This morning, oil analyst Bob van der Valk published an open letter to Governor Schwarzenegger asking for a one-year delay in a California Air Resources Board (CARB) rule that forces small gas stations to install costly new EVR equipment on their gas pumps to reduce pump vapors by three percent.  

In the LETTER, published at UCAN's Gas Project, Mr. van der Valk compares the problem to a regulatory Gordian Knot that must be cut immediately and cites 7 good reasons for delaying implementation ( a position UCAN supports).

Those reasons are:  

1) 1,000 to 4,500 of California's 11,000 gas stations could be forced to shut down or pay crippling fines.

UCAN's intensive research of the San Diego market has shown irrefutably that neighborhoods with locally owned independent gas stations pay less for their gasoline. Unfortunately, these are the stations that will be closed under the April Fuel's Day Mandate.

2) A bipartisan group of California lawmakers supports the delay.

And so does UCAN. On April 30, UCAN's Executive Director, Michael Shames, sent a letter to key lawmakers and Air Resource Board officials urging them to delay the deadline for at least six months to a year on the grounds that financing is not available at this time for cash-strapped retailers.

3) Due to the bank meltdown, gas station owners can't finance the costly upgrades

When the law was passed in 2,000 it ordered the industry to reduce nozzle fumes and drips by 3%. At that time the technology didn't exist. It was assumed that the industry would find a cheap solution to the problem by 2009. It didn't. Upgrades cost upwards of $11,000 per pump. And thanks to the current financial crisis, even dealers with excellent credit can't get financing. In order for dealers to install the new nozzles, they must tear down and replace equipment that is located below the pavement.

4) The new pollution-fighting nozzles are poorly made and fail frequently

The nozzles can be broken with a quick twist. They fail frequently, and are costly to replace.

5) The  impact on pollution is minimal.

The new nozzles are not only costly and unreliable, but they only reduce nozzle drips and fumes by 3%, a negligible improvement at the cost of potentially thousands of jobs.

6) The mandate will increase gasoline consumption and pollution.

Consumers will be forced to drive farther to buy their gasoline. Even short trips can result in significant increases in pollution levels. For example, a typical SUV driver will dump 1.6 pounds of carbon into the atmosphere per mile driven. By closing local gas stations, many drivers will have to travel greater distances.

7) Working people will be hit the hardest and "Ghost Stations" will be a blight in poorer neighborhoods.

The worst impacts will be felt in low-income neighborhoods where the majority of independent stations are located. Since locally owned stations are usually the cheapest stations, gas prices will increase. The ultimate effect will be that residents of poorer neighborhoods will be forced to pay more for their gasoline.

Click here for the full text of the LETTER. 

See also "The April Fool's Day Joke That Isn't Funny" and UCAN's Letter to Mary D. Nichols, Chairman, California Air Resources Board.