To Members:
Please see the attached presentation. Importantly, generally fuel mandates would have no chance of passing in Colorado, outside of Clean Air Act requirements pertaining to ozone. That said, in the new political environment, they are seen as viable policy options depending on the outcome. The attached presentation weighs heavily on carbon and VOC reduction benefits and reviews the following policy proposals as potential for Colorado. Senator Fenberg is exploring possible options because of this presentation.
1. Clean Fuel Program Tax-Based Incentives –
2. Tax Credit for Sales/Blending/Usage –
3. Production Tax Credit –
4. Fuel Tax Differential for Higher Blends
5. Infrastructure Development Programs Statewide Blending Level Requirement State Fleet Usage Standard (Colorado has B20 standard in place, CO Rev Statutes 24-30-1104 (2)(c)(IV))
CWPMA has met with Senator Fenberg and provided some additional things to think about when considering intervening in fuel policy including the RFS, RIN requirements on obligated parties, BTU content variations, labeling requirements, Retailer’s liability protection, ASTM/UL specifications, the biodiesel blenders tax credit that we expect to be retroactively applied, and the
CWPMA is a fuels neutral association, meaning that the board generally doesn’t take a position of the relative merits of different blends or fuels in the market. That said, mandates that cause disruption and skewed pricing in the market is something that we have worked closely with our refining partners to resist in the past. It is important to remember that due to RFS requirements almost every gallon of diesel currently has a biodiesel element up to 5%. While this is generally not noted on BOL’s and product transfer documents it is commonly understood by blenders and marketers to be the case. CWPMA also passed a below the rack blending law for biodiesel back around 2010.
The liquid fuels industry is under assault in Colorado and the industry needs to work collaboratively and in partnership to forward policy objectives.
More to come on this issue.
