Texas urges U.S. EPA to speed-up non-road diesel desulfurization, clarify retrofit credits proposal

Diesel Fuel News, Sept 29, 2003

Texas Urges U.S. EPA To Speed-Up Non-Road Diesel Desulfurization, Clarify Retrofit Credits Proposal: Under Texas Commission on Environmental Quality (TCEQ) rules, 110 east-Texas counties must switch to 15-ppm sulfur ULSD for both highway and non-road by mid-2006. But it would help if EPA mandated this "one-step" desulfurization nationally rather than delaying it until 2010, TCEQ tells EPA in comments on the non-road proposed rule.

Locomotive and marine likewise should only use ULSD from mid-2006, as TCEQ requires for east Texas. "Widespread availability of ULSD to these sectors encourages the development and implementation of retrofit technologies in marine and locomotive," TCEQ says. Meantime, TCEQ frets over the impact of EPA's proposed retrofit credit program on "states such as Texas which already have their own programs to encourage retrofits." So, TCEQ wants EPA to clarify what the terms "surplus, verifiable, quantifiable and enforceable" mean for emissions credits. "The term ,surplus' especially needs defining; we need to understand if 'surplus' reductions are those not yet accounted for as part of a state SIP [state implementation plan], an existing agreement or an enforceable commitment," TCEQ says. "We are concerned that such a program would be extremely difficult to track in order to prevent overlap and determine what is truly 'surplus' and could lead to double-counting of [emissions] reductions."