Comment Log Display

Talking points are:·        AB 32 regulation is reaching deep into
our small business membership with very negative impacts.·       
The looming AB 32 premiums on fuel will significantly affect fuel
distributors by decreasing margins and increasing business costs.· 
      AB 32 fuels programs have the significant potential to
decrease fuels market competition (starting to see that with the
Tesoro acquisition) by running our members out of various segments
of the fuels industry (members participating above the rack, fuel
blending).  CARB has never looked at the consequences to the
consumer through elimination of competition.·        Late 2014 and
early 2015 we believe will see convergence of fuels under the cap
and LCFS program impacts.  Several studies have indicated that this
may create a $1-$2/gallon CA premium on fuel costs – having ripple
effects to other small businesses in the state.·        CARB needs
to look at their programs through the eyes of existing small
businesses and consumers, not try and protect new entrants to the
marketplace at the expense of fuel consumers and ordinary
citizens.
-    CARB needs to have exit ramps for their fuels programs in case
unintended consequences create significant fuel price increases
and/or supply impacts.
-        The level of complexity in the new GHG fuels regulations
is unprecedented creating new, unique and unusual reporting and
economic burdens on small companies who do not have the staff,
resources or sophistication to manage their new involvement.
-       CARB needs to take advantage of the recent law suit on LCFS
to completely re-evaluate that program and its operation.