THE LETTERS

摘要

This responds to your May 12, 2008 letter requesting clarification on the registration requirements in 49 CFR Part 107, Subpart G. Specifically, you ask if you must register and pay a registration fee. According to your letter, you are a gas distributor for Sinclair. Your dealers order fuel, which is delivered to them by Sinclair in Sinclair's trucks. The gas delivery is billed to you and you collect payment from the dealers. You do not own gas stations nor do you operate the motor vehicles that deliver gas. In accordance with 49 CFR 107.601, shippers and carriers of certain quantities of hazardous materials must register with the Pipeline and Hazardous Materials Safety Administration and pay a registration fee. Because you are neither a shipper nor a carrier, based on the information provided in your letter, it is the opinion of this Office that you are not subject to the registration requirements.