from: taylor henderson cc: joe
TRANSCRIPT
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From: Taylor Henderson <[email protected]>Sent: Friday, August 16, 2019 7:12 PMTo: Karin ManwaringCc: Joe Okpaku; Irene Koulouris; John Dunlap; Kevin McGeeSubject: Fwd: June & July 2019 Monthly Dispensing ReportsAttachments: Booster Monthly Dispensing Report - SCAQMD - JUNE 2019.pdf; Booster Fueling Locations and
Fueling Schedules - SCAQMD - AUGUST 2019.pdf
Karin,
Please find attached, Booster's current list of fueling locations and schedule of fueling within the SCAQMD. The attached fueling location/schedule list will be updated and re‐distributed to SCAQMD within 24 hours upon adding or revising a location and fueling schedule.
Have a great weekend.
Best, Taylor
‐‐‐‐‐‐‐‐‐‐ Forwarded message ‐‐‐‐‐‐‐‐‐ From: Taylor Henderson <[email protected]> Date: Fri, Aug 16, 2019 at 6:58 PM Subject: Re: June & July 2019 Monthly Dispensing Reports To: Han Tran <[email protected]> Cc: Kevin McGee <[email protected]>, [email protected] <[email protected]>, Irene Koulouris <[email protected]>, Kiersten Melville <[email protected]>, Rafael Reynosa <[email protected]>, Marian Coleman <[email protected]>, Randy Matsuyama <[email protected]>, John Dunlap <[email protected]>
Han,
Please find the attached monthly dispensing records per the original R&D permit requirements for the month of June 2019—along with the current list of Booster's fueling locations and schedule of fueling, as requested by Ms. Coleman under items D and F of the additional records request. As stated in our previous email above, the July report per the original R&D permit requirements is in the process of being completed and will be submitted by end of next week.
We will keep SCAQMD updated on our automation efforts for the records requested under items A, C, and E of the additional records request. Again, we look forward to our continued work together to revolutionize the fuel supply chain for the greater good of community and environment.
Best, Taylor
On Fri, Aug 16, 2019 at 10:32 AM Han Tran <[email protected]> wrote:
Good morning Taylor,
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Please submit the current vehicle record reports per the original R&D permit requirements for June & July now. Once the new automation is implemented in mid‐September, please re‐submit June & July records as well as August records per the new guidelines. Please let me know if you have any questions.
Thank you,
Han Tran
Supervising Air Quality Inspector
South Coast AQMD
Phone: (909) 396-2478
Fax: (909) 396-3015
Email: [email protected]
From: Taylor Henderson [mailto:[email protected]] Sent: Wednesday, August 14, 2019 4:42 PM To: Han Tran <[email protected]> Cc: Kevin McGee <[email protected]>; [email protected]; Irene Koulouris <[email protected]>; Kiersten Melville <[email protected]>; Rafael Reynosa <[email protected]>; Marian Coleman <[email protected]>; Randy Matsuyama <[email protected]>; John Dunlap <[email protected]> Subject: Re: June & July 2019 Monthly Dispensing Reports
Good Afternoon Han,
Thank you for your outreach. The 2019 Booster June and July monthly dispensing reports required under the current R&D permit requirements have been compiled and are nearly complete. The nearly complied records include what has been previously required per the R&D permits: make, model, year, VIN, quantity of fuel dispensed, and date of refueling per each transaction—along with total throughput and number of vehicles refueled per each MFOD unit. With
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these records now fully automated, we will have the June report submitted by the end of this week and the July report submitted by the end of next week.
As for the additional records requested by Deputy Executive Officer Coleman on 8/7/2019, Booster is still in the process of automating these additional record requests as the need for this information was just recently brought to Booster's attention. In order to do this, Booster will need to build out a new program, similar to what was done with the original report requirements, as mentioned by the Booster team at the July 25th meeting. Booster's current procedure to collect this information is very manual, therefore, the data currently available is subject to manual error due to no current automation in place. With this data now being required going forward, our team is working toward automating a system to ensure accuracy. That said, just as it took a substantial amount of time and resources to work out the bugs during automation of our vehicle records, automation of our inventory/mileage records will also be time‐intensive. Until we are fully automated, we have implemented new procedures to collect and audit this information to streamline the manual process. However, even these procedures will take time to fully develop due to the learning curve involved with the implementation of additional management processes. As it stands right now, compiling all of the additional records requested for June and July would take until Mid‐September at the earliest. That said, there are some items requested that we can immediately provide with our vehicle record report. I have outlined the current procedures, new procedures being developed, and expected timeline for each additional data request below.
A) Totalizing meter reading at the start and end of the day (calculate total gallons dispensed each day)
CURRENT PROCEDURE:
o Booster Service Professionals ("SPs") take pictures of the totalizer readings and upload to internal messaging service during the Pre and Post‐Trip inspections.
o Booster Manager/Lead required to manually record each totalizer reading for inventory reconciliation. o CURRENT ISSUES:
Human Error ‐ SPs uploads picture under the wrong MFOD unit, SPs forget to take pictures or upload on the wrong day, typos when manually inputting the reading.
NEW PROCEDURES BEING IMPLEMENTED:
o Booster Manager/Lead required to audit each Pre and Post‐Trip inspection daily to ensure SP did not forget to upload the totalizer pictures.
o Two‐step verification: SPs shall be required to record the Pre and Post‐Trip totalizer reading in a hand‐written log which will be cross‐referenced with the Pre and Post‐Trip totalizer reading photos. The cross‐reference shall be completed by Booster Manager/Lead.
o EXPECTED TIMELINE TO GET JUNE & JULY DATA TO SCAQMD: MID‐SEPTEMBER
AUTOMATION:
o Booster Product and Engineering ("P&E") team working to computerize each truck system, which will allow integration with each meter and automatically collect data on totalizer readings at the beginning and end of each shift.
o EXPECTED TIMELINE: End of Q3
B) Motor vehicle’s make, model, year, VIN, and total number of gallons fueled in each transaction
CURRENTLY FULLY AUTOMATED
o EXPECTED TIMELINE TO COMPILE:
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JUNE 2019: Submitted by August 16, 2019 JULY 2019: Submitted by August 23, 2019
C) Bill of Lading("BOL") for each MFOD’s loading
CURRENT PROCEDURES:
o SPs are required to keep all BOLs received during a shift stored in a designated folder on the truck. o At end of shift, each SP is required to transfer each BOL from the MFOD unit to a designated file in the
office. o Booster Manager/Lead keeps master record of all BOLs turned in. o CURRENT ISSUES:
SPs forget to transfer a BOL from the truck to the master file or gets misplaced. A BOL goes missing while in route to service (wasn't stored on the truck properly).
NEW PROCEDURES BEING IMPLEMENTED:
o Booster Manager/Lead will audit truck beginning and ending inventory with dispensing records for each truck upon the completion of each route to ensure all purchases have been accounted for with a BOL.
o EXPECTED TIMELINE TO GET JUNE & JULY DATA TO SCAQMD: MID‐SEPTEMBER
AUTOMATION:
o P&E team working to implement a system that will allow us to store BOL data digitally. o EXPECTED TIMELINE: Q3‐Q4
D) Fueling locations
CURRENTLY FULLY AUTOMATED AND AVAILABLE TO BE SUBMITTED WITH VEHICLE RECORD REPORTS
E) Starting and ending mileage for each MFOD (calculate total miles driven each day)
CURRENT PROCEDURES:
o SPs are required to input odometer readings into Booster's fleet management software platform during Pre and Post‐Trip inspections.
o Booster Manager/Lead required to monitor recorded mileage on the platform to track vehicle maintenance/inspections.
o CURRENT ISSUES:
Human Error‐ SPs manually inputs the wrong odometer reading (typos), SPs forgets to input the reading, fleet management software platform develops an internal bug.
NEW PROCEDURES BEING IMPLEMENTED:
o Booster Manager/Lead required to audit each Post‐Trip and Pre‐Trip inspection daily to ensure SP did not forget to input the Pre and Post‐trip odometer readings
o Two‐step verification: SPs are required to record the Pre and Post‐trip odometer reading in a hand‐written log to be cross‐referenced with the fleet management software. The cross‐reference shall be completed by Booster Manager/Lead.
o EXPECTED TIMELINE TO GET JUNE & JULY DATA TO SCAQMD: MID‐SEPTEMBER
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AUTOMATION:
o P&E working to computerize each truck system, which will allow integration with each odometer and automatically collect data at the beginning and end of each shift.Additionally, P&E team working to integrate Booster's fleet management software platform into an internal database for automated records rather than using the fleet management platform purely for vehicle maintenance/inspection purposes
o EXPECTED TIMELINE: Q3‐Q4
F) Schedule of Fueling – 24 hours prior to scheduled fueling
SCHEDULE OF FUELING LOCATIONS AVAILABLE TO BE SUBMITTED ALONG WITH LIST OF EACH FUELING LOCATION
o Any new locations added will be emailed to [email protected] within 24 hours as directed.
So we know how to move forward on both June and July 2019, please let us know what you prefer we do. We can 1) send the current vehicle record report per the original R&D permit requirements, which we can then have both reports submitted by the end of next week, or 2) wait until at least mid‐September and send you the June and July vehicle record reports with the additional information.
Please let us know if you have any additional questions regarding the above. We look forward to our continued work together to serve the community and clean the air that we breathe.
Best, Taylor
On Tue, Aug 13, 2019 at 4:56 PM Han Tran <[email protected]> wrote:
Good afternoon Taylor & Kevin,
Thank you for sending the February – May 2019 monthly dispensing reports. I wanted to check on the status of the June and July 2019 monthly dispensing reports and to see if the reports will meet all the requirements set forth in our Deputy Executive Officer Marian Coleman’s email on 8/7/2019. Please let me know if there are any issues obtaining the required records. I have listed the requirements below.
A) Totalizing meter reading at the start and end of the day (calculate total gallons dispensed each day)
B) Motor vehicle’s make, model, year, VIN, and total number of gallons fueled in each transaction
C) Bill of Lading for each MFOD’s loading
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D) Fueling locations
E) Starting and ending mileage for each MFOD (calculate total miles driven each day)
F) Schedule of Fueling – 24 hours prior to scheduled fueling (list of each MFOD fueling location should be provided by email to [email protected])
Thank you,
Han Tran
Supervising Air Quality Inspector
South Coast AQMD
Phone: (909) 396-2478
Fax: (909) 396-3015
Email: [email protected]
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To help protect you r priv acy, Microsoft Office prevented automatic download of this picture from the Internet.photo
Taylor Henderson Launch Partner + Public Policy Associate, Booster Fuels
(316) 213-9488 | [email protected]
| On CBS This Morning | Booster In Action!
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‐‐
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Taylor Henderson Launch Partner + Public Policy Associate, Booster Fuels (316) 213-9488 | [email protected]
| On CBS This Morning | Booster In Action! ‐‐
To help protect you r priv acy, Microsoft Office prevented automatic download of this picture from the Internet.photo
Taylor Henderson Launch Partner + Public Policy Associate, Booster Fuels (316) 213-9488 | [email protected]
| On CBS This Morning | Booster In Action!
1
From: Taylor Henderson <[email protected]>Sent: Friday, August 23, 2019 6:40 PMTo: Karin Manwaring; Han TranCc: kmelville; Rafael Reynosa; Marian Coleman; Randy Matsuyama; Joe Okpaku; Irene Koulouris; John
Dunlap; Kevin McGeeSubject: Re: June & July 2019 Monthly Dispensing ReportsAttachments: Booster Response Letter to SCAQMD Fleet Location Request.pdf; Booster Corporate Fleet Partner
Locations and Fueling Schedules - SCAQMD - AUGUST 2019.pdf; Booster Monthly Dispensing Report - SCAQMD - JULY 2019.pdf
Karin,
Please find the attached letter responding to your request for information on the two different types of services Booster provides, and under what approvals, within the SCAQMD. Also attached is the current list of all Booster’s Corporate Fleet partner locations within SCAQMD for both diesel and gasoline.
Additionally, I have attached our monthly dispensing records per the original R&D permit requirements for the month of July 2019.
If there are any additional questions, please do not hesitate to reach out. Look forward to our continued work together.
Best, Taylor
On Tue, Aug 20, 2019 at 5:06 PM Karin Manwaring <[email protected]> wrote:
Thank you for providing this, but I think there may be some confusion.
The request was for a list of where Booster is fueling and under what authority. As Joe and I discussed, the list should include city and permitting agencies. We are already aware of air permits from us and a special activity permit from OCFA to fuel at locations in Irvine.
1. Are you able to confirm that Irvine is the only city you are presently operating in, including both private and fleetvehicles?
2. Does the list you provided include both private and fleet vehicle customers?
If not, please provide us with information about where in the SCAQMD’s four county jurisdiction, and under what permits, Booster is fueling private or fleet vehicles, by the close of business Friday.
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Thank you,
Karin
From: Taylor Henderson [mailto:[email protected]] Sent: Friday, August 16, 2019 7:12 PM To: Karin Manwaring <[email protected]> Cc: Joe Okpaku <[email protected]>; Irene Koulouris <[email protected]>; John Dunlap <[email protected]>; Kevin McGee <[email protected]> Subject: Fwd: June & July 2019 Monthly Dispensing Reports
Karin,
Please find attached, Booster's current list of fueling locations and schedule of fueling within the SCAQMD. The attached fueling location/schedule list will be updated and re‐distributed to SCAQMD within 24 hours upon adding or revising a location and fueling schedule.
Have a great weekend.
Best,
Taylor
‐‐‐‐‐‐‐‐‐‐ Forwarded message ‐‐‐‐‐‐‐‐‐ From: Taylor Henderson <[email protected]> Date: Fri, Aug 16, 2019 at 6:58 PM Subject: Re: June & July 2019 Monthly Dispensing Reports To: Han Tran <[email protected]> Cc: Kevin McGee <[email protected]>, [email protected] <[email protected]>, Irene Koulouris <[email protected]>, Kiersten Melville <[email protected]>, Rafael Reynosa <[email protected]>, Marian Coleman <[email protected]>, Randy Matsuyama <[email protected]>, John Dunlap <[email protected]>
Han,
Please find the attached monthly dispensing records per the original R&D permit requirements for the month of June 2019—along with the current list of Booster's fueling locations and schedule of fueling, as requested by Ms. Coleman
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under items D and F of the additional records request. As stated in our previous email above, the July report per the original R&D permit requirements is in the process of being completed and will be submitted by end of next week.
We will keep SCAQMD updated on our automation efforts for the records requested under items A, C, and E of the additional records request. Again, we look forward to our continued work together to revolutionize the fuel supply chain for the greater good of community and environment.
Best,
Taylor
On Fri, Aug 16, 2019 at 10:32 AM Han Tran <[email protected]> wrote:
Good morning Taylor,
Please submit the current vehicle record reports per the original R&D permit requirements for June & July now. Once the new automation is implemented in mid‐September, please re‐submit June & July records as well as August records per the new guidelines. Please let me know if you have any questions.
Thank you,
Han Tran
Supervising Air Quality Inspector
South Coast AQMD
Phone: (909) 396-2478
Fax: (909) 396-3015
Email: [email protected]
4
From: Taylor Henderson [mailto:[email protected]] Sent: Wednesday, August 14, 2019 4:42 PM To: Han Tran <[email protected]> Cc: Kevin McGee <[email protected]>; [email protected]; Irene Koulouris <[email protected]>; Kiersten Melville <[email protected]>; Rafael Reynosa <[email protected]>; Marian Coleman <[email protected]>; Randy Matsuyama <[email protected]>; John Dunlap <[email protected]> Subject: Re: June & July 2019 Monthly Dispensing Reports
Good Afternoon Han,
Thank you for your outreach. The 2019 Booster June and July monthly dispensing reports required under the current R&D permit requirements have been compiled and are nearly complete. The nearly complied records include what has been previously required per the R&D permits: make, model, year, VIN, quantity of fuel dispensed, and date of refueling per each transaction—along with total throughput and number of vehicles refueled per each MFOD unit. With these records now fully automated, we will have the June report submitted by the end of this week and the July report submitted by the end of next week.
As for the additional records requested by Deputy Executive Officer Coleman on 8/7/2019, Booster is still in the process of automating these additional record requests as the need for this information was just recently brought to Booster's attention. In order to do this, Booster will need to build out a new program, similar to what was done with the original report requirements, as mentioned by the Booster team at the July 25th meeting. Booster's current procedure to collect this information is very manual, therefore, the data currently available is subject to manual error due to no current automation in place. With this data now being required going forward, our team is working toward automating a system to ensure accuracy. That said, just as it took a substantial amount of time and resources to work out the bugs during automation of our vehicle records, automation of our inventory/mileage records will also be time‐intensive. Until we are fully automated, we have implemented new procedures to collect and audit this information to streamline the manual process. However, even these procedures will take time to fully develop due to the learning curve involved with the implementation of additional management processes. As it stands right now, compiling all of the additional records requested for June and July would take until Mid‐September at the earliest. That said, there are some items requested that we can immediately provide with our vehicle record report. I have outlined the current procedures, new procedures being developed, and expected timeline for each additional data request below.
A) Totalizing meter reading at the start and end of the day (calculate total gallons dispensed each day)
CURRENT PROCEDURE:
o Booster Service Professionals ("SPs") take pictures of the totalizer readings and upload to internal messaging service during the Pre and Post‐Trip inspections.
o Booster Manager/Lead required to manually record each totalizer reading for inventory reconciliation. o CURRENT ISSUES:
Human Error ‐ SPs uploads picture under the wrong MFOD unit, SPs forget to take pictures or upload on the wrong day, typos when manually inputting the reading.
NEW PROCEDURES BEING IMPLEMENTED:
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o Booster Manager/Lead required to audit each Pre and Post‐Trip inspection daily to ensure SP did not forget to upload the totalizer pictures.
o Two‐step verification: SPs shall be required to record the Pre and Post‐Trip totalizer reading in a hand‐written log which will be cross‐referenced with the Pre and Post‐Trip totalizer reading photos. The cross‐reference shall be completed by Booster Manager/Lead.
o EXPECTED TIMELINE TO GET JUNE & JULY DATA TO SCAQMD: MID‐SEPTEMBER
AUTOMATION:
o Booster Product and Engineering ("P&E") team working to computerize each truck system, which will allow integration with each meter and automatically collect data on totalizer readings at the beginning and end of each shift.
o EXPECTED TIMELINE: End of Q3
B) Motor vehicle’s make, model, year, VIN, and total number of gallons fueled in each transaction
CURRENTLY FULLY AUTOMATED
o EXPECTED TIMELINE TO COMPILE:
JUNE 2019: Submitted by August 16, 2019 JULY 2019: Submitted by August 23, 2019
C) Bill of Lading("BOL") for each MFOD’s loading
CURRENT PROCEDURES:
o SPs are required to keep all BOLs received during a shift stored in a designated folder on the truck. o At end of shift, each SP is required to transfer each BOL from the MFOD unit to a designated file in the
office. o Booster Manager/Lead keeps master record of all BOLs turned in. o CURRENT ISSUES:
SPs forget to transfer a BOL from the truck to the master file or gets misplaced. A BOL goes missing while in route to service (wasn't stored on the truck properly).
NEW PROCEDURES BEING IMPLEMENTED:
o Booster Manager/Lead will audit truck beginning and ending inventory with dispensing records for each truck upon the completion of each route to ensure all purchases have been accounted for with a BOL.
o EXPECTED TIMELINE TO GET JUNE & JULY DATA TO SCAQMD: MID‐SEPTEMBER
AUTOMATION:
o P&E team working to implement a system that will allow us to store BOL data digitally. o EXPECTED TIMELINE: Q3‐Q4
D) Fueling locations
CURRENTLY FULLY AUTOMATED AND AVAILABLE TO BE SUBMITTED WITH VEHICLE RECORD REPORTS
E) Starting and ending mileage for each MFOD (calculate total miles driven each day)
6
CURRENT PROCEDURES:
o SPs are required to input odometer readings into Booster's fleet management software platform during Pre and Post‐Trip inspections.
o Booster Manager/Lead required to monitor recorded mileage on the platform to track vehicle maintenance/inspections.
o CURRENT ISSUES:
Human Error‐ SPs manually inputs the wrong odometer reading (typos), SPs forgets to input the reading, fleet management software platform develops an internal bug.
NEW PROCEDURES BEING IMPLEMENTED:
o Booster Manager/Lead required to audit each Post‐Trip and Pre‐Trip inspection daily to ensure SP did not forget to input the Pre and Post‐trip odometer readings
o Two‐step verification: SPs are required to record the Pre and Post‐trip odometer reading in a hand‐written log to be cross‐referenced with the fleet management software. The cross‐reference shall be completed by Booster Manager/Lead.
o EXPECTED TIMELINE TO GET JUNE & JULY DATA TO SCAQMD: MID‐SEPTEMBER
AUTOMATION:
o P&E working to computerize each truck system, which will allow integration with each odometer and automatically collect data at the beginning and end of each shift.Additionally, P&E team working to integrate Booster's fleet management software platform into an internal database for automated records rather than using the fleet management platform purely for vehicle maintenance/inspection purposes
o EXPECTED TIMELINE: Q3‐Q4
F) Schedule of Fueling – 24 hours prior to scheduled fueling
SCHEDULE OF FUELING LOCATIONS AVAILABLE TO BE SUBMITTED ALONG WITH LIST OF EACH FUELING LOCATION
o Any new locations added will be emailed to [email protected] within 24 hours as directed.
So we know how to move forward on both June and July 2019, please let us know what you prefer we do. We can 1) send the current vehicle record report per the original R&D permit requirements, which we can then have both reports submitted by the end of next week, or 2) wait until at least mid‐September and send you the June and July vehicle record reports with the additional information.
Please let us know if you have any additional questions regarding the above. We look forward to our continued work together to serve the community and clean the air that we breathe.
Best, Taylor
On Tue, Aug 13, 2019 at 4:56 PM Han Tran <[email protected]> wrote:
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Good afternoon Taylor & Kevin,
Thank you for sending the February – May 2019 monthly dispensing reports. I wanted to check on the status of the June and July 2019 monthly dispensing reports and to see if the reports will meet all the requirements set forth in our Deputy Executive Officer Marian Coleman’s email on 8/7/2019. Please let me know if there are any issues obtaining the required records. I have listed the requirements below.
A) Totalizing meter reading at the start and end of the day (calculate total gallons dispensed each day)
B) Motor vehicle’s make, model, year, VIN, and total number of gallons fueled in each transaction
C) Bill of Lading for each MFOD’s loading
D) Fueling locations
E) Starting and ending mileage for each MFOD (calculate total miles driven each day)
F) Schedule of Fueling – 24 hours prior to scheduled fueling (list of each MFOD fueling location should be provided by email to [email protected])
Thank you,
Han Tran
Supervising Air Quality Inspector
South Coast AQMD
Phone: (909) 396-2478
Fax: (909) 396-3015
Email: [email protected]
8
‐‐
Taylor Henderson Launch Partner + Public Policy Associate, Booster Fuels
(316) 213-9488 | [email protected]
| On CBS This Morning | Booster In Action!
‐‐
Taylor Henderson Launch Partner + Public Policy Associate, Booster Fuels
(316) 213-9488 | [email protected]
| On CBS This Morning | Booster In Action!
‐‐
Taylor Henderson Launch Partner + Public Policy Associate, Booster Fuels
(316) 213-9488 | [email protected]
| On CBS This Morning | Booster In Action!
‐‐
9
To help protect you r priv acy, Microsoft Office prevented automatic download of this picture from the Internet.photo
Taylor Henderson Launch Partner + Public Policy Associate, Booster Fuels (316) 213-9488 | [email protected]
| On CBS This Morning | Booster In Action!
Booster Fuels, Inc. 1840 Gateway Drive
Suite 200 San Mateo, CA 94404
August 23, 2019 Ms. Karin Manwaring Senior Deputy District Council South Coast Air Quality Management District 21865 Copley Drive Diamond Bar, CA 91765 RE: BOOSTER FUELING LOCATIONS AND APPROVALS Ms. Manwaring: We apologize for any confusion related to our submittal of Booster’s fueling locations on August 19, 2019. Booster is broken down into two different types of service: (1) Consumer Campus, and (2) Corporate Fleet. Each differ substantially in terms of operation and how they are regulated. On the Consumer Campus side, Booster delivers gasoline to corporate employees on privately owned commercial parking lots as an on-site amenity. This transaction occurs directly between the private consumer and Booster as a mobile retail service station. This service is the most responsible version of the new and growing industry of “On-Demand” Mobile Fueling being studied by various regulatory agencies across the nation. The fueling locations provided to SCAQMD on August 19 is the current list of all Consumer Campus fueling locations Booster services within SCAQMD. Each of these campuses are within the City of Irvine and have been approved for consumer fueling by Orange County Fire Authority. As for the Corporate Fleet side, Booster partners with corporations to provide an on-site fuel platform they can use to fuel their wholly-owned fleet of vehicles as an alternative to installing on-site storage tanks. This is the traditional fuel delivery service that has existed for decades. This is regulated by established State standards such as California Fire Code, Sections 5706 and 5707, the latter of which Booster worked to develop in coordination with Cal Fire. Approval here is most often governed under industry-set standards due to the non-retail nature between the service provider and fleet businesses, the predictable and already tested environment of fleet fueling, and the industrial zoned areas where fleet fueling typically occurs. The list of fueling locations provided to SCAQMD did not include Corporate Fleet locations that have partnered with Booster throughout SCAQMD due to the non-retail nature of the service. Per your request, I have included the list of all Booster’s Corporate Fleet partner locations within SCAQMD for both diesel and gasoline. The gasoline vehicles in these fleet accounts have been included in all of our ORVR records that we have previously provided to the District. Please let us know if you have any questions, and we look forward to our continued work together to improve community and environment. Sincerely,
-1-
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From: Cole, Bradley@ARB <[email protected]> Sent: Tuesday, March 3, 2020 10:38 AM To: Kiersten Melville <[email protected]> Cc: Han Tran <[email protected]>; Randy Matsuyama <[email protected]> Subject: Booster R&D (CARB) Kiersten, Per our conversation via email this morning I want to clarify CARB’s issuance of R&D permits for the original 5 units in the SCAQMD. The R&D designation allows the uncertified equipment to operate in California while CARB is testing and/or drafting the EO. CARB’s issuance of the R&D status does not preclude the SCAQMD from denying permits in the district. CARB does not need any additional data from Booster to move forward on the EO as the compliance methods, namely ORVR fleet percentages (100% in SCAQMD), need to satisfy the districts once an EO is issued and the system is certified. The EO issued by CARB will only call out restrictions present in state statutes, all other restrictions will be rooted in local district rules and regulations. Please let me know if this helps address Booster’s claim that I directed them to request an R&D permit from the SCAQMD in order to provide CARB with additional data, this is unequivocally false. Thank you, Brad
Bradley Cole Air Resources Supervisor I Vapor Recovery Certification Section Monitoring and Laboratory Division 916.322.8959 [email protected]