Fuel Terminal Operators say heating oil demand surges make EPA non-road 'baseline' production limit impractical

Diesel Fuel News, Sept 2, 2003

Fuel Terminal Operators Say Heating Oil Demand Surges Make EPA Non-Road 'Baseline' Production Limit Impractical: Independent Fuel Terminal Operators Association (IFTOA) says the worsening natural gas supply situation for North America makes it more likely that many customers will demand more heating oil in winter months.

"It is reasonable to assume that during a cold winter consumers with dual-fuel capability (both natural gas and heating oil) would switch to the lower-priced fuel, which in recent years has been heating oil. Such surges in demand result in substantial price spikes; a baseline [non-road diesel limitation] program would only exacerbate the situation and could create significant supply problems," IFTOA warns EPA. "The production or importation of home heating oil should not be subject to the restrictions of an historical baseline." Terminal operators, like pipelines and refiners, instead favor the "designate and track" system to separate non-road diesel from heating oil or other fungible fuels at terminals. As for proposed yellow-dyeing, IFTOA says it's unnecessary, since sulfur differences can be detected anyway.