Fuel Delivery Temperature Study Report
Fuel Delivery Temperature Study Report
CALIFORNIA
ENERGY
COMMISSION
FUEL DELIVERY
TEMPERATURE STUDY
COMMITTEE REPORT
January 2009
CEC-600-2009-002-CTF
DISCLAIMER
ACKNOWLEDGEMENTS
The authors wish to express appreciation to those who have provided input and support in the
production of this report.
California Energy Commission Staff
Paul Deaver
Nicholas Janusch
Karen Kasuba
Robert Kennedy
Laura Lawson
Keith O’Brien
Sherry Stoner
Gerald Zipay
California Department of Food and Agriculture, Division of Measurement Standards Staff
Ron Flores
Ken Lake
Roger Macey
Dan Reiswig
Edmund Williams
California Air Resources Board Staff
Steve Brisby
Fred Schmidt
Other Individuals
Ross Anderson – New York Department of Agriculture and Markets
John Elkins – California State Water Resources Control Board
Kurt Floren – Los Angeles County Agricultural Commissioner
David Lazier – Sacramento County Weights and Measures
Craig Mattimoe
George Mattimoe
Mark Thompson ‐ Measurement Technology International (MTI), LTD
i
Advisory Group
• AAA of Northern California, Nevada & Utah
• American Petroleum Institute
• American Trucking Association
• Arizona Department of Weights and Measures
• Arizona Petroleum Marketers Association
• Boyett Petroleum
• California Air Resources Board
• California Independent Oil Marketers Association
• California Trucking Association
• California Department of Food and Agriculture’s Division of Measurement Standards
• Hawaii Department of Weights and Measures
• Kraus Global, Inc
• Los Angeles County Weights and Measures Department
• Measurement Technology International, LTD
• Metercal
• National Association of Truck Stop Operators
• Natural Resources Defense Council
• New York Department of Agriculture and Markets Bureau of Weights and Measures
• Owner Operator Independent Driver Association
• Petroleum Marketers Association of America
• Public Citizen’s Energy Program
• Sacramento County Department of Weights and Measures
• Society of Independent Gasoline Marketers
• The Foundation for Taxpayer and Consumer Rights
Please use the following citation for this report:
Gordon Schremp and Nicholas Janusch, 2009. Fuel Delivery Temperature Study, California Energy
Commission. CEC‐600‐2009‐002‐CTF.
ii
TABLE OF CONTENTS
LIST OF FIGURES .................................................................................................................................... v
LIST OF TABLES ..................................................................................................................................... vi
ABSTRACT .............................................................................................................................................. vii
EXECUTIVE SUMMARY ........................................................................................................................ 1
PRIMARY RECOMMENDATIONS ..................................................................................................... 3
AREAS FOR FURTHER RESEARCH.................................................................................................... 4
CHAPTER 1: Introduction ....................................................................................................................... 5
Background .............................................................................................................................................. 5
California Issues ...................................................................................................................................... 9
Assembly Bill 868 .................................................................................................................................. 10
CHAPTER 2: Other Approaches and Studies .................................................................................... 14
Other Approaches to Retail Temperature Compensation .............................................................. 14
Other Studies ......................................................................................................................................... 17
CHAPTER 3: Data Collection and Analysis ....................................................................................... 21
Transportation Fuel Volumes ............................................................................................................. 21
Retail Fuel Prices ................................................................................................................................... 23
Fuel Temperature Study ...................................................................................................................... 25
Fuel Density ........................................................................................................................................... 37
CHAPTER 4: ATC Retrofit Option ...................................................................................................... 57
Cost‐Benefit Analysis Approach and Methodology ........................................................................ 57
Costs (Equipment, Labor and Inspection) ......................................................................................... 58
Potential Consumer Benefits Resulting From ATC Retrofit ........................................................... 73
Retail Station Characteristics and Trends.......................................................................................... 81
CHAPTER 5: New Reference Temperature Option.......................................................................... 85
Overview ................................................................................................................................................ 85
Costs ....................................................................................................................................................... 86
Benefits ................................................................................................................................................... 87
Potential Net Costs or Benefits ........................................................................................................... 87
Compliance Schedule ........................................................................................................................... 87
CHAPTER 6: Related Issues .................................................................................................................. 89
Permissive vs. Mandatory ATC at Retail Stations ........................................................................... 89
Labeling .................................................................................................................................................. 91
Authority to Activate Retail ATC ....................................................................................................... 95
iii
Implementation Timeline Options for Retail ATC .......................................................................... 96
ATC and Other Liquid Transportation Fuels ................................................................................. 101
Leak Detection – Potential Benefit .................................................................................................... 102
Applicability of Findings to Other Regions of the United States ................................................. 103
CHAPTER 7: Findings and Recommendations ............................................................................... 105
Findings (Sequential Order) .............................................................................................................. 105
Recommendations .............................................................................................................................. 116
GLOSSARY OF ACRONYMS .............................................................................................................. 120
APPENDIX A: County Demand and Percentages ............................................................................ 123
APPENDIX B: NCDC Average Ambient Temperatures .................................................................. 124
APPENDIX C: Fuel Temperature Regression Results ...................................................................... 125
APPENDIX D: Modified DMS Temperature Survey Data ............................................................... 129
APPENDIX E: Canada Fuel Density Values ...................................................................................... 130
APPENDIX F: Distribution Terminal Survey .................................................................................... 131
APPENDIX G: Biodiesel Density ......................................................................................................... 133
APPENDIX H: B20 Density .................................................................................................................. 134
APPENDIX I: Fuel Dispenser Survey ................................................................................................. 135
APPENDIX J: ATC Retrofit Kit Equipment Costs ............................................................................. 136
APPENDIX K: ATC Retrofit Kit Labor Costs ..................................................................................... 137
APPENDIX L: County Sealers and Equipment Costs ....................................................................... 138
APPENDIX M: ATC Retrofit Total Costs ........................................................................................... 139
APPENDIX N: High Case Financing Costs ........................................................................................ 140
APPENDIX O: Low Case Financing Costs ......................................................................................... 141
APPENDIX P: Retail Station Average Fuel Sales .............................................................................. 142
APPENDIX Q: At Risk Retail Station Costs ....................................................................................... 143
APPENDIX R: Valuation of Reduced “Gallons” Sold ...................................................................... 144
APPENDIX S: Information Asymmetry ............................................................................................. 145
iv
LIST OF FIGURES
Figure 1: Assembly Bill No. 868 ............................................................................................................. 13
Figure 2: California Monthly Average Retail Fuel Prices ................................................................... 24
Figure 3: NIST Results for California .................................................................................................... 27
Figure 4: DMS Temperature Survey Sample Points............................................................................ 28
Figure 5: Alameda County Gasoline Temperature – Actual vs. Predicted ...................................... 31
Figure 6: Los Angeles County Gasoline Temperature – Actual vs. Predicted ................................ 32
Figure 7: Other Factors Influencing Fuel Temperature ...................................................................... 33
Figure 8: California Regular Grade Gasoline – Prover Less UST Temperature .............................. 34
Figure 9: California Premium Grade Gasoline – Prover Less UST Temperature ........................... 35
Figure 10: California Diesel Fuel – Prover Less UST Temperature ................................................... 35
Figure 11: California Monthly Average Prover Temperatures .......................................................... 36
Figure 12: AAM Survey Results – Summer 2006 ................................................................................. 39
Figure 13: AAM Survey Results – Winter 2007 .................................................................................... 40
Figure 14: California Refinery Gasoline – Relative Density Distribution ........................................ 42
Figure 15: Regular Grade Summer Gasoline Density – United States and
California Comparison ........................................................................................................................... 43
Figure 16: United States Gasoline – Seasonal Density Distribution .................................................. 44
Figure 17: AAM Survey Results – Diesel Fuel ..................................................................................... 46
Figure 18: California Refinery Diesel Fuel – Relative Density Distribution .................................... 48
Figure 19: Summer Diesel Fuel Density – United States and California Comparison ................... 49
Figure 20: United States Diesel Fuel – Seasonal Density Distribution ............................................. 49
Figure 21: California Ethanol Use in Gasoline – 1980 Through 2007 ................................................ 51
Figure 22: Diesel Fuel and Biodiesel – Density Distribution ............................................................. 54
Figure 23: Historical Prime Rate ............................................................................................................ 66
Figure 24: ATC Retrofit Kit ..................................................................................................................... 69
Figure 25: Service Station of the Past – 1936 ......................................................................................... 81
Figure 26: United States Convenience Store Pre‐Tax Profits ............................................................. 82
Figure 27: United States Convenience Store Financial Trends .......................................................... 83
Figure 28: United States Convenience Store Per‐Gallon Margins ..................................................... 84
Figure 29: Example of Fuel Dispenser Label ........................................................................................ 92
Figure 30: Potential ATC Implementation Options – NCWM........................................................... 97
v
LIST OF TABLES
Table 1: California Counties With Temperature Data ........................................................................ 29
Table 2: California Annual Average Prover Temperatures ............................................................... 37
Table 3: California Refinery Production Properties – Summer of 2006 Gasoline ........................... 41
Table 4: California Refinery Production Properties – Summer of 2006 Distillate ........................... 47
Table 5: ATC Retrofit Kit Costs by Dispenser Attributes ................................................................... 60
Table 6: ATC Retrofit Costs Summary .................................................................................................. 70
Table 7: ATC Retrofit – CBA Low Cost Summary .............................................................................. 77
Table 8: ATC Retrofit – CBA High Cost Summary ............................................................................. 78
Table 9: Gradual ATC Phase‐in – CBA Cost Summary ...................................................................... 79
Table 10: Mandatory ATC Compliance Schedule Options .............................................................. 100
vi
ABSTRACT
This report was prepared in response to AB 868 (Davis, Chapter 398, Statutes of 2007). The bill
directs the California Energy Commission to conduct a cost‐benefit analysis and make
recommendations relative to the implementation of Automatic Temperature Compensation
devices at retail service stations. Like many other liquids, fuel experiences expansion and
contraction with temperature change. So the warmer the fuel, the less energy and fewer miles to
the gallon a vehicle will receive. The Energy Commission analyzed and compared the options
of retaining the current reference temperature of 60 degrees Fahrenheit, establishing a different
statewide reference temperature, and requiring the installation of automatic temperature
compensation equipment at retail.
Keywords: ATC, automatic temperature compensation, diesel, fuel dispensers, fuel
temperature, gasoline, prover temperature, reference temperature, temperature compensation,
volume correction factor, weights and measures
vii
EXECUTIVE SUMMARY
The issue of reduced volumes of gasoline or diesel when distributed at high temperature, or
“hot fuel,” is not new. It is, however, a controversial subject that has created strong and
divergent opinions. Some stakeholders believe that if temperature compensation was practiced
at retail stations, motorists would realize significant monetary benefits in the warmer areas of
the United States. Other stakeholders representing business interests believe that the costs to
retail station owners will be significant.
Hawaii is the only state that has adopted temperature compensation at retail outlets by
allowing existing retail fuel dispensers to be modified to distribute an additional quantity of
fuel (as measured in cubic inches) to compensate that the fuel sold is warmer. Hawaii’s retail
sales unit of gasoline is now 233.8 cubic inches, roughly equivalent to how much a standard
gallon of gasoline would expand when warmed from 60 to 80 degrees Fahrenheit. Canada, too,
has adopted regulations and standards for automatic temperature compensation (ATC) at retail.
Even though ATC at retail is voluntary in Canada, more than 90 percent of the retail stations
have converted to using the equipment. Most of the time in Canada, the temperature of the fuel
is colder than the reference standard of 60 degrees Fahrenheit. The ATC dispensers compensate
for colder fuel temperatures by decreasing the average size of the liter dispensed to motorists in
that country.
This national debate has continued for several years but without any analysis being performed
to determine if ATC at retail stations would be a net benefit to retail motorists. As a result of
these activities and the lack of analysis, in October 2007 the California Legislature passed and
the Governor signed Assembly Bill 868 (Davis), which directed the California Energy
Commission to conduct a cost‐benefit analysis.
This report quantifies the benefits and costs associated with temperature compensation for
retail sales of gasoline and diesel fuels in California. The cost‐benefit analysis concludes that the
results are negative or a net cost to society under all the options examined, however when
quantified by cents per gallon these costs are small. The estimated total annual recurring net
costs to society, if completely passed through to consumers, could amount to between eight
hundredths (8/100) and 18 hundredths (18/100) of a cent per gallon. It is also unlikely that there
are any plausible circumstances consumers could receive a small net benefit with installed ATC
devices at California’s retail stations.
The primary issues associated with the ATC debate is best characterized in a series of questions.
• Is the temperature of gasoline and diesel fuel sold to California consumers warmer, on average, than
the 60 degree Fahrenheit reference standard?
1
California is considered a warmer state regarding fuel temperature at retail stations. Based on
the results of a recent survey of retail stations, the average temperature of regular grade
gasoline during the base period from April 2007 through March 2008 was about 71 degrees
Fahrenheit. Diesel fuel was a little warmer with an average temperature of nearly 73 degrees
Fahrenheit.
• If temperature compensation has been instituted for most wholesale transactions to remove the
inequity of temperature variations, why has that practice not extended to the California retail
consumer?
Currently, no retail station operator has chosen to install and operate ATC‐ready dispensers in
California, and it is unclear whether the voluntary use of ATC devices is permitted under
California law.
• If ATC was mandated at retail stations in California, how would businesses and consumers be
impacted? Would the overall costs outweigh any potential benefits?
California retail motorists are expected to receive slightly larger gallons (as measured in cubic
inches) that vary in size with changes in temperature. ATC devices adjust for warmer fuel
temperatures by slightly increasing the size of the gallon dispensed to California consumers (in
cubic inches). The adjustment for the motorist would be approximately 1 percent for every 15
degree Fahrenheit increase in the temperature of gasoline greater than the reference standard of
60 degrees Fahrenheit. The slightly larger and variable sized gallons (in cubic inches) would not
have changed the total amount of fuel consumed in the state as measured in cubic inches, but
would have reduced the actual number of net or adjusted gallons purchased by motorists.
If ATC had been installed at retail gasoline stations during the one‐year study period, the
quantity of net gasoline gallons sold would have been approximately 15.5 billion or about 117
million gallons less compared to status quo (no ATC at retail outlets) because the fuel was
warmer (71.1 degrees Fahrenheit) than the 60 degree Fahrenheit reference standard.
Under the ATC scenario, the quantity of net diesel fuel gallons sold would have been
approximately 3.037 billion or about 19 million gallons less compared to the status quo (no ATC
at retail) of 3.056 billion because the fuel was also warmer (72.9 degrees Fahrenheit) than the 60
degree Fahrenheit reference standard.
Currently, motorists compare retail fuel prices when deciding where to purchase fuel for their
vehicle. Prices posted by two retail stations at an intersection showing identical prices may
appear to be equivalent in value by the consumer, but if the fuel temperature at one station is
higher than the other, the motorist would want to select the station with the cooler fuel
temperature. If ATC were mandated for use at retail stations, consumers would be able to more
accurately and fairly compare prices because variations in temperature would be corrected by
2
the ATC equipment. California consumers could expect a slight financial benefit of
approximately $258,000 per year due to this increased price transparency.
California retail station owners would experience additional expenses for the ATC retrofit
equipment and slightly higher inspection fees. If ATC devices are mandated, California
businesses would incur a total first cost between $103.8 million and $127.4 million, or between
$10,704 and $13,136 per retail outlet. Recurring costs for more expensive ATC‐ready dispensers,
maintenance, and higher inspection fees would total between $7.4 million and $20.6 million per
year.
The initial ATC retrofit costs combined with the recurring annual expenses would average
between eight hundredths (8/100) and 18 hundredths (18/100) of a cent per gallon, if retail
station owners pass through all of the retrofit expenses by raising fuel prices over 10 to 15 years.
• Would retail station owners charge the same price if ATC equipment is installed and dispensed
slightly larger sized gallons when fuel is warmer than the 60 degree Fahrenheit standard? If so,
would consumers still receive anticipated financial benefits?
If retail station owners and operators continue to grow and remain profitable, then retail station
owners will most likely raise their fuel prices to compensate for selling fewer “gallons.” If this is
the case then expected benefits for retail motorists will be essentially zero.
• If a new reference temperature was mandated, would the overall costs to businesses and governmental
agencies to implement and oversee the program outweigh any potential benefits?
The estimated costs of adopting a new reference temperature and a larger gallon size (in cubic
inches) could total between $9 million and $27.9 million or from $925 to $2,879 per retail station.
On a per‐gallon basis these additional expenses incurred by retail station owners would be
between five hundredths (5/100) and 15 hundredths (15/100) of a cent per gallon for only one
year. After the modifications were completed, there would be no additional recurring costs for
businesses or consumers.
Primary Recommendations
• If the only criterion for assessing the merit of mandatory ATC installations for use at
California retail stations is a net benefit to consumers, the Transportation Committee
(Committee) of the California Energy Commission concludes that ATCs should not be
required since the results of the cost‐benefit analysis show a net cost for consumers.
• However, the Committee recommends that the Legislature also consider whether the value
of the public perception of increased fairness, accuracy, and consistency of fuel
measurement, in addition to the benefits quantified in the cost‐benefit analysis, justify
mandating ATC at California retail stations.
3
• If the Legislature chooses to mandate the use of ATC at retail stations, two options are
available: (1) require all retail stations to retrofit their fuel dispensers over a two‐year
period, or (2) a more gradual phase‐in approach, requiring new and refurbished stations to
install, but not activate, ATC devices over a five‐year period. The remainder of retail
stations would be required to install ATC devices during the fifth year, and all stations
would activate their devices at the end of that year. Such a phase‐in approach is the least‐
cost option for mandatory ATC, although it would still result in a net cost to society.
• If the Legislature chooses not to mandate the use of ATC at retail stations, they should
clarify if the current intent of the existing statutes is to permit or prohibit voluntary ATC at
retail outlets for gasoline and diesel fuel.
• If the Legislature chooses to permit or mandate ATC at retail, they should direct the
California Division of Measurement Standards to develop standards addressing equipment
approval, certification testing, compliance enforcement, and consumer labeling provisions
for ATC at retail stations.
• Based on the report analysis, the Committee concludes that establishing a new statewide
reference temperature, or different regional reference temperatures for the state, would not
successfully address temperature compensation at the retail level and therefore does not
recommend this approach.
4
CHAPTER 1:
Introduction
Background
Expansion and Contraction of Liquids
Liquids, regardless of type, expand and contract within the space they occupy under varying
temperatures. Increasing temperatures will cause a liquid to expand and occupy a slightly
larger volume. The converse is also true, as decreasing temperatures will cause a liquid to
contract in volume. Usually, the less dense a liquid is, the greater its capacity to expand and
contract with equivalent temperature changes. These expansion and contraction characteristics
only apply as long as the material remains a liquid.1
The importance of these physical changes in volume due to changes in temperature has been
known for more than a century by the petroleum industry. It was determined that fluctuation in
a liquid’s temperature could alter the quantity of product available for sale or use. For example,
a refiner would purchase warm crude oil from an oil field producer and place the oil in storage
tanks before processing. Before distillation, the oil cools down to ambient temperature, and the
volume that the liquid occupies shrinks in size, resulting in fewer barrels available to the refiner
than were originally purchased from the producer. Likewise, petroleum fuels stored in above
ground tanks at refineries or distribution terminals can expand at warmer (and contract at
cooler) ambient temperatures, creating variation in the energy content of a gallon of fuel sold at
wholesale.
To remedy these types of potential wholesale transaction inequities, a national standard
reference temperature of 60 degrees Fahrenheit was adopted, enabling a seller and buyer to
calculate the exact number of standard gallons (231.0 cubic inches at 60 degrees Fahrenheit)
involved in a transaction, regardless of the temperature of the fuel at the time of the sale.
However, gasoline and diesel fuel sold at retail in California is not adjusted to compensate for
variations in temperature, leading to concerns over potential inequities for motorists.
1 Liquids that reach a temperature point when a transition to a gaseous phase initiates will no longer
adhere to their coefficient of expansion. Also, as liquids cool to the point that a transition to a solid phase
begins, the material will begin to exhibit different properties of contraction or possibly expanding as in
the case with water freezing.
5
Net (Standard) and Gross (Non-standard) Gallons
Various units of measurement are used in this report when describing petroleum sales
transactions. Gallons of transportation fuel are normally expressed in common usage in two
ways: net or gross.
“Net gallons” is a phrase used throughout this document and is a shorthand version familiar to
most people and the petroleum industry alike. However, the more precise terminology is
standard or temperature‐assigned gallons. A standard gallon is a specific volume of fuel (231.0
cubic inches) at an exact temperature (60 degrees Fahrenheit), which is why net gallons are also
expressed as temperature‐assigned gallons. The other phrase, “gross gallon”, is normally used
to express the types of gallons transacted at retail stations. The more precise terminology,
although, is either “non‐standard” or “unit” gallons. A non‐standard gallon is a specific volume
of fuel (231.0 cubic inches) dispensed at any temperature. A standard (net) and non‐standard
(gross) gallon of gasoline would only be equivalent in volume (231 cubic inches) when the
temperature is exactly 60 degrees Fahrenheit). At any other temperature, these two different
forms of expressing gallons would not be equivalent. Temperature compensation means that
the transaction would be expressed in standard or net gallons.
California wholesale fuel market transactions are measured in standard or net gallons that
account for variations in density and temperature. California retail market transactions, on the
other hand, are measured in non‐standard or gross gallons that do not account for variations in
density and temperature. A non‐standard or gross gallon is measured as 231 cubic inches,
regardless of temperature. A change from gross to net gallons at retail stations in California
would not be similar to a conversion to the metric system, as some stakeholders have suggested,
because the cubic inches dispensed to retail motorists would vary according to temperature.
The number of cubic inches dispensed to retail motorists if stations converted to liters would be
fixed under varying temperatures.
Petroleum Transactions - Standard of Measurement
The National Bureau of Standards is credited with having published, in 1916, the first handbook
of liquid hydrocarbon thermal expansion tables based on temperature and density. By 1952, the
American Society for Testing and Materials (ASTM) and the Institute of Petroleum (IP)
published an expanded set of tables using three types of measurement standards: metric, British
(or Imperial), and U.S. units.2 The reference temperatures used were 60 degrees Fahrenheit and
15 degrees Celsius. Density values were represented by American Petroleum Institute (API)
gravity, relative density, and density measured in kilograms per cubic meters (kg/m3). These
new tables enabled market participants to determine what the actual delivered volume of any
transaction should be if the temperature of the petroleum liquid varied from the reference
standard of 60 degrees Fahrenheit.
2 ASTM has expanded and is now referred to as ASTM International [http://www.astm.org/].
6
The process for determining how many net gallons are involved in a wholesale transaction
require knowing the gross gallons, average temperature, and density of the fuel involved in the
sale. This information is then used with mathematical equations related to the reference volume
correction factor tables to calculate the quantity of net gallons.
It is uncertain exactly when the majority of wholesale transactions for liquid petroleum
products in the United States were consummated using the 60 degree Fahrenheit reference
standard and volume correction factors from published tables, but it is reasonable to accept that
this practice has been commonplace for at least 50 years.
Temperature Compensation at Wholesale
Today, temperature compensation for wholesale transactions has advanced to the point that
electronic devices and software programs are readily available and can continuously monitor
the temperature of liquid hydrocarbons being transferred to a tanker truck, barge, or marine
vessel and can determine what volume of fuel would have been loaded if the temperature of the
fuel had been 60 degrees Fahrenheit. Through this technology, temperature has now been
removed as a variable in wholesale transactions of petroleum product liquids at most locations
throughout the world.
According to a recent California Energy Commission (Energy Commission) survey of the
distribution terminals serving California,3 transactions at the terminal are measured in gross
gallons and then a software calculation using the API gravity and temperature of the dispensed
fuel is used to calculate the quantity of net gallons. The net gallons are then multiplied by the
posted net gallon price to calculate the total cost for that load of fuel.
Retail station owners have the option of purchasing deliveries on either a gross or net basis for a
year. California Business and Professions Code Section 13520 states:
“It is unlawful for any distributor or for any broker to sell any product to a
retailer or to any person, when the quantity distributed in any single delivery to
a single location is 5,000 or more gallons, as, or purporting to be, gasoline or
diesel fuel, unless the distributor or broker, as the case may be, offers to invoice
the purchaser for such gasoline or diesel fuel on the basis of temperature‐
corrected gallonage to 60 degrees Fahrenheit for all such deliveries to the
purchaser over a period of 12 consecutive months and settles his accounts with
the purchaser on the same basis.”
3 California Energy Commission sent out a terminal survey in August 2008. See Appendix F for a copy of
the survey questions.
7
Energy Commission staff learned that the majority of retail stations buy on a net basis. Since
temperature compensation does not occur at the retail level, the transactions that occur
throughout the entire distribution chain of transportation fuels do not use a standard unit of
measure.
Retail Transactions and Temperature Compensation
The practice of compensating for differences in temperature during sales transactions for
petroleum products at wholesale has not been extended to retail station sales to consumers. The
technology necessary to enable automatic temperature compensation (ATC) at retail locations
was developed during the 1980s. Advances in electronics, miniaturization, and computing
capability have reduced the costs to a level that improved economic affordability for retail
operators.
Retail ATC devices do not function the same way as the temperature compensation units used
at the wholesale level. A retail ATC unit dispenses either a greater or lesser quantity of cubic
inches based on the volume correction factor (VCF) calculated using the temperature and
density characteristics of the dispensed fuel. The density value is input into the software of the
device and will remain fixed over the life of the unit unless a technician manually changes the
input value.
No California retail fuel outlets currently practice temperature compensation. If temperature
compensation was implemented at retail stations in California, distribution of fuel under
warmer temperature conditions would be adjusted by dispensing (compared to the volume
indicated by the device) slightly more gasoline or diesel fuel in cubic inches provided to
motorists. Conversely, if the fuel is colder than 60 degrees Fahrenheit, fewer cubic inches would
be dispensed to motorists.
California law stipulates that retail gasoline must abide by the latest standards as recommended
by the National Institute of Standards and Technology (NIST) Handbook 44 that states that a
gallon is 231 cubic inches and does not mention the temperature of the fuel.4 It is unclear
whether the voluntary use of ATC devices for retail sales transactions of gasoline and diesel fuel
is permitted under California law. California law specifies the following:
• Requires retailers to sell motor fuel by the gallon.5
• Requires retailers to advertise prices on a per gallon basis on its dispensers.6
• Defines a gallon as “231 cubic inches (exactly).”7
4 Handbook 44, Appendix C – General Tables and Units of Measure.
5 See California Business and Professions Code §12107 (incorporating Handbook 44 § 3.30 ¶ S.1.2.1 (2007
Ed.) (“[d]deliveries shall be indicated and recorded … in …gallons and decimal subdivisions or fractional
equivalents thereof []”).
6 See Title 4 C.C.R. § 4201.
8
County sealers of weights and measures inspect fuel dispensers to ensure compliance with
California law, making certain that five gallons dispensed measure 1,155 cubic inches, within a
tolerance level of plus or minus six cubic inches. California Business and Professions Code
Section 12240(d) states: “Retail gasoline pump meters, for which the above‐fees are assessed,
shall be inspected as frequently as required by regulation, but not less than once every two
years.”
National ATC Debate
The debate involving temperature compensation at retail in the United States has been ongoing
for several decades. The primary discussion and analysis has been carried out by the National
Conference of Weights and Measures (NCWM). This organization consists of state agencies that
develop measurement standards and enforcement procedures to strive for a balance of fairness
for both businesses and consumers. Active members include representatives of private
companies that have some connection to the product measurement in transactions. Careful
deliberation and methodical development of proposed new standards are hallmarks of this
organization.
The NCWM has compiled an extensive body of information and analysis regarding ATC that
cannot be adequately characterized in this section. One of the most difficult ATC issues involves
the national versus regional approach. Based on retail fuel temperature data presented at
NCWM proceedings, it is clear that some portions of the United States have annual fuel
temperatures warmer than the reference standard of 60 degrees Fahrenheit, while other regions
are below the reference standard. These regional variations can complicate a perceived “one‐
size‐fits‐all” regulatory action being called for by stakeholders representing consumers.
Although national standards could be developed for use by individual states or regions of the
United States, the matter of mandating ATC at retail could ultimately be decided by individual
state legislative and regulatory bodies. However, almost all aspects of this ATC debate have
been addressed by the organization.8
California Issues
The debate in California regarding retail temperature compensation (TC) is similar to the one at
the national level, an issue that involves perceptions of fairness, concerns over costs, and the
valuation of potential consumer benefits. There are a number of questions that Energy
Commission staff has attempted to address in this report. These are:
7 See Business and Professions Code §12107; Title 4 C.C.R. §§ 4000; 4001 (incorporating Handbook 44,
App. C at pp. C‐3, C‐9 and C‐16).
8 Presentations and other documentation involving ATC may be viewed by accessing the NCWM
meeting archive site at: [http://www.ncwm.net/events/index.cfm?fuseaction=meeting_archives].
9
• Is the temperature of gasoline and diesel fuel sold to California consumers warmer, on average, than
the 60 degree Fahrenheit reference standard?
• If temperature compensation has been instituted for most wholesale transactions to remove the
inequity of temperature variations, why has that practice not extended to the California retail
consumer?
• If ATC was mandated at retail stations in California, how would businesses and consumers be
impacted? Would the overall costs outweigh any potential benefits?
• Would retail station owners charge the same price if ATC equipment is installed and dispensed
slightly larger sized gallons when fuel is warmer than the 60 degree Fahrenheit standard? If so,
would consumers still receive anticipated financial benefits?
• If a new reference temperature was mandated, would the overall costs to businesses and governmental
agencies to implement and oversee the program outweigh any potential benefits?
• Are there some factors that may be difficult to quantify, yet have a potentially significant bearing on
the primary conclusions?
• If ATC was mandated, what types of standards should be adopted that address:
o Timing of the transition?
o Labeling?
o Differences in fuel density?
o Enforcement of the standard?
Assembly Bill 868
Assembly Bill 868 (Davis, Chapter 398, Statues of 2007) requires the California Energy
Commission, in partnership with the Department of Food and Agriculture and the California
State Air Resources Board, to conduct a cost‐benefit analysis and to make recommendations
relating to ATC reference temperature for fuel dispensation. The bill requires that the Energy
Commission evaluate and compare the following options for temperature compensation:
• Retaining the current reference temperature of 60 degrees Fahrenheit.
• Establishing a different statewide reference temperature.
• Establishing different regional reference temperatures for the state.
• Requiring the installation of temperature correction or compensation at the pump.
The Energy Commission also was directed to include in its analysis how ATC may apply to
alternative fuels and the low‐carbon fuel standard (LCFS).
10
After the Governor signed the legislation in October 2007, the Energy Commission held three
staff workshops in January, March, and June 2008, as well as a publicly open advisory group
meeting in April 2008. Following a Committee workshop in December 2008, the report is
scheduled for adoption at an Energy Commission Business Meeting. Following the adoption the
report will be sent to the Legislature in February of 2009.
In January 2008, the Energy Commission convened an advisory group that included equipment
manufacturers, consumer groups, fuel industry representatives, agricultural commissioners/
sealers of weights and measures, representatives of government agencies, and other interested
parties who would provide guidance on the analysis and recommendations for the study. The
advisory group communicated directly with Energy Commission staff, had an active role in the
workshops, and provided expertise on the issue of temperature compensation. The advisory
group included:
• AAA of Northern California, Nevada and Utah
• American Petroleum Institute
• American Trucking Association
• Arizona Department of Weights and Measures
• Arizona Petroleum Marketers Association
• Boyett Petroleum
• California Air Resources Board
• California Department of Food and Agriculture (Division of Measurement Standards)
• California Independent Oil Marketers Association
• California Trucking Association
• Former head of Hawaii Department of Weights and Measures
• Kraus Global, Inc.
• Los Angeles County Weights and Measures Department
• Measurement Technology International, Ltd.
• Metercal
• National Association of Convenience Stores
• National Association of Truck Stop Operators
• Natural Resource Defense Council
• New York Department of Agriculture and Markets, Bureau of Weights and Measures
• Owner Operator Independent Driver Association
• Petroleum Marketers Association of America
• Public Citizen’s Energy Program
• Sacramento County Department of Weights and Measures
• Society of Independent Gasoline Marketers
• The Foundation for Taxpayer and Consumer Rights
Energy Commission staff interpreted the legislation (see Figure 1) to mean that a cost‐benefit
analysis would be used to compare three options: implementation of temperature compensation
at retail outlets, a new reference temperature, and status quo. Staff divided temperature
11
compensation into two subsets: the installation of retrofit kits for dispensers and the installation
of new dispensers.
Upon the recommendation of the California Department of Food and Agriculture’s Division of
Measurement Standards and other stakeholders, the Energy Commission staff decided to
exclude the option of regional reference temperature in the analysis due to inspection
complications and confusion that would result from that option. Instead, the Energy
Commission staff analyzed the statewide reference temperature option (deemed the “Hawaii
example”) that involves changing the amount of fuel dispensed at the retail level and not
changing any operations at the wholesale level. A higher reference temperature would mean
that the 231‐cubic‐inch gallon mandated by law at retail stations would change to a gallon that
would be larger than 231 cubic inches in volume.
The Division of Measurement Standards requested county sealers begin surveying fuel
temperature in California before passage of Assembly Bill 868. The fuel temperatures were
recorded during the regular inspection by county sealers at retail sites between April 2007 and
March 2008. The data collected does not yield information of differences in temperatures
between retail sites in a particular county or local location.
12
Figure 1: Assembly Bill No. 868
An act to add Article 19 (commencing with Section 13630) to Chapter 14 of Division 5 of the Business
and Professions Code, relating to gasoline dispensing.
SECTION 1. Article 19 (commencing with Section 13630) is added to Chapter 14 of Division 5 of the
Business and Professions Code, to read:
13630. (a) The California Energy Commission in partnership with the Department of Food and
Agriculture and the State Air Resources Board shall conduct a comprehensive survey and cost-benefit
analysis, as follows:
(1) The department shall conduct a survey on the effect of temperatures on fuel deliveries. The survey
shall be conducted during routine dispenser inspections by determining the accuracy of fuel delivery, and
recording fuel temperature, air temperature, and storage tank temperature at fuel stations and other fuel
facilities subject to inspection. It is the intent of the Legislature that the department use data collected by
the survey that the department started on April 1, 2007, and will complete on March 31, 2008.
(2) The department shall transmit the results of the survey to the California Energy Commission, which
shall conduct a cost-benefit analysis and comparison of various options relative to temperature-corrected
gallon temperatures for the following:
(A) Retaining the current reference temperature of 60 degrees Fahrenheit.
(B) Establishing a different statewide reference temperature.
(C) Establishing different regional reference temperatures for the state.
(D) Requiring the installation of temperature correction or compensation equipment at the pump.
(b) The commission shall evaluate how different reference temperatures or temperature correction
devices apply to alternative fuels and low-carbon fuel standards.
(c) The California Energy Commission shall convene an advisory group no later than January 25, 2008,
including, but not limited to, equipment manufacturers, consumer groups, fuel industry representatives,
agricultural commissioners, appropriate government agencies, and other interested parties to provide
guidance on the study pursuant to this section and provide guidance on the analysis and recommendations.
(d) The California Energy Commission, in partnership with the Department of Food and Agriculture
and the State Air Resources Board, shall conduct public hearings on the results of the cost-benefit analysis
and report to the Legislature regarding recommended legislation and regulations based on the results of the
study not later than December 31, 2008.
13
CHAPTER 2:
Other Approaches and Studies
Other Approaches to Retail Temperature Compensation
To date, temperature compensation at retail stations has been adopted in Hawaii, Canada, and
Belgium. This section describes the approach used by Hawaiian officials to change the reference
size of their retail gallon (adopting a different reference temperature for retail fuel). In addition,
this section details Canada’s voluntary use of automatic temperature compensation (ATC) at
retail outlets and the recent changes in Belgium for a phased‐in mandatory use of ATC at their
retail stations.
Hawaii
With an average daily temperature slightly above 80 degrees Fahrenheit, Hawaii has a
consistently warm climate. Hawaii approached the thermal expansion issue by adopting a new
reference temperature of 80 degrees Fahrenheit.9 In 1974, Hawaii enacted law to allow retail fuel
dispensers to be modified such that the size of each dispensed retail sales unit would be slightly
larger than the gross or non‐standard gallon of 231 cubic inches at any temperature.10 Hawaii’s
retail sales unit of gasoline is now 233.8 cubic inches, roughly equivalent to how much a
standard gallon of gasoline would expand when warmed from 60 to 80 degrees Fahrenheit. A
retail sales unit of diesel fuel dispensed in Hawaii now contains 233.3 cubic inches at any
temperature.
George Mattimoe (former Deputy Director, Division of Weights and Measures, Department of
Agriculture, State of Hawaii, and former chair of the National Conference of Weights and
Measures) spear‐headed the campaign to have a standardized unit of measure for Hawaii and
advocated for a national standard of measurement for fuel for the United States.11
9 Although Hawaii’s average temperature is slightly higher, the reference was rounded down to
80 degrees Fahrenheit (interview with George Mattimoe, April 4, 2008).
10 Act 239 revised statutes 486‐50, [http://www.capitol.hawaii.gov/hrscurrent/Vol11_Ch0476‐0490
/HRS0486/HRS_0486‐0052.htm].
11 George Mattimoe invented the first known Automatic Temperature Compensated retail gasoline
dispenser in the United States. A thorough review of the history and technical issues associated with
temperature compensation is covered by Mr. Mattimoe in his paper, The Intellectually Dishonest Myth
Regarding The Accurate Delivery of a Standard Gallon of Gasoline at Retail, January 13, 2009.
[http://www.energy.ca.gov/transportation/fuel_delivery_temperature_study/documents/comments/2009‐
01‐13_George_Mattimoe‐Intellectually_Dishonest_Myth_Re_Accurate_Deliver_of_a_Gallon_of_Gas_TN‐
49799.PDF]
14
In 1974, at the 69th National Conference on Weights and Measures, Mr. Mattimoe presented the
work done in Hawaii to address the thermal expansion issue.12 In Hawaii, they adjusted the
dispensers to deliver a larger gallon to accommodate the average temperature for Hawaii. He
stated that the adjustment process occurred over a year. In total, 80 to 85 percent of all
dispensers were recalibrated by the meter inspectors during their routine inspections.13
Mr. Mattimoe advocated that all transactions throughout the year should be equitable to the
buyer and seller. Despite improving the situation and reportedly saving consumers money by
having a higher reference temperature, he does not favor advocating a new reference
temperature. In his 1974 presentation, he mentioned that “two wrongs don’t make a right” in
that shorting the consumer in the warm season and shorting the retailer in the cold season does
not result in equity. He also states the disparity is amplified when the average American
motorist drives more in the summer season than in the winter season.
Energy Commission staff believes that a reference temperature is more viable in Hawaii
because there is little seasonal volatility in climate temperatures throughout the year, as well as
small geographic differences in temperature in areas dispensing gasoline on any given day.
California, on the other hand, has many climate zones that have large variations in seasonal
temperatures throughout the year. The existence of the diversity and range of temperatures at
any given time in California would also make the reference temperature option not as
preferable as it is in Hawaii.
As mandated by the AB 868 legislation, the Energy Commission evaluated the effects of
implementing a new statewide reference temperature for California. The Energy Commission
staff assumes that the only change in operation would be the retail station dispensing a fixed
gallon larger in size than 231 cubic inches and that there would be no changes in wholesale
operations at refineries and distribution terminals.
Canada
In the early 1990s, Canada established standards that allowed retailers to sell temperature‐
compensated fuel, but did not require temperature compensation for the entire country.
According to Measurement Canada, in 1984, a Canadian electronics manufacturer designed an
ATC device that could readily measure the temperature of liquids and perform the calculations
necessary for fuel compensation. Today, more than 90 percent of Canadian fuel retailers
voluntarily sell temperature‐compensated fuel.14 All temperature compensation devices must be
operating throughout the year and cannot be turned off. The pumps with automatic
12 George Mattimoe, presentation at 69th National Conference on Weights and Measures, 1974.
13 69th National Conference on Weights and Measures, 1974.
14 Measurement Canada (an agency of Industry Canada), Information Bulletin ‐ Automatic Temperature
Compensation and the Retail Sale of Gasoline and Diesel Fuel, April 8, 2005 (updated February 21, 2008),
[http://www.ic.gc.ca/eic/site/mc‐mc.nsf/eng/lm00116.html].
15
temperature compensation must be identified by having a sticker on the register that says
“Volume Corrected to 15°C.”15
According to an ATC retrofitter, the information printed on the receipt is limited due to the
inability of the ATC technology to communicate with the dispenser receipt printing technology.
A Canadian receipt can show only the net gallon amount and whether the gallons dispensed
were temperature compensated. The receipts will not have any information on the temperature
nor will the receipt post both net and gross quantities sold.
Energy Commission staff learned that the ATC was marketed to retailers by ATC retrofitters as
a cost‐saving technology that provides a more accurate method of measuring fuel and
addresses inventory loss issues caused by the cold Canadian climate. Retailers soon learned that
the operation of retail ATC in a colder fuel temperature climate would result in less volume (in
cubic inches) being dispensed to customers using a reference of 15 degrees Celsius. Additional
revenue could be obtained, therefore, by charging the same price for the slightly smaller sized
liters. Retailers who could successfully increase their revenues in this manner used the
additional money to recoup the cost of purchasing and installing the ATC devices over some
reasonable period of time. In fact, Canadian fuel retailers prioritized their higher‐volume
petroleum product fuel dispensers (regular grade gasoline) for conversion because the payback
period for this investment was shorter when compared to premium grade gasoline sales.16
Without any ad hoc policy report detailing the effects of ATC in Canada, Energy Commission
staff perceives that the standard unit of measure for fuel for 90 percent of the distribution chain
benefited retailers and consumers, but retailers benefited more by dispensing a smaller gallon.
Retailers now have a technology that fixes the problem of inventory loss reconciliation from
colder temperatures, and consumers can now more accurately compare prices among
competing retail fuel stations because the number of volume units (liters) received and the
associated unit prices (price‐per‐liter) equally reflect those transaction components at a standard
reference temperature.
Energy Commission staff understands that a retailer’s incentive to implement ATC can be
influenced by a state’s climate. Retailers have the incentive to incorporate ATC in a “cold fuel
state.” In a “hot fuel state” consumers will demand temperature compensation since the retailer
will not have the incentive to implement ATC unless it is a marketing advantage for them. The
voluntary status and widespread implementation of ATC in Canada implies that a mandatory
policy could be necessary to deal with thermal expansion in “hot fuel states.”
15 Measurement Canada Information Bulletin, revised January 1, 2008, [http://www.ic.gc.ca/eic/site/mc‐
mc.nsf/eng/lm00116.html].
16 Measurement Canada, Policy on Use of Automatic Temperature Compensation, Bulletin V‐19 (rev.1), issued
May 13, 2005, page 1, [http://www.ic.gc.ca/eic/site/mc‐mc.nsf/eng/lm00116.html].
16
Belgium
Belgium passed laws mandating temperature compensation for retail sales of fuel beginning in
January 2008. The phase‐in period to comply with the law is underway, and retailers are
purchasing ATC retrofits. The Energy Commission has learned that retrofit companies are
marketing universal retrofit kits that can be installed on most dispensers regardless of the
dispenser make and model. The universal retrofit kits are broken down by the number of
products a dispenser distributes. The law’s intention is to require a standard unit of measure
throughout the entire distribution chain.
Other Studies
Temperature compensation of retail fuels has been debated for an extensive period.
Periodically, various entities undertake analysis or research for purposes of assessing the
potential merits of ATC at retail stations. This section highlights three of those studies that have
been published over the last nine years in the United Kingdom, Australia, and most recently by
the Federal Government Accountability Office (GAO).
United Kingdom
In 1999, the United Kingdom’s National Weights and Measures Laboratory (NWML), a
government agency, released a report on temperature compensation prepared by its contractor,
National Engineering Laboratory (NEL), an industrial research organization.17 NWML
commissioned the study to investigate the effects of temperature on petroleum transactions
from the gantry loading meter (called “distribution terminal” in California) through the retail
level, including underground storage tanks. Concern over product loss due to temperature
change, primarily between the wholesaler and retailer, motivated the study. The result was a
list of 15 recommendations to improve the petroleum distribution chain. Specifically, the report
recommended a voluntary adoption of standard temperature accounting, which accounts for
volumes at a standard temperature, since reduced capital and labor costs from technology
improvements would allow for improved efficiency and reduce operating costs.
To gather information and data, NEL requested information from industry representatives and
trade organizations using forms, outreach letters, and a seminar. NEL contacted 16 retailers, 56
oil and supply managers, and 19 trading standards officers, in addition to contacts with oil and
retail organizations. One of the surveys was sent out to oil depots requesting information
involving the temperature of gasoline and diesel, the source, storage temperature, and seasonal
fluctuations of the fuel. They received responses from 16 depots and 6 companies, which were
categorized based on their fuel supply source, such as sea, pipeline, or refinery. NEL found that
17 Boam, D. and Paton, R., National Engineering Laboratory, Temperature Compensation of Liquid Fuels, a
study for National Weights and Measures Laboratory, Project No. NWM006, Report No: 184/99, July 21,
1999, [http://www.nwml.gov.uk/Docs/FAQs/MID/NEL%20REPORT%20Temp%20Comp%20on%20LF.pdf].
17
there were temperature differences among different oil depots. While differences occurred both
above and below the 15 degrees Celsius (59 degrees Fahrenheit) petroleum standard, the
average fell below that mark and typically followed trends in the ambient air temperature.
Some of the data was gathered by other organizations as well. The Petrol Retailers’ Association
sent NEL results from a survey of 67 retail stations. This data shows some stock loss for gasoline
that could possibly be due to temperature. The results for diesel differed, however, showing
gains as well as losses for diesel stocks. Their survey classified stations into two categories:
motorway or other stations.
The NEL investigated the situation in the United Kingdom but also interviewed stakeholders
from other countries, particularly within Europe, to understand their current practices with
temperature compensation. At the time of their study, Canada, the Netherlands, Switzerland,
and Germany had temperature compensation while Australia, the United States, Austria,
Poland, Spain, Sweden, Ireland, Denmark, the Czech Republic, Iceland, and France did not. The
study strongly recommended Australia and Canada as contacts due to their well‐documented
history with temperature compensation.
Among other things, the NEL report found that the petroleum industry should adopt standard
temperature accounting (known as automatic temperature compensation in the United States)
to 15 degrees Celsius, but the standard “should be voluntary and based on contract
negotiation.”18 This includes temperature accounting at the wholesale level as well as the retail
level for consumers. As a requirement, the report recommended disclosure of temperature on
the bill of lading. To ensure that volume changes due to temperature are accounted for after the
fuel has left the gantry meter, NEL also recommended delivery trucks should be fitted with
temperature probes, but only for accounting and not contract purposes. The NEL also believed
it was important to have a system of self‐verification and audit by trading standards officers at
the gantry meters.
Australia
In 2001, the Australian government released a regulatory impact statement (RIS).19 Similar to
California, Australia has a warm climate and has fuel that is warmer on average than the
reference temperature. Citing a 1996 Australian study on temperature compensation,20 the 2001
RIS focused on the effects of temperature compensation implementation on independent
wholesale/retail establishments along with the effects on Australian motorists.
18 Ibid.
19 Consumer and Business Affairs Victoria, Trade Measurement Victoria, and Office of Regulation Reform
Victoria. Regulatory Impact Statement: Temperature Compensation of Petrol and Diesel Fuel, November 2001,
[http://www.consumer.vic.gov.au/CA256902000FE154/Lookup/CAV_Publications_Fuel_Pricing/$file
/of_fuel_tempcomp.pdf].
20 Australian Institute of Petroleum, The Temperature Correction of Petrol, March 1996.
18
Concerned about the competiveness of the retail fuel market in the absence of temperature
compensation, the RIS recognized an unfair competitive edge to oil majors that do have
temperature compensated transactions at the wholesale level over independent stations that do
not have temperature compensated transactions. The regulatory proposal was to increase the
transparency of volume measurement and pricing of petrol and diesel fuel within the oil
industry. Considering all other alternatives,21 the RIS recommended mandatory temperature
compensation of fuel from refineries and terminals due to its very low cost and increased
confidence in the market from the elimination of market distortion between oil majors and
independent oil companies. The RIS stated that mandatory temperature compensation at the
retail level would involve considerable costs and assessed it as an inferior alternative compared
to other options.
The Australian study determined that mandatory temperature correction is not justified by
stating that the costs associated with temperature compensation at retail would put upward
pressure on fuel prices, and argued that market pressures compensate for slight inaccuracies in
the measurement in fuel.
Government Accountability Office Report
In September 2008, the United States Government Accountability Office (GAO) released a
report on temperature compensation.22 This report provided information on (1) the views of
stakeholders in the United States on the costs to implement automatic temperature
compensation, (2) the views of stakeholders in the United States on who would bear these costs,
and (3) the reasons some state and national governments have adopted or rejected automatic
temperature compensation.
GAO presented all the arguments and ambiguities before concluding that the issues have not
changed, despite the weights and measures community debating over the costs and benefits of
automatic temperature compensation for more than three decades. The report provided
examples of what was done with temperature compensation in other countries like the United
Kingdom, Australia, Belgium, and Canada. GAO summarized that the supporters of ATC
argued for improved transparency in retail fuel prices, while the opponents argued that ATC
would be too costly for retailers.
21 List of alternatives: (1) Temperature compensation at refinery/terminals (the regulatory proposal), (2)
status‐quo, (3) temperature compensation at both refinery/terminals and depots, (4) temperature
compensation phased‐in at depots, and (5) temperature compensation at all wholesale and retail sites.
22 United States Government Accountability Office, Motor Fuels: Stakeholder Views on Compensating for the
Effects of Gasoline Temperature on Volume at the Pump, September 25, 2008, GAO‐08‐1114,
[http://www.gao.gov/products/GAO‐08‐1114].
19
GAO concluded that the cost of implementation remains unclear and that it was also uncertain
whether consumers or retailers would end up paying those costs. It also stated that none of the
states or countries that have experienced temperature compensation has ever studied the effects
on the retail fuels market. The report concluded that there was a clear need for an objective
analysis of the cost and benefit issues raised by stakeholders. The report also noted that the
Energy Commission cost‐benefit analysis being prepared for California could help resolve the
national debate on automatic temperature compensation.
20
CHAPTER 3:
Data Collection and Analysis
This chapter includes details associated with the various sources of information used and
analysis performed by staff to determine fuel consumption, retail prices, average fuel
temperatures, and fuel density properties throughout the study period of April 2007 through
March 2008.
Transportation Fuel Volumes
The volume of transportation fuel sold at retail stations during the study period is important for
two reasons ‐‐ averaging the fuel temperature data and quantifying the initial consumer
benefits before incorporating the revenue shift recapture by retail station operators (discussed
later in the cost section of this report).
California Demand for Transportation Fuels
Approximately 23 billion gallons of gasoline, diesel and jet fuel were consumed by California
motorists and businesses during 2007. Gasoline demand is estimated at 15.64 billion gallons for
2007, based on taxable sales figures reported by the California State Board of Equalization
(BOE).23 For the study period April 2007 through March 2008, taxable gasoline sales were 15.62
billion gallons, reflecting a slightly lower demand due to historically high retail prices.
Taxable sales for diesel fuel are also reported by BOE and totaled 3.08 billion gallons in 2007
and about 3.06 billion gallons during the study period.24 A significant portion of total diesel
demand is either exempt from state excise taxes (referred to as red‐dyed diesel) or excluded
from taxable sales figures on the basis of refunds for fuel used in an exempt manner (such as
agricultural use). Staff estimates that the exempt portion of total diesel fuel sales (demand)
could be between 30 and 40 percent of total demand. Since the ATC study is focused on the
retail level application, excluding the exempt volumes is acceptable because the majority of
these sales are through wholesale distribution terminals, rather than through retail stations or
truck stops. Therefore, the taxable diesel fuel figures reported by BOE were used for this study.
23 BOE taxable sales figures for gasoline on a monthly basis may be viewed at the following link:
[http://www.boe.ca.gov/sptaxprog/reports/MVF_10_Year_Report.pdf]. These totals also include aviation
gasoline taxable sales that must be subtracted to obtain gasoline sales figures. The link to the aviation
gasoline volumes is at: [http://www.boe.ca.gov/sptaxprog/reports/AVGAS_10_Year_Report.pdf].
24 BOE taxable sales figures for diesel fuel on a monthly basis may be viewed at the following link:
[http://www.boe.ca.gov/sptaxprog/reports/Diesel_10_Year_Report.pdf].
21
California County Demand for Transportation Fuels
The analysis performed to quantify fuel temperatures, consumer benefits, and business costs
was conducted at the county level. BOE does not report taxable fuel sales by each county, so
Energy Commission staff estimated monthly county fuel demand figures between April 2007
and March 2008. Staff used the 2007 California Motor Vehicle Stock, Travel, and Fuel Forecast
(MVSTAFF) produced by the California Department of Transportation (CalTrans).25 The
MVSTAFF produced gasoline and diesel demand estimates for each county for 2007. Staff used
the county‐specific MVSTAFF values to estimate the percentage of total California gasoline and
diesel consumption for each county. Staff took these county percentages and multiplied each
one by the total monthly California consumption that came from the BOE to estimate monthly
fuel demand for each county (Appendix A).
For example, Los Angeles County accounted for 24.1 percent of total California gasoline
consumption in 2007 according to MVSTAFF estimates. Applying this percentage to the
statewide BOE taxable gasoline sales total of 15.64 billion gallons for the period April 2007
through March 2008, yielded a value of 3.76 million gallons, the estimated consumption of
gasoline in Los Angeles County during the study period. Staff recognizes that applying the
annual county sales portion consistently for each month may not capture seasonal fluctuations
that can occur on a regional or county level. However, individual county fuels sales figures are
not available. For example, the annual portion of gasoline demand for Los Angeles County of
24.1 percent may actually fluctuate between 23 and 25 percent during any particular month.
Gasoline Grades – County Estimates
Quantifying the volume of gasoline consumed in a specific county was the first step in the
temperature and benefit analysis. Fuel temperature data obtained from the DMS Temperature
Survey, however, included data for regular and premium grades of gasoline. Since the estimate
of total gasoline demand by county does not specify the ratio of different grades of gasoline
consumed, staff estimated the ratio of different gasoline grades.
Staff used information collected through an annual Energy Commission survey of retail outlets
(referred to as the A15 survey) that contained sales volumes by grade of gasoline by individual
retail station.26 Using the A15 survey results from calendar year 2007, staff calculated that
regular grade gasoline sales averaged 76.2 percent of total sales, followed by mid‐grade at 9.9
percent and premium grade at 13.9 percent. Staff then applied these various ratios to the
individual county gasoline demand totals to estimate gasoline sales volumes by grade for each
county. These final gasoline demand estimates were then used to volume‐weight the fuel
25 California Department of Transportation, 2007 California Motor Vehicle Stock, Travel, and Fuel Forecast,
May 2008, Table 3, page 48, [http://www.dot.ca.gov/hq/tsip/smb/documents/mvstaff/mvstaff07.pdf].
26 California Retail Fuel Outlet Annual Report, CEC Form A15. A blank A15 form may be viewed at:
[http://www.energy.ca.gov/piira/forms_instructions/CEC_A15_RetailSurvey_Dec07_Rev.pdf].
22
temperature data collected through the DMS Temperature Survey and were also used for the
initial step of quantifying potential consumer benefits by county.
Retail Fuel Prices
California retail prices of transportation fuels were used by staff to help quantify any potential
consumer benefits associated with ATC. Staff determined the average monthly price of retail
gasoline and diesel fuel for each county, then applied these prices to the change in the size of
the petroleum gallon (in cubic inches) that would have resulted if ATC equipment had been in
place at all California retail outlets during the study period. During warmer months, the
average size of the petroleum gallon dispensed would be greater than the standard 231 cubic
inches at 60 degrees Fahrenheit. The difference in volume is determined by the temperature of
the fuel and the coefficient of expansion associated with the type and density of fuel that result
in a volume correction factor (VCF) that would be some fraction either greater or less than one.
These VCFs were then applied to average retail prices as part of the initial step to quantify
potential consumer benefits.
Conversely, during the colder periods of the year, the opposite would apply. Temperature
below the reference standard of 60 degrees Fahrenheit would result in slightly smaller
petroleum gallons being dispensed to consumers during the study period. During this part of
the year for some counties, consumers would have received less fuel if ATC had been installed
at the retail level. County‐specific retail prices were used to quantify the value of the fuel that
consumers would not have received during this portion of the year.
To collect retail gasoline and diesel prices for this study, staff used existing databases (as
described below). Staff organized the data by county for each month from April 2007 to March
2008. The statewide average retail price for regular grade gasoline in California was $3.29 per
gallon, with a downward trend in the summer of 2007 and an upward trend in the late fall of
the same year (see Figure 2). For diesel, the statewide average retail price was $3.41 per gallon
with upward trends in the fall of 2007 and spring of 2008.
The retail prices for regular grade gasoline (87 octane) used in this study were obtained from
the Oil Price Information Service (OPIS).27 This company provides daily price transactions at
individual retail stations and truck stops. In addition to the data from OPIS, staff also used
prices from the Energy Information Administration (EIA) to estimate prices for midgrade
(89 octane) and premium (91 octane) gasoline.28 Since the information from EIA is weekly,
however, staff needed to estimate monthly prices for midgrade and premium. This estimate
was done by looking at the EIA data and calculating the differences between regular and
[http://www.opisnet.com/].
27
Energy Information Administration, Petroleum Navigator, Weekly Retail Gasoline and Diesel Prices,
28
[http://tonto.eia.doe.gov/dnav/pet/pet_pri_gnd_dcus_nus_w.htm].
23
Figure 2: California Monthly Average Retail Fuel Prices
$4.30
$4.10
Regular Grade Gasoline
$3.90 Diesel Fuel
$3.70
$3.50
$3.30
$3.10
$2.90
$2.70
$2.50
Apr‐07 May‐07 Jun‐07 Jul‐07 Aug‐07 Sep‐07 Oct‐07 Nov‐07 Dec‐07 Jan‐08 Feb‐08 Mar‐08
Source: Energy Commission staff analysis of OPIS daily retail fuel prices.
midgrade as well as the differences between regular and premium. Staff then applied those
differences to the regular grade data from OPIS to obtain an estimate for monthly mid‐grade
and premium prices. On average, staff found that the difference between regular and midgrade
was 10.8 cents per gallon (ranging from 10.2 to 11.4 cents). The difference between regular and
premium grades averaged 20.8 cents per gallon (ranging from 20 to 21.4 cents). Using this
approach, staff was able to calculate monthly average gasoline retail prices for each of the 58
California counties over the study period.
Retail diesel fuel prices were not available for all California counties. The diesel retail prices
Energy Commission staff used came from these sources:
• Oil Price Information Service (OPIS)
• California American Automobile Association (AAA)
• Staff estimates (where data gaps occurred)
24
Staff first collected OPIS daily diesel fuel price transactions by individual retail stations and
truck stops. Truck stop data was available from OPIS for 17 counties, representing 65 percent of
the diesel consumption in California. For those counties where OPIS data was unavailable, staff
used AAA diesel retail price data, representing 28 percent of diesel consumption.29 If a county
had both OPIS and AAA prices, staff used the OPIS data if there were at least four reporting
stations. For those counties with fewer than four OPIS reporting sites, the AAA retail price was
used to estimate the retail diesel fuel price. Using these two data sources, staff calculated
average monthly retail prices for 34 of California’s 58 counties ‐‐ a total of 93 percent of
California’s diesel consumption, including the major population centers such as Los Angeles,
San Diego, and San Francisco counties.
For the remaining 7 percent of diesel consumption, represented by 24 counties in California’s
primarily rural regions, staff estimated diesel fuel prices by comparing the differences between
various counties for gasoline prices, less all applicable taxes. Staff assumed that these
differentials for gasoline would be similar for diesel fuel. This estimate was based on the prices
in counties where diesel prices were available (called “origin” counties). The staff chose a few
selected origin counties that have a gasoline and diesel wholesale rack, or distribution terminal,
supplying the destination county.
To remove differences in prices due to taxes, staff took out sales, excise and other taxes so a
price comparison would be focused on differentials due to transportation costs and market
conditions in each respective county. To find a gasoline differential between the origin and
destination county, staff subtracted gasoline prices without tax between the origin and
destination counties. Then taxes were taken out for diesel prices in the origin county. Next, the
gasoline differential between the pairs of origin and destination counties were added to the
diesel prices (less all applicable taxes) in the origin county to obtain a diesel price (less all
applicable taxes) for the destination county. The final step for determining an estimated retail
diesel price for the remaining 24 counties involved the addition of all applicable excise (state
and federal) and sales taxes.
Fuel Temperature Study
The Fuel Temperature Study is an analysis of temperature data collected by county sealers
throughout the state over a 12‐month period, beginning in April 2007 and ending in March
2008. This data collection determined the average fuel temperature levels for retail gasoline and
diesel fuel for California. The findings are similar to an earlier National Institute of Standards
and Technology (NIST) investigation that indicated California retail gasoline temperatures
were, on average, warmer than the reference standard of 60 degrees Fahrenheit. The
information collected under the DMS Temperature study had greater detail and included a
larger sample size compared to the earlier NIST work.
California AAA, Daily Fuel Gauge Report. Data provided by Oil Price Information Service in
29
cooperation with Wright Express, [http://www.fuelgaugereport.com/CAavg.asp].
25
Previous Fuel Temperature Survey Work
According to a NIST study, the temperature of gasoline and diesel fuel stored in storage tanks
at retail establishments varies nationally by geographic location and season.30 NIST collected
temperature data from approximately 1,000 retail stations located throughout the United States,
primarily between April 2002 and February 2004. The annual gasoline temperature averaged
64.3 degrees Fahrenheit. On a seasonal basis, the summer average was 75.3 degrees Fahrenheit,
while the winter fuel temperature averaged 51.2 degrees Fahrenheit. Additionally, this study
noted that Hawaii’s 80 degree Fahrenheit reference temperature was suited to Hawaii due to
the state’s warm, stable tropical climate. However, NIST also found that, as a result of climate
variability in the United States as a whole, a 60 degree Fahrenheit temperature at 231 cubic
inches made sense nationwide.31
The NIST database indicates that California appears to be one of the warmer states where the
gasoline temperature in storage tanks averaged 74.7 degrees Fahrenheit (Figure 3). Based on the
data collected by county sealers as part of the DMS fuel temperature study, the annual
statewide average regular grade gasoline temperature was 71.1 degrees Fahrenheit, slightly
lower than the earlier NIST survey results.32 It should be noted that the DMS temperature
survey results used in this report are the fuel from the fuel dispenser versus the fuel
temperature in the storage tanks at retail stations. Differences in fuel temperatures between the
underground storage tank (UST) and the fuel dispenser can be as great as 15 to 20 degrees
Fahrenheit. However, such large differences are uncommon, based on staff analysis of the DMS
temperature survey data that shows that more than 70 percent of the UST‐to‐dispenser fuel
temperature differentials are within plus or minus 3 degrees Fahrenheit for a typical California
retail station (discussed in greater detail later in this chapter).
This small difference in temperature is not surprising considering that most California retail
stations process one tanker truckload of fuel every couple of days.33 The fuel stored in the USTs
30 National Institute of Standards and Technology, State Charts for Temperature of Gasoline in Filling Station
Holding Tanks, presented at National Conference on Weights and Measures, Automatic Temperature
Compensation (ATC) Steering Committee meeting, Chicago, Illinois, August 27‐29, 2007,
[http://www.ncwm.net/events/atc2007/item9_avg_temp_states.pdf].
31 Suiter, Richard, National Institute of Weights and Measures, Hot Fuels – The Impact on Commercial
Transactions of the Thermal Expansion of Gasoline, testimony before the House of Representatives,
Committee on Oversight and Government Reform, Subcommittee on Domestic Reform, June 8, 2007,
[http://www.nist.gov/testimony/2007/rsuiter%20hover‐govt%20subc%20dom%20pol%206‐8‐07.htm].
32 Average is a weighted value based on ratio of estimated fuel consumption per county. Source is the
2007‐2008 DMS fuel temperature study.
33 Staff assumed that an average tanker truckload of gasoline is about 8,000 gallons. Over the study period
(April 2007 through March 2008), California motorists consumed 15.62 billion gallons of gasoline that was
purchased at about 9,700 retail stations, equating to an average daily throughput per station of 4,412
gallons. This is roughly equal to an 8,000 gallon delivery every 1.8 days.
26
is dispensed to consumers within 48 hours, with little time for the fuel to change temperature
due to the insulated double‐walled underground storage tanks.
Figure 3: NIST Results for California
Source: NCWM presentation materials.
DMS Temperature Study Background
As a warm state, California’s mean gasoline and diesel temperatures average above 60 degrees
Fahrenheit. Also important, however, is the distribution of gasoline and diesel temperatures
within California. To determine this distribution and calculate monthly average fuel
temperatures, the DMS conducted a survey from April 2007 to March 2008.34 During this
survey, county sealers collected gasoline and diesel temperature data from retail fuel
establishments. This data collection effort was voluntary, and 24 out of 58 California counties
participated. Staff defines “participation” as a county that reported 6 or more months of
temperature data to DMS for the 12‐month study period.
As shown in Figure 4, three types of temperature measurements were collected from retail
stations in counties that participated: (A) storage tank temperature, (B) prover temperature
(temperature coming out of the fuel nozzle and measured upon introduction into a “prover,”
the vessel used by Weights and Measures inspectors to verify dispenser accuracy), and (C)
ambient air temperature.
A link to the fuel temperature survey information may be viewed at the following DMS site:
34
[http://www.cdfa.ca.gov/dms/fueltempsurvey/FuelTempReports.pdf].
27
Figure 4: DMS Temperature Survey Sample Points
Air Temp. “C”
Prover Temp. “B”
Tanker Temp.
Tank Temp. “A”
Source: NCWM graphic amended by Energy Commission staff.
No fuel temperatures were obtained from tanker trucks delivering to retail stations. Since
county sealers were collecting temperature data during their routine inspections, the presence
of a delivery truck would be a coincidence. For the prover temperature, the fuel temperature
was normally taken after an initial five gallons of fuel was pumped from the dispenser. Fuel
temperatures consisted of regular and premium grades of gasoline, along with diesel fuel (if
available). No fuel temperature samples were obtained for mid‐grade gasoline since this fuel is
normally “created” at the dispenser by combining equal parts of regular and premium grades
of gasoline as the motorist fills their fuel tank. As such, there are a limited number of storage
tanks for mid‐grade gasoline available at retail stations to take temperature samples.35
Incomplete Temperature Data for Certain Counties
County sealers collected temperature data for gasoline in the counties listed as participants for
at least six months (Table 1). Many of these counties had temperature data for some but not all
months of the April 2007 to March 2008 study period. While those participating are a minority
of counties, they account for approximately 85 percent of California total gasoline sales and 78
percent of total diesel fuel sales.
Energy Commission staff estimate that less than 10 percent of California’s retail stations have a
35
dedicated storage tank for mid‐grade gasoline.
28
Table 1: California Counties With Temperature Data
29
To see if it would be possible to estimate fuel temperatures in the remaining counties, staff
determined the relationship between ambient temperatures and fuel dispenser (prover)
temperatures. Gasoline and diesel fuel sold at retail stations are delivered by tanker trucks that
load the fuel from one of 53 distribution terminals located throughout the state. The fuel is held
in aboveground storage tanks from a couple of days to a couple of weeks before being
transferred to a tanker truck. It is believed that ambient temperatures can influence the fuel
temperature in these storage tanks by either warming or cooling the fuel depending on the
season. Further, it is believed that the fuel temperatures do not appreciably change (on average)
from the tanker truck loading event and fueling of the motorists’ vehicles.
To test this hypothesis of correlation to ambient temperatures, staff compared average monthly
temperature data from the National Climactic Data Center (NCDC) to the fuel prover
temperatures collected by county sealers.36 The NCDC had temperature data for 275 weather
stations in California for the period covered by the DMS Temperature Study. Some weather
stations were in cities that did not have any fuel stations, and a number of fuel stations were in
cities that did not have any weather stations. Data from these categories was not included in the
temperature correlation calculation.
Each county’s mean ambient retail fuel station air temperature was obtained by weighting each
weather station’s temperature by the number of fuel stations in the same city as the weather
station. For cities containing more than one station, the mean of the weather stations’
temperature recordings was taken. Weather stations missing four or more months of data were
excluded from these calculations. Average ambient temperatures for all California counties
throughout the study period are in Appendix B.
For April 2007 through February 2008, monthly mean temperature was taken. For March 2008,
the median between each day’s high and low temperature was taken. The mean of these
medians was then calculated for each weather station. Counties that had only one weather
station were assumed to have that temperature county wide. Alpine and Sutter counties lack
ambient temperature data because they did not have any weather stations. Additionally,
Mariposa County only has temperatures available for two months of 2007. Staff used
temperatures in neighboring counties to estimate temperatures in these counties. The results
and methods apply only to California, and temperatures that were measured from April 2007 to
March 2008. These results should not be applied to other regions outside the state.
Results of Air and Fuel Temperature Correlation Analysis
Staff used the monthly ambient temperature data for counties that had sufficient fuel
temperature data for gasoline and diesel fuel to assess the relationship between air and fuel
National Climactic Data Center is a division of the National Oceanic and Atmospheric Administration.
36
A link to their web site is at: [http://lwf.ncdc.noaa.gov/oa/climate/climatedata.html].
30
temperatures. The results of statistical analysis consisting of regression equations indicated that
the average air temperature and seasonal factors produced the strongest relationship for
predicting fuel temperatures dispensed at retail stations. A more detailed description of the
variables and regression equation specifics is found in Appendix C. A visual example of how
well the regression equation “fits” the actual fuel temperature data is illustrated in the monthly
comparison for Alameda County in Northern California (Figure 5) and Los Angeles County in
Southern California (Figure 6).
Figure 5: Alameda County Gasoline Temperature – Actual vs. Predicted
Regular Grade Gasoline Dispenser (Prover)Temperature
90
Temperature in Degrees Fahrenheit
80
70
60
ActualTemp
PredictedTemp
50
40
30
10/1/2007
12/1/2007
11/1/2007
4/1/2007
5/1/2007
6/1/2007
7/1/2007
8/1/2007
9/1/2007
1/1/2008
2/1/2008
3/1/2008
Source: Energy Commission staff analysis of DMS temperature survey information.
The coefficient of determination or R2 number is a statistical measure of how closely the
variables (in this case ambient temperature and season of the year) predict the actual fuel
prover temperature. If the variables are a precise predictor for all of the monthly fuel
temperatures, the R2 number would be 1.0. Values of less than one usually imply that there are
other factors influencing the fuel prover temperatures besides ambient temperature and season.
The R2 number for regular grade gasoline was 0.87, followed by 0.78 for premium grade
gasoline, and 0.70 for diesel fuel. These values can be interpreted to mean that ambient
temperature can explain between 76 and 87 percent of the fuel prover temperature throughout
the year. However, the relationship falls short of precisely predicting fuel prover temperature.
31
Figure 6: Los Angeles County Gasoline Temperature – Actual vs. Predicted
Regular Grade Gasoline Dispenser (Prover)Temperature
90
Temperature in Degrees fahrenheit
80
70
60
ActualTemp
PredictedTemp
50
40
30
10/1/2007
12/1/2007
11/1/2007
4/1/2007
5/1/2007
6/1/2007
7/1/2007
8/1/2007
9/1/2007
1/1/2008
2/1/2008
3/1/2008
Source: CEC staff analysis of DMS Temperature Survey information.
Actions to Modify Database
Besides estimating monthly prover temperatures for various California counties, staff also made
slight modifications to the DMS temperature survey database. In one instance, an obviously
incorrect fuel prover temperature was replaced with another value that staff assumed was the
correct value. Six prover temperatures were excluded from the average temperature
calculations, two for regular grade gasoline and four for diesel fuel. A combination of 23 prover
and storage tank temperature “pairs” was excluded from the analysis used to create the
histogram charts illustrating the average difference between the fuel dispenser (prover) and
storage tank fuel temperatures. These excluded pairs consisted of five for regular grade
gasoline, nine for premium grade gasoline, and nine for diesel fuel. Finally, any temperature
data information from any dates outside the study period (April 2007 through March 2008) was
excluded from any average temperature or differential analysis. All of the specific instances are
detailed in Appendix D.
32
Other Factors Influencing Fuel Temperatures
Staff has not quantified other factors that could potentially influence the fuel dispenser
temperatures, but is aware that gasoline and diesel fuel can be warmed or cooled as the fuel is
distributed from storage tank to tanker truck to retail station underground storage tank (UST)
to fuel dispenser and the motorist’s fuel tank. The National Conference on Weights and
Measures (NCWM) ATC Committee has analyzed temperature information from several states
in order to better understand how these other factors could be influencing the temperature of
fuel at the point of the dispenser.37 Figure 7 illustrates some of the results from this analysis.
Figure 7: Other Factors Influencing Fuel Temperature
Difference in temperature from meter to
standard usually ≤ 1.5 °F (See Ross
Andersen’s tests with Measurement
Canada). Corrections are made for the
temperature difference when testing a
dispenser with ATC.
Meter
Temperature change from storage
tank to meter (based on five months
of data) can be up to +15 to ‐20 °F.
This affects the product inventory for
the station.
Temperature change from time of delivery to station
until dispensed. This temperature change affects the
product inventory for the station.
Source: NCWM presentation materials.
Analysis of information supplied by several states indicates that the temperature of the gasoline
or diesel fuel can vary by as much as 15 to 20 degrees Fahrenheit warmer or cooler between the
UST and the fuel dispenser. Although this temperature differential range appears large, the
majority of the fuel temperatures are grouped in a much closer range. Energy Commission staff
37 Oppermann, Henry, Temperature Data from Weights and Measures Programs, presentation at NCWM
annual meeting, July 15, 2008, [http://www.ncwm.net/events/annual2008/service_station_annual08.ppt].
33
analyzed the data collected during the DMS temperature survey to assess the difference in
temperatures between the UST and the fuel dispenser (prover) between April 2007 and March
2008. The distribution of these temperature differences is plotted in Figure 8 for regular grade
gasoline.
1000
919
900
800
722
700
600
Instances
500 454
400
332
300
200 177
132
88
100 61
17 29 31
2 1 7 6 2 1
0
≥ ‐15
‐13 thru ‐15
‐11 thru ‐13
‐9 thru ‐11
11 thru 13
13 thru 15
≥ 15
‐7 thru ‐9
‐5 thru ‐7
‐3 thru ‐5
‐1 thru ‐3
9 thru 11
‐1 thru 1
1 thru 3
3 thru 5
5 thru 7
7 thru 9
Degrees Fahrenheit
Source: Energy Commission staff analysis of DMS temperature survey information.
The differential in fuel temperatures has a similar broad range compared to the NCWM results.
The fairly even distribution appears to be slightly shifted to the positive side of zero, but only
minimally. Figure 8 also shows how tightly grouped the differentials are with more than 70
percent of the data points within plus or minus 3 degrees Fahrenheit and 94.7 percent within
plus or minus 7 degrees Fahrenheit. The distribution of temperature differentials for premium
grade gasoline and diesel fuel are similar, but with a somewhat broader spread as indicated by
Figure 9 and Figure 10. A measure of this flatter distribution is evident by the smaller
percentage of data points within plus or minus 7 degrees Fahrenheit for premium grade
gasoline (91.3 percent) and diesel fuel (85.4 percent).
34
Figure 9: California Premium Grade Gasoline – Prover Less UST Temperature
800
706
700
614
600
500
455
Instances
400
351
300
221
200
135 149
100 62 59
25 40 37
1 10 13 3 1
0
≥ ‐15
‐13 thru ‐15
‐11 thru ‐13
≥ 15
‐9 thru ‐11
11 thru 13
13 thru 15
‐7 thru ‐9
‐5 thru ‐7
‐3 thru ‐5
‐1 thru ‐3
9 thru 11
‐1 thru 1
1 thru 3
3 thru 5
5 thru 7
7 thru 9
Degrees Fahrenheit
Source: Energy Commission staff analysis of DMS temperature survey information.
Figure 10: California Diesel Fuel – Prover Less UST Temperature
300
249
250
223
200 191
Instances
150
123
114
100
72
54
47
50 36
23 26
5 7 9 9 7 6
0
≥ ‐15
‐13 thru ‐15
‐11 thru ‐13
≥ 15
‐9 thru ‐11
11 thru 13
13 thru 15
‐7 thru ‐9
‐5 thru ‐7
‐3 thru ‐5
‐1 thru ‐3
‐1 thru 1
9 thru 11
1 thru 3
3 thru 5
5 thru 7
7 thru 9
Degrees Fahrenheit
Source: Energy Commission staff analysis of DMS temperature survey information.
35
California Retail Station Fuel Temperature Results
The statewide monthly average prover temperatures for diesel fuel and gasoline ranged from
the upper 50s to the mid 80s (degrees Fahrenheit). Diesel fuel normally had the warmest
temperature in any month, followed by premium grade gasoline, then regular grade gasoline.
Even with significant differences in density, all three fuel types are remarkably similar in
temperature, regardless of winter or summer. The numbers in Figure 11 also show us that the
monthly average temperatures are almost always above the reference standard of 60 degrees
Fahrenheit, similar to the earlier NIST survey results.
Figure 11: California Monthly Average Prover Temperatures
90
Fuel Prover Temperature ‐ Degrees Fahrenheit
85
Diesel Fuel
80 Premium Grade Gasoline
Regular Grade Gasoline
75
70
65
60
55
50
Nov‐07
Jul‐07
Jun‐07
Feb‐08
May‐07
Aug‐07
Sep‐07
Mar‐08
Jan‐08
Oct‐07
Dec‐07
Apr‐07
Source: Energy Commission staff analysis of DMS temperature survey information.
The data presented in Figure 11 are a combination of the original DMS temperature survey data
and the estimated fuel temperatures developed by Energy Commission staff based on the
relationship between ambient and fuel temperatures. Staff then used annual fuel consumption
estimates by county obtained from the California Department of Transportation to calculate
volumetric‐weighted average prover temperatures. Table 2 displays the statewide average
results for the NIST, DMS, and the Energy Commission adjusted fuel temperature information.
36
Table 2: California Annual Average Prover Temperatures
Regular Premium
Grade Grade Diesel
Gasoline Gasoline Fuel
Degrees F Degrees F Degrees F
NIST Survey Results
Statewide Average 74.7
Statewide Minimum Monthly (Feb.) 64.3
Statewide Maximum Monthly (Aug.) 83.0
DMS Survey Results ‐ Raw Data*
Statewide Arithmetic Mean (Average) 71.5 72.0 72.5
DMS Survey Results ‐ CEC Modified
Statewide Weighted Average 71.1 71.5 72.9
Statewide Minimum Monthly (Jan.) 59.7 59.8 60.4
Statewide Maximum Monthly (Aug.) 82.0 82.9 84.6
* Selected data points modified or removed from calculated averages.
Although the statewide average fuel temperatures were almost always greater than 60 degrees
Fahrenheit, there are several instances when specific counties diverged by a greater margin than
indicated by the statewide maximum and minimum county averages. For example, the warmest
average county fuel temperatures were:
• 89.6 degrees Fahrenheit – regular grade gasoline – Riverside County in July 2007
• 90.7 degrees Fahrenheit – premium grade gasoline – Tulare County in September 2007
• 92.0 degrees Fahrenheit – diesel fuel – Fresno County in August 2007
The coldest average county fuel temperatures over the study period were:
• 49.4 degrees Fahrenheit – premium grade gasoline – Lake County in January 2008
• 50.5 degrees Fahrenheit – regular grade gasoline – Butte County in January 2008
• 51.8 degrees Fahrenheit – diesel fuel – Butte County in January 2008
Fuel Density
Transportation fuel densities are a potentially important property relative to retail ATC due to
differences in their thermal expansion and contraction properties, known as coefficient of
expansion. Volume correction factors (VCFs) are developed for transportation fuels for
purposes of determining conversions between gross and net gallons. The accuracy of applying
industry standard VCF tables to determine expansion and contraction of transportation fuels
can be reduced in two ways: variation of densities for the same types of transportation fuel, and
37
increased use of fuels that have density values dissimilar to fuels in widespread use. This
section of the report presents density information for traditional and alternative transportation
fuels, estimates changes in use of alternative fuels and their potential impacts on densities, and
outlines consequences of variable density values with regard to retail ATC.
Density Analysis and Findings for Gasoline and Diesel Fuel
Density of gasoline and diesel fuel varies due to differences in crude oil, refining processing,
and seasonal specifications (for gasoline). Staff examined information from various sources to
determine typical density values for transportation fuels and to what extent these values
diverge from the average. Information was obtained from confidential refiner surveys
conducted by the Energy Commission and other technical sources.
Gasoline Density – U.S. Variability
The petroleum industry generally uses a term known as American Petroleum Institute (API)
gravity to compare various liquid petroleum products to one another using a formula that
incorporates specific gravity or the ratio of a substance’s density relative to water.38 If one
knows the API gravity designation for a particular transportation fuel, this information can be
used to calculate the density of the petroleum product relative to water (specific gravity) using
the following formula:
The API adopted this formula in 1922 and the equation is widely used by the industry.
ASTM D 1250 Petroleum Measurement Tables are used by the industry to obtain the
temperature VCF of transportation fuels. To use these tables, the density of the product must be
known in order to obtain the corresponding VCF of the particular product. The assumed
density of finished gasoline in Canada that is used for retail ATC calculations is 0.7302 grams
per milliliter (g/ml).39 A table listing the various density reference values by fuel type may be
viewed in Appendix E.
38 The ratio of the density of a substance relative to water is usually calculated at a standard temperature
and pressure. For purposes of using the API gravity formula, the assumed temperature is 60 degrees
Fahrenheit and a pressure of one atmosphere. Water has a density of 1.00 g/ml.
39 Automatic Temperature Compensation Steering Committee, “Progress Report,” January 28, 2008, slide
number 18, [http://www.ncwm.net/ppt/steering_committee_interim_report_2008.ppt].
38
A recent survey of retail gasoline in the United States by the Alliance of Automobile
Manufacturers (AAM) yielded an average of 0.740 g/ml at 60 degrees Fahrenheit.40 It should be
noted that this value is a representation of retail gasoline from various locations throughout the
United States and encompasses the seasonal period beginning in the summer of 2006 (July and
August) through the winter of 2006/2007 (January and February). In addition, the gasoline
samples included both regular and premium grades, as well as blends containing ethanol at
10 percent by volume concentrations and conventional gasoline without any ethanol. Figure 12
depicts the relative density distribution of retail gasoline during the summer of 2006, while
Figure 13 depicts the relative density values for winter 2007.
On average, winter gasoline blends in the United States tend to be lower in density, a reflection
of higher concentrations of lighter components such as butane. However, the main issue that
must be addressed is how the gasoline densities in California differ from the typical industry
values and what are the potential impacts on retail ATC accuracy?
Figure 12: AAM Survey Results – Summer 2006
Relative Density of US Gasoline - Summer Distribution
Source: Alliance of Automobile Manufacturers' North American Fuel Survey - Summer 2006
70
Regular unleaded - with ethanol
Regular unleaded - without ethanol
60 Premium unleaded - with ethanol
Premium unleaded - without ethanol
50
Number of Samples
40
30
20
10
0
0.70 0.71 0.72 0.73 0.74 0.75 0.76 0.77 0.78 0.79 0.80
40 Oppermann, Henry, “Temperature Compensating Meters, the Concepts and Calculations for Testing
ATC Meters,” presentation at Western Weights and Measures Association Conference, September 11,
2007, [http://www.westernwma.org/presentations/2007%20Presentations/ATC%20slides%20for%20WWMA%209‐11‐07.pdf].
39
Figure 13: AAM Survey Results – Winter 2007
Relative Density of US Gasoline - Winter Distribution
Source: Alliance of Automobile Manufacturers North American Fuel Survey--Winter 2007
80
Regular unleaded - with ethanol
Regular unleaded - without ethanol
70
Premium unleaded - with ethanol
Premium unleaded - without ethanol
60
Number of Samples
50
40
30
20
10
0
0.70 0.71 0.72 0.73 0.74 0.75 0.76 0.77 0.78 0.79 0.80
Relative Density (60/60 degrees F)
Gasoline Density – California Variability
The Energy Commission periodically conducts confidential surveys of the petroleum industry
as part of their normal analytical activities. Information is collected under confidentiality
provisions of the Petroleum Industry Information Reporting Act (PIIRA).41 A recent survey of
California refiners provided, in part, API gravity information for the base gasoline used to
blend with ethanol at an average concentration of 5.7 volume percent. The survey obtained
refinery‐specific average gasoline properties for the summer blending season of 2006 that are
presented in Table 3.42
The volume‐weighted API gravity for regular California Reformulated Blendstock for
Oxygenate Blending (CARBOB) was 59.3 (0.7416 g/ml), while premium grade CARBOB
averaged 60.5 (0.7370 g/ml). Slightly higher API gravity values have an inverse correlation to
relative density, meaning that higher API gravity numbers are less dense than lower API
gravity numbers. However, the density of gasoline delivered to retail establishments was
estimated by staff using a typical density value for fuel ethanol of 0.769 g/ml.43
41 [http://www.energy.ca.gov/piira/index.html].
42 The summer season refers to the period June 1 through September 30, 2006 (122 calendar days).
43 Staff assumed fuel ethanol has a specific gravity of 0.7690 g/ml. Source: U.S. Department of Energy,
Office of Energy Efficiency and Renewable Energy, Alternative Fuels Data Center, Table 2.4,
[http://cta.ornl.gov/bedb/biofuels/ethanol/Fuel_Property_Comparison_for_Ethanol‐Gasoline‐No2Diesel.xls].
40
Table 3: California Refinery Production Properties – Summer of 2006 Gasoline
Octane
MON 85.6 81.8 88.2 83.0 86.4 82.8 86.9 83.3
RON 93.3 88.6 94.7 91.4 96.0 91.7 95.1 91.3
API Gravity 60.5 59.3 63.2 59.0 56.6 56.6 62.0 58.8
RVP (psi) 5.6 5.6 6.8 6.7 8.4 8.1 6.9 7.7
Oxygen (wt%)
Aromatics (vol%) 23.7 24.8 22.3 25.8 33.8 32.7 20.5 27.5
Benzene (vol%) 0.5 0.6 0.4 0.7 0.5 0.7 0.3 0.6
Olefins (vol%) 6.1 5.9 2.2 11.1 6.7 7.5 6.6 5.5
Sulfur (ppm) 7.4 10.1 6.0 22.2 5.3 27.4 3.4 24.0
E200 (%) 39.9 41.9 34.7 41.7 34.8 40.6 44.3 42.7
E300 (%) 87.7 86.8 83.9 84.8 83.1 78.3 89.3 84.7
Distillation (°F)
IBP 103.4 106.4 91.0 100.2 91.3 92.6 106.0 93.9
T10 150.9 148.7 152.0 142.0 132.5 128.2 142.3 132.6
T30 184.3 179.7 193.0 173.9 186.3 165.5 NA 138.2
T50 217.4 214.5 220.0 217.1 232.1 225.4 212.1 215.4
T70 248.7 252.4 254.0 255.3 268.1 277.3 NA 275.9
T90 309.4 311.7 321.0 320.6 320.3 338.2 300.5 321.0
FBP 384.2 381.2 390.0 400.0 391.3 403.8 374.0 396.8
Source: Energy Commission staff analysis of confidential PIIRA information.
Since the gasoline sold at retail during 2006 contained approximately between 5.7 and 6.0
percent ethanol by volume, staff calculated what the finished gasoline API gravity could have
been assuming a linear density blending relationship between the base gasoline (CARBOB) and
fuel ethanol (denatured ethanol). API gravity values for finished California gasoline were
estimated at 58.5 (0.7447 g/ml) for regular grade and 59.6 (0.7403 g/ml) for premium grade
gasoline, assuming an average ethanol concentration of 5.7 volume percent. Figure 14 illustrates
the estimated specific gravities (relative densities) for regular and premium grades of finished
California gasoline containing 5.7 percent ethanol and the distribution as a percentage of total
production.
Figure 14 illustrates the density variation in gasoline produced at California’s refineries during
the summer of 2006. The national AAM survey yielded an average regular grade gasoline
specific gravity of 0.7450 g/ml for blends containing 10 percent by volume ethanol compared to
the estimated average 0.7447 g/ml for California gasoline with an average ethanol content if 5.7
percent by volume, a difference of 0.04 percent. For premium gasoline, the AAM survey value
was 0.7460 g/ml compared to the California estimated average of 0.7403, less than 0.8 percent
difference. The year‐round Canadian gasoline density value of 0.7302 g/ml is within 2.0 percent
of the California regular grade summer average and within 1.4 percent of the premium grade
value.
41
Figure 14: California Refinery Gasoline – Relative Density Distribution
Both Grades of CARBOB ‐ Summer 2006
40%
Percent of Total Statewide Production
35%
Premium Grade Regular Grade
30%
25%
20%
15%
10%
5%
0%
.725‐.73 .73‐.735 .735‐.74 .74‐.745 .745‐.75 .75‐.755
Specific Gravity
Source: Energy Commission staff analysis of confidential PIIRA information.
Not only does the California’s average relative density value for gasoline differ from the
accepted Canadian number used for ATC calculations, but the distribution of gasoline densities
can vary by as much as 4.7 percent from the mean. The consequences of this variability are that
VCFs used to program ATC software will not always be precise from one delivery to the next.
However, this level of imprecision may not matter with regard to potential differences in
volume correction factors.
Since the refinery production information is not finished gasoline and the data is from the
summer blending season of 2006, Energy Commission staff felt it was necessary to obtain
additional information concerning API gravity properties of finished California gasoline. A
confidential survey of California refiners was conducted to obtain API gravity information from
their distribution terminals. The survey and associated questions used to obtain the confidential
information from the petroleum marketing companies may be viewed in Appendix F.
ATC at wholesale involves a conversion of gross gallons to net gallons using the measured
temperature of the fuel and the input density of the transportation fuel loaded into the tanker
42
truck before delivery to a retail station. Refiners were requested to provide this information for
the time period coinciding with the temperature survey, discussed earlier in this chapter.
Analysis of the survey information indicates that the density of regular grade gasoline in
California containing 5.7 volume percent ethanol during the study period is within the
estimated range of the 2006 refinery data.
Gasoline Density – California and United States Versus Canada Standard
The variability in California and the United States gasoline density values is shown in Figure 15
compared to the accepted industry reference standard used in Canada to program ATC devices
at retail stations. As indicated by the graphic, the Canadian standard density value for gasoline
is at the lower range of both the California and United States density values for the summer
period of 2006. However, the seasonal change in properties for gasoline will tend to decrease
the density values closer to the Canadian standard.
43
certain geographic regions of the state.44 The seasonal gasoline density variation from the
2006/07 NIST survey, depicted in Figure 16, indicates that winter blends tend to be less dense
compared to the summer blends of gasoline with 10 percent ethanol (E10). This shift would be
consistent with the use of a larger portion of lighter gasoline blendstocks.
80
Summer - Regular Grade - E10
70 Winter - Regular Grade - E10
40
30
20
10
0
0.70 0.71 0.72 0.73 0.74 0.75 0.76 0.77 0.78 0.79 0.80
Results of the California terminal survey data for gasoline densities also show that winter
blends containing 5.7 percent ethanol by volume are also shifted to the left (lower density), such
that the average is closer to the Canadian value.
44 Winter Rvp upper limits are determined by ASTM D 4814 standards that include six classes of regions.
California includes four of these geographic regions. In practice, the common carrier pipeline distribution
system operated by Kinder Morgan has upper Rvp limits for CARBOB shipped through their pipelines
and at their distribution terminal storage tanks. Kinder Morgan, Pacific Operations Specification Manual,
Section 5.1 Rvp Terminal Compliance, “Maximum Terminal Rvp Specifications for Calendar Year
2008/2009,” December 1, 2008, [http://www.kindermorgan.com/business/products_pipelines/sec5‐1.pdf].
44
Gasoline Density Variability and Volume Correction Factor Impact
The variability of gasoline density in California that occurs from one refinery to the next and
across seasons demonstrates that there are no static, accepted values for gasoline. This
distribution of densities means that the use of a single density value for finished gasoline at
retail will result in imprecise calculations of volume correction factors for ATC at retail the
majority of the time. However, the magnitude of this potential inaccuracy may be somewhat
small. For example, nearly 96 percent of the AAM gasoline density values are within 2.7
percent of the average of 0.740 g/ml. The volume correction factor for gasoline at 75 degrees
Fahrenheit using this average density would be 0.98992. However, if the actual density of the
gasoline was 0.720 g/ml, the correct VCF would be 0.98950, a difference of 0.042 percent.45 In
other words, the use of a single gasoline density value close to the annual average will yield a
VCF at 75 degrees Fahrenheit that is within plus or minus 0.04 percent of the actual, true value
96 percent of the time.
Improving upon this level of precision by altering the accepted density value on a seasonal or
per‐delivery basis would be costly, problematic, and only decrease the potential error by an
almost imperceptible measure. Therefore, staff believes that a single density value would be
optimal for use in California for gasoline if ATC was to be mandated at retail stations. Keep in
mind that the selection of a density reference standard for gasoline at retail in California is more
important during the summer months, when the fuel temperatures divert the most from the 60
degree Fahrenheit level. During the winter months, when retail gasoline temperatures are much
closer to 60 degrees Fahrenheit, the accuracy of the gasoline density reference standard would
be less important. The actual California value selected may differ from that of the Canadian
standard of 0.730 g/ml since that number appears to be at the lower range of gasoline densities
observed for California gasoline. The final value should be one that is at or near the summer,
rather than annual, California gasoline density value as determined by DMS in consultation
with industry and appropriate state agencies.
Diesel Fuel Density – United States Variability
Diesel fuel density issues are somewhat similar to those of gasoline, but with fewer differences
compared to California and the Canadian reference standard. As was the case with gasoline, the
AAM also collected diesel fuel density property information during the summer of 2006 and the
winter of 2006/07. The average density for diesel fuel was 0.846 g/ml for the combined data set,
with no difference from summer to winter for #2 diesel fuel. However, as is the case with
gasoline, density values do have variability caused by variations in crude oil properties and
refining techniques. The AAM survey yielded density values ranging from a low of 0.819 g/ml
to a high of 0.863 g/ml. Figure 17 shows the distribution of the AAM survey results.
VCF value obtained by using the API’s Temperature and Pressure Volume Correction Factor for Generalized
45
Crude Oils, Refined Products, and Lubricating Oils CD and software program.
45
Figure 17: AAM Survey Results – Diesel Fuel
90
#2 Diesel Regular - Summer
60
50
40
30
20
10
0
0.80 0.81 0.82 0.83 0.84 0.85 0.86 0.87 0.88 0.89 0.90
Energy Information Administration, “Definitions, Sources and Explanatory Notes,”
46
[http://tonto.eia.doe.gov/dnav/pet/TblDefs/pet_cons_821use_tbldef2.asp].
46
production from the summer of 2006. The API gravity for California diesel fuel averaged 38.5 or
0.832 g/ml specific gravity. California refiners also produce diesel fuel for export to Arizona and
Nevada. The density of that EPA ULSD was 0.841 g/ml or an API gravity of 36.8, slightly higher
in density compared to the California type of diesel fuel. Table 4 contains information for the
API gravity and other properties for all distillate fuels, including jet fuel.
Table 4: California Refinery Production Properties – Summer of 2006 Distillate
Distillation (°F)
IBP 320.1 341.8 355.7 405.4
T10 349.5 390.6 397.3 454.1
T30 382.4 426.9 432.2 487.6
T50 402.0 479.3 476.3 514.5
T70 431.9 524.1 520.7 544.2
T90 465.1 605.8 596.9 590.2
FBP 504.5 659.2 657.7 629.6
Source: Energy Commission staff analysis of confidential PIIRA information.
The variability or distribution of California diesel fuel is illustrated in Figure 18. As indicated by
the chart, nearly 97 percent of the California refinery output during the summer of 2006 was
within 1.2 percent of the average density value, with only 3 percent outside the primary
distribution range.
47 California Air Resources Board, The California Diesel Fuel Regulations, August 14, 2004,
[http://www.arb.ca.gov/fuels/diesel/081404dslregs.pdf]. Also see U.S. EPA diesel fuel programs at
[http://www.epa.gov/OMS/regs/fuels/diesel/diesel.htm].
47
Figure 18: California Refinery Diesel Fuel – Relative Density Distribution
Both Types of Diesel Fuel ‐ Summer 2006
70%
Percent of Total Statewide Production
60%
CARB Diesel Fuel EPA Diesel Fuel
50%
40%
30%
20%
10%
0%
.820‐.825 .825‐.830 .830‐.835 .835‐.840 .840‐.845 .845‐.850 .850‐.855
Specific Gravity
Source: Energy Commission staff analysis of confidential PIIRA information.
Diesel Fuel Density – California and United States Versus Canada Standard
The variability in the United States and California diesel fuel density values is shown in
Figure 19 compared to the accepted industry reference standard used in Canada to program
ATC devices at retail stations. As indicated by the graphic, the Canadian standard density value
for diesel fuel is nearly midway between the average California and AAM survey results for the
summer of 2006, rather than on the lower end of the distribution range as was the case with
gasoline density values.
As was the case with California gasoline density distribution, the range is within that of the
United States values. This is not a surprise in light of the greater variation in refinery
configurations that exist outside of California.
48
Figure 19: Summer Diesel Fuel Density –
United States and California Comparison
U.S. Min.
CA. Min.
90
#2 Diesel Fuel - Winter
80
#2 Diesel Fuel - Summer
70
Number of Samples
60 Canada
Reference
Standard
50
40
30
20
10
0
0.78 0.80 0.82 0.84 0.86 0.88 0.90
Relative Density (60/60 degrees F)
49
Diesel Fuel Density – Seasonal Variation
The distribution range of diesel fuel density values does not vary from summer to winter, a
marked difference compared to the seasonal swing of gasoline. Figure 20 shows the summer
and winter density distribution from the AAM diesel fuel survey compared to the Canadian
reference standard of .840 g/ml used to program the volume correction factors for ATC devices
installed at retail stations. You will notice that there is an absence of seasonal variation and that
the Canadian reference standard is within 0.7 percent of the AAM average of 0.846 g/ml.
Results of the California terminal survey data analysis for diesel fuel densities show that the
distribution of values are within the upper and lower limits illustrated above in Figure 20.
Diesel Density Variability and Volume Correction Factor Impact
The variability of diesel fuel density in California is consistent with AAM values and a
distribution within plus or minus 1.5 percent of the Canadian reference value of 0.840 g/ml. This
tight grouping of diesel fuel densities means that if ATC were mandated in California for use at
retail stations, the overwhelming majority of diesel fuel transactions would likely be within 0.02
percent of the true VCF for diesel fuel at 75 degrees Fahrenheit. Obviously, the use of variable
density values at retail stations would be problematic, as is the conclusion regarding gasoline.
However, unlike gasoline, the Canadian reference density value of 0.840 g/ml for diesel fuel is
probably acceptable for use in California, if ATC was to be mandated at retail stations.
Potential Implications of Renewable Fuel Standard and Low Carbon Fuel
Standard for Retail ATC
Typical alternative based transportation fuels in California currently consist of low‐level blends
of ethanol and biodiesel. Although other types of alternative transportation fuels can include
methanol, compressed natural gas (CNG), and liquefied petroleum gas (LPG),48 these fuel types
will not be addressed in this report. Methanol is only used in limited application, primarily as a
transit fuel not subject to retail transaction. Regarding the latter fuels, CNG is sold by weight,
and temperature compensation of LPG is voluntary at retail in California through regulations
administered by DMS.49
AB 868 directs the Energy Commission to, among other things, “evaluate how different
reference temperatures or temperature correction devices apply to alternative fuels and low‐
carbon fuel standards.” Energy Commission staff interprets this portion of the legislation to
include analysis of how the varying types of alternative fuels would be addressed in a retail
ATC environment.
48 Propane used in transportation is referred to as automotive propane or HD5 propane. This grade of
heavy duty propane is a specification that limits the propylene content to a maximum of 5 percent by
volume and butanes (and heavier hydrocarbons) to maximum of 2.5 percent by volume.
49 Title 4 CCR 4000 NIST Handbook 44, Section 3.32 U.R.2.4.
50
Staff elected to identify the different discrete types of alternative fuels that are currently used in
California and how their use may change as a consequence of the yet‐to‐be‐defined Low Carbon
Fuels Standard (LCFS) being developed by the California Air Resources Board (ARB).50 Both of
these regulations are expected to increase the use of ethanol and biodiesel that is used in retail
transportation fuels for the state over the mid to longer term time period.
Ethanol
Ethanol is primarily used in California’s gasoline in low concentrations; averaging about
6 percent by volume during 2007, and amounting to nearly 950 million gallons (see Figure 21).51
Figure 21: California Ethanol Use in Gasoline – 1980 through 2007
7%
6%
Volume Percent Fuel Ethanol
5%
4%
3%
2%
1%
0%
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
Source: Energy Commission staff analysis of FHA and BOE information.
50 For further details concerning the LCFS regulatory process staff and development, please refer to the
California Air Resources Board’s web site at [http://www.arb.ca.gov/fuels/lcfs/lcfs.htm].
51 Information obtained from the Department of Transportation’s Federal Highway Administration
(FHA), the California State Board of Equalization (BOE), and PIIRA. A link to the FHA historical data is
at: [http://www.fhwa.dot.gov/policy/ohpi/hss/hsspubsarc.cfm].
51
The increased use of this alcohol as a blending component was driven by federal reformulated
gasoline provisions mandating the use of a minimum quantity of oxygen in gasoline on a year‐
round basis and the phase‐out of the competing blendstock methyl tertiary‐butyl ether (MTBE)
beginning in 2003. The promulgation of LCFS regulations are anticipated sometime during
2009. These regulations are designed to decrease the carbon intensity of transportation fuels
over time. Alternative fuels such as ethanol and biodiesel normally have lower carbon
intensities, but the average values that will be ultimately adopted into regulation are uncertain
at this time. There is a general recognition that ethanol developed from corn has a greater
carbon intensity when compared to ethanol produced from other cereal crops or sugar cane.
Regardless, the final values adopted are presumed to be lower than gasoline and will likely
result in greater use of ethanol in California. However, there is also a federal regulation that is
expected to spur greater use of ethanol and other biofuels in the United States, including
California, referred to as the Renewable Fuel Standard (RFS).52
Due to these state and federal renewable fuel regulations, staff assumed that California’s
gasoline will contain an average of 10 percent ethanol (E10) by volume as early as 2009, but no
later than 2010. For purposes of this analysis, therefore, staff assumed that the typical gasoline
in use will be E10 before any retail ATC regulations take effect in California. Increased ethanol
use will alter the density of finished gasoline (gasoline sold at retail stations) and could alter the
expansion and contraction properties of the new transportation fuels sufficient to render the
standard VCF values for gasoline to be less accurate for use in California.
Staff assumed the LCFS and RFS will also require even greater use of ethanol in California over
the mid to longer term. This could be accomplished by (1) increased sales of E85 (a mixture of
15 percent gasoline and 85 percent ethanol), or (2) adoption of new upper limits for low‐level
ethanol blends in excess of the current E10 standard. Experts generally recognize that there are
potential vehicle operability and emission issues that need to be addressed before the low‐level
cap on ethanol blends in gasoline can be increased to levels greater than 10 percent.
Original Engine Manufacturers (OEMs) generally have vehicle warranties that are voided if the
owner uses gasoline with more than 10 percent by volume ethanol. OEMs are concerned about
potential harm to the catalyst in their vehicles. A recent study conducted on behalf of the
University of Minnesota, however, yielded information that suggests existing vehicles could
operate at slightly higher ethanol concentrations without undue operational or emissions
problems.53 The U.S. Department of Energy (U.S. DOE) is also conducting vehicle testing of
intermediate ethanol blends (E15 and E20) to quantify effects on vehicle emissions, catalysts,
and engine durability. This group has recently released a preliminary report that did not
52 Energy Independence and Security Act of 2007, Title II – Energy Security Through Increased Production of
Biofuels, Subtitle A – Renewable Fuel Standard, Section 202 – Renewable Fuel Standard, December 2007,
[http://frwebgate.access.gpo.gov/cgi‐bin/getdoc.cgi?dbname=110_cong_bills&docid=f:h6enr.txt.pdf].
53 University of Minnesota, Department of Mechanical Engineering, Demonstration and Driveability Project
to Determine the Feasibility of Using E20 as a Motor Fuel, November 4, 2008,
[http://www.mda.state.mn.us/news/publications/renewable/ethanol/e20drivability.pdf].
52
identify any significantly detrimental issues.54 The use of intermediate ethanol blends in
California may require new VCFs for both E15 and E20.
Measurement Canada specifies that the assumed standard density of gasoline containing
ethanol at up to 15 percent by volume be identical to that of gasoline, 730 kg/m3 at 15 degrees
Celsius, when such blends are used in retail fuel dispensers equipped with ATC devices.55
E85
There is also a very limited quantity of ethanol sold in higher concentrations to some owners of
flexible fuel vehicles (FFVs) in California. FFVs can operate on gasoline or E85. Over time, staff
expects that the quantity of E85 sold in California will increase in response to the federal RFS
and the state LCFS. If retail ATC was mandated in California, stations with E85 dispensers
would require software that was programmed with a density and associated VCF equation
specific to E85. Although average density values could be calculated for E85 using API gravity
values for each fuel in the correct proportions, it is possible that the resultant mixture may
exhibit other characteristics sufficiently dissimilar to gasoline to render the VCF equations less
useful. Therefore, staff believes that it would be optimal that laboratory testing be performed by
DMS to determine expansion and contraction values for E85 before the introduction of ATC.
Biodiesel
Biodiesel is a general term used to describe mixtures of diesel fuel with varying concentrations
(between 2 and 20 percent) of biomass‐based distillate. Retail sales of biodiesel in California are
quite modest at this time, but will likely increase for the same reason as ethanol (the state LCFS
and the federal RFS). If retail ATC was mandated in California, accuracy of biodiesel fuel
dispensers may be less when compared to gasoline and traditional diesel fuel, because of
variable densities for different types of biodiesel and imprecise biodiesel concentrations at retail
locations. The potential level of inaccuracy is related to the degree to which biodiesel densities
differ from traditional diesel fuel. If the differences are small, the VCF for traditional diesel fuels
should be sufficient for purposes of ATC application at retail.
Blenders of biodiesel are permitted to vary the concentration in diesel fuel depending on which
standard is adhered to for the final blend. Low level biodiesel blends can range from 2 to 5
percent of B100 mixed with the conventional diesel fuel to meet ASTM specification D975.
Higher blends of B100 between the range of 6 and 20 percent by volume must meet ASTM
54 Oak Ridge National Laboratory, Effects of Intermediate Ethanol Blends on Legacy Vehicles and Small Non‐
Road Engines, Report 1, publication number ORNL/TM‐2008/117, October 2008, [http://feerc.ornl.gov
/publications/Int_blends_Rpt_1.pdf].
55 Measurement Canada, Selection of Volume Correction Factor Tables and Standard Density Values for Some
Common Products, Bulletin V‐18 (rev. 5), April 1, 2008, [http://www.ic.gc.ca/eic/site/mc‐mc.nsf/eng
/lm00116.html].
53
specification D7467.56 Density values for the pure biodiesel (B100) can vary due to the feedstock
used or the type of process employed. A survey of biodiesel producers in the United States was
conducted in 2004 to identify the properties of both B100 and B20.57
Among the findings was that the density values for the B100 samples averaged 0.883 g/ml, with
a low value of 0.875 g/ml and a high value of 0.889 g/ml. Samples were also analyzed during the
survey for low level blends of biodiesel. The density of all of the samples with biodiesel
concentrations between 18 and 22 volume percent averaged 0.857 g/ml, with a low of 0.836 g/ml
and a high of 0.870 g/ml. A table with the accompanying density values for B100 can be found
in Appendix G, while the table containing the low level biodiesel blend properties (including
density) is located in Appendix H of this document. Figure 22 shows the distribution of these
density values in relation to the diesel fuel density distribution from the AAM 2006 survey.
Figure 22: Diesel Fuel and Biodiesel – Density Distribution
90
#2 Diesel Fuel - Winter
80 #2 Diesel Fuel - Summer
B20
70 B100
Number of Samples
60
50
Canada
Reference
40
Standard
30
20
10
0
0.80 0.81 0.82 0.83 0.84 0.85 0.86 0.87 0.88 0.89 0.90
Relative Density (60/60 degrees F)
Source: Energy Commission staff analysis of AAM and NREL information.
56 National Renewable Energy Laboratory, Biodiesel Handling and Use Guide, fourth edition, publication
number NREL/TP‐540‐43672, September 2008, page 23, [http://www.nrel.gov/docs/fy08osti/43672.pdf].
57 National Renewable Energy Laboratory, Survey of the Quality and Stability of Biodiesel and Biodiesel Blends
in the United States in 2004, publication number NREL/TP‐540‐38836, October 2004, pages 18, 49 and 50,
[http://www.nrel.gov/docs/fy06osti/38836.pdf].
54
The varying nature of low‐level biodiesel blends should not pose an accuracy problem if retail
ATC was mandated in California, since the variation of density appears to be within the normal
distribution for regular diesel fuel. However, pure or neat biodiesel (B100) density is outside the
normal distribution variability and should merit consideration for a separate reference standard
density value if sold at ATC retail. Measurement Canada acknowledges that “bio‐diesel and
bio‐diesel blends do not expand and contract in the same manner as petroleum diesel of the
same density.”58 The ability of a retailer to know the actual density of the biodiesel blends
delivered to the service station is quite limited. Therefore, Measurement Canada requires ATC
at retail to use the same standard density as diesel fuel, 840 kg/m3 at 15 degrees Celsius.59
Density Conclusions
If ATC is mandated at retail fuel stations in California, the following conclusions regarding fuel
density are offered:
• Density reference values used to program retail ATC software should not be altered on a
seasonal or per‐load basis due to the impractical and problematic consequences of such an
approach.
• A single reference density value for finished gasoline should be selected and be
representative of the summer blending season, since the highest divergence from the
60 degree Fahrenheit reference standard exists at that time of year in California. Slightly less
accurate density representation during the winter blending season is more acceptable
because the fuel temperatures during that time of year are much closer to the reference
temperature of 60 degrees Fahrenheit.
• The Canadian reference value of 0.730 g/ml is outside the lower range of California gasoline
density values and should not be used as the reference density standard in this state for
ATC at retail.
• The final value should be one that is at or near the summer average, rather than annual,
California retail gasoline density value as determined by DMS in consultation with industry
and appropriate state agencies. For purposes of this conclusion, the summer period includes
May 1 through September 30.
• The ethanol concentration in retail gasoline should be assumed to be 10 percent by volume
for purposes of determining a reference density standard.
58 Measurement Canada, Selection of Volume Correction Factor Tables and Standard Density Values for Some
Common Products, Bulletin V‐18 (rev. 5), April 1, 2008, [http://www.ic.gc.ca/eic/site/mc‐mc.nsf/eng
/lm00116.html].
59 Ibid, Table 1.
55
• Retail sales of E85 at ATC retail stations should use a density reference standard other than
the one selected for California retail gasoline containing 10 percent ethanol. DMS should
conduct laboratory work to determine the appropriate density value of E85 in consultation
with industry and appropriate state agencies.
• The Canadian reference density standard of 0.840 g/ml for diesel fuel would be acceptable
for use in California since that value is at or near the average retail density properties for
retail diesel fuel in this state.
• ATC retail sales of diesel fuel that contains biodiesel at concentrations up to 20 percent by
volume should use the Canadian reference diesel density standard of 0.840 g/ml.
• The Canadian reference value of 0.840 g/ml is outside the lower range of B100 density
values and should not be used as the reference density standard in this state for ATC at
retail. Rather, DMS should conduct laboratory work to determine the reference standard
density value for B100 in consultation with industry and appropriate state agencies.
56
CHAPTER 4:
ATC Retrofit Option
This chapter of the report includes details associated with the quantification of Automatic
Temperature Compensation (ATC) retrofit costs, options to decrease costs for some retail
outlets, potential consumer and retailer benefits, cost‐benefit comparison, and trends in the
retail gasoline business relevant to the analysis.
Cost-Benefit Analysis Approach and Methodology
A cost‐benefit analysis (CBA) of a particular option (in this case an ATC retrofit of California’s
retail stations) sums all of the monetized benefits resulting from an option and subtracts all
associated monetized costs over 10 or 15 years. The CBA results of this ATC option can then be
compared against other ATC options, such as the new reference temperature option discussed
in Chapter 5.
The methodology used in the ATC retrofit option was to identify and quantify the associated
costs and benefits over time to determine if benefits outweighed costs. Costs examined included
the expense of the ATC retrofit equipment, labor to install the devices, and incremental time to
certify the new devices. These initial costs are considered to occur only once under an
assumption that all of the retail stations would be retrofitted initially. Energy Commission staff
also identified and quantified additional expenses that were assumed to recur annually. These
recurring costs included increased device registration fees, ATC equipment for new or
refurbished stations, and periodic maintenance to service ATC devices. One final aspect of the
ATC retrofit cost valuation methodology was to include an additional expense for financing the
money required to pay for the initial retrofit of the retail stations.
On the benefit side of the ledger, staff performed analysis to monetize the expected benefits
society might realize from the ATC retrofit option. In this context, “society” would include all
California consumers who purchase gasoline and diesel fuel at retail stations within the state
and owners of retail stations. The two types of potential benefits that were analyzed as part of
this option included expected benefits for retail motorists that might be derived from changes in
the method by which retail fuel was sold at the retail station and potential economic benefit to
society of improved information regarding transparency of California retail fuel prices.
Since the ATC equipment would operate in such a fashion as to dispense slightly larger gallons
of variable size (in cubic inches) in a warmer fuel temperature state such as California, the
expected benefit to consumers is perceived by various stakeholders to be the value of the
decreased quantity of gallons that would have been purchased if ATC equipment had been
installed at retail stations, referred to as net gallons.
57
Improved transparency concerning retail price information is the other expected benefit for
California retail motorists associated with ATC retrofit and involves the elimination of
temperature variation from the retail station transaction. California retail motorists are able to
examine and compare prices of gasoline or diesel fuel at various potential fueling destinations
by examining retail prices posted on large signs as they drive. However, this comparison of
retail fuel prices is not completely accurate because variations in fuel temperatures can alter the
effective size of the net gallons that would be received at any given retail station available to an
individual motorist who is seeking to obtain transportation fuel at the lowest price. If the retail
stations had ATC dispensers, the variability of fuel temperature (and corresponding impacts on
net gallon size) would be corrected and retail motorists would be able to more accurately
compare gasoline and diesel fuel prices posted at various potential fueling destinations.
In economic terms, this imperfect market condition resulting from less transparent retail fuel
prices is referred to as dead‐weight loss (DWL). Installing ATC at retail stations in California
would improve retail fuel price transparency by increasing consumer information, thus
eliminating the dead‐weight loss to the California retail fuel market. Although small in
magnitude, the quantification of this impact was included in the consumer benefit analysis.
Costs (Equipment, Labor and Inspection)
If ATC was mandated for use at retail stations in California, the operators of these fueling
facilities would need to retrofit their existing fuel dispensers to comply with such a
requirement. As part of the ATC retrofit option analysis, Energy Commission staff quantified
the following ATC‐related costs: new equipment for fueling dispensers, labor to install and
calibrate the devices, and fee increases by inspectors to verify correct calibration of ATC
equipment during regularly scheduled certification inspections.
Energy Commission staff used data from a variety of different sources in order to estimate
attributes of retail fueling sites, such as the total number of retail fuel dispensers, number of fuel
products per dispenser and which retail fuel establishments blend their midgrade gasoline as a
mixture of regular and premium grade gasoline. These sources include the Energy
Commission’s California Retail Fuel Outlet Annual Report (A15 report),60 data collected from
County Agricultural Commissioners/Sealers of Weights and Measures (county sealers), data
from various air quality management districts, survey responses from the petroleum industry,
and information provided by ATC equipment manufacturers.
California Retail Fuel Outlet Annual Report, CEC Form A15. A blank A15 form may be viewed at:
60
[http://www.energy.ca.gov/piira/forms_instructions/CEC_A15_RetailSurvey_Dec07_Rev.pdf].
58
Costs – ATC Retrofit Equipment Overview
There are roughly 9,700 retail fuel establishments in California containing about 42,050 active
fuel dispensers, with the majority (91 percent) of these devices being electronic. Energy
Commission staff used approximately 5,100 completed A15 forms to obtain data on what fuel
types each retail fuel establishment dispenses and whether that particular site blends fuels to
produce its midgrade gasoline. This data focused mainly on retail sites that sell gasoline and
diesel fuel, rather than other fuels such as propane and natural gas.
Data was collected from county sealers, on the total number of meters per retail site. In this
context, total meters means the total number of product delivery streams available to
customers. For example, if a retail fuel establishment has three dispensers, each of which
dispenses six product delivery streams (three per side), then there are 18 total meters at that site.
The meter data alone was used to help estimate costs for approximately 3,000 retail fueling sites.
The Energy Commission contacted the majority of Air Quality Management Districts (AQMDs)
in California and also visited one to obtain dispenser data for retail fuel establishments. Most
retail establishment operators are required to submit an application for a Gasoline Dispensing
Facility (GDF) permit on an annual basis. Most of the AQMDs that use GDF permits require
specific data to be submitted that includes: the make and model of retail dispensers, the number
of dispensers, and the number of nozzles each dispenser has. In theory, the information
provided in the GDF permits would be ideal for use in the cost estimation. In practice, however,
the GDF information was either unavailable electronically, outdated, or incomplete. As a result,
the AQMD resource was of limited use to staff.
Lastly, a dispenser survey was sent out to retail fuel sites in counties that did not require GDFs
to report dispenser make and model information. A copy of the survey may be viewed in
Appendix I. The survey was also sent to many of the major oil companies and retailers in
California. The purpose of this survey was to collect the same type of GDF data that is required
to be filed by the majority of retail outlets applying for their AQMD permits. Additional
questions were included in the survey regarding whether the dispensers are electronic or
mechanical. This survey generated nearly 600 responses; some of the responses were from retail
sites that had data from the A15 report and from the county sealers.
59
dispenser makes and models.61 This development simplified the cost quantification task for
Energy Commission staff and shifted the emphasis of the retail station attributes to the number
of dispensers, fuel types, and mid‐grade gasoline blending capability.
Universal Automatic Temperature Compensation (ATC) kits are priced based on how many
fuel products are delivered from a dispenser. On the low end are one‐product dispensers that
would require an ATC retrofit kit costing $1,700. On the upper end are four‐product dispensers
(non‐blending) that would cost about $2,426. Blending for midgrade reduces the kit cost and
was also considered in the analysis. Other aspects that staff included are whether dispensers are
mechanical or electronic. Mechanical dispensers are more expensive to retrofit (between $3,200
and $4,000) with an ATC kit because, in addition to installing the kit, some equipment on the
dispenser needs to be replaced with electronic components. Table 5 lists the various ATC
retrofit kits and their associated costs.
Table 5: ATC Retrofit Kit Costs by Dispenser Attributes
Conversations with Krause Global representatives concerning their recent ATC retrofit plans and
61
activities in Belgium.
60
To calculate the number of dispensers, staff used the average number of dispensers, by county,
from the retail dispenser survey. For retail stations in Los Angeles and Monterey counties
however, the respective air quality management district provided data used to calculate the
average number of dispensers. For only 8 percent of the stations, Energy Commission staff did
not have any dispenser information. Again, the staff took averages by county for the number of
fuel products and dispenser count except for Los Angeles and Monterey Counties, which have
their own averages. Staff has full dispenser information for 12 percent of the stations in
California, which required the most information gathering and data compilation. Staff was able
to calculate a cost for each retail station with this information without using averages.
From the retail dispenser survey, which included 12 percent of all retail stations, staff
determined which stations have electronic or mechanical dispensers. For retail stations where
staff does not have dispenser survey information, staff took an average cost difference between
mechanical and electronic dispensers and took into account that most stations have electronic
dispensers. From the dispenser survey, only 9 percent of stations have mechanical dispensers.
Using the retail dispenser survey and A15 data, which included 52 percent of all retail stations,
staff knew which stations blend midgrade and which do not. For stations without that
information, staff took an average cost difference between a blended dispenser and non‐
blended dispenser for all stations. Through the retail dispenser survey and A15 report, staff
found that about 70 percent of stations blend for midgrade and took this into consideration
when calculating dispenser costs.
Costs – ATC Retrofit Equipment Totals
Statewide costs for ATC retrofit kits are estimated by staff to amount to approximately $84
million or $8,682 per retail station. Highest per‐station county average was $10,474 in Orange
County, while the lowest per‐station cost average was estimated at $2,212 for Alpine County.
Retail outlets in the urban areas tended to have higher per‐station ATC retrofit costs due to a
greater number of dispensers and fuel types, when compared to counties that are rural in
nature. Appendix J provides a county‐specific breakdown of the ATC retrofit kit equipment
costs.
Costs – Labor to Install ATC Retrofit Equipment
Energy Commission staff calculated an estimate for labor expenses to install ATC retrofit kits at
all of California’s retail stations of between $9.0 million and $27.9 million. Staff assumed that the
ATC installation work would require two technicians working between one and a half to four
hours to install ATC kits for each dispenser.62 The labor rate per technician was estimated to be
62 Energy Commission staff labor time estimate based on discussions with industry representatives.
61
between $60 and $70 per hour.63 These hourly wage rates are assumed to be “fully loaded,”
meaning that the rates are sufficient to cover the salary of the worker, benefits, and sufficient
overhead for the company to maintain a profit.
Staff took the number of dispensers in each retail station used initially in the equipment costs
and multiplied the number of dispensers by the hours required per dispenser, technicians, and
labor rate to calculate a labor cost per station. Installation costs for retail stations located greater
distances from large metropolitan areas were increased to account for time spent away from the
business’s headquarters. These additional costs included: fuel allowance, hotel stay and per
diem overhead. Staff considered counties “rural” if they are far enough from a major
metropolitan center to necessitate overnight stays. Examples of counties that are considered
metropolitan areas are Fresno County (due to the city of Fresno) and Kern County (due to
Bakersfield). Counties in the greater San Francisco Bay Area, Los Angeles basin and San Diego
regions were designated as ”urban” with no adjustments made for additional labor costs. The
large eastern geographic extent of San Bernardino and Riverside counties was also designated
“rural” in terms of calculating higher labor costs.
Installation costs were adjusted to take into account the additional time required for technicians
to drive to their retail station destinations, assuming clients were being charged when the
technician departed their place of business.64 Staff assumed that California cities with
populations of greater than 200,000 would have technicians certified to install ATC retrofit
devices. Calculations for additional technician driving time for each county used the nearest
technician “home base” to estimate additional labor expenses. This approach yielded an
additional labor cost component of between $1.1 million and $3.8 million. The lower estimate
assumes two technicians each charging $60 per hour. The higher estimate used a wage rate of
$70 per hour.
Costs – ATC Retrofit Labor Totals
Statewide costs for ATC retrofit kit installation labor are estimated by staff to amount to
between $9.0 million and $27.9 million or from $925 to $2,879 per retail station. The low labor
estimate assumes a $60 per hour wage rate (fully loaded) and one and a half hours worked by
two technicians on each dispenser. Under these assumptions, the highest per‐station labor cost
average was $1,241 in Del Norte County, while the lowest per‐station labor cost average was
estimated at $521 for Trinity County. The high labor estimate assumes a $70 per hour wage rate
63 California wage rates of workers in Standard Occupational Classification (SOC) code 49‐2094
(designated for electrical and electronics repairers, commercial and industrial equipment) averaged
$25.67 per hour during May 2007 with a 90th percentile wage rate of $38.28. A link to the state SOC data is
at: [ftp://ftp.bls.gov/pub/special.requests/oes/oesm07st.zip]. Due to the specialized nature of fuel
dispenser technician work, it would be reasonable to assume their hourly wages are closer to the 90th
percentile level in California. Further, fully‐loaded wage rates in the $60 to $70 per hour range would
appear sufficient to cover all fully loaded company expenses.
64 Based on comments received during the December 9, 2008, Committee Workshop.
62
(fully loaded) and four hours worked by two technicians on each dispenser. Under these
assumptions, the highest per‐station labor cost average was $3,647 in Riverside County, while
the lowest per‐station labor cost average was estimated at $1,312 for Alpine County. Counties
with the higher averages were a mixture of both urban and rural locations. Urban areas with
higher than average number of dispensers per location would push up the labor costs, while
rural locations with average numbers of dispensers but more distant locations also had some
higher labor costs. Appendix K provides a county‐specific breakdown of the ATC retrofit kit
labor costs.
Costs – Increased Inspection and Certification Fees
Retail stations in California are normally visited every 12 to 18 months by county weights and
measures inspectors for purposes of verifying accuracy of measurement devices, which would
include retail fuel dispensers. Currently, these inspectors check and verify the accuracy of fuel
dispensers to ensure that the correct quantity of fuel (in cubic inches) is within specified
measurement tolerances. If the fuel dispenser is within acceptable measurement tolerances, the
devices receive a weights and measures seal. Over the last couple of years, initial inspections of
retail motor fuel metering devices have resulted in approved certification 93 percent of the
time.65 If the fuel dispenser is not within acceptable range of accuracy, the inspector shall
require the fuel dispenser to be properly calibrated.
The time required to perform these field calibration tests varies by individual site according to
the number of dispensers, the number of fuel types (different grades of gasoline and the
presence of diesel fuel), and the percentage of dispensers that dispense mid‐grade gasoline by
combining equal portions of regular and premium grades of gasoline (referred to as
“blenders”). County Weights and Measures Departments charge a device registration fee to
offset the cost of this inspection and certification service that will usually vary as a reflection of
the time required to perform the field work. Currently, in Sacramento County, the fee for
service stations is $100 for the location and $20 per meter. The $20 per meter fee is based on an
average of 12 minutes inspection time per meter. If the time was doubled, the fee would
theoretically need to be increased to $40 per meter,66 as the fees are designed to recapture the
expenses incurred by each county to perform this inspection service. The registration fee that
can be charged by county sealers, though, is currently capped by statute to no more than $1,000
per business location.67
Energy Commission staff estimated the time needed to inspect and certify retail fuel dispensers
will increase between 10 and 20 percent if ATC is mandated for use at retail stations in
65 California Division of Measurement Standards, County Monthly Report (CMR) summaries for period
July 1, 2006 through June 30, 2008.
66 Telephone conversation with David Lazier of Sacramento County Weights and Measures.
67 California Business and Professions Code, Section 12240, subdivision (n). A link to this provision is at:
[http://www.leginfo.ca.gov/calaw.html].
63
California. As such, the corresponding costs incurred by each county will rise and fees will need
to be increased to compensate for the additional expenses (such as the hiring of additional
weights and measures inspectors). However, there may be some instances when the fee in some
counties or locations already being charged is at or near the upper limit imposed by Section
12240 of the California Business and Professions Code. If ATC is mandated in California at retail
stations, the maximum limit stipulated in subdivision (n), Section 12240, California Business
and Professions Code should be increased to at least $1,200 to ensure that counties will be able
to recover all of their additional costs of performing inspections and certifications. The
maximum permissible limit on inspection fees does not mean that county weights and measures
departments can automatically set their inspection fees at the upper limit. Rather, these agencies
must demonstrate that the fees being charged to retail station operators reflect the actual costs
being incurred by the county sealers and no more. Approval for inspection fee increases
typically must be approved by each respective county’s board of supervisors.
Equipment costs for county weights and measures sealers are expected to increase if ATC was
to be mandatorily implemented, but only slightly. Based on analysis performed by the NCWM,
inspectors are expected to use an electronic device to measure fuel temperature during the
dispenser testing and certification process, referred to as a digital thermistor thermometer
(including the probe). Staff estimates that each inspector will probably require one such
temperature measuring device, with one additional device to use as a back‐up while in the field.
Total cost for each device (including flexible probe) is not expected to exceed $450.68
Certification costs of these additional standards will be borne by DMS. Costs to each county will
vary and will be directly related to the number of inspectors that would be required in a post‐
ATC scenario. The number of county inspectors involved with testing retail motor fuel (RMF)
meters is estimated by staff to be between 129 and 156 statewide.69 Total statewide costs for the
thermistor thermometers, therefore, are estimated to range between $77,000 and $140,000.
Individual county totals are located in Appendix L. Assuming that these devices would be
sufficiently durable to last several years, initial costs to each county could be recovered as part
of the increased registration fee. Costs for other equipment (such as VCF look‐up charts,
calculators, and so on) should be minor.
68 The cost estimate range will vary by quality of the handheld thermistor thermometer as reflected by
level of accuracy and data recording and housing capability. For example, two models of Digi‐Sense
Thermistor Thermometers (models 60010‐70 and 60010‐75) retail for $174 and $315, respectively. Each
device would also require the use of a flexible thermistor probe that would cost approximately $120
(stainless steel model) [http://www.novatech‐usa.com/Products/RTD‐Thermistor‐Temperature‐Meters].
Also see Digi‐Sense product catalogue, [http://www.digi‐sense.com/digi‐sense‐brochure‐r2.pdf].
69 Based on information from Los Angeles County, there are 14 full‐time inspectors for over 1,900 retail
stations. Applying this ratio to the rest of the state, staff estimates that 82 inspectors would be required
(on a full‐time basis) for about 9,700 retail outlets. Not all counties have inspectors dedicated solely to
retail motor fuel (RMF) meter testing. The low estimate assumes all counties can inspect 100 RMF
locations per year per sealer. All calculated values were rounded up to the next whole number. The high
estimate assumes all counties with under 200 retail outlets inspect 50 RMF locations per year per sealer.
64
For purposes of this portion of the total cost estimate, Energy Commission staff assumed that
registration fees are at the maximum upper limit of $1,000 per retail station location and that
these fees will need to increase by 10 to 20 percent if ATC is mandated at retail stations in
California. As such, the costs to retail station operators is estimated to increase between $100 to
$200 per year per location to cover the increased time required to perform testing and
certification of fuel dispensers by county sealers or certified technicians. On a statewide basis,
that fee increase would amount to between $970,000 and $1.94 million per year. This
registration fee increase is expected to cover all additional expenses including new equipment
that may be required to test accuracy of ATC‐ modified or equipped retail fuel dispensers. It
should be noted that this would be an upper limit estimate for increased registration fees since
there are likely several counties that are below the $1,000 limit. In those circumstances, the
increased per‐station inspection fees would be less than those used in the staff estimate.
Summary of Initial ATC Retrofit Costs
If ATC is mandated for use at retail stations in California, total initial costs to retail station
owners are estimated to amount to between $94.1 million and $114.0 million or a per‐station
initial total cost of between $9,707 and $11,761. Alpine County had the lowest total initial cost
estimate of between $2,848 and $3,724 per station, while Orange County was estimated to have
the highest costs at between $11,533 and $13,647 per station. All of the county‐specific costs are
located in Appendix M.
Energy Commission staff assumed that the cost to pay for the ATC retrofit equipment
(including installation) would be accomplished through the use of business loans that would be
either secured (by real estate property and other assets) or unsecured. Although some retail
station owners may elect to pay the retrofit costs with cash or other liquid assets, for purposes
of calculating per‐gallon total costs on a statewide basis, staff used two different interest rates
and payback periods to bracket the upper and lower bounds of the total expenditures. The
higher per‐gallon ATC retrofit case assumes the cost to install the ATC retrofit kits (including
labor and slightly higher inspection fee) are financed through loans at the highest prime rate
experienced over the last decade and paid off within one year. The lower per‐gallon ATC
retrofit case assumes a loan at the lowest prime rate paid off over three years. The Prime Rate
(as published by the Wall Street Journal) is an aggregate of the lending rates of the top 75
percent of the nation’s banks. Over the last ten years, this rate has fluctuated between 4 and 9.5
percent as depicted in Figure 23.
Based on the high case borrowing assumptions discussed in the previous paragraph, staff
estimated that the statewide financing expenses (interest and various loan fees) for ATC retrofit
costs would amount to $13.3 million and be paid back over a period of one year at an average
interest rate of 9.5 percent.70 As such, the additional financing expenses would increase the
For purposes of this analysis, staff assumed that loan fees (points and other expenses) amounted to
70
2 percent of the loan amount.
65
statewide costs to a new total of $127.4 million or an average of $13,136 per retail station. Refer
to Appendix N for county‐specific results of the higher financing expense scenario. Staff
assumed that retail station owners will attempt to recover these costs by raising prices on
products that are sold at retail stations, both fuel and non‐fuel commodities. It is uncertain as to
how these price increases would be apportioned between the two classes of consumer goods,
but the industry as a whole is expected to be successful in passing all of these expenses through
to consumers over the long run.
Figure 23: Historical Prime Rate
10%
9%
8%
7%
6%
5%
4%
3%
2%
1%
0% Nov‐08
Nov‐98
Nov‐03
Dec‐00
Oct‐01
Jan‐03
Dec‐05
Oct‐06
Jan‐08
Apr‐99
May‐01
Apr‐04
May‐06
Feb‐00
Mar‐02
Aug‐02
Feb‐05
Mar‐07
Aug‐07
Jun‐03
Jun‐08
Sep‐99
Sep‐04
Jul‐00
Jul‐05
Source: Wall Street Journal
If one assumes that these costs will only be passed through to consumers by raising the price of
gasoline and diesel fuel over the useful lifetime of the fuel dispenser (10 years for the high
estimate and 15 years for the low estimate), then the incremental retail price would increase by
nearly seven hundredths (7/100) of a cent per gallon.
If the ATC retrofit expenses are financed through borrowing over a longer period of time
(3 years) and at a lower interest rate (4 percent), the statewide financing cost would amount to
$9.7 million and paid back by the retail station owners over 3 years. Total statewide initial costs
66
(including equipment, labor, and financing) for ATC retrofit at retail would be approximately
$103.8 million or an average of $10,704 per station. Assuming that these initial costs are
completely passed through to consumers over 15 years by only increasing fuel prices, the price
increase for gasoline and diesel fuel would be less at around four hundredths (4/100) of a cent
per gallon. Refer to Appendix O for county‐specific results of the lower financing expense
scenario. Regardless of the financing and payback period assumptions, the temporary cost to
consumers to retrofit retail stations with ATC devices would be extremely modest.
Recurring Annual Costs
If ATC is mandated for use at retail stations in California, there would be some level of
recurring costs for such items as increased device registration fees, ATC equipment for new or
refurbished stations, and periodic maintenance to service ATC devices.
The estimated inspection cost increase of $100 to $200 per station would be an incremental cost
for retail station owners that would continue indefinitely. That increased expense would equate
to between five thousandths (5/1000) and one hundredth (1/100) of a cent per gallon, an
insignificant value.
Another type of recurring cost related to ATC would be for slightly more expensive fuel
dispensers that are ATC capable that would be required to be installed at all new retail stations
or refurbished stations after ATC regulations became effective. ATC‐ready fuel dispensers are
estimated to reflect the additional electronics and other components that are already part of an
ATC retrofit kit. The additional expense of labor to install the devices in the field would not be
included in the estimated incremental expense because that work would already have been
performed in the factory.
Staff assumed that between 2,100 and 4,200 new dispensers would be installed throughout
California each year.71 All of the fuel dispensers are assumed to be electronic and capable of
blending mid‐grade gasoline within the dispenser. Approximately 85 percent of these
dispensers would deliver 3 grades of gasoline, while 15 percent are estimated to also dispense
71Energy Commission staff analyzed CMR Summary data for new retail motor fuel devices (or meters)
obtained from the Division of Measurement Standards. There were 6,671 new meters inspected at retail
stations over the last couple of years. Assuming that 85 percent of new fuel dispensers are designed for 3
fuel types and the remaining 15 percent designed for 4 different fuel types, there would be an average of
6.3 meters per new fuel dispenser. That means that there were an average of 529 new fuel dispensers
installed each of the last 2 years with a low of 509 and a high of 550. Based on comments received from
various stakeholders as part of the December 9, 2008, Committee Workshop proceedings, staff modified
the estimate of new fuel dispensers installed to a higher range of between 2,100 and 4,200 per year. The
lower figure assumes that all fuel dispensers would be replaced every 20 years, while the higher figure
assumes replacement every 10 years.
67
diesel fuel.72 As such, the incremental expenses for these types of dispensers are estimated to
average $1,810 each. The statewide incremental costs for these more expensive fuel dispensers
would amount to between $3.8 million and $7.6 million per year or between two hundredths
(2/100) and four hundredths (4/100) of a cent per gallon.
A final category of recurring ATC costs is periodic maintenance. Energy Commission staff has
learned that, if an ATC unit detects an error or “bad pulse,” it will abort any active transactions,
will show an error on the dispenser display, and would remain in that condition until the ATC
unit is power‐cycled.73 The ATC software in dispensers will notify the operator if there is a
current malfunction with the dispenser. These malfunctions would include the incorrect
pulsation of the device or the device not working. Uncertainty does exist on the timeliness and
the incentives for retailers in a warm state to quickly fix the problem. Over time, it is expected
that some percentage of ATC retrofit components will fail to operate properly, necessitating an
in‐field adjustment or replacement by a certified technician.
Staff is not aware of any field repair statistics available from Canada that could shed light on
this portion of the cost estimate, but understand that the overwhelming majority of new fuel
dispensers have warranties of at least 12 to 24 months. It is reasonable to assume that the ATC
retrofit kit components (pictured in Figure 24) are a combination of electronic, electrical, and
solid‐state probes. The lack of moving parts decreases the probability of significant failure rates.
In addition, if failure rates were significant, the companies that manufacture these kits would be
motivated to improve the ruggedness and field lifetime expectancy of the components to reduce
the expense incurred to service ATC‐ready dispensers still under warranty.
72 Staff estimate based on the ratio of diesel fuel availability at existing California retail stations per the
CEC A15 Retail Outlet Survey from 2007.
73 Evaluation Certificate Number TC7167, Project Number 800337. Issued by NMi Certin B.V.; Hugo de
Grootplein 1; 3314 EG Dordrecht, The Netherlands.
68
Figure 24: ATC Retrofit Kit
Photo Credit: Pump Service Automatic NV, http://www.pumpservice.be/engels/en_atc.htm.
Over the typical service life of a fuel dispenser, it is likely some degree of maintenance or repair
would be necessary that is directly related to the ATC components. Therefore, staff assumed
that some portion of the existing retail station locations will require some degree of ATC‐related
maintenance before the normal replacement cycle of the fuel dispensers. The low end of the
annual maintenance estimate assumes that 10 percent of all retail stations will require a service
technician to spend 8 hours of field time (at $60 per hour) and replace 25 percent of the initial
cost of the ATC components at the retail location. The labor costs were increased by
approximately 20 percent to allow for the increased expenses incurred for overnight stays in
rural locations and the travel time for the technician to the retail station. This set of assumptions
would amount to a recurring average statewide cost of $2.7 million, equivalent to 14
thousandths (14/1000) of a cent per gallon if applied to all gallons of gasoline and diesel fuel
sold at retail stations.74 The low maintenance scenario implies an average failure rate of 2.5
percent per year for ATC‐related equipment.
The actual per‐gallon cost valuation for a station owner who incurs the additional maintenance cost on
74
any given year will vary and be greater than the statewide valuation of 0.014 cents per gallon. Assuming
an average per‐station fuel sales volume, the maintenance cost for only those stations incurring the
additional expense could be up to 14 hundredths (14/100) of a cent per gallon for the low maintenance
cost estimate and up to 29 hundredths (29/100) of a cent per gallon for the high maintenance cost
69
The higher maintenance scenario assumes that 20 percent of all retail stations will require a
service technician to spend 16 hours of field time (at $70 per hour) and replace 50 percent of the
initial cost of the ATC components at the retail location. This set of assumptions would amount
to a recurring average statewide cost of $11.0 million, equivalent to six hundredths (6/100) of a
cent per gallon. The high maintenance scenario implies an average failure rate of 10 percent per
year for ATC‐related equipment.
ATC Retrofit Costs – Summary
ATC‐related costs are summarized in Table 6 for both the low and high estimates expressed in
total dollars and monetized in terms of cents per gallon of retail transportation fuel.
Table 6: ATC Retrofit Costs Summary
Low Cost Estimate High Cost Estimate
Statewide Cents Statewide Cents
Total Per Gallon Total Per Gallon
Initial Retrofit Costs
Equipment $84,180,731 0.0300 $84,180,731 0.0451
Labor & Increased Inspection Fee $9,938,300 0.0035 $29,853,925 0.0160
Financing $9,662,874 0.0034 $13,330,651 0.0071
Subtotal $103,781,905 0.0370 $127,365,308 0.0682
Recurring ATC‐Related Costs
Inspection Fees $969,600 0.0052 $1,939,200 0.0104
New Dispenser Incremental Costs $3,801,000 0.0203 $7,602,000 0.0407
ATC‐Related Maintenance $2,663,008 0.0143 $11,024,358 0.0590
Subtotal $7,433,608 0.0398 $20,565,558 0.1101
Source: Energy Commission staff analysis.
Note: Initial costs recovered over 15 years (low estimate) or over 10 years (high estimate).
Recovery of Expenses
Most retail station owners in California operate in a highly competitive business environment
that can, at times, create temporary difficulties and challenges with regard to recovering
increased expenses. This sphere of competition can consist of a single busy intersection that has
four retail stations, a short stretch of road where two to three stations and their retail fuel prices
are visually evident to motorists, or a single outlet in a small community. Each of these
examples highlights varying degrees of competition for any retail station operator and can
factor in his or her ability to pass through any and all incremental expenses to their customers.
estimate. However, this valuation is for illustrative purposes as retail station owners are expected to try
to pass along these incremental maintenance expenses by raising prices of fuel and non‐fuel commodities
that they sell.
70
However, in all of these situations, staff believes that retail station owners (in aggregate) may be
able to successfully pass along increased expenses over the long run, regardless of the type.
But this staff assumption, although plausible, is not a certainty considering the fact that the
convenience store industry profitability has declined between 2005 and 2007.75 Over this period
of time, expenses for the industry have been increasing at a faster rate than the industry’s
collective ability to pass 100 percent of increased expenses through to customers. Increased
expenses can include, but not be limited to, such items as higher wages, more expensive rents,
utilities, rising credit card fees, new regulatory requirements (such as enhanced vapor
recovery), and ATC. Increasingly higher charges by credit card companies for convenience store
owners have been especially challenging to recover having reached a total of $7.6 billion in
2007, more than double the size of total pre‐tax profits for the industry.76 It is recognized,
though, that even if the industry is able to eventually recover these increased expenses there
could be some retail establishments that will go out of business while new stations will emerge.
For any given retail station owner, there are also other variables that can affect the ability to
completely recover increased business expenses or the speed at which those costs can be
recovered. One such example is the types of revenue streams available at the retail stations. For
example, retail stations that sell both fuel and non‐fuel commodities (such as convenience
stores) have increased flexibility to attempt incremental expense recovery by increasing prices
for multiple goods (gasoline and foodstuffs) and/or services (car washes). A retail station that
only sells transportation fuels, however, has less flexibility and can only attempt to pass along
increased expenses by raising the price of fuel they sell. These types of retail stations are
estimated to account for less than 20 percent of the gasoline and diesel fuel sales.77 Based on
information obtained through the Energy Commission’s A15 Retail Outlet Annual Survey,
76 percent of the retail outlets in California are categorized as convenience stores.
Another factor that will help determine how successfully or quickly a retail station owner can
recover increased expenses is the average monthly or annual fuel sales. Obviously, retail
stations that have a higher‐than‐average throughput of retail fuel sales can distribute increased
expenses over a greater quantity of gallons, lessening the extent to which retail margins would
need to be increased relative to their competitors. The converse is also true, retail stations that
sell quantities of gasoline and diesel fuel that are below the California average of 160,550
gallons per month, would need to increase fuel prices to a higher level compared to a
competitor with higher monthly fuel sales volumes in order to recover an identical level of
expenses over the same period of time. The highest average retail fuel sales volumes in the state
were in San Bernardino County at an estimated 210,761 gallons per month, while the lowest
75 National Association of Convenience Stores, State of the Industry Report of 2007 Industry Data, 2008,
page 20. Convenience store industry pre‐tax profits were $5.9 billion in 2005, but declined to $4.8 billion
in 2006, and then dropped further to $3.4 billion in 2007.
76 Ibid, page 22.
77 National Association of Convenience Stores, The Convenience and Petroleum Retailing Industry,
February 1, 2008, [http://www.nacsonline.com/NACS/News/FactSheets/Pages/TheIndustry.aspx].
71
average was 54,569 gallons per month in Plumas County during the period April 2007 through
March 2008. A listing of each county and the average fuel sales is located in Appendix P.
Agency Costs
If ATC is mandated for use at retail stations in California, DMS would need to craft regulations
and conduct public workshops as part of a series of proceedings designed to culminate in new
rules for businesses and inspection procedures for county sealers. This regulation development
is assumed to be handled by DMS technical staff and management as part of their normal
activities and should not require additional funding or positions.
Evaluation testing of ATC retrofit kits, as well as ATC‐capable fuel dispensers, to ensure
accurate performance, durability, and ability to maintain calibration is known as “type‐
evaluation.” Applicants in this program are charged fees designed to cover related expenses
incurred by DMS. This portion of ATC‐related activity would be self‐ funding, as those fees are
paid by the manufacturers of the devices. It is uncertain whether any additional staffing
positions would be necessary for this type of work, but it should be noted as a possibility.
Potential Impacts on Fuel Availability for Isolated Locations
If ATC is mandated at retail stations in California, it is possible that the expense to comply with
the regulation could be onerous for some station owners. Further, some of these station owners
may be unable to obtain adequate financing and could possibly shutter their business. Under
such circumstances, this development could result in the loss of retail fuel supplies for
consumers. Usually the closure of a retail station in an urban area does not result in the
unavailability of retail fuel for motorists that normally frequent the retail establishment, as long
as there are alternative retail stations within reasonable proximity to the station that had to go
out of business. There can be other circumstances, though, when the retail station may be either
the sole source or one of only two sources of retail fuel for a community.
If ATC is required in California, there should be provisions to ensure that retail stations serving
isolated California communities receive special consideration for financial assistance. Criteria
should be developed to identify candidate retail stations and revenue sources developed to
fund ATC retrofit installations. One potential source of additional revenue would be to assess a
special fee on gasoline and diesel fuel for a period of six months. As an example, a fee of
two hundredths (2/100) of a cent per gallon would generate approximately $1.9 million. Staff
has estimated that ATC retrofit costs for approximately 200 locations (2 percent of all retail
outlets) could be fully financed through this 6‐month temporary fee structure.78
Energy Commission staff estimates that there are currently 150 communities in the state that have
78
either one or two sources of retail fuel, with the next alternative source of retail fuel supply a minimum of
10 miles driving distance (one way) from the community. The number of retail stations that currently
meet the above criteria is estimated at 182 locations. Appendix Q contains a list of the number of retail
72
ATC Retrofit Cost Conclusions
If ATC is mandated for use at retail stations in California:
• The maximum limit stipulated in subdivision (n), Section 12240, California Business and
Professions Code would need to be increased to at least $1,200 to ensure that counties will
be able to recover all of their additional costs of performing inspections and certifications.
• There should be provisions to ensure that retail stations serving isolated California
communities receive special consideration for financial assistance. One such example would
be the assessment of a special fee of two hundredths (2/100) of a cent per gallon on all
gasoline and diesel fuel wholesale transactions for a period of six months to cover the
expenses incurred for ATC retrofit for retail stations that meet all of the criteria established
by the DMS in consultation with appropriate state agencies.
Potential Consumer Benefits Resulting From ATC Retrofit
Mandating the use of ATC at retail stations in California has been proposed by certain
stakeholders because the anticipated consumer benefits are expected to outweigh the costs.
“Consumers,” in this context, refers to California motorists who purchase gasoline and diesel
fuel at retail stations. This section of the report details the staff efforts to properly characterize
and quantify these potential benefits. “Consumer benefits” have been denoted as the monetary
value of the additional transportation fuel that California motorists would have received if ATC
devices had been in place during the study period. The additional fuel would be in slightly
larger size gallons as measured in cubic inches that would occur under circumstances in which
retail fuel temperatures are warmer than 60 degrees Fahrenheit. Retail transactions transitioning
from gross to net gallons will not alter the total demand for fuel consumed over the study
period, but rather result in variable size gallons depending on temperature. The main question
to address is whether consumers would retain the additional cubic inches dispensed from ATC
fuel dispensers during warmer period of the year without any attempt by retail station owners
to raise the price of the fuel to compensate for selling slightly larger‐sized “gallons”.
Quantification of Potential Consumer Benefits
Various stakeholders claim that retail station owners are receiving higher profits during the
summer months and that a conversion to ATC at retail stations will benefit motorists by
providing them with slightly larger‐sized gallons, but with no or little adjustment to the retail
price of the fuel. Although consumers would receive slightly larger‐sized gallons as measured
in terms of cubic inches, the actual units sold by the retail station owners would decline as a
stations by county and the estimated costs to retrofit those locations. Additional costs of technician travel
time and cost of overnight stays has been factored in to these expense estimates.
73
result of a conversion from gross to net gallons at retail. The more important point that has
direct bearing on potential benefits for motorists has to do with the expected reaction by retail
station owners to ATC at retail. Is it reasonable to assume that retail station owners will not
increase their fuel prices if the cost of their fuel remains unchanged (wholesale purchase of net
gallons) and the expected number of units sold declines? Staff assumes that the industry of
retail station owners and operators will continue to grow and remain profitable.
The conclusion, therefore, is that retail station owners will in fact raise their fuel prices to
compensate for selling fewer units, all other things being equal.79 The quantification of the
reduced number of units and a valuation of their worth during the study period are presented
in the following paragraphs only to illustrate the magnitude of the anticipated retail price
adjustment.
Energy Commission staff used retail fuel temperature, volume correction factor (VCF)
equations, and retail fuel prices to quantify the net change in cubic inches that would have been
dispensed if retail stations had been selling gasoline and diesel fuel as net gallons instead of
gross gallons. It is recognized that the total volume of fuel sold during the study period would
have remained unchanged. However, the primary difference would have manifested itself in
the decreased quantity of “gallons” as measured on a net basis. For example, during the study
period there were 15.625 billion gross gallons sold at retail that equated to 3,609.375 billion
cubic inches. If ATC had been in effect at retail during the same period of time, the quantity of
net gallons of gasoline sold would have been approximately 15.508 billion or about 117 million
gallons less compared to status quo (no ATC at retail) because the fuel was warmer (71.1
degrees Fahrenheit) than the 60 degree Fahrenheit reference standard. Under the ATC scenario,
the quantity of net gallons of diesel fuel sold would have been approximately 3.037 billion or
about 19 million gallons less compared to status quo (no ATC at retail) of 3.056 billion because
the fuel was also warmer (72.9 degrees Fahrenheit) than the 60 degree Fahrenheit reference
standard.
The next step in the analysis was to match these decreased quantities of gallons with the retail
prices of the fuel during the study period. Doing so, staff calculated that the decreased
quantities of gasoline gallons were valued at about $376.4 million and diesel fuel at about $61.1
million. Appendix R details the county‐specific valuation. This amount of money is the
representative value of the reduced quantity of gallons for which consumers would not have
purchased if ATC had been in place at retail stations in California during the study period.
However, this potential benefit to consumers perceived by some stakeholders is not expected to
79 The outlook for convenience stores (that sell transportation fuels) in the United States appears to be one
of growth. According to statistics developed by Willard Bishop, convenience store numbers are forecast
to increase from 120,740 in 2007 to 142,026 by 2012. Annual sales of non‐fuel goods (groceries and
consumables) are also expected to rise from a per‐store average of $1.03 million in 2007 to $1.18 million by
2012. Bishop, Willard, The Future of Food Retailing, June 2008, [http://www.willardbishop.com/filebin
/200806FFR.pdf].
74
materialize. Rather, the retail station owners are expected to adjust the price of the new units to
a slightly higher level to try and maintain similar levels of profitability in a post ATC scenario.
Quantification of Increased Price Transparency Benefits
Energy Commission staff acknowledges that having no knowledge of fuel temperature at the
time of a transaction creates a problem because retail fuel consumers cannot adequately
compare the benefits or value of fuel prices advertised by two competing retail stations. If
consumers seek the lowest priced fuel and if temperature variation is not taken into account in
the advertised price per gallon, a consumer could potentially buy a higher priced gallon when
they could have received a better value if they had knowledge of the net price of that gallon. For
example, a 15 degree Fahrenheit difference in temperature would produce an approximate one
percent expansion or contraction of actual volume of fuel delivered, translating to a three cent
per gallon variance in value received if the fuel were advertised at $3.00 per gallon. If the
competing stations’ respective advertised prices vary by only 2 cents per gallon, value
comparison is not facilitated.
A mandated implementation of ATC will remove the effects of temperature variance and would
remove information asymmetry as it involves the temperature of the fuel. This would force
retailers to price gasoline and diesel products in net gallons, which would allow consumers to
more accurately compare the prices among retail stations and retail station owners to more
competitively price their fuel. By improving the retail price transparency for retail motorists and
station owners, an inefficiency in the marketplace is corrected resulting in a monetary benefit
for society, albeit quite small. In economics, this consumer benefit is described as elimination of
deadweight loss. Staff had originally calculated this value to be approximately $3.2 million per
year. However, additional information provided during the December 9, 2008, Committee
Workshop and documents submitted to the docket during January 2009 provided new
analytical insight that allowed staff to modify the earlier work and to take into account other
factors not addressed in the earlier analysis (discussed in greater detail in Appendix S). As a
consequence of these adjustments, the revised societal benefit of increased price transparency or
removal of deadweight loss is now estimated at a little more than $250,000 per year.
The assumed net benefit to society, including business operators and consumers, would come
through the ability of consumers to perform accurate value comparison in shopping among
competing fuel retailers, as advertised per‐gallon prices would reflect gallons of the same size
under equivalent conditions (i.e., adjusted automatically to a 60 degree Fahrenheit reference
standard). Station operators would benefit from the facilitation of fair competition achieved by
such clarification. Any uncertainty regarding whether or not temperature influences had been
factored into the advertised per‐gallon price would be removed and the consumer’s selection of
the lowest priced fuel would consistently result in an actual savings to the consumer.
Measurement Canada, the governmental organization that oversees ATC in that country,
describes consumer benefits in terms of more accurate retail transactions and increased
75
consumer fairness. The following language is taken from their information bulletin dated
January 1, 2008:
“What are the benefits of using ATC for the purchase and sale of gasoline?
Automatic temperature compensation is a more accurate and equitable method of
measuring gasoline as it removes the effect of temperature on the volume of
gasoline. The purchase and sale of gasoline based on a common reference
temperature allows gasoline retailers to sell product on the same basis as it was
purchased (facilitating accurate product inventories and early detection of product
loss). The use of gasoline pumps equipped with automatic temperature
compensation benefits consumers by removing the effects of temperature when
purchasing gasoline.”80
Quantification of Fairness
The concept of increased fairness for motorists has been raised by some stakeholders as a type
of benefit that has not been accounted for in the cost‐benefit‐analysis. Some stakeholders believe
that the collective benefits for motorists that would result from a conversion to ATC at retail
station could amount to hundreds of millions of dollars per year in California. Although no
quantification of “fairness” has been attempted as part of these proceedings due to the
subjective nature of this perceived consumer benefit, there are some research survey techniques
and methodologies that could be used to provide some valuable insight into this variable and
subjective consumer belief.
ATC Retrofit Cost-Benefit Analysis Results for Society
The following tables depict the results of ATC at retail stations under three scenarios: retrofit of
existing stations (low estimate), retrofit of existing stations (high estimate), and gradual phase‐
in of ATC devices at retail stations. Assuming that the transition from gross gallons to net
gallon at retail results in a corresponding price increase by retail station owners, the only benefit
for society of ATC at retail would be the value of increased price transparency or elimination of
deadweight loss. If retail station owners are completely successful in recovering their initial
expenses (equipment, labor, and financing) by raising prices of fuel and non‐fuel commodities
at a commensurate and offsetting rate over the payback period, then theoretically the
implementation of ATC at retail stations in California will result in a net cost to consumers,
albeit extremely small.
The cost‐benefit analysis results for the lower estimate of ATC retrofit for all retail stations are
presented in Table 7. Net costs to society amount to approximately $245 million and range
80 Measurement Canada, Selection of Volume Correction Factor Tables and Standard Density Values for Some
Common Products, Bulletin V‐18 (rev. 5), April 1, 2008, [http://www.ic.gc.ca/eic/site/mc‐mc.nsf/eng
/lm00116.html].
76
between four hundredths (4/100) and seven hundredths (7/100) of a cent per gallon over a 20‐
year period. After applying a discount rate of 5 percent over the 20‐year time period to obtain a
single unit of measure of net present value (since $100 today is more valuable to a person than
$100 ten years from now), the net present value of costs amounts to about $165 million. The
assumptions used to create this estimate are that demand and price for transportation fuels
remain fixed over the next two decades. All of the retrofits are completed within the first couple
of years and their associated expenses are completely recovered by retail station owners over a
15‐year period of time. Increased transparency benefits do not begin until the ATC devices are
activated in the third year.
77
applying a discount rate of 3 percent, the net present value of costs amounts to about $417
million.
Table 8: ATC Retrofit – CBA High Cost Summary
A B C (A+B)‐C
Initial Recurring Increased Present
Industry Industry Transparency Value of
Costs Costs Benefits Net Costs Net Costs Net Costs
Year Dollars Dollars Dollars Dollars CPG Dollars
$127,365,308 $20,565,558 $257,729
1 $12,736,531 $18,626,358 $0 $31,362,889 0.1679 $31,362,889
2 $12,736,531 $18,626,358 $0 $31,362,889 0.1679 $30,422,002
3 $12,736,531 $20,565,558 $257,729 $33,044,360 0.1769 $31,091,438
4 $12,736,531 $20,565,558 $257,729 $33,044,360 0.1769 $30,158,695
5 $12,736,531 $20,565,558 $257,729 $33,044,360 0.1769 $29,253,934
6 $12,736,531 $20,565,558 $257,729 $33,044,360 0.1769 $28,376,316
7 $12,736,531 $20,565,558 $257,729 $33,044,360 0.1769 $27,525,027
8 $12,736,531 $20,565,558 $257,729 $33,044,360 0.1769 $26,699,276
9 $12,736,531 $20,565,558 $257,729 $33,044,360 0.1769 $25,898,297
10 $12,736,531 $20,565,558 $257,729 $33,044,360 0.1769 $25,121,349
11 $0 $20,565,558 $257,729 $20,307,829 0.1087 $14,975,483
12 $0 $20,565,558 $257,729 $20,307,829 0.1087 $14,526,219
13 $0 $20,565,558 $257,729 $20,307,829 0.1087 $14,090,432
14 $0 $20,565,558 $257,729 $20,307,829 0.1087 $13,667,719
15 $0 $20,565,558 $257,729 $20,307,829 0.1087 $13,257,687
16 $0 $20,565,558 $257,729 $20,307,829 0.1087 $12,859,957
17 $0 $20,565,558 $257,729 $20,307,829 0.1087 $12,474,158
18 $0 $20,565,558 $257,729 $20,307,829 0.1087 $12,099,933
19 $0 $20,565,558 $257,729 $20,307,829 0.1087 $11,736,935
20 $0 $20,565,558 $257,729 $20,307,829 0.1087 $11,384,827
Totals $127,365,308 $407,432,758 $4,639,122 $530,158,944 $416,982,573
Source: Energy Commission staff analysis.
Discount rate of 3 percent used to calculate net present values.
Table 9 presents the cost and benefit results of gradually phasing in ATC equipment at retail
stations. Under this scenario, all fuel dispensers installed at new or refurbished retail stations
would need to be ATC‐ready, but not activated. It is estimated that nearly 50 percent of the fuel
dispensers in California could be replaced through this natural form of replacement over five
years, negating the additional expense for labor to retrofit an existing fuel dispensers in the
field. The remaining portion of the fuel dispensers would then be retrofitted during the fifth
year. That portion of the work would also include the additional expenses associated with
installation labor, travel costs, and financing. Net costs to society of this scenario amount to
approximately $205 million and range between one hundredth (1/100) and nine hundredths
(9/100) of a cent per gallon over a 20‐year period. After applying a discount rate of 5 percent, the
net present value of costs amounts to about $127 million.
78
Table 9: Gradual ATC Phase-in – CBA Cost Summary
A B C (A+B)‐C
Initial Recurring Increased Present
Industry Industry Transparency Value of
Costs Costs Benefits Net Costs Net Costs Net Costs
Year Dollars Dollars Dollars Dollars CPG Dollars
$84,180,731 $7,433,608 $257,729
1 $841,807 $266,301 $0 $1,108,108 0.0059 $1,108,108
2 $1,683,615 $532,602 $0 $2,216,216 0.0119 $2,105,405
3 $2,525,422 $798,902 $0 $3,324,324 0.0178 $3,000,203
4 $3,367,229 $1,065,203 $0 $4,432,432 0.0237 $3,800,257
5 $9,398,132 $1,331,504 $0 $10,729,636 0.0574 $8,739,355
6 $9,398,132 $6,464,008 $257,729 $15,604,411 0.0835 $12,074,396
7 $9,398,132 $7,433,608 $257,729 $16,574,011 0.0887 $12,183,421
8 $9,398,132 $7,433,608 $257,729 $16,574,011 0.0887 $11,574,250
9 $9,398,132 $7,433,608 $257,729 $16,574,011 0.0887 $10,995,537
10 $9,398,132 $7,433,608 $257,729 $16,574,011 0.0887 $10,445,760
11 $8,556,324 $7,433,608 $257,729 $15,732,203 0.0842 $9,419,451
12 $7,714,517 $7,433,608 $257,729 $14,890,396 0.0797 $8,469,659
13 $6,872,710 $7,433,608 $257,729 $14,048,589 0.0752 $7,591,297
14 $6,030,903 $7,433,608 $257,729 $13,206,781 0.0707 $6,779,597
15 $0 $7,433,608 $257,729 $7,175,879 0.0384 $3,499,497
16 $0 $7,433,608 $257,729 $7,175,879 0.0384 $3,324,522
17 $0 $7,433,608 $257,729 $7,175,879 0.0384 $3,158,296
18 $0 $7,433,608 $257,729 $7,175,879 0.0384 $3,000,381
19 $0 $7,433,608 $257,729 $7,175,879 0.0384 $2,850,362
20 $0 $7,433,608 $257,729 $7,175,879 0.0384 $2,707,844
Totals $93,981,318 $114,529,030 $3,865,935 $204,644,413 $126,827,596
Source: Energy Commission staff analysis.
Discount rate of 5 percent used to calculate net present values.
Although the total cost of the ATC‐ready dispensers would be lower under this scenario, it
should also be noted that the relative economic burden to the retail station owner would be
lessened as well. The reason is that the cost of the incremental costs of the ATC‐ready
dispensers of between $8,000 and $12,000 per retail station are quite small when compared to
the total costs for a new retail station that are estimated by the National Association of
Convenience Stores (NACS) to range between $2.5 and $3.2 million per site. This means that the
additional expense amounted to roughly 0.3 to 0.4 percent of the total business expense. For
remodeled retail stations, the relative percentage of the incremental costs for ATC‐ready
dispensers is greater (about 4 percent) because the expense of a remodeled retail station is much
less, roughly $312,000 during 2007. 81 However, the relative costs for the owner of an existing
retail station are much greater, $8,000 to $12,000 versus zero (assuming no remodeling plans for
81 NACS State of the Industry Report, 2007 data.
79
the facility). This is why the option of a gradual phase‐in of ATC devices at retail stations is the
more favorable compliance pathway if ATC was to be mandated at retail stations in California.
A final point pertaining to the total costs for these various ATC retail options involves a
comparison to expected expenditures for transportation fuels by consumers and business
owners over the 20‐year period. Although the total net costs to society of between $127 million
and $417 million (expressed in terms of present value) appear to be quite large, it should be
recognized that these values are very small when compared to the expected expenditures for
transportation fuels in California over the same period of between $700 billion and $1.4
trillion.82
82 Assumes nearly 18.7 billion gallons of gasoline and diesel fuel are purchased each year at an average
cost of $3 per gallon. The lower present value estimate assumes a discount rate of 5 percent, while the
higher fuel expenditure present value estimate assumes a discount rate of 3 percent.
83 In this context, the “motorists” who may have benefited were those people who purchased their
transportation fuel at a convenience store, but did not purchase any non‐fuel items during their fueling
event. Information from the Convenience Store News indicates that a new analytical approach employed
by Homescan allowed them to determine that 9 of the 23 household trips to convenience stores during
2007 were gas trips only. This information implies that about 39 percent of household trips to
convenience stores were for purposes of purchasing gasoline only, significantly higher than the 10
percent average estimate assumed by Energy Commission staff. Convenience Store News, 2008 Extended
Industry Report, May 2008, page 7.
80
Retail Station Characteristics and Trends
Retail fueling stations in the United States have evolved from facilities that, in the early years of
automobile development, sold fuel, lubricants, and provided repairs to motorists. A number of
stations in more remote portions of the nation’s roadways also provided lodging. However, the
days of helpful attendants (as depicted in Figure 25) and garage repair services are all but a
memory.
Like most types of businesses, selling transportation fuel to the motoring public has undergone
significant change. Gasoline stations have been transformed into fueling locations that offer a
plethora of non‐fuel goods and services designed to enhance revenue streams and increase
profitability. The early roots of the convenience store chain can be traced back to the late 1920s
when the Southland Ice Company of Dallas, Texas, started selling everyday fresh goods such as
eggs, milk, and bread from their ice docks. That company, now referred to as 7‐Eleven, has
transformed into a business with more than 18,000 convenience stores located in
18 countries around the world.84
Figure 25: Service Station of the Past - 1936
Source: Online Archive of California, [http://oac.cdlib.org/].
Funding Universe, Company Perspectives, 7‐Eleven, Inc., [http://www.fundinguniverse.com/company‐
84
histories/7Eleven‐Inc‐Company‐History.html].
81
During 2007, more than 80 percent of the gasoline sold to the public nationwide was through
convenience stores.85 These places of business have continued to be profitable over the last
decade, averaging nearly $33,000 per store pre‐tax profits between 1998 and 2007. Figure 26
shows that these profits are not steady, but can fluctuate over time.
Figure 26: United States Convenience Store Pre-Tax Profits
$45,000
$40,000
$35,000
$30,000
Average Per Store
$25,000
$20,000
$15,000
$10,000
$5,000
$0
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
Source: NACS State of the Industry Report data.
Profit margins for convenience stores across the United States show that in‐store sales (non‐fuel)
have a consistently higher and steadier profit margin, relative to that of the steadily declining
profit margins for fuel sales as depicted in Figure 27.
Declining gross profit margins for convenience store motor fuel sales can be interpreted to
indicate that retail store operators are having to price their retail gasoline and diesel fuel at
increasingly competitive prices and lower profit margins (as a percent of total price), to
National Association of Convenience Stores, The Convenience and Petroleum Retailing Industry,
85
February 1, 2008, [http://www.nacsonline.com/NACS/News/FactSheets/Pages/TheIndustry.aspx].
82
continue attracting a sufficient number of in‐store customers purchasing non‐fuel commodities
to help sustain overall profitability. Declining profit margins for motor fuel sales, however, does
not necessarily mean that the per‐gallon margin for motor fuel is also declining. Fluctuations in
average annual retail fuel prices for the United States in combination with declining profit
margins have actually resulted in a rather steady margin for motor fuel sales at convenience
stores as evidenced by the values in Figure 28. Staff interprets these stable per‐gallon margins as
an indication that the ability of convenience store owners to pass through increased expenses by
increasing the price of their gasoline and diesel fuel only is not reflected in the overall trend.
Therefore, retail station owners will likely have to recapture a portion of the revenue shift by
raising prices of non‐fuel commodities.
Figure 27: United States Convenience Store Financial Trends
35
30
25
Gross Profit Margin
20
15
10
5
In‐Store Motor Fuel Combined
0
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
Source: NACS State of the Industry Report data.
83
Figure 28: United States Convenience Store Per-Gallon Margins
18
16
14
12
Cents Per Gallon
10
0
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
Source: NACS State of the Industry Report data.
84
CHAPTER 5:
New Reference Temperature Option
This chapter includes details associated with an option similar to the approach taken in Hawaii,
adjusting the retail fuel dispensers to distribute an additional quantity of fuel (as measured in
cubic inches). The purpose of the adjustment was to increase the total number of cubic inches
contained in each “gallon” sold to a quantity that would represent the expanded volume that
would result from warming a standard gallon of fuel from 60 degrees Fahrenheit to a higher
temperature that is intended to represent the average annual fuel temperature. In the case of
Hawaii, it was ultimately decided that the average target temperature would be 80 degrees
Fahrenheit.
The new reference temperature approach for California would work in a similar fashion, the
retail fuel dispensers would be modified to distribute an additional quantity of fuel that would
reflect how much an individual standard gallon would have expanded if the gasoline was
warmed from 60 degrees Fahrenheit to 71.7 degrees Fahrenheit (average temperature of regular
grade gasoline during the study period).
It should be noted that the resulting non‐standard gallons dispensed in a new reference
temperature scenario would always be the same size (as measured in cubic inches) regardless of
the actual fuel temperature. The dispensed gasoline gallon would only be accurate in terms of
“temperature adjustment” at precisely 80 degrees Fahrenheit for Hawaii and 71.7 degrees
Fahrenheit for California.
Overview
Requiring new reference temperatures for gasoline and diesel fuel (that are higher than the
current standard or temperature‐assigned gallon of 60 degrees Fahrenheit) would involve
adjusting each retail fuel dispenser in California to provide more than 231 cubic inches to
consumers for each gallon they purchase. How much larger these new “California gallons”
would be depends on the statewide average annual temperature of gasoline and diesel fuel in
conjunction with their assumed density values.
The new size of these non‐standard gallons will be determined using volume correction
formulas based on Energy Commission’s collected density and fuel temperature data analysis.
Using this methodology, the new California gallon capacity would increase from 231 cubic
inches to 232.7 cubic inches for gasoline and to 232.4 cubic inches for diesel fuel. Therefore,
retail gasoline dispensers would need to be modified such that an additional 1.7 cubic inches
would be distributed for each non‐standard gallon (231 cubic inches at any temperature) sold to
the consumer such that the resulting volume would amount to 232.7 cubic inches. These new
85
size California gallons would be dispensed to retail fuel consumers each and every instance,
regardless of different temperatures on a regional or seasonal basis in California.
The new values were calculated by using the API Table 6B VCF software and assuming the
gasoline in the very near future will contain 10 percent ethanol (E10). The average density of
E10 will be 57.9 API gravity, while the volume correction factor (VCF) at 71.1 degrees would be
0.99261. This means that the new statewide, year‐round ʺCalifornia gasoline gallonʺ would
equate to 232.72 cubic inches, rather than 231.0 cubic inches for the current non‐standard or
gross retail gallon.
For diesel fuel with an assumed API gravity of 38.5 and an average statewide, year‐round
temperature of 72.9, the VCF (per the software) is 0.99391. The new ʺCalifornia diesel gallonʺ
would be 232.42 cubic inches.
The Division of Measurement Standards (DMS) informed Energy Commission staff that the
alternative option of regional reference temperatures should be omitted from the cost‐benefit
analysis. The existence of different regional reference temperatures would create regulatory
confusion along with confusion in the industry. An example of one of the difficulties that
regional reference temperatures could create is the use of multiple calibration and certification
protocols that would be necessary to create several different regions throughout the state that
have varying size California gallons as measured in terms of cubic inches. Development of such
variable inspection and certification procedures in conjunction with the creation of multiple
new jurisdictions that cross county boundaries could create difficulties for enforcement officials.
Staff believes, therefore, that a regional reference temperature approach may create too many
difficulties and should not be considered as an option to pursue in California.
Costs
Energy Commission staff assumed that no new equipment or labor costs to install devices will
occur under the statewide reference temperature option. The only cost will be a one‐time
calibration adjustment of the fuel dispenser so that each gallon sold to retail fuel consumers
meets the new size definitions. Although this adjustment, in theory, could probably be
accomplished by county sealers during their normal inspection and certification visit, staff
assumed that a certified technician would need to make the fuel dispenser modifications.
Further, staff assumed that no new parts would be necessary.
For purposes of quantifying labor costs associated with a new statewide reference temperature
standard, staff assumed that the estimated range of labor costs identified as part of the ATC
retrofit option would also be used in this option’s cost calculation. Staff recognized that the per‐
dispenser labor hours could be less, but took a more conservative approach to help compensate
for any additional unforeseen costs that would be necessary beyond minor adjustments to
electronic and mechanical dispensers. Therefore, the estimated costs of a new reference
temperature and associated larger gallon size (in cubic inches) could amount to between $9.0
86
million and $27.9 million or from $925 to $2,879 per retail station. On a per‐gallon basis these
additional expenses incurred by retail station owners would equate to between five hundredths
(5/100) and 15 hundredths (15/100) of a cent per gallon for only one year. If the expenses
incurred by retail station owners were recovered over a longer period of time, the per‐gallon
costs would decline significantly, but be present for a longer period of time. For example, the
costs would amount to between 5 thousandths (5/1000) and 15 thousandths (15/1000) of a cent
per gallon if completely recovered over a period of 10 years. After the modifications were
completed, there would be no additional recurring costs.
Benefits
The new statewide reference temperature will not eliminate variability of fuel temperatures, but
would set the standard such that the additional volume received by retail consumers (as
measured in cubic inches) would be the same (in theory) as they would have received prior to
modifying the dispensers. Since the size of the California gallon will be fixed at a permanently
larger size, this type of change could be viewed as similar to transitioning from U.S. gallons to
the metric system. As a direct consequence, the number of California gallons sold in a particular
year would be less when compared to the number of U.S. gallons that would have been sold at
231 cubic inches in size.
Staff believes that the retail station owners will realize that the new reference standard option
will decrease the number of “gallons” sold and will compensate by raising retail prices to avoid
any potential permanent decrease in revenues. In other words, the potential expected benefits
for retail fuel consumers would therefore be zero.
Unlike the ATC retrofit option, there will be no uncertainty by retail station owners concerning
the day‐to‐day size of each gallon due to variability in temperatures because the size of the new
California gasoline gallon will always be 232.7 cubic inches, regardless of fuel temperature.
Potential Net Costs or Benefits
Staff calculated the statewide reference temperature option to have a net cost in the first year of
between five hundredths (5/100) and 15 hundredths (15/100) of a cent per gallon, followed by a
zero net cost/benefit in the following years.
Compliance Schedule
If a statewide reference temperature option was mandated for use at California retail stations,
the implementation schedule is less complex than that of the ATC retrofit option. In this case,
adjustments by certified technicians to retail fuel dispensers could be accomplished over several
months. Only one visit would be required to complete the work without the use of any new
equipment or components. It would be optimal for the conversion of the dispensers to take
place during the time of year when fuel temperatures are anticipated to be close to the current
87
reference standard of 60 degrees Fahrenheit. This approach would be consistent with the
optimal conversion timing discussed for the ATC retrofit option. Prior to any adjustments to
existing fuel dispensers, though, authority would need to be granted to DMS through
enactment of new legislation, and regulations would need to be developed by DMS to clarify
procedures that would have to be adhered to by certified technicians and county sealers. These
procedural steps could take between 18 and 24 months to complete.
88
CHAPTER 6:
Related Issues
An assessment of automatic temperature compensation (ATC) entails more than a
quantification of potential benefits and costs. There are several other issues that need to be
addressed to better understand ATC in a broader context and conclusions regarding procedures
that should be considered if such regulations were to be mandated for use in California.
86 The Gilbarco Model Nxx series was approved with electronic Automatic Temperature Compensation
capability that became effective on May 17, 2007. Department of Food and Agriculture, Division of
Management Standards, California Type Evaluation Program, “Certificate of Approval for Weighing and
Measuring Devices,” Certificate Number 5510(a)‐07, [http://www.cdfa.ca.gov/dms/programs/ctep
/CTEPApprovals/PDF2007/5510a‐07.pdf].
87 CIOMA issued a letter to DMS requesting adoption of emergency regulations to prevent any retail
station operators from installing ATC‐ready fuel dispensers. The request was denied by DMS on grounds
that the agency did not have authority to promulgate such a regulatory modification without legislative
directive. McKeeman, Jay, “Letter From CIOMA Regarding Temperature Compensating Devices,”
February 15, 2008, [http://www.energy.ca.gov/transportation/fuel_delivery_temperature_study
/documents/index.html].
89
be activated, either upon installation or later at the discretion of the retail station operator. DMS
regulations do, though, specify that, if ATC is operated at retail, it must remain active for 12
consecutive months at a time. This requirement precludes the selective use of ATC at retail to
solely benefit the station operator on a seasonal basis (such as operating the device when the
fuel is colder than the 60 degree Fahrenheit reference temperature and disabling the ATC
function when fuel temperatures rise above 60 degrees Fahrenheit).
Even the ability to activate an approved ATC‐ready fuel dispenser would be difficult without
any established procedures for properly assessing the calibration of the device. It would be
these same sets of protocols that would need to be followed by a county sealer during an
inspection and fuel dispenser recertification visit.
The fact that there are no regulatory guidance standards for labeling of fuel dispensers or large
signs could lead to consumer confusion at the initial stages of permissive ATC use at retail
stations. Over time, consumers would become more knowledgeable of circumstances that could
be beneficial to them in a permissive ATC environment, namely electing to fill‐up at stations
advertising ATC during the warmer months, while avoiding ATC stations during the coldest
months (assuming non‐ATC stations are readily available options). Adequate labeling
requirements would be necessary to empower consumers with sufficient information so as to
make a better informed decision. Permissive ATC without adequate regulatory structure does
not ensure that sufficient labeling standards would be adhered to by an ATC fuel retailer.
Lastly, there would be the possibility that permissive ATC retail fuel dispenser use could be
viewed as a marketing advantage, especially during the warmer months of the year. To
succeed, this scenario would require that the retailer advertise the fact that he or she has ATC
fuel dispensers on the large sign, thereby enticing the consumer into the station, and consumers
would have to understand the beneficial significance. Since temperature compensation has been
a media issue in California for several months, it is likely that motorists understand the benefits
of going to an ATC station during the summer months. It is also highly probable that a
permissive ATC retailer would realize the potential for increased numbers of customers that
could be attracted assuming other retail stations within their immediate sphere of competition
do not also have ATC fuel dispensers. A permissive ATC environment with partial adoption in
a state with generally warmer fuel temperatures could result in a marketing disadvantage to
those retailers who did not have ATC fuel dispensers.
In order to diminish or eliminate any potential disagreements or misinterpretations involving
permissive use of ATC at retail stations in California, it is recommended that the California
Legislature consider clarifying the use of ATC at retail stations. If the Legislature chooses not to
mandate the use of ATC at retail stations, they should clarify if the current intent of the existing
statutes is to permit or prohibit voluntary ATC at retail outlets for gasoline and diesel fuel. If the
Legislature chooses to permit or mandate ATC at retail, they should direct the California
Division of Measurement Standards to develop standards addressing equipment approval,
90
certification testing, compliance enforcement, and consumer labeling provisions for ATC at
retail stations.
Labeling
Temperature compensation, if recommended for application at retail, should include
regulations that help to ensure that consumers will be provided with information sufficient to
alert a motorist to the presence of ATC at the service station. There are several options to
consider for conveying ATC information, such as labels on the fuel dispenser, large retail station
display signs, and printed sales receipts.
Fuel Dispenser Labels
Fuel dispensers could be labeled with a brief notation indicating the use of ATC. It would be
most advantageous if the message was mandatory, consistent at all stations, and brief. Canada
has taken the approach to label the fuel dispensers with “Volume corrected to 15° C” (see
Figure 29).88 A similar labeling approach could be used in California that would require a brief
message on the fuel dispenser, such as: “Corrected to 60 degrees Fahrenheit.”
In California, the Division of Measurement Standards (DMS) has existing legal authority
regarding labeling of fuel dispensers and has developed specific regulations stipulating
requirements for such labeling.89 It is possible that this portion of the regulations could be
amended to include ATC fuel dispenser labeling requirements.
The cost of fuel dispenser labels is estimated to be modest, amounting to no more than $20 per
dispenser. Most small pump decals used in the retail fuel industry cost less than $5, such as the
sticker sold by one retail company that reads “Contains 10% or less ethanol.”90
88 Measurement Canada is the government agency responsible for setting the rules of the marketplace
with respect to trade measurement. This agency requires labeling of any meter that is equipped with an
automatic temperature compensator. See Section 21 of the Weights and Measures Regulations (C.R.C.,
c.1605), [http://laws.justice.gc.ca/en/ShowDoc/cr/C.R.C.‐c.1605///en?page=1].
89 State of California, California Code of Regulations, Title 4 (Business Regulations), Division 9. Also
California Business and Professions Code, Chapter 14, Article 8, Sections 13470 through 13477. Extracts
for both codes can be found at: [http://www.cdfa.ca.gov/dms/publications.html].
90 Allied Electronics with headquarters in Chicago, Illinois, prices these types of decals at $1 each. Octane
decals are even less expensive [http://www.alliedelectronics.com/miscellaneous‐decals.html].
91
Figure 29: Example of Fuel Dispenser Label
Fuel dispenser in Waterton, Alberta (Canada) displays temperature correction labeling in French and English.
Photo Credit: Gordon Schremp, California Energy Commission.
Retail Station Display Signs
Another option involving labeling would be a requirement for the large display signs at the
service stations to contain an indication that ATC is present or in use at the site. Such a
requirement would be unnecessary if ATC is mandatory for all retail establishments. In a
mandatory setting, sufficient information could be conveyed to consumers using appropriate
fuel dispenser decals. If ATC at retail was voluntary, on the other hand, consumers would not
be able to determine which retail stations had ATC equipment until they pulled up to the fuel
dispenser and searched for the presence of an “ATC‐ready” decal.
Obviously, consumers would be better served in a permissive setting if retail stations that had
installed ATC equipment were to display that information as prominently as their posted fuel
prices. This type of approach would provide consumers with sufficient information allowing
92
them to make a more informed decision on where they should fuel their vehicle. A logical
location for indicating the presence of ATC at retail in a voluntary environment would be the
large display or street signs that are normally mounted on poles in an elevated position readily
visible and easily legible by consumers driving by a retail site.
DMS also has the regulatory authority regarding retail station street sign advertising (referred
to as price sign advertising).91 It is possible that this portion of the regulations could be
amended to include ATC street sign labeling requirements for retail establishments. It should be
noted that Measurement Canada has no such requirement in their voluntary retail application
of ATC.
If the message indicating ATC is limited to an acronym of two or three letters and a height no
greater than six inches (similar to the street sign price number requirement), expenses for the
retail station operator can be kept to a modest amount of approximately $50 to $100 per retail
establishment, assuming that there is spare space on the existing big display signs to place these
three letters.92 The message should be limited to a recognizable acronym such as “ATC” for
automatic temperature compensation or “TC” for temperature compensation. The size, limited
number of letters, and placement of the message should be such that existing signs would not
have to be modified or replaced to accommodate ATC labeling.
There may be some styles of retail street signage that have limited space available for the
placement of letters that are six inches in height. As an alternative, it may be possible to place an
ATC placard on top of the main display sign for a cost of $400 to $600 per retail establishment.
Any message, though, that is more extensive and larger in size could result in significantly
greater expenses being incurred by a retail establishment operator.
In those circumstances, a retail station operator may be required to retrofit an existing display
sign to allow an additional row that would be used to include the ATC message. If so, the
expense of this work could be considerably more than several letters placed on the street signs.
Staff estimates that costs for retrofitting existing retail street signs could amount to $1,600 to
$5,000 per retail station.93 Local planning ordinances may limit the ability of stations to extend
the size of the street sign resulting in a complete redesign of the signs, in which case the cost
could be even greater.
91 California Business and Professions Code, Division 5, Chapter 14, Article 12, Sections 13530 through
13536, [http://www.cdfa.ca.gov/dms/publications.html].
92 Staff estimated costs for gasoline sign lettering by viewing various signage options offered by Alphabet
Signs [http://www.alphabetsigns.com/c/CL25/?gclid=CPm4p76G‐pUCFQ0xawod9FWGFA]. Gas price
numbers that are six inches in height are priced in a package of 48 pieces at less than $3 each. Staff
assumed that letters of identical height would be priced at a slightly higher value for orders involving
smaller quantities. Retail station operators would be expected to purchase up to six letters per street sign
(up to three for each side) and have up to two street signs per retail establishment. For purposes of this
estimate, staff included an additional cost of $20 per street sign for shipping and handling.
93 Sign Resource of Maywood, California, and McCale Signs of Redding, California.
93
Printed Sales Receipts
A final ATC labeling option involves requiring some form of information to be included with
consumers’ printed receipts indicating that the retail transaction has included an adjustment
that compensates for variations in fuel temperature. One example of information that could be
included on the receipt is a simple message, such as “retail transaction has been compensated
for temperature.” Most retail establishments in California use electronic fuel dispensers that
distribute a printed receipt after each pump transaction. Station operators are able to program a
message to be included at the bottom of each receipt through the Point of Sale (POS) register
and associated software. A typical example would be a “Thank You” phrase. Including an
additional, brief message would require little effort and essentially no expense.
Any attempts to increase the level of information to include net and gross gallons would pose
some difficult and problematic issues. Although the ATC retrofit kits possess electronics and
software designed to monitor fuel temperature and adjust the volume dispensed to consumers,
there is no current capability for this system to convey the two different forms of measurement
to the cash register or POS equipment. It is possible that, over time, POS and ATC retrofit
manufacturers could collaborate to enable this exchange of data, but the initial expense of this
software and some electronic modifications is unknown.
Measurement Canada does not appear to require acknowledgment of ATC on the printed
consumer receipt, as long as the fuel dispenser is appropriately labeled.94
Timing of Requirement
Any requirement for ATC labeling would also involve the correct “timing” of the message. ATC
labeling regulations should stipulate when signage would be present at a retail site. One
example is to require that signage be present when the ATC equipment is activated. That step
could occur when installation of an ATC retrofit kit has been completed or at a later date when
the ATC equipment is activated by a certified installer/inspector.
Labeling Conclusions
If ATC is required at retail fuel stations, DMS should develop amended regulatory language for
labeling fuel dispensers that includes guidance for:
• Wording of the ATC message (such as “Corrected to 60°F”).
94 Measurement Canada, Printer Requirements for Volumetric Liquid Meters Equipped with Automatic
Temperature Compensation (ATC), Bulletin V‐20 (rev. 1), April 1, 2008, [http://www.ic.gc.ca/eic/site/mc‐
mc.nsf/eng /lm00116.html].
94
• Font size (similar to existing standards).
• Location of the decal.
• Timing of the requirement (when ATC equipment is activated).
• Authority to affix the decal (certified equipment installers and inspectors).
If voluntary use of ATC at the retail level is clarified by the State’s Legislature to be permissible,
DMS should develop amended regulatory language for the large price display signs that
includes guidance for:
• Wording of the ATC message (such as the notation of “ATC” or “TC”).
• Font size (similar to existing standards for the prices).
• Location of the message.
• Timing of the requirement (when ATC equipment is activated).
• Authority to affix the message (retail station operators).
Retail station operators should be required to include a message on the printed consumer
receipt that fuel is corrected to 60 degrees Fahrenheit, but not be required to include any
additional information such as fuel temperature or net and gross gallons. Over time, it should
be possible for ATC equipment and point‐of‐sale manufacturers to design the software to
communicate between measurement software and printer software to enable the registration of
both net and gross gallons. Such a program could be phased in over time, but should not be
permanently ruled out if ATC were to be mandated at retail in California.
Authority to Activate Retail ATC
Access to retail ATC devices in fuel dispensers is usually limited to only those entities that have
a need to make repairs or modifications to the devices in the field. To reduce the possibility of
illegal manipulation of software settings or operation, ATC devices in Canada are required to
have tamper‐proof seals in place that must be removed or damaged if someone were to attempt
unauthorized access.95 There can also be audit software programs that track access to the
devices or alterations to any of the settings. This type of software can be employed to determine
how long a device has been out of calibration.
In Canada, access to retail ATC devices is limited to authorized technicians or inspectors. If
retail ATC was mandated in California, it would be appropriate for a similar class of authorized
individuals to have sole access to the devices. In a scenario in which retail ATC has been
mandated, these technicians or certified inspectors would need to make an additional visit to a
retail establishment whenever an idle ATC device needed to be activated. This assumes that
existing retail fuel dispensers have been retrofitted with ATC devices before some compliance
deadline period. A permissive retail ATC market, such as Canada, does not require a return
Measurement Canada, Metering Assemblies Incorporating Electronic ATCs Specifications (SI/90‐155),
95
[http://laws.justice.gc.ca/en/Showdoc/cr/SI‐90‐155///en?page=1].
95
visit by a technician because the devices are activated at the time of installation. No waiting
period exists in Canada. However, in a mandatory setting, activation of retail ATC devices
would have to be delayed until all of the existing stations had time to modify their dispensers
(refer to Timeline section of this chapter), necessitating an additional technician visit. In
California, DMS already has regulations and other provisions in place to handle this aspect of
ATC if temperature compensation was mandated for use throughout the state.
Implementation Timeline Options for Retail ATC
If ATC was mandated for use in California at retail stations, how much time would be required
to develop regulations, what would be an optimal sequence of steps, and how should
compliance deadline be structured?
Questions like those listed above have been grappled with during the national debate of ATC at
retail stations for several years. Most recently, though, the National Conference on Weights and
Measures (NCWM) Steering Committee on ATC has devoted a great deal of thought to the
various elements associated with timing of ATC regulations and a number of options that could
be pursued on a national level. A schematic of these potential implementation timelines is
illustrated in Figure 30. 96
Development of Regulations and Standards
To ensure adequate guidance for businesses, consumers, and enforcement officials, regulations
should be developed before ATC is adopted for widespread use at retail stations in California.
The minimum steps associated with regulatory development include:
• Legislation granting authority for oversight and regulation development for appropriate
agency or agencies.
• Development and adoption of regulations through rule‐making procedures.
• Revision of guidance documents and handbooks.
Before mandatory retail ATC could happen in California, the Legislature would have to
approve and the Governor sign a new bill requiring ATC at retail stations. DMS would then
initiate a rule‐making process that includes the development of draft standards, public
consultations and comment periods, and ultimately adoption of new regulations. A final set of
steps would involve the updating of various guidance documents that are used by enforcement
officials as an inspection procedure reference as well as by business owners to better
Automatic Temperature Compensation Steering Committee, “Progress Report,” presentation at
96
National Conference of Weights and Measures, Albuquerque, New Mexico, January 28, 2008,
[http://www.ncwm.net/ppt/steering_committee_interim_report_2008.ppt].
96
Figure 30: Potential ATC Implementation Options – NCWM
Source: Automatic Temperature Compensation Steering Committee presentation, January 28, 2008, slide 33.
understand compliance rules and timelines. A primary example of such a reference document is
the DMS Field Reference Manual.97 Examples of informational resources that could be revised
would be the Petroleum Products Program Information Guides for both businesses and
consumers.98
Staff estimates that the time required to complete all of these discrete regulatory steps could
take between 18 and 24 months from the date an approved piece of legislation is signed into
law.
97 California Department of Food and Agriculture, Division of Measurement Standards, Field Reference
Manual – Division 9, 2008, [http://www.cdfa.ca.gov/dms/programs/general/CCR2007.pdf].
98 California Department of Food and Agriculture, Division of Measurement Standards, Petroleum
Products Program Information Guide (Businesses), 2008, [http://www.cdfa.ca.gov/dms/programs/petroleum
/petInfoGuideBusiness.pdf]. A link to the consumer guide is at: [http://www.cdfa.ca.gov/dms/programs
/petroleum/petInfoGuideConsumer.pdf].
97
Certification of ATC Equipment
If ATC was mandated for use at retail stations in California, retail station operators would need
to have available to them a sufficient selection of ATC retrofit kits certified for use in California
that would encompass the majority of fuel dispensers in use at retail stations throughout the
state. The process for receiving approval for ATC‐related equipment has two pathways, the
California Type Evaluation Program (CTEP) and the National Type Evaluation Program
(NTEP).
The CTEP certification process involves an application process that takes between three and six
months, followed by a testing and evaluation step of between two and three months. Any
deficiencies identified during the evaluation step would require corrective measures by the
applicant and could extend this step by several months.99
The NTEP certification process is a national program administered by the NCWM. California
has the authority to “approve” devices separately from NTEP for in‐state use.100 An ATC device
from one manufacturer has been evaluated and approved for use in California. All devices
submitted under this program must meet all applicable regulations outlined in the National
Institute of Standards and Technology (NIST) Handbook 44 (Specifications, Tolerances, and Other
Technical Requirements for Weighing and Measuring Devices). California has the authority to adopt
exceptions to Handbook 44 and would need to do so if ATC was to be used in the state.
Applicants are required to submit a completed application and associated fees to NTEP. Their
application will then be assigned to a certified testing laboratory where the actual certification
testing will occur. Actual testing of the equipment could take between 40 and 200 hours, the
lengthier time period if field testing is deemed necessary. The total time to receive an NTEP
certification will range from two to seven months and cost upwards of $20,000.101 Any
manufacturer of ATC‐related equipment or fuel dispensers who obtains an NTEP certificate
may use the approved device in California, unless expressly denied by DMS.
Staff estimates that a minimum period of 11 to 15 months would be required for manufacturers
of ATC retrofit kits and ATC‐ready dispensers to obtain certification from DMS from the date
ATC regulations are adopted and published by DMS. This time frame assumes that ATC
manufacturers would initially submit for certification retrofit kits and some ATC‐ready
dispensers already in use in other countries (such as Canada and Belgium). It is likely that some
additional time would be necessary for equipment manufacturers to develop additional kits
and modified ATC‐ready dispensers, on the order of six months.
99 California Department of Food and Agriculture, Division of Measurement Standards, California Type
Evaluation Program, 2008, [http://www.cdfa.ca.gov/dms/programs/ctep/CTEPInfoGuide.pdf].
100 A list of newer California certificates of approval going back to 2000 appears on the DMS website at
[http://www.cdfa.ca.gov/dms/programs/ctep/ctep.html].
101 Additional details associated with the NTEP certification process may be viewed at the following link:
[http://www.ncwm.net/ntep/index.cfm?fuseaction=faq].
98
Existing Retail Stations and ATC Compliance
If ATC was mandated at retail stations in California, compliance could either exclude or include
existing retail establishments. Exclusion of existing retail stations from compliance would create
a pseudo‐permissive market. Such a development would be undesirable for reasons described
in the “permissive” section of this chapter. Therefore, staff concludes that it would be optimal
that all retail stations should comply under any mandated ATC regulation scenario. However,
the timing for installing the ATC retrofit kits would be somewhat discretionary for the retail
station operator, as long as the modifications were completed before the full compliance
deadline. The risk of waiting too long to schedule the work could result in some retail stations
not fully complying by the deadline. To avoid stations being out of compliance and unable to
legally dispense fuel, staff concludes that it would be optimal that there be a process to enable
some retail station operators additional time to comply conditioned on a “showing” that the
ATC retrofit work or installation of ATC‐ready dispensers was already under contract for that
retail location, but the work was not yet completed.
Activation of ATC Devices
Activation of ATC devices can occur in either of two scenarios: at the time of installation or by
some prescribed deadline for full compliance. If ATC devices were allowed to be activated at
the time a retrofit kit or ATC‐ready dispenser was installed, inspection costs for the retail
station operator could be decreased by avoiding one additional inspection visit. The assumption
is that a licensed service agent would have the capability to approve operation of the fuel
dispenser after modification or installation under authority of law.
Optimal Compliance Schedule Conclusion
After reviewing the various steps necessary for converting California’s retail stations to ATC
capability, staff is proposing three compliance schedules if ATC was to be mandated for use at
retail stations in the state. The shorter compliance timeline is five years and three months in
duration, while the lengthier schedule requires six years and three months to complete. The
main difference in schedule length is due to varying estimates of time required to complete the
regulatory and certification steps. The final phase of each respective compliance schedule occurs
during an identical time of the year designed to coincide with fuel temperatures that are closer
to the 60 degree Fahrenheit reference standard (October through March). Staff believes that the
longer compliance schedule would be more reasonable and have a higher likelihood of success.
99
Table 10: Mandatory ATC Compliance Schedule Options
Phase Description Option 1 Option 2 Option 3
1 Legislation Signed Into Law January 1, 2010 January 1, 2010 January 1, 2010
2 DMS Regulations Adopted and July 11, 2011 January 1, 2012 July 11, 2011
Guidance Documents Revised (18 months) (24 months) (18 months)
3 CTEP/NTEP Certification Completed by June 1, 2012 April 1, 2013 June 1, 2012
Majority of Equipment Manufacturers (11 months) (15 months) (11 months)
4 ATC Compliance ‐ Initial Installation November 1, 2012 November 1, 2013 November 1, 2012
5 ATC Compliance ‐ Final Installation October 1, 2014 October 1, 2015 October 1, 2017
6 ATC Compliance ‐ Activation April 1, 2015 April 1, 2016 April 1, 2018
Phases 1 through 3 consist of the time needed to develop regulations, guidance documents, and
certifications. At Phase 4, initial ATC compliance would begin:
• New retail stations required to install ATC‐ready fuel dispensers.
• All existing retail station operators may begin to install ATC retrofit kits or ATC‐ready
fuel dispensers.
• ATC set to “inactive” mode.
At Phase 5 compliance continues:
• All existing retail station operators required to have completed installation of ATC
retrofit kits or ATC‐ready fuel dispensers
• ATC set to “inactive” mode.
• Limited number of existing stations with temporary exemptions allowed additional six
months to comply.
• Temporary exemption granted with “proof of work contract.”
At Phase 6, activation would commence:
• ATC set to “active” mode at all existing stations.
• All new ATC‐ready dispensers installed activated at time of installation.
• All existing retail stations that received temporary exemptions required to complete
installation of ATC retrofit kits or ATC‐ready fuel dispensers and set to “active” mode
upon completion of the work.
• All retail stations that have not fully complied by the final deadline will be prohibited
from dispensing transportation fuels until full ATC compliance is achieved.
The optimal compliance schedule from the perspective of most consumers would likely be as
quickly as feasible. Consumer advocacy groups, such as the Foundation for Taxpayer and
Consumer Rights, believe that mandatory ATC at retail is long overdue. However, an
unreasonably short compliance deadline could create problems for regulators, retail station
operators, equipment manufacturers, and inspectors. Staff believes that the three schedules
100
would be best characterized as optimistic, especially when contrasted with the recommended
timeline of 10 years suggested by the NCWM ATC Steering Committee.102
ATC and Other Liquid Transportation Fuels
Temperature compensation (TC) application at retail for transportation fuels other than gasoline
and diesel fuel is also addressed in this report for aviation fuels. For purposes of this report, it is
assumed that bunker fuels used in marine vessels would not be subject to any retail ATC
program since these fuels are primarily sold through wholesale, rather than retail transactions.
Energy Commission staff conclude that other traditional petroleum‐based aviation
transportation fuels are not initially considered for inclusion in any ATC program due to the
limited use of these fuel types and the greater expense that would be incurred by airport‐based
retail fuel operators. The rationale is that these fuels, such as aviation gasoline and jet fuel for
private airplanes are significantly smaller in total sales compared to gasoline.103 Jet fuel sold for
use in private planes is normally a retail transaction at a private or public airport. The vast
majority of jet fuel used in California is done so in conjunction with the operation of commercial
aircraft. These sales transactions are not considered a retail taxation event and would, therefore,
not be subject to any retail ATC regulation.
Further, it is believed that the retail fuel dispensers used at the majority of California’s private
airports are usually mechanical, rather than electronic. Consequently, the expense for
retrofitting these devices would be more than double compared to typical retail gasoline station
fuel dispensers. Finally, the average annual sales volume for retail aviation fuel providers is
significantly lower compared to their counterparts at a typical service station, roughly 90
percent less per fueling establishment.104 Higher retrofit costs in conjunction with lower average
sales volumes could result in significantly greater per‐gallon recovery cost increases if the
102 Automatic Temperature Compensation Steering Committee, “Progress Report,” slide 35, presentation
at National Conference of Weights and Measures, Albuquerque, New Mexico, January 28, 2008,
[http://www.ncwm.net/ppt/steering_committee_interim_report_2008.ppt].
103 Total aviation gasoline sales amounted to 27.8 million gallons in 2007, approximately 0.2 percent of
total gasoline sales. California State Board of Equalization, Taxable Aviation Gasoline Gallons 10 Year Report,
November 21, 2008, [http://www.boe.ca.gov/sptaxprog/reports/AVGAS_10_Year_Report.pdf]. Jet fuel
sales for private planes amounted to 155.4 million gallons in 2007, approximately 4 percent of total jet fuel
sales in California. Military jet fuel is excluded from these totals. California State Board of Equalization,
Taxable Jet Fuel Gallons 10 Year Report, November 21, 2008, [http://www.boe.ca.gov/sptaxprog/reports
/Jet_Fuel_10_Year_Report.pdf].
104 Staff estimates that there are about 185 locations throughout the state that offer aviation gasoline (100
LL) or jet fuel (Jet A) for retail sales. Based on 2007 retail aviation gasoline sales, the average annual
throughput per airport amounted to roughly 92,000 gallons. By comparison, there are nearly 10,000 retail
stations in California that sell retail gasoline and diesel fuel, averaging more than 1.5 million gallons of
gasoline per location in 2007.
101
aviation fuel provider elected to pass along all of the additional costs solely by raising their fuel
prices.
Other Liquid Transportation Fuels Conclusions
The following aviation transportation fuels should be initially excluded from any retail ATC
standards:
• Aviation gasoline (100 LL)
• Commercial jet fuel (Jet A)
• Military grade jet fuel (JP‐5 and JP‐8)
If ATC was mandated at retail in California, application at airports for private aircraft could still
be reconsidered in some delayed form, such as a phase‐in as aviation fuel dispensers are
replaced.
Leak Detection – Potential Benefit
One reported potential benefit of automatic temperature compensation is enhanced inventory
tracking and leak detection. If inventory tracking is used to detect leaks in storage tanks (loss of
fuel into surrounding soil or into the space between inner and outer walls of double‐walled
tanks), automatic temperature compensation improves this process because the expansion or
contraction of temperature compensated gallons is known with inventory tracking systems and
only estimated when gross gallons are measured. If more precise measurement methods are
already in place, automatic temperature compensation will not confer any additional leakage
detection benefit.
Energy Commission staff investigated current leak detection standards. Staff contacted the
state Water Resources Control Board and obtained the following information:105
• Current underground storage tank leak detection sensitivity requirements depend upon the
time when the tank was installed and upon whether the tanks are single‐walled or double‐
walled.
• Approximately 88 percent of California underground storage tanks are double walled.
These tanks are required to have leak detection sensors within the retaining area between
the two tanks. Those tanks built since 2003 must be initially certified to leak no more than
.005 gallons per hour (gph) gasoline liquid and vapor combined. Tanks built earlier, and
those built recently that are renewing their certification, must use third‐party certified leak
detection sensors.
105 Per email from John Elkins, UST Leak Prevention Unit, State Water Resources Control Board.
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• Approximately 4 to 5 percent of California underground storage tanks are single walled,
built before 1984, and within 1000 feet of a water source. These tanks are required to detect
leaks (via vacuum pressure) of .005 gph via an enhanced leak detection test every 36
months. The rest of the time, the system is required to be tested to detect 0.1 or 0.2 gph
leaks.
• The remaining 6 to 7 percent of California underground storage tanks are single walled
storage tanks built before 1984 and not within 1000 feet of a water source. These tanks are
required to detect 0.1 or 0.2 gph leaks. Their piping systems are required to detect 0.1, 0.2, or
3.0 gph of leaks.106
The above information indicates that inventory tracking is not currently being used as a
primary method of leak detection, and most California underground storage tanks are either
double walled or subject to a .005 gph vacuum pressure test. Inventory tracking alone does not
detect leaks to the standard that most stations are presently required to meet. Energy
Commission staff concluded, therefore, that ATC implementation would not significantly affect
underground storage tank leak detection in California because stronger leak detection
requirements are already in place.
Applicability of Findings to Other Regions of the United
States
A great deal of debate has occurred over the last couple of years as various stakeholders and
governmental organizations strive to objectively address the primary question: Should
temperature compensation be used for retail transportation fuel transactions throughout the
United States? If so, should ATC be mandatory or permissive?
The Energy Commission staff work embodied in this report was directed at addressing ATC for
California. Some portions of the methodology, assumptions, findings, and conclusions
contained in this report may be directly transferrable to other states or regions of the
United States. It is likely that the analysis of the costs, potential agency impacts, labeling, and
timing issues could be germane to the discussion of ATC in other areas outside of California.
However, issues of quantifying potential net benefits and value of increased accuracy for retail
transactions (fairness) are possibly less useful when applied to ATC in the United States as a
whole.
Although there are a number of other states that have annual fuel temperature profiles that are
similar to those in California (such as Texas, Arizona, and Florida), there are also some states in
the Union that have temperature profiles considerably cooler than this state and below the 60
Statutes of Chapter 6.7, Health and Safety Code, Underground Storage of Hazardous Substances,
106
Sections 25281 and 25292, January 1, 2006, [http://www.waterboards.ca.gov/ust/regulatory/docs
/hs_chp7_w_additions.pdf].
103
degree Fahrenheit reference standard (such as Alaska, Minnesota, and Wyoming).107 In
addition, there likely exist examples of states that normally have wholesale transactions on a
gross, rather than net, basis (such as New York). These types of differences between individual
states or regions of the United States could render comparisons to all of the findings and
conclusions in this report less meaningful to areas outside of California, especially with regard
to the net benefit assessment portion of the analysis.
The state and regional differences may be of such significance that a national consensus is
neither achievable nor prudent. A more sensible approach would be for national standards and
guidelines to be adopted through the NCWM ATC steering committee structure that could be
referenced and adhered to by individual states that elected to promulgate retail ATC
regulations. Such standards could include field test procedures and equipment used for
certification of ATC fuel dispensers, minimum labeling recommendations, and possibly
standardized densities for various types of transportation fuel.108 It may be preferable that
individual states retain the flexibility and autonomy regarding any decision to adopt ATC at
retail stations within their own state boundaries.
National Conference of Weights and Measures, “State Charts for Temperature of Gasoline in Filling
107
Station Holding Tanks,” presentation at ATC Meeting, Chicago, Illinois, August 2007,
[http://www.ncwm.net/events/atc2007/item9_avg_temp_states.pdf].
An expanded discussion on these other standards can be found in “Report of ATC Steering Committee
108
Meeting,” presented at the NCWM ATC meeting, Chicago, Illinois, August 2007,
[http://www.ncwm.net/events/atc2007/ATC_Meeting_Report_8_07.doc].
104
CHAPTER 7:
Findings and Recommendations
This chapter highlights the main findings and recommendations concerning the implementation
of automatic temperature compensation (ATC) at retail stations in California.
Findings (Sequential Order)
Chapter 1 Findings
Background
• Liquids expand and contract in volume due to changing temperatures. Gasoline and diesel
fuel are no exception.
• Gasoline warmed from 60 degrees Fahrenheit to 75 degrees Fahrenheit will expand by
approximately 1 percent. The volume of gasoline will expand from 231.0 cubic inches to
233.3 cubic inches.
• If the 233.3 cubic inches of gasoline is cooled back down to 60 degrees Fahrenheit, the liquid
will occupy a space of 231.0 cubic inches (assuming no losses from evaporation).
• The majority of wholesale transactions of gasoline and diesel fuel at California’s 53
distribution terminals are normally consummated using a volumetric measurement referred
to as a standard or net gallon that can be expressed as 231 cubic inches at 60 degrees
Fahrenheit.
• The final temperature compensated price paid by wholesale fuel customers is the calculated
standard or net gallon quantity multiplied by the posted wholesale price in net gallon.
• Retail fuel sale transactions are conducted in non‐standard or gross gallons, represented by
231.0 cubic inches, regardless of fuel temperature.
• Currently, there are no retail ATC devices installed and operating in California. It is unclear
whether the voluntary use of ATC devices for retail sales transactions of gasoline and diesel
fuel is permitted under California law.
105
Chapter 2 Findings
Hawaii
• Fuel temperatures in Hawaii have minor seasonal fluctuations and can average near 80
degrees Fahrenheit on an annual basis.
• In the early 1970s the majority of Hawaii’s retail fuel dispensers were modified to distribute
an additional quantity of fuel (as measured in cubic inches) to compensate for the fact that
the fuel sold is warmer.
• Hawaii’s retail sales unit of gasoline is now 233.8 cubic inches, roughly equivalent to how
much a standard gallon of gasoline would expand when warmed from 60 to 80 degrees
Fahrenheit.
• Retail diesel fuel dispensed in Hawaii now contains 233.3 cubic inches for each unit of sale.
• Energy Commission staff believes that a reference temperature is a more viable option in
Hawaii because there is very little seasonal volatility in climate temperatures throughout the
year, as well as very small geographic differences in temperature in areas dispensing
gasoline on any given day. California, on the other hand, has many climate zones that have
large variations in seasonal temperatures throughout the year. The existence of the diversity
and range of temperatures at any given time in California would also make the reference
temperature option not as preferable as it is in Hawaii.
Canada
• Canada has adopted ATC at retail on a voluntary basis, beginning back in the early 1990s.
• Today, more than 90 percent of Canadian fuel retailers sell temperature‐compensated fuel.
• Fuel temperatures in Canada are cooler than the reference standard of 15 degrees Celsius,
resulting in the distribution of liters that are slightly smaller in size (in cubic centimeters).
• The fuel temperature circumstances in Canada (cooler fuel) are opposite of those in
California (warmer fuel).
Chapter 3 Findings
Fuel Demand
• Approximately 23 billion gallons of gasoline, diesel and jet fuel were consumed by
California motorists and businesses during 2007.
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• For the study period (April 2007 through March 2008), taxable gasoline sales in California
were 15.62 billion gallons, reflecting a slightly lower demand due to historically high retail
prices. Taxable diesel fuel sales amounted to 3.06 billion gallons over the same period.
• Demand for gasoline is greatest in Los Angeles County, accounting for 24.1 percent of
statewide consumption.
Retail Fuel Prices
• During the study period, the statewide average retail price for regular grade gasoline in
California was $3.29 per gallon, while diesel fuel averaged $3.41 per gallon.
• The Oil Price Information Service (OPIS) was used as the source of retail fuel prices that
were available for all 58 California counties.
• County‐specific retail fuel prices were obtained from OPIS and California American
Automobile Association (AAA) sources for 34 of California’s 58 counties. These counties
collectively represented a total of 93 percent of California’s diesel consumption. The
remaining counties were estimated by staff using gasoline price differentials calculated from
the OPIS data.
Fuel Temperatures
• County sealers collected temperature data for retail gasoline and diesel fuel from some but
not all months of the study period. While those counties account for a minority of counties,
they account for approximately 85 percent of California gasoline sales and 78 percent of
total statewide diesel fuel sales.
• Energy Commission staff determined that there is a statistically significant correlation
between ambient average temperatures and the temperature of fuel dispensed from retail
stations. These ambient temperatures can explain between 76 and 87 percent of the fuel
prover temperature throughout the year. This statistical relationship was used to estimate
fuel temperatures in the remaining counties.
• Fuel temperatures can fluctuate between the underground storage tanks (UST) and the
dispenser on any given day by as much as 15 to 20 degrees Fahrenheit. Large differentials
are unusual since more than 70 percent of these temperature differences are within plus or
minus 3 degrees Fahrenheit and 94.7 percent of the temperatures are within plus or minus
7 degrees Fahrenheit.
• Gasoline and diesel fuel temperatures dispensed at California’s retail stations during the
study period were warmer than the reference standard of 60 degrees Fahrenheit.
107
• Regular grade gasoline averaged 71.1 degrees Fahrenheit, premium grade gasoline
averaged 71.5 degrees Fahrenheit, and diesel fuel averaged 72.9 degrees Fahrenheit.
• Fuel temperatures fluctuate on a seasonal basis with the highest monthly averages recorded
in August and coldest monthly averages occurring during January.
• Highest statewide fuel temperature (in August) for regular grade gasoline averaged 82.0
degrees Fahrenheit, premium grade gasoline averaged 82.9 degrees Fahrenheit, and diesel
fuel averaged 84.6 degrees Fahrenheit.
• Lowest statewide fuel temperature (in January) for regular grade gasoline averaged 59.7
degrees Fahrenheit, premium grade gasoline averaged 59.8 degrees Fahrenheit, and diesel
fuel averaged 60.4 degrees Fahrenheit.
• Individual county extremes during the study period were as follows:
o 89.6 degrees Fahrenheit – regular grade gasoline ‐ Riverside County in July 2007
o 90.7 degrees Fahrenheit – premium grade gasoline ‐ Tulare County in September 2007
o 92.0 degrees Fahrenheit – diesel fuel ‐ Fresno County in August 2007
o 49.4 degrees Fahrenheit – premium grade gasoline ‐ Lake County in January 2008
o 50.5 degrees Fahrenheit – regular grade gasoline ‐ Butte County in January 2008
o 51.8 degrees Fahrenheit – diesel fuel ‐ Butte County in January 2008
• Fuel temperature survey results were similar to the earlier NIST work from April 2002
through February 2004 that determined regular grade retail gasoline averaged 74.7 degrees
Fahrenheit.
Fuel Density - General
• Transportation fuel densities are a potentially important property relative to retail ATC due
to differences in their thermal expansion and contraction properties, known as coefficient of
expansion.
Gasoline Density
• The assumed density of finished gasoline in Canada that is used for retail ATC calculations
is 0.7302 grams per milliliter (g/ml).
• Density of gasoline and diesel fuel varies due to differences in crude oil, refining processing,
and seasonal specifications (for gasoline).
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• The Canadian standard density value for gasoline is at the lower range of both the
California and United States density values for the summer period of 2006.
• The use of a single gasoline density value in California that is close to the annual average
will yield a volume correction factor (VCF) at 75 degrees Fahrenheit that is within plus or
minus 0.04 percent of the actual, true value 96 percent of the time.
• Improving upon this level of precision by altering the accepted density value on a seasonal
or per‐delivery basis would be costly, problematic, and only decrease the potential error by
an almost imperceptible measure.
Diesel Fuel Density
• Diesel fuel density does not vary on a seasonal basis in California or the United States.
• The Canadian standard density value for diesel fuel of 0.840 g/ml is nearly midway between
the average California and AAM survey results for the summer of 2006, rather than on the
lower end of the distribution range as was the case with gasoline density values.
• If ATC was mandated in California for use at retail stations, the overwhelming majority of
diesel fuel transactions would likely be within plus or minus 0.02 percent of the true volume
correction factor (VCF) for diesel fuel at 75 degrees Fahrenheit.
• The Canadian reference density value of 0.840 g/ml for diesel fuel is probably acceptable for
use in California, if ATC was mandated at retail stations.
Renewable Fuels
• Due to development of the state’s Low Carbon Fuel Standard and federal requirements of
the Renewable Fuel Standard, staff assumed that California’s gasoline will contain an
average of 10 percent ethanol by volume as early as 2009, but no later than 2010.
• If retail ATC was mandated in California, stations with E85 (a mixture of 85 percent ethanol
and 15 percent gasoline) dispensers would require software that was programmed with a
density and VCF equation specific to E85.
• The varying nature of low‐level biodiesel blends should not pose an accuracy problem if
retail ATC was mandated in California, since the variation of density appears to be within
the normal distribution for regular diesel fuel.
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Chapter 4 Findings
Initial ATC Retrofit Costs
• Statewide costs for ATC retrofit kits are estimated by staff to amount to approximately $85
million or $8,763 per retail station. The highest per‐station county average was $10,474 in
Orange County, while the lowest per‐station cost average was estimated at $2,212 for Alpine
County.
• Statewide costs for ATC retrofit kit installation labor are estimated by staff to amount to
between $9.0 million and $27.9 million or from $925 to $2,879 per retail station. The highest
per‐station labor cost average was $3,647 in Riverside County, while the lowest per‐station
labor cost average was estimated at $1,312 for Alpine County
• Energy Commission staff estimated that the time required to inspect and certify retail fuel
dispensers will increase between 10 and 20 percent if ATC is mandated for use at retail
stations in California.
• The number of county inspectors involved with testing and certifying retail motor fuel
meters are estimated by staff to be between 129 and 156 statewide. Total statewide costs for
the new equipment (specialized thermometers) they will need to verify the accuracy of ATC
dispensers is estimated to range between $77,000 and $140,000.
• Staff assumed that the cost to pay for the ATC retrofit equipment (including installation)
would be accomplished through the use of business loans that were either secured (by real
estate property and other assets) or unsecured. Total financing costs of these loans is
estimated to be between $9.7 million and $13.3 million.
• If one assumes that the total initial costs of retrofitting all of California’s retail stations will
only be passed through to consumers by raising the price of gasoline and diesel fuel, then
the incremental retail price would increase by four hundredths (4/100) to seven hundredths
(7/100) of a cent per gallon.
• These estimates assume that the lower cost is recovered over 15 years, while the higher
estimate assumes retrofit costs are recovered over 10 years.
Recurring ATC-Related Costs
• The estimated inspection cost increase of $100 to $200 per station would be an incremental
cost for retail station owners that would continue indefinitely. On a statewide basis, that fee
increase would amount to between $970,000 and $1.94 million per year. That increased
expense would equate to between five thousandths (5/1000) and one hundredth (1/100) of a
cent per gallon.
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• After ATC retrofit was completed, all new dispensers installed in the state after that time
would be required to have ATC capability. The statewide incremental costs for these more
expensive fuel dispensers would amount to between $3.8 million and $7.6 million per year
or between two hundredths (2/100) and four hundredths (4/100) of a cent per gallon.
• Staff estimated that between 10 and 20 percent of existing retail stations will require some
degree of ATC‐related maintenance before the normal replacement cycle of the fuel
dispensers. Maintenance could add between $2.7 million and $11.0 million per year to
ongoing expenses. This cost is equivalent to between 14 thousandths (14/1,000) and 59
thousandths (59/1000) of a cent per gallon.
• Total recurring ATC‐related costs are estimated to amount to between four hundredths
(4/100) and 11 hundredths (11/100) of a cent per gallon.
Potential Impacts on Fuel Availability for Isolated Locations
• If ATC was to be mandated at retail stations in California, it is possible that the expense to
comply with the regulation could be onerous for some station owners. Some of these station
owners may be unable to obtain adequate financing and could possibly close their business.
• The closure of a retail station that was either the sole or one of only two sources of retail fuel
for a community could create a local fuel supply availability problem.
Quantification of Potential Consumer Benefits
• If ATC had been in effect at retail during the study period, the quantity of net gallons of
gasoline sold would have been approximately 15.508 billion gallons. This is about 117
million gallons less compared to status quo (no ATC at retail) because the fuel was warmer
(71.1 degrees Fahrenheit) than the 60 degree Fahrenheit reference standard.
• Under the ATC scenario, the quantity of net or petroleum gallons of diesel fuel sold would
have been approximately 3.037 billion gallons. This is about 19 million gallons less
compared to status quo (no ATC at retail) of 3.056 billion gallons because the fuel was also
warmer (72.9 degrees Fahrenheit) than the 60 degree Fahrenheit reference standard.
• The representative value of the reduced quantity of “gallons” that consumers would not
have purchased if ATC had been in place at retail stations in California during the study
period was calculated at about $376.4 million for gasoline and about $61.1 million for diesel
fuel.
• But the perception by various stakeholders that the price of the retail fuel would not be
raised to compensate for the selling of slightly larger‐sized “gallons” is unrealistic if retail
111
station owners are expected to maintain a similar level of profitability before and after a
conversion to mandated ATC. Staff assumes that since the industry of retail station owners
and operators will continue to grow and remain profitable. The conclusion is that retail
station owners will in fact raise their fuel prices to compensate for selling fewer units, all
other things being equal
Quantification of Increased Price Transparency Benefits for Society
• A mandated implementation of ATC will remove the effects of temperature variance and
would remove information asymmetry as it involves the temperature of the fuel. This
would force retailers to price gasoline and diesel products in net gallons, which would
allow consumers to more accurately compare the prices among retail stations and retail
station owners to more competitively price their fuel.
• The revised societal benefit of increased price transparency or removal of deadweight loss is
now estimated at a little more than $250,000 per year.
Quantification of Fairness
• The concept of increased fairness for motorists has been raised by some stakeholders as a
type of benefit that has not been accounted for in the cost‐benefit‐analysis.
• Some stakeholders believe that the collective benefits for motorists that would result from a
conversion to ATC at retail station could amount to hundreds of millions of dollars per year
in California.
• Although no quantification of “fairness” has been attempted as part of these proceedings
due to the subjective nature of this perceived consumer benefit, there are some research
survey techniques and methodologies that could be used to provide some valuable insight
into this variable and subjective consumer belief.
ATC Retrofit Cost-Benefit Analysis Results for Society
• The cost‐benefit analysis results for the lower estimate of ATC retrofit for all retail stations
are presented in Table 7. Net costs to society amount to approximately $245 million and
range between four hundredths (4/100) and seven hundredths (7/100) of a cent per gallon
over a 20‐year period. The net present value of costs amounts to about $165 million.
• The higher estimate scenario amounts to approximately $530 million and range between 11
hundredths (11/100) and 18 hundredths (18/100) of a cent per gallon over a 20‐year period.
The net present value of costs amounts to about $417 million.
112
• Gradually phasing in ATC equipment at retail stations minimizes the expense for retail
station owners because most of the expenses associated with installation labor can be
avoided. Net costs to society of this scenario amount to approximately $205 million and
range between one hundredth (1/100) and nine hundredths (9/100) of a cent per gallon over
a 20‐year period. The net present value of costs amounts to about $127 million.
ATC Retrofit – Potential Net Benefit to Consumers under Certain Circumstances
• Although likely that a portion of the capital costs will be recovered by retail station owners
raising non‐fuel commodity prices, it is improbable that the apportionment will be
significantly skewed to non‐fuel items. As such, it is unlikely that there are any plausible
circumstances whereby some consumers could realize a small net benefit of ATC at retail in
California.
Retail Station Characteristics and Trends
• Today, more than 80 percent of the gasoline sold to the public nationwide is through
convenience stores.
• These places of business have continued to be profitable over the last decade, averaging
nearly $34,000 per store pre‐tax profits between 1998 and 2006.
• Profit margins for convenience stores across the United States show that in‐store sales (non‐
fuel) have a consistently higher and steadier profit margin, relative to that of the steadily
declining profit margins for fuel sales.
• On a per‐gallon basis, the average margin of motor fuel sales at a typical convenience store
has remained fairly steady between 2000 and 2006, averaging 10.5 cents per gallon.
• Staff interprets these stable per‐gallon margins as an indication that the ability of
convenience store owners to pass through increased expenses by increasing the price of
their gasoline and diesel fuel only is not reflected in the overall trend.
• As such, retail station owners will likely have to recapture a portion of the revenue shift by
raising prices of non‐fuel commodities.
Chapter 5 Findings
Initial Reference Temperature Costs
• The estimated costs of a new reference temperature and associated larger gallon size (in
cubic inches) could amount to between $9.0 million and $27.9 million or from $925 to $2,879
per retail station. On a per‐gallon basis these additional expenses incurred by retail station
113
owners would equate to between five hundredths (5/100) and 15 hundredths (15/100) of a
cent per gallon for only one year. After the modifications were completed, there would be
no additional recurring costs for businesses or consumers.
Regional Reference Temperature
• Development of such variable inspection and certification procedures in conjunction with
the creation of multiple new jurisdictions that cross county boundaries could create
difficulties for enforcement officials. Staff believes, therefore, that a regional reference
temperature approach may create too many difficulties and should not be considered as an
option to pursue in California.
Chapter 6 Findings
Permissive vs. Mandatory ATC at Retail Stations
• The status of permissive (voluntary) use of ATC devices at California retail stations is
currently in dispute by various stakeholders.
Labeling
• Canada requires all fuel dispensers equipped with ATC to be labeled with the message:
“Volume corrected to 15°C”.
• If ATC was mandated for use at California retail stations, the cost of fuel dispenser labels is
estimated to be modest, amounting to no more than $20 per dispenser.
• Canada does not require the large price signs to contain any message that the station has
ATC capability.
• If ATC was mandated for use at California retail stations, the cost of displaying an ATC
message on the large price sign could range from as little as $50 to nearly $5,000 if a
complete large sign replacement was necessary.
• Canada does not require that printed receipts for retail customers have any ATC‐related
message or notation of net and gross quantities.
• Any attempts to increase the level of information on printed receipts at retail stations to
include net and gross gallons would pose some difficult and problematic issues due to
software limitations between the dispenser ATC equipment and the electronic cash register
or Point of Sale (POS).
114
• It is possible that, over time, POS and ATC retrofit manufacturers could collaborate to
enable this exchange of data, but the initial expense of this software and some electronic
modifications is unknown.
Authority to Activate Retail ATC
• Access to retail ATC devices in fuel dispensers is usually limited to only those entities that
have a need to make repairs or modifications to the devices in the field.
• To reduce the possibility of illegal manipulation of software settings or operation, ATC
devices in Canada are required to have tamper‐proof seals in place that must be removed or
damaged if someone were to attempt unauthorized access.
• The Division of Measurement Standards (DMS) already has regulations concerning
authority to activate ATC devices (for such fuel as LPG) and a stipulation that the ATC
device must remain active for at least 12 consecutive months, once it is activated.
• This DMS regulation is to help ensure that a retail station operator could not selectively
operate the device when it was only a benefit to the owner.
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Leak Detection
• ATC implementation would not significantly affect underground storage tank leak
detection in California because stronger leak detection requirements are already in place.
Recommendations
Primary
• If the only criterion for assessing the merit of mandatory ATC installations for use at
California retail stations is a net benefit to consumers, the Transportation Committee
(Committee) of the California Energy Commission concludes that ATCs should not be
required since the results of the cost‐benefit analysis show a net cost for consumers.
• However, the Committee recommends that the Legislature also consider whether the value
of the public perception of increased fairness, accuracy, and consistency of fuel
measurement, in addition to the benefits quantified in the cost‐benefit analysis, justify
mandating ATC at California retail stations.
• If the Legislature chooses to mandate the use of ATC at retail stations, two options are
available: (1) require all retail stations to retrofit their fuel dispensers over a two‐year
period, or (2) a more gradual phase‐in approach, requiring new and refurbished stations to
install, but not activate, ATC devices over a five‐year period. The remainder of retail
stations would be required to install ATC devices during the fifth year, and all stations
would activate their devices at the end of that year. Such a phase‐in approach is the least‐
cost option for mandatory ATC, although it would still result in a net cost to society.
• If the Legislature chooses not to mandate the use of ATC at retail stations, they should
clarify if the current intent of the existing statutes is to permit or prohibit voluntary ATC at
retail outlets for gasoline and diesel fuel.
• If the Legislature chooses to permit or mandate ATC at retail, they should direct the
California Division of Measurement Standards to develop standards addressing equipment
approval, certification testing, compliance enforcement, and consumer labeling provisions
for ATC at retail stations.
• Based on the report analysis, the Committee concludes that establishing a new statewide
reference temperature, or different regional reference temperatures for the state, would not
successfully address temperature compensation at the retail level and therefore does not
recommend this approach.
116
Fuel Density
If ATC was mandated for use at retail stations in California:
• Density reference values used to program retail ATC software should not be altered on a
seasonal or per‐load basis due to the impractical and problematic consequences of such an
approach.
• A single reference density value for finished gasoline should be selected and be
representative of the summer blending season, since the highest divergence from the
60 degree Fahrenheit reference standard exists at that time of year in California. Slightly less
accurate density representation during the winter blending season is more acceptable
because the fuel temperatures during that time of year are much closer to the reference
temperature of 60 degrees Fahrenheit.
• The Canadian reference value of 0.730 g/ml is outside the lower range of California gasoline
density values and should not be used as the reference density standard in this state for
ATC at retail.
• The final value should be one at or near the summer average, rather than annual, California
retail gasoline density value as determined by DMS in consultation with industry and
appropriate state agencies. For purposes of this conclusion, the summer period is May 1
through September 30.
• The ethanol concentration in retail gasoline should be assumed to be 10 percent by volume
for purposes of determining a reference density standard.
• Retail sales of E85 at ATC retail stations should use a density reference standard other than
the one selected for California retail gasoline containing 10 percent ethanol. DMS should
conduct laboratory work to determine the appropriate density value of E85 in consultation
with industry and appropriate state agencies.
• The Canadian reference density standard of 0.840 g/ml for diesel fuel would be acceptable
for use in California since that value is at or near the average retail density properties for
retail diesel fuel in this state.
• ATC retail sales of diesel fuel that contains biodiesel at concentrations up to 20 percent by
volume should use the Canadian reference diesel density standard of 0.840 g/ml.
• The Canadian reference value of 0.840 g/ml is outside the lower range of B100 density
values and should not be used as the reference density standard in this state for ATC at
retail. Rather, DMS should conduct laboratory work to determine the reference standard
density value for B100 in consultation with industry and appropriate state agencies.
117
ATC Retrofit Costs
If ATC was mandated for use at retail stations in California:
• The maximum limit stipulated in subdivision (n), Section 12240, California Business and
Professions Code should be increased to at least $1,200 to ensure that counties will be able to
recover all of their additional costs of performing inspections and certifications.
• There should be provisions put in place to ensure that retail stations that serve isolated
California communities should receive special consideration for financial assistance. One
such example would be the assessment of a special fee of two hundredths (2/100) of a cent
per gallon on all gasoline and diesel fuel wholesale transactions for a period of six months to
cover the expenses incurred for ATC retrofit for retail stations that meet all of the criteria
established by the DMS in consultation with appropriate state agencies.
Permissive vs. Mandatory ATC at Retail Stations
• The status of permissive (voluntary) use of ATC devices at California retail stations is
currently in dispute by various stakeholders.
• If the Legislature chooses not to mandate the use of ATC at retail stations, they should
clarify if the current intent of the existing statutes is to permit or prohibit voluntary ATC at
retail outlets for gasoline and diesel fuel.
• If the Legislature chooses to permit or mandate ATC at retail, they should direct the
California Division of Measurement Standards to develop standards addressing equipment
approval, certification testing, compliance enforcement, and consumer labeling provisions
for ATC at retail stations.
Labeling
• If ATC is required at retail fuel stations, DMS should develop amended regulatory language
for labeling fuel dispensers that includes guidance for:
o Wording of the ATC message (such as “Corrected to 60°F”).
o Font size (similar to existing standards).
o Location of the decal.
o Timing of the requirement (when ATC equipment is activated).
o Authority to affix the decal (certified equipment installers and inspectors).
• If voluntary use of ATC at the retail level is clarified by the State’s Legislature to be
permissible, DMS should develop amended regulatory language for the large price display
signs that includes guidance for:
118
o Wording of the ATC message (such as the notation of “ATC” or “TC”).
o Font size (similar to existing standards for the prices).
o Location of the message.
o Timing of the requirement (when ATC equipment is activated).
o Authority to affix the message (retail station operators).
• Retail station operators should be given the option to include a message on the printed
consumer receipt, but not be required to include any additional information such as fuel
temperature, net and gross gallons.
Optimal Compliance Schedule
• If ATC is mandated for use at California retail stations, the longer schedule (option 3) would
be optimal to minimize costs to businesses and allow adequate lead‐time for a final
compliance deadline of April 1, 2018.
Other Liquid Transportation Fuels
• The following aviation transportation fuels should initially be excluded from any retail ATC
standards:
o Aviation gasoline (100 LL)
o Commercial jet fuel (Jet A)
o Military grade jet fuel (JP‐5 and JP‐8)
Applicability of Findings to Other Regions of the United States
• National standards and guidelines should be adopted through the National Conference of
Weights and Measures (NCWM) committee structure that could be referenced and adhered
to by individual states that elected to promulgate retail ATC regulations.
119
GLOSSARY OF ACRONYMS
°C Degrees Celsius
°F Degrees Fahrenheit
100 LL Low‐lead aviation gasoline designation with minimum 100 octane
AAA American Automobile Association
AAM Alliance of Automobile Manufacturers
AB Assembly Bill
API American Petroleum Institute
AQMD Air Quality Management District
ARB California Air Resources Board
AST Aboveground Storage Tank
ATC Automatic Temperature Compensation
ASTM American Society for Testing and Materials
B100 Biomass‐based diesel fuel
B5 Diesel fuel containing up to 5 percent biomass‐based diesel by volume
B6‐20 Diesel fuel containing from 6 to 20 percent biomass‐based diesel by volume
bbl/d Barrels per Day
BOE California State Board of Equalization
CARBOB California Reformulated Blendstock for Oxygenate Blending
CBG Cleaner Burning Gasoline
CBA Cost‐Benefit Analysis
C.C.R. California Code of Regulations
CIOMA California Independent Oil Marketers Association
CMR County Monthly Reports
CNG Compressed Natural Gas
CTEP California Type Evaluation Program
DFA Department of Food and Agriculture
DMS Division of Measurement Standards
E10 Finished gasoline containing 10 percent fuel ethanol by volume
E15 Finished gasoline containing 15 percent fuel ethanol by volume
E20 Finished gasoline containing 20 percent fuel ethanol by volume
E200 The percentage of fuel evaporated at 200 degrees Fahrenheit
E300 The percentage of fuel evaporated at 300 degrees Fahrenheit
E85 Finished gasoline containing 85 percent fuel ethanol by volume
EIA Energy Information Administration
EPA Environmental Protection Agency (U.S.)
FBP Final Boiling Point
FFV Flexible Fuel Vehicles
FHA Federal Highway Administration
g/ml grams per milliliter
GAO Government Accountability Office
120
GDF Gasoline Dispensing Facility
gph gallons per hour
Gross gallon Non‐standard or unit gallon (231 cubic inches at any temperature)
IBP Initial Boiling Point
HD‐5 Heavy Duty propane specification for automotive fuel use
IP Institute of Petroleum
Jet A Kerosene grade of fuel suitable for most turbine engine aircraft meeting
ASTM D1655 specification
JP‐5 Military jet fuel designed for use in aircraft stationed aboard aircraft
carriers, meeting the MIL‐DTL‐5624U specification
JP‐8 Military jet fuel meeting the MIL‐DTL‐83133E specification
Kg/m3 Kilograms per cubic meter
LCFS Low Carbon Fuel Standard
mm millimeters
MON Motor Octane Number
MTBE Methyl Tertiary Butyl Ether
MVSTAFF Motor Vehicle Stock, Travel, and Fuel Forecast
NA Not Available or Not Applicable
NACS National Association of Convenience Stores
NCDC National Climactic Data Center
NCWM National Conference on Weights and Measures
NEL National Engineering Laboratory
Net gallon Standard or temperature‐assigned gallon (231 cubic inches at 60 degrees
Fahrenheit)
NIST National Institute of Standards and Technology
Non‐standard gallon Gross or unit gallon (231 cubic inches at any temperature)
NREL National Renewable Energy Laboratory
NTEP National Type Evaluation Program
NWML National Weights and Measures Laboratory (United Kingdom)
OAC Online Archive of California
OEM Original Engine Manufacturer
OPIS Oil Price Information Service
PIIRA Petroleum Industry Information and Reporting Act
POS Point of Sale
ppm parts per million
psi pounds per square inch
RFS Renewable Fuel Standard
RIS Regulatory Impact Statement
RMF Retail Motor Fuel
RON Research Octane Number
Rvp Reid vapor pressure
SOC Standard Occupational Classification
Sp.Gr. Specific Gravity
121
Standard gallon Net or temperature‐assigned gallon (231 cubic inches at 60 degrees
Fahrenheit)
T10 Temperature on the fuel distillation curve at which 10 percent of the fuel
has distillated or transitioned from a liquid to vapor state
T30 Temperature on the fuel distillation curve at which 30 percent of the fuel
has distillated or transitioned from a liquid to vapor state
T50 Temperature on the fuel distillation curve at which 50 percent of the fuel
has distillated or transitioned from a liquid to vapor state
T70 Temperature on the fuel distillation curve at which 70 percent of the fuel
has distillated or transitioned from a liquid to vapor state
T90 Temperature on the fuel distillation curve at which 90 percent of the fuel
has distillated or transitioned from a liquid to vapor state
TC Temperature Compensation
Temperature‐assigned Net or standard gallon (231 cubic inches at 60 degrees Fahrenheit)
gallon
UATC Universal Automatic Temperature Compensation
ULSD Ultra Low Sulfur Diesel
Unit gallon Gross or non‐standard gallon (231 cubic inches at any temperature)
U.S. United States
UST Underground Storage Tank
VCF Volume Correction Factor
vol. volume
wt. weight
122
Appendix A: County Demand and Percentages
April '07 to 2007 April '07 to 2007 April '07 to
March '08 CalTrans March '08 CalTrans March '08
Gasoline Percent Diesel Fuel Percent Total Fuel
COUNTY MM Gallons of Total MM Gallons of Total MM Gallons
ALAMEDA 680.114 4.35% 105.200 3.44% 785.314
ALPINE 3.127 0.02% 0.467 0.02% 3.594
AMADOR 20.633 0.13% 3.477 0.11% 24.109
BUTTE 83.453 0.53% 14.669 0.48% 98.123
CALAVERAS 20.191 0.13% 3.038 0.10% 23.229
COLUSA 29.156 0.19% 15.067 0.49% 44.223
CONTRA COSTA 399.901 2.56% 52.187 1.71% 452.088
DEL NORTE 12.054 0.08% 2.324 0.08% 14.379
EL DORADO 80.899 0.52% 12.359 0.40% 93.257
FRESNO 383.935 2.46% 103.024 3.37% 486.959
GLENN 24.019 0.15% 11.147 0.36% 35.167
HUMBOLDT 62.062 0.40% 13.790 0.45% 75.852
IMPERIAL 92.672 0.59% 29.167 0.95% 121.840
INYO 25.552 0.16% 5.918 0.19% 31.470
KERN 387.380 2.48% 177.920 5.82% 565.299
KINGS 64.047 0.41% 24.994 0.82% 89.041
LAKE 28.440 0.18% 5.442 0.18% 33.882
LASSEN 24.835 0.16% 8.137 0.27% 32.972
LOS ANGELES 3,760.363 24.07% 627.652 20.54% 4,388.016
MADERA 73.808 0.47% 29.156 0.95% 102.964
MARIN 138.536 0.89% 14.243 0.47% 152.779
MARIPOSA 12.235 0.08% 1.367 0.04% 13.602
MENDOCINO 55.089 0.35% 10.866 0.36% 65.955
MERCED 124.149 0.79% 48.685 1.59% 172.835
MODOC 9.712 0.06% 2.851 0.09% 12.563
MONO 15.068 0.10% 3.224 0.11% 18.292
MONTEREY 171.437 1.10% 40.105 1.31% 211.542
NAPA 54.475 0.35% 7.864 0.26% 62.339
NEVADA 56.808 0.36% 13.596 0.44% 70.404
ORANGE 1,240.410 7.94% 175.801 5.75% 1,416.211
PLACER 164.846 1.06% 36.340 1.19% 201.186
PLUMAS 16.205 0.10% 3.440 0.11% 19.645
RIVERSIDE 918.030 5.88% 230.182 7.53% 1,148.212
SACRAMENTO 566.573 3.63% 96.226 3.15% 662.798
SAN BENITO 25.650 0.16% 7.765 0.25% 33.415
SAN BERNARDINO 1,027.588 6.58% 282.499 9.24% 1,310.088
SAN DIEGO 1,342.201 8.59% 187.456 6.13% 1,529.657
SAN FRANCISCO 163.297 1.05% 14.620 0.48% 177.917
SAN JOAQUIN 318.576 2.04% 100.852 3.30% 419.429
SAN LUIS OBISPO 139.252 0.89% 28.796 0.94% 168.048
SAN MATEO 315.937 2.02% 33.097 1.08% 349.035
SANTA BARBARA 174.842 1.12% 28.561 0.93% 203.402
SANTA CLARA 729.457 4.67% 88.179 2.89% 817.636
SANTA CRUZ 95.865 0.61% 11.131 0.36% 106.997
SHASTA 93.991 0.60% 28.411 0.93% 122.402
SIERRA 5.197 0.03% 1.666 0.05% 6.862
SISKIYOU 44.100 0.28% 19.469 0.64% 63.570
SOLANO 219.586 1.41% 35.105 1.15% 254.691
SONOMA 183.588 1.17% 28.111 0.92% 211.700
STANISLAUS 194.687 1.25% 55.542 1.82% 250.229
SUTTER 42.092 0.27% 7.210 0.24% 49.302
TEHAMA 45.645 0.29% 16.785 0.55% 62.430
TRINITY 8.407 0.05% 2.033 0.07% 10.440
TULARE 168.441 1.08% 60.959 1.99% 229.400
TUOLUMNE 30.664 0.20% 4.479 0.15% 35.142
VENTURA 321.816 2.06% 46.058 1.51% 367.874
YOLO 100.726 0.64% 28.811 0.94% 129.537
YUBA 32.751 0.21% 8.192 0.27% 40.943
TOTAL 15,624.571 3,055.714 18,680.285
Source: CalTrans MVStaff 2007
http://www.dot.ca.gov/hq/tsip/smb/documents/mvstaff/mvstaff07.pdf
123
Appendix B: NCDC Average Ambient Temperatures
County Apr-07 May-07 Jun-07 Jul-07 Aug-07 Sep-07 Oct-07 Nov-07 Dec-07 Jan-08 Feb-08 Mar-08
ALAMEDA 57.709 60.905 63.672 66.434 67.206 65.667 60.685 56.751 49.122 48.772 52.057 54.533
Alpine 43.510 52.500 59.920 67.790 64.970 53.970 46.550 37.371 27.100 23.980 23.350 35.875
AMADOR 56.900 64.800 72.700 76.900 77.700 67.000 61.600 57.200 42.000 43.900 47.700 54.080
BUTTE 58.683 66.879 73.690 78.525 78.600 70.126 64.794 57.725 45.671 45.062 48.262 54.492
CALAVERAS 48.540 57.640 63.840 70.040 69.820 59.920 52.720 49.700 35.700 34.880 38.300 43.028
COLUSA 60.500 68.600 73.500 74.000 75.500 68.700 60.200 55.700 45.200 44.900 50.800 55.060
CONTRA COSTA 59.540 64.161 68.857 71.315 71.502 67.417 61.321 56.204 47.504 46.825 51.072 55.101
Del Norte 49.900 52.500 54.700 61.700 60.100 56.200 53.300 48.200 43.400 43.300 45.200 44.940
El Dorado 48.590 56.316 55.667 71.895 69.587 58.790 50.726 45.806 34.419 32.939 36.797 42.809
FRESNO 63.004 71.401 77.415 82.091 82.286 74.174 65.656 58.148 45.368 46.953 51.280 57.992
GLENN 61.416 69.105 74.242 77.174 76.689 70.489 61.895 57.468 46.768 44.984 50.237 54.789
HUMBOLDT 50.886 53.024 56.515 61.687 59.993 57.318 53.878 50.267 44.698 44.717 45.676 47.343
IMPERIAL 72.300 79.800 87.400 93.100 93.700 85.400 75.300 66.500 52.100 53.400 58.900 65.400
INYO 62.275 71.100 79.375 86.400 82.825 72.275 60.925 52.525 38.550 39.975 59.400 48.290
KERN 63.924 72.709 78.770 83.509 82.989 74.044 64.402 57.536 45.996 48.694 52.384 57.939
KINGS 61.387 70.069 75.978 80.404 80.349 71.909 62.016 54.553 43.067 45.189 48.221 55.086
LAKE 54.300 62.200 67.800 73.300 72.600 64.900 55.000 50.000 42.500 43.500 46.200 49.000
LASSEN 48.327 56.307 63.193 71.667 69.107 58.600 48.400 41.300 31.000 27.400 33.373 41.042
LOS ANGELES 60.976 63.929 67.583 72.891 74.231 69.839 66.478 61.130 54.219 54.201 56.014 59.985
MADERA 60.800 68.700 74.900 79.200 79.600 71.400 61.000 53.800 43.500 45.500 48.400 54.290
MARIN 56.932 60.444 64.248 67.148 67.816 65.052 59.588 55.176 47.392 46.488 51.076 53.642
MARIPOSA 60.800 68.700 74.900 79.200 79.600 71.400 61.000 53.800 43.500 45.500 48.400 54.290
MENDOCINO 52.091 58.642 60.949 66.509 65.749 61.531 52.365 50.446 42.351 42.931 46.353 43.890
MERCED 61.457 69.663 75.026 78.987 79.170 72.028 62.707 56.224 45.439 46.100 49.809 55.655
Modoc 46.150 53.833 58.683 68.783 69.550 58.900 43.200 37.450 28.783 24.683 27.767 37.555
MONO 43.510 52.500 59.920 67.790 64.970 53.970 46.550 37.371 27.100 23.980 23.350 35.875
MONTEREY 54.587 57.015 59.251 62.319 63.090 62.771 59.105 55.308 47.946 48.563 50.676 52.283
NAPA 55.845 61.494 65.697 68.636 68.709 65.688 58.709 52.288 44.964 45.964 48.752 51.298
NEVADA 47.015 58.307 64.055 68.200 69.672 63.314 50.883 47.397 35.038 35.414 38.097 43.492
ORANGE 62.388 65.683 68.369 73.776 76.249 71.554 68.492 63.119 55.881 56.977 58.590 62.652
PLACER 54.012 62.318 69.362 73.647 67.991 65.735 56.576 52.297 40.729 39.362 43.959 39.005
PLUMAS 47.833 55.605 62.038 69.210 66.781 58.014 47.771 41.481 32.367 30.348 33.705 40.445
RIVERSIDE 64.167 69.507 75.258 80.766 82.558 73.738 70.797 62.119 51.424 51.580 54.986 62.960
SACRAMENTO 61.200 67.300 72.850 76.350 76.650 69.550 62.100 56.100 46.400 46.700 50.300 55.470
SAN BENITO 57.300 61.000 65.000 68.100 68.300 65.200 60.300 55.200 46.100 46.800 49.200 52.560
SAN BERNARDINO 64.016 71.560 79.084 85.441 85.126 75.575 65.585 58.693 45.855 45.807 53.442 59.767
SAN DIEGO 59.768 62.989 65.183 70.031 73.472 69.753 66.696 61.217 54.058 54.240 55.545 58.743
SAN FRANCISCO 54.150 55.650 57.200 60.100 60.500 63.400 59.150 57.050 50.800 49.900 53.200 54.480
SAN JOAQUIN 62.224 68.753 73.874 77.209 77.334 70.510 62.846 56.220 45.648 46.090 49.743 54.404
SAN LUIS OBISPO 57.052 61.369 65.931 69.969 70.492 65.815 60.788 56.752 44.179 45.610 49.383 53.834
SAN MATEO 56.266 59.698 63.338 65.860 66.216 64.285 59.647 55.644 49.289 48.372 51.186 52.210
SANTA BARBARA 59.063 59.829 61.984 65.439 66.327 65.539 62.552 58.148 50.637 52.364 54.387 54.041
SANTA CLARA 58.611 62.910 66.540 69.533 69.834 67.311 61.445 56.466 46.651 46.862 50.316 54.200
SANTA CRUZ 55.812 58.319 61.421 64.465 64.216 62.956 59.047 55.098 47.756 47.756 50.691 52.879
SHASTA 58.992 68.823 76.449 81.164 79.142 70.619 59.760 55.100 44.291 43.158 48.658 52.992
SIERRA 52.200 55.242 61.331 68.021 66.282 60.800 49.124 47.100 35.400 34.500 38.200 44.600
SISKIYOU 50.217 58.517 64.817 72.533 71.620 62.067 48.933 42.283 32.950 30.550 36.200 40.885
SOLANO 60.732 67.132 71.768 75.460 75.414 70.283 62.440 57.152 47.300 45.948 50.648 55.711
SONOMA 57.410 61.315 65.982 68.758 68.967 65.910 59.729 54.488 46.696 46.104 49.673 52.699
STANISLAUS 63.172 70.209 75.837 80.094 80.390 72.279 64.099 57.152 46.992 47.581 51.302 57.016
SUTTER 60.500 68.600 73.500 74.000 75.500 68.700 60.200 55.700 45.200 44.900 50.800 55.060
TEHAMA 60.500 69.900 76.700 82.000 79.500 71.100 61.300 56.000 45.400 44.200 50.100 54.400
TRINITY 52.900 61.300 66.800 74.200 72.000 64.500 52.400 47.800 37.600 36.300 41.500 45.810
TULARE 61.823 70.026 75.655 81.484 80.616 72.668 62.181 56.530 44.838 46.893 50.658 55.961
TUOLUMNE 49.800 59.800 66.400 71.200 71.500 62.700 53.200 48.700 36.600 37.500 41.900 46.260
VENTURA 58.172 60.515 64.384 69.273 69.645 66.669 64.597 58.822 53.100 53.657 54.710 58.304
YOLO 62.416 68.720 73.523 76.732 76.532 70.768 62.820 56.484 46.986 45.714 50.127 55.773
YUBA 55.700 63.400 68.600 74.700 74.900 65.400 61.877 53.400 42.800 42.400 46.000 51.290
Source: Energy Commission staff analysis of NCDC ambient temperature data.
124
Appendix C: Fuel Temperature Regression Results
The regression equations look at fuel prover (fuel from the dispenser nozzle) temperature as a
function of ambient air temperature and other variables. The data used are monthly
observations for each California county for April 2007 through March 2008. Four different
specifications were estimated for regular and premium grade gasoline along with diesel fuel.
Regression Equation 1 has fuel temperature as a function of only ambient air temperature;
Equation 2 uses ambient air temperature and four regional variables; Equation 3 uses ambient
air temperature and month dummy variables; while Equation 4 uses ambient air temperature,
the regional variables and the month variables. The variables in Equation 3 have the highest
significance among all the equations. Also, Equation 3 appears to fit the data the best when
graphed. Thus, Equation 3 will be used to estimate the temperatures from missing counties.
The regression variables are defined as follows: Air temperature is the median monthly air
temperature collected from NCDC. The month variables, Feb‐Dec, are dummy variables equal
to one for that month and zero otherwise. For example, in March, the March variable would
equal one while all the other month variables equal zero. Also, there is no variable for January
as all the month variables are relative to January. The F Statistic is a measure of overall fit of the
equation. Generally, an F Statistic of 4 or more is significant at the 1 percent level. The # of
observations is just the number of data points used for that equation. R sq measures how well
the independent variables (month variables, regional variables, air temperature) can explain the
dependant variable (fuel temperature).
In all the specifications, ambient air temperature is significant at the 1 percent level for
explaining fuel prover temperature. In the two specifications which include the month dummy
variables, most of the months are positive and significant. The regional dummy variables are
negative, but only about half are significant. Specification 3 was chosen over Specification 4 as
adding the regional dummy variables to Specification 3 did not change the fit of the equation.
The variables: Central, North, Sierra, and South are dummy variables that represent various
regions in California.
The three tables below show the regression results for regular grade gasoline, premium grade
gasoline, and diesel fuel.
125
Regression Results for Regular Grade Gasoline
Variable Equation 1 Equation 2 Equation 3 Equation 4
126
Regression Results for Premium Grade Gasoline
Variable Equation 1 Equation 2 Equation 3 Equation 4
127
Regression Results for Diesel Fuel
Variable Equation 1 Equation 2 Equation 3 Equation 4
128
Appendix D: Modified DMS Temperature Survey Data
Original
Data
Temp. Point
Date County Type Degrees F Action Taken
March 2007 Merced All NA Temperature data outside study period, excluded from analysis.
4/26/2007 Siskiyou Dsl‐P 77 Temperature excluded from prover average & differential calculations.
8/7/2007 Los Angeles Dsl‐ST 103.5 Temperature excluded from differential calculation.
9/22/2007 Los Angeles 87‐P 96.5 Temperature excluded from prover average & differential calculations.
9/25/2007 Stanislaus 91‐ST 54.3 Temperature excluded from differential calculation.
10/17/2007 Inyo/Mono Dsl‐ST 45.4 Temperature excluded from differential calculation.
11/5/2007 Butte Dsl‐ST 85.4 Temperature excluded from differential calculation.
11/8/2007 San Bernardino Dsl‐P 61.4 Temperature excluded from prover average & differential calculations.
11/20/2007 San Bernardino Dsl‐P 101 Temperature excluded from prover average & differential calculations.
11/20/2007 San Bernardino Dsl‐ST 112.3 Temperature excluded from prover average & differential calculations.
11/21/2007 Los Angeles 87‐ST 91 Temperature excluded from differential calculation.
12/6/2007 Riverside Dsl‐P 14.9 Original data point changed to 74.9 & included in calculations.
12/13/2007 San Bernardino 87‐ST 97.8 Temperature excluded from differential calculation.
12/14/2007 Los Angeles 91‐ST 90.6 Temperature excluded from differential calculation.
12/15/2007 Fresno Dsl‐ST 37.3 Temperature excluded from differential calculation.
1/8/2008 Los Angeles 91‐ST 90.3 Temperature excluded from differential calculation.
1/8/2008 Los Angeles 91‐ST 90.3 Temperature excluded from differential calculation.
1/22/2008 Los Angeles 91‐ST 72.9 Temperature excluded from differential calculation.
1/30/2008 Butte 91‐ST 67.3 Temperature excluded from differential calculation.
2/7/2008 Santa Barbara 87‐ST 6237 Temperature excluded from differential calculation.
2/25/2008 San Bernardino 87‐P 86.8 Temperature excluded from prover average & differential calculations.
2/28/2008 San Bernardino 91‐ST 95 Temperature excluded from differential calculation.
3/6/2008 San Bernardino Dsl‐ST 94.1 Temperature excluded from differential calculation.
3/14/2008 Los Angeles 91‐ST 91.1 Temperature excluded from differential calculation.
3/21/2008 Los Angeles 91‐ST 85.8 Temperature excluded from differential calculation.
4/2/2008 Lake All NA Temperature data outside study period, excluded from analysis.
April 2008 Alameda All NA Temperature data outside study period, excluded from analysis.
Source: Energy Commission staff analysis of DMS Temperature study data set.
87‐P Temperature of regular grade gasoline from prover.
87‐ST Temperature of regular grade gasoline from storage tank.
91‐P Temperature of premium grade gasoline from prover.
91‐ST Temperature of premium grade gasoline from storage tank.
Dsl‐P Temperature of diesel fuel from prover.
Dsl‐ST Temperature of diesel fuel from storage tank.
129
Appendix E: Canada Fuel Density Values
Source: Measurement Canada
130
Appendix F: Distribution Terminal Survey
AB 868 - Distribution Terminal Questions – August 22, 2008
Please address Questions 1 through 3 for each of the terminals that you control or operate. For
example, private companies would not address these questions for Kinder Morgan distribution
terminals, but they would answer these questions for their own proprietary distribution
terminals.
1. Are your truck‐loading facilities equipped with meters having automatic temperature
compensation capability?
2. If so, what is the nature of the fuel‐loading event with regard to temperature
compensation? For example, is fuel loaded into the tanker truck measured in gross
gallons (U.S. gallons) and then converted to net gallons (petroleum gallons) using
temperature measurement and assumed fuel density properties? Please confirm or
specify.
3. How long are temperature and/or API gravity (or density) data records retained for the
distribution terminal? Is the historical backlog of information in electronic format?
If the data is available, please provide the following information for the time period
April 1, 2007 through March 31, 2008:
• Daily average fuel temperature by type (CaRFG and CARB diesel) differentiating
between difference ethanol concentrations, if appropriate.
• Daily average density values by fuel type.
• Daily distribution volumes associated with the aforementioned data.
If the information is readily available in a “per loading event” format, the data can be
submitted as such without aggregating to a daily level. Whichever method is easier for
the survey respondent would be acceptable.
Please address Questions 4 through 6 for each of the distribution terminals from which you
conduct wholesale transactions. These questions should apply to business conducted at both
proprietary and common carrier distribution terminals. Operators of common carrier
distribution terminals would not respond to these questions.
4. Are unbranded wholesale fuel prices posted and/or quoted for your terminal in units of
net gallons or gross gallons? For purposes of this question, a net gallon is 231 cubic
inches at 60 degrees Fahrenheit. A gross gallon is 231 cubic inches, regardless of
temperature.
131
5. What portion, approximately, of your customers purchase their fuel on a net gallon vs.
gross gallon basis?
6. Which of the following information is normally displayed on a Bill of Lading (BOL)
issued for individual transactions? Please indicate all that apply.
• Net gallons quantity
• Gross gallons quantity
• Temperature of fuel (degrees Fahrenheit)
• API gravity of the fuel
132
Appendix G: Biodiesel Density
Source: NREL/TP-540-38836, October 2005, Table 4, page 18.
133
Appendix H: B20 Density
Source: NREL/TP-540-38836, October 2005, Appendix E, pp 49-50.
134
Appendix I: Fuel Dispenser Survey
California Energy Commission Facility Name: Phone Number:
Address:
Ph. 916-654-4868, Fax 916-654-4753
City and Zip code: County:
E-mail: [email protected]
Dispenser type 1 Dispenser type 2 Dispenser type 3
1. Is this retail fuel dispenser Electronic or Electronic Electronic Electronic Mechanical
Mechanical Mechanical
Mechanical?
Gilbarco Gilbarco Gilbarco
2. What is the make of each type of dispenser
you use to sell fuel at your retail establishment? Dresser Wayne Dresser Wayne Dresser Wayne
Tolkheim Tolkheim Tolkheim
Gasboy Gasboy Gasboy
Other* Other* Other*
3. If "Other", please indicate the make* * * *
4. Please indicate the name of the dispenser:
5. Please list the model # of the dispenser:
6. How many fuel products does the dispenser
1 2 3 4 1 2 3 4 1 2 3 4
have?
1 2 3 4 1 2 3 4 1 2 3 4
7. How many fuel nozzles does the dispenser
have? (include both sides of dispenser) 5 6 7 8 5 6 7 8 5 6 7 8
8. How many dispensers of this type does your Dispensers of this type Dispensers of this type Dispensers of this type
facility have?
9. Does the dispenser sell regular gasoline? YES NO YES NO YES NO
10. Does the dispenser sell midgrade gasoline? YES NO YES NO YES NO
11. Does the dispenser blend midgrade at the
YES NO YES NO YES NO
pump?
12. Does the dispenser sell premium gasoline? YES NO YES NO YES NO
13. Does the dispenser sell diesel fuel? YES NO YES NO YES NO
135
Appendix J: ATC Retrofit Kit Equipment Costs
Number of ATC Per
Retail Retrofit Kit Station
COUNTY Stations Cost Average
ALAMEDA 349 $3,355,984 $9,616
ALPINE 5 $11,059 $2,212
AMADOR 28 $134,419 $4,801
BUTTE 95 $640,799 $6,745
CALAVERAS 34 $170,884 $5,026
COLUSA 19 $113,529 $5,975
CONTRA COSTA 292 $2,632,966 $9,017
DEL NORTE 11 $77,298 $7,027
EL DORADO 67 $501,914 $7,491
FRESNO 355 $2,694,660 $7,591
GLENN 22 $133,340 $6,061
HUMBOLDT 70 $453,528 $6,479
IMPERIAL 70 $630,275 $9,004
INYO 19 $112,071 $5,898
KERN 327 $2,695,184 $8,242
KINGS 60 $401,238 $6,687
LAKE 40 $220,428 $5,511
LASSEN 24 $100,799 $4,200
LOS ANGELES 1942 $18,161,351 $9,352
MADERA 69 $486,799 $7,055
MARIN 65 $586,965 $9,030
MARIPOSA 20 $80,610 $4,030
MENDOCINO 55 $331,248 $6,023
MERCED 91 $591,650 $6,502
MODOC 7 $30,993 $4,428
MONO 13 $64,900 $4,992
MONTEREY 130 $886,616 $6,820
NAPA 33 $257,693 $7,809
NEVADA 36 $249,563 $6,932
ORANGE 596 $6,242,527 $10,474
PLACER 118 $917,297 $7,774
PLUMAS 30 $101,991 $3,400
RIVERSIDE 462 $4,609,029 $9,976
SACRAMENTO 367 $3,172,562 $8,645
SAN BENITO 16 $106,671 $6,667
SAN BERNARDINO 518 $4,920,281 $9,499
SAN DIEGO 747 $6,915,025 $9,257
SAN FRANCISCO 111 $814,559 $7,338
SAN JOAQUIN 204 $1,744,715 $8,553
SAN LUIS OBISPO 109 $783,302 $7,186
SAN MATEO 200 $1,687,073 $8,435
SANTA BARBARA 117 $900,579 $7,697
SANTA CLARA 375 $3,759,259 $10,025
SANTA CRUZ 70 $513,570 $7,337
SHASTA 130 $859,220 $6,609
SIERRA 6 $15,138 $2,523
SISKIYOU 40 $240,320 $6,008
SOLANO 146 $1,362,472 $9,332
SONOMA 154 $1,399,546 $9,088
STANISLAUS 193 $1,587,863 $8,227
SUTTER 40 $218,053 $5,451
TEHAMA 34 $279,006 $8,206
TRINITY 10 $25,619 $2,562
TULARE 233 $1,552,707 $6,664
TUOLUMNE 37 $210,205 $5,681
VENTURA 188 $1,772,007 $9,426
YOLO 60 $465,725 $7,762
YUBA 37 $195,648 $5,288
TOTAL 9,696 $84,180,731 $8,682
Source: Energy Commission staff analysis.
136
Appendix K: ATC Retrofit Kit Labor Costs
Number of Low Est. High Est. Low High
Retail Labor Labor Per Station Per Station
COUNTY Stations Cost Cost Cost Cost
ALAMEDA 349 $310,320 $961,520 $889 $2,755
ALPINE 5 $2,680 $6,560 $536 $1,312
AMADOR 28 $17,940 $62,627 $641 $2,237
BUTTE 95 $87,303 $261,397 $919 $2,752
CALAVERAS 34 $23,291 $68,027 $685 $2,001
COLUSA 19 $15,684 $45,983 $825 $2,420
CONTRA COSTA 292 $270,926 $812,593 $928 $2,783
DEL NORTE 11 $13,648 $37,756 $1,241 $3,432
EL DORADO 67 $53,229 $159,487 $794 $2,380
FRESNO 355 $256,755 $795,597 $723 $2,241
GLENN 22 $17,473 $51,671 $794 $2,349
HUMBOLDT 70 $72,284 $218,008 $1,033 $3,114
IMPERIAL 70 $74,201 $221,920 $1,060 $3,170
INYO 19 $17,480 $52,060 $920 $2,740
KERN 327 $277,674 $832,840 $849 $2,547
KINGS 60 $46,247 $157,810 $771 $2,630
LAKE 40 $31,331 $93,833 $783 $2,346
LASSEN 24 $16,421 $47,103 $684 $1,963
LOS ANGELES 1942 $1,970,096 $5,903,227 $1,014 $3,040
MADERA 69 $51,506 $154,313 $746 $2,236
MARIN 65 $62,049 $186,133 $955 $2,864
MARIPOSA 20 $12,006 $34,767 $600 $1,738
MENDOCINO 55 $45,976 $136,080 $836 $2,474
MERCED 91 $65,083 $222,640 $715 $2,447
MODOC 7 $5,467 $16,620 $781 $2,374
MONO 13 $11,060 $32,353 $851 $2,489
MONTEREY 130 $112,582 $393,467 $866 $3,027
NAPA 33 $31,984 $111,360 $969 $3,375
NEVADA 36 $30,707 $107,480 $853 $2,986
ORANGE 596 $571,731 $1,771,697 $959 $2,973
PLACER 118 $100,297 $300,696 $850 $2,548
PLUMAS 30 $17,919 $51,100 $597 $1,703
RIVERSIDE 462 $528,463 $1,685,063 $1,144 $3,647
SACRAMENTO 367 $296,405 $918,509 $808 $2,503
SAN BENITO 16 $13,200 $46,013 $825 $2,876
SAN BERNARDINO 518 $497,658 $1,507,387 $961 $2,910
SAN DIEGO 747 $746,747 $2,555,333 $1,000 $3,421
SAN FRANCISCO 111 $87,510 $271,040 $788 $2,442
SAN JOAQUIN 204 $162,771 $504,347 $798 $2,472
SAN LUIS OBISPO 109 $108,800 $325,447 $998 $2,986
SAN MATEO 200 $174,579 $523,720 $873 $2,619
SANTA BARBARA 117 $112,440 $335,607 $961 $2,868
SANTA CLARA 375 $375,351 $1,126,040 $1,001 $3,003
SANTA CRUZ 70 $58,834 $200,890 $840 $2,870
SHASTA 130 $114,798 $343,595 $883 $2,643
SIERRA 6 $3,240 $8,063 $540 $1,344
SISKIYOU 40 $34,683 $101,893 $867 $2,547
SOLANO 146 $148,899 $509,300 $1,020 $3,488
SONOMA 154 $160,230 $560,840 $1,040 $3,642
STANISLAUS 193 $146,966 $455,290 $761 $2,359
SUTTER 40 $29,100 $101,267 $728 $2,532
TEHAMA 34 $35,581 $106,540 $1,046 $3,134
TRINITY 10 $5,210 $14,333 $521 $1,433
TULARE 233 $173,128 $592,030 $743 $2,541
TUOLUMNE 37 $29,843 $88,206 $807 $2,384
VENTURA 188 $160,260 $496,673 $852 $2,642
YOLO 60 $45,913 $142,280 $765 $2,371
YUBA 37 $24,643 $86,093 $666 $2,327
TOTAL 9,696 $8,968,600 $27,914,525 $925 $2,879
Source: Energy Commission staff analysis.
137
Appendix L: County Sealers and Equipment Costs
Number of Low Est. High Est. Low High
Retail County County Equipment Equipment
COUNTY Stations Sealers Sealers Cost Cost
ALAMEDA 349 4 5 $2,400 $4,500
ALPINE 5 1 1 $600 $900
AMADOR 28 1 1 $600 $900
BUTTE 95 1 2 $600 $1,800
CALAVERAS 34 1 1 $600 $900
COLUSA 19 1 1 $600 $900
CONTRA COSTA 292 3 3 $1,800 $2,700
DEL NORTE 11 1 1 $600 $900
EL DORADO 67 1 2 $600 $1,800
FRESNO 355 4 4 $2,400 $3,600
GLENN 22 1 1 $600 $900
HUMBOLDT 70 1 2 $600 $1,800
IMPERIAL 70 1 2 $600 $1,800
INYO 19 1 1 $600 $900
KERN 327 4 4 $2,400 $3,600
KINGS 60 1 2 $600 $1,800
LAKE 40 1 1 $600 $900
LASSEN 24 1 1 $600 $900
LOS ANGELES 1942 20 20 $12,000 $18,000
MADERA 69 1 2 $600 $1,800
MARIN 65 1 2 $600 $1,800
MARIPOSA 20 1 1 $600 $900
MENDOCINO 55 1 2 $600 $1,800
MERCED 91 1 2 $600 $1,800
MODOC 7 1 1 $600 $900
MONO 13 1 1 $600 $900
MONTEREY 130 2 3 $1,200 $2,700
NAPA 33 1 1 $600 $900
NEVADA 36 1 1 $600 $900
ORANGE 596 6 6 $3,600 $5,400
PLACER 118 2 3 $1,200 $2,700
PLUMAS 30 1 1 $600 $900
RIVERSIDE 462 5 5 $3,000 $4,500
SACRAMENTO 367 4 4 $2,400 $3,600
SAN BENITO 16 1 1 $600 $900
SAN BERNARDINO 518 6 6 $3,600 $5,400
SAN DIEGO 747 8 8 $4,800 $7,200
SAN FRANCISCO 111 2 3 $1,200 $2,700
SAN JOAQUIN 204 2 3 $1,200 $2,700
SAN LUIS OBISPO 109 2 3 $1,200 $2,700
SAN MATEO 200 2 3 $1,200 $2,700
SANTA BARBARA 117 2 3 $1,200 $2,700
SANTA CLARA 375 4 4 $2,400 $3,600
SANTA CRUZ 70 1 2 $600 $1,800
SHASTA 130 2 3 $1,200 $2,700
SIERRA 6 1 1 $600 $900
SISKIYOU 40 1 1 $600 $900
SOLANO 146 2 3 $1,200 $2,700
SONOMA 154 2 4 $1,200 $3,600
STANISLAUS 193 2 4 $1,200 $3,600
SUTTER 40 1 1 $600 $900
TEHAMA 34 1 1 $600 $900
TRINITY 10 1 1 $600 $900
TULARE 233 3 3 $1,800 $2,700
TUOLUMNE 37 1 1 $600 $900
VENTURA 188 2 4 $1,200 $3,600
YOLO 60 1 2 $600 $1,800
YUBA 37 1 1 $600 $900
TOTAL 9,696 129 156 $77,400 $140,400
Source: Energy Commission staff analysis.
138
Appendix M: ATC Retrofit Total Costs
Number of ATC Low Est. High Est. Low Est. High Est. Low High
Retail Retrofit Kit Labor Labor Total Total Per Station Per Station
COUNTY Stations Cost Cost* Cost* Cost* Cost* Cost* Cost*
ALAMEDA 349 $3,355,984 $345,220 $1,031,320 $3,701,204 $4,387,304 $10,605 $12,571
ALPINE 5 $11,059 $3,180 $7,560 $14,239 $18,619 $2,848 $3,724
AMADOR 28 $134,419 $20,740 $68,227 $155,159 $202,645 $5,541 $7,237
BUTTE 95 $640,799 $96,803 $280,397 $737,602 $921,197 $7,764 $9,697
CALAVERAS 34 $170,884 $26,691 $74,827 $197,576 $245,711 $5,811 $7,227
COLUSA 19 $113,529 $17,584 $49,783 $131,114 $163,313 $6,901 $8,595
CONTRA COSTA 292 $2,632,966 $300,126 $870,993 $2,933,092 $3,503,959 $10,045 $12,000
DEL NORTE 11 $77,298 $14,748 $39,956 $92,046 $117,254 $8,368 $10,659
EL DORADO 67 $501,914 $59,929 $172,887 $561,843 $674,801 $8,386 $10,072
FRESNO 355 $2,694,660 $292,255 $866,597 $2,986,915 $3,561,257 $8,414 $10,032
GLENN 22 $133,340 $19,673 $56,071 $153,012 $189,410 $6,955 $8,610
HUMBOLDT 70 $453,528 $79,284 $232,008 $532,812 $685,536 $7,612 $9,793
IMPERIAL 70 $630,275 $81,201 $235,920 $711,476 $866,195 $10,164 $12,374
INYO 19 $112,071 $19,380 $55,860 $131,451 $167,931 $6,918 $8,838
KERN 327 $2,695,184 $310,374 $898,240 $3,005,557 $3,593,424 $9,191 $10,989
KINGS 60 $401,238 $52,247 $169,810 $453,485 $571,048 $7,558 $9,517
LAKE 40 $220,428 $35,331 $101,833 $255,759 $322,262 $6,394 $8,057
LASSEN 24 $100,799 $18,821 $51,903 $119,619 $152,702 $4,984 $6,363
LOS ANGELES 1942 $18,161,351 $2,164,296 $6,291,627 $20,325,647 $24,452,978 $10,466 $12,592
MADERA 69 $486,799 $58,406 $168,113 $545,205 $654,913 $7,902 $9,491
MARIN 65 $586,965 $68,549 $199,133 $655,513 $786,098 $10,085 $12,094
MARIPOSA 20 $80,610 $14,006 $38,767 $94,616 $119,377 $4,731 $5,969
MENDOCINO 55 $331,248 $51,476 $147,080 $382,724 $478,328 $6,959 $8,697
MERCED 91 $591,650 $74,183 $240,840 $665,833 $832,490 $7,317 $9,148
MODOC 7 $30,993 $6,167 $18,020 $37,160 $49,013 $5,309 $7,002
MONO 13 $64,900 $12,360 $34,953 $77,260 $99,853 $5,943 $7,681
MONTEREY 130 $886,616 $125,582 $419,467 $1,012,198 $1,306,083 $7,786 $10,047
NAPA 33 $257,693 $35,284 $117,960 $292,978 $375,653 $8,878 $11,383
NEVADA 36 $249,563 $34,307 $114,680 $283,870 $364,243 $7,885 $10,118
ORANGE 596 $6,242,527 $631,331 $1,890,897 $6,873,859 $8,133,424 $11,533 $13,647
PLACER 118 $917,297 $112,097 $324,296 $1,029,394 $1,241,593 $8,724 $10,522
PLUMAS 30 $101,991 $20,919 $57,100 $122,910 $159,091 $4,097 $5,303
RIVERSIDE 462 $4,609,029 $574,663 $1,777,463 $5,183,691 $6,386,492 $11,220 $13,824
SACRAMENTO 367 $3,172,562 $333,105 $991,909 $3,505,668 $4,164,472 $9,552 $11,347
SAN BENITO 16 $106,671 $14,800 $49,213 $121,471 $155,884 $7,592 $9,743
SAN BERNARDINO 518 $4,920,281 $549,458 $1,610,987 $5,469,739 $6,531,267 $10,559 $12,609
SAN DIEGO 747 $6,915,025 $821,447 $2,704,733 $7,736,472 $9,619,758 $10,357 $12,878
SAN FRANCISCO 111 $814,559 $98,610 $293,240 $913,169 $1,107,799 $8,227 $9,980
SAN JOAQUIN 204 $1,744,715 $183,171 $545,147 $1,927,886 $2,289,862 $9,450 $11,225
SAN LUIS OBISPO 109 $783,302 $119,700 $347,247 $903,002 $1,130,549 $8,284 $10,372
SAN MATEO 200 $1,687,073 $194,679 $563,920 $1,881,751 $2,250,993 $9,409 $11,255
SANTA BARBARA 117 $900,579 $124,140 $359,007 $1,024,719 $1,259,586 $8,758 $10,766
SANTA CLARA 375 $3,759,259 $412,851 $1,201,040 $4,172,110 $4,960,299 $11,126 $13,227
SANTA CRUZ 70 $513,570 $65,834 $214,890 $579,404 $728,460 $8,277 $10,407
SHASTA 130 $859,220 $127,798 $369,595 $987,018 $1,228,815 $7,592 $9,452
SIERRA 6 $15,138 $3,840 $9,263 $18,978 $24,401 $3,163 $4,067
SISKIYOU 40 $240,320 $38,683 $109,893 $279,003 $350,214 $6,975 $8,755
SOLANO 146 $1,362,472 $163,499 $538,500 $1,525,970 $1,900,972 $10,452 $13,020
SONOMA 154 $1,399,546 $175,630 $591,640 $1,575,176 $1,991,186 $10,228 $12,930
STANISLAUS 193 $1,587,863 $166,266 $493,890 $1,754,128 $2,081,753 $9,089 $10,786
SUTTER 40 $218,053 $33,100 $109,267 $251,153 $327,319 $6,279 $8,183
TEHAMA 34 $279,006 $38,981 $113,340 $317,987 $392,346 $9,353 $11,540
TRINITY 10 $25,619 $6,210 $16,333 $31,829 $41,952 $3,183 $4,195
TULARE 233 $1,552,707 $196,428 $638,630 $1,749,134 $2,191,337 $7,507 $9,405
TUOLUMNE 37 $210,205 $33,543 $95,606 $243,748 $305,811 $6,588 $8,265
VENTURA 188 $1,772,007 $179,060 $534,273 $1,951,067 $2,306,281 $10,378 $12,267
YOLO 60 $465,725 $51,913 $154,280 $517,638 $620,005 $8,627 $10,333
YUBA 37 $195,648 $28,343 $93,493 $223,991 $289,141 $6,054 $7,815
TOTAL 9,696 $84,180,731 $9,938,300 $29,853,925 $94,119,031 $114,034,656 $9,707 $11,761
Source: Energy Commission staff analysis.
Note: * Includes incremental inspection fee cost.
139
Appendix N: High Case Financing Costs
Number of High Estimate Repayment Per Station
COUNTY Retail Stations Total Cost* Total Cost Total Cost
ALAMEDA 349 $4,387,304 $4,900,180 $14,041
ALPINE 5 $18,619 $20,795 $4,159
AMADOR 28 $202,645 $226,335 $8,083
BUTTE 95 $921,197 $1,028,884 $10,830
CALAVERAS 34 $245,711 $274,435 $8,072
COLUSA 19 $163,313 $182,404 $9,600
CONTRA COSTA 292 $3,503,959 $3,913,572 $13,403
DEL NORTE 11 $117,254 $130,961 $11,906
EL DORADO 67 $674,801 $753,685 $11,249
FRESNO 355 $3,561,257 $3,977,567 $11,204
GLENN 22 $189,410 $211,552 $9,616
HUMBOLDT 70 $685,536 $765,675 $10,938
IMPERIAL 70 $866,195 $967,453 $13,821
INYO 19 $167,931 $187,562 $9,872
KERN 327 $3,593,424 $4,013,495 $12,274
KINGS 60 $571,048 $637,803 $10,630
LAKE 40 $322,262 $359,934 $8,998
LASSEN 24 $152,702 $170,553 $7,106
LOS ANGELES 1942 $24,452,978 $27,311,531 $14,064
MADERA 69 $654,913 $731,472 $10,601
MARIN 65 $786,098 $877,993 $13,508
MARIPOSA 20 $119,377 $133,332 $6,667
MENDOCINO 55 $478,328 $534,245 $9,714
MERCED 91 $832,490 $929,808 $10,218
MODOC 7 $49,013 $54,742 $7,820
MONO 13 $99,853 $111,526 $8,579
MONTEREY 130 $1,306,083 $1,458,764 $11,221
NAPA 33 $375,653 $419,567 $12,714
NEVADA 36 $364,243 $406,823 $11,301
ORANGE 596 $8,133,424 $9,084,221 $15,242
PLACER 118 $1,241,593 $1,386,735 $11,752
PLUMAS 30 $159,091 $177,689 $5,923
RIVERSIDE 462 $6,386,492 $7,133,073 $15,440
SACRAMENTO 367 $4,164,472 $4,651,299 $12,674
SAN BENITO 16 $155,884 $174,107 $10,882
SAN BERNARDINO 518 $6,531,267 $7,294,773 $14,083
SAN DIEGO 747 $9,619,758 $10,744,308 $14,383
SAN FRANCISCO 111 $1,107,799 $1,237,301 $11,147
SAN JOAQUIN 204 $2,289,862 $2,557,546 $12,537
SAN LUIS OBISPO 109 $1,130,549 $1,262,710 $11,584
SAN MATEO 200 $2,250,993 $2,514,134 $12,571
SANTA BARBARA 117 $1,259,586 $1,406,831 $12,024
SANTA CLARA 375 $4,960,299 $5,540,158 $14,774
SANTA CRUZ 70 $728,460 $813,617 $11,623
SHASTA 130 $1,228,815 $1,372,463 $10,557
SIERRA 6 $24,401 $27,254 $4,542
SISKIYOU 40 $350,214 $391,154 $9,779
SOLANO 146 $1,900,972 $2,123,195 $14,542
SONOMA 154 $1,991,186 $2,223,956 $14,441
STANISLAUS 193 $2,081,753 $2,325,110 $12,047
SUTTER 40 $327,319 $365,583 $9,140
TEHAMA 34 $392,346 $438,211 $12,889
TRINITY 10 $41,952 $46,856 $4,686
TULARE 233 $2,191,337 $2,447,504 $10,504
TUOLUMNE 37 $305,811 $341,561 $9,231
VENTURA 188 $2,306,281 $2,575,885 $13,702
YOLO 60 $620,005 $692,483 $11,541
YUBA 37 $289,141 $322,942 $8,728
TOTAL 9,696 $114,034,656 $127,365,308 $13,136
Source: Energy Commission staff analysis. Note: * Includes incremental inspection fee cost.
Interst Rate: 9.50% Payback Period: 1 Year
140
Appendix O: Low Case Financing Costs
Number of Low Estimate Repayment Per Station
COUNTY Retail Stations Total Cost* Total Cost Total Cost
ALAMEDA 349 $3,701,204 $4,081,194 $11,694
ALPINE 5 $14,239 $15,700 $3,140
AMADOR 28 $155,159 $171,088 $6,110
BUTTE 95 $737,602 $813,329 $8,561
CALAVERAS 34 $197,576 $217,860 $6,408
COLUSA 19 $131,114 $144,575 $7,609
CONTRA COSTA 292 $2,933,092 $3,234,222 $11,076
DEL NORTE 11 $92,046 $101,496 $9,227
EL DORADO 67 $561,843 $619,525 $9,247
FRESNO 355 $2,986,915 $3,293,571 $9,278
GLENN 22 $153,012 $168,722 $7,669
HUMBOLDT 70 $532,812 $587,514 $8,393
IMPERIAL 70 $711,476 $784,521 $11,207
INYO 19 $131,451 $144,946 $7,629
KERN 327 $3,005,557 $3,314,127 $10,135
KINGS 60 $453,485 $500,043 $8,334
LAKE 40 $255,759 $282,017 $7,050
LASSEN 24 $119,619 $131,900 $5,496
LOS ANGELES 1942 $20,325,647 $22,412,411 $11,541
MADERA 69 $545,205 $601,179 $8,713
MARIN 65 $655,513 $722,813 $11,120
MARIPOSA 20 $94,616 $104,330 $5,216
MENDOCINO 55 $382,724 $422,017 $7,673
MERCED 91 $665,833 $734,192 $8,068
MODOC 7 $37,160 $40,975 $5,854
MONO 13 $77,260 $85,192 $6,553
MONTEREY 130 $1,012,198 $1,116,116 $8,586
NAPA 33 $292,978 $323,057 $9,790
NEVADA 36 $283,870 $313,014 $8,695
ORANGE 596 $6,873,859 $7,579,574 $12,717
PLACER 118 $1,029,394 $1,135,079 $9,619
PLUMAS 30 $122,910 $135,528 $4,518
RIVERSIDE 462 $5,183,691 $5,715,883 $12,372
SACRAMENTO 367 $3,505,668 $3,865,582 $10,533
SAN BENITO 16 $121,471 $133,942 $8,371
SAN BERNARDINO 518 $5,469,739 $6,031,298 $11,643
SAN DIEGO 747 $7,736,472 $8,530,749 $11,420
SAN FRANCISCO 111 $913,169 $1,006,921 $9,071
SAN JOAQUIN 204 $1,927,886 $2,125,816 $10,421
SAN LUIS OBISPO 109 $903,002 $995,710 $9,135
SAN MATEO 200 $1,881,751 $2,074,944 $10,375
SANTA BARBARA 117 $1,024,719 $1,129,923 $9,657
SANTA CLARA 375 $4,172,110 $4,600,447 $12,268
SANTA CRUZ 70 $579,404 $638,889 $9,127
SHASTA 130 $987,018 $1,088,352 $8,372
SIERRA 6 $18,978 $20,926 $3,488
SISKIYOU 40 $279,003 $307,647 $7,691
SOLANO 146 $1,525,970 $1,682,636 $11,525
SONOMA 154 $1,575,176 $1,736,894 $11,279
STANISLAUS 193 $1,754,128 $1,934,219 $10,022
SUTTER 40 $251,153 $276,938 $6,923
TEHAMA 34 $317,987 $350,633 $10,313
TRINITY 10 $31,829 $35,096 $3,510
TULARE 233 $1,749,134 $1,928,712 $8,278
TUOLUMNE 37 $243,748 $268,773 $7,264
VENTURA 188 $1,951,067 $2,151,377 $11,443
YOLO 60 $517,638 $570,782 $9,513
YUBA 37 $223,991 $246,987 $6,675
TOTAL 9,696 $94,119,031 $103,781,905 $10,704
Source: Energy Commission staff analysis. Note: * Includes incremental inspection fee cost.
Interst Rate: 4.00% Payback Period: 3 Years
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Appendix P: Retail Station Average Fuel Sales
Apr.07 to Mar.08 Fuel Sales
Number of Fuel Sales Per Station
COUNTY Retail Stations Millions of Gallons Monthly Gallons
ALAMEDA 349 785.314 187,515
ALPINE 5 3.594 59,896
AMADOR 28 24.109 71,754
BUTTE 95 98.123 86,072
CALAVERAS 34 23.229 56,933
COLUSA 19 44.223 193,959
CONTRA COSTA 292 452.088 129,020
DEL NORTE 11 14.379 108,929
EL DORADO 67 93.257 115,992
FRESNO 355 486.959 114,310
GLENN 22 35.167 133,208
HUMBOLDT 70 75.852 90,300
IMPERIAL 70 121.840 145,047
INYO 19 31.470 138,026
KERN 327 565.299 144,062
KINGS 60 89.041 123,668
LAKE 40 33.882 70,588
LASSEN 24 32.972 114,487
LOS ANGELES 1,942 4,388.016 188,295
MADERA 69 102.964 124,353
MARIN 65 152.779 195,871
MARIPOSA 20 13.602 56,673
MENDOCINO 55 65.955 99,932
MERCED 91 172.835 158,274
MODOC 7 12.563 149,555
MONO 13 18.292 117,253
MONTEREY 130 211.542 135,604
NAPA 33 62.339 157,422
NEVADA 36 70.404 162,973
ORANGE 596 1,416.211 198,016
PLACER 118 201.186 142,080
PLUMAS 30 19.645 54,569
RIVERSIDE 462 1,148.212 207,109
SACRAMENTO 367 662.798 150,499
SAN BENITO 16 33.415 174,037
SAN BERNARDINO 518 1,310.088 210,761
SAN DIEGO 747 1,529.657 170,644
SAN FRANCISCO 111 177.917 133,571
SAN JOAQUIN 204 419.429 171,335
SAN LUIS OBISPO 109 168.048 128,477
SAN MATEO 200 349.035 145,431
SANTA BARBARA 117 203.402 144,874
SANTA CLARA 375 817.636 181,697
SANTA CRUZ 70 106.997 127,377
SHASTA 130 122.402 78,463
SIERRA 6 6.862 95,312
SISKIYOU 40 63.570 132,437
SOLANO 146 254.691 145,372
SONOMA 154 211.700 114,556
STANISLAUS 193 250.229 108,044
SUTTER 40 49.302 102,713
TEHAMA 34 62.430 153,016
TRINITY 10 10.440 86,997
TULARE 233 229.400 82,046
TUOLUMNE 37 35.142 79,149
VENTURA 188 367.874 163,065
YOLO 60 129.537 179,913
YUBA 37 40.943 92,213
TOTAL 9,696 18,680.285 160,550
Source: Energy Commission staff analysis.
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Appendix Q: At Risk Retail Station Costs
Number of ATC
Retail Retrofit
COUNTY Stations Cost
ALPINE 5 $20,419
BUTTE 4 $26,021
CALAVERAS 2 $12,762
COLUSA 6 $35,784
DEL NORTE 2 $18,969
EL DORADO 3 $22,723
FRESNO 11 $58,679
GLENN 1 $3,718
HUMBOLDT 8 $61,085
IMPERIAL 6 $42,251
INYO 5 $35,931
KERN 2 $10,633
LASSEN 8 $49,968
MADERA 2 $11,670
MARIN 1 $3,058
MARIPOSA 7 $44,124
MENDOCINO 8 $52,593
MERCED 2 $14,366
MODOC 2 $9,037
MONO 5 $38,082
MONTEREY 2 $19,709
NEVADA 2 $11,413
PLACER 7 $56,533
PLUMAS 8 $43,609
RIVERSIDE 3 $24,000
SACRAMENTO 3 $24,950
SAN BERNARDINO 6 $42,796
SAN DIEGO 8 $50,941
SAN JOAQUIN 1 $19,994
SAN LUIS OBISPO 1 $6,549
SAN MATEO 2 $18,582
SANTA BARBARA 4 $24,906
SANTA CLARA 1 $16,246
SHASTA 7 $46,371
SIERRA 6 $27,135
SISKIYOU 13 $105,242
SONOMA 1 $3,623
SUTTER 1 $6,054
TRINITY 6 $25,940
TULARE 1 $2,955
TUOLUMNE 2 $12,422
YOLO 1 $2,882
YUBA 6 $22,908
TOTAL 182 $1,187,631
Source: Energy Commission staff analysis.
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Appendix R: Valuation of Reduced “Gallons” Sold
Regular Mid-Grade Premium Diesel All
COUNTY Gasoline Gasoline Gasoline Fuel Fuels
ALAMEDA $6,725,220 $933,288 $1,399,909 $1,466,294 $10,524,711
ALPINE -$9,184 -$926 -$910 $1,470 -$9,550
AMADOR $252,802 $35,722 $54,453 $57,350 $400,328
BUTTE $1,081,140 $157,622 $246,999 $236,791 $1,722,552
CALAVERAS $118,179 $19,090 $32,392 $30,106 $199,767
COLUSA $458,988 $63,727 $95,622 $265,180 $883,517
CONTRA COSTA $5,406,818 $693,746 $961,185 $879,622 $7,941,372
DEL NORTE $45,153 $7,073 $11,727 $16,800 $80,753
EL DORADO $256,856 $41,643 $70,714 $96,418 $465,631
FRESNO $7,315,386 $1,037,089 $1,585,825 $2,134,299 $12,072,599
GLENN $393,558 $54,549 $81,713 $200,324 $730,145
HUMBOLDT $368,526 $50,009 $73,400 $109,791 $601,726
IMPERIAL $2,763,628 $376,257 $554,191 $784,185 $4,478,261
INYO $449,708 $62,229 $93,056 $112,653 $717,646
KERN $7,687,905 $1,058,765 $1,576,379 $3,606,642 $13,929,691
KINGS $988,418 $135,364 $200,458 $382,350 $1,706,590
LAKE $334,150 $46,171 $68,955 $83,818 $533,094
LASSEN $54,604 $9,641 $17,294 $55,907 $137,446
LOS ANGELES $82,279,504 $11,142,317 $16,325,934 $14,089,409 $123,837,163
MADERA $1,351,778 $187,196 $280,163 $530,940 $2,350,077
MARIN $1,661,608 $233,949 $355,566 $206,889 $2,458,012
MARIPOSA $209,279 $28,993 $43,413 $25,200 $306,884
MENDOCINO $391,440 $57,241 $89,889 $111,995 $650,564
MERCED $2,145,664 $296,067 $441,619 $928,100 $3,811,450
MODOC -$9,398 -$307 $911 $12,714 $3,921
MONO -$47,738 -$4,888 -$4,945 $9,857 -$47,714
MONTEREY $2,085,393 $301,807 $470,030 $570,419 $3,427,650
NAPA $738,693 $104,323 $159,019 $140,365 $1,142,400
NEVADA $273,102 $41,633 $67,575 $125,737 $508,046
ORANGE $24,253,341 $3,307,540 $4,879,715 $3,909,243 $36,349,839
PLACER $2,066,142 $280,464 $411,690 $591,514 $3,349,810
PLUMAS $24,284 $4,718 $8,934 $21,820 $59,757
RIVERSIDE $23,660,103 $3,240,870 $4,801,021 $6,414,998 $38,116,992
SACRAMENTO $7,252,716 $1,051,163 $1,638,593 $1,581,851 $11,524,323
SAN BENITO $302,870 $42,671 $64,887 $109,546 $519,974
SAN BERNARDINO $21,927,792 $2,951,351 $4,297,853 $6,512,949 $35,689,946
SAN DIEGO $26,044,708 $3,612,828 $5,417,058 $3,928,630 $39,003,224
SAN FRANCISCO $518,970 $70,215 $102,765 $159,987 $851,939
SAN JOAQUIN $5,446,135 $735,356 $1,074,137 $1,628,052 $8,883,680
SAN LUIS OBISPO $1,810,023 $244,633 $357,713 $408,828 $2,821,198
SAN MATEO $3,830,430 $512,422 $741,920 $409,849 $5,494,621
SANTA BARBARA $2,431,908 $354,378 $555,194 $446,806 $3,788,286
SANTA CLARA $11,174,377 $1,465,443 $2,078,700 $1,428,914 $16,147,434
SANTA CRUZ $1,236,563 $168,684 $248,862 $153,712 $1,807,821
SHASTA $1,478,967 $209,447 $319,940 $484,083 $2,492,438
SIERRA $23,011 $3,570 $5,874 $15,081 $47,537
SISKIYOU $181,267 $24,682 $36,273 $117,492 $359,714
SOLANO $2,588,538 $354,504 $524,977 $467,549 $3,935,568
SONOMA $2,040,990 $285,937 $432,573 $352,628 $3,112,129
STANISLAUS $3,680,778 $491,374 $709,642 $1,107,094 $5,988,888
SUTTER $729,135 $104,132 $160,293 $132,072 $1,125,632
TEHAMA $767,399 $104,339 $153,436 $285,493 $1,310,667
TRINITY $76,169 $10,436 $15,449 $23,146 $125,200
TULARE $4,062,805 $557,629 $827,636 $1,689,837 $7,137,907
TUOLUMNE $222,558 $32,493 $50,941 $48,287 $354,278
VENTURA $5,626,278 $755,184 $1,096,921 $827,889 $8,306,272
YOLO $1,493,643 $203,358 $299,404 $442,198 $2,438,602
YUBA $510,523 $65,959 $92,024 $136,322 $804,828
TOTAL $281,233,602 $38,415,174 $56,756,964 $61,107,496 $437,513,236
Source: Energy Commission staff analysis.
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Appendix S: Information Asymmetry
Information asymmetry exists in the retail fuels market as it pertains to fuel temperature which
implies that the knowledge of the temperature is not equal between the motorists and retail
stations. In the case of retail fuels market, sellers have more knowledge of the temperature of
the fuel than motorists. Absent this temperature information consumers may over‐value or
under‐value fuel depending on the temperature of fuel. Sellers do not have any information
signals to specify their fuel temperature or temperature differences with other retail stations, so
government intervention through the mandating of automatic temperature compensation
(ATC) equipment would be required to remove this information asymmetry since retailer will
not have the incentive to do so on their own.
Figure 1 – Information Asymmetry Model109
Economists distinguish three types of products: search goods, experience goods, and post‐
experience goods110. The Energy Commission considers transportation fuels as a post‐
109 Figure 1 Assumption: Retailers price fuel on a net gallon basis and then sell the fuel on a gross gallon
basis. This is illustrated by Qnone indicating gross gallons sold, and Pnone as net price posted. Qfull then
indicates net gallons sold and Pfull indicates gross price posted.
110 Boardman, Anthony, et al. Cost Benefit Analysis: Concepts and Practice. Third Edition. Prentice Hall.
New Jersey: Upper Saddle River, 2001. Search goods are products with characteristics that consumers can
learn about by examining them prior to consumption. Experience goods are products where consumers
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experience good since consumption does not necessarily reveal the temperature or quality of
the fuel. Fuel is unique in that it is a product that consumers never observe but only experience.
Economics provides a methodology for analyzing costs to society from the distortion of the
market from temperature variation over time and across retailers. In Figure 1, with no
information the market outcome is price Pnone and quantity gallons consumed Qnone. With full
information the demand would be lower resulting in a price of Pfull and a quantity consumed of
Qfull. These two outcomes in Figure 1 illustrate the two effects of information asymmetry. The
first effect is the increase in price and quantity demand of the good purchased, creating a
transfer of wealth from the buyer to the seller. The second impact is the increased amount of
goods sold relative to the full information scenario which is a deadweight loss which is shown
by the triangle. The deadweight loss is the cost to society due to the inefficiency that
information asymmetry creates. The first effect of a transfer wealth does not represent a
decrease in social welfare and therefore is not relevant in determining the costs from the
inefficiency created by misinformation, but may have relevance in the question of fairness.111
The perception is that consumers in warmer states, such as California, are not receiving their
“fair share” of transportation fuels since consumers are not receiving the larger gallon as they
would at the wholesale level. The inefficiency occurs when consumers over‐value fuel in warm
weather or fuel sold by retailers offering warmer fuel, purchasing more than they if they had
full information on temperature. The opposite is also true where consumers may undervalue
fuel in colder weather or when retailers offer colder fuel, purchasing less than they would have
if they had known the temperature of the fuel.
Deadweight loss calculations:
In the November 2008 Fuel Delivery Temperature Study Staff Report Appendix R, the
calculation of the deadweight loss was a simplistic geometric exercise measuring the area of the
deadweight loss triangle. Applying the average fuel temperature difference from the reference
temperature to Figure 1 yielded the calculations of total annual deadweight loss for all grades of
gasoline and diesel equal $3.22 million, $2.84 million for gasoline and $380,000 for diesel. The
revised calculation of total annual deadweight loss for all grades of gasoline and diesel is
$257,729.
Since the release of the November staff report, a white paper written by University of Chicago
Professors Kevin M. Murphy and Robert H. Topel provided a more technical econometric
methodology for measuring the costs of information asymmetry.112 A similar figure is used as
can obtain full knowledge only after purchasing and consuming them. Post‐experience goods are
products where consumption does not necessarily reveal information to consumers.
111 Vining, Aidan R. and Weimer, David L. “Information asymmetry favoring sellers: a policy
framework.” Policy Sciences 21: 281‐303, 1988.
112 Murphy, Kevin M., Topel, Robert H. White Paper: “Comments on the California Energy Commission’s
Fuel Delivery Temperature Study.” University of Chicago.
146
Figure 1 and they included the deadweight loss formula that includes economic components
like own‐price elasticity of demand, pass‐thru rate, and variability of information effects. Their
“best case” calculation of $200,000 for the gain in increased transparency for gasoline is much
smaller than the original $3.2 million dollar value primarily due to the inclusion of a 0.2 own‐
price elasticity of demand for gasoline.
The formula for calculating the deadweight loss or the overall social cost of the purchasing
decisions that are distorted by information asymmetry is:
(1)
In the deadweight loss formula in equation (1), X = Pnone x Qnone is total market expenditure on
gasoline during the period, ηD represents the own‐price elasticity of demand for gasoline, α
represents the percentage reduction of the effective energy content of warmer fuel from the
average temperature, and R represents the pass‐thru rate. The formula for equation (1) is both
used to estimate the total social costs of fuel temperature differences over time and across
regions.
After performing some algebra, equation (2) incorporates the variance of α and is used as the
formula calculate the final deadweight loss for seasonal and across retailers differentials.113
(2)
Given a pass‐thru rate, R=1.0 (an upper bound value), a short‐run own‐price elasticity for
gasoline and diesel, ηD=0.23114, and values X and α estimated from the report, the total annual
gain for both gasoline and diesel from increased price transparency from ATC is $257,729. The
reduction of seasonal variation for gasoline gives an annual gain of $108,876 and $14,622 for
diesel. The reduction of variation across retailers results in an annual gain of $111,756 for
gasoline and $22,475 for diesel.115
[http://www.energy.ca.gov/transportation/fuel_delivery_temperature_study/documents/2008‐12‐
09_workshop/comments/] White paper provides further discussion of deadweight loss methodology.
113 Equation (2) is derived in the Murphy and Topel white paper cited in the above footnote.
114 Espey, Molly. “Gasoline demand revisited: an international meta‐analysis of elasticities.” Energy
Economics 20: 273‐295, 1998. Molly Epsey examined 101 studies and found a median price elasticity (ηD)
for gasoline of 0.23. For simplicity we used the same price elasticity for both diesel and gasoline.
115 Actual consumption (Qnone) of gasoline during the 12th‐month study period was 15,624,571,016 gallons
with an average volume‐weighted price (Pnone) of $3.284. Actual consumption (Qnone) of diesel during the
12th‐month study period was 3,055,713,800 gallons and average volume‐weighted price (Pnone) of $3.377.
The estimated seasonal value for α is 0.00744 for gasoline and 0.00608 for diesel, the variance of α is
147
(0.007442)/3 for gasoline and (0.00608)/3 for diesel. For costs associated from variation across retailers the
values of ηD=30, R=0.2, and α=0.00333 were used for all fuels.
148