January 31, 2000

VIA FACSIMILE &
REGULAR MAIL

Federal Trade Commission
Office of the Secretary
600 Pennsylvania Avenue, N.W.,
Washington, D.C. 20580.

Re:  Consent Agreement in the Exxon Mobil Merger

Dear Sir/Madam:

By way of introduction, the Office of Advocacy of the U.S.
Small Business Administration (SBA) was established by
Congress under Pub. L. No. 94-305 to represent the views of
small business before federal agencies and Congress.  On
October 8, 1999, the Office of Advocacy submitted a letter
to the FTC expressing concerns about the potential long-term
effect of the numerous oil mergers on the various small
business sectors of the oil industry.  On November 30, 1999,
the Federal Trade Commission (FTC) issued a Complaint and a
proposed Consent Agreement for the merger of Exxon
Corporation (Exxon) and Mobil Corporation (Mobil).  The FTC
has requested comments on the proposal.

Although the proposed agreement provides provisions that
will be beneficial to several small businesses in the oil
industry, the Office of Advocacy is concerned about the lack
of a provision to assure the supply and transport of crude
oil for small refiners.  As the Office of Advocacy stated in
its letter on October 8th, if the small refiners are unable
to obtain crude at a reasonable price, they will be forced
out of the market.  If the small refiners exit the market
place, the large companies will have complete control over
petroleum prices for the independent non-affiliated gasoline
dealers, the home heating oil companies, the agricultural
diesel users, the concrete manufacturers, etc.  The end
result will be higher prices for the consumer.

Advocacy asserts that a simple provision requiring the
acquirer to provide a contract for access to transport and
supply of crude oil to small independent refiners would
remedy this situation and assure continued competition.
Such a provision will assure continued competition for all
levels of the oil industry

Thank you for allowing me to comment on this important
topic.  If you any questions, please feel free to contact
Jennifer Smith or me at (202) 205-6533.

Sincerely,

Jere W. Glover
Chief Counsel
Office of Advocacy

Jennifer A. Smith
Assistant Chief Counsel
 for Economic Regulation

cc:  Chairman Pitofsky