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Please disregard last submittal - we did not have both attachments
in a zip file. Thank you.

Attached are the Western States Petroleum Association (WSPA)
comments on CARB’s modified text/15 day package for the proposed
2007 amendments to California phase 3 reformulated gasoline
regulations.

Our industry remains concerned over the inclusion in the rule of
an alternative emissions reduction plan (AERP).  As currently
designed, this unprecedented AERP amounts to a penalty payment
program.  The record before ARB in this rulemaking demonstrates
that the AERP rests on an unrealistic and unreasonable compliance
timeline, and it is therefore unjustified. 

We look forward to continued dialogue on this important matter.