Comment Log Display

BP appreciates the opportunity to provide comments on the draft Cal
EPA Fuels Guidance Document.  BP believes this document will serve
as an important reference to inform regulators and stakeholders
about impediments and opportunities in bringing new fuels to
market. As the regulations referenced and reviewed for the purpose
of assembling this document are always subject to change, we
suggest that the final document be clearly dated to indicate the
time of review.

Because this document provides critically important information
that could ultimately affect rulemaking and legislation, BP
believes more review is necessary and strongly recommends that
either the review period be extended, or a second 60-day review
period be provided following any initial revisions that Cal EPA
makes to the document.  It is important that this document convey
as accurate information as possible.  We would also ask that the
next version be published in a Word format that would enable
comments to be directly inserted which should help both of our
reviews.

In the last 30-days, BP has endeavored to review as much of the
document as possible - but with specific focus on the matrix.  We
have included a spreadsheet version of the matrix with our
suggested changes and comments.  We have marked this draft because
this is a "work in progress" and we were not able to review all of
the regulatory aspects for each of the fuels.  We have labeled the
cells in the spreadsheet where we did not complete our review and
anticipate providing additional information during a subsequent
review period. Note that we are suggesting that the document
include a review of the federal regulatory and other national code
impacts as well (see supporting matrix tab).

The focus of BP's submittal is the matrix, but BP has also
provided comments through WSPA.  We view the submittals as
complementary.

Thank you again for the opportunity to comment and please contact
me with any questions.