Regulatory
Alert
EMA Cautions EPA Against Fast-Tracking Gas Pipelines Based on Outdated Heating Oil Assumptions
EMA Regulatory Counsel Contacts: Jeff Leiter and Jorge Roman
Washington, D.C. -
August 5, 2025 - The Energy Marketers of America (EMA) today
submitted comments to the U.S. Environmental Protection Agency (EPA) in
response to its request for public input on implementation challenges
under Section 401 of the Clean Water Act (CWA). EMA emphasized the
importance of preserving a diverse energy mix, including modern liquid
heating fuels, to support energy independence, small business viability,
environmental innovation, and consumer choice—particularly in regions like
the Northeast where these fuels remain essential. Notably, EMA cautioned
against bypassing established safeguards to fast-track natural gas
pipeline approvals based on outdated assumptions that it displaces "dirty"
heating oil.
In its comments, EMA urged EPA to carefully consider
the potential unintended financial consequences of promoting the rapid
expansion of natural gas infrastructure through favorable permitting
policies––such as diminished competition, suppressed environmental
innovation, increased barriers for small businesses, higher costs for
ratepayers, and potential impacts on grid reliability. The organization
also asked EPA not to rely on misconceptions about the environmental
profile of heating oil as justification for greenlighting major
infrastructure projects without thorough review under the CWA.
"Modern liquid heating fuels, such as ultra-low sulfur heating oil (ULSHO)
and renewable BioHeat® blends, have achieved environmental profiles
comparable to natural gas," said EMA President Rob Underwood. "These
advancements underscore the need for balanced policies that recognize
progress in the liquid fuels sector and avoid stifling competition."
EMA highlighted the oilheat industry's leadership in clean energy
innovation, citing advances in ULSHO and the integration of U.S.-produced
renewable fuels. ULSHO, with sulfur levels reduced to just 15 parts per
million (ppm), has become the standard in states such as New York, Maine,
New Hampshire, Vermont, Massachusetts, Connecticut, Rhode Island, New
Jersey, Pennsylvania, Delaware, and Maryland since 2018. This transition
has resulted in a 99 percent reduction in sulfur content and sulfur
dioxide emissions, effectively eliminating particulate emissions and
enabling "Zero Smoke" performance—making it equivalent to natural gas in
cleanliness and far superior to alternatives like wood pellets.
Meanwhile, BioHeat®––a blend of ULSHO with biodiesel or renewable
diesel––reduces greenhouse gas emissions while supporting American
agriculture and energy independence. These fuels integrate seamlessly with
existing infrastructure, enabling cleaner energy adoption without costly
equipment changes. EMA reiterated the industry’s commitment to further
increasing biofuel content to drive additional emissions reductions.
Beyond environmental benefits, EMA emphasized the role of modern
heating fuels in grid reliability and the local economy, positioning
energy marketers as critical players during winter peak demands and as
vital community anchors sustaining thousands of jobs and preserving
consumer choice.
To promote balanced, consumer-focused policy, EMA
recommended that EPA:
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Promote energy diversity by preserving access to ULSHO and its renewable blends as reliable, clean heating alternatives to utility-supplied natural gas.
-
Acknowledge the environmental advancements of modern liquid fuels, including dramatic reductions in particulate and sulfur emissions through renewable blending.
-
Support innovation in renewable fuel development to further lower emissions from existing infrastructure without requiring expensive overhauls.
-
Encourage adoption of high-efficiency heating technologies via voluntary incentives to improve energy efficiency and reduce emissions in residential and commercial settings.
"Rushing natural gas
infrastructure expansion could diminish competition, hinder
environmental innovation, pose barriers for small energy marketers,
and increase consumer costs through higher utility bills," Underwood
added. "A diverse energy mix incorporating environmentally friendly
liquid heating fuels offers a more cost-effective and reliable path
forward."
EMA will continue to encourage EPA to consider the
economic, social, and environmental benefits of modern heating fuels
as part of an all-of-the-above energy strategy.
Click here to
read the comments.