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NORA Statement Regarding AOCA November Government Affairs Update

Wednesday, December 4, 2019  
Posted by: Lauren Groves
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NORA appreciates its long-standing working relationship with the Automotive Oil Change Association (AOCA). However, AOCA’s “November 2019 Government Affairs Update” inaccurately represented NORA’s position and presentation to the US Department of Energy (DOE) Stakeholder Meeting. This statement will correct the record.

On March 27, 2017, US Representative Susan Brooks (R-IN) introduced House Resolution 1733. On December 21, 2018, President Trump signed HR 1733. The legislation specifically directs “the Secretary of Energy to review and update a report on the energy and environmental benefits of the re-refining of used lubricating oil.”

It called for the Department of Energy (DOE) to review and update the report prepared by DOE in 2006 by the end of 2019. In addition, the DOE is directed to prepare and submit to Congress a coordinated Federal strategy to increase the beneficial reuse of used lubricating oil, that—

increase the responsible collection of used oil;
disseminate public information concerning sustainable reuse options for used oil; and
promote sustainable reuse of used oil by Federal agencies, recipients of Federal grant funds, entities contracting with the Federal Government, and the general public.

Congress required the DOE to consult with relevant affected industry and stakeholder groups. NORA is the only trade association that has members in every sector of the oil recycling industry (major oil companies, generators, collectors, processors and re-refiners, space heater manufacturers, end users and government agencies). Because of that, NORA has served as a primary association stakeholder on this important project. 

In February 2019, the NORA Board of Directors met to review the association’s position and strategy related to HR 1733. The Board unanimously agreed that NORA would reiterate its support for 40 CFR Part 279 (the current Standards for the Management of Used Oil). Additionally, the NORA Board directed that the association’s focus should be on increased collection of used oil and better ongoing data analysis.

Those NORA positions were provided during the October DOE Stakeholder meeting. However, AOCA misrepresented NORA’s position in their November Update. For the record:

• NORA did not tell DOE that generators are the problem;
• NORA did not recommend more government oversight of the generator community;
• NORA did not state that commercial generators would not comply with basic management standards; and
• NORA did not suggest the elimination of used oil-fired space heaters.

NORA did raise two important issues of concern related to future collections. It is widely believed that the vast majority of gallons that are not collected (i.e. non-permitted activity) are related to DIY used oil. The key to collecting DIY used oil is convenience for the DIY oil changer. NORA identified two concerns to the DOE that potentially could decrease the number of drop off locations for DIY used oil and therefore increase non-permitted activity and decrease the responsible collection of used oil.

First, NORA informed the DOE about the upcoming IMO 2020 regulation that goes into effect on January 1, 2020 that will reduce the maximum sulfur content in marine fuels worldwide from 3.5% to 0.5%. The magnitude of this sea change appears massive, affecting about 4 million barrels per day (bpd) or about 4% of the total crude oil production worldwide. It is widely believed that this will generally create downward pressure on the value of used oil derived products. There is evidence that when oil prices fell sharply in 2016, certain generators stopped accepting DIY oil because of the cost factor. That is allowed by 279; however it does reduce the DIY drop off locations. NORA raised the question if increased enforcement might be necessary of the DIY community if they have fewer outlets to ensure used oil is not ending up in landfills, waterways, etc.

Second, NORA encouraged the DOE federal strategy to include encouragement of the EPA to reconsider NORA’s PCB Proposal. Under the current system, there is real risk associated for AOCA members that accept DIY used oil and unmanned municipal drop off locations. There is no field test for PCB’s. NORA members, AOCA members and municipal drop off locations are improperly penalized when PCB DIY used oil ends up in the collection stream by bad actors. A single PCB ‘hit’ can shut down these types of DIY programs. NORA’s proposal would dramatically improve the situation for NORA and AOCA members.

NORA appreciates the opportunity to correct the record. NORA will continue to work with AOCA on important issues of interest to memberships of both organizations to ensure that every gallon of used oil is responsibly recycled.

 

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