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Environmental Protection Agency & State Fuels Programs

Attorneys at Davis Graham & Stubbs LLP have years of experience working with the U.S. Environmental Protection Agency’s Fuels Program, headquartered in Denver, Colorado, which implements the provisions of the Clean Air Act and the Energy Policy Act related to fuel integrity, fuel composition, registration, reporting, anti-dumping, and renewable fuels.

Representative Experience

  • Assisting a fuels blender and distributor in responding to a grand jury subpoena related to purchase of allegedly fraudulent Renewable Identification Numbers (RINs).
  • Assisting a mobile fueling company in achieving compliance with EPA’s evolving Product Transfer Documentation (PTD) requirements related to fuels delivered via truck.
  • Defending a petroleum distributor against claims related to unlawful refining of fuels due to alleged improper blending of natural gas condensate into previously certified gasoline.
  • Defending a purchaser and blender of fuels against claims related to unlawful addition of mixed alcohol additive to previously certified fuels to boost octane content of fuel.
  • Assisting clients in responding to EPA Clean Air Act Section 114 information requests concerning compliance with EPA’s fuels regulations.
  • Assisting refinery clients with resolution of alleged fuels violations regarding refining and distribution of fuel with higher than allowed Reid Vapor Pressure (RVP), sulfur, and benzene.
  • Assisting clients with resolving alleged fuels program violations though use of EPA’s self audit and voluntary disclosure policy.
  • Negotiating consent decrees with EPA and the Department of Justice to resolve alleged violations of EPA’s fuels regulations.
  • Assisting clients with evaluation of legislation related to mandatory use of renewable fuels.

Related Attorneys

Laura J. Riese

Partner, Environmental Law & Litigation, Natural Resources & Environmental Litigation, Toxic Tort Litigation, Safety & Health, Brownfields Redevelopment, Environmental Protection Agency & State Fuels Programs, CERCLA & State Equivalent Programs, Crisis Management, Environmental