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enclosed is the widespread use analysis

Duane Yantorno

to:

Jefferson Wehling, Joanne Wells

10/25/2010 01:27 PM

Cc:

“Martinkovic.Deborrah”, Jeffrey Buss, Wienke Tax

Show Details

Jeff and Joanne,

Enclosed is the clean copy of the widespread use analysis we conducted for E85 you have the report and the supporting documentation. I am still working to look for the documentation on the Racing event and proving ground stuff.

Duane M. Yantorno

Director

Transportation Fuels and Air Quality Programs

Phone (602) 771-4933

Fax (623) 939-7825

Cellular (602) 920-4218
Widespread Use Analysis for E85 Stage II Waiver Request

December 5, 2008

On December 12, 2006 the Environmental Protection Agency (EPA) issued a letter on widespread use of Onboard Vapor Recovery Systems (ORVR). EPA said it believed that Flex-Fuel vehicles, being relatively new, would include ORVR, and therefore should not be required to comply with Stage II requirements. The letter also suggested that a State could submit an analysis to EPA and request a waiver of stage II requirements for E85 dispensers.

This analysis is intended to serve as Arizona’s request for such a waiver for E85 dispensers in Area A, based on data showing that a majority of Flex-Fuel vehicles operating in the Phoenix Metropolitan Area are equipped with Onboard Vapor Recovery Systems (ORVR).

Issue:

Given the rising price differential between ethanol and gasoline, more motorists

are looking for alternatives to conventional fuel. In addition many automakers have responded by increasing the number of Flex-Fuel vehicles they produce. As a result of both trends, a growing number of consumers are looking to use E85 instead of traditional fuels.

E85 consumption has risen sharply throughout Arizona, especially in the southern portion of the state, where efforts by the Clean Cities Coordinator for the City of Tucson have encouraged its use.

Stage Il emissions controls are mandated in Area A, which includes the Phoenix Metropolitan Area, as a control measure for VOC. The State of Arizona would like to encourage the use of E85 in area A, but this is difficult, given the lack of a certified stage II system for E85.

Currently E85 stage Il systems are balance systems. This adds to the cost of developing an alternative fuels infrastructure, since it restricts the development of the market. The California Air Resources Board (CARB) has made an effort to certify stage II equipment bUt manufacturers currently are unwilling to submit a complete system for certification.

Background:

Th

A
The MVD database included VIN numbers, Year, Make, Model and Zip Code for

all vehicles registered in Arizona. Using information provided by the Ethanol

Vehicle Coalition and Auto manufactures, the data base was sorted as follows:

• First by zip code to isolate vehicles registered in area

A

• Then by the make and model of these vehicles.• Using the VIN number and information provided by the Ethanol Vehicle

Coalition, the data were then sorted by the

8th character in the VIN number

to identify Flex-Fuel vehicles.

The analysis was conducted to quantify the number of Flex-Fuel vehicles within

area A, and the number of Flex-Fuel vehicles that do not have ORVR.

A

conservative approach was taken to use the cutoff dates the EPA used for

requiring ORVR. The portion of Flex-Fuel vehicle without ORVR will be the

group generating VOC Emission when fueling.

Data Issues:The following issues were encountered:

• MVD Data entry is inconsistent. In many cases different abbreviations

apparently were used to enter the vehicle model.

• Zip codes did not always match the county. Thus the data included 10,847

Null values in the zip code data base.

• The key used to identify Flex-Fuel vehicles was not always correct.

• The volume of the data was overwhelming.

Analysis:

The initial data base included 4,611,827 vehicles in the state. The initial data sort

by zip codes narrowed the database to 2,693,847 vehicles registered in Area A.

The next data sort looked at vehicles built after 1998, which reduced the number

of vehicles to 2,058,824.

The data were then sorted by make and model, resulting in

a data set that

included 398,014 vehicles with

a NULL value in the model field.

In an effort to identify these 398,014 vehicles, the Department used VIN

numbers, along with information supplied by the National Ethanol VehiclesCoalition and EPA data, Dated February 28, 2008, to identify the specific Flex

Fuel models.
The next step was to identify which of the 66,231 Flex-Fuel vehicles were equipped with ORVR. The EPA schedule for fleet conversion requires all light- duty vehicles to come equipped with ORVR by the 2000 model year, and all light duty trucks were required to have QRVR by the 2003 model year. Table I below lays out the percentage of vehicles that must have ORVR, based on these EPA mandates.

Table I

Phase-in Schedule

For ORVR by Vehicle Class for overall Fleet

Vehicle Class 40% 80% 100%

• Light Duty Vehicles 1998 1999 2000

• Light Duty Trucks 2001 2002 2003

Using the phase-in schedule for light duty trucks, the analysis found the data presented in table 2 below:

Table 2

Breakdown of Area A FFV Fleet,

ORVR and Non-ORVR vehicles

Vehicle Total Number of Number of % Of Total of % Of Total of Type Number of vehicles Vehicles with Class Without Class With

Vehicles in without ORVR ORVR ORVR

Class ORVR

Light Duty

Vehicle 11,090 18 11,072 <1% 99% Light Duty

Trucks 55,141 8,604 46,537 16% 84%Total for 66,231 8,622 57,609 13% 87% Fleet

As this table shows, 13% of the Flex-Fuel fleet does not have ORVR. The majority, 99%, are light-duty trucks.
vehicles without ORVR will obtain gasoline at

a station that does dispense E85

but does have

a stage II system.

This analysis assumes that Flex-Fuel vehicles will need refueling at

a lower rate

than vehicles without QRVR. Thus, if 13% of Flex-Fuel vehicles do not have

ORVR, emissions from this cadre of Flex-Fuel vehicles appear to be small.

Going forward, E85 fueling location will continue to be

a small portion of the total

number of stations within Area A, which will restrict the public’s ability to obtain

E85. Currently there is

a high level of demand for E85 from State, city, county

and private sector fleets. In general these fleets are comprised of newer-model

vehicles that are equipped with ORVR.

The EPA letter of December 12 states that EPA believes that these fleets will

have minimum impact on emissions and would not require stage II.