Stage II Vapor Recovery Update

SIP Steering Committee Meeting April 13, 2011

On-Board Vapor Recovery

• Clean Air Act (CAA) requires newer cars have an on-board vapor recovery system (ORVR); phased in for 1998 and newer vehicles

• CAA says EPA may eliminate requirement for states to maintain Stage II when EPA determines that ORVR is in “widespread use”

• EPA has not determined what level of ORVR fleet penetration constitutes “widespread use”

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Widespread Use (WSU) Guidance

• WSU guidance has been discussed for years; EPA is expected to issue a proposed rule by mid-2011

• Each state makes its own decision if and when to eliminate its Stage II program based on:– EPA’s WSU parameters– State’s vehicle fleet characteristics– Benefits/costs of keeping Stage II to capture vapors

from older vehicles that do not have ORVR– Dis-benefit of “incompatible” Stage II systems

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“Incompatible” Stage II Systems• 2 types of Stage II systems: vapor balance and

vacuum assist– Use of vacuum assist systems with ORVR-

equipped cars creates excess emissions ; more vapors are released than if there was just ORVR

– Results in an earlier “crossover year” - the year when Stage II is no longer getting air quality benefits

– MA has a substantial number of vacuum assist systems

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State Analysis

• MassDEP beginning analysis of Stage II for MA fleet in anticipation of EPA WSU proposal

• Requires analysis of: fleet characteristics; fleet turnover; % vacuum assist systems; use of an incompatibility “excess emission factor”

• Looking at potential for Stage I enhancements (also part of OTC control measures review)

• Evaluating Stage II decommissioning requirements

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EPA’s Partial Widespread Use Guidance

• 2006 - EPA issued WSU guidance for rental car facilities

• If rental facility certifies to the state that 95% of the vehicles refueling at its facility have ORVR, then WSU use is met

• States are free to amend their Stage II regulations and SIPs to incorporate an exemption for rental car facilities

• 2007 guidance – EPA extended policy to apply to other corporate/commercial fleets

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MassDEP Proposed Revisions to Stage II

• Massport requesting an exemption from Stage II for new Logan Airport rental car facility

• Consistent with EPA’s limited WSU guidance for fleets that can certify 95% of vehicles have ORVR

• MassDEP expects to propose regulation to exempt rental car, corporate/commercial fleets covered by EPA’s WSU guidance from Stage II

• Reviewing potential for Stage I enhancements as a condition of exemption

• Looking at decommissioning requirements for existing facilities

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