.9 0.7%

PADD1B

Year PADD1B Residual >1%S PADD1B Residual ≤ 1%S Differential % Difference

2006 117.7 136.5 19.6 16.9%

2007 135.5 155.1 19.5 15.2%

2008 186.9 222.9 39.2 23.7%

2009 131.4 160.4 26.4 22.1%

06-09 Avg 142.9 168.7 26.2 19.5%

StdDev 30.3 37.5 9.3 4.1%



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### 2TextFuel Oil Stocks (05/03/10)Data from U.S. Department of Energy,Energy Information Administration website http://tonto.eia.gov/dnav/pet/Annual Residual Fuel Oil Stocks by Sales Type, by SulfurPetroleum Marketing Monthly, February 2011Annual East Coast (PADD 1) -Thousand Barrels200020012002200320042005200620072008200906-09 Avg06-08 StdDevResidual < 0.31%3,1154,0092,5383,8614,1284,3834,5953,6043,3062,7803,835675Residual 0.31-1.00%6,4379,0735,7426,7457,3535,8718,7716,5095,4655,3176,9151,690Residual > 1.00%4,1084,6754,2475,1745,5394,2605,3014,5604,4905,3174,784449Total13,66017,75712,52715,78017,02014,51418,66714,67313,26113,41415,5342,804Annual U.S. - Thousand Barrels200020012002200320042005200620072008200906-09 Avg06-08 StdDevResidual < 0.31%5,2687,5944,7325,1825,6665,9316,3815,7665,3123,3025,820537Residual 0.31-1.00%12,04515,1469,46613,11114,46711,64914,45812,22610,61511,55812,4331,930Residual > 1.00%18,88018,30616,90519,25521,94519,63221,47421,32420,06122,30820,953776Total36,19341,04631,10337,54842,07837,21242,31339,31635,98837,16839,2063,164PADD1 as % of U.S.200020012002200320042005200620072008200906-09 Avg06-08 StdDevResidual < 0.31%59.1%52.8%53.6%74.5%72.9%73.9%72.0%62.5%62.2%84.2%66%6%Residual 0.31-1.00%53.4%59.9%60.7%51.4%50.8%50.4%60.7%53.2%51.5%46.0%55%5%Residual > 1.00%21.8%25.5%25.1%26.9%25.2%21.7%24.7%21.4%22.4%23.8%23%2%Total37.7%43.3%40.3%42.0%40.4%39.0%44.1%37.3%36.8%36.1%39%4%Pricing by <= 1.00% or >1.00%1