| Comment | Lunday-Thagard Company (LTR) appreciates the opportunity to provide
comments on the proposed amendments to the Mandatory Reporting
Regulation (MRR). LTR is a small privately-owned petroleum
refinery that produces a variety of paving and roofing asphalts
from the distillation of crude oil. While our principal products
are finished asphalts, our process concurrently produces
straight-run, light distillate products (intermediates) that are
sold to other refineries for further processing/refining. As a
result, LTR is requesting that the California Air Resources Board
modify the current draft language of Sec. 95121 (a), to clearly
exclude the reporting of straight-run petroleum intermediates,
which are not intended for use as a transportation fuel, even
though these materials may meet the physical properties of
“Distillate Fuel Oils.”
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