
PIPELINE PUNKS · INTELLIGENCE SERIES
Action Summary
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From the Compliance Deadline Radar, October 20, 2026 (PP-RADAR-2026-10-20)
For small and midsize U.S. petroleum distributors: bulk fuel, tank wagon, cardlock, transport, lubricants and propane.
PP-ACTION-2026-10-20 | Revision 1
1. PRIORITY 1 | DUE TODAY, OCT 20, AND OCT 26: File state fuel returns.
Nebraska: Form 73 for September (electronic) and Form 74 for Q3; initiate EFT payment by 5:00 p.m. CT today. Form 73 is required even with no activity. Nebraska rate through Dec 31: $0.3180/gal.
Colorado: September distributor, terminal and carrier returns due Oct 26 at ERS $0.0125/gal. Starting with October volumes, ERS drops to $0.0094/gal (listed as 0.009375); update billing and ERP rate tables now.
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2. PRIORITY 2 | DUE OCT 24: Wind down EPA waiver diesel in Texas and Arctic Alaska.
The Texas waiver (up to 500 ppm diesel for pre-2007 highway and Tier 1-3 nonroad engines only) and the Arctic Alaska diesel waiver expire Oct 24. No renewal was posted at verification. Stop introducing waiver fuel unless EPA renews; volume certified or in the pipeline before expiration may be sold through. Keep it segregated and labeled.
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3. PRIORITY 3 | DUE OCT 29 AND NOV 2: Federal excise deposit and quarterly filings.
Oct 29: semimonthly deposit for Oct 1-15. Nov 2: Form 720 for Q3, Forms 720-TO and 720-CS for September, and Q3 IFTA. Federal rates including the $0.0010/gal LUST tax: gasoline $0.1840/gal, diesel and kerosene $0.2440/gal. Dyed-diesel penalty relief (Oct 1-Dec 31) does not defer section 4081 tax, and IRS has not yet issued its payment-postponement or Form 720 guidance. Keep reporting unchanged until it does.
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4. PRIORITY 4 | DUE NOV 20 AND DEC 16: Fleet and workplace safety.
OSHA HazCom 2024 employer compliance date for substances is Nov 20: update labels, the written program and training from revised SDSs for single-substance products such as propane. The FMCSA HOS waiver for gasoline and diesel haulers ends Dec 16 at 11:59 p.m.; check logs now against its limits (no more than 16 hours driving in 24; 6 consecutive sleeper-berth or 8 consecutive off-duty hours each 24) and the rule to report crashes to MCPSD@DOT.GOV within 2 business days. Confirm your ELD is not on FMCSA's revoked list.
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5. PRIORITY 5 | DUE OCT 28, NOV 12, DEC 4: Decide on comments (terminals, bulk plants, obligated parties).
EPA Gasoline Distribution NESHAP and NSPS XXa reconsideration: comments due Nov 12 (paperwork comments to OMB Oct 28). EPA RFS proposal adding 770 million RINs to 2026 and 2027 small refinery reallocation: register by Oct 28 for the Nov 4 virtual hearing; comments due Dec 4.
Sources
- https://www.federalregister.gov/documents/2026/09/28/2026-19774/national-emission-standards-for-hazardous-air-pollutants-for-gasoline-distribution-facilities-and
- https://www.federalregister.gov/documents/2026/10/16/2026-21155/renewable-fuel-standard-rfs-program-reallocation-of-additional-2025-small-refinery-exemptions
Not legal advice; confirm applicability with counsel or the issuing agency.
Full radar with every dated item through Jan 18, 2027: https://www.pipelinepunks.com/briefs/radar/2026-10-20/r1
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