Statement Regarding BAAQMD Rule 12-15

Sacramento, CA // April 20, 2016 — Western States Petroleum Association President Catherine Reheis-Boyd’s statement on BAAQMD Rule 12-15:

“WSPA and its member companies strongly object to Rule 12-15, which was passed by the BAAQMD Board of Directors on April 20, 2016. We have worked with the Air District to construct a reasonable regulation, but the BAAQMD Board of Directors passed a rule that contains unworkable requirements, many of which are already governed by the State and Federal governments.”


The requirement to report crude oil characteristics on a daily basis is unworkable and unnecessary to control air emissions. Information about the refineries’ raw materials is proprietary business information that would create a competitive disadvantage if that information became public.

The District is requiring refineries to be responsible for air emissions from cargo carriers, which are ships, rail cars and trucks. Refineries cannot control emissions from equipment they do not own or operate. By including emissions from ships and trains Rule 12-15 would encroach upon US EPA and federal government jurisdiction over shipping.

The proposed rule requires the refineries to be responsible for emissions from other facilities that support the refineries that they do not own or operate. This exceeds the District’s authority over the refineries and they should provide oversight of those facilities from the owners and operators of those sources.

Bay Area refineries have reduced NOx emissions by 88% since 1995 and SOx emissions by 95% since 2000 and will continue to innovate and invest in technology and practices that promote a clean and safe Bay Area community.

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