Legal Memos

2/19/10 - RFS2 MEMO FORM STEPTOE & JOHNSON - singled spaced version - double spaced version

10/9/09 - SIGMA’s COMMENTS FOR INTERCHANGE HEARING

10/5/09 - SIGMA comments on Regulation of Fuels and Fuel Additives

10/2/09 - New CAFE Standards

8/26/09 - Memo on Market Manipulation Rule

7/31/09 - SUMMARY OF HR 2454—Waxman Markey Climate Change Bill

6/26/09 - SIGMA’s Comments on EPA Endangerment Finding

6/25/09 - SIGMA RFS II SUMMARY
Please read over the SIGMA RFS II Summary. We will need to file comments by July 25, 2009. We would like your input. Please carefully read the provisions and email Tim Columbus (tcolumbus@steptoe.com) or Jim Barnette (jbarnette@steptoe.com) with any concerns you may have.

6/19/09 - Applicability of Red Flag Memos to SIGMA Members

Short Version of Red Flag Memo

7/30/09 - SUMMARY OF HR 2454—Waxman Markey Climate Change Bill

1/16/09 - Economic Analysis of Automatic Temperature Compensation

1/9/09 - Derivatives Markets And Accessibility Act summary

1/9/09 - UL’s statement on E85 and other ethanol blends

1/9/09 - Biofuels Incentives: A Summary of Federal Programs

2/20/09 - CHANGES TO COBRA RULES IN STIMULUS PACKAGE REQUIRE IMMEDIATE ACTION FOR HEALTH PLANS

12/5/08 - Stage II Vapor Recovery and Onboard Refueling Vapor Recovery
Widespread Use - letter

12/5/08 - Card Check Seminar Presentation

9/10/08 - Fuel Waivers in Alabama, Georgia, and North Carolina

8/28/08 - FTC's Proposed Rule on Petroleum Wholesale Market Manipulation

8/1/08 - FTC Regulation Memo

7/18/08 - Speculation and Energy Prices

6/30/08 - Arguments in Favor of Legislation Requiring Access to "Clear Fuel" >>

6/27/08 - CALL MEMBERS OF THE HOUSE JUDICIARY COMMITTEE AND SAY YOU ARE FED UP WITH UNFAIR CREDIT CARD FEES

GRASSROOTS LETTERS

Letter 1

Letter 2

Letter 3

TALKING POINTS

HOUSE JUDICIARY COMMITTEE CONTACT INFO

6/27/08 - SIGMA’s comments to FTC on market manipulation

5/15/08 - Testimony: Tom Robinson, before U.S. Committee on the Judiciary, Anti-trust Task Force

1/7/08 - Legal Memo Regarding Marketer Provisions of H.R. 6

11/30/07 - ULSD Winterization Memo

9/7/07 - Letter on Automatic Temperature Compensation

8/10/07 - Final Operator Training Grant Guidelines For Underground Storage Tank Programs

6/21/07 - SIGMA Counsel Memo on the RFS Program

5/18/07 - SIGMA issues Action Alert to members regarding Price Gouging
The Bill: HR 1252~ Template Letter to send to you represenative


4/20/07 - SIGMA's position on Fuel Mandates

2/23/07 - LUST GAO Memo

12/15/06 - EPA Letter on Ethanol Gasoline Blends

12/1/06 - EPA fact sheet on pump labeling

11/3/06 - Comments to EPA on Stage II Recovery

10/13/06 - SIGMA Statement at EPA RFS Hearing

10/13/06 - PEI Emergency Shut Off Device Information

9/29/06 - EPA List of Approved ULSD Sulfur Test Facilities
(Contact EPA with questions.)

9/26/06 - Combat Meth Act Rules

9/19/06 - RFS Implementation Memo

9/8/06 - Recent Credit Card Interchange News

9/1/06 - Combat Meth Materials

9/1/06 - California Diesel Label Regulations

8/18/06 - EPA Releases Information on ULSD Sampling

7/13/05 - Schumer Amendment IP Opposition

7/7/06 - SIGMA sends a letter of support to Rep. Roy Blunt regarding Boutique Fuel Legislation.

6/2/06 - EPA’s Proposed National Boutique Fuels List

6/2/06 - Enforcement Discretion in Alaska

5/19/06 - ULSD Memorandum from SIGMA Counsel: Marketer Issues

5/19/06 - EPA Exercise Enforcement Discretion in Grant Parish, LA

5/19/06 - SIGMA Presentation to EPA’s Governor’s Task Force on Boutique Fuels

5/11/06 SIGMA Legislative Committee Chairman Paul Reid testifies before the House Energy and Commerce Committee

3/31/06 - Updated Diesel Sulfur Memo

3/31/06 - Letter from SIGMA and NACS re: E85 Mandates

3/31/06 - Joint Letter re: LUST Fund Appropriations

3/31/06 - SIGMA Member Bill Douglass’ testimony on MTBE Elimination

3/7/06 - JOINT LETTER IN SUPPOR OF THE VITTER AMENDMENT

3/3/06 - SIGMA Call To Action On Senate Native American Campaign Finance Loophole

2/27/06 - RFG Mandate Memo

2/2/06 - EPA response to SIGMA letter on LUST Trust Fund

1/13/06 - Implementation of EPA Gasoline Sulfur Program

1/3/06 - Renewable Fuel Standards For 2006


12/22/05 - Letter from Bill Shipley to DOE Regarding Finished Products Reserve

11/23/05 - EPA "All Appropriate Inquiry" Ruling

11/10/05 - Utah Oxy Fuel Waiver

11/7/05 - Fuel Excise Tax Memo

10/26/05 - Fuel Waivers

Florida Low Sulfur

Iowa Low Sulfur

Nebraska Low Sulfur

Mississippi Diesel Fuel

Kentucky Diesel Fuel

10/22/05 - California RVP Fuel Waiver

10/18/05 - SIGMA files statement to Senate Committee in Support of S.1772

10/7/05 - Fuel Waiver - St. Louis

10/5/05 - Fuel Waivers

Alabama

Arkansas

Florida

Georgia

Kentucky

Louisiana

Mississippi Diesel Fuel Waiver

New Mexico

North Carolina

South Carolina

Tennessee

Texas

Virginia

10/1/05 - Fuel Waivers

Kentucky

ExxonMobil

9/28/05 - Fuel Waivers

California Fuel Waiver RVP Extension

Houston Dallas RFG Extension

Richmond RFG

St. Louis RFG

Atlanta Low Sulfer Extensions

9/22/05 - API PRICE GOUGING ADVERTISEMENT and Letter of Explanation

9/21/05 - Fuel Waiver Concerning RFG in the Houston/Galveston RAG covered area

9/13/05 - Fuel Waiver for Texas RVP Season

9/13/05 - Fuel Waiver for Phoenix, Arizona RVP Season

9/13/05 - Fuel Waiver Concerning the California Gasoline Volatility Requirements

9/13/05 - Fuel Waiver Concerning  Use of Off-Road Diesel Fuel for PADD I, PADD III, plus the state of Tennessee, through October 5, 2005

9/7/05 - Shipley Testified Before the Senate - Bill Shipley testified before the Senate Committee on Energy and Natural Resources on “Gasoline Prices and Factors Contributing to Current High Prices” Tuesday, September 6, 2005.

Shipley Testimony

Douglass Testified Before the House – Bill Douglass testified before the House Committee on Energy and Commerce on “Hurricane Katrina’s Effect on Gasoline Supply and Prices” Wednesday, September 7, 2005.

Douglass Testimony

9/3/05 - RFG Fuels Waiver for Richmond, Virginia

9/2/05 - IRS issued an announcement waiving the penalty for having dyed diesel in an on-road tank.

9/2/05 - Atlanta, GA Fuel Waiver

8/31/05 - EPA Issues Nationwide Fuels Waiver
This afternoon, EPA issued a nationwide emergency fuel waiver concerning diesel fuel and gasoline in response to Hurricane Katrina. EPA is waiving the requirement to sell summer gasoline and will allow regulated parties to supply diesel fuel with a sulfur content higher than 500 parts per million. EPA decided to take this action to minimize or prevent supply disruptions of gasoline and diesel fuel.

The attached is a sample letter that will be distributed to all 50 states.
  
Please contact SIGMA counsel, Greg Scott, at 202-342-8646 for further information.

8/30/05 - EPA fuel specification waiver letter issued this evening for Florida, Alabama, Mississippi, and Louisana. For those marketers operating in these areas and dealing with the aftermath of Katrina, this waiver may offer some flexibility.
 
Please call SIGMA counsel Greg Scott at (202-342-8646) if you have questions or if you have information for him to relay to EPA regarding supply impacts outside these states.

8/30/05 - EPA fuel specification waiver letter issued this evening for Florida, Alabama, Mississippi, and Louisana. For those marketers operating in these areas and dealing with the aftermath of Katrina, this waiver may offer some flexibility.
 
Please call SIGMA counsel Greg Scott at (202-342-8646) if you have questions or if you have information for him to relay to EPA regarding supply impacts outside these states.

8/15/05 - Memo on Biodiesel Excise Tax Credits

1/15/05 - Research and Special Programs Administration's Proposed Rule Regarding Wetlines

1/7/05 - National Petroleum Council's report on petroleum product supply

11/23/04 - SIGMA's Detailed Memo on Ultimate Vendor Tax Refunds

11/9/04 - Memo on American Jobs Creation Act, Fuel Tax Provisions (including ethanol changes)

4/2/04 - SPCC Rule - Legal Memo

Link to EPA's New Winter-to-Summer RFG Transition Rules

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