Summary and Analysis of the
2011-2019 Gasoline Sulfur
Compliance Reports
United States
Environmental Protection
^1	Agency

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Summary and Analysis of the
2011-2019 Gasoline Sulfur
Compliance Reports
Compliance Division
Office of Transportation and Air Quality
U.S. Environmental Protection Agency
NOTICE
This technical report does not necessarily represent final EPA decisions or
positions. It is intended to present technical analysis of issues using data
that are currently available. The purpose in the release of such reports is to
facilitate the exchange of technical information and to inform the public of
technical developments.
%	United States
Environmental Protection
^1	Agency
EPA-420-R-20-025
December 2020

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Table of Contents
List of Acronyms	1
I.	Executive Summary	2
II.	Background on Gasoline Sulfur Programs	4
A. Tier 2 Gasoline Sulfur Program	4
1. Overview	4
2.	Averaging, Banking and Trading (ABT) Program for Gasoline Sulfur Credits	4
3.	California Gasoline	5
4.	Oxygenate Blending and Accounting	5
B. Tier 3 Gasoline Sulfur Program	7
III.	Gasoline Sulfur Compliance Analysis from 2017 through 2019	8
A.	Summary	8
B.	Analysis	10
1.	Compliance with 10 ppm Annual Average Sulfur Standard	10
2.	Credit Generation and Use	14
3.	Combined Annual Data from GSF030X and GSF0100 Reports	18
4.	Small Volume Refinery and Small Refiner Data	21
5.	Compliance with 80 ppm Per-Gallon Standard	23
6.	2020 Gasoline Sulfur Data Submitted to EPA	24
IV.	Conclusion	26
V.	Appendix	27
List of Acronyms
ABT
Averaging, Banking, and Trading
ASTM
American Society for Testing and Materials
CBOB
Conventional Blendstock for Oxygenate Blending
CFR
Code of Federal Regulations
CG
Conventional Gasoline
EMTS
EPA Moderated Transaction System
EPA
United States Environmental Protection Agency
PADD
Petroleum Administration for Defense District
ppm
Parts per Million
RBOB
Reformulated Blendstock for Oxygenate Blending
RIG
Reformulated Gasoline
GSF0100
Gasoline sulfur credit averaging, banking and trading (ABT) report
GSF0200
Gasoline sulfur credit transfer report
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GSF030X
Gasoline sulfur facility summary report
RFG030X
Batch report for RFG and CG
GSF0402
Gasoline sulfur supplementary batch report
I. Executive Summary
Beginning in 2004, the United States Environmental Protection Agency ("EPA" or "the
Agency") set standards limiting the amount of sulfur in gasoline to help reduce vehicle
emissions, and protect emission controls in vehicles and engines.1 The Tier 2 gasoline sulfur
program established standards beginning January 1, 2004, which phased down gasoline sulfur
over a seven-year period. Under this program, all gasoline produced in or imported into the
United States was required to meet an annual average sulfur standard of 30 parts per million
("ppm") beginning January 1, 2011, and also meet a maximum per-gallon standard of 80 ppm
sulfur. The program allowed refiners and importers to generate gasoline sulfur credits by
producing or importing gasoline containing less than 30 ppm sulfur on an annual average basis.
These credits could be used by refiners and importers which produced or imported gasoline
containing more than 30 ppm sulfur on an annual average basis. Credits could be "banked" for
use in future years, and expired if not used within five years after the year of generation. The
result was that the phasedown to 30 ppm continued beyond 2011.
The Tier 3 gasoline sulfur program further reduced gasoline sulfur so that all gasoline
produced or imported in the United States met an annual average sulfur standard of 10 ppm. The
Tier 3 standards began on January 1, 2017 and were fully phased in beginning January 1, 2020.
Similar to the Tier 2 program, the Tier 3 program also provides refiners and importers the
flexibility to generate and use credits in complying with the 10 ppm average standard, potentially
allowing the phasedown to 10 ppm to continue beyond 2020.
The purpose of this report is to provide an explanation of how refiners and importers
complied with the Tier 2 30 ppm annual average sulfur standard from 2011 through 2016, and
the Tier 3 10 ppm annual average sulfur standard from 2017 through 2019. This period of time
covers the six years leading up to the start date of the 10 ppm Tier 3 sulfur standard, and the first
three years during which the 10 ppm Tier 3 sulfur standard was phased in. The report also
discusses how refiners and importers used "early" Tier 3 credits for compliance with the 10 ppm
average sulfur standard, and used a regulatory option that allowed small volume refineries and
small refiners to delay compliance with the 10 ppm standard for 3 years. This report builds on
the information and analysis in EPA's previous gasoline sulfur compliance report (published
March, 2018), which covered gasoline sulfur compliance with the Tier 2 standards from 2011
through 2016.
The data in this report were aggregated from compliance data reported to the EPA by
gasoline refiners and importers. Key findings include:
1 In order to protect emission controls, a 1977 amendment to the Clean Air Act required unleaded gasoline in
commerce to be "substantially similar" to the unleaded gasoline used in certifying vehicles to emission standards. In
an interpretive rule, the Agency defined "substantially similar," including compliance with the ASTM standard
which limited sulfur in unleaded gasoline to 1000 ppm. The rule also limited an additive's sulfur contribution to
unleaded gasoline to 15 ppm.
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	The reported national average gasoline sulfur content of gasoline decreased from 21.2
ppm in 2017 to 17.5 ppm in 2019. National gasoline sulfur is expected to average
very near 10 ppm in 2020 and following years, since few credits from previous years
were generated to use for compliance.
	Refiners and importers used large quantities of "early" Tier 3 credits (generated from
2012 through 2016) to comply with the 10 ppm annual average standard from 2017
through 2019
	Annual credit generation from 2017 through 2019 was relatively low, compared to
annual credit generation from 2011 through 2016.
	Small volume refineries and small refiners used provisions in the Tier 3 regulations
which allowed them 3 additional years to comply with the 10 ppm annual average
standard.
	Although EPA has only limited reporting of 2020 data at this time, the data we have
suggests that the average gasoline sulfur concentration for 2020 will be below 10 ppm
(see Section III.6 for a discussion of the available 2020 data).
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ickground on Gasoline Sulfur Programs
A. Tier 2 Gasoline Sulfur Program
1.	Overview
Beginning in 2004, refiners and importers were subject to gasoline sulfur standards
established in the "Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control
Requirements" ("Tier 2 rule"). The EPA finalized the Tier 2 rule on February 10, 2000,
including gasoline sulfur requirements promulgated in 40 CFR Part 80, Subpart H. 2-3 The
purpose of these gasoline sulfur requirements was to reduce the sulfur concentration of all
gasoline sold in the United States from approximately 300 ppm to an average of 30 ppm, in order
to enable emissions control equipment on new vehicles to significantly reduce emissions of
pollutants, such as nitrogen oxides and volatile organic compounds, as well as to provide public
health and welfare benefits. The Tier 2 gasoline sulfur regulations achieved this reduction by
establishing a series of annual sulfur standards that gradually decreased allowable sulfur
concentrations so that by 2011, all refiners and importers had to meet an annual average sulfur
standard of 30 ppm, and a per-gallon sulfur standard of 80 ppm.4
Gasoline refiners and importers could meet the annual average sulfur standard by either
of two ways:
1)	Producing or importing gasoline with an annual average sulfur content less than or
equal to the 30 ppm average standard; or,
2)	Producing or importing gasoline with an annual average sulfur content greater than
the 30 ppm average standard, and using credits to meet the standard (more discussion
below on credits).
The 80 ppm per-gallon sulfur standard had to be met directly; credits could not be used to
meet the 80 ppm per-gallon standard.
2.	Averaging, Banking and Trading (ABT) Program for Gasoline Sulfur Credits
Refiners and importers could generate gasoline sulfur credits (in ppm-gallons) on a
refinery-specific or Petroleum Administration for Defense District (PADD) basis, respectively.
Beginning in 2004, most refiners and all importers could generate credits for each year by
producing gasoline with an annual average sulfur content less than 30 ppm, according to the
formula "(30 - annual average sulfur) X total annual gasoline volume".5 Beginning in 2011, all
refiners and importers could generate credits using this formula. Credits could be used for
2	See 65 FR 6697, February 10, 2000.
3	More information on the Tier 2 and Tier 3 gasoline sulfur programs can be found at the EPA's website at
https://www.epa.gov/gasoline-standards/gasoline-suifiir.
4	All gasoline downstream of refineries and import facilities had to meet a per-gallon standard of 95 ppm sulfur.
5	From 2004 through 2010, some refineries had annual average standards that were greater than 30 ppm, and could
generate credits by producing gasoline with an annual average sulfur content less than their specific standard, see 40
CFR 80.310.
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compliance up to five years after the year that they were generated, and could be transferred no
more than twice between refiners and/or importers. Credits expired if unused after five years.
3.	California Gasoline
Gasoline produced or imported for use in California ("California gasoline") was exempt
from all of the requirements in 40 CFR Part 80, Subpart H, provided it met certain requirements
specified in 40 CFR 80.375. As a result, no California gasoline was reported to the EPA under
the Tier 2 rule, and all volume and property data shown in this report does not include California
gasoline.6
4.	Oxygenate Blending and Accounting
Similar to Subparts D (Reformulated Gasoline) and E (antidumping) of 40 CFR Part 80,
Subpart H also allowed refiners and importers to include downstream-blended oxygenate
(typically ethanol) in their gasoline sulfur compliance calculations if they complied with the
requirements in 40 CFR 80.69(a) or 80.101(d)(4).7 Refiners and importers generally met the
oversight program requirement in 40 CFR 80.69(a)(l 1) for downstream blending of oxygenate in
reformulated blendstock for oxygenate blending ("RBOB"), by participating in the RFG Survey
Association, and used the sulfur test result from their hand blend of RBOB and oxygenate per 40
CFR 80.69(a)(2) in their gasoline sulfur compliance calculations.8 For downstream blending of
oxygenate in CG or conventional blendstock for oxygenate blending ("CBOB"), refiners and
importers met the oversight program requirement in 40 CFR 80.101 (d)(4)(ii) on an individual
basis. Refiners and importers that met the oversight program requirement in 40 CFR
80.101(d)(4)(ii) could assume that oxygenate blended into their conventional gasoline or CBOB
contained no sulfur.9 Oxygenate blenders (i.e., downstream parties that simply blended
oxygenate into RBOB, CBOB, or CG) were only required to ensure that any ethanol they
blended into RBOB, CBOB or CG contained no more than 30 ppm sulfur, prior to January 1,
2017. Beginning January 1, 2017, ethanol blended into RBOB, CBOB or CG was required to
contain no more than 10 ppm sulfur. Tables 1 through 3 provide data on total volumes of ethanol
in gasoline (not including California gasoline) from 2011 through 2019, based on reports
submitted by refiners and importers to EPA.10 These volumes are not the annual volumes of
6	California gasoline is also excluded from reports submitted by refiners and importers under 40 CFR Part 80,
Subparts D (RFG) and E (antidumping), per 40 CFR 80.81.
7	Refiners and importers benefit from including ethanol in their gasoline sulfur compliance calculations because of
ethanol's low sulfur content. The provisions in 40 CFR 80.69(a) and 80.101(d)(4) required refiners and importers to
verify their included volumes of downstream-blended oxygenate through a combination of product transfer
documents, contractual arrangements with oxygenate blenders, and periodic sampling and testing of oxygenate-
blended gasoline.
8	RBOB is a gasoline blendstock that becomes RFG upon blending with a specified type of oxygenate, typically
ethanol. In order to comply with the RFG standards in Subpart D, refiners and importers of RBOB prepare a "hand
blend" sample of RFG by blending a batch sample of RBOB with a refiner-specified percentage of ethanol, and test
the RBOB/ethanol blend for several properties, including sulfur, per 40 CFR 80.69(a)(2). The refiner-specified
percentage of ethanol is transmitted on the product transfer document for the RBOB to a downstream oxygenate
blender, who blends the RBOB batch with the specified percentage of ethanol.
9	CBOB is a blendstock that becomes conventional gasoline upon blending with a specific type of oxygenate.
10	Gasoline volumes and ethanol concentrations were taken from the RFG030X reports. Volumes of ethanol in RFG,
CG, and (RFG+CG) were calculated by multiplying the corresponding gasoline volumes and ethanol concentrations.
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ethanol actually blended into gasoline, but simply the volumes of ethanol included in refiner and
importer compliance reports.11
Table 1: Annual RFG Volumes, Ethanol Concentrations, and Ethanol Volume in RFG
(from Refiner and Importer Compliance Reports)
Year
Total RFG,
million gallons
Ethanol in RFG,
volume percent
Ethanol in RFG,
million gallons
2011
30,901.7
9.65
2,982.4
2012
30,418.7
9.62
2,925.3
2013
30,689.7
9.63
2,956.1
2014
31,268.2
9.64
3,014.8
2015
32,125.3
9.66
3,104.6
2016
33,254.2
9.68
3,218.5
2017
32,809.9
9.69
3,179.7
2018
33,127.7
9.68
3,205.8
2019
32,592.4
9.72
3,166.8
Table 2: Annual CG Volumes, Ethanol Concentrations, and Ethanol Volume in CG
(from Refiner and Importer Compliance Reports)
Year
Total CG,
million gallons
Ethanol in CG,
volume percent
Ethanol in CG,
million gallons
2011
84,305.6
2.08
1,751.8
2012
84,512.6
2.08
1,757.9
2013
84,354.7
2.06
1,738.3
2014
85,140.2
2.30
1,956.4
2015
87,169.6
2.40
2,096.3
2016
89,283.4
2.39
2,130.6
2017
90,135.9
2.35
2,115.4
2018
89,899.2
2.71
2,433.0
2019
90,650.5
2.40
2,174.3
Table 3: Annual (RFG+CG) Volumes, Ethanol Concentrations, and Ethanol Volume in
(RFG+CG)
(from Refiner and Importer Compliance Reports)
Year
Total (RFG+CG),
million gallons
Ethanol in (RFG+CG),
volume percent
Ethanol in (RFG+CG),
million gallons
2011
115,207.3
4.11
4,734.2
11 The regulations for downstream oxygenate accounting have been significantly revised as part of the fuels
regulatory streamlining rule. The new regulations are located in 40 CFR 1090.710, and broaden the oversight
program approach for RFG to also apply to CG. This should enable refiners and importers to include larger volumes
of ethanol in their compliance calculations and reports.
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2012
114,931.3
4.07
4,683.2
2013
115,044.4
4.08
4,694.3
2014
116,408.4
4.27
4,971.2
2015
119,309.4
4.36
5,200.9
2016
122,537.6
4.36
5,349.1
2017
122,945.8
4.31
5,295.0
2018
123,026.9
4.58
5,638.7
2019
123,242.9
4.33
5,341.1
B Tier 3 Gasoline Sulfur Program
The EPA finalized the "Tier 3 Motor Vehicle Emission and Fuel Standards" rulemaking
("Tier 3 rule") on April 28, 2014, including gasoline sulfur requirements promulgated in 40 CFR
Part 80, Subpart 0.12 The purpose of the Tier 3 rule was to further reduce the sulfur
concentration of all gasoline sold in the United States from an average of 30 ppm to an average
of 10 ppm. This enabled emissions control equipment on new vehicles to further reduce
emissions of pollutants, such as nitrogen oxides and volatile organic compounds, providing
significant benefits to public health and welfare. The Tier 3 gasoline sulfur regulations required
most refiners and all importers to meet an annual average standard of 10 ppm sulfur beginning
January 1, 2017. Small volume refineries and small refiners (both defined in the regulations)
were allowed to delay compliance with the 10 ppm annual average sulfur standard for 3 years,
until January 1, 2020.13 During this 3 year period, small volume refineries and small refiners
continued to be subject to the previously established Tier 2 30 ppm annual average standard.14
The Tier 3 rule has many similarities to the Tier 2 rule. The 10 ppm average standard in
the Tier 3 rule applies to each refinery's annual gasoline production, and each importer's annual
gasoline importation on a PADD basis.15 Refiners and importers continue to be subject to a per-
gallon sulfur standard of 80 ppm, and all gasoline continues to be subject to a downstream per-
gallon standard of 95 ppm. The Tier 3 gasoline sulfur regulations also include an ABT program
for gasoline sulfur credits that allows refiners and importers to generate credits (in ppm-gallons)
and use them to comply with the 10 ppm average standard. Beginning January 1, 2017, sulfur
credits are generated by producing or importing gasoline containing an annual average sulfur of
less than 10 ppm. These credits have a life of five years after the year of generation (i.e., 2017
credits expire if not used after the 2022 compliance period), and may be banked by the refiner or
importer that generated them, or sold to another refiner or importer for use in complying with the
10 ppm standard.
12	Additional information on the Tier 3 rule can be found on the EPA website at https://www.epa.gov/regulat.ions~
emissions-vehicles-and-engines/final-rule-control-air-poHution-motor-vehicles-tier-3.
13	Small volume refineries were defined as refineries which processed an annual average of 75,000 barrels per day of
crude oil or less during calendar year 2012, see 40 CFR 80.1621. Small refiners were defined as refiners which
employed an average of 1,500 people or less during 2012, and had a corporate average crude oil capacity of 155,000
barrels per calendar day or less during 2012, see 40 CFR 80.1620.
14	See 40 CFR 80.1603(a)(l)(iii)(B).
15	Additional information on PADDs can be found on EIA's website at
https://www.eia.gov/todavinenergy/de tail.php?id=4890.
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Additionally, the Tier 3 rule allowed refiners and importers to use Tier 2 gasoline sulfur
credits generated from 2012 through 2016 for compliance with the 10 ppm average sulfur
standard from 2017 through 2019.16 From 2012 through 2016, refiners and importers could
generate gasoline sulfur credits for use in meeting either the 30 ppm average sulfur standard
through 2016, or for use in meeting the 10 ppm average sulfur standard from 2017 through 2019.
Individual credits could be used to meet either the 30 ppm or 10 ppm average standard, but the
same credits could not be used to meet both standards (see example in the Appendix of credit
generation and use under the Tier 2 and Tier 3 programs). These credits have a maximum life of
five years after the year of generation (i.e., 2012 credits expire if not used after the 2017
compliance period), and all expire if not used by the 2019 compliance period.
Lastly, the Tier 3 rule included provisions which established an additional temporary
ABT program for only small volume refineries and small refiners. This ABT program lasted 3
years (2017 through 2019) and allowed small volume refineries and small refiners to generate
gasoline sulfur credits by producing gasoline with an annual average sulfur content between 10
ppm and 30 ppm. These credits could be banked by the refiner that generated them or sold to
another small volume refinery or small refiner for use in complying with their 30 ppm standard
from 2017 through 2019.17 However, these credits could not be used by non-small volume
refineries, non-small refiners, or importers, and all of these credits expired after 2019. Small
volume refineries and small refiners could also separately generate Tier 3 credits like other
refiners, by producing gasoline with an annual average sulfur content of less than 10 ppm. These
credits had a five year life, and could be banked or transferred to any other refiner or importer for
compliance.
111. Gasoline Sulfur Compliance Analysis from 2017 through 2019
A. Summary
This report presents analyses of data, primarily from the gasoline sulfur reports, from
2017 through 2019. This report also includes data from 2011 through 2016, which was analyzed
in EPA's previous gasoline sulfur compliance report18, and is helpful in illustrating how refiners
and importers used gasoline sulfur credits generated from 2012 through 2016 for compliance
from 2017 through 2019. The data is reported to the EPA on various reporting forms by refiners
and importers on an annual basis for all gasoline they produce for use in the U.S. outside of
California. Thus, the report provides a comprehensive summary of gasoline sulfur
concentrations, and gasoline sulfur credit generation and use for all gasoline reported to EPA
from 2011 through 2019.
Under the pre-existing RFG and antidumping programs, refiners and importers were
required to report several properties, including sulfur, for each batch of gasoline on the EPA
batch report form RFG0300. In addition to the RFG and antidumping gasoline batch report form,
17 Small volume refineries and small refiners could also use any credits generated by all other refiners and importers,
for compliance from 2017 through 2019.
17 Small volume refineries and small refiners could also use any credits generated by all other refiners and importers,
for compliance from 2017 through 2019.
18See https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100U3P5.pdf
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the EPA created four new reporting forms for refiners and importers to report data for the Tier 2
program. These five forms are listed below, along with a description of each form's purpose
under Tier 2.
1)	Gasoline Sulfur Credit Banking and Allotment Generation Report (GSF0100)
	Refiners and importers report total annual gasoline sulfur credit generation, use,
transfers, and expiration by facility (credit units are ppm-gallons)
All information is reported separately by credit creation year
2)	Gasoline Sulfur Credit Transfer/Conversion Report (GSF0200) 19
	Refiners and importers report each transfer of credits to or from another party
	Reported information includes credit quantity, transfer date, company and facility
IDs for the buyer and seller, credit type, and credit creation year
3)	Gasoline Sulfur Facility Summary Report (GSF0300)20
	Refiners and importers report their total annual gasoline production, average
sulfur before using credits, and average sulfur after using credits (if applicable) by
facility
	Demonstrates compliance with the 30 ppm annual average sulfur standard
4)	Reformulated Gasoline and Anti-Dumping Batch Report (RFG0300) 21
	Refiners and importers report all complex model properties (including sulfur) for
each batch of gasoline
	Demonstrates compliance with the 80 ppm per-gallon sulfur standard, except for
CG batches that are composited
5)	Gasoline Sulfur and Benzene Batch Report (GSF0402)
Supplementary report used by refineries or importers which report properties for
composited batches of CBOB and/or CG on the RFG0300 report22
	Refiners and importers must report the volume and sulfur content of each sub-
batch of CBOB and/or CG used to form the composite batch, in order to
demonstrate compliance with the 80 ppm per-gallon standard for each sub-batch
Also used by ethanol producers beginning January 1, 2017 to report the volume
and sulfur content of each batch of ethanol produced, in order to demonstrate
compliance with the 10 ppm per-gallon standard for each batch of ethanol.
The analysis contained in this report is primarily focused on the period from 2017
through 2019, which were the first 3 years during which the 10 ppm sulfur standard was in
effect. However, data from 2011 through 2016 is also included in the following graphs and
tables in order to show the interrelationship between the Tier 2 and Tier 3 gasoline sulfur
programs. The industry compliance trends reported here reflect, to a large extent, the ABT
provisions which are a part of both the Tier 2 and Tier 3 gasoline sulfur regulations.
19	The GSF0200 form has been superseded by EPA's Moderated Transaction System (EMTS), which allows refiners
and importers to report credit transactions online.
20	The GSF0300 reporting form was revised and was subsequently re-issued as the GSF0301 reporting form. In this
report, both forms will be collectively referred to as the GSF030X reports.
21	The RFG0300 reporting form was subsequently revised and re-issued 3 times as the RFG0301, RFG0302 and
RFG0303 reporting forms, respectively. In this report, these 4 reporting forms will be collectively referred to as the
RFG030X reports.
22	40 CFR Part 80, Subpart E (antidumping) allows refiners and importers to test a single composite sample prepared
from all of the gasoline they produce or import for a period of up to one month, per 40 CFR 80.101(i)(2).
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Data in this report does not include any volume or property data for California gasoline,
and reflects the impact on actual in-use sulfur concentrations of only a portion of the total
amount of ethanol that is actually blended into CG and CBOB at locations downstream of
refineries and import facilities. Gasoline produced or imported for use in California is not
reported to the EPA, under certain reporting exemptions in the EPA regulations. Also, refiners
and importers calculate their total gasoline volume and average sulfur using only a portion of the
total ethanol that is actually blended at downstream locations into their CG and CBOB, due to
certain compliance requirements in the EPA regulations.23 Lastly, butane and pentane that were
blended into gasoline under the EPA's simplified compliance requirements are included in the
GSF030X report data, but not in the GSF0100 report data, since butane blenders and pentane
blenders may not generate gasoline sulfur credits.
In this report, the term "facilities" is generally used to describe all facilities that produce
or import gasoline. These include refineries that produce gasoline by refining crude oil, and other
facilities ("blender-refineries") that produce gasoline simply by combining gasoline blendstocks
obtained from other refineries.24 In the analysis section below from 2017 through 2019, the
number of crude oil refineries in the facility counts varies from 105 to 109.25 The number of
blender-refineries in the EPA's facility count varies from 289 to 335.26 Lastly, the number of
import facilities varies from 26 to 30, where all of an importer's import locations in one PADD
are typically reported as a single facility (e.g., an importer that imported gasoline into five
different locations in PADD 1 would report the total volume of imported gasoline under a single
"PADD 1" import facility).
B Analysis
1. Compliance with 10 ppm Annual Average Sulfur Standard
Gasoline sulfur concentrations trended down from 2017 through 2019, continuing their
downward trend from 2011 through 2016, as shown in Figure 1. As expected, the decrease in
annual average sulfur from 2016 to 2017 was only 2.7 ppm, much less than the 20 ppm decrease
in annual average sulfur standard from 2016 to 2017. Annual average sulfur exceeded 10 ppm
23	See Tables 1 through 3.
24	The EPA defines a refinery as "any facility, including but not limited to, a plant, tanker truck, or vessel where
gasoline or diesel fuel is produced, including any facility at which blendstocks are combined to produce gasoline or
diesel fuel, or at which blendstock is added to gasoline or diesel fuel". See 40 CFR 80.2(h). As part of the fuels
regulatory streamlining rule, EPA has replaced the definitions of refiner and refinery with fuel manufacturer and fuel
manufacturing facility, respectively. Also, a blender refiner is defined as a blending manufacturer. The new
definitions are in 40 CFR 1090.80.
25	The number of crude oil refineries was determined by comparing the list of reporting facilities with the annual
lists of refineries with crude distillation units, prepared by the U.S. Energy Information Administration as part of its
annual refinery capacity reports.
26	The number of blender-refineries was calculated by subtracting the number of crude oil refineries and import
facilities from the total number of reporting facilities. Blender-refineries also include a small number (between 5 and
8) of transmix processing facilities which distill transmix (i.e., pipeline interfaces of gasoline and distillate fuel) into
gasoline and distillate, and sometimes add other blendstocks to the gasoline distilled from the transmix.
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from 2017 through 2019, as refiners and importers used significantly more credits generated in
previous years to comply with the 10 ppm standard.27
Figure 1: Total Gasoline Volume and Average Sulfur from GSF030X Reports
35.0 	 125.0
30.0
25.0
20.0
15.0
10.0
5.0
u.u
2011
2012
2013
2014
2015
2016
2017
2018
2019
^HGSF030X Volume
114.8
115.0
114.9
116.1
119.5
122.2
122.5
122.8
123.2
GSF030X Sulfur
31.43
30.75
28.79
26.61
24.51
23.85
21.18
20.49
17.47
Sulfur standard (non-small)
30
30
30
30
30
30
10
10
10
120.0 <2
115.0
110.0
105.0 >
100.0
Figure 2 shows the number of facilities producing gasoline with an annual average sulfur
content over the applicable annual average standard, and the number of facilities producing
gasoline with an annual average sulfur content equal to or less than the applicable annual average
standard. From 2011 through 2016 the applicable annual average standard was 30 ppm for all
facilities. From 2017 through 2019, the applicable annual average standard was 30 ppm for all
small volume refineries and small refiners, and 10 ppm for all other facilities. The number of
facilities above the applicable standard increased significantly (from 51 to 208) from 2016 to
2017, then decreased to 191 facilities in 2019. Conversely, the number of facilities at or below
the applicable standard decreased significantly (from 371 to 238) from 2016 to 2017, then
increased to 286 facilities in 2019.
27 Refiners and importers reported on their 2011 GSF0100 reports that they held a total of 3,514 billion gasoline
sulfur credits as of January 1, 2017.
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Figure 2: Facilities Producing Gasoline with Annual Average Sulfur Above/Below Annual
Average Standard (pre-credits)

2011
2012
2013
2014
2015
2016
2017
2018
2019
Facilities above avg std
85
95
90
84
71
51
208
185
191
Facilities at or below avg std
257
297
331
327
337
371
238
251
286
Average standard (non-small)
30
30
30
30
30
30
10
10
10
Figure 3 shows the volume of gasoline produced by facilities that averaged over the
applicable annual average sulfur standards, and the volume of gasoline produced by facilities that
averaged equal to or less than the applicable annual average sulfur standard. The volume above
the applicable standard increased significantly (from 23.5 billion to 97.7 billion gallons) from
2016 to 2017, then decreased to 88.0 billion gallons in 2019. Conversely, the volume at or below
the applicable standard decreased significantly (from 98.6 billion to 24.8 billion gallons) from
2016 to 2017, then increased to 35.1 billion gallons in 2019.
12

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Figure 3: Volume of Gasoline Produced at Facilities with Annual Average Sulfur Above/Below
Annual Average Standard (pre-credits)
140.0	35

2011
2012
2013
2014
2015
2016
2017
2018
2019
Volume above avg std
61.1
57.1
47.3
47.8
37.5
23.5
97.7
95.7
88.0
Volume at or below avg std
53.5
57.8
67.6
68.3
82.0
98.6
24.8
27.1
35.1
^^^Average standard (non-small)
30
30
30
30
30
30
10
10
10
Figure 4 shows the average sulfur before and after use of gasoline sulfur credits from
2011 through 2019. The black bars (pre-credits) include all facilities, both credit generators, and
credit users (prior to use of any credits). The red bars (post-credits) include all facilities, both
credit generators, and credit users (after the use of credits). The difference between the black
and red bars increased from approximately 2.0 ppm in 2016 to approximately 10.5 ppm in 2017,
indicating an increase in the number of credits used for compliance with the 10 ppm average
sulfur standard, compared to credit use for compliance with the 30 ppm standard.28 By 2019, the
difference between the black and red bars had decreased to approximately 7.4 ppm, indicating a
decrease in the number of credits used for compliance.
28 The differences in sulfur before and after using credits in 2015 and prior years also include the effect of refiners
and importers using credits that they had generated and banked prior to 2011.
13

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Figure 4: Average Annual Sulfur Content Before and After Using Credits

35

30
E

Q.
Q.
25
3
20
3

OO

CD
15
CuO

(O

&_
CD
10
>

<


5

0
! i ,
i ii i
35
30
25

2011
2012
2013
2014
2015
2016
2017
2018
2019
Sulfur (pre-credits)
31.43
30.75
28.79
26.61
24.51
23.85
21.18
20.49
17.47
Sulfur (post-credits)
25.93
25.40
24.92
23.25
21.52
21.91
10.70
10.54
10.10
Average standard (non-small)
30
30
30
30
30
30
10
10
10
E
Q.
Q.
20 -a
c
CD
15
10
(D
tLO

<
2. Credit Generation and Use
Figure 5 shows total annual credit generation, use, and expiration from 2011 through
2019 for all refiners and importers, including small volume refineries and small refiners. Credit
generation increased by approximately 512 billion credits from 2011 through 2016, then
decreased by approximately 825 billion credits from 2016 to 2017, as fewer facilities produced
gasoline containing 10 ppm sulfur or less. Credit use decreased by approximately 395 billion
credits from 2011 through 2016, then increased by 1,048 billion credits from 2016 to 2017, as
more facilities produced gasoline containing more than 10 ppm sulfur. These changes in credit
generation and use from 2016 to 2017 were due to refiners and importers choosing to use "early'
Tier 3 credits in 2017 through 2019. The number of expired credits was relatively small in 2017
and 2018, indicating overall efficiency in management of credit inventories by refiners and
importers.29 However, expired credits increased to 560 billion in 2019, as all "early" Tier 3
credits, and credits generated by small refineries and small refiners under their temporary ABT
program from 2017 through 2019, expired under the Tier 3 regulations.
29 "Early" Tier 3 credits were generated under the Tier 2 program by refiners and importers prior to 2017, by
producing gasoline containing less than 30 ppm sulfur on an annual average basis. These credits all expired after the
2019 compliance period, resulting in over-compliance with the 30 ppm average sulfur standard.
14

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Figure 5: Credit Generation, Use and Expiration
1400.0
35

O
T3
CD
1200.0
1000.0
800.0
600.0
400.0
200.0
0.0

2011
2012
2013
2014
2015
2016
2017
2018
2019
Credits generated
464.8
525.0
582.0
773.4
999.9
976.6
151.2
161.7
189.2
Credits used
632.0
614.8
445.2
389.9
358.2
236.7
1284.7
1224.6
907.6
Credits expired
131.6
51.7
112.4
31.1
3.0
69.6
5.1
2.7
560.0
Average standard (non-small)
30
30
30
30
30
30
10
10
10
30
25
20

Q.
Q.
15 

-------
Figure 6: Credit Use (colors show year of credit generation)
T3
CD
T3
CD
1,400.0
1,200.0
.,000.0
800.0
600.0
400.0
200.0
0.0
credit
2011
I' ll
2012 2013 2014 2015 2016
Compliance Year
2017
2018
2019
12019
12018
12017
12016
12015
12014
12013
12012
12011
12010
2009
12008
12007
12006
C
o
!-h
(L)
c
(L)
O
T3
(L)
!-h
u
<+H
o
!-h
S3
(L)
Table 4: Credit Use (in billions), by Year of Credit Generation
Year of Credit Use

2011
2012
2013
2014
2015
2016
2017
2018
2019
2006
160.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
2007
155.6
260.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
2008
104.2
163.9
241.1
0.0
0.0
0.0
0.0
0.0
0.0
2009
141.5
52.1
29.5
293.9
0.0
0.0
0.0
0.0
0.0
2010
55.0
84.8
73.3
66.8
294.3
0.0
0.0
0.0
0.0
2011
14.9
43.4
50.4
13.4
46.0
224.1
0.0
0.0
0.0
2012
0.0
10.5
40.4
3.1
8.2
9.9
427.3
0.0
0.0
2013
0.0
0.0
10.6
10.5
4.4
1.0
462.9
106.6
0.0
2014
0.0
0.0
0.0
2.2
2.6
0.6
248.4
429.7
64.2
2015
0.0
0.0
0.0
0.0
2.6
0.9
88.2
489.0
336.8
2016
0.0
0.0
0.0
0.0
0.0
0.3
56.1
189.7
500.8
2017
0.0
0.0
0.0
0.0
0.0
0.0
1.9
9.1
4.0
2018
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.5
1.8
2019
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Total
632.0
614.8
445.2
389.9
358.2
236.7
1284.7
1224.6
907.6
Credits can be traded only twice before they are used, to enable reasonable enforcement
oversight of the program. Figure 7 and Table 5 present credit use data according to the number
of times credits were transferred between refiners and/or importers. CCO credits are credits that
were never transferred by the refiner or importer that generated them, CC1 credits are credits that
16

-------
were transferred once, and CC2 credits are credits that were transferred twice. Figure 7 and
Table 5 indicate that a significant percentage of credits used by refiners and importers each year
for compliance are obtained from other refiners and/or importers.31
Figure 7: Credit Use (colors show numbers of times credits were transferred)
1,400.0
1,200.0
 1,000.0
T3
CD
T3
CD
800.0
600.0
400.0
200.0
0.0
III.
2011 2012 2013 2014 2015 2016
Compliance Year
2017
2018
2019
ICC2
ICC1
ICCO
Table 5: Credit Use (in billions), by Number of Times Credits Transferred
Year of Credit
Use
Type of Credit Used
Total Use
CCO
CC1
CC2
2011
161.8
460.8
9.5
632.0
2012
177.4
378.2
59.2
614.8
2013
197.8
201.8
45.5
445.2
2014
85.2
255.6
49.2
389.9
2015
88.1
196.4
73.7
358.2
2016
104.2
116.6
16.0
236.7
2017
753.9
490.8
40.0
1,284.7
2018
787.2
392.4
45.0
1,224.6
2019
462.1
402.1
43.4
907.6
31 The limit on credit transfers only applied to transfers between companies (intercompany transfers). Companies
that owned more than one refinery and/or more than one import facility could transfer credits between their
refineries and import facilities (intracompany transfers) without limit. EPA is aware of a few instances where
refiners accidentally assigned a credit transfer code of CC1 (instead of CCO) to intracompany credit transfers, so the
number of intercompany-transferred credits is expected to be slightly less than indicated in Figure 7 and Table 5.
17

-------
Figure 8 shows the variation in the total number of usable credits held by all refiners and
importers each month from June, 2015 through June, 2020.32 Figure 8 shows that the biggest
changes in total usable credits held occurs in March of each year, and that the total number of
usable credits remained relatively constant for the remainder of the year for most years.33 Figure
8 also shows how the total number of usable credits held increased in 2015 and 2016, before
being drawn down significantly through use or expiration of credits in the 2017, 2018 and 2019
compliance periods.
Figure 8: Total Usable Credits Held by All Refiners and Importers
4,000
3,500
3,000
2,500
2,000
1,500
1,000
3. Combined Annual Data from GSF030X and GSF0100 Reports
Tables 6 through 14 show the combined data from the GSF030X reports and the
GSF0100 reports for each year from 2011 through 2019, summarizing the data for credit
generators, credit users, and total combined credit generators and users. Each table quantifies the
relationship between the number of reporting facilities, gasoline volume/sulfur, and quantity of
credits generated/used for each year.
For credit generators, each table shows the number of facilities that generated credits,
total gasoline production, average sulfur, and total credits generated. For credit users, each table
shows the number of facilities that used credits, total gasoline production, average sulfur before
use of credits, total credits used, and average sulfur after credit use. For some years from 2011
through 2016, average sulfur after credit use is slightly lower than 30 ppm due to over-
compliance by some facilities which used more credits than necessary to meet the 30 ppm
32	June of 2015 is the first month for which total numbers of credits were available from EMTS.
33	March is the last month during which refiners and importers can submit compliance reports for the previous
compliance year. EPA receives the bulk of its gasoline compliance reports in March.
18

-------
average sulfur standard. For 2017 through 2019, the results include information reported by
small volume refineries and small refiners, which continued to have an annual average
compliance standard of 30 ppm sulfur during this time, and information from all other refineries
and importers, which had an annual average compliance standard of 10 ppm sulfur beginning in
2017.
Table 6: 2011 Combined Data from GSF0301 and GSF0100 Reports
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSF0100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
257
53,474,891,296
21.27
464,872,004,037

21.27
Sulfur credit users
85
61,143,086,933
40.32

631,997,949,988
29.99
Total
342
114,617,978,229
31.43
464,872,004,037
631,997,949,988
25.93
Table 7: 2012 Combined Data from GSF0301 and GSF0100 Reports
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSF0100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
pm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
297
57,840,914,920
20.85
521,752,433,180

20.85
Sulfur credit users
95
57,139,164,526
40.76

614,752,724,705
30.00
Total
392
114,980,079,446
30.75
521,752,433,180
614,752,724,705
25.40
Table 8: 2013 Combined Data from GSF0301 and GSF0100 Reports
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSF0100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
331
67,617,998,125
21.36
581,985,499,587

21.36
Sulfur credit users
90
47,297,601,663
39.41

445,166,177,796
29.99
Total
421
114,915,599,788
28.79
581,985,499,587
445,166,177,796
24.92
Table 9: 2014 Combined Data from GSF0301 and GSF0100 Reports
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSF0100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
327
68,296,832,085
18.54
773,369,798,536

18.53
Sulfur credit users
84
47,841,073,575
38.13

389,948,545,636
29.99
Total
411
116,137,905,660
26.61
773,369,798,536
389,948,545,636
23.25
19

-------
Table 10: 2015 Combined Data from GSF0301 and GSF0100 Reports
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSFO100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
337
81,954,525,179
17.66
999,863,511,293

17.66
Sulfur credit users
71
37,524,437,331
39.48

358,167,066,402
29.95
Total
408
119,478,962,510
24.51
999,863,511,293
358,167,066,402
21.52
Table 11: 2016 Combined Data from GSF0301 and GSFO100 Reports
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSFO100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
371
98,634,876,413
19.99
976,572,320,993

19.99
Sulfur credit users
51
23,546,921,946
39.99

236,741,413,865
29.97
Total
422
122,181,798,359
23.85
976,572,320,993
236,741,413,865
21.91
Table 12: 2017 Combined Data from GSF0301 and GSF0100 Reports
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSFO100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
238
24,824,233,110
11.96
151,169,101,590

11.96
Sulfur credit users
208
97,704,257,887
23.53

1,284,698,534,287
10.37
Total
446
122,528,490,997
21.18
151,169,101,590
1,284,698,534,287
10.70
Table 13: 2018 Combined Data from GSF0301 and GSF0100 Reports
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSFO100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
251
27,060,133,076
10.05
161,687,588,154

10.05
Sulfur credit users
185
95,707,680,789
23.45

1,224,606,711,464
10.68
Total
436
122,767,813,865
20.49
161,687,588,154
1,224,606,711,464
10.54
20

-------
Table 14: 2019 Combined Data from GSF0301 and GSF0100 Reports
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSF0100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
286
35,100,701,584
9.06
189,176,187,090

9.06
Sulfur credit users
191
88,035,606,175
20.82

907,597,343,328
10.52
Total
477
123,136,307,759
17.47
189,176,187,090
907,597,343,328
10.10
4. Small Volume Refinery and Small Refiner Data
Tables 15 through 20 parse the data from Tables 12 through 14 into two separate tables for each
year, one table with data for small volume refineries and small refiners, and one table with data
for all other refiners and importers. Tables 15 and 16 show data for 2017, tables 17 and 18 show
data for 2018, and tables 19 and 20 show data for 2019. A total of 39 refineries were approved
under 40 CFR 80.1622 either as small volume refineries, or refineries owned by qualified small
refiners.34 Three of these refineries stopped producing gasoline before 2017, and two more were
disqualified in 2015 as small volume refineries under 40 CFR 80.1621(d), because they
processed more than 75,000 bpd crude oil on an annual average basis during 2015. Both of the
disqualified refineries began complying with the 10 ppm sulfur standard in late December,
2018.35
Tables 15 through 20 illustrate how small volume refineries and small refiners collectively
complied with the 30 ppm annual average sulfur standard from 2017 through 2019, and how the
remaining refiners and importers complied with the 10 ppm annual average sulfur standard
beginning in 2017. Annual average sulfur (before credit use) for small volume refineries and
small refiners ranged from 22.8 ppm in 2017 to 22.2 ppm in 2019, less than their 30 ppm annual
average standard, and required the use of only 53.2 billion credits total from 2017 through 2019.
Annual average sulfur (before credit use) for all other refineries and importers ranged from 21.0
ppm in 2017 to 17.0 ppm in 2019, above their 10 ppm annual average standard, and required the
use of 3.36 trillion credits total from 2017 through 2019.
Table 15 through 20 also show that the majority of credits generated from 2017 through 2019
were generated by small volume refineries and small refiners. A total of approximately 508.8
billion credits were generated by all refiners and importers from 2017 through 2019, including
307.7 billion credits generated by small volume refineries and small refiners, and 201.1 billion
credits generated by all other refiners and importers.
34	This total included 37 small volume refineries and 2 refineries owned by approved small refiners. Both of the
refineries owned by approved small refiners could have also qualified as small volume refineries because they
processed less than 75,000 bpd crude oil on an annual average basis during 2012.
35	Small volume refineries or small refiners that were disqualified had a 30 month grace period to begin complying
with the 10 ppm sulfur standard. For refineries disqualified in 2015, the grace period started June 21, 2016, which
was the effective date of a rulemaking which established the disqualification provisions in the Tier 3 gasoline sulfur
regulations.
21

-------
Of the 307.7 billion credits generated by small volume refineries and small refiners from 2017
through 2019, 283.5 billion credits were generated by refineries producing gasoline with an
annual average sulfur between 10 ppm and 30 ppm, and 24.2 billion credits were generated by
refineries producing gasoline with an annual average sulfur less than 10 ppm. The 283.5 billion
credits were generated under the temporary ABT program for small volume refineries and small
refiners, and were all either used by small volume refineries and small refiners from 2017
through 2019, or expired after 2019. The remaining 24.2 billion credits generated by small
volume refineries and small refiners could be used like the 201.1 billion credits generated by
other refiners and importers from 2017 through 2019.
Table 15: 2017 Combined Data from GSF0301 and GSF0100 Reports
Small Volume Refineries and Small Refiners
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSF0100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
30
10,148,048,885
19.69
104,650,642,484

19.69
Sulfur credit users
6
1,715,789,834
41.13

19,068,489,682
30.02
Total
36
11,863,838,719
22.79
104,650,642,484
19,068,489,682
21.18
Table 16: 2017 Combined Data from GSF0301 and GSF0100 Reports
Non-Small Volume Refineries, Non-Small Refiners, and Importers
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSF0100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
208
14,676,184,225
6.62
46,518,459,106

6.62
Sulfur credit users
202
95,988,468,053
23.21

1,265,630,044,605
10.02
Total
410
110,664,652,278
21.01
46,518,459,106
1,265,630,044,605
9.57
Table 17: 2018 Combined Data from GSF0301 and GSF0100 Reports
Small Volume Refineries and Small Refiners
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSF0100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
27
8,316,615,081
16.93
108,608,464,516

16.93
Sulfur credit users
9
3,249,110,645
36.56

21,351,283,894
30.00
Total
36
11,565,725,726
22.44
108,608,464,516
21,351,283,894
20.60
22

-------
Table 18: 2018 Combined Data from GSF0301 and GSF0100 Reports
Non-Small Volume Refineries, Non-Small Refiners, and Importers
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSF0100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
224
18,743,517,995
6.99
53,079,123,638

6.99
Sulfur credit users
176
92,458,570,144
22.99

1,203,255,427,570
10.00
Total
400
111,202,088,139
20.29
53,079,123,638
1,203,255,427,570
9.49
Table 19: 2019 Combined Data from GSF0301 and GSF0100 Reports
Small Volume Refineries and Small Refiners
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSF0100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
24
7,973,909,082
18.16
94,404,778,041

18.16
Sulfur credit users
8
2,447,053,084
35.23

12,783,875,809
30.00
Total
32
10,420,962,166
22.17
94,404,778,041
12,783,875,809
20.94
Table 20: 2019 Combined Data from GSF0301 and GSF0100 Reports
Non-Small Volume Refineries, Non-Small Refiners, and Importers
Report
GSF0301
GSF0301
GSF0301
GSF0100
GSF0100
GSF0301

Number of
facilities
Gasoline
produced,
gallons
Average
sulfur,
ppm
Total credits
generated,
ppm-gallons
Total credits used,
ppm-gallons
Average sulfur
after credit use,
ppm
Sulfur credit generators
262
27,126,792,502
6.38
94,771,409,049

6.38
Sulfur credit users
183
85,588,553,091
20.41

894,813,467,519
9.96
Total
445
112,715,345,593
17.03
94,771,409,049
894,813,467,519
9.10
5. Compliance with 80 ppm Per-Gallon Standard
Figure 9 illustrates how sulfur in individual batches of gasoline changed from 2017 to
2019. Based on batch data submitted in the RFG030X reports, Figure 9 shows the percentage of
total gasoline for 2017 (orange line) and 2019 (blue line), as a function of sulfur content (in 1
ppm increments). As expected, the 2019 distribution curve is shifted to the left compared to the
2017 curve, due to sulfur reductions by refiners and importers from 2017 to 2019.
Figure 9 also illustrates compliance by refiners and importers with the 80 ppm per-gallon
sulfur standard. The right side of the curve indicates that a small percentage (0.0019 percent) of
total gasoline exceeded the 80 ppm per-gallon standard in 2017, and approximately the same
percentage (0.003 percent) exceeded 80 ppm in 2019. From 2017 through 2019, a total of only
105 batches out of approximately 180,000 batches were reported containing more than 80 ppm
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sulfur. Ninety nine of these batches were reported in 2018, and were blendstocks which were
added to previously certified gasoline (PCG), where the final blends of blendstock and PCG had
a sulfur content less than 80 ppm. Another 3 of these batches contained less than 95 ppm sulfur,
which is the per-gallon sulfur standard downstream of refineries and import facilities. The
remaining 3 batches were reported with a sulfur concentration of 970 ppm, which is the default
sulfur concentration specified in 40 CFR 80.80 that is used when a refiner or importer doesn't
have a sulfur test result for a batch of gasoline.
The total volume of these 105 batches was 26 million gallons, which represented
approximately 0.007 percent of the total reported volume of 363 billion gallons from 2017
through 2019. Most of this volume (20 million gallons) was blendstocks that were blended into
PCG, where each blend of PCG and blendstock was tested to ensure that the sulfur of the blend
was less than 80 ppm, Therefore, all gasoline used in vehicles was likely to have been below the
95 ppm downstream per-gallon standard.
Figure 9: Annual Distribution of Gasoline Sulfur Content in 2017 and 2019 (from RFG030X
Reports)
6,000
5,000
5 4,000
= 3,000
o 2,000
1,000
2019
2017
-----Per-gallon maximum
40	60
Sulfur content, ppm
80
100
6. 2020_Gasoline Sulfur Data Submitted to EPA
At the time this report was published, EPA had not yet received annual gasoline sulfur
reports for 2020. However, EPA had received RFG0303 gasoline batch reports from refiners
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and importers for all RFG produced or imported during the first two quarters of 2020.36
These batch reports include the volume and properties of each batch of RFG produced or
imported during the first six months of 2020, including the sulfur concentration of each
batch. The total volume of gasoline included in these reports is 13.74 billion gallons, and the
average sulfur content of this volume is 7.7 ppm. Although this volume represents only
approximately 11% of 2019 total gasoline production and importation, EPA believes the
relatively low average RFG sulfur concentration for the first 6 months of 2020 indicates
significant progress by refiners and importers towards complying with the 10 ppm annual
average sulfur standard in 2020. Also, although the sulfur concentration of CG produced in
2020 is unknown to EPA at this time, the annual average sulfur concentrations of CG and
RFG have been relatively close since 2011, as shown in Table 21 below.
Table 21: Annual Average Sulfur Concentrations for CG and RFG from RFG030X Reports
Year
Annual average sulfur,
ppm
Sulfur difference,
ppm

CG
RFG
(CG minus RFG)
2011
31.57
31.28
0.29
2012
30.71
31.25
-0.54
2013
29.08
28.36
0.72
2014
26.08
28.08
-2.00
2015
25.01
23.37
1.64
2016
23.96
23.83
0.13
2017
20.99
21.54
-0.55
2018
20.36
20.52
-0.16
2019
17.32
17.21
0.11
36 Refiners and importers are required to submit RFG030X batch reports on a quarterly basis for all RFG produced
or imported during each quarter. Refiners and importers are only required to submit RFG030X batch reports on an
annual basis for all CG produced or imported during a compliance year.
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IV. Conclusion
The gasoline sulfur analysis presented in this report shows a high level of compliance
with refinery and importer annual average and per-gallon sulfur standards under the Tier 3
gasoline sulfur program from 2017 through 2019, and a significant increase in the use of gasoline
sulfur credits for compliance with the 10 ppm annual average standard beginning in 2017. The
gasoline sulfur credit program analysis further illustrates the beneficial flexibility it has provided
the industry in lowering gasoline sulfur levels over time.
Compliance data reported to the EPA by refiners illustrates several key findings:
	Refiners and importers have taken full advantage of the flexibilities of the ABT
program to reduce sulfur levels at a rate and time that is most conducive to their
business plans.
	The national annual average reported sulfur content of gasoline, before credits,
decreased from 21.18 ppm in 2017 to 17.47 ppm in 2019.
	Although EPA has only limited reporting of 2020 data at this time, the data we have
suggests that the average gasoline sulfur concentration for 2020 will be below 10 ppm
without the use of credits (see Section III.6 for a discussion of the available 2020
data).
	Tier 3 credit generation (beginning in 2017) was much lower than Tier 2 credit
generation, as refiners and importers generated a total of 224.3 billion standard Tier 3
credits (i.e., credits with a 5 year life) from 2017 through 2019, compared to 976.6
billion Tier 2 credits generated in 2016.
	The percentage of gasoline produced or imported at facilities averaging 10 ppm sulfur
or less on an annual basis increased from 20.3 percent in 2017 to 28.5 percent in
2019.
	Refiners and importers used large quantities of sulfur credits for compliance with the
10 ppm annual average standard in 2017 through 2019, but still let560 billion credits
expire at the end of the 2019 compliance period, including both "early" Tier 3 credits
and credits generated by small volume refineries and small refiners.
	Small volume refineries and small refiners successfully utilized the provisions in the
Tier 3 regulations which allowed them 3 additional years to comply with the 10 ppm
annual average sulfur standard.
This report, along with other fuels trends analyses and sulfur compliance credit data
posted on the agency's website, provide comprehensive information about the EPA's national
gasoline sulfur control programs and their effects in reducing gasoline sulfur levels in the U.S.37
The EPA will continue to make gasoline sulfur data available to maximize the transparent
implementation of its regulatory programs.
37 See https://www.epa.gov/fiiels-regisfration-reporting-aiid-compliance-help/pnblic-data-gasoline-programs.
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V. Appendix
Life of a Standard Sulfur ABT Credit
Life of a Standard Sulfur Credit
o
r\i
I
-
T3
O
100,000 gallons of
gasoline produced at
refinery or imported in
calendar year 2017.
Each 2017 batch of gasoline is tested for sulfur content per 80.1630
The 2017 batch results are used to calculate the annual average sulfur
content per 80.1603(c). In this example, the result is 3.41 ppm for 2017
2017 Credit Generation Calculation (to be reported by March 31, 2018)
(10 ppm less 3.41 ppm) * 100,000 gallons = 659,000 credits (ppm-gal)
659,000 Sulfur Credits Generated in CY 2017
Credits available for 2018 - 2022 compliance years (5 years)
Credits may be traded twice in their 5-year lifetime
Producer/Importer
GENERATES 659,000
Sulfur Credits

Trade 1
o
r\i
Credit Generator
RETIRES 250,000
Credits to meet
2018 compliance
obligation
ZZL
Credit Generator
TRADES 300,000
Credits to
Importer A
o
rsl
o
rsl
o
rsl
QradeP^
Credit Generator
TRADES 100,000
Credits to
RefinerX
Orade2^)
X
Importer A TRADES
200,000 Credits to
Refiner Y
(these credits cannot
be traded againj
s
Importer A
RETIRES 100,000
Credits to meet
2020 compliance
obligation
r\i
O
r\i
RefinerY RETIRES
200,000 Credits
to meet 2021
compliance
obligation
r\i
r\i
O
r\i
RefinerX RETIRES
100,000 Credits
to meet 2022
compliance
obligation
Credit Generator did
not use or trade 9,000
credits; these will
EXPIRE no later than
March 31, 2023
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