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

2. 2 Reporting - Topics Covered zRegistration zBaseline Applications zFirst year deadlines zAnnual Report Information Required zAnnual Report Issues zOther Important Deadlines zGuidance on Annual Reports zElectronic Reporting Issues

3. 3 Registration zRFG/Antidumping Registrations are sufficient (new registrations minimal) zMay 10, 2000: all early credit generators must be registered zNovember 1, 2003: all refiner/importer registrations due zFuture refineries: due 3 months before production

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

5. Important Deadlines at Beginning of Sulfur Program

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

7. 7 Baseline Submissions zRFG vendor software accommodates spreadsheet format. zInformation must include all appropriate gasoline batches from ‘97 & ‘98 including volumes and sulfur content. zOnly 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. 9 What do annual reports track? zCredit/allotment generation and use (accounting of credit/allotment balance) zCompliance with corporate pool average zCompliance with refinery standard zTransfer of credits/allotments zConversion 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. Batch numbers Date batch produced Batch volume Sulfur content of the batch Additionally, for importers of sulfur FRGAS: Annual Reports (continued) 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. 12 Annual Report Issues zSeparate company/facility report zNew report formats as program changes? yCredit Generation yAllotment generation/use yCorporate average standard ySmall refinery timing allowances zTracking of allotment/credit conversions zDiscounting credits

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

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

16. 16 Sulfur Reporting zQuestions? zCan email comments to: zDave Kortum zkortum.dave@epa.gov