July 27, 2015

Via Electronic Filing

The Honorable Gina McCa rthy Christopher Grundler

Office of the Administrator Director U.S. Environmental Protection Agency Office of Transportation and Air Quality 1200 Pennsylvania Avenue, NW Asst. Ad ministrator for Air and Radiation Room 3000 U.S. Environmental Protection Agency Washington, D.C. 20460 1200 Pennsylvania Avenue, NW

Room 6420 Washington, D.C. 20460

RE: Proposed Rule to Approve Georgi a State Improvement Plan Revisions,

Docket No.: EPA-R04-O AR-2015-0161, FRL-9929-47-Region 4

Dear Administrator McCart hy and Director Grundler,

On behalf of the Society of Independent Gasoline Marketers of America (“SIGMA”) and the National Association of Convenience Stores (“ NACS”), I write to expr ess support – with one qualifier discussed below – for the Environmenta l Protection Agency’s (“EPA’” or “Agency”) plans to approve the State of Georgia’s February 5, 2015, Stat e Implementation Plan (“SIP”)

revision.

Specifically, SIGMA and NACS support EPA’s pl ans to approve Geor gia’s SIP revision, which would remove Georgia’s Gasoline Marke ting Rule 391-3-1-.02(2)( bbb) – the so-called Georgia Fuel Rule – that curren tly requires the sale of low sulf ur 7.0 psi Reid Vapor Pressure (“RVP”) gasoline in the 45-county Georgi a Fuel Area during the high ozone season. The revision would permit the sale of 7.8 psi RVP ga soline in the Atlanta 1- Hour Ozone Area and 9.0 psi RVP fuel for the remainder of the Georgia Fuel Area.

While SIGMA and NACS support the Agency’s plan to approve and implement this change, it would be a serious mi stake for EPA to approve and implement this modification in the middle of the summer fuel season. Currently, there is a 17 cents spread between low sulfur 7.0 psi RVP gasoline and 9.0 psi RV P gasoline; and a 10 cents spread between low sulfur 7.0 psi RVP gasoline and 7.8 psi RVP gasoline. Should EP A approve the Georgia revised SIP and make it immediately effective during the high ozone season, it would subject fuel marketers and retailers, who have complied res ponsibly with the Georgia Fuel Rule and EPA’s Clean Air Act mandate, to significant and highly damaging financial losses that will run into the many millions. R. Timothy Columbus

202 429 6222

1330 Connecticut Avenue, NW
Washington, DC 20036-1795

202 429 3000 main

www.steptoe.comEssentially, if EPA were to approve the Ge orgia revised SIP and make it immediately effective, i.e. without providing fuel marketers a nd retailers enough lag time to adjust their fuel stocks; the Agency will damage its reputation with the fuel industry for absolutely no environmental gain. EPA should always remember that in a place such as Georgia, which is supplied by pipeline, it is desirable to have at le ast 90 days between a fuel specification change and implementation in order to permit the fuel supply distribution system to make proper arrangements. This is necessary because the cy cle to acquire, schedule and ship fuel on a pipeline generally takes between 30-60 days . Therefore, although SIGMA and NACS support EPA’s plan to approve Georgia’ s revised SIP, SIGMA and NACS respectfully request that EPA approve and implement the Georgia revised SIP in a manner that will not damage the fuel marketing and retail industry and ultimately penalize those who have complied with the Agency’s environmental mandate.

SIGMA and NACS appreciates the opportunity to comment on this Proposed Rule.

Please do not hesitate to contact me if either association may provide any assistance to the Agency in this critical rulemaking.

Respectfully,

R. Timothy Columbus

General Counsel

SIGMA and NACS

SIGMA represents approximately 260 independent chai n retailers and marketers of motor fuel. SIGMA members represent signifi cant diversity within the i ndustry. While 92 percent are involved in gasoline retailing, 66 percent are involved in wholesaling, 36 percent transport product, 25 percent have bulk plant operations, and 15 percent operate terminals Member retail outlets come in many forms including travel plazas , traditional “gas stations,” convenience stores with gas pumps, cardlocks, and unattended p ublic fueling locations. Some members sell gasoline over the Internet, many are involved in fleet cards, and a few are leaders in the mobile refueling movement.

NACS is an international trade association representing more than 2,200 retail and 1,800 supplier company members. NACS member co mpanies do business in nearly 50 countries worldwide, with the majority of members base d in the United States. The U.S. convenience store industry, with approximately 1.8 million employees and 151,000 stores across the United States, posts nearly $700 billi on in total sales, and accounts fo r approximately $500 billion in motor fuel sales alone each year.