CWPMA has received over 30 calls from individual distributors asking that the Association implore the Governor's office for an emergency declaration relative to HOS and R.V.P going into the holiday weekend. Distributors of all sizes have reached out and I want to thank the Colorado State Patrol, (one of our most important partners) for issuing the attached variance relative to HOS.
Further I have received calls from out partners in other states asking for our support for a regional variance.
On R.V.P. – I would encourage all members and partners who think this would be useful to reach out to the Governor's office if a waiver would be a benefit to you: gov_constituentservices@state.
co.us Note: that CWPMA has made a request and that we are hopeful that due consideration would be provided.
Of important note : CWPMA’s request has objectors – whenever we interfere in the supply market there are going to be shifts in market dynamics. Some important CWPMA partners have rightfully questioned, due to the supply shortages that are affecting our entire region, if an R.V.P waiver would be helpful and if there would be any impact on pricing. Suppliers with compliant fuel would have market impacts due to this request. It is important to note that trade associations cannot unduly influence a market, we don’t operate in a way for example like the teachers union who can shut down schools across Colorado or like airlines unions who can ground thousands of flights per day. When we have a majority of Board members who support an action we respond with requests and it is up to the regulatory powers in the state if they want to intervene or not. CWPMA does not negotiate political actions in the press nor do we take any action without due consideration.
With the Biden’s administration’s R.V.P. allowance relative to blends up to E-15 having a static 7.8. standard in the DMFNR is candidly head scratching. The below chart sourced from our friends at NREL demonstrate that retailers that are selling blends at E-14 for example are already well above the 7.8 Ceiling. What our request does do is help to highlight to interesting decision to mandate RFG in the DMNFR next year. If our supplier partners are having issues suppling a 7.8. blend – can we reasonably assume that RFG which has an even lower R.V.P. floor will be sustainable? Further CWPMA continues to question the effect and benefit to air quality based on altitude and tail pipe emissions.
State Partners,
It has been a challenging year for fuels here in Colorado. I want to thank the Governor and all our partners at the various agencies we depend on for their support this year.
– First off Suncor doesn’t have access to email currently, so I am including these folks for the record. For our distributors – our state partners are copied here for awareness.
CWPMA is making an official request to the Governor and the Chief of the State Patrol –
The Board of the Colorado Petroleum Marketers Association and Colorado Convenience Store Association formally request that the Governor issue an emergency declaration to assuage the impacts of fuel supply in Colorado. The request is an effort going into the holiday weekend, which traditionally sees the highest demand for fuels in a calendar year, to help mitigate the impact on supply and alleviate disruptions for transportation fuel on communities and families in Colorado. The impact that fuel shortages would have on our state would be immense . The communities that rely on summer economic support through tourism as well as the public safety services cannot be placed in jeopardy. As of this morning I can confirm that at least 50 stations are out of fuel or will have outages by the end of the day – this number will increase as demand surges going into next week.
Our suppliers are a foundational and integral part of Colorado’s economy and help maintain the economic vitality of Colorado. Throughout this year our supplier partners have spent enormous resources and moved millions of gallons of fuel across the country to help maintain our economy. Our suppliers along with our political and regulatory partners have saved Colorado families 10’s of millions of dollars through mitigation and Regulatory actions. CWPMA members who distribute and retail these fuels are grateful. This request will have market implications and will artificially move pricing and fuel supply economics.
We request Regulatory relief in the following two ways:
- The Denver Metro North Front Range is a nine county area which under the Federal Clean Air Act has a requirement that gasoline sold in that area must meet an R.V.P. standard. This standard is in effect from June 1st until September 15th each year at retail and applies only to gasoline. CWPMA is requesting that under the auspices of a declared emergency the R.V.P requirement be lifted until July 15th 2023. We request this in order to bring in fuel that is sold in the rest of Colorado into the Denver Metro area. It is important to note that this summertime blend is primarily sourced from four suppliers.
- Based on current supply dynamics that have almost statewide impacts (excepting only the southwest corner of the state) CWPMA is formally requesting the Colorado State Patrol, under a declaration from the Governor, provide mitigation and regulatory relief from Hours of Service requirements. This request is to address wait times at terminal racks which have been reported to be in excess of 3 hours and up to 6 hours so that distributors can supply communities throughout Colorado. It quite simply isn’t feasible for distributors, for example based in Montrose, to come to Denver and expect to return under standard rules. It is important to note that a Declaration/Waiver helps fuel distributors to reach potential supply points in neighboring states for gallons.
Respectfully and for your consideration,
Grier Bailey
Grier W. Bailey
Executive Director
CWPMA
Colorado Wyoming Petroleum Marketers AssociationColorado Convenience Store Association
303.422.7805 (W) 303.902.0132 (c)
gbailey@cwpma.org